Reply briefs were filed on Monday that pretty much wrap up the participatory phase. The only thing left to do is for the Commissioners to issue an Order demonstrating that they take their responsibility to protect West Virginians seriously.
The Consumer Advocate Division's reply brief continues to call for the companies to read every meter every month for one year in order to expunge accumulated "bad data" upon which future estimates are based. The CAD notes that the EPRI study does not even mention incorrect historical data being used as the basis for the estimate.
I note that EPRI used a set of "good data" to set up its billing estimate experiment.
But, everything you need to know can be found in PSC Staff's short and sweet reply:
Staff has reviewed the initial briefs filed in this matter and finds it has very little to
respond to. Actually, the initial brief of the Companies and the most recently filed
monthly statistical report confirms many of Staffs fears. The Companies are still
providing a lot of excuses without many answers. They continue to point the finger at the Derecho and Super Storm Sandy, when the truth of the matter is those two storms did not cause this problem, but simply exposed the problems within the Companies that were
destined to arise and will do so again if changes aren’t made.* Further, a review of the February monthly statistical report shows an increase in consecutive reads due to weather related causes, just as Staff suspected. That will continue to be a problem as long as there is weather. Also, as Staff suspected, the Companies cannot or are not willing to seek a modification to its billing system to allow manual changes to a customer’s account when it is shown the estimation routine is inaccurate for that customer. These are just a few examples of many where Staff fears have been confirmed.
Also, Staff finds it odd that the Companies dedicate such a large portion of its
brief arguing why the Commission should not impose the “penalty” provision for missed
meter reads when they claim this problem has been solved. If the problem has indeed
been solved and given the concessions Staff made for reasonable circumstances to avoid the penalty, these penalties should seldom come into play if at all. Again, it is important
to remember the Companies are required to read every meter bi-monthly, absent exigent
circumstances, not just the ones that are convenient at the time. Further, the Commission has approved similar service based performance credits in the past, specifically in the settlement in the Verizon quality of service case, Case No. 08-0761-T-GI. This circumstance is almost unprecedented in West Virginia and calls for bold action. This penalty provision is just that action, a stick in order to incentivize the Companies to make better decisions in the future to the benefit of their customers instead of to the benefit of the Companies.
*In their Initial Brief, the Companies state they have had no problems in Pennsylvania as evidence that the Derecho and Super Storm Sandy were the root causes of these problems. Staff has learned that on February 4, 2014, a complaint was filed by the Utility Workers Union of America against Penelec on behalf of its workers and individual customers for failure to properly staff the meter reading section and for failure to obtain meter readings, leading to three, four, five consecutive estimated readings.
It would be nice if the Commission issued a quick decision holding the company accountable for its transgressions. However, if the Commission waits to see how many new complaints are filed in the month of February, I'm okay with that too. It seems that something went horribly awry with the companies' January estimates that resulted in substantial underestimation. This problem was compounded by the prolonged period of cold weather, and has resulted in February bills that are hundreds of dollars higher than normal when an actual meter reading is performed.
Ut-oh. When do the service shutoffs begin this year? Deja vu.