Itemm | PSC Code | Public Service Commissionon of WIisconsin Proposed Changes | Comments and Questions | PSC Responses |
1 | WUA | 113.0614(7) & note | Preservation of records – meter test records | WUA members do not want to keep two records of meter tests. Often meters are tested in the field and those test results are entered into meter history records and then purged. (Suggested change) Modify period to be retained to “See PSC 113.0919. Until the information is the meter test record is entered in the meter history record.” | Agree in part. The proposed language is not a change. Currently, a meter test record must be kept until the next test is performed, and a meter history record must be kept. The proposed language only clarified that the test record information must also be made a part of the meter history record before it is disposed of. However, the language will be changed to make clear that a utility need only retain test record information until it is entered into the meter history record. It is important to note that the meter history record need not be a separate, stand-alone document so long as the required information can be gathered from other sources. |
2 | WUA | 113.0919(1)(b) | Location of the unit of metering equipment | A clarification is needed. Is this part of where the meter was tested, or a history of location of meters, service address, etc. ? | Agree. Clarify that “location” is intended to mean the service address. |
3 | WUA | 113.0919 (1) (j) 4. | A statement of repairs made, if any | If a product is returned to a manufacturer that fact is tracked however the details of the repair are not. | Agree. Language will be changed to require a statement of repairs made by the utility or a notation that the unit was returned to the manufacturer for repairs. |
4 | WUA | 113.0921(1)(g) | Repeal | WUA members would oppose repeal of PSC 113.0921(1)(g). A clarification of when meters can be retired without a test is needed. As drafted the repeal could be costly to customers. Meters in sampling program with acceptable lot performance would be found to be accurate. A retention period for retired without test under PSC 113.0922 could be acceptable. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
5 | WUA | 113.0922(3)(d) | Meter retention when a complaint or dispute occurs | The proposed rule provision referring to “meter-related issue” is vague. The wording should refer to complaints related to meter accuracy. | Agree. Change made. |
6 | WUA | 113.0922(3)(e) | When a meter is retired | The rule needs to clarify on when a meter can be retired without a test. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
7 | WUA | 113.0922(6) | Records Retention Requirements | WUA members do not want to keep two records of the meter tests. Often meters are tested in the field and those test results are then recorded in the meter history records and purged from the field test records. | Agree in part. The proposed language is not a change. Currently, a meter test record must be kept until the next test is performed, and a meter history record must be kept. The proposed language only clarified that the test record information must also be made a part of the meter history record before it is disposed of. However, the language will be changed to make clear that a utility need only retain test record information until it is entered into the meter history record. It is important to note that the meter history record need not be a separate, stand-alone document so long as the required information can be gathered from other sources. |
8 | WUA | 113.0922 | Records Retention Requirements | The draft rule includes 1-3 and 6 but does not include 4 and 5. | Agree. Provisions have been renumbered as necessary |
9 | WUA | 134.19(1) | Meter Test Records | The requirement to create a record every time a meter is tested implies a redundant recordkeeping system that would add to costs. WUA would prefer changing the term from “create” to “keep” a record so that entries in the meter history record are sufficient for compliance. | Agree in part. The proposed language is not a change. Currently, a meter test record must be kept until the next test is performed, and a meter history record must be kept. The proposed language only clarified that the test record information must also be made a part of the meter history record before it is disposed of. However, the language will be changed to make clear that a utility need only retain test record information until it is entered into the meter history record. It is important to note that the meter history record need not be a separate, stand-alone document so long as the required information can be gathered from other sources. |
10 | WUA | 134.19(1)(a)4 | Meter Test Records | The provision needs to recognize that certain meters (rotary and turbine) are tested by methods that do not calculate meter accuracy. They test the functioning of the meter. WUA would prefer language that requires a test record to include the “results” of measurement instead of “accuracy” of measurement. | Agree. Change made. |
11 | WUA | 134.20 | Preservation of Records | Also see WUA comment on PSC 113.0614(7). WUA would support a note similar to that being proposed for 113.0614 but referring to meter history records under PSC 134.19(2) | Agree in part. The proposed language is not a change. Currently, a meter test record must be kept until the next test is performed, and a meter history record must be kept. The proposed language only clarified that the test record information must also be made a part of the meter history record before it is disposed of. However, the language will be changed to make clear that a utility need only retain test record information until it is entered into the meter history record. It is important to note that the meter history record need not be a separate, stand-alone document so long as the required information can be gathered from other sources. |
12 | WUA | 134.31(4)(a) | Meter Retention | Some meters will need to be left in place following a test and it would be preferable for them to be adjusted for accuracy instead of requiring them to remain in “as tested” condition. The rule needs to accommodate adjustment of a field-tested meter and the time of a test. | Disagree. The goal of this rule is to have meters available in “as tested” condition in case further testing is requested or required. This requires that inaccurate meters be removed rather than adjusted in the field. |
13 | WUA | 134.31(4)(c) | Meter Retention | PSC 134.31(4)(c) should be modified to specify that it is when the meter is tested for an “accuracy reason” and the test results in a backbilling or credit that meter retention is required. WUA would also like clarification on the exact start of the retention period. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
14 | WUA | 134.31(4)(d) | Meter Retention | The use of the terms “meter-related issue” is too vague and should instead refer to “meter accuracy.” (see WUA comment on PSC 113.0922(3)(d)) Also would like clarification of when retention period starts. Is the date of the meter test the start of the retention period? | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
15 | WUA | 134.31 | Drafting issue | We notice that the rule seems to be drafted without a (5) but continues to a (6) | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
16 | WUA | 134.31(6) | Record retention requirement | WUA would like a clarification as to whether the retention time period requirement applies to meter history records, meter test records, or both? | Agree in part. This provision has been deleted. A note has been added referring readers to the records retention chart. |
17 | WEPCO | 113.0921 (1) (g) | PSC 113.0921(1)(g) appears in the portion of ch. PSC 113 that defines the statistical sample test plan for in-service electric meters and currently reads "Any meter that is included in this plan, which is removed from service for retirement, may be retired without a test." We do not understand the rationale for and do not agree with the repeal of this portion of the code. From a meter retention perspective, meter retirement without a test is addressed in the proposed PSC 113.0922 (3) (e). Since PSC 113.0921 (1) (g) was implemented in 2000 we have retained meters for multiple billing periods when meters are removed from service for retirement to allow for customer requested tests and have received very few test requests. Staffing in our meter shop has been reduced based on PSC 113.0921 (1) (g). Repeal of PSC 113.0921 (1) (g) will significantly increase the number of meters that require a test, will require additional meter shop staff and will result in additional cost for the utility and our customers. We do not believe this additional cost adds significant value to our overall customer service. We agree the retention of the meters before retirement should remain in order to allow customer-requested tests but feel that PSC 113.0921 (1) (g) should be retained. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
18 | WEPCO | 134.19 (1) | PSC 134.19(1) defines the creation of a "Meter test record". PSC 134.19(2) defines the creation of a "Meter History Record" which includes "the dates and results of all tests". PSC 134.19(1) requires the utility to create a redundant record since we are required to keep a record of the same information in the meter history record. We recommend PSC 134.19(1) be eliminated and all references to "meter test record" be removed and replaced with a reference to the "meter history record" when appropriate. | Agree in part. The proposed language is not a change. Currently, a meter test record must be kept until the next test is performed, and a meter history record must be kept. The proposed language only clarified that the test record information must also be made a part of the meter history record before it is disposed of. However, the language will be changed to make clear that a utility need only retain test record information until it is entered into the meter history record. It is important to note that the meter history record need not be a separate, stand-alone document so long as the required information can be gathered from other sources. As |
19 | Nicolas E. Kumm Electric, Communi-cations, & Gas Manager Marshfield Utilities | 113.0911 (1) (d), 113.0912 (1) (d), 113.0913 (1) (d) | Currently, PSC 113.0911 (1) (d), PSC 113.0912 (1) (d), PSC113.0913 (1)(d), and PSC113.0914(1)(d) require utilities to test every electric meter that is removed from service or retired. The proposed rule in PSC 113.0922(3)(e) states retired meters do not need to be tested if the meter is kept by the utility in the “as found” condition for a period of time. The existing rules and the proposed rules appear to contradict each other. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
20 | Daniel Duchniak Waukesha Water Utility | 185.77 | Request and referee tests, tests at retirement | This adds an unnecessary burden and cost to the utilities to address an issue that is limited in nature. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
21 | Julie Bohen Watertown | 185.77 | Request and referee tests, tests at retirement | Storing meters for 4 months is a bad idea. The benefit is really, really small as very few if any customers ever inquire about their old meters. The potential detriment is very, very large. The extra storage costs and labor needed to handle all the old meters will add up quickly. These extra costs could be passed on to ratepayers. Please consider getting rid of the language that requires water utilities to store meters four 4 months. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
22 | Kelly Zylstra Waukesha. | 185.77 | Request and referee tests, tests at retirement | Why spend the money when less than 0.2% of customers who had retired meters replaced had concerns over the accuracy of their new meter? Those funds could be spent in much better ways to help our failing infrastructure. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
23 | Valerie Kraemer Oconomo-woc | 185.77 | Request and referee tests, tests at retirement | I do not support the new requirement in PSC 185.77 (3) (e). | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
24 | Earl Smith Milwaukee Water Works | 185.77 | Request and referee tests, tests at retirement | Endorse and support the concept of ensuring that meters used to prepare a customer’s bill are performing their designed function accurately, thus providing the customer for an accurate bill. That being said, MWW tests meters as they are retired on a routine basis and always tests them upon customer request. Current PSC code more than adequately promotes this, therefore it is the opinion of MWW that the rule changes proposed address a scenario that happens very rarely. The adoption of these proposed changes will not benefit the majority of ratepayers of MWW. This is especially true since it is the understanding of MWW that a meter that tests within the PSC accuracy limits for a removed meter that will not result in an adjustment to a customer bill can be destroyed immediately with no requirement to retain them. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
25 | Municipal Environ-mental Group - Water Division (MEG) | 185.77 | Request and referee tests, tests at retirement | MEG-water supports the meter retention requirements applicable after a customer-requested test, after a referee test, when performing other tests, and when a complaint or dispute occurs. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
26 | MEG | 185.77 | Request and referee tests, tests at retirement | Does not support the new requirement in PSC 185.77 (3) (e) that requires a utility to test or retain all meters that have been retired. This is burdensome, increases costs, will increase utility rates, and would provide no benefit customers in most cases. The limit to benefits that would be provided by this requirement do not justify the additional costs and burdens that would be imposed by this requirement. A better, more targeted, approach would be to require the utility to test or retain an untested retired meter only if 1) the utility issues the customer a backbill for service provided while the retired meter was used or 2) the bill issued prior to the meter replacement was estimated. In those cases, a customer request for a meter test could be reasonably anticipated and might provide useful information to the customer. This targeted approach would only require those retired meters that meet the specified conditions to be tested are retained. This would limit the utility’s costs, while providing customer protection in those situations where an issue might arise. MEG believes this is a better, more cost effective approach that focuses utility resources on those situations where meaningful benefits might be provided. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
27 | Waukesha Water Utility | 185.77 | Request and referee tests, tests at retirement | PSC 185.77 (3) (e) is over-arching. This language is proposed to address only a few specific events. It reacts to a special cause as if it were common. Customer requests to check retired meters are not common. WWU only received two requests from customers to test meters in 2012 (rate of 0.13%). If WWU is accepted as a sample of the state, it appears unnecessary to implement a procedure that would provide very little value to the general public. If the PSC does receive a complaint related to a retired, untested meter, the WWU would like to suggest that a settlement be negotiated between the involved parties. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
28 | Waukesha Water Utility | 185.77 | Request and referee tests, tests at retirement | PSC 185.77 (3) (e) adds cost to the system. Testing showed that capping and storing was ineffective and costly. While there is an opportunity for a utility to request a waiver, this is yet another unnecessary and costly process for a utility to engage in. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
29 | Sen. Paul Farrow | 185.77 | Request and referee tests, tests at retirement | The proposed rule for retired water meters appears to be an overbroad and costly burden for the state’s water utilities and their customers, especially considering the small number of water users who could potentially see any benefit. In addition, it appears that the storage requirements may actually be ineffective in preserving the meter. If effective preservation is possible, any requirements should be limited to those cases where customers had water use estimated or were issued a backbill for past unmetered use. The State has an obligation to ensure the wise use of financial resources and to avoid regulations that are overly burdensome or unnecessary. The PSC should work with utilities to find a better way to address its limited concern. I urge the Commission to carefully review the public comments and to consider needed revisions to the proposed rule before submitting it for legislative review. | Agree. The new provisions about retaining meters at retirement and after other tests have been deleted. |
