rocky mountain power docket no. 20-035-04 witness: melissa ... · i. introduction and...

Rocky Mountain Power Docket No. 20-035-04 Witness: Melissa S. Nottingham

BEFORE THE PUBLIC SERVICE COMMISSION

OF THE STATE OF UTAH

ROCKY MOUNTAIN POWER

____________________________________________

Direct Testimony of Melissa S. Nottingham

May 2020


I. INTRODUCTION AND QUALIFICATIONS 1

Q. Please state your name, business address, and present position with PacifiCorp 2

d/b/a Rocky Mountain Power (the “Company”). 3

A. My name is Melissa S. Nottingham and my business address is 825 NE Multnomah 4

Street, Suite 2000, Portland, Oregon 97232. I am currently employed as Manager, 5

Customer Advocacy and Tariff Policy. I am testifying on behalf of the Company. 6

Q. Please describe your education and professional experience. 7

A. I have a Bachelor of Arts in English from Arizona State University. I began working 8

for the Company in 1996, and worked in various positions with progressive 9

responsibility for the past 20 years. For the past 10 years, I have been the Manager of 10

Customer Advocacy and Tariff Policy in the Company’s Regulation department. 11

Q. Please describe your current duties. 12

A. My current duties include overseeing a team of regulatory analysts who respond to 13

consumer commission complaints, sponsoring tariff changes, ensuring compliance 14

with the Company’s tariff rules, and participating in general rate cases and other 15

regulatory proceedings for the Company’s six state service territory. In addition, I 16

oversee a team of business analysts responsible for the administration of the contracts 17

for new electrical load and the implementation and operation of the Company’s 18

customer guarantee program. As my team supports the Company’s tariff rules in each 19

state, we also support changes to Electric Service Schedule No. 300, Regulation 20

Charges ("Schedule 300"), which are the charges associated with the implementation 21

of the rules. 22


Q. Have you appeared as a witness in other regulatory proceedings? 23

A. Yes. I have testified in proceedings before the California Public Utilities Commission, 24

the Public Utility Commission of Oregon, the Washington Utilities and Transportation 25

Commission, and the Wyoming Public Service Commission. 26

II. PURPOSE OF TESTIMONY 27

Q. What is the purpose of your testimony in this case? 28

A. My testimony supports proposed updates to charges in Schedule 300 and a proposal for 29

customers to receive a credit for selecting paperless billing ("Paperless Bill Credit"). 30

Additionally, I propose housekeeping changes to Schedule 300 regarding the 31

referenced regulations. 32

Q. Why is the Company proposing these changes? 33

A. The proposed changes reflect the Company’s continued commitment to keep costs low 34

for our customers, update charges to align with current labor costs, and empower 35

customers to control their monthly bills. 36

Q. Please provide a summary of your testimony and the proposed changes. 37

A. My testimony supports the Company's proposed updates to several customer charges 38

in Schedule 300. The Company reviewed the costs associated with Schedule 300 39

charges and identified areas where costs have changed. A variety of factors, including 40

automation of returned checks and increased labor costs, have contributed to a change 41

in actual costs to perform work. Accordingly, the Company is proposing to align 42

customer charges to more accurately reflect current costs. 43

My testimony also supports the Company's proposal to implement a monthly 44

bill credit for customers who choose paperless billing. The proposed Paperless Bill 45


Credit will incentivize customers to either remain on or select this lower cost option 46

and pass the cost savings to those customers. The credit is reflected in proposed tariff 47

changes to Electric Service Regulation No. 8, Billings (“Regulation 8”) and Schedule 48

300, which are included in Mr. Robert M. Meredith’s Exhibit RMP___(RMM-14). 49

All of the proposed changes are a continuation of PacifiCorp’s ongoing 50

commitment to provide fair and reasonable charges by closely managing expenses 51

while still meeting customers’ increasing expectations. 52

III. SCHEDULE 300 53

Q. Please describe the changes the Company is proposing to the Schedule 300 54

charges. 55

A. Table 1 shows the regulation, a description of the charge, the current charge, and the 56

proposed charge. 57

TABLE 11 ,2 58

Reg Description of Charge Current Proposed 8R.2 Returned Payment Charge $20 $12

10R.9 Pole-Cut Disconnect/Reconnect Charges: Normal Business Hours

$125 $200

12R.11 Temp Service Charge - Single Phase $85 $215 12R.11 Temp Service Charge - Three Phase $115 $215

Returned Payment Charge 59

Q. Please describe the Returned Payment Charge. 60

A. If a customer presents a payment that is returned by the customer’s bank, the Company 61

incurs a cost to process the returned payment. Payments can be returned for a variety 62

1 The Company’s Schedule 300 currently notes the Temporary Service charge comes from 12R.11. The reference should read 12R.16 and is corrected in housekeeping changes later in the testimony. 2 The Company proposes to consolidate the single phase and three phase into one Temporary Service Charge, with the same amount.


of reasons, including, but not limited to, insufficient funds, incorrect account numbers, 63

or closed accounts. 64

Q. What is the current Returned Payment Charge? 65

A. The current Returned Payment Charge is $20. 66

Q. What is the proposed change to the Returned Payment Charge? 67

A. The Company proposes to reduce the Returned Payment Charge from $20 to $12. 68

Q. Why is the Company proposing this change? 69

A. Banks are now able to electronically transfer money from one bank to another bank 70

with less human interaction. This automation of a portion of the return payment process 71

has led to reduced costs to the Company when a payment is returned. Each time the 72

Company’s bank receives a returned item, the bank assesses a fee to the Company. 73

These fees account for the majority of the cost to the Company when a customer’s 74

payment is not acknowledged as valid. The bank fee plus the Company’s processing 75

costs can vary from $11 to $16 based on the bank presenting the returned payment, the 76

amount of the payment, and the number of times the payment is presented for payment. 77

While processing these payments has become more automated, labor costs are 78

not completely eliminated. Each returned item requires that a Company employee 79

update the account information and reverse the payment if the billing system has 80

already posted the payment to the account. The labor costs range from $1 to $6 per 81

transaction. The Company proposes $12 as it closely represents the low-end of the 82

average costs of both the labor and the bank fees associated with these returned 83

payments. See Exhibit RMP__(MSN-1) for the calculation of the proposed charge. 84


Pole Cut Disconnect/Reconnect Charge 85

Q. Please describe the Pole Cut Disconnect/Reconnect Charge. 86

A. The charge applies to customers involuntarily disconnected for either non-payment of 87

bills, tampering with facilities, access issues to the meter, or other actions taken by the 88

customer requiring the electric service to be disconnected at the transformer as opposed 89

to disconnecting the electric service at the meter. 90

Q. What is the current Pole Cut Disconnect/Reconnect Charge? 91

A. The current charge is $125 during normal business hours and $250 all other times. 92

Q. What is the proposed change to the Pole Cut Disconnect/Reconnect Charge? 93

A. The Company is proposing to increase the charge to $200 during normal business 94

hours. 95

Q. Why is the Company proposing to raise the Pole Cut Disconnect/Reconnect 96

Charge? 97

A. The work associated with a Pole Cut Disconnect/Reconnect must be conducted by 98

specialized employees, such as linemen, who are trained to work on the power lines. 99

The increased charge represents an increase in the loaded labor costs for a lineman to 100

complete the work. The rate for normal business hours is based on the availability of 101

employees. During routine business hours, linemen are readily available to perform the 102

work, resulting in lower labor costs. The after business hours rate is based on a 103

classification for union employees, which requires a two hour minimum call out for 104

work performed during after business hours. Accordingly, the after business hours rate 105

is based on the labor rate for two hours and represents the lowest possible costs to 106

perform after business hours work. The current charge for the after business hours pole 107


reconnect is currently $250 and closely reflects the current costs; therefore the 108

Company is not proposing a change to the rate for after business hours at this time. The 109

increase in the normal business charge better aligns with updated labor costs to perform 110

the work. 111

Temporary Service Charge 112

Q. Please describe the Temporary Service Charge. 113

A. A Temporary Service Charge applies when a customer requests the energization of a 114

temporary pedestal for temporary electric service. Temporary pedestals are typically 115

needed for periods when a premise is under construction. The Temporary Service 116

Charge covers the labor cost to bring either a single-phase or three-phase service line 117

to the temporary pedestal and energize the service. Once the service is energized, the 118

requesting customer is billed for the energy used. After the structure is completed, the 119

temporary service is de-energized and the meter is relocated to the permanent meter 120

base. 121

Q. What is the current Temporary Service Charge? 122

A. The current charge is $85 for single-phase service and $115 for three-phase service. 123

Q. What are the proposed changes to the Temporary Service Charge? 124

A. The Company proposes to increase the charge to $215 for all temporary service 125

installations and combine all phases into one charge. The $215 charge is based on the 126

current loaded rate for one hour and 40 minutes of journeyman time, which is the 127

average time to install the temporary service for customers. Since the Company's labor 128

cost is the same whether the Company installs temporary single-phase or three-phase 129

service, there is not a cost-based reason to differentiate the two services. 130


Q. Why is the Company proposing a change to the Temporary Service Charge? 131

A. The Temporary Service Charge has not been updated regularly and does not reflect the 132

Company’s current cost to provide this service. See Exhibit RMP___(MSN-1) for a 133

summary of the cost calculation. 134

Paperless Bill Credit 135

Q. Please describe the Paperless Bill Credit. 136

A. The Company proposes to add a credit to Schedule 300 and Regulation 8 to provide 137

customers a monthly credit if they participate in paperless billing. 138

Q. What is the proposed amount of the Paperless Bill Credit? 139

A. The proposed monthly credit is $0.50. 140

Q. Why is the Company proposing a monthly credit for paperless billing? 141

A. The proposed Paperless Bill Credit is correlated to the savings and benefits of not 142

sending a paper bill to a customer when that customer voluntarily enrolls in paperless 143

billing. Electronic delivery of the customer’s monthly bill eliminates the cost of the bill 144

paper, the envelope, printing and stuffing of the envelope, and the postage to mail the 145

bill. Eliminating these costs results in savings of approximately $0.49 per metered 146

service. By passing this savings to the customer in a $0.50 monthly credit, the Company 147

is encouraging customers to utilize a billing option that is both lower cost and more 148

environmentally friendly. All customers, whether they are currently participating in or 149

are new to paperless billing, are eligible to receive a credit as long as they are enrolled 150

in paperless billing. Please see Exhibit RMP___(MSN-1) for more detail on the 151


calculation of the credit and Mr. Meredith’s Exhibit RMP__(RMM-14) for the 152

proposed tariff changes to Schedule 300 and Regulation 8. 153

154

IV. HOUSEKEEPING 155

Q. What housekeeping changes are you proposing? 156

A. I am proposing housekeeping changes to Sheet No. 300.1 and Sheet No. 300.3 in 157

Schedule 300 to correct inaccurate sheet references. Sheet No. 300.1 has been updated 158

to reflect the correct regulation reference for the Manual Meter Reading charge (7R.3). 159

Sheet No. 300.3 has been corrected to show the proper regulation references for the 160

Temporary Service Charge from 12R.11 to 12R.16 and the Contract Administration 161

Credit from 12R.16 to 12R.17. Please see Mr. Meredith’s Exhibit RMP___(RMM-14). 162

V. CONCLUSION 163

Q. Please summarize your testimony. 164

A. The proposed changes to the Company’s Schedule 300 represent both the ongoing 165

commitment by the Company to keep operational costs low for customers and align 166

customer charges with cost. The proposed Paperless Bill Credit creates an opportunity 167

for customers to manage costs and directly receive the benefits of their choices. 168

Q. What is your recommendation regarding changes to Schedule 300, Regulation 8, 169

and the proposed Paperless Bill Credit? 170

A. I recommend that the Commission approve the updated charges in Schedule 300, the 171

proposed Paperless Bill Credit in Regulation 8, and the identified housekeeping 172

changes. 173

Q. Does this conclude your direct testimony? 174

A. Yes. 175

Rocky Mountain Power Exhibit RMP___(MSN-1) Docket No. 20-035-04 Witness: Melissa S. Nottingham

BEFORE THE PUBLIC SERVICE COMMISSION

OF THE STATE OF UTAH

ROCKY MOUNTAIN POWER

____________________________________________

Exhibit Accompanying Direct Testimony of Melissa S. Nottingham

Calculations Supporting Proposed Charges and Credit

May 2020

Rul

eC

harg

eT

imes

Cha

rged

1/

1/19

-12/

31/1

9C

urre

nt C

harg

eA

ctua

l Cos

tPr

opos

ed C

harg

eC

omm

ents

8R.2

Ret

urne

d Pa

ymen

t Cha

rge

27,1

64$2

0.00

$11.

25 to

$16

.25

$12

The

fees

cha

rged

by

the

com

pany

's ba

nks w

hen

a pa

ymen

t is r

etur

ned

and

the

labo

r to

proc

ess r

etur

ned

paym

ents

on

cust

omer

ac

coun

ts. T

he fe

es v

ary

base

d on

the

bank

and

how

man

y tim

es th

e sa

me

paym

ent i

s pro

cess

ed.

10R

.9Po

le C

ut D

isco

nnec

t/Rec

onne

ct C

harg

e:

Nor

mal

Bus

ines

s Hou

rs

19$1

25.0

0 $2

66.2

6$2

00

Incr

ease

in la

bor c

osts

. Pr

opos

ed $

200

fee

to re

flect

low

vol

ume

of re

ques

ts, i

ncre

men

tal i

ncre

ase

for l

ess i

mpa

ct to

cu

stom

ers.

Cos

t to

perf

orm

dis

conn

ect/r

econ

nect

at t

he p

ole

afte

r hou

rs re

quire

s a c

all o

ut b

ut a

pol

e co

nnec

t dur

ing

rout

ine

busi

ness

hou

rs u

tiliz

es a

ctiv

e re

sour

ces a

nd d

oes n

ot re

quire

a m

inim

um c

all o

ut fe

e. I

nten

t is t

o in

crea

se th

e ch

arge

to a

lign

with

exi

stin

g co

sts w

hile

not

mak

ing

the

char

ge c

ost p

rohi

bitiv

e to

cus

tom

ers.

12R

.11

Tem

p Se

rvic

e C

harg

e - S

ingl

e Ph

ase

7,39

2$8

5.00

$2

19.6

6$2

15In

crea

se in

labo

r cos

ts, c

alcu

late

d at

1.6

5 ho

urs o

f the

load

ed la

bor c

ost f

or th

e ty

pe o

f em

ploy

ee p

erfo

rmin

g th

e w

ork.

12R

.11

Tem

p Se

rvic

e C

harg

e - T

hree

Pha

se10

$115

.00

$219

.66

$215

Thre

e ph

ase

tem

pora

ry se

rvic

e is

rare

ly u

sed

by o

ur c

usto

mer

s as t

he ty

pe o

f ser

vice

lend

s its

elf t

o pe

rman

ent i

nsta

llatio

ns.

Rec

omm

end

rem

ovin

g th

is c

ost a

nd m

ergi

ng th

e tw

o te

mpo

rary

serv

ice

char

ges i

nto

one.

NEW

Pape

rless

Bill

Cre

dit

--

$0.4

9$.

50 B

ill C

redi

tEa

ch m

onth

, cus

tom

ers p

artic

ipat

ing

in p

aper

less

bill

ing

will

rece

ive

a cr

edit

dire

ctly

cor

rela

ted

to th

e sa

ving

s and

ben

efits

of

this

opt

ion.

Sche

dule

300

Fee

Sum

mar

y

Rocky Mountain Power Exhibit RMP___(MSN-1) 1 of 4

Docket No. 20-035-04 Witness: Melissa S. Nottingham

Cus

tom

er S

ervi

ces R

espo

nse

Tes

t Per

iod:

For

ecas

t tes

t yea

r en

ding

Dec

embe

r 31

, 202

1

Cha

rge

Cur

rent

Fee

in E

ffec

tN

umbe

r of

tim

es fe

e as

sess

ed

duri

ng th

e hi

stor

ic p

erio

dE

mpl

oyee

cla

ssifi

catio

n co

mpl

etin

g w

ork

Ave

rage

tim

e fo

r em

ploy

ee to

pe

rfor

m th

e w

ork

Act

ivity

Rat

eC

ost

Cos

t*R

etur

ned

Paym

ent C

harg

e$2

0.00

27,1

64B

ank

Cha

rge

N/A

$5 to

$10

$5.0

0$1

0.00

CC

O0.

0041

667

$36.

24$0

.15

$0.1

5Pa

ymen

t Sup

port

0.08

6666

67$5

5.56

$4.8

2$4

.82

Cus

tom

er C

are

0.03

3333

33$3

8.58

$1.2

9$1

.29

$11.

25$1

6.25

*Ban

k fe

es v

ary

depe

ndin

g on

the

bank

and

the

subm

issi

ons.

Cos

ts a

re a

rang

e.



T&

D O

pera

tions

Res

pons

esT

est P

erio

d: F

orec

ast t

est y

ear

endi

ng D

ecem

ber

31, 2

021

Cha

rge

Cur

rent

Fee

in E

ffec

tN

umbe

r of

tim

es fe

e ch

arge

d du

ring

his

tori

c pe

riod

Em

ploy

ee

clas

sific

atio

n co

mpl

etin

g w

ork

Act

ivity

Rat

e of

E

mpl

oyee

Ave

rage

tim

e fo

r em

ploy

ee p

erfo

rmin

g th

e w

ork

Ave

rage

trav

el ti

me

for

empl

oyee

per

form

ing

the

wor

kA

ctua

l Cos

tPo

le C

ut D

isco

nnec

t/Rec

onne

ct C

harg

e:

Nor

mal

Bus

ines

s Hou

rs

$1

25.0

019

Jour

neym

an$1

33.1

3$2

66.2

6

Tem

pora

ry S

ervi

ce C

harg

e fo

r Ser

vice

Dro

p an

d M

eter

Onl

y

Sing

le P

hase

$85.

0073

92Jo

urne

yman

$133

.13

$219

.66

Tem

pora

ry S

ervi

ce C

harg

e fo

r Ser

vice

Dro

p an

d M

eter

Onl

y

Thre

e-Ph

ase

$115

.00

10Jo

urne

yman

$133

.13

$219

.66

1.65

hou

rs

1.65

hou

rs

2 ho

urs



Proposed Paperless Credit Calculation

Average Cost of One Sheet Paper BillPaper $0.0107

Envelope $0.0382Printing and Mailing $0.0562

Postage $0.3910Total Cost $0.4961

Proposed Paperless Credit ($0.50)



rocky mountain power docket no. 20-035-04 witness: melissa ... · i. introduction and...

Documents