The WV PSC staff filed a memo in the FirstEnergy General Investigation of customer service, billing and meter reading practices case yesterday.
The staff agrees with recommendations of many of the consumers who came before the Commission last month.
The staff requests the Companies provide the number of consecutively estimated readings for residential and non-residential customers separately.
As pointed out repeatedly by Jefferson County consumer Kery Fries, the companies have been skewing these statistics by including monthly read commercial customers in the numbers, but excluding annual read residential customers.
And speaking of those "annual read" customers, staff believes that FirstEnergy's policy of requiring meter readers to use their personal vehicles is causing too many customers to be designated as "annual read" customers.
The staff agrees with recommendations of many of the consumers who came before the Commission last month.
The staff requests the Companies provide the number of consecutively estimated readings for residential and non-residential customers separately.
As pointed out repeatedly by Jefferson County consumer Kery Fries, the companies have been skewing these statistics by including monthly read commercial customers in the numbers, but excluding annual read residential customers.
And speaking of those "annual read" customers, staff believes that FirstEnergy's policy of requiring meter readers to use their personal vehicles is causing too many customers to be designated as "annual read" customers.
According to the MP and PE response dated October 14,2013 to Commission Question No. 3 both MP and PE currently employ more than the number of budgeted meter readers. Based on an informal meeting on October 10, 20 13 between Staff and MP and PE some of the above budgeted meter readers are “floaters” or “rovers” used to address both planned and unplanned meter reader absences. During the October 1Oth meeting it was confirmed that since April 2012
full time and contract meter readers are required to use personal vehicles which, according to the utilities are subject to monthly inspections. While not necessarily an unreasonable practice Staff has concerns that requiring meter readers to use personal vehicles may bias the utilities’ determination of which customers are annual read customers using stated criteria of remote access and or safety where for example “Safety is defined as anything that may pose a hazard to the meter reader or his/her vehicle.” (FirstEnergy Supplemental Response dated 8/30/13, Emphasis Added.)
In other words, if your non-union meter reader drives a lowrider hooptie you may be designated an "annual read" customer, whereas if your meter reader was driving a company-owned 4WD pick up designed for higher clearance and better traction, you might receive readings more often.
The staff also takes exception to the company's refusal to provide data on the number of complaints it has received from customers.
Mr. Fletcher notes the Companies have not provided answers to question 7 from the Commission: “The number of complaints handled by the customer contact center with a breakdown by complaint type.” The Companies have responded that the tracking of complaints is not done through a customer contact. The only information supplied in answer to this request is a regurgitation of the formal and informal complaints filed before the Commission. Mr. Fletcher states Electric Rule 2.1.a requires utilities to maintain the records required by the Electric Rules and Electric Rule 5.5 requires the utilities to keep detailed records of adjustments t o customer accounts and detailed records of high bill complaints. It appears to Mr. Fletcher the Companies have not been in compliance with these sections of the Electric Rules.
Well, sweet! If Potomac Edison has to count every call that resulted in an adjustment to the customer's bill, I'm probably good for 5 or 6 myself. If done Potomac Edison's way, my "complaints" probably wouldn't register. Remember, Potomac Edison doesn't have a "complaint department" according to one of the customers who spoke in Shepherdstown.
I'm not really on board with the staff's analysis and recommendation regarding customer-supplied meter readings, though. Staff seems to be under the impression that multiple bills are generated when a customer calls in a meter reading after receiving an incorrectly estimated bill. While the customer will receive a new bill (and is informed of that during the phone call), the multiple bills customers have been complaining about are randomly generated at company initiative. When FirstEnergy makes an internal adjustment to a customer's account without the customer's knowledge, a bill is generated. These bills are being mailed to the customer, instead of being culled from the outgoing bill stream. In-house adjustments should appear as line items on a customer's regular monthly bill, not as separate "restatements" of previously billed amounts mailed to the customer.
Also, the staff doesn't seem to see the problem with customers continuing to do the meter reader's job and call in their readings. With very few exceptions, customers don't want to read their own meters when they are paying the company to do so. Some do simply because they cannot afford to pay an incorrect bill, but this shouldn't be a requirement.
Staff recommends that pre-billing customer reads be done within a window of time, instead of on a certain day, and that post-billing customer reads only be accepted for a difference greater than 10%.
Staff also agrees with us that FirstEnergy has not fixed the problems with its estimation routine, but fails to recommend any corrective action.
I'm not really on board with the staff's analysis and recommendation regarding customer-supplied meter readings, though. Staff seems to be under the impression that multiple bills are generated when a customer calls in a meter reading after receiving an incorrectly estimated bill. While the customer will receive a new bill (and is informed of that during the phone call), the multiple bills customers have been complaining about are randomly generated at company initiative. When FirstEnergy makes an internal adjustment to a customer's account without the customer's knowledge, a bill is generated. These bills are being mailed to the customer, instead of being culled from the outgoing bill stream. In-house adjustments should appear as line items on a customer's regular monthly bill, not as separate "restatements" of previously billed amounts mailed to the customer.
Also, the staff doesn't seem to see the problem with customers continuing to do the meter reader's job and call in their readings. With very few exceptions, customers don't want to read their own meters when they are paying the company to do so. Some do simply because they cannot afford to pay an incorrect bill, but this shouldn't be a requirement.
Staff recommends that pre-billing customer reads be done within a window of time, instead of on a certain day, and that post-billing customer reads only be accepted for a difference greater than 10%.
Staff also agrees with us that FirstEnergy has not fixed the problems with its estimation routine, but fails to recommend any corrective action.
Staff remains concerned about the prospects for an increase in MP and PE complaints during the forthcoming winter heating season. The October 14thmonthly report states no changes have been made to the estimation routine “this month” pending completion of EPRI’s review. Staff notes that some changes have been made to the estimation routines based on the FirstEnergy response dated August 2,2013 to Staffs Second Data Request Question No. 3. Staffs review of numerous billing and usage histories associated with complaints received by the Commission show the majority of such histories for individual complainants contain numerous months from the summer of 20 12 through the summer of 20 13 with “bad” data. “Bad” in that several consecutive low estimated monthly usages are followed by a month with significantly large “true up’’ actual usage. The large “true up” actual then tends to bias upwards the subsequent estimates. These trends were illustrated by Attachment 3 to Staffs July 15thInitial Memorandum and Staff has subsequently observed the repetition of those trends many times. Consequently, regardless of how theoretically sound the estimation routines are or might be improved to be, Staff is concerned that “bad” data generated in 2012-2013 will produce unreliable future estimate usages for the same customers.
And? Is there a page missing here? Let's get this fixed, before the winter heating season really gets underway and the service shutoffs begin. They're still happening.
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