WV PSC Opens Investigation of FirstEnergy Billing Disaster

The WV PSC has opened a general investigation into the collapse of the billing system of FirstEnergy subsidiaries Mon Power and Potomac Edison in WV.  The case number at the PSC is 13-0830-E-GI.  You can see all activity in the case on the PSC Web site by plugging this case number into the blank on this page, and then choosing “Activity” from the resulting case information page.  You can also create an account with the PSC and receive email notices of all filings in the case at this page, using the same case number.

In its initial procedural order, the PSC has stated that it is not interested in hearing individual horror stories from rate payers:

The purpose of this general investigation is not to address individual customer bills directly. We recognize that considering the high level of formal and informal filings by individual customers to date, there may be a tendency for individuals to want to address their grievances in this proceeding. Each customer is entitled to specific evaluation of the particulars of individual billing and payment issues and such evaluation is best accomplished through the formal and informal review processes available for individual complaints. Customer-specific, formal and informal matters will continue to be resolved individually. This proceeding will focus on the practices, policies and procedures in place at Mon Power and PE and evaluate the strengths and weaknesses at a structural level.

So the investigation is an investigation of power company practices, not customer complaints.  Here is how the PSC will proceed with the investigation:

While the existing formal complaint and informal assistance mechanisms provided by the Commission are better suited to resolving individual billing disputes, the Commission believes that this number of similar complaints may indicate a wider underlying problem that must be identified and resolved. It also demonstrates a need for investigation of the meter reading, billing and customer service practices of FirstEnergy, particularly related to estimated and average billing. Therefore, the Commission will open a general investigation into these practices and will name both Mon Power and PE as respondents. , The Commission believes that the following issues are relevant to this general investigation:

1. Following the acquisition ofMon Power and PE in 2010, what changes, if any, to meter reading and customer billing has FirstEnergy implemented?

2. What data does FirstEnergy use to derive estimated or average bills?

3. To what extent has FirstEnergy reviewed or analyzed each current method of calculating estimated or averaged monthly bills of West Virginia customers after the acquisition of Mon Power and PE?

4. What was the effect of the severe storms in 2012 on how FirstEnergy calculated bills or its meter reading practices?

5. What is the total number of complaints received by First Energy from West Virginia customers about meter reading, estimated bills or average billing. Please provide a breakdown by complaint category.

6. What percentage of FirstEnergy customers in West Virginia had actual company employee meter readings (i) from one to five times per consecutive twelve month period, (ii) six times per consecutive twelve month period, (iii) more than six times per consecutive twelve month period over the last twenty-four consecutive months?

7. Did FirstEnergy maintain and incorporate historical billing data that pre-dated the merger into its calculation of estimated bills or average payment plans?

8. Describe in detail the manpower and equipment currently used to provide meter reading to Mon Power and PE customers and provide the same information for that activity prior to the FirstEnergy acquisition.

9. Describe in detail the manpower and equipment currently used to provide billing and customer service to Mon Power and PE customers and provide the same information for that activity prior to the FirstEnergy acquisition and after the FirstEnergy acquisition.

10. Describe the meter reading scheduling for Mon Power and PE, and describe the alternatives and options that are available to Mon Power and PE to reschedule or otherwise handle unexpected interruptions to normal meter reading schedules such as weather related incidents, unscheduled employee leave, transportation equipment failures or other such disruptive incidents.

11. Does FirstEnergy collect metrics regarding its customer service call center or other customer service contacts with ratepayers for any purpose including internal evaluations, planning and budgeting, or external reporting to other regulatory agencies? Provide a twenty-four month summary of each available customer service metric for all customers and separately for West Virginia customers along with a brief description of each metric.

12. What assistance does FirstEnergy provide to customers that receive large actual bills following a period of estimated bills?

Mon Power and PE will file a written response to the items listed above along with any other information that they deem relevant to the general investigation on or before the close of business on July l, 2013. After Mon Power and PE respond to this Order, Commission Staff will also file a response addressing the points listed above and the responses filed by FirstEnergy. Staff should also note any need for formal discovery as part of its investigation. Staff will file its response within fourteen days of the initial filing from FirstEnergy. After the Commission receives the initial filings from FirstEnergy and Staff, it will formulate a further procedural schedule.

Here is my suggestion to individual customers who want to file public comments.  Wait until the FirstEnergy companies and PSC staff file their responses to the Commission’s 12 questions.  Look at all the responses and determine from your own experience, and the experience of your neighbors whether you think those responses are accurate and truthful.  If you do not believe the answers are adequate, base your public comments on a specific criticism of why you think these responses are not accurate.

In other words, focus on rebutting the companies’ excuses rather than telling your own personal story.  The PSC Commissioners will be much more interested in your comments if they fit within the framework of the investigation they have created.

And my hat is off to all the citizens in the Eastern Panhandle who forced the PSC to open this investigation.  The PSC didn’t really listen to the little people until you got your legislators mobilized.  But you lit a fire under Del. Skinner, and he got the job done.

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