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4.2. ERMUSR 12-08-2015 Elk River Municipal Utilities UTILITIES COMMISSION MEETING TO: FROM: Elk River Municipal Utilities Commission Tom Sagstetter—Conservation and Key Accounts John Dietz—Chair Manager Al Nadeau—Vice Chair Jennie Nelson—Customer Service Manager Daryl Thompson—Trustee MEETING DATE: AGENDA ITEM NUMBER: December 8th,2015 4.2 SUBJECT: Security Deposit Policy BACKGROUND: Based on recent commercial customer experiences and direction from the Utility Commission,staff has been reviewing the Security Deposit Policy, The goal of the policy review is to have measures in place that are consistent with industry standards and minimize the financial risk to the Utility and all customers. At this time,the focus of the policy review is for the commercial customer class only because of the magnitude of financial risk with the largest customers, A number of items regarding the policy were already discussed at the November commission meeting. Per commission direction, staff has identified several options to strengthen procedures and minimize risk.Below is a list of information staff has assembled to determine next steps in the policy review.Attached is the current Security Deposit Policy for reference. DISCUSSION: The goal of the security deposit policy revision is to minimize the risk to all ratepayers,yet still provide an environment that encourages business to locate within the ERMU service territory. The policy also has to be executable and administratively manageable for staff in order for this to be successful. Also,the administrative costs need to be reasonable in comparison to the risk mitigation. Staff understands that risk will always be a part of this business,but we know that there needs to be a balance between policy/procedure and economic development. Staff also surveyed several utilities in the area and found that our current policy is very similar to others, even a tad more strict.With all of those thoughts in mind, staff has created a new procedure for commercial account move-ins. The new move-in process is made of roughly three different parts: new commercial application,security deposit dollar amount and pre3ayment,and a revised service agreement that needs to be signed in person.Below are bullet points outlining the potential new procedure: 1. Account Application a. New commercial application i. Based on other local utilities' applications ii. Signed by local customer authorized representative iii. Help obtain current property owner or broperty management contact information to assist with disconnects that may be needed T EDED DI Page 1 of 2 NATURE Reliable PublicG Power Provider P O W E R E D T o S ERV E 58 2. Calculating the Security Deposit a. Credit Report i. Corporate if registered as an LLC ii. Individual if sole proprietor b. Past Utility Bills(Minimum of 12 months with current electric provider) c. Estimating deposit based on connected load(New or expanding business) d. New Application Fee(Cover cost of credit report and administrative costs) e. Process for ERMU staff i. Receive completed application ii. Review completed application 1. Credit check 2. Determine security deposit based on utility bills or connected load calculations furnished by company representative. 3. Security deposit is subject to re-evaluation over time if the deposit is too low or too high depending on past 12 months of use on ERMU system. 4. Customer will be required to come to the office to sign the service agreement and pay the security deposit as well as the application fee prior to establishing the account in the business" name. 3. Determining the credit risk of commercial customers a. Credit score of less than or no established credit will require a deposit of 3 times their highest bill in the past 12 months or that monthly estimated cost based on the connected load submitted on the application. b. Based on the credit score and a risk matrix that is being developed,the customer will have a security deposit that ranges from one to three times their highest monthly bill in the past 12 months or the estimated monthly cost determined by ERMU staff. c. Commercial customers can also submit a letter of credit for the security deposit instead of cash. d. ERMU may,in its discretion,waive or reduce the required deposit for commercial or industrial customers based on credit risk. Even with recent events resulting in larger losses due to non-payment,it is important to remember that ERMU is currently doing a good job protecting our customer's interests.These are few and far between. The Average National Write-Off percentage is between.10%and .41%. ERMU's write off percentage is well below this average at.01%currently.Also,our current policy and procedures are very similar to other utilities.This said,there is an opportunity to strengthen both. This is not a problem you solve,but rather an issue you manage; this requires periodic review as our world changes. Staff is looking for the commission's approval to continue working in the direction identified above and determine final policy revision language. Staff will also create the new service application form and revise the commercial service agreement that will be brought back to the commission for an approval at a later date. After revision and commission approval of any changes to the commercial customer portion of the security deposit,staff will review the residential security deposit policy and process. Staff will also review risk associated with credit card payments for residential and commercial accounts. These will be brought back to the commission for discussion throughout this process over the coming months. ACTION REQUESTED: Provide staff with guidance on the measures outlined for further research and policy development. ATTACHMENTS: • ERMU Policy A.6—Customer Deposit Policy P�0W 0E0 0V Page 2 of 2 NATURE Reliable Public Power Provider P O W E R E D T O S ERV E 59 )4''*-- Elk River Municipal Utilities A.6—Customer Deposit Policy 1.0 Policy In order to protect its ratepayers from customers who default on their accounts,the Elk River Municipal Utilities(ERMU)has adopted this Customer Deposit Policy. Deposit Required: All residential, commercial and industrial customers of ERMU will be required to submit a deposit in the form set forth below subject to the exceptions set forth below. In addition, customers who have been disconnected by ERMU for non- payment of amounts due shall be required to submit a deposit before service will be reconnected. Failure to submit the required deposit when due shall be cause for ERMU to immediately terminate service. Amount of Deposit: The amount required to be deposited for residential services shall be: $100 for apartments $100 for water and sewer service $150 all electric service $250 for all services The amount required to be deposited for commercial services shall be equal to two times ERMU's estimate of the customer's highest monthly utility bill, at a minimum of$250. Form of Deposit: The deposit shall be in the form of a cash deposit or an irrevocable letter of credit. If in the form of an irrevocable letter of credit,the letter of credit shall be renewed at least 30 days prior to its expiration. Failure to renew a letter of credit will result in the letter of credit being drawn on and the cash recovered from the letter of credit being held by ERMU as a cash deposit. If ERMU is not able to draw on the letter of credit,the customer shall submit a cash deposit prior to expiration of the letter of credit. Failure to submit the required deposit shall be cause for immediate termination of service by ERMU. Receipt for Deposit: ERMU shall furnish the customer with a written receipt at the time a deposit is made. The receipt shall specify the conditions pursuant to which the amount of the deposit will be diminished upon return of the deposit to the customer. 1 60 Return of Deposit: Any deposit received by ERMU shall be returned to the customer within 45 days of termination of service,provided that the customer has paid in full all amounts due on the account. If the customer has not paid in full within 30 days of the termination of service, the deposit will be applied to any outstanding amounts owed by the customer to ERMU. If the deposit exceeds the amount due,the balance will be returned to the customer. If the deposit is not sufficient to cover the amount due,the customer shall remain liable to ERMU for the balance and shall pay the balance due within 15 days of notice from ERMU. ERMU reserves the right to use reasonable legal means to collect amounts due. Interest on Deposits: Interest shall be paid on all deposits in excess of$20 at the rate established by Minnesota Statutes. ERMU may, at its option,pay the interest at intervals it chooses,but at least annually,by direct payment or as a credit on the customer's account. Submission of and Exceptions to Deposit Requirement: A. Residential Customers. Residential customers may submit the required deposit at the time service is requested, or have the deposit billed with the customer's first bill for services provided. Failure to pay a deposit when billed shall be cause for ERMU to immediately terminate service. ERMU may, in its discretion, waive the required deposit for residential customers if the customer consents to ERMU's collection of credit history data on the customer, the customer's credit score falls above 90 percent probability of non-default, and the customer has no history of disconnection for non payment to ERMU, and no history of late payments to ERMU two times in 12 months. B. Commercial and Industrial Customers. All commercial and industrial customers shall submit the required deposit and enter into a service agreement with ERMU at the time service is requested. The customer's application for service shall identify the individual or business entity entering into the service agreement. The service agreement shall be an agreement on the part of this individual or business entity to make payment of all amounts billed by ERMU for electric, water and sewer services, and to be liable for any default or non-payment of amounts billed by ERMU. ERMU may, in its discretion, waive or reduce the required deposit for commercial and industrial customers if a service agreement is executed by the customer,the customer has provided ERMU with sufficient information to allow ERMU to analyze the credit risk of the individual or business entity executing the service agreement, and ERMU, in its sole discretion, determines to waive or reduce the deposit required based on its analysis of credit risk. Waivers and/or reductions in the deposit requirement shall be reserved for rare exceptions when the risk of default is minimal. 2 61 Adopted 3/9/2010 Revised 2/14/2012 Revised 6/16/2015 GP:2740880 v4 3 62