carlton d. watson @dteenergy

May 26, 2021 Lisa Felice Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Lansing, MI 48917

RE: In the matter of the application of DTE Electric Company for the approval of a partial waiver of the Consumer Standards and Billing Practices for Electric Residential Service and approval of a Voluntary Prepay Billing Program. MPSC Case No: U-21087

Dear Ms. Felice:

Attached for electronic filing in the above referenced matter is DTE Electric Company’s Application and Affidavit of Eric W. Pokriefka for ex parte approval of the its Prepay Program as well as requisite waivers of the Billing Rules needed to implement the Prepay Program. Also attached is the Proof of Service. Very truly yours, Carlton D. Watson CDW/erb Encl. cc: Service List

Carlton D. Watson (313) 235-6648 [email protected]

DTE Electric Company One Energy Plaza, 1650 WCB Detroit, MI 48226-1279

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

In the matter of the application of DTE Electric ) Company for the approval of a partial waiver of ) the Consumer Standards and Billing Practices for ) Case No. U-21087 Electric Residential Service and approval of a ) Voluntary Prepay Billing Program. )

DTE ELECTRIC COMPANY’S EX PARTE APPLICATION

DTE Electric Company (“DTE Electric”) files this Ex Parte Application requesting

authority from the Michigan Public Service Commission (“Commission” or “MPSC”) for approval

of a waiver to certain requirements the Consumer Standards and Billing Practices for Electric and

Natural Gas Service Rules (“Billing Rules”), Mich Admin Code, R 460.101 et seq., and approve

the Company’s proposal to implement a program offering a prepaid electric customer billing

option. In support thereof, the Company states as follows:

1. DTE Electric is a corporation organized and existing under and by virtue of the

laws of the State of Michigan, with its principal office at One Energy Plaza, Detroit, Michigan

48226. DTE Electric is a wholly-owned subsidiary of DTE Energy Company supplying retail

electric service to 2.1 million customers located in Southeast Michigan. The Company is a public

utility with more than 1,000,000 retail customers in Michigan and is therefore subject to the

jurisdiction of the Commission per various provisions of 1919 PA 419, as amended, MCL

460.51 et seq.; 1939 PA 3, as amended MCL 460.1 et seq.; and 2008 PA 295, as amended MCL

460.1001 et seq.

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2. DTE Electric company files this Application to request ex parte approval of the its

Prepay Program as well as requisite waivers of the Billing Rules needed to implement the Prepay

Program.

3. This voluntary Prepay Program allows customers to provide prepayment for their

energy prior to its use. DTE Electric plans to launch enrollments in the first quarter 2022. To

achieve this target, DTE Electric will need to complete the programming in the fourth quarter of

2021.

4. The Prepay Program will feature methods to gather customer feedback for

improvement of the customer experience; as such, the Company may change program features

after launch, but it will consult with Commission Staff and interested parties when such changes

are considered.

5. For this program, “Customer” is defined as a residential customer taking service

under the Company’s D1 Rate Schedule with single electric commodity and an AMI meter with

remote connection and disconnection capability currently installed at the premise.

6. In order to implement the Company’s Prepay Program, waivers of several of the

Commission’s Billing Rules primarily related to shutoff of service are required. Specifically, the

Company requires a waiver of the following Billing Rules: 460.129(4), 460.139(1), 460.139(6),

460.140(1), 460.140(2) and 460.143(1).

7. In support of this Application, DTE Electric submits the Affidavit of Eric W.

Pokriefka, Manager in Customer Service, which is attached and incorporated herein, as well as

Attachments A and B. Mr. Pokriefka more specifically provides the basis for the requested Billing

Rule waivers.

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8. Approval of the relief requested in this Application “will not result in an increase

in the cost of service to customers.” Accordingly, this Application “may be authorized and

approved without notice or hearing” pursuant to MCL 460.6a(1). Thus, approval of this

Application without notice or hearing is lawful and appropriate.

9. DTE Electric Company respectfully requests that the Commission approve the

relief requested on an ex parte basis without the time and expense of notice or public hearing.

WHEREFORE, Applicant requests that the Commission enter an Order:

A. Approving DTE Electric’s request for ex parte approval of its Prepay Program

B. Waiving the Rules 460.129(4), 460.139(1), 460.139(6), 460.140(1), 460.140(2)

and 460.143(1) of the Michigan Administrative Code in order to allow DTE

Electric to implement the Prepay Program.

C. Granting DTE Electric with such further additional relief as the Commission deems

appropriate.

DTE ELECTRIC COMPANY

By: Attorney for the Applicant Carlton D. Watson (P77857) One Energy Plaza, 1650 WCB Detroit, Michigan 48226 (313) 235-6648

Date: May 26, 2021

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the application of DTE Electric ) Company for the approval of a partial waiver of ) the Consumer Standards and Billing Practices for ) Case No. U-21087 Electric Residential Service and approval of a ) Voluntary Prepay Billing Program )

A FFIDAVIT OF ERIC W. POKRIEFKA

STATE OF MICHIGAN )

) COUNTY OF WAYNE )

Eric W. Pokriefka being first duly sworn, deposes and says:

1. I am employed by DTE Energy Corporate Services, LLC, a subsidiary of DTE

Energy (DTE or Company), as a Manager in Customer Service. I graduated from Wayne State

University with a Bachelor of Science Degree in Accounting.

2. My role at DTE began as a Manager in Customer Service, Digital Experience in

2014 with subject matter expertise in defining the customer experience for transformational

Capital and O&M projects. Additionally, my responsibilities included leading business unit

initiatives in Continuous Improvement and Project Management. In 2018, I began my role as

Manager in Customer Transformation a department within Customer Service. I currently serve

as the Customer Closed Loop and Residential Prepay program expert. This includes, but is not

limited to, the system operations, policy development and implementation concerning the Prepay

program. In addition, my responsibilities as Manager include operational team management,

customer experience leadership, development of customer policy and programs, regulatory policy

development, and initiatives centered around the transformation of the customer experience.

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3. The Prepay program is a voluntary payment program for customers to provide

prepayment for their energy prior to its use. DTE plans to launch enrollments in the first quarter

of 2022. To achieve this target date, DTE will need to complete the programming in the fourth

quarter of 2021. Refer to Attachment A for an overview of the program and Attachment B for

terms and conditions.

4. For participation in this voluntary Prepay payment program “Customer” is defined

as residential being provided service through the Company’s D1 Rate Schedule with single electric

commodity. Customers who receive electric utility service only from the Company will have the

opportunity to enroll into the program. Customers who receive both gas and electric utility service

from DTE Gas and DTE Electric (dual commodity customers) will currently not be eligible for

the program. In addition, the program requires an AMI meter with remote connection and

disconnection capability currently installed at the customer’s premise.

5. Customer classes excluded from enrollment in Prepay include but are not limited

to customers with:

• Medical Emergency self or Medical Emergency household

• Active Military Service

• Seniors with Winter Protection Plan

6. Customers enrolled in Prepay will be provided with an estimated daily usage

amount for their premise in both kWh and dollars. These estimates will be used to determine

prepayment amounts. The estimated daily usage is wholly based on the actual usage as measured

by the AMI meter at the customers current premise averaged for past 12 rolling months. Enrolled

customers will also have access to historical actual usage data through the existing data download

feature on dteenergy.com or through a request to a Customer Service Representative.

7. Customers enrolled in Prepay will be able to make one-time payments through the

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DTE Contact Center, dteenergy.com, the automated phone system (IVR) as well as authorized

payment agents. Future dated payments can be scheduled through the DTE Contact Center and

dteenergy.com. Average daily usage information in the form of estimated dollars and number of

days of energy use will be provided through each channel to guide customers on how much

energy they will have available for use based on the amount of their prepayment.

8. Customers enrolled in Prepay will have their energy disconnected through the

AMI meter remote disconnect feature for failure to make a payment before reaching a zero dollar

balance. Customers will receive low balance notifications through email and optionally text

messages five, three and one day prior to reaching a zero balance. Customers disconnected for

non-payment can be reconnected by calling DTE’s Contact Center, requesting reconnection and

making a minimum payment of $40 which will be applied to their account as credit. Customers

reconnection requests will be submitted to their AMI meter in real-time by the Customer

Representative with an average processing and reconnection time of 30 minutes after payment

approval.

9. Customers enrolled in Prepay may unenroll from the program at any time. A

customer who unenrolls from the Prepay program and elects to continue receiving energy from

DTE will be returned to the post-pay/credit billing method.

10. Customers enrolled in Prepay will receive mandatory communications in the form

of email and optionally in the form of SMS text messages regarding payment, low balance and

disconnection status. Customers enrolled in Prepay may elect to enroll in optional

communications which provide current account balance on a recurring basis.

11. The program will develop and track standardized data to accurately measure the

success and opportunities of the program. Key performance indicators include enrollment/de-

enrollment volume and rate, service disconnection/re-connection rates, arrears reduction amount

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and rate and customer satisfaction. In depth analysis will also involve examining customer energy

assistance eligibility to capture best practices for continuous improvement opportunities.

12. Because this program will feature methods to gather customer feedback and

sentiment for improvement of the customer experience, the Company may change program

features after launch. The Company will consult with Commission Staff and interested parties

when such changes are considered.

13. The Company is requesting waivers for the following rules to facilitate its

implementation of the Prepay Program.

• Rule 460.129 (4) which states: (4) When a residential customer receives a past-due notice from the utility, the utility shall provide the customer access to information about energy assistance programs referenced in subrules (1) and (3) of this rule, which shall, at minimum, include a telephone number of a utility representative able to provide this information.

• Customers enrolled in Prepay will not receive a past due notice via USPS mail.

They will receive electronic communications notifying them of balances and

days of estimated usage remaining. Beginning at 5 days of estimated usage

remaining, customers will receive electronic communications every other day,

at a minimum.

• Rule 460.139 (1) which states: (1) Not less than 10 days before the proposed shut off of service, pursuant to the provisions of R 460.140, R 460.142 and R 460.143 of these rules, a utility shall send a notice to the customer by first-class mail, or personal service.

• Customers enrolled in Prepay will not have a grace period based on their

billing cycle. Customers enrolled in Prepay upon reaching a zero balance with

no pending payment will be scheduled for disconnection the next day based

upon the existing and approved disconnection calendar.

• Upon reaching a zero balance customers enrolled in Prepay will receive a zero

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balance email and a scheduled disconnection email with instructions on how

to avoid disconnection including contact information, assistance instructions

and payment methods.

• Rule 460.139 (6) which states: (6) For an involuntary shutoff, at least 1 day before shutoff of service, the utility shall make not less than 2 attempts to contact the customer by telephone, if a telephone number is available to the utility, to advise the customer of the shutoff and what steps the customer must take to avoid shutoff. If the utility uses an automated notification system, it shall document the process for ensuring that at least 2 attempts are made to notify the customer of the pending shutoff. If the telephone number is not available, the customer has no telephone, or the utility chooses not to make telephone contacts, the utility shall either leave a notice at the premises advising the customer that service will be shutoff on or after the next business day or send notice by first-class mail postmarked at least 5 business days before shutoff of service is scheduled. The utility shall document all attempts to contact the customer. The 10-day notice sent under subsections (1) or (5) of this rule shall be considered as 1 attempt.

• Customers enrolled in Prepay will receive low balance electronic

communications five, three and one day prior to reaching zero balance. Upon

reaching a zero balance, customers enrolled in Prepay will receive a zero

balance notification by e-mail only and a scheduled disconnection email with

instructions on how to avoid disconnection including contact information,

assistance instructions and payment methods.

• Upon reaching a zero balance customers enrolled in Prepay will receive a zero




• Rule 460.140 (1)(d) which states: (1) A notice of shutoff of service shall contain all of the following information:

(d) That the residential and small nonresidential customer may have the right to enter into a payment plan with the utility for an amount owed to the utility that is not in dispute and that the customer is presently unable to pay in full.

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• Prepay is a payment plan with payment allocation rules to allow enrolled

customers to pay down their arrears by applying 20% of each payment to

arrears.

• Rule 460.140 (2)(f) which states: (2) For residential customers a notice of shutoff of service shall also contain the

following information: (f) That the utility will postpone the shutoff of service if a certified medical

emergency exists at the customer's residence and the customer informs and provides documentation to the utility of that medical emergency.

• Customers with a certified medical hold will not be eligible for enrollment into

the prepay program.

• Rule 460.140(1) which states: (1) A notice of shutoff of service shall contain all of the following information:

(a) The name and address of the customer, and the address at which service is provided, if different.

(b) A clear and concise statement of the reason for the proposed shutoff of service.

(c) The date on or after which the utility may shut off service, unless the customer takes appropriate action.

(d) That the residential and small nonresidential customer may have the right to enter into a payment plan with the utility for an amount owed to the utility that is not in dispute and that the customer is presently unable to pay in full.

(e) That the residential and small nonresidential customer may have the right to enter into a settlement agreement with the utility if the claim is for an amount that is in dispute.

(f) That the customer has the right to file a complaint disputing the claim of the utility before the proposed date of the shutoff of service.

(g) That the customer has the right to request a hearing before a hearing officer if the customer disputes the reasonableness of the payment plan or settlement agreement offered by the utility or if the complaint cannot be otherwise resolved and that the customer must pay to the utility that portion of the bill that is not in dispute within 10 business days of the date that the customer requests a hearing.

(h) That the customer has the right to represent himself or herself, to be represented by counsel, or to be assisted by other persons of his or her choice in the complaint process.

(i) That the utility will not shut off service pending the resolution of a complaint that is filed with the utility or the commission in accordance with these rules.

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(j) The telephone number and address of the utility where the customer may make inquiry, enter into a payment plan or settlement agreement, or file a complaint.

(k) That the utility may require a deposit and restoration charge if the utility shuts off service for nonpayment of a delinquent account or for unauthorized use of utility service.

• Upon reaching a zero balance Customers enrolled in Prepay will receive a zero




• Rule 460.140(2) which states: (2) For residential customers a notice of shutoff of service shall also contain the

following information: (a) A combination utility shall include the following information on

disconnection notices for eligible low-income customers whose natural gas and electric services are combined: (i) The amounts for both natural gas and electric service, listed separately, and (ii) That the customer has the option of choosing one of his/her services to retain with the appropriate payment, and (iii) That the customer may have the option to enter into a payment plan for both natural gas and electric service, or to retain either natural gas or electric service as chosen by the customer.

(b) That the customer should contact a social services agency immediately if the customer believes he or she might be eligible for an energy assistance program or other emergency economic assistance and should inform the utility of any efforts being made to obtain payment assistance.

(c) That customers who believe they may be eligible for assistance from an energy assistance program should determine if assistance is available before enrolling in a payment plan because many agencies may not provide assistance if shutoff is avoided by signing a settlement agreement.

(d) That during the heating season the utility will postpone shutoff of service if a customer is an eligible low-income customer that enters into a winter protection payment plan with the utility and the customer provides documentation that the customer is actively seeking emergency assistance from an energy assistance program.

(e) The energy assistance telephone line number at the department of human services or an operating 2-1-1 system telephone number.

(f) That the utility will postpone the shutoff of service if a certified medical emergency exists at the customer's residence and the customer informs and provides documentation to the utility of that medical emergency.

(g) That the customer should contact the utility for information about a

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shutoff protection program.





• Rule 460.143 (1) which states: (1) For an involuntary shutoff of service using meters with remote shutoff and

restoration capability, at least 1 day before shutoff of service, the utility shall make at least 2 attempts to contact the customer by 1 of the methods listed in R 460.139(6) of these rules. The notice shall conspicuously state that the disconnection of service will be done remotely and that a utility representative will not return to the premises before disconnection.





Further, Affiant sayeth not.

ERIC W. POKRIEFKA

Subscribed and sworn to before me this 26th day of May, 2021.

Estella R. Branson, Notary Public Oakland County, Michigan My Commission Expires: 10-26-2023 Acting in Wayne County


Attachment A to Affidavit of Eric W. Pokriefka

We continue to make progress in the development of a voluntary Prepay program

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DESIGN COMPLETE

BUILD COMPLETE

TESTING COMPLETE

PROGRAM LAUNCH

05/28/2021 08/20/2021 11/12/2021 11/19/2021

❑ Journey Mapping

❑ Benchmarking

❑ Focus Groups

❑ Requirements Gathering

❑ Change Mgt. Assessment

❑ Conceptual Design

❑ Vendor Selection

❑ Charter & Project Plan

❑ Implement & integrate core SAP back-end functionality

❑ CR channel eligibility checks, enrollment & account mgt.

❑ Web & IVR Prepay self-serve balance presentment

❑ Preconfigured text & email low balance alerts

❑ Payments accepted across multiple service channels

❑ Marketing & Organizational Change Management

❑ Expand enrollment & acct. mgt. to web/mobile web

❑ Customer configured alerts (threshold/frequency)

❑ Time-of-Use (TOU)

❑ 2-Way TextingNovember

Go-Live

TBD Go-Live*

* Phase 2 to begin mid-2022 in support of a planned Q1 2023 launch, allowing time for Phase 1 launch and stabilization and the incorporation of TOU of requirements

Targeting 3,000 enrollments in

first year

We recently submitted an ex parte filing requesting approval of the voluntary program and the required billing rule waivers

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We have filed Case No. U-21087…… Which includes requests to……• Waive issuance of a monthly bill/invoice• Waive 21-day payment grace period• Waive written notice of shutoff via USPS mail• Waive/modify content of shutoff notices• Waive requirement for two attempted calls

ahead of scheduled shutoff

In lieu of the above, Prepay customers will……1. Receive a monthly electronic reconciliation statement summarizing

the previous month’s account activity2. Make payments (i.e. credit their account) according to their needs3. Receive email and/or text low balance alerts, shutoff pending, and

shutoff scheduled notifications with relevant reconnect information4. Be disconnected no sooner than 1 day after they exhaust their credits

DTE ELECTRIC COMPANY’S EX PARTE APPLICATION

DTE Electric Company (“DTE Electric”) files this Ex Parte Application requesting

authority from the Michigan Public Service Commission (“Commission” or “MPSC”) for approval

of a waiver to certain requirements the Consumer Standards and Billing Practices for Electric and

Natural Gas Service Rules (“Billing Rules”), Mich Admin Code, R 460.101 et seq., and approve

the Company’s proposal to implement a program offering a prepaid electric customer billing

option. In support thereof, the Company states as follows:

We have firmed up several outstanding program design attributes since our last update in March based on analytics and benchmarks

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Enrollment

• Limited in Phase 1 to electric only AMI customers

• Customer can transfer < $750 in electric arrears @ enrollment

• Phase 1 will exclude customers on non-metered programs (e.g. HPP, MIGP, TreeGuard)

Payments

Notifications

Disconnects

• Initial payment of $40 to establish account (~10 days of usage)

• Phase 1 will allow unlimited number of minimum $10 payments

• Auto-reload option will be available @ customer selected thresholds

Will expand to include combo customers in Phase 2 + potentially non-metered program customers

20% of each payment will be applied to outstanding

arrears balance

• Customer must provide a valid email to participate in the program

• Customer will have the option to add text notifications

• Triggered at 5D, 3D, and 1D (risk of disconnect) + 0D (disconnect pending)

Customers can elect to receive daily

balance updates

• Disconnects will occur no sooner than one day after balance reaches 0

• Customers will be reconnected within 15-30 minutes of making a payment

• Customer responsible for unpaid usage + $40 replenishment fee

Payment made through authorized pay agent may result in reconnect delays


Attachment B to Affidavit of Eric W. Pokriefka

DTE Prepay Program Terms and Conditions

Page 1 of 2

Availability:

Participation in the DTE Prepay Program (hereinafter referred to as “DTE Prepay Program”) is voluntary.

New Customers:

New customers applying for DTE Prepay Program will need to call 877-477-4747 to speak to a Customer

Service Representative. A minimum payment of $40.00 must be made on the DTE Prepay Program

account within 1 calendar days.

Existing Customers:

Existing customers may convert to DTE Prepay Program. When an account is converted to DTE Prepay

Program, the existing deposit (if applicable) is applied toward any outstanding balance and any

remaining credit (if applicable) will be applied to the DTE Prepay Program account. Any outstanding

balance, up to $750, on the traditional account will be moved over to the prepaid account and set up on

our debt recovery plan. In this plan, 20% of each payment made will be applied to the deferred balance.

A minimum credit of $40.00 must be made on the DTE Prepay Program account within 1 calendar days.

Security Deposit and Late Fees:

The normal security deposit for a residential account is not required and no late fees are applied to

prepaid accounts.

Payments:

The minimum payment amount is $10.00. Payments can be made 24 hours a day via credit card or debit

card online at dteenergy.com or by calling 877-477-4747. Cash and check payments can also be made at

any DTE Energy Direct Payment Office and Authorized Payment Agent locations during business hours.

Billing:

DTE Prepay Program accounts will not receive a monthly bill. A monthly statement of payment activity,

usage data and account history will be available at dteenergy.com. This website will allow the customer

to modify their notification settings. The customer is solely responsible for managing and updating the

notification settings on their DTE Prepay Program account.

Bill Viewing and Bill Calculation:

All DTE Prepay Program accounts will be calculated daily with daily adjustments of all charges and fees

deducted from the prepaid credit balance. The account will be reconciled once per month.

DTE Prepay Program accounts are mutually exclusive for payment arrangements, credit extensions, life

support status, or for participation in any other programs or service related to payments or billing.

Disconnection and Minimum Payments for Reconnection:

A prepaid account will be subject to immediate disconnection any time the account reaches a zero

balance. Service that has been disconnected due to a credit deficit will remain disconnected until any

outstanding balance and a minimum credit balance of $40 is paid. Amount to pay can be found at

dteenergy.com.

DTE Prepay Program Terms and Conditions

Page 2 of 2

Reconnection Process and Timing:

A prepaid account can be reconnected by contacting a Customer Service representative and bringing the

prepaid accounts credit balance to a minimum of $40. Timing to reconnect will be an average 30

minutes to a maximum of 4 hours depending on day and time of the customer’s payment.

Returned Checks:

If a returned check or a chargeback is received on an account, the amount of the return will be charged

back to that account immediately. If this causes the credit on the account to be exhausted, service will

be subject to immediate disconnection. DTE Energy has the right to decline payments by check if the

account reflects two or more return items in the last 12 months.

If an account is disconnected for nonpayment for 7 consecutive days, the account will be considered

inactive and will be permanently disconnected. If permanent disconnection occurs, the customer will

have to contact DTE Energy for reconnection.

Termination of Service:

Service terminated at the request of the customer will receive a refund of any remaining credit on the

account after all final bill amounts have been calculated. All refund checks will be sent to the mailing

address on file.

Conversion to a Post Pay account:

A customer may elect to convert their account to a post pay account at any time. DTE Energy will require

full payment of the deposit and balance owed, if applicable, as a condition of continued service.

Prepaid customers will comply with and be bound by DTE Energy’s Terms and Conditions of Retail

Electric Service. All charges and fees, such as returned check fees, meter tampering fees, etc. apply to

prepaid accounts. Service will not be connected if electrical code is not met.

Communication / Balance Alerts:

The customer is responsible for managing and updating the notification methods on their DTE Prepay

Program account. DTE Energy will communicate to customers when the credit balance on file is

approaching zero ($0.00). Customers will be notified by default at 5 days, 3 days, 1 day and 0 day energy

use remaining. Customers will also have the option to receive weekly and/or daily notifications of their

credit balance.

In compliance with the Terms and Conditions of mobile carrier, the customer must opt in to receive text

messages. An opt-in code will be sent via text message to all customers electing to receive notifications

through text message. Standard carrier rates and fees may apply.

Existing Terms and Conditions apply unless superseded or countermanded by Terms and Conditions

defined in this document.

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION


PROOF OF SERVICE

ESTELLA R. BRANSON states that on May 24, 2021, she served a copy of the DTE Electric

Company’s Application and Affidavit of Eric W. Pokriefka for ex parte approval via electronic mail upon

the persons listed on the attached service list.

ESTELLA R. BRANSON

MPSC Case No. U-21087 SERVICE LIST

MPSC STAFF Steven D. Hughey Assistant Attorney General Public Service Division 7109 W. Saginaw Highway, Fl 3 Lansing, MI 48917 [email protected]

mailto:[email protected]

carlton d. watson @dteenergy

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