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Potomac Edison/Mon Power Investigation Briefs Summarize Lessons Unlearned by FirstEnergy

2/4/2014

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It appears that FirstEnergy didn't learn a thing from its recent trip to the PSC hot seat over the company's shocking disregard for its customers who were trampled on the way to "merger synergy savings."  FirstEnergy maintains that it never did anything wrong, but has magnanimously offered a few ineffectual parting gifts for its customers as a fig leaf to cover its hoped-for ruling by the Commission that would let the company off scot-free.

The PSC Staff and the Consumer Advocate Division have different ideas, and the Staff, in particular, rakes FirstEnergy over the coals in its own blistering brief.  That's all fine and good, but I hope a bunch of scathing words in a brief isn't all we get out of this.  Staff says:
The Companies responding to this General Investigation proceeding have provided a lot of excuses to the Commission as to why so many customers received multiple consecutive poorly estimated bills that led to dramatically high “true up” bills.
Originally, the Companies tried to convince the Commission and the public the problems
were mainly caused by the timing and size of the Derecho and Super Storm Sandy.
When the problems continued, the Companies started providing further excuses, but did
not take responsibility for their role in creating many of the problems themselves
and compounded the problem further by making unreasonable demands for payments from the impacted customers. In Staffs opinion, they still have not taken that responsibility.
The Derecho and Super Storm Sandy undeniably played a significant role in the problems underlying this case. However, all along the way, the Companies made poor decision after poor decision with little to no thought as to how it might impact their customers.
These poor decisions lead to multiple and continued violations of their tariffs. Staff takes
these violations very seriously and believes it is time the Companies own up to their mistakes and provide the Commission with concrete evidence these types of problems
will not reoccur. Further, the Companies should be required to either correct the ongoing problems with their estimation routine or switch from bi-monthly to monthly meter reading.
Oh, so it really wasn't about storms after all?  But FirstEnergy continues the storm drama charade.  Know how I know it's being over dramatized?  Because FirstEnergy included one too many adjectives in its brief:
Hurricane Sandy struck the service territories with large amounts of heavy, salt-laden, snow that tore down trees and power lines...
Really, FirstEnergy?  That's a meteorological first -- it snowed heavy "salt-laden" snow on the trees and power lines?  What the heck, FirstEnergy?  How does that happen?  How does the salt get into the atmosphere and how does it become encapsulated in snowflakes?  When "salt-laden" snow melts, does it leave a residue behind?  That defies common sense!  Got a little carried away there, didn't you?

So, what was the REAL cause of the problems?  Staff says:
It is easy, and some may say unfair, to play Monday morning quarterback with the decisions of the Companies. Staff does not believe it is unfair to do so in this circumstance. A poor decision here or there is just that, a decision that did not work out.
What we have here is something completely different, poor decision on top of poor
decision on top of devastating storms on top of more poor decisions with no management
thought of potential impacts to customers. This is a pattern of behavior. It appears FirstEnergy had a plan for integration and was determined to follow through with that
plan no matter the result. Little consideration was given to the customers, “merger
synergy savings”
had to be captured. Indeed the Companies suspected as early as
September of 2012 there may be problems, but did nothing to attempt to resolve them
until April 2013. At that point, the problems had become so widespread the Companies
had no choice but to try and address them. However, shockingly, the Companies
continue to act as though they were simply a victim of circumstance
. Generally, Staff believes the Commission should send a strong message to the Companies that this type of behavior will not be tolerated, that the Commission believes the Companies did indeed violate their tariff in multiple ways and that continued violations will be looked upon
very unfavorably.
The Consumer Advocate's brief was not kind either.  The Consumer Advocate is still requesting that FirstEnergy be ordered to read every meter, every month, for one year
Bad historical usage data begets bad data and, thus, CAD believes the only way to correct the problem caused by the Companies’ failure to conduct bi-monthly reads of residential meters is to obtain one year’s worth of reliable data from actual monthly meter reads. It is the goal of the CAD that this matter be resolved in the best possible manner for customers of MP and PE, who have undeniably suffered - and, in some instances, continue to suffer - the ill effects of the Companies’ meter reading and billing practices.
The Consumer Advocate also thinks the companies' storm excuses are a feeble attempt to pretend that the real culprit isn't the company's merger:
Throughout the course of this proceeding, the Companies have attempted to place the
majority of the blame for their billing and meter reading problems on the Derecho that occurred in June 2012 and Superstorm Sandy, which occurred in October 2012. However, while the storms may have exacerbated the Companies’ existing problem, it is inaccurate to contend that the storms caused the billing problems so many customers have faced. In actuality, the evidence shows that the merger of Allegheny Power into FirstEnergy in 2011 and subsequent transition issues in the wake of the merger, including understaffing, transitioning from the Allegheny billing system to the FirstEnergy billing system, and the questionable timing of the meter route “renumbering” project, created this problem.
The Consumer Advocate also noted that, contrary to the company's contentions, customer complaints have been trending up again this winter.  We ain't seen nothin' yet!  Underestimations in January bills, combined with this month's prolonged frigid temperatures, are sure to cause a charlie foxtrot of unprecedented proportions in February.  Enough is enough.

Even though FirstEnergy's EPRI report still seems to be suspiciously missing, it's time for the Commission to act, if nothing else than from a position of self-preservation.  I'm starting to lose track of all the "let's punish the PSC" legislation that's been introduced in Charleston this session.  Although we'd rather see the company punished for its transgressions, I guess someone has to take the fall for this.
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Potomac Edison's Estimated Bills Are More Screwed Up Than Ever

1/27/2014

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Yeah, I know, news flash, right?  But I was actually surprised to get my most recent estimated bill.  No, it wasn't because it took 10 long days to get here after it was issued.  And, no, it wasn't because it was all bulky like it contained a small booklet of some sort.

It's because the estimated usage was much lower than I was expecting, and just over half the amount actually showing on my meter.  I was expecting the usual larger than actual estimated bill again this month, especially because the actual from the same period last year was one of those outrageously high "catch up bills" resulting from the company's failure to read meters.

So, how did the company come up with this month's ridiculously low usage estimate?  If you sat through December's PSC hearing on the General Investigation of the company's billing, meter reading and customer service practices, you'd know that the company has two estimation routines in place.  One uses same period from prior year, adjusted to current weather and days in billing period.  The other uses prior month data.

A phone call to a delightful customer service representative named Kelly advised me that my bill was based on prior year actual.  Using the handy-dandy usage history graph on my current bill, I find that my last year same period was over 4,000 kwh.  So, Kelly informs me that because the company "renumbered" me and adjusted my billing period, the current estimate also used some data from the following month on my bar graph.  That month's usage was 2,406.  So, Potomac Edison's average of 4000 and 2406 is 2,576?  No wonder there's an investigation going on.  Helpful and pleasant Kelly offered to adjust my bill because we determined that my next month actual reading will produce an outrageous bill.  But, it really doesn't matter since I am on the average payment plan.  However, many Potomac Edison customers whose bills were estimated by the same method mine was this month may not be.  Those customers are going to get gigantic bills next month, bills they may be unable to pay.  As if that's not bad enough, the unusually cold weather is going to exacerbate this problem tremendously.

I thought I heard FirstEnergy telling the PSC Commissioners that it had solved all the estimation routine problems.  It looks like that's not true, and a whole new wave of unhappy customers is quietly building and should start crashing in during the month of February.  How much longer is this going to go on?  How much longer are West Virginians supposed to put up with this stunning incompetence?  Let's get with the program here, PSC!

So, in conclusion, let's add a little levity by going back to my intro. paragraph and examining the reason for my unusually bulky bill.  That was because it contained ELEVEN (11), count 'em 11, copies of this month's bill insert.  The insert urges me to sign up for FirstEnergy's eBill program so I can "use less paper" which "is better for the environment."  Right, FirstEnergy, as soon as you take your own advice.  And to add one last giggle on top, my customer service rep., Kelly, offered to send me some energy efficiency literature because that's what she's been instructed to do when she gets a high bill call.  But, wait a sec, FirstEnergy has been fighting against energy efficiency programs in West Virginia (and many other states).  As well, maybe customers wouldn't have such high bills if the company read every meter every month until it established accurate base data and corrected its hideously inaccurate estimation routines.  Does FirstEnergy have any literature on that problem?  Probably not.

Loving those "merger synergies," FirstEnergy!
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FirstEnergy Slashes Dividend - Sigh, Scribble, UT-OH!

1/22/2014

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Sometimes it's worth getting to work early to enjoy a little schadenfreude!  FirstEnergy put on a special show for investment analysts this morning in the wake of the company's announcement yesterday that it would FINALLY be cutting its dividend to reflect the mess our pal Tony the Trickster has made of the company.

Investors have long used the services of voice analysts to pick up clues that indicate CEO lying.  In response, companies have done a better job preparing their CEOs to mask verbal tells.  And then there was today's FirstEnergy call...  no fancy voice analyst needed!  It was obvious to anyone tuning in that Tony was very put upon to be there and have to answer questions.  Very pointed questions.

The call began with much heavy sighing and attitude, and if that wasn't enough, once the questions from analysts began, the sound of someone scribbling furiously on a piece of paper to feed answers to company officials kept getting louder... and louder... and louder.  Right.... that's the sound of a healthy company poised for enormous growth....

So, what's Tony's next great plan?  Betting on guaranteed earnings from FirstEnergy's regulated business.  If you've been listening in on the earnings calls of Ohio's utility Tweedledum and Tweedledee over the past few years, you may note that Tony the Trickster was so focused on "beating" rival AEP in the Ohio retail market, that he didn't see what was sneaking up behind him.  AEP was forced to retreat from its competitive business a lot sooner, because FirstEnergy was so willing to take quantity over quality in order to sign up the most customers in Ohio.  Fortunately for AEP, concentrating on its regulated business a lot sooner than FirstEnergy saved it from a lot of sighing and scribbling.

Oh, that competition thing... it can make smart men do really stupid things.  Tony the Trickster got all offended when asked if the company would need to continue to inject cash in its loser competitive business segment, or if that part of the business would begin supporting itself.  Truth hurts, doesn't it?

FirstEnergy finds itself squarely behind the curve now, so the next great plan is to start pumping money (i.e. "investing") into its regulated transmission business.  What can go wrong with this plan?  Lots. 

FirstEnergy also plans to file base rate cases in West Virginia and Pennsylvania this year, despite the fact that its JCP&L rate case in New Jersey hasn't actually "derisked" the company.  Tony forgot to tell analysts that it must file a West Virginia rate case as a result of its dumping of the Harrison power station into West Virginia's regulated system, not that it wants to file a rate case to increase earnings.

Tony says that "reality" caused the company to most effectively "reposition" itself because now is the time to make a move to eliminate uncertainty, speculation and rumors by refocusing the company.

You believe him, don't you?
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Where is FirstEnergy's EPRI Report?

1/14/2014

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During the West Virginia Public Service Commission's evidentiary hearing on the Potomac Edison/Mon Power Billing, Meter Reading and Customer Service Practices General Investigation, company witness Kaye Julian told the Commissioners that the EPRI report would be completed on January 6.
Q. Okay. All right. And you mentioned EPRI and the EPRI study, and I know that you --- while we’re on the subject, on page 11 of your testimony, your Direct testimony, you’d made a change at line eight. You state that the EPRI study is now expected to be completed by January 6th, 2014; correct?
A. Correct.
Q. Do you know why it’s been pushed back from December 31st?
A. I received an e-mail this morning from them requesting a little bit more time, because they’ve been meeting with the teams that actually were on site, and after they’ve had a couple of their meetings, they just feel like they’re going to need a little more time.
Q. Now, do you participate in these meetings? A. I have been.
Q. I’m sorry, you have been?
A. Yes.
Q. Okay.
A. Now, I have not been making every single one of them, but ---.
Q. I mean, they’re weekly meetings?
A. That’s right. Recently they had me come daily.
Q. Okay. When did this --- when did the EPRI review begin? I mean, it’s been several months now in the making; correct?
A. Yeah, I believe we signed the statement of work with them in July.
Q. And what are you --- what specifically are you --- are the Companies having EPRI look at? I mean, what is the purpose?
A. What we’re doing is we’re trying to simulate the estimation routine with having lots of good data, and then going through and creating all those scenarios of every other estimate --- every other month estimate, two months in a row estimate, three months in a row estimate, and letting the routine take that data and determining --- I guess we’re trying to figure out where are those checkpoints that we might need. Are we not applying something appropriately that we should be? So we’re more or less --- we’re calling it forensics. That’s basically what they’re doing for us, trying to help us determine, you know, with the data available where we see some issues or breakdown and how can we improve our routine.
Q. And is EPRI going to tell you how it should be improved, assuming it finds breakdowns?
A. Yes.
Q. Okay. Now, is the Company’s plan to implement whatever correction EPRI recommends?
A. I think it’s a little early for me to say that, because I don’t know all of the expense associated with what they would ask us to implement or recommend we implement.
Q. Okay. So there’s a chance that EPRI may say you need to do these 20 things, for example, and the Company says we don’t have the money or the resources to do any of those; we’re just going to disregard your recommendation? That’s a possibility; correct? A. Anything’s possible.
January 6 has come and gone, with the EPRI report still missing from the public information on the case docket.

I guess we should prepare ourselves for "possible."
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Frederick County Asks Potomac Edison to Donate Maryland PATH Substation Site

1/14/2014

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WFMD reports:
Frederick County Commissioner Billy Shreve is asking Potomac Edison to donate some land for a park; specifically, the 150-acre Browning Farm, where the utility was planning to build a substation for the Potomac Appalachian Transmission Highline.

He called it a win-win for First Energy and county citizens.
Frederick County citizens commenting on the article agree.  Potomac Edison has a lot of public image issues in Maryland right now stemming from the Maryland PSC's investigation of its billing and meter reading practices.

What do you think about the county's proposal?
5 Comments

Will FirstEnergy Lock Out Potomac Edison Meter Readers?

1/12/2014

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Just when Potomac Edison customers were getting used to having their electric meters read on some sort of regular schedule again...

The Herald-Mail reports:
FirstEnergy is trying to reach new labor agreements with two of its Utility Workers Union of America bargaining units.

They include Local 102, which represents several hundred workers in FirstEnergy’s Potomac Edison territory in Maryland and West Virginia and its West Penn Power territory in Pennsylvania.

The members of Local 102 are working as linemen, substation workers, meter readers and technicians.
In November, FirstEnergy locked out nearly 150 union workers at one of its Pennsylvania subsidiaries when contract negotiations broke down.  The company has been limping along by using contract workers and managers to perform the duties of locked out workers.

Now union-busting parent company FirstEnergy's labor dispute with Potomac Edison workers is heating up:
Robert Whalen, system president of Local 102, said Thursday that so far, FirstEnergy hasn’t threatened to lock out his Potomac Edison and West Penn members. Local 102 began contract talks with FirstEnergy in March 2013.

About 125 of Local 102’s members work at PE service centers in Williamsport; Frederick, Mount Airy and Thurmont, Md.; Martinsburg and Berkeley Springs, W.Va.; and Waynesboro and McConnellsburg, Pa.

Whalen said many of the company’s offers are unacceptable.

“Every benefit — health care, long-term disability, dental plan, vision plan, 401(k) — that’s in our contract now, they (FirstEnergy) want to make them completely at the discretion of FirstEnergy to modify, terminate or amend,” Whalen said.

Company spokesmen disputed such arguments, and said FirstEnergy’s offers have been fair.

The company is “cautiously optimistic we can come together on something,” spokesman Todd Meyers said about negotiations with Local 102. “I think we have a good offer.”

But as to the lockout in Pennsylvania, FirstEnergy spokesman Scott Surgeoner said the company isn’t backing down.

“We think our last best offer is very, very fair, and we are committed to seeing this lockout through,” Surgeoner said.
Wonder what this would do to FirstEnergy's little plan to read 10,000 West Virginia customers' meters monthly through January if they end up short-handed, or, horror of horrors, some doofus like Toad Meyers had to do some real work for a change and read meters?

And what if it snows?  Are we going to see Gary Jack scowling at downed wires from a bucket truck?
 

As fun as this sounds, I don't think it's a good idea.  FirstEnergy would do better letting qualified workers work and keep their "managers and supervisors" shuffling papers and making crap up for the media, where they belong.


FirstEnergy is failing its employees, its customers and its stockholders.


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FirstEnergy One of Forbes "Worst-Performing Stocks of 2013"

1/6/2014

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Wow!  Looks like FirstEnergy made all sorts of important lists in 2013!  Here's another stunning accomplishment for the company:
FirstEnergy and other utilities began to slide in May after Federal Reserve Chairman Ben Bernanke suggested that the central bank could begin go to pull back on its stimulus measures.

FirstEnergy, which serves 6 million customers across the Midwest and the Mid-Atlantic, also got hit after the company posted a nearly 50% drop in earnings for the third quarter due to cooler than usual summer temperatures cutting the need for air conditioning. Shares have recently been trading at their lowest levels in a decade.
The long, slow slide into irrelevance will be enjoyed by many!
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Residential Power Use Expected to Fall Again in 2014:  Utilities Continue Pollyanna Plans

1/4/2014

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Remember Jonathan Fahey?  He wrote an article in 2011 headlined Shocker: Power demand from US homes is falling that pioneered the idea that even though we're using more electric "gadgets" than ever, power use is dropping.  Well, now he's back with a similar article, Home electricity use in US falling to 2001 levels.
The trend Fahey first reported in 2011 continues, more than 2 years later.

Have utilities gotten any smarter since then?  Partially.  It took them forever to admit that dropping demand wasn't tied to the economy and that a rebound of electric use wasn't just over the horizon.  However, some utilities have simply moved on to other unsound business plans that continue to bank on the same old ideas that are no longer sustainable. 

Now utilities have moved on to transmission investments as their savior.  This is pretty puzzling, considering that long-distance transmission champion AEP concluded a year ago that enormous projects built across multiple states were an impossible dream.
Mr. Akins said he wants to avoid the bruising battles that delayed or doomed big projects in the past, like the 275-mile Potomac-Appalachian Transmission Highline project from West Virginia to Maryland. AEP and partner FirstEnergy Corp. dropped development plans for the complex project in 2011.

"Sometimes, we were just dreaming" that the companies could get enormous power lines built across multiple states, Mr. Akins said. He said AEP now is focusing on shorter projects blessed by federal regulators that eliminate grid bottlenecks. "It's where you want to put your money," he said.
The transmission investment gravy train has also left the station.  The sheer number of new transmission projects proposed combined with today's ease of online information sharing and social media tools has led to an explosion of knowledgeable, interconnected transmission opposition groups who are combining resources across the country to delay or stop unneeded projects altogether.

Instead of embracing innovation and new technology to make the existing grid smarter, some utilities are intent on merely building more of the same old dumb grid, or actively attempting to stifle innovation by forcing us all into an historic "consumer" position where we must funnel money to incumbent utilities in order to survive.  Ultimately, this plan will also fail, because technology marches relentlessly on. 

How we produce and use electricity is also changing.  Not only is producing our own electricity locally better for our economy, it's also much more reliable.  Hurricane Sandy was one of the biggest wake-up calls we've had recently, and the inevitable Monday morning quarterbacking of that disaster reveals that increasing long distance, aerial transmission from remote generation is simply dangerous.
  Making our grid more reliable isn't about building more transmission.  It's about change:
This includes traditional tactics, such as upgrading power poles and trimming trees near power lines. But it also encompasses newer approaches, such as microgrids and energy storage, which allow operators to quickly reconfigure the system when portions of the grid go down. Implicit to such plans is the need to ensure uninterrupted power to critical sites such as oil and gas refineries, water-treatment plants, and telecommunication networks, as well as gasoline stations, hospitals, and pharmacies.

Some of the nation’s leaders seem receptive to such approaches.
Elected officials, progressive regulators, energy producers, energy consumers, and innovative companies embracing new technology are also increasingly joining forces to move our energy economy forward and away from the dated centralized generation and transmission business plan of the past.  Companies who continue to deny the inevitable will ultimately be the ones left behind in irrelevance.
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Citi Says Sell FirstEnergy

1/3/2014

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Sell, sell, SELL!

Do you suppose the Citi analyst knows that FirstEnergy subsidiary Potomac Edison's crappy customer service was the #2 story in 2013 in its West Virginia service territory?
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Potomac Edison/Mon Power Billing & Meter Reading Investigation Evidentiary Hearing

12/29/2013

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The WV PSC's evidentiary hearing in the General Investigation of Potomac Edison and Mon Power Meter Reading, Billing and Customer Service Practices was held in Charleston December 17 -18.  If you didn't have an opportunity to watch the hearing live, never fear, we drove 12 hours, spent 2 nights in a hotel, talked to people we don't particularly like, fended off icy stares, and stayed awake for the entire thing in order to generate 13 pages of notes just so you can find out what happened.  The media took no notice of the event, even though FirstEnergy media personality Toad Meyers was there to act as their personal hearing interpreter.  Maybe they're waiting for him to share his notes...

If you've never watched one of these hearings, let's set the stage.  It's a quasi-judicial, court-like proceeding, sans robes and much of the formality.  This was an opportunity for the Commissioners to consider evidence and examine witnesses.  Witnesses sponsored by the parties to the case filed written testimony and rebuttals in advance.  At the hearing, the witnesses took the stand to have their testimony officially recognized and to give opposing parties a chance to cross examine them.  The Commissioners also took the opportunity to ask the witnesses questions.  The parties to this case are FirstEnergy's Potomac Edison and Mon Power utilities, the Staff of the PSC, and the Consumer Advocate Division of the PSC.  Between them, they produced 6 witnesses, 4 from the company, and one each from the Staff and the CAD.

FirstEnergy's first witness was John Hilderbrand, Director of Operations Support for Mon Power, who was grilled by the attorneys for CAD and Staff, and the Commissioners, for more than three hours.  From my notes:
  1. Exigent circumstances prevented the company from making bi-monthly reads as directed in its tariff.  The dreaded "exigent circumstances," or "EC" were defined as:  weather, access issues, unplanned absences and equipment failures.  Weather = ice, snow, rain, flooding that impedes access to meters. Access issues include a broad range of items such as new gates being erected, no keys being provided, meters on the interior of the home, animals, such as dogs.  Unplanned absences = sickness or illness, or 3 personal convenience days that can be used w/24 hour notice.
  2. Because the company has limited resources, they don't attempt to read in the month following a missed read, when an estimate is scheduled.
  3. Company now has 7 substitutes, or "rovers" to cover for unplanned absences.  This process began several months ago,  However, the company did not have substitute meter readers before that.  But, there may still be missed reads due to "EC" because there are only 7 rovers.
  4. The company was not adequately staffed to read meters for some period of time due to merger organization and that contributed to the problem.
  5. As a result of the merger, meter readers are devoted to meter reading only.  (Despite the fact that FirstEnergy was recently recruiting for meter readers that would also perform collection activities and disconnects and reconnects.)
  6. When meter readers transferred to other positions after the merger, FirstEnergy had to shift resources to read meters and catch up on missed reads.  FirstEnergy shifted resources 8/15/11 and again 4/2/2012.
  7. It takes 6 months to train a meter reader (but the company wants YOU to read your own meter with no training whatsoever!)
  8. Company has not researched how the storms affected other power companies, but AEP didn't have the same problems because their meter reading is automated and is a different process.
  9. The proposal to read meters every month for one year would increase the cost to WV ratepayers $5M.  But who said WV ratepayers would be paying for that?  Nobody.
  10. Renumbering is a "short term inconvenience to customers" but will make the process better in the long run.  Why not a short term inconvenience to the company?  It's good utility practice to see that reading is as efficient as possible.
  11. The company added renumbering to the existing staffing, merger transition and storm problems.  But it results in cost savings (for the company!)
  12. Readers hired since mid 2012 must use their own vehicles.  Decision was made as part of merger integration aligning practices across FE and the company always evaluates ways to deliver product cost effectively. 
  13. Meter readers using their own vehicle are paid IRS mileage rates and must carry certain insurance, although the FirstEnergy witness doesn't know how much.  "Most" personal vehicles used by meter readers are all-wheel drive, however that is not a requirement.  The supervisor inspects the vehicle monthly to ensure the vehicle can complete the route.  If a personal vehicle breaks down the company may facilitate getting it back on the road with a tow or a jump, but does not normally provide a back-up vehicle.  If a meter reader has continued vehicle issues, that affects the ability to get the job done.  Meter readers are not compensated if they don't get the job done.
  14. When asked about missed readings due to the Derecho, Hilderbrand's logic came up short.  Staff attorney John Auville walked him through a typical storm-altered read schedule:  The Derecho caused a missed read in the first half of July.  The August read was a scheduled estimate.  The meter should have been read in September, but was not.  Hilderbrand said the company was still not recovered from the Derecho and able to read meters in September.  Hilderbrand started talking about the dreaded EC again.
  15. On renumbering:  When you reorganize routes and shift between even and odd cycle reads, that results in some customers being estimated when due an actual read, or some customers receive back-to-back reads (is there anyone this happened to?  I'm still waiting for someone, anyone, to tell me they got back-to-back reads due to renumbering).  It was a poor decision to renumber the Eastern Panhandle in the winter.  Why didn’t FirstEnergy think of that beforehand?  The FirstEnergy staff had never renumbered before, so they didn’t understand it.
  16. FirstEnergy has selected 10,000 residential accounts for monthly reads between Nov. 2013 and Jan. 2014.  FirstEnergy has approximately 445,000 customers in WV.  At most, this provides one, maybe two additional reads for these customers.
  17. FirstEnergy has 16,920 "annual read" customers in WV.  An annual read customer is one whose meter is read only once per year.  Reasons for an account being designated "annual read" include:  Safety, access, customer request and seasonal.  The company is reviewing these accounts to make sure designation is correct, but has no plans to notify the customers of the review, the results, or notify them of their right to appeal the determination.  Maybe that would be a good idea.
  18. When a meter reading is considerably higher than expected based on prior reads, the reader's hand-held computer unit emits an audible tone that causes the reader to do an immediate re-check.  However, it's up to the reader and supervisor to set the parameters of error allowed.
  19. It would take up to a year to get staff in place to read every meter every month.
  20. If a reader has access issues, one of several form letters is sent to the customer to remedy the access issue.  If the customer fails to respond, the company may be more aggressive in turning off service.
  21. The company has a 3-day read window for each account during a scheduled read month.  If an unplanned absence occurs on the last day of the read window, it cannot be made up.  Note that the company can read your meter at any time within that 3-day window.
  22. Commissioner McKinney vigorously questioned this witness about meter readers driving their personal vehicles and identifying themselves and asked the company to look hard at providing some sort of "work around" in the case of a missed read.  Then he started in about renumbering, observing that the company could have chosen to read all meters during renumbering, but they didn’t choose to do that.  That’s a resource issue from Commissioner McKinney's perspective.  It was something the company made an intentional decision to do.
  23. Commissioner Albert wanted to know what was going on with the Maryland PSC billing investigation, but couldn't get a straight answer from the witness.
Second witness was Kaye Julian, Director of Customer Management.
  1. The system has calculated expected consumption and if it falls outside expectations, then it goes to billing personnel for review.  This is supposed to catch a large true up.  They could send a re-read order or a billing rep. would catch an obvious error.  But, if the reader has verified the reading (see #18 above), then they release it for billing.  Customer is not notified of the reason for such a high bill, but the company is considering doing that, along with giving the customer payment plan options.
  2. If a customer's history contains "bad data" (defined as inaccurate estimates) then it’s possible that the estimated reading is going to be inaccurate.  If there are more than 4 estimates, then "we do have issues."  The company has a levelizing routine for 4 estimates and are confident it’s correct.  But if there are more than 5 estimates in a row, it does not work.  Those customers go through an estimation routine that uses prior month usage to calculate current month estimate.  If the prior month was estimated, this would make the current estimate based on "bad data."
  3. The company's estimation routine did not perform as they intended it to.
  4. In April 2012, a computer system change (result of the company's merger) was made that changed the estimation routine.  Although Allegheny's estimation routine worked well, FirstEnergy "enhanced" it because it was not possible to retain the old and support the business environment we’re in.  In order to share resources it’s best to all be on the same platform – it’s about managing costs and best practice.
  5. Agrees that adding additional months to the levelizing routine may only add more "bad data" and that an average is only as good as the data used to create it.  If data is off, then estimate will be wrong.
  6. EPRI study of company estimation routine expected January 6.  EPRI has been meeting with FirstEnergy "team" and needs more time.  Weekly/daily meetings on review that began in July.  EPRI is trying to simulate estimation routine with good data and creating other scenarios with additional estimates.  EPRI will tell them how to improve. Too early to say if the company will do whatever EPRI recommends because the company doesn’t know how much it may cost.  Could reject EPRI's recommendation if it’s too expensive for the company.
  7. Regarding the 10,000 "special" customers who will receive monthly readings between Nov. & Jan. -- The system picked them based on the following criteria:  5 consecutive estimates in 2012 and more than 25% variance after an actual read.  Only accounts with 5 consecutive estimates because the company believes its levelizing routine for 4 or less estimates is accurate.  The purpose of actual reads is to replace "bad data" and high true-ups with actual reads because they could not be levelized.  The company will reassess these accounts at the end of January.  
  8. Doesn't think actual reads for a year would be necessary based on how the system works and based on read rates.  Not all customers were impacted like that. Not all accounts need special handling, just "anomalies" (10,000 accounts).
  9. Believes there's a difference between a high bill inquiry and a complaint.  Maybe the customer called simply because they didn't understand something about their high bill.
  10. FirstEnergy applied its own estimation routines used for monthly read accounts to Allegheny's bi-monthly read system, but doesn't believe that exacerbated the estimation problems.
  11. Chairman Albert asked what are "we" going to do with this thing?  Lots of customer issues, lack of confidence in the company’s processes.  To what extent is somebody going to suggest to us what needs to be done?  Julian responded that the company has discovered that their bills are confusing for customers.  Will enhance customer messaging on bill to let them know why there is a huge variance in the bill.  "Little idiosyncrasies"  came out.  Chairman Albert asked again about the Maryland PSC case and still got no answer.
FirstEnergy counsel helps out by asking witness on redirect if there is a similar billing problem in FirstEnergy's West Penn Power territory.  Julian says there is not because WPP didn't suffer the consequences of Hurricane Sandy.

Next witness was Gary Grant, FirstEnergy's Director of Customer Contact Centers:

  1. Companies have voluntarily implemented modified guidelines for payment plan procedures for high bills with no financial qualification.  Gives the customer a repayment period similar to the estimation period that caused the high bill.  Customer Service Reps. offer payment plans as an "opportunity" for customers, but only when they call and ask because each customer is "unique".  Hand-out refers to customers as "business partners."
  2. West Penn Power doesn't have high bill payment plans "at this scale" (not that they don't have the same high bill problems - see paragraph above).
  3. Disagrees that customers got rude treatment from customer service reps. Wait times at call center have decreased, and the company's robust quality assurance process ensures CSRs are not rude.  But did customers in fact express concern during the public hearings?  Yes, they said that.
  4. The company does not inform new customers about the company's bi-monthly reading practices, and if they did it would be an additional cost.
  5. Commissioner Palmer questioned this witness about hold times once initial contact is made.  These hold times are not counted in the company's ASA statistics.  The company tracks handle time for individual reps. as well as overall call center, and any hold time would count in the handle time metric.  They don't keep track of how long customers are on hold once answered.  The supervisor can see how long customer is on hold.  When asked if there will be any changes to the process, the witness said just payment plan and high bill refreshers for the CSRs.
  6. Chairman Albert asked what the harm was in informing the customer about bi-monthly reading when they apply for new service over the phone.  The witness said it would add seconds to the call.  Chairman Albert speculated that it would add about 3 seconds.
Next witness was Kevin Wise, Director of Rates and Regulatory Somethingorother:
  1. Witness claimed he had not seen the lawsuit filed by Potomac Edison customer John Kilroy in Jefferson County the day before.
  2. Said the company would never accept the $5 customer refund for a missed reading, even if exceptions were made for exigent circumstances.  Was asked how many times the company would be paying this fine.  Said there will always be meters that aren't read and would be estimated.
  3. Commissioner Palmer asked if the company had future renumbering projects planned.  Witness has no idea what the company's future plans may be.
Next witness, Suzanne Akers, Utility Analyst with the Consumer Advocate Division, was cross examined by FirstEnergy's counsel.
  1. Acknowledged that if the company were to read meters monthly for a year, it would take time to increase staff.  Could not answer if the cost of the extra readings would be recoverable in rates.  
  2. Was asked what she would do with those extra meter readers after the year.  Said perhaps they may still be needed.  Was asked if she would lay off those meter readers, because that might affect FirstEnergy's ability to hire workers.  (Hey, I didn't write this comedy, I'm just reporting here.)  Akers noted that many current meter readers are contract employees.
Final witness was Michael Fletcher, Deputy Director of Consumer Operations Section at the PSC:
  1. Part of his concern about changing to FirstEnergy's new estimation routine is that under Allegheny’s estimation process, the company did an analysis on the specific customer and had 5 estimating routines to fit different scenarios.  Allegheny used to look at what routine is appropriate and current system does not.
  2. Concerned that sequence of estimates are adjusted for weather, until there are too many estimates and then the routine changes to levelized midstream.
  3. FirstEnergy's counsel asked if the linear routine uses prior year historic data, and witness said it varied, either prior year or prior month, but neither estimate may be accurate.
  4. Witness said that the weather-adjusted estimates were put in place in a settlement in the 1990s and if the company wants to change them they should file a new tariff.
  5. The customer supplied meter reading should be used as supplied if within the company's 3-day read window.  (Note #21 under Hilderbrand.)  However, the company has been adjusting the customer-supplied reading to their scheduled read date within the window and then marking it as an estimate on the customer's bill.  The tariff supports Fletcher's interpretation.  Fletcher said that when the customer calls in a reading and the bill shows a different number coded as an estimate, that increases customer anger and complaints.
  6. FirstEnergy counsel asked Fletcher about several missed read situations and whether they would count as missed reads where the $5 refund applied.  Fletcher agreed that some would be exceptions.  Fletcher said the company needs to have enough back up meter readers to cover absences.  Sick or vacation excuses for not reading meters are not acceptable.  He understands the company can’t plan for every eventuality, but needs additional rovers to take up the slack for planned absences. If it’s the same problem that has brought us here because of poor planning, then the refund would apply.  The company says they have increased meter readers and fixed all the other problems, and if they have, it wouldn’t apply to anyone.
  7. The $5 customer charge includes the cost of reading, billing, maintenance, and parties may agree to include charges in there that are not direct customer costs. However, it's primarily related to those items in the Uniform System of Accounts that can be tied to the customer, even if the customer had zero usage.  The company’s cost to serve that customer, according to Wise’s testimony says the cost of meter reading is $1.19 (or $1.56 later in the testimony).  Meter reading has a $3.7M yearly cost.  There are other costs recovered in addition to meter reading.  Fletcher is not trying to compensate customer for company’s cost – he was picking easy number to reference ($5).
  8. FirstEnergy's counsel contends that the $5 refund is performance rate making (where there are penalties and rewards), but Fletcher's proposal has no reward.  Fletcher said the reward is not incurring the penalty. 
  9. Fletcher said if a customer got 5 consecutive estimates, it sends incorrect signals to the customer about energy use and is not fair to the customer.
  10. Chairman Albert questioned witness about exigent circumstances (EC) and whether or not EC can be verified how do we avoid more EC circumstances and whether discount should apply.  Aren’t we setting up a system with a penalty that would result in a bunch of contested cases?
If you found this summary interesting, or laughable, check back for links to the hearing transcripts, when they are available.

And now we wait for the Commission to issue an Order to fix this mess.  At some point, FirstEnergy has to right its wrongs and make amends to its customers.  Otherwise, this saga will simply continue in another venue.
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    About the Author

    Keryn Newman blogs here at StopPATH WV about energy issues, transmission policy, misguided regulation, our greedy energy companies and their corporate spin.
    In 2008, AEP & Allegheny Energy's PATH joint venture used their transmission line routing etch-a-sketch to draw a 765kV line across the street from her house. Oooops! And the rest is history.

    About
    StopPATH Blog

    StopPATH Blog began as a forum for information and opinion about the PATH transmission project.  The PATH project was abandoned in 2012, however, this blog was not.

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