The staff gets really, really close to determining the probable cause of the most recent problem.
Of particular note is that on about April 1, 2012 MP and PE changed over from the prior Allegheny Power billing system to the billing system of FirstEnergy.
Within the eleven months prior to the initiation of the general investigation, customers of the Companies filed approximately 750 Requests for Assistance (RFAs) related to billing practices in addition to nearly seventy formal complaints.
Staff noted a significant increase in RFAs concerning the Companies' billings beginning in January 2013, particularly RFAs directly related to estimated bills.
The PSC isn't convinced that all the problems are "in the rearview mirror."
A major Staff concern is the future impact on MP and PE customers affected by recent problems whether storm related, related to meter reading staffing problems, or route renumbering projects that have been unreasonably billed. Since both estimation methods generally rely on historical usage data, how is MP, in the customer example of Attachment 3, going to produce reasonable usage estimates for that customer in the forthcoming "winter heating season" given the obviously bad usage data that has been generated? How for all other similarly affected MP and PE customers?
Staff is very concerned that the unreasonable billings sent to customers who previously received bills based on unreasonable estimates will be self-perpetuating. As both the estimation methods generally rely on historical usage data, it seems likely that MP and PE will produce unreasonable usage estimates in the future because they are relying on historical bad usage data the utilities based on bad estimates. Staff does not currently agree that the Companies' recently implemented initiatives, set forth on Page 14 of its report, are sufficient to resolve this proceeding without further investigation.
The Companies report that it reassigned meter readers to assist in storm restoration after Super Storm Sandy caused damage on October 30, 2012, which would account for MP averaging 27% of customers receiving consecutive estimated bills in November 2012 and PE averaging 23%. In December 2012, PE
continued to average 23% of customers receiving consecutive estimated bills and MP
averaged 31%. While Super Storm Sandy went through West Virginia on October 30, 2012 FirstEnergy's responses and responses to individual complaints indicate that meter readers were reassigned to assist in storm restoration which presumably accounts for the November 2012 27% for MP and 23% for PE, but fails to explain why December 2012 was even greater for MP at 31% and the same for PE at 23%.
Technical Staff believes the trends shown on Attachments 1 and 2 are indicative of problems with the Companies' billing practices and cannot be attributed solely to the Summer 2012 Derecho and Super Storm Sandy. The foregoing table and Attachments 1 and 2 indicate that MP and PE have current billing problems that are not likely to disappear because the causes of those problems occurred in the past such as from the Derecho and Hurricane Sandy.
After reviewing the Companies' report and their responses to discovery requests, Staff believes it requires additional information in order formulate final recommendations in this general investigation proceeding. Staff is seeking this information through a separately filed second set of discovery requests. Staff will continue to review this matter and submit final recommendations in accordance with a procedural schedule to be established by the Commission.