05/14/2018 Douglas A. Herling President & CEO of CMP, Avangrid, Inc. Corporate Headquarters 180 Marsh Hill Road Orange, CT 06477 Re: Docket 2018-00052 Dear Mr. Douglas A. Herling, We represent 3,500 ratepayers whose electric utility is Central Maine Power. We are extremely concerned about CMP's excessive over-billing, deficient customer service, and lack of accountability. We present to you our most pressing concerns and questions: • • • • • • • • • Billing Customer usage inexplicably/exorbitantly spiking beginning October 2017. Customers receiving duplicate bills. Customers not receiving bills. Customers billed for usage when grid is down (locally or regionally). Customers billed for usage during the 10 days of system wide outages following the October 2017 windstorm. Customers receiving bills for vacant camps or vacant homes. Customers on simple pay suddenly finding their monthly charge quadruple. CMP’s failure to phase in a new billing system without proper preparation before “go live”. Customers receiving disconnect notices before legally allowed during Winter Months. Customer Service Customers long wait times during attempts to reach CMP Customer Service Department. CMP’s failure to respond to phone messages, online complaints, or customer emails in a prompt manner. • Frightened customers forced to accept payment plans way beyond their means. • Customer Service Representatives failure to investigate excessive usage with a proactive mentality, instead, placing the burden and misinformation on the customer. • Customer Service Representatives preposterous explanations for exorbitant usage e.g. fish tanks, washing the dog, auxiliary heating systems, where wood stoves are primary heat. • • • • • Customer Interface (Energy Manager, CMP Website) The Energy Manager not functioning or malfunctioning. Graphs indicating kWh usage up in summer and tanking in Winter Mobile devices unable to view bills or payment data. 1 Metering • Smart meter field testing showed inaccuracies during testing causing some meter replacements. CMP has denied this. • CMP Field Technicians resetting meters before removing them for testing. • No Explanation why bills dropped drastically after smart meters were replaced by non-standard meters. • Meter Data raw files showing abnormal/excessive usage during abnormal times e.g. while asleep, on vacation, or away from home. • What does "time of day" usage mean? • Are ratepayers being billed for VA (volt-amperes) consumption obtained via incremental smart meter data, translated into kWh? Are consumers load factors or historical usage patterns determining the threshold for “estimations” on consumption? • Did any bridges, repeaters, or gateways used to communicate between CMP’s HES (Head End System) and End User Smart Meters Fail? What redundancies are in place in the event communication protocols are disrupted with this system? • Why did CMP adjust usage information on customer accounts during and after the windstorm? • What are "Implausible" meter readings? • Who has the authority at CMP to approve, adjust, or edit meter reading data in the MDM (Meter Data Management System)? Is there oversight to these actions? • • • • • • • Socioeconomic Importance Consumers faced with financial sacrifices while bills continue to exceed the cost of rent. No family should have to choose between feeding their family or paying utility bills. Elderly/Disabled on fixed income unable to pay bills. Elderly/Disabled terrified of having power turned off. Elderly/Disabled unable to navigate the system to protest exorbitant bills. Those eligible for ELP benefits denied, others forced to return benefits approved and received. PUC ruling customers will subsidize wind storms expenses in the form of rate increases. Regulatory Issues, Questions, and CMP’s commitment • CMP’s lack of preparedness during the October 2017 windstorm leading to up to 10 days of power loss system wide. • How will CMP be more prepared to respond to Tier 3 Storms? • How will ratepayers be compensated for overcharges? Will they receive a full accounting? What about independent electricity providers? • What happens to overdue portions of bills that customers were counseled to pay only 25% over last year's usage? If consumers are unable to pay these bills, how will CMP resolve the account balances? • What protection does PUC offer customers who can’t pay bills? • Who will subsidize the independent audit into CMP? • Who is screening the companies that would perform the independent audit? Will the audit include a licensed independent engineer to test smart meters? • How can we be assured the investigating company and its employees have no ties to CMP or its parent company? 2 The investigation which the Maine Public Utilities Commission has ordered has made progress. However, it has raised more questions than answered. There needs to be immediate relief to the customers until the seemingly endless list of problems with the new system are resolved. There are unanswered questions about alternatives for resolution. Central Maine Power has not directly addressed its customers, instead creating a website that contains information which directly contradicts documents submitted to the Commission. Susan Clary, Director of Electric Supply advising other CMP Management to get a handle on the issues or “We will find ourselves in the middle of a Commission investigation.” is alarming. The attitude from the Company overall is deflective in nature and undermines the trust we must place in a Public Utility to provide critical services. Lawmakers need to change the scope of authority of the PUC to include protecting the public as a priority. The Commission has delayed the plea of the Office of the Public Advocate to open a full investigation. Title 35-A Chapter 31 §3155 Authorizes the Attorney General to Intervene before the Commission to protect consumer interest. The Consumers are unable to accept anything other than a thorough and timely investigation. We the People of Maine demand transparency with our regulated public utilities. This situation requires your immediate attention. Sincerely, Representing CMP Ratepayers unite: Patrick Milligan milliganpm@gmail.com Lauren Loomis sunatmidnght@gmail.com cc: Harry Lanphear, Adm. Director, MPUC Attorney General Janet Mills Committee on Energy, Utilities and Technology Public Advocate Barry J. Hobbins Governor John Lepgae Steven McGrath 3