20140930Coughlin Direct.pdf

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BEFORE THE IDAHO PUBLIC UTILITTES COMMISSION
IN THE MATTER OF TIIE JOINT )
PETTUON OF AVISTA CORPORATION, )
IDAHO POWER COMPAI.IY AND ) CASE NO. GNR-U-14-01
ROCKY MOIJNTAIN POWER COMPAI\IY )
FOR AN EXEMPTION FROM UTILITY )
cusToMER RELATIONS RULE 3l l(4) )and(S). )
)
ROCKY MOUNTAIN POWER
DIRECT TESTIMONY
OF
BARBARA COUGIILIN
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a.Please state your name, business address and position with PacifiCorp dba Rocky Mountain
Power (the "Company" or *RMP").
My name is Barbara Coughlin. My business address is 825 N.E. Multnomah, Suite 800, Portland,
Oregon 97232. My present position is Director, Customer & Regulatory Liaison in the Customer
Services Department.
Briefly describe your educational and professional background.
I have worked in the gas and electric utility industry since 1978. I received a Legal Assistant
Certificate from Marycrest College in 1991. From 1978 to 1997,I held various positions of
increasing levels of responsibility within the legal/regulatory department of Iowa-Illinois Gas and
Electric, a predecessor company to MidAmerican Energy Company. In 1997 ,I was promoted to
a customer services supervisor and in 1999 was promoted to customer services manager at
MidAmerican Energy Company. I worked as manager of regulatory projects at PacifiCorp from
2006 through 2008, when I was promoted to my current position of Director of Customer &
Regulatory Liaison.
Have you previously appeared as a witness for the Company?
Yes. I have testified in proceedings in the states of Washington, Oregon, Idaho, Utah, and
Wyoming.
What is the purpose of your testimony in this case?
Rocky Mountain Power is among the utilities filing a joint petition for an exemption from Utility
Customer Relations Rules 311 (a) and (5). Specifically, UCRR 311 (4) and (5) state:
04. Opportunity to Prevent Termination of Service.
Immediately preceding terrnination of service, the employee designated to
terminate service shall identiff himself or herself to the customer or other
responsible adult upon the premises and shall announce the purpose of the
employee's presence. This employee shall have in his or her possession
the past due account record ofthe customer and shall request any available
verification that the outstanding bills are satisfied or currently in dispute
before this Commission. Upon presentation of evidence that outstanding
bills are satisfied or currently in dispute before this Commission, service
Coughlin, D[ I
Rocky Mountain Power
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shall not be terrrinated. The employee shall be authorized to accept
full payment, or, at the discretion of the utility, partial payment, and in
such case shall not terminate service. Nothing in this rule prevents a
utility from proceeding with termination of service if the customer or
other responsible adult is not on the premises.
05. Notice of Procedure for Reconnecting Service. The utility
employee designated to terminate service shall give to the customer or
leave in a conspicuous location at the affected service address, a notice
showing the time of and grounds for termination, steps to be taken to
secure reconnection, and the telephone numbers of utility personnel or
other authorized representatives who are available to authorize
reconnection.
My testimony outlines the Company's interest in receiving an exemption to UCRR 311 (4) and
(5) to address RMP's ever-increasing safety concerns, impacts of the proposed change to the
Company's customers, anticipated impacts to the company, availability of numerous payment
options, and review of the disconnect notifications customers receive. Also included is the
Company's experience after the process was changed in other states in which it serves, and its
plan to communicate the change in practice if an exemption is granted.
Background
a. What is the Company's current practice when disconnecting a customer for nonpayment of
their electric bill?
A. The Company considers disconnection of electric service as a last resort. However, when it is
necessary to disconnect a customer's service for nonpayment of the bill, following numerous
mandatory and courtesy notifications of the due date of the customer's final notice, a field
metering specialist is dispatched to the site to collect payment or disconnect service. Once at the
site the specialist makes an attempt to speak with the customer or responsible adult at the site by
knocking on the door. If there is no answer at the door, or payment or a payment arrangement
cannot be made, the specialist leaves the door hanger and proceeds to disconnect the service. [f
the customer makes payment (in an amount sufficient to void the disconnection order), the
Coughlin, DI 2
Rocky Mountain Power
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service is left on and a $20 field service collection charge as authorized in the Company's
Schedule 300 is added to the customer's next billing statement.
Does the Company have the ability to remotely disconnect service using an Advanced
Metering Infrastructure (6'AMI") technology?
No, not at this time. RMP's meters in Idaho are a mix of electro mechanical, digital, and radio
frequency (one-way communication) meters, with none having remote disconnection capability.
Does the Company have plans to install AMI technology in ldaho?
No, not at this time. However, the Company continually evaluates the options and business case
and will bring to this Commission for discussion at such time as the Company determines it is
feasible and cost-effective for its Idaho customers.
If a customer makes a payment at the time of the disconnection site visit, how does the field
metering specialist process that payment?
The field metering specialist provides the customer a hand written receipt for the payment and
makes an entry into their work management system via a laptop computer. This entry into the
work management system indicates how the order was completed (service disconnected or
service left on) and the amount of any payment made. The field metering specialists ythe
payments in a locked vehicle until a deposit is made at a pay station at the end of their shift.
Payment information is updated in the Company's customer information system within thirty
minutes of the payment processing at the pay station.
With an exemption from UCRR 311 (4) and (5), what change is the Company proposing to
make?
When it is necessary to disconnect a customer's service for nonpayment of their bill, following
the due date and numerous notifications discussed later in my testimony, a field metering
specialist will be dispatched to the site to disconnect service. Once at the site, the field metering
specialist will leave a door hanger with the required reconnection information and then proceed to
disconnect the service.
Coughlin, DI 3
Rocky Mountain Power
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a. If the customer is home at the time and indicates they will pay the bill, will the field
metering specialist accept payment?
A. No. Once this new practice is implemented the field metering specialist will no longer accept any
payments. The field metering specialist at their discretion may offer the customer the opportunity
to make a telephone, internet or pay station payment and delay the disconnection for a few
minutes or hours to allow the customer to do so. Additionally, the field metering specialists
always have the discretion to delay or void a disconnection if they are made aware or observe a
situation where they believe disconnection of service will be harmful to a resident at the site.
Safety and Security for Employees and Customers
a. Why is the Company proposing to stop knocking at the door and accepting payments at the
time of disconnection of service?
A. The Company's interest in seeking an exemption to allow this proposed change in its practices
was heightened by a disturbing incident that took place on June 26, 2012, in Mississippi. A
collector with East Mississippi Electric Power Association went to a customer's premise to
disconnect service. The collector was later found dead, having been beaten by a shovel and shot
in the back.
As a result of this incident, Rocky Mountain Power re-evaluated existing Company safety
policies for its field personnel. Fortunately, the Company has not experienced a tragic incident
such as the one in Mississippi. However, based on the Company's monitoring these types of
incidents across the nation as well as the threats and incidents reported by its personnel indicates
the number and severity of threats or incidents have increased from year to year.
Does Rocky Mountain Power or PacifiCorp have record of any physical altercations within
its service territory?
Yes, PacifiCorp recorded thirteen physical incidents n 2012 and 2013. Of the thirteen physical
incidents, one involved a customer spitting on an employee and then slamming the Company
truck door on the employee's leg, one involved a pitbull attack, one involving a customer
Coughlin, DI 4
Rocky Mountain Power
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attempting to engage the employee in a fist fight, one was an unspecified physical attack on a
meter reader, one involved a customer turning a hose on an employee driving a vehicle and then
spitting on the employee and eight involved a customer brandishing their firearm. Four incidents
in particular noted the customer pointed the firearm directly at the employee.
Currently in Idaho, the Company has nine sites where aggressive customer behavior has
been documented and three additional sites where police escort is required. These are sites where
it is known we must use an abundance of caution. Unfortunately, unlawful and harmful behavior
does not always come with a warning.
Does the current rule, which requires an attempt to make face-to-face contact and collection
of payment at the premises, present safety concerns?
Yes. As I just noted customer confrontation and threats continue to increase and escalate.
Additionally, multiple governmental agencies have researched workplace violence and provided
useful information and statistics regarding workplace violence, including identification of factors
leading to higher risk of violence to occur. Some notable risks were associated with employees
dealing with the public and exchange of money with the public.
Field employees who carry money or collect money from customers have the potential to
experience a hostile interaction leading to injury, or even worse, death. Field employees who are
known to carry money in their vehicle are inherently at risk for being attacked and robbed as they
travel their daily route.
Does eliminating the practice of face-to-face contact with the customer and/or and collecting
payment at the premise at the disconnection visit reduce the risk of harm for employees,
customers, and the general public?
Yes. The Company is aware that stopping collecting payment and stopping knocking at the door
during a disconnection visit will not remove all risk, but it is a pro-active approach towards
minimizing the risk and providing a safer workplace. Injuries or death to employees should not
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Rocky Mountain Power
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be an accepted cost of doing business, nor should it be the inevitable result of one's chosen
occupation.
Are the Company's concerns limited to the risk of harm to the employees while at a
customer's site during a disconnection?
No. The Company has had experience with the field metering specialists being robbed. Not
only is it a concern for the physical well-being of the employee, but potentially the public that
maybe nearby at the time of an incident. Additionally, there is concern for the personal banking
information on a customer's check that may be stolen and fraudulently used.
PacifiCorp operates as Pacific Power in Oregon, Washington, California, rnd as Rocky
Mountain Power in Utah, Idaho, and Wyoming. Has PacifiCorp changed its field collection
practices in any ofits service territories as a result ofsafety concerns?
Yes, the Company has stopped making personal contact and collecting payment in the field at the
time of the disconnection visit in the states of Wyoming, Utah, California and Oregon. This was
implemented in Utah in October 2012, followed by Wyoming, California and most recently
implemented in Oregon in May 2014.
Did the Company conduct any surveys or poll other utilities regarding their collections
practices?
Prior to this change in practice the Company conducted an informal survey of utilities through
members of the National Association of Credit Managers. PacifiCorp received many responses
from various utilities across the United States and Canada. Based on the information gathered
from the responses, more than half of the utilities did not knock on the door prior to disconnecting
service and near 75 percent of the utilities did not collect payment. The results of this survey were
provided as Attachment I to the Utilities' Petition for exemption to UCRR 311 (4) and (5).
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Rocky Mountain Power
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Payment Alternatives and Noticing
a. You previously stated a customer making a payment at the site at the time of the
disconnection is charged a $20 fee. How does that compare with the costs of other payment
alternative available to customers?
A. Customers choosing to make their payment at the time of the disconnection are utilizing the most
expensive method to pay their electric bill. The customer's cost for making payment other than at
the time of the disconnection visit range from S0 to S1.95. If the customer waits until the field
metering specialist is at their home to disconnect services the customer is charged a $20 field
service collection charge.
a. Without the option to pay a Company representative at the door, will customers be
hampered in their ability to make payments on their account?
A. No, not at all. Over the past decade, new payment methods have been made available to
customers. In addition to the traditional methods of paying by check through the United
States mail or at pay stations, the Company offers customers the option of automatic payment
from their checking or savings accounts, pay online, and pay by phone. With these electronic
payment methods, customers can quickly pay for utility service or remedy past due amounts and
the customer's accounts are updated almost instantaneously. All of these options are either no- or
low-cost to the customer and are utilized by 63 percent of our customers in our six states.
How many customers utilize the option to pay the field metering specialist at the time of the
field visit?
In 2013, 1051 payments were collected by field metering specialists in ldaho. Of these 1051
payments, this represented a total of 516 distinct customers making payment. This is less than
one percent of the total customer population in Idaho utilizing this payment option. Of those 516
customers, 27 were known to be a certified as a low-income customer.
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Rocky Mountain Power
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1 Q. \ilould you please summarize the payment options available to all customers?
2 A. Yes, the options are as follows:
3 Automatic payments through the customer's bank - no fee
4 Online payment through Company website - no fee
5 U.S. Mail - $0.49 stamp
6 Pay stations - $1 fee (pay stations will increase their fee to $1.50 in 2015)
7 Pay-by-telephone, $1.95 fee (reduced from $2.80 in September 2013)
89 Notification Prior to Disconnection
10 a. If an exemption is granted, is there any concern that customers won't be provided with
LL adequate notice of disconnection prior to the disconnection site visit?
L2 A. No. Disconnecting electric service for non-payment is always a utility's last resort. Rocky
13 Mountain Power already provides customers with multiple notifications of account balances and
L4 potential disconnection of service. Specifically, the Company provides the following before a
15 site visit to disconnect service:
L6 1. Monthly bill (mandatory)
L7 2. 7 Day Notice (past due notice) (mandatory)
18 3. 3 Day Notice (final written notice) (courtesy)
19 4. Outbound phone call (mandatory)20 5. Door hanger at site 48 hours prior to date ofdisconnection (courtesy)
2t22 As illustrated above, this billing and collection process provides customers with numerous
23 notifications using various communication methods prior to the disconnection visit, giving ample
24 time to arrange for a payment to be made prior to the Company visiting the site. Including the
25 initial bill, the Company makes a minimum of five (5) notification attempts prior to disconnection
26 for any billed charge.
27 Company Experience and Communication
28 a. How well did customers accept this change in practice in Utah, Wyoming, California, and
29 Oregon?
30 A. The Company has found, through first-hand experience in implementing this policy change in
31 Utah, Wyoming, California, and Oregon, that customers accept the concerns the Company has for
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safety of field personnel and have been very understanding of this policy change. To date, the
Company has not received any escalated customer issues or commission complaints due to the
change in business practice in these states.
How did the Company communicate this change in practice with its employees and
customers prior to implementation?
In preparation for the change in Wyoming, Utah, California and Oregon, the Company conducted
a two-month communications campaign to inform customers with past due balances of this new
practice. The Company included bill messages on bills with past due account balances, stapled 3"
x 5" message cards (Exhibit 1) to any 48 hour courtesy door hanger and disconnection door
hanger left at a site, and verbally delivered the message to any customer responding to a door
knock during the two-month period of time as well as handed out the message card to those same
customers. Additionally, call center representatives communicated the information to customers
calling regarding past due balances.
Field metering specialists attended a special training session to inform the specialist of
the change in practice, discussed why the Company was making the change, discussed the two-
month communications campaign and their role in the campaign, and discussed possible ways in
which to handle customer questions and concerns. As a follow-up to the training, metering
managers road along with the specialists periodically during the two-month communications
campaign to ensure the message was being delivered and understand first-hand how customers
were receiving the message.
Since the implementation of this practice in Utah and Wyoming the field metering
specialists assisted with the special training sessions in Oregon and California and advised their
counterparts this has been a positive experience, that is safer not having money with them in the
field and there are no more negotiations that escalate into negative interactions.
Can you summarize the reason the Company is requesting a waiver to Rule 311 (4) and (5)?
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A.The Company can no longer support business practices allowing for the risk of injury or death to
an employee. For PacifiCorp safety and its responsibility to reduce the risk of harm to its
employees is a top priority. One way to do that is to eliminate the requirement that an employee
will be making personal contact on the date of disconnect and carrying customer payments.
Removing the requirement to make personal contact on the date of disconnect and accept
payment would reduce the risk of an employee becoming a target, eliminate the risk of
customer's personal banking information being stolen and used fraudulently and eliminate the
opportunity for theft of cash. Ensuring a safe working environment for employees is in the public
interest and the Utilities' request is consistent with underlying rules and applicable statutes. Such
an exemption would allow Rocky Mountain Power the ability to increase the safety of employees
without sacrificing customer service.
Does this conclude your testimony?
Yes.
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Rocky Mountain Power
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR.U-I 4.01
ROCKY MOUNTAIN POWER
COUGHLIN, DI
TESTIMONY
EXHIBIT NO. 1
COMMUNICATION OF FIELD COLLECTION POLICY CHANGE USED IN UTAH
Utah Card - Side 1 English, Side 2 Spanish:
To our valued customers:
As of October l, 2012 we are no longer
able to collect customer payments when
our employees come to your home
or business. We have several payment
options available once your account is
past due:
. Pay online
. Pay by phone (fees apply)
lf you need further arrangements or
other payment options, please call our
toll-free customer service number
| -888-22 t -7070.
This change was made for employee safety
and security of customer payments. lt also
helps reduce costs for all our customers.
We appreciate your patience and
understanding. lt's a pleasure to serve you.
xryffito )
a
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A nuestros apreciados clientes:
A partir del I de octubre de 2012, nuestros
empleados ya no podrdn aceptar los pagos
directamente de los clientes m;estros cuando
van a su casa o negocio, Tenemos varias
opciones de pago disponibles una vez que
se ha venodo el plazo de pago:
. Pago en linea por lntemet
. Pago portel6fono (se aplican cargos)
Para realizar otros arreglos o para otras
opciones de pago, por favor llame a nuestro
ndmero gratuito de servicio al cliente
al l-888-225-261 l.
Este cambio es por razones de seguridad
para nuestros empleados y para la seguridad
de los pagos de nuestros clientes. Tambidn
ayuda a reducrr los costos para todos
nuestros clientes.
Apreciamos su pacrencia y comprensi6n.
Es un placer servirle.xffi::lo
Exhibit No. 1
Case No. GNR-U-14-01
B. Coughlin, RMP
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