Before the Minnesota Public Utilities Commission State of Minnesota. Docket No. E002/GR Exhibit (MCG-1) Customer Care and Bad Debt Expense

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1 Direct Testimony and Schedules Michael C. Gersack Before the Minnesota Public Utilities Commission State of Minnesota In the Matter of the Application of Northern States Power Company for Authority to Increase Rates for Electric Service in Minnesota Docket No. E00/GR-1- Exhibit (MCG-1) Customer Care and Bad Debt Expense November, 01

2 Table of Contents I. Introduction 1 II. Customer Care Organization A. Overview B. Test Year O&M Budget Overall Customer Care C. O&M Budgets by Business Function 1 1. Billing Services 1. Customer Contact Center 1. Credit and Collections 1. Customer Operations 1. Meter Reading and Field Collections 1 III. Commodity Bad Debt Expense 1 A. Introduction 1 B. Bad Debt Expense Budget and Forecast Process C. Test Year Bad Debt Calculation 1. Bad Debt Ratio and Trend. Bad Debt Expense and Trend D. Allocation Methodology 1 IV. Non-Commodity Bad Debt Expense V. Proposed New Bill Payment Assistance Program VI. Annual Incentive Program VII. Conclusion i Docket No. E00/GR-1-

3 Schedules Resume Schedule 1 Customer Care O&M Expense Levels Schedule Voice of the Customer Relationship (VOC) Survey Schedule Xcel Energy Write-Off Policy Schedule Summary Base Cost of Fuel Calculation Schedule Bad Debt Ratio Calculation Schedule Commodity Bad Debt Expense Schedule FERC 0 Comparison Schedule Non-Commodity Non-Energy Bad Debt Expense Schedule Pre-Filed Discovery Appendix A ii Docket No. E00/GR-1-

4 I. INTRODUCTION Q. PLEASE STATE YOUR NAME AND OCCUPATION. A. My name is Michael C. Gersack. I am Vice President of Customer Care for Xcel Energy Services Inc. (XES), which provides services to Northern States Power Company (NSPM or the Company). Q. PLEASE SUMMARIZE YOUR QUALIFICATIONS AND EXPERIENCE. A. I have more than 0 years of experience in the areas of customer service, accounting, and finance. In my current position, I am responsible for the overall business performance of the Customer Care organization. Prior to this, I held various operational, accounting and financial positions supporting Xcel Energy s distribution, marketing, transmission, and customer service functions. Before joining Xcel Energy, I held similar positions with KN Energy. My resume is provided as Exhibit (MCG-1), Schedule 1. Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? A. My testimony provides an overview of the Customer Care organization and its Operation and Maintenance (O&M) expense levels. I share insights into the research we do with our customers to measure their satisfaction, and to determine how we can best meet their needs on an ongoing basis. I also present and discuss the Company s commodity and noncommodity bad debt expense, and the actions we have taken to minimize and manage it to the benefit of customers. Finally, I address opportunities related to the Company s low income and senior programs, and the Customer Care organization s goals that support Xcel Energy s Annual Incentive Program (AIP). 1 Docket No. E00/GR-1-

5 Q. PLEASE SUMMARIZE YOUR TESTIMONY. A. The Customer Care organization has achieved strong customer satisfaction results, controlled its O&M expenses, and outperformed other utilities in managing bad debt expense. The 01 test year O&M expense I propose for the Customer Care organization is $.1 million for the State of Minnesota Electric Jurisdiction. This level of O&M expense continues Customer Care s trend of relatively flat levels of O&M expense since 01 while at the same time continuing to achieve strong results in the Company s service quality measures and high levels of satisfaction with the service we provide our customers. The 01 test year bad debt ratio we propose is 0. percent, which results in a 01 test year commodity bad debt expense of $. million for the State of Minnesota Electric Jurisdiction. In addition to comparing favorably to other utilities, this bad debt ratio is lower than 01, and maintains our trend of declining and moderated bad debt expense that began in 00. I am also excited to propose a new bill payment assistance program for lower income seniors and those with certified medical conditions. The Company recognizes the income limitations of existing programs and is offering an opportunity for currently ineligible customers to receive benefits from this expanded program. Q. HOW IS YOUR TESTIMONY ORGANIZED? A. I present the remainder of my testimony in the following sections: Customer Care Organization. I discuss my organization in terms of the business functions it provides to the Company and its customers. I also discuss the improvements we have made to various aspects of our Docket No. E00/GR-1-

6 service, research done to understand our customers and to measure their satisfaction with the service we provide and, I summarize the Company s service quality results. In this section, I also present the overall Customer Care O&M budget and the budgets by business function. Commodity Bad Debt Expense. This is the bad debt expense associated with the provision of electric and natural gas energy services. I discuss the test year expense and proposed bad debt ratios, as well as how we determine our bad debt ratios and manage our bad debt expense. Non-Commodity Bad Debt Expense. This is bad debt expense associated with all types of retail customer billing, other than the provision of energy services. I discuss the Company s test year levels of expense, the various components of non-commodity bad debt expense, and what the various business functions do to manage non-commodity bad debt expense. Bill Payment Assistance Programs. In this section, I discuss our proposal to expand bill payment assistance to seniors and customers with certified medical conditions. This program expands bill payment assistance benefits to customers just over income guidelines for other federal and Company-managed programs. Annual Incentive Plan Goals. The Customer Care Key Performance Indicators align with the Company s priorities and factors that are most important to delivering quality service to its customers. We base our targets on actual past performance, and expect either improved results or maintained high performance in each goal area each year, with the test year targets in this case being no different. Docket No. E00/GR-1-

7 Q. DO YOU PROVIDE ANY ADDITIONAL INFORMATION RELATED TO THE CUSTOMER CARE ORGANIZATION AS PART OF YOUR DIRECT TESTIMONY? A. Yes. To prepare testimony for this case, we reviewed the discovery related to the Customer Care organization from the 01 test year rate case. We incorporated much of this discovery into my testimony through expanded discussion and schedules. 1 II. CUSTOMER CARE ORGANIZATION A. Overview Q. PLEASE SUMMARIZE THIS SECTION OF YOUR TESTIMONY. A. In this section, I discuss the fundamental goals of the Customer Care organization and how they align with the Company s overall goals. I also discuss the structure of my organization, outlining the various functions involved in providing service to the Xcel Energy organization, including NSPM and the other Operating Companies and their customers. In addition, I highlight new customer options that we have implemented to enhance our service. Finally, I present the Company s test year O&M expense, and discuss how we have managed to keep O&M expenses relatively flat since 00 while introducing new customer programs and options and improving customer satisfaction. Q. PLEASE DISCUSS THE FUNDAMENTAL GOALS OF THE CUSTOMER CARE ORGANIZATION AND HOW THEY RELATE TO THE COMPANY S OVERALL BUSINESS GOALS. 1 The Appendix A Index provides a list of relevant information requests from the 1-1 and 1- rate cases that I have addressed in this case (applying new time frames as appropriate to reflect the November, 01 filing date) and indicates where the responsive information is included in my testimony or schedules. Docket No. E00/GR-1-

8 A. The Customer Care organization performs essential functions that help the Company effectively provide its customers energy products and services and high levels of customer service. We ensure energy use is measured and billed accurately, collect and process customer payments, and assist our customers with questions, concerns or requests about their energy services. For most customers, Customer Care is the main point of contact with the Company. We understand customer needs and expectations are evolving in the energy marketplace. We strive to meet those changing needs through improved communication, energy consulting and information, and automated functionality intended to improve the customers experience. We recognize that our organization is critical to the Company s long-term vision of becoming more customer-centric as we strive to be the trusted and preferred provider of energy services in an increasingly competitive marketplace. Q. PLEASE PROVIDE AN OVERVIEW OF THE CUSTOMER CARE ORGANIZATION AND HOW THE ORGANIZATION SUPPORTS THESE COMPANY EFFORTS. A. The Customer Care organization provides service to approximately. million electric and million natural gas retail customers served by the various Xcel Energy Operating Companies. We support customers starting when they initiate their energy service, as we collect ongoing meter readings and issue bills, through posting their payments to their accounts. We are available to customers hours a day, seven days a week, via phone, web, mobile, and various social media. We consider customer survey data and other feedback, and use it to assess our performance and opportunities for improvement. Below is a brief description of the various business functions that comprise the Customer Care organization: Docket No. E00/GR-1-

9 Billing Services. Responsible for the production and delivery of billing statements, researching billing inquiries and resolving related customer issues, and receiving and posting all customer receipts. Contact Center. Responsible for interacting with our customers, answering their questions, resolving their concerns, and fulfilling their requests including communication during power outages or other significant events. Credit and Collections. Responsible for accounts receivable management, minimizing customer receivable write-offs and operation of credit contact centers. Customer Operations. Responsible for staff training, quality control, process efficiencies, operational management and reporting, resolving customer complaints, communications within the organization, customer policy and low income programs. Meter Reading and Field Collections. Responsible for reading customer meters and performing field disconnection and collection activities. Q. WHAT TYPE OF TECHNOLOGY IMPROVEMENTS HAS THE COMPANY MADE RECENTLY TO ENHANCE ITS SERVICE TO CUSTOMERS? A. In the last few years, we have implemented many enhancements to our online customer tools, as well as increased options for customers to get notifications for certain events and transactions. With respect to online improvements, we re-designed our web and mobile sites to align with the moments that matter most to customers starting service, providing information about a power outage, paying a bill, and managing energy choices. Docket No. E00/GR-1-

10 We also established the My Energy portal within MyAccount on xcelenergy.com, where customers can learn more about their energy use and ways to save energy. We enabled customers ability to report a power outage via our website using a computer or mobile device. We also improved our outage map functionality, allowing anyone visiting our website to geographically view power outages occurring on our system at that time. In terms of customer notification enhancements, we enabled customers ability to specify their contact preferences telling us how they prefer us to interact with them, such as text, , or phone including the time of day they want us to make contact. Customers can save these preferences for ongoing notifications in the areas of billing reminders, payment confirmation, and outages or they can specify them as a one-time preference for a specific power outage event. Since we began allowing customers to save their contact preferences earlier in 01, over,000 Minnesota customers have signed up to receive ongoing notifications through a specified contact preference. Overall, this enhancement has provided a significant improvement to our customers experience in doing business with us in terms of ease-of-use, access to event and account information, and affording customers choice and control in how we interact, which we know is an area of growing importance. Q. DO YOU USE OTHER ONLINE OR TECHNOLOGY TOOLS TO INTERACT WITH CUSTOMERS? A. Yes. We continue to interact with customers over and social media channels such as Facebook and Twitter. Social media has been an effective addition to our communication channels that allows us to efficiently interact Docket No. E00/GR-1-

11 with our customers. Based on feedback, our customers have said that they find these means of communication valuable, especially during weather-related events. Our Interactive Voice Response (IVR) automated phone system is another important tool customers use to conduct quick and easy transactions without the need to speak with a customer service representative. We actively manage this tool, making enhancements to ensure customers experience highly satisfying and efficient transactions. Recent improvements include updating our menus and providing advanced options for customers to make payment arrangements without the need to speak with a customer service representative. As I discuss further in Section II.B below, our customers use the IVR system extensively and are very satisfied with it. Q. ARE YOU SEEING ANY AREAS OF EVOLVING CUSTOMER EXPECTATIONS? A. Customers expect choices when it comes to billing and payment options, as well as how they interact with Xcel Energy. Research done by J.D. Power indicates that utility customers expect their choices to continue to grow and that being in control of their energy decisions helps them manage their energy bills and make informed choices that best fit their lifestyle. Q. DO YOU HAVE AN EXAMPLE OF WHERE CUSTOMERS CURRENTLY APPRECIATE HAVING OPTIONS AVAILABLE TO THEM? A. Yes. We currently offer several payment alternatives to our customers, which we group into four payment channels: Mail, Phone, Electronic, and Other. Customers can pay their bills by phone, and either complete the payment using our IVR system or by talking to a customer service representative. Customers can also use the Company s online MyAccount portal to pay their Docket No. E00/GR-1-

12 bill electronically, or they can pay their bill at pay stations in locations such as grocery stores, K-Marts and WalMarts. Business customers have an additional option to pay their bills through Electronic Funds Transfer. As shown in Figure 1 below, a declining number of customers are submitting their payments through the mail and are increasingly taking advantage of electronic payment options. In addition to being more convenient for a significant number of customers, this shift creates efficiencies for the Company, as the use of any electronic channel helps reduce overall billing costs. Figure 1 Average Monthly Customer Payments by Channel Xcel Energy 0% 0% 0% 0% 0% 0% 0% 0% 0% % 0% thru July B. Test Year O&M Budget Overall Customer Care Q. HOW DOES THE CUSTOMER CARE ORGANIZATION DEVELOP ITS PLANS AND BUDGETS? Electronic Mail Phone Other A. We assess the needs of the Customer Care organization and the various The Electronic payment channel includes payments through My Account, CheckFree, auto payments, and electronic funds/wire transfers. The Other payment channel includes payments through pay stations, credit/debit cards through a contracted vendor, energy assistance payments, and payments from collection activities. Docket No. E00/GR-1-

13 Operating Companies we support, and plan and budget at the business function level. This is necessary given the variety of services provided by the different business functions that make-up the Customer Care organization. Unless otherwise noted, this discussion relates to Customer Care O&M at the NSPM Electric level. Q. PLEASE PROVIDE AN OVERVIEW OF THE CUSTOMER CARE O&M BUDGET. A. Figure below summarizes the overall Customer Care O&M expense since 01. Please see Exhibit (MCG-1), Schedule for additional details regarding Customer Care O&M expense levels. Customer Care O&M - NSP Electric ($Millions) Figure Customer Care O&M Trend NSPM Electric $0 $0 $0 $0 $0 $0 $0 $ $ JF 01TY Overall, the Customer Care 01 O&M is slightly higher than 01. The total 01 Customer Care test year O&M expense of $. million is roughly equivalent to what it was in 01, with slight variations up and down over the Company witness Mr. Adam R. Dietenberger explains how the Company allocates and assigns Xcel Energy Service Company costs to the NSPM Operating Company. Company witness Ms. Anne E. Heuer explains the utility and jurisdictional allocation process that assigns NSPM operating company costs to the State of Minnesota Electric Jurisdiction. Docket No. E00/GR-1-

14 timeframe. In comparison to 01, the most recent year of available actuals, the total 01 test year Customer Care O&M budget is projected to be approximately. percent higher. This increase is primarily driven by increased O&M in the Company s Meter Reading and Field Collections area, which I discuss in more detail below. Q. WHAT CUSTOMER CARE O&M EXPENSE LEVELS DOES THE COMPANY REQUEST RECOVERY OF FOR THE 01 AND 01 PLAN YEARS? A. I discuss the drivers of Customer Care s O & M expenses in 01 and 01 below. However, Company witness Mr. Aakash H. Chandarana explains the basis of the Company s overall approach to its O&M expense requests for the 01 and 01 plan years and the general use of electric industry index factors for these expenses; Company witnesses Mr. Charles R. Burdick and Mr. John Mothersole explain the basis for the Company s selection of the particular factors used in our rate requests for these years. Q. PLEASE SUMMARIZE KEY ASPECTS IMPACTING CUSTOMER CARE EXPENSE LEVELS IN 01 AND 01. A. As shown in our 01 and 01 supporting information provided in Volume of our Initial Filing, Customer Care will see the need for changes in its O&M expenses in the areas of overall Labor and Outside Services costs, which I discuss below. Q. PLEASE EXPLAIN THE PURPOSE AND IMPACT OF THE KEY COST DRIVERS ON CUSTOMER CARE S 01 O&M EXPENSES. A. From 01 to 01, we anticipate an increase of $01, in labor costs due to a three percent merit increase impacting most Customer Care business areas, as well as a meter reading severance accrual adjustment. We anticipate that Docket No. E00/GR-1-

15 these drivers will be partially offset by staffing level decreases in our customer contact centers as a result of an adjustment to forecasted workload needs and our decision to not backfill anticipated retirements in credit and collections. In the area of Outside Services, we anticipate an increase of $1, associated with meter reading contract cost escalation, partially offset by lower billing-related costs. Q. PLEASE EXPLAIN THE PURPOSE AND IMPACT OF THE KEY COST DRIVERS ON CUSTOMER CARE S 01 O&M EXPENSES. A. From 01 to 01, we anticipate an increase of $, due to higher labor costs in several Customer Care business areas as a result of a three percent merit increase for employees in these business areas. We anticipate that these increased labor costs will be partially offset by lower labor costs in meter reading, due to not hiring seasonal field collectors. In Outside Services, we expect an increase of $,0 due to higher costs primarily in meter reading due to contractual cost escalation. In addition, we expect an increase of $, due to higher postage costs resulting from increasing postal rates and volumes. We note, however, that we have factored in higher levels of customer participation in our electronic billing and payment programs, which serves to offset higher postal rates. Q. GIVEN THE IDENTIFICATION OF THESE DRIVERS, WHY DO YOU BELIEVE IT IS APPROPRIATE TO UTILIZE AN INDEX FOR 01 AND 01 O&M COSTS? A. Mr. Chandarana and Mr. Burdick discuss this in more detail. However, as I have discussed, Customer Care has worked to keep our O&M costs within a reasonable range of year-over-year average increases. The application of an index to Company O&M to set future rates is appropriate given our consistency in limiting increases in O&M costs to reasonable levels. Further, 1 Docket No. E00/GR-1-

16 while actual O&M costs of Customer Care may vary somewhat from the indexed costs, as Customer Care is operating within a broader Company budget where overall cost increases are managed across Business Areas, the specific Business Areas can manage this variability to keep total O&M costs reasonably close to the indexed increases. As a result, application of an index for ratemaking is also consistent with how the Business Areas and the Company manage to reasonable O&M budgets. Q. HOW HAS THE COMPANY BEEN ABLE TO KEEP ITS O&M BUDGET RELATIVELY FLAT OVER SUCH A LONG PERIOD OF TIME? A. We have largely been able to achieve such favorable results by deploying new technologies to automate work processes and focusing on operational performance improvements. Q. GIVEN THE RELATIVELY FLAT O&M OVER THE PAST SEVERAL YEARS, HAVE YOU SEEN A NEGATIVE IMPACT TO CUSTOMERS? A. No. In fact, we have seen continued improvement in the results from the Company s Voice of the Customer (VOC) Transaction survey that measures satisfaction of customers shortly after they contact the Company to conduct business. The Company s VOC Transaction survey is the most direct measure of the service provided by the Customer Care organization. As shown in Table 1 below, our VOC transaction results have steadily improved since 01, meaning that customers satisfaction with their interaction with the Company has increased over the same period. 1 Docket No. E00/GR-1-

17 Table 1 Voice of the Customer Transaction Survey Minnesota Electric (Percentage of Customers Providing a Positive Rating) Overall Satisfaction with Transaction 0.% 1.%.% IVR Overall Satisfaction with Transaction.%.%.% I provide more information regarding customers overall satisfaction with the Company in Exhibit (MCG-1), Schedule. Q. ARE THERE OTHER INDICATORS THAT REFLECT THAT YOU ARE MEETING CUSTOMER EXPECTATIONS? A. Yes. In addition to achieving high customer satisfaction levels over this period, the Company has consistently met the service quality performance measures contained in its Minnesota Service Quality Plan tariff. These measures include the Company s time to answer customer calls, meter reading rates, and reliability performance (i.e., how well it responds to power outages on its system System Average Interruption Duration Index (SAIDI) and System Average Interruption Frequency Index (SAIFI)). C. O&M Budgets by Business Function Q. PLEASE SUMMARIZE CUSTOMER CARE O&M BY BUSINESS FUNCTION. A. Table below provides an overall view of Customer Care O&M expense levels since 01. Please see Exhibit (MCG-1), Schedule for additional details regarding Customer Care O&M. As I discussed above, overall Customer Care O&M levels have remained relatively flat over a significant Positive rating equates to a score of,, or on a 0- scale. See, Annual Report Service Quality Plan, Docket Nos. E,G00/CI-0-0 and E,G00/M-1-. (May 1, 01). 1 Docket No. E00/GR-1-

18 period of time. I discuss below some of the variations that have occurred in the various functional areas of Customer Care for the 01 to 01 period. I discussed the drivers of Customer Care s 01 and 01 plan year expense levels in Section II.B above. Billing Services Contact Center Credit and Collections Customer Operations Meter Reading and Field Collections Vice President of Customer Care Total Customer Care O&M Table Customer Care O&M by Business Area NSPM Electric ($ millions) 1. Billing Services Historic Actuals Q. PLEASE DESCRIBE THE CHANGE IN BILLING SERVICES O&M. A. For the 01 test year, the Billing Services O&M budget decreases by 1. percent compared to 01. We are able to achieve this reduction by maintaining flat Company labor, outside services, and postage costs as a result of process improvements and efficiencies. July 01 Forecast 01 Test Year Percentage Change $. $. $. $. $.1-1.% $. $.0 $. $. $.1.% $. $.0 $. $. $. -1.% $1. $1. $1. $1.1 $1..0% $. $.1 $. $0. $0..% $0.1 $0.1 $0.1 $0.1 $ % $. $.0 $. $. $..% Also contributing to the flat 1 Docket No. E00/GR-1-

19 postage expense, despite postal rate increases, is increasing customer adoption of electronic billing and payment channels.. Customer Contact Center Q. PLEASE DESCRIBE THE CHANGE IN CUSTOMER CONTACT CENTER O&M. A. Customer Contact Center O&M is higher than 01 levels due to higher labor costs. It has been necessary to increase Contact Center entry-level wage rates to attract an adequate number of qualified job candidates, given more competitive labor markets. Historically, we have been able to maintain our O&M levels by increasing utilization of our IVR system and improved processes. However, while IVR utilization continues to increase, it is not sufficient to offset the impacts from the more competitive labor markets we are experiencing. Tables and below illustrate Minnesota customers increased use of the IVR system during the last few years, as well as total Minnesota call volume trends. Call volume varies from year to year, with weather primarily influencing the volume of both power outage and billing-related calls (from bill amounts that are either higher or lower than expected). Table Minnesota Customer IVR Utilization Rate State of Minnesota Percent of Calls Handled in the IVR YTD (through July) % 0% % % % % 1 Docket No. E00/GR-1-

20 Total Offered Calls (Agent and IVR) Average Monthly Call Volume Q. HAS THE INCREASE IN CUSTOMER USE OF IVR HAD A NEGATIVE IMPACT ON CUSTOMER SATISFACTION? A. No. In fact, as shown in the VOC Transaction results in Table 1, customer satisfaction has increased along with customers increased use of the IVR system. The same table also shows that our customers have a high level of satisfaction with our IVR system. We continually make enhancements to our IVR system to add functionality, ensure its availability, and increase customer satisfaction with its structure and menus.. Credit and Collections Q. PLEASE DISCUSS CREDIT AND COLLECTIONS O&M. A. The Credit and Collections 01 test year O&M is 1. percent lower than its 01 level. This decline is primarily due to flat labor costs and lower outside service costs. Table Customer Call Volume State of Minnesota The lower outside services costs are driven by in-sourcing of certain proactive outbound credit call campaigns to the Company s customers, which we have integrated with our IVR system and existing credit call center team workload. We expect that in addition to contributing to lower O&M expense levels, our continued process improvement efforts in this area will also aid lower levels of bad debt expense for our customers. 01 YTD (through July),,,00,,,,,,1,1,,,, 1,00,,0,0 1 Docket No. E00/GR-1-

21 Customer Operations Q. PLEASE DISCUSS THE CUSTOMER OPERATIONS O&M. A. Customer Operations 01 test year O&M is projected to be a nine percent increase over 01 actuals. While this is a high percentage, it represents only a $1,000 increase in actual dollars, so the net percentage is somewhat exaggerated by the function s smaller size. The increase from 01 is primarily driven by increased labor costs and forecasted costs associated with outside services associated with increased customer notifications and customer data privacy efforts.. Meter Reading and Field Collections Q. PLEASE DISCUSS THE METER READING AND FIELD COLLECTIONS O&M. A. The 01 Meter Reading and Field Collections test year O&M is projected to be approximately $0. million or. percent higher than 01 levels. Contributing to the increase are aspects of the Company s service contract with Cellnet, its automated meter reading services provider. Q. WHAT ASPECTS OF THE CELLNET AGREEMENT ARE DRIVING THE INCREASE IN O&M LEVELS? A. The cost per meter read has increased slightly since 01, and the credits the Company receives when Cellnet does not perform automated meter reads according to the contractual schedule have declined. Because these credits act as an offset to O&M expense, the effect is an increase in our O&M expense level. Q. PLEASE EXPLAIN THE BASIS OF THE CREDITS THE COMPANY RECEIVES UNDER THE CELLNET AGREEMENT. A. The credits are based on the Company s costs to retain Meter Readers to 1 Docket No. E00/GR-1-

22 manually read the assigned meters that Cellnet either does not read or is unable to automate in the Company s Minnesota and Wisconsin territories. In addition to labor, the credits include amounts intended to reimburse the Company for associated costs such as pension contributions, employee benefits, and other overhead costs. The total amount is divided by the number of manual reads, then Minnesota and Wisconsin are each credited based on the number of manual reads in their respective territories. As the implementation of our meter reading automation winds down to completion, the credits also naturally reduce due to the declining number of nonautomated meters. Q. HOW HAS THE ACTUAL AMOUNT OF CELLNET CREDITS RECEIVED COMPARED TO THE BUDGETED AMOUNT? A. There has historically been a difference in the actual amount of Cellnet credits received by the Company and the budgeted amount of credits. This discrepancy is not due to any failure on the part of the Company or any error in the budgeting process. Rather, in 01 and 01 there were extensive delays in Cellnet automating large Commercial and Industrial load profile meters that resulted in Cellnet being obligated to pay higher levels of credits than we had budgeted. Cellnet completed the automation of these meters in May 01, and almost all meters were turned over to Cellnet in June 01. This delay in the contractual schedule caused a corresponding discrepancy between the actual amount of Cellnet credits received compared to the expected/budgeted amount. Because Cellnet did not automate these meters per the schedule, the Company was forced to expend O&M to maintain manual readers to read the meters longer Docket No. E00/GR-1-

23 than expected; thus, Cellnet was obligated to provide higher levels of credits than initially budgeted. Since Cellnet automated these meters, we have reduced the number of meter readers in Minnesota by two positions. We intend to reduce another two positions in 01 as we gain efficiencies by optimizing meter routes in the Metro West and Metro East areas. We initially planned and budgeted to reroute the meters in these areas in 01 and 01. Because of the delays in the automation, the rerouting will not be performed until 01, further contributing to the difference between the actual credits received from Cellnet and the amount budgeted by the Company for Q. HAVE THERE BEEN ANY OTHER ISSUES THAT HAVE IMPACTED HOW THE AMOUNT OF CELLNET CREDITS ACTUALLY RECEIVED BY THE COMPANY DIFFERS FROM THE AMOUNT BUDGETED? A. Yes. Because the credits are calculated based on Cellnet s performance in both Minnesota and Wisconsin, Cellnet s improved performance in Wisconsin and the static cost of labor in Wisconsin have also impacted the budget versus actuals. Recently, Cellnet has improved performance in the Company s Wisconsin territory and increased the number of meters that it reads, reducing the number of manual meter reads. However, the average cost per read is higher for Wisconsin due to the large geographic area that needs to be covered by the remaining meter readers, increasing the average cost per read. This has the effect of artificially increasing the credit amount realized by Minnesota. 0 Docket No. E00/GR-1-

24 Q. HOW DOES THE COMPANY EXPECT THE AMOUNT OF CREDITS PROVIDED BY CELLNET TO COMPARE TO THOSE PROVIDED IN 01? A. We expect the amount of Cellnet credits to decrease in 01, as a result of Cellnet automatically reading the meters that were previously manually read by the two meter reader positions we expect to eliminate in 01. After this reduction, we believe the amount of credits provided by Cellnet will largely stabilize. III. COMMODITY BAD DEBT EXPENSE A. Introduction Q. WHAT IS COMMODITY BAD DEBT EXPENSE? A. Commodity bad debt expense is billed commodity revenue for electric and natural gas service that is considered uncollectible from customers. Commodity revenue refers to the revenue billed to the Company s customers for the cost of utility service, including fuel charges and all regulated charges to customers, such as riders. This definition represents virtually all of the Company s billed retail customer revenue. It does not include comparatively minor ancillary charges such as damage claims, which are considered noncommodity revenue discussed in Section IV of my testimony. Q. PLEASE SUMMARIZE THE COMPANY S PROPOSED TEST YEAR BAD DEBT EXPENSE. A. For the 01 test year, we propose a 0. percent of revenue ratio compared to the 0. percent ratio approved in our most recent rate case and our 0. percent actual expense in 01. On a State of Minnesota Electric Jurisdiction level, this represents an increase in our bad debt expense to $. million from the $. million approved in our most recent rate case and our 1 Docket No. E00/GR-1-

25 actual $1.0 million expense in 01. I discuss the methodology we use to determine our bad debt ratios in Part C below, and our proposed 01 and 01 plan year bad debt expense levels in Part D. Q. DID THE COMPANY USE THE SAME INDEX TO DETERMINE ITS 01 AND 01 COMMODITY BAD DEBT EXPENSE AS IT USED FOR OTHER O&M EXPENSES? A. No. As I discuss and demonstrate below, commodity bad debt expense is primarily driven by billed customer revenue. Therefore, the factor most relevant to commodity bad debt expense is the sales forecast, rather than the factors underlying the index used for 01 and 01 plan year O&M expenses in this case. Q. IN SUMMARY, HOW DOES THE PROPOSED BAD DEBT EXPENSE LEVELS COMPARE TO PREVIOUS LEVELS? A. The 01 to 01 bad debt expense levels continue to be relatively stable following a significant and steady decline from 00, when the Company s bad debt expense ratio was at 0. percent. B. Bad Debt Expense Budget and Forecast Process Q. HOW DOES THE COMPANY BUDGET AND FORECAST COMMODITY BAD DEBT EXPENSE? A. In general, we recognize commodity bad debt expense through a combination of: (1) estimating an amount of accounts receivable Reserve (or Provision) associated with outstanding receivables that will be unrecoverable; and, () writing-off uncollectible accounts not previously reflected in this Reserve. From the combination of these amounts, we derive a weighted average ratio of bad debt to overall billed commodity revenue. To determine forecasted bad debt expense, as is necessary for budgeting purposes and for a rate case, Docket No. E00/GR-1-

26 the Company applies this bad debt ratio to forecasted commodity revenues and allocates it between its electric and natural gas operations. Q. WHY IS IT REASONABLE TO ESTIMATE BAD DEBT EXPENSE BASED UPON A RATIO OF BAD DEBT EXPENSE TO COMMODITY REVENUE? A. Using a ratio of billed commodity revenue is reasonable because there is a direct relationship between billed commodity revenue and bad debt expense. In particular, as billed commodity revenue increases and decreases, bad debt proportionately increases and decreases. This practice is commonly used by industry groups, as verified by the Edison Electric Institute, and this trend is also supported by historical data. Q. WHAT FACTORS IMPACT COMMODITY BAD DEBT EXPENSE? A. All else being equal, commodity bad debt expense varies directly with billed commodity revenues. Other factors affecting bad debt expense include changes in credit policy, external considerations such as the economy, low income energy assistance programs, levels of business bankruptcies, as well as the efficiency of the Company s supporting processes and operations. Q. CAN YOU DEMONSTRATE THE CORRELATION BETWEEN BILLED COMMODITY REVENUES AND THE RESERVE FOR BAD DEBT? A. Yes. Figure below demonstrates the historical correlation between billed commodity revenues and the change in bad debt reserve. Docket No. E00/GR-1-

27 Figure Billed Commodity Revenues and Change in Reserves NSPM Total Company Billed Commodity Revenue ($ Millions) $,00 $,00 $,000 $,00 $,00 $,00 $,00 $,000 Q. DOES THE FUEL FORECAST IMPACT COMMODITY BAD DEBT EXPENSE? A. The revenue forecast is a primary input to the bad debt expense forecast, and the fuel cost forecast is used in developing the revenue forecast. Therefore, the relationship of fuel cost increases and decreases are directly correlated to changes in revenues, and ultimately bad debt expense budgets and forecasts. Once the revenue forecast is complete, the bad debt expense model uses that forecast as an input so that the bad debt expense forecast directly reflects forecasted changes in revenue. Q. HAS THE COMPANY PROVIDED A FORECAST OF NATURAL GAS SALES VOLUMES AND FUEL PRICES? $ $ $1 $- $(1) $() $() Billed Commodity Revenue (NSPM - Total Company) Change in Reserves (NSPM - Total Company) Change in Reserves ($ Millions) Docket No. E00/GR-1-

28 A. Yes. Forecasted 01 natural gas sales volumes and fuel prices are included as Exhibit (MCG-1), Schedule. Q. HOW DO YOU CALCULATE THE ACCOUNTS RECEIVABLE RESERVE PORTION OF BAD DEBT EXPENSE? A. We calculate the Reserve by applying provisioning factors to various aging categories of outstanding arrears for both active and inactive customers. A provisioning factor is the percentage of the accounts receivable estimated to eventually prove uncollectible. In general, as arrears age, and as they move with our customers from active to inactive status, we apply a higher provisioning factor to reflect the declining likelihood that we will collect the full outstanding balance. These Reserve amounts are updated monthly and combined with net write-offs to become the total bad debt expense for the period. Q. HOW DOES THE COMPANY KNOW THAT ITS PROVISIONING FACTORS ARE REASONABLE? A. The provisioning factors we apply to outstanding arrears are developed from annual Reserve Studies in which we analyze historical customer payment behavior data and consider contributing factors such as the sales forecast and underlying fuel forecast, any changes in credit policy, and external considerations such as the economy. Our most recent Reserve Study was completed in June 01. Based on the results of the Study, we were able to confirm our provisioning factors. Q. IS THE IMPACT OF LOW INCOME PROGRAMS REFLECTED IN THE COMPANY S 01 TO 01 PLAN YEAR BAD DEBT EXPENSE? Docket No. E00/GR-1-

29 A. Generally, yes. Low income programs (i.e. Low Income Home Energy Assistance Program (LIHEAP), our Electric Low Income Discount Rider, and/or our Gas Affordability Program) help customers pay amounts due for energy services, thereby reducing outstanding receivables. To the extent the remaining balance of these customer accounts are later written off, the lower receivables ultimately serve to reduce the amount of the write-off, and thus bad debt expense. Current information indicates funding levels for these programs at both the federal and state level will remain consistent for the test years. Q. HOW DOES THE COMPANY WORK TO MINIMIZE ITS BAD DEBT EXPENSE TO CUSTOMERS? A. We continue to use a combination of approaches to minimize bad debt expense. First, we ensure that our organization and related resources are aligned to most efficiently perform necessary credit and collection activities. Second, we ensure that our processes appropriately balance our goal to receive timely payment with public policy and our priority to provide good customer service. Third, we continually monitor our level of bad debt expense and the factors that influence it, and take action to respond through process or other changes. I discuss specific initiatives that Customer Care has implemented in an effort to further manage bad debt expense in conjunction with my discussion of our bad debt expense trend in Part C below. C. Test Year Bad Debt Calculation 1. Bad Debt Ratios and Trend Q. HOW WAS THE 01 BAD DEBT RATIO CALCULATED? A. The 01 bad debt ratio was calculated by comparing average net write-offs for the 1-month period ended March 1, 01, to billed commodity revenues Docket No. E00/GR-1-

30 over the same period. Exhibit (MCG-1), Schedule includes a detailed calculation of the bad debt ratio. Q. HOW DID YOU DERIVE THE 01 AND 01 BAD DEBT RATIOS? A. The bad debt ratios for 01 and 01 were calculated by using the same methodology as 01, and included the year-over-year improvement of 0.01 percent commodity bad debt expense to billed commodity revenue. Q. IS THE COMMODITY BAD DEBT RATIO OF 0. THE COMPANY PROPOSES FOR THE 01 TEST YEAR REASONABLE? A. Yes. As shown in Table below, our bad debt ratio has improved since 0. Also, the 0. ratio we propose for 01 is consistent with our 01 actual bad debt expense and our expectations for year-end 01 actual results. Q. WHY ARE THE 01 AND 01 PLAN YEAR BAD DEBT RATIOS REASONABLE? A. The 0. and 0. ratios we propose for 01 and 01 plan years, respectively are reasonable because they are consistent with our expectations for year-over-year improvement based on historical trends. Table Commodity Bad Debt Ratio NSPM Total Company Actuals Test Year Approved July Forecast Test Year Plan Years % 0.1% 0.% 0.% 0.% 0.% 0.% 0.% 0.% 0.% Docket No. E00/GR-1-

31 Bad Debt Expense and Trend Q. WHAT IS THE PROPOSED 01 COMMODITY BAD DEBT EXPENSE? A. We propose bad debt expense of $1. million for NSPM Total Company, which translates to a 01 test year bad debt expense of $. million for the State of Minnesota Electric Jurisdiction. We provide detailed calculations supporting the 01 test year commodity bad debt expense as Exhibit (MCG-1), Schedule. Q. WHAT IS THE PROPOSED 01 AND 01 COMMODITY BAD DEBT EXPENSE? A. We propose 01 bad debt expense of $1. million for NSPM Total Company, which translates to a 01 plan year bad debt expense of $. million for the State of Minnesota Electric Jurisdiction. For 01, we propose a Total NSPM Company bad debt expense of $1.1 million, which translates to a 01 plan year bad debt expense of $. million for the State of Minnesota Electric Jurisdiction. We provide detailed calculations supporting the 01 and 01 plan year commodity bad debt expense as Exhibit (MCG-1), Schedule. Q. HOW WAS THE PER-YEAR BAD DEBT EXPENSE CALCULATED? A. We calculate the commodity bad debt expense level by applying the bad debt ratio for each year to each year s total Company forecasted commodity revenues. We then allocate the proposed bad debt expense to the State of Minnesota Electric Jurisdiction through an allocation process that I discuss in Section III.E of my testimony. Q. HOW DOES THE BAD DEBT EXPENSE LEVELS COMPARE TO HISTORICAL BAD DEBT EXPENSE LEVELS? Docket No. E00/GR-1-

32 A. Table below presents the trend of the Company s commodity bad debt expense since 0. Table Commodity Bad Debt Expense Trend State of Minnesota Electric ($ millions) Actuals Test Year Approved July Forecast Test Year Plan Years $. $.1 $. $.0 $1.0 $. $.1 $. $. $ Q. PLEASE DISCUSS THE TREND IN THE COMPANY S COMMODITY BAD DEBT EXPENSE. A. Table above shows the Company s bad debt expense has had some ups and downs and overall slightly increased since 0. The primary reason is the increase of approximately $ million in total Company billed commodity revenue from 0 to the 01 test year Q. WHAT DOES THE COMPANY DO TO MANAGE BAD DEBT EXPENSE, PARTICULARLY WHEN REVENUES ARE INCREASING? A. To help offset the effect of increases in revenue on bad debt expense levels, the Company has focused on managing bad debt expense through several initiatives, including: Proactively contacting delinquent residential customers through outbound calls, which we have now also integrated into our credit and collections function, further increasing its efficiency and effectiveness, Close monitoring of commercial accounts and industry trends and work to keep these customers as current as possible to minimize potential bankruptcy impacts, Docket No. E00/GR-1-

33 Focused management of collection agency practices to help improve collections from customers whose debt had previously been written off, Developing advanced analytical methods to ensure the most effective credit activities are utilized, and, Strong support of low income programs that help the Company s most at-risk customers. Q. HOW DOES THE COMPANY S TOTAL BAD DEBT EXPENSE COMPARE TO OTHER UTILITIES? A. The Company s bad debt expense compares favorably to other utilities in terms of FERC account 0 expenses. For the 0-01 period, which is the most current information available, the combination of the Company s total commodity and non-commodity bad debt expense has consistently been below the mean expense level of other utilities. We provide a summary of this expense level comparison in Table below; details can be found in Exhibit (MCG-1), Schedule. Table Customer Records and Uncollectible Expense per Retail Customer Comparison NSPM Total Company $. $.0 $. $. $. Competitor Group (mean) $1. $1. $. $1. $1. Source: SNL FERC account 0 is charged with amounts sufficient to provide for losses from uncollectible utility revenues. 0 Docket No. E00/GR-1-

34 D. Allocation Methodology Q. HOW DOES THE COMPANY ALLOCATE COMMODITY BAD DEBT EXPENSE BETWEEN ELECTRIC AND NATURAL GAS OPERATIONS? A. We allocate bad debt expense to our natural gas and electric operations consistent with the process by which debt is written off. Total bad debt expense is assigned at a total Operating Company level, because customer payments and write-offs are recorded to the customer s overall account not separately for electric and gas service. Therefore, because we have combined electric and gas customers who pay for utility service on an integrated basis, the bad debt expense is also integrated at a customer account level. To differentiate bad debt expense between gas and electric service, we use an allocation to reasonably approximate the proportions of electric and gas utilities bad debt expense. After applying the bad debt ratio to total NSPM commodity revenue, the resulting amount is allocated to the Minnesota jurisdiction and between the electric and gas utilities by using a rolling fouryear total of revenues to utility and jurisdiction. The allocator in the current year is developed based on the four previous years actual operating revenues from the corporate income statement, which we update every April. Using this methodology, the amount of bad debt expense allocated to the State of Minnesota Electric Jurisdiction utility operations for 01 in this case is. percent of the total bad debt expense for the Company. Essentially, this reflects the fact that Minnesota electric commodity revenues equaled. percent of NSPM commodity revenues during the January 0 through December 01 period. 1 Docket No. E00/GR-1-

35 Q. DID YOU USE THE SAME ALLOCATION PERCENTAGE FOR THE 01 AND 01 PLAN YEARS? A. Yes. The 01 and 01 plan years use the same allocation percentage as 01 test year. Q. HAS THE COMPANY USED THIS ALLOCATION METHODOLOGY IN ITS PREVIOUS RATE CASES? A. Yes. This is the same methodology used in all recent rate cases, including the 01 rate case (Docket No. E00/GR-1-) and the Company s most recent natural gas rate case (Docket No. G00/GR-0-). IV. NON-COMMODITY BAD DEBT EXPENSE Q. WHAT IS NON-COMMODITY BAD DEBT EXPENSE? A. Non-commodity bad debt expense is billed revenue that is considered uncollectible for everything other than electric and natural gas service. The non-commodity bad debt budget categories align with functional Business Areas and include the following: Customer Care: Miscellaneous charges such as returned check and connection-related fees, Transmission and Distribution: Contributions In Aid Of Construction; charges for requests made by customers for non-standard equipment or set-up; claims against third parties that damage the Company s electric and gas facilities, Energy Supply: Wholesale sales of short-term generation and energy trading non-retail commodity, Wholesale: Wholesale sales such as to municipalities for resale to their customers, and, Docket No. E00/GR-1-

36 Corporate / Other: Write-off of inactive sundry accounts receivable balances. Q. WHAT IS THE 01 TEST YEAR AMOUNT FOR NON-COMMODITY BAD DEBT? A. The 01 test year non-commodity bad debt expense for the State of Minnesota Electric Jurisdiction is $0. million, compared to $0. million approved in the 01 case. Detailed calculations supporting the test year non- commodity bad debt expense are provided in Exhibit (MCG-1), Schedule. Q. WHAT IS THE 01 AND 01 PLAN YEAR AMOUNTS FOR NON-COMMODITY BAD DEBT EXPENSE? A. The 01 and 01 plan year non-commodity bad debt for the State of Minnesota Electric Jurisdiction is $0. million each year. We provide the details as Exhibit (MCG-1), Schedule to my testimony. Q. HOW DO THESE AMOUNTS COMPARE TO PAST YEARS? A. Table below provides actual non-commodity bad debt expense amounts for the 0-01 period, the approved 01 test year amount, the 01 forecast, the 01 test year and the 01 and 01 plan year amounts. Table Non-Commodity Bad Debt Expense Trend State of Minnesota Electric Jurisdiction ($ millions) Test Year July 01 Test Year Plan Years Actuals Approved Forecast Proposed Proposed $0. $0. $(0.) $0.01 $0.1 $0. $0. $0. $0. $0. Docket No. E00/GR-1-

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