rocky mountain power informal comments to wy psc …psc.state.wy.us/pscdocs/dwnload/7-31-15...

RockyMountainPowerInformalCommentstoWYPSCRed‐LineVersionofProposedChapter3(issuedJuly31,2015)

SubmittedonAugust22,2015

8/22/2015

Rocky Mountain Power Informal Comments to WY PSC Red‐Line Version of Proposed Chapter 3 (issued July 31, 2015)

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ContentsSection 7 (a) (viii) – Customer Deposits ................................................................................................................................................................................................... 2

Section 7 (h)(i) and (ii) ‐ Customer Deposits ............................................................................................................................................................................................ 4

Section 9 (a) and (b) – Discontinuation of Service to Customers ............................................................................................................................................................ 5

Section 18 (c)(ix) ‐ Meter Testing Program .............................................................................................................................................................................................. 6

Section 27 (c)(ii) ‐ SIRT; Reportable Incidents .......................................................................................................................................................................................... 7


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Section7(a)(viii)–CustomerDepositsExisting Rule Not Applicable (this section is new)

March Version

Not Applicable (this section is new)

June 15 Red‐line

Not Applicable (this section is new)

July 31 Red‐line

(a) The utility may require a customer deposit if: (viii) A utility has determined that it has a significant financial risk in continuing to provide service to a specific load or non‐residential customer. The utility shall file a petition requesting expedited review and Commission approval prior to collecting the customer deposit. The petition shall contain the basis for the utility’s determination, the amount of deposit sought and sufficient information for the Commission to contact the customer.

RMP Suggested Changes 8/21/15

(viii) A utility has determined that it has a significant financial risk in continuing to provide service to a specific load or non‐residential customer. The utility shall file a petition requesting expedited review and Commission approval prior to collecting the customer deposit. The petition shall contain the basis for the utility’s determination, the amount of deposit sought and sufficient information for the Commission to contact the customer.

RMP Concern and Comments

We believe this section is potentially in conflict with existing section (a)(v) and increases the reporting burden on all utilities. RMP would like to better understand the intent of newly added language. We are concerned this new provision will be detrimental to the Company and rate payers in terms of risk exposure. A large number of the company’s industrial customers are located in Wyoming and are in the oil /gas industry, an industry which is speculative and has experienced continued depressed crude oil prices. Market volatility can impact credit quality for customers, which increases a utility’s risk since electric service is billed only after it has been used. Any limitation or delay in obtaining security from these large customers that are deemed to pose a credit risk will significantly increase the company’s exposure to a potential write‐off. For example, the Company has an existing customer with an average monthly electrical usage around $3.9 million. If the Company identified a need to collect a deposit to mitigate risk, any delay (such as the proposed


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requirement of filing a petition with the Commission) in collecting the deposit would increase exposure to a potential write‐off by $130,000 per day. We believe paragraph (a)(v) in this section can allow utilities to assess a deposit to an existing customer based on an objective credit screen. This proposed paragraph is in direct conflict with that authorization. A customer always has the right to dispute the deposit, and if they choose, file a complaint with the Commission. Additionally, a Company has the ability to include specific deposit provisions within their own tariff for these types of situations. We recommend that section (a)(viii) be removed as it creates additional risk for both the utility and rate payers, conflicts with (a)(v), and adds another layer of administrative reporting burden.


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Section7(h)(i)and(ii)‐CustomerDepositsExisting Rule (ii) The customer will be considered to have demonstrated creditworthiness, when the customer has received twelve

(12) consecutive months of service, there has been no cause to disconnect, and bills have been paid by the payment due date. Upon this demonstration of creditworthiness, the deposit plus interest shall be promptly refunded to the customer or applied to the remaining balance by the utility.

March Version

(h) Deposits and any unpaid interest earned on deposits shall be returned to customers: (i) Upon customer request, and if the accrued interest equals or exceeds $5.00, the utility shall annually apply the interest as a credit to the customer’s bill; (ii) When the customer has received 12 consecutive months of service, with no cause to disconnect and bills have been paid when due. With the customer’s consent, the deposit and unpaid interest shall be applied to the customer’s account balance;

June 15 Red‐line

(h) Deposits and any unpaid interest earned on deposits shall be returned to customers: (i) Upon customer request, and if the accrued interest equals or exceeds $510.00, the utility shall annually apply the interest as a credit to the customer’s bill; (ii) When the a residential customer has received 12 consecutive months of service, with no cause to disconnect and bills have been paid when due. With the customer’s consent, the deposit and unpaid interest shall be applied to the customer’s account balance.

July 31 Red‐line

(h) Deposits and any unpaid interest earned on deposits shall be returned to customers: (i) Upon customer request, and if the accrued interest equals or exceeds $10.00, the utility shall annually apply the interest as a credit to the customer’s bill; (ii) When a residential customer has received 12 consecutive months of service, with no cause to disconnect and bills have been paid when due. With the customer’s consent, theThe deposit and unpaid interest shall be applied to the customer’s account balance unless requested by the customer to be refunded;

RMP Request for Clarification

After further review, we want to be sure we are interpreting these sections correctly. Does this preclude RMP applying the interest annually on an account when a customer has not explicitly requested the interest applied annually? Our billing system automatically applies interest annually on all deposits. If we are required to receive explicit customer consent, it would require a system change to apply deposit interest annually only upon customer request.


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Section9(a)and(b)–DiscontinuationofServicetoCustomersExisting Rule (a) Notice requirements. No gas, electric or water utility shall terminate its service to any customer for violation of

any of its rules and regulations, or for nonpayment of bills covering such service, until the utility shall have first given at least seven (7) days written notice to residential customers which includes any premise occupied as living quarters, and three (3) days written notice to commercial and industrial customers.

March Version

(a) No utility shall terminate service to any customer for violating the utility’s rules and regulations or for nonpayment of bills for service until the utility has given at least seven days’ written notice to the customer. (b) Notice shall be effective when a copy is left with the customer or sent by U.S. mail to the customer’s last known physical address. Additional notice may be provided electronically. The notice shall contain:

June 15 Red‐line

(a) No utility shall terminate service to any customer for violating the utility’s rules and regulations or for nonpayment of bills for service until the utility has given at least seven calendar days’ written notice to the customer residential customers or three calendar days’ to commercial or industrial customers. (b) Notice shall be effective when a copy is left withprovided to the customer or sent received by U.S. mail to the customer’s last known physical mailing address. Additional notice may be provided electronically. The notice shall contain:

July 31 Red‐line

(a) No (a) Unless otherwise ordered by the Commission, no utility shall terminate service to any customer for violating the utility’s rules and regulations or for nonpayment of bills for service until the utility has given at least seven calendar days’ written notice to residential customers or three calendar days’ to commercial or industrial customers. (b) Notice shall be effective when a copy is provided to the customer in person, by telephone after customer verification, or received by U.S. mail toat the customer’s last known mailing address. Additional notice may be provided electronically. The notice shall contain:

RMP Request for Clarification

Section (b) references providing a copy of the written notice “by telephone after customer verification.” We are looking for clarification on how this would work to provide a written notice by telephone.


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Section18(c)(ix)‐MeterTestingProgramMarch Version

(c) At a minimum, the meter testing program shall include: (ix) For electric utilities, a requirement that instrument transformers shall be tested for accuracy at the same interval as the associated meter.

June 15 Red‐line

(c) At a minimum, the meter testing program shall include: (ix) For electric utilities, a requirement that instrument transformers shall be tested for accuracy at the same interval as the associated meter.

July 31 Red‐line

(c) At a minimum, the meter testing program shall include: (ix) For electric utilities, a requirement that instrument transformers shall be tested for accuracy range at the same interval as the associated meter.


(c) At a minimum, the meter testing program shall include: (ix) For electric utilities, a requirement that instrument transformers shall be tested for accuracy range or burden performance at the same interval as the associated meter.

RMP Concern and Comment

According the Company’s Metering Standards and Engineering group, we do not have equipment to test the accuracy of in‐service instrument transformers. However, we can and do perform a “burden test” which will verify the current instrument transformer is functioning within its full operating limits. We currently do not know of any equipment on the market that can test the accuracy of in‐service instrument transformers.


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Section27(c)(ii)‐SIRT;ReportableIncidentsExisting Rule Section 233. For utilities other than rail carriers and gas utilities, a reportable accident is defined as an accident that results in

one or more of the following circumstances: (a) Death of a person. (b) Injuries to persons, including employees of utilities, which result in total disability, loss of sight, or limb, or which incapacitates them to the extent that they are unable to perform their ordinary duties or follow their customary vocations for a period of more than ten days immediately following the accident. (c) Damage to the property of the utility which substantially affects its service to the public. (d) Damage to the property of others amounting to more than $2000.00.

March Version

(c) Additional reportable incidents for electric utilities: (ii) Outages to emergency response facilities; or

June 15 Red‐line


July 31 Red‐line



(ii) Outages to emergency response facilities; or

RMP Concern This section continues to be of great concern to Rocky Mountain Power and we will continue to oppose this rule during the official rule making process. We want to reiterate that our current systems in place do not have this capability and Wyoming would be the only state requiring this information to be reported for our system. As such, all costs associated with developing a program to allow this type of reporting could greatly affect the Wyoming rate payer since the costs to implement


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Section27(c)(ii)‐SIRT;ReportableIncidentsthis would be assigned solely to Wyoming. This will only continue to put upward pressure on rates. While we do not have an actual estimate of what it would cost, this is not a quick fix with an easy solution to 1) determine how these can be identified within our billing system with a specific ID code that does not exist at this time; 2) determine how these can be identified within our mapping system; 3) determine how these can be identified on a specific circuit during an outage; 4) determine the data source (which may not exist and may have to be created from scratch); 5) reconfigure our existing systems; and 6) update our reporting procedures.

rocky mountain power informal comments to wy psc …psc.state.wy.us/pscdocs/dwnload/7-31-15...

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