June 7, 2006

Via Electronic Filing and U.S. Mail

Oregon Public Utility CommissionAttention: Filing CenterPO Box 2148Salem OR 97308-2148

Re: Ash Hill Signs v. Portland General Electric Co.OPUC Docket No. UCB 32

Attention Filing Center:

Enclosed for filing in the above-captioned docket is Portland General Electric’s Answer. This document is being filed by electronic mail with the Filing Center.

An extra copy of this cover letter is enclosed. Please date stamp the extra copy and return it to me in the envelope provided.

Thank you in advance for your assistance.

Sincerely,

/s/ INARA K. SCOTT

Inara K. Scott

cc: Bryan Ashby, Ash Hill Signs

Enclosure

Page 1 – ANSWER OF DEFENDANT

BEFORE THE PUBLIC UTILITY COMMISSION

OF OREGON

UCB 32

Ash Hill Signs,

Complainant,

vs.

Portland General Electric,

Defendant

ANSWER OF DEFENDANT PORTLAND GENERAL ELECTRIC COMPANY

INTRODUCTION

On May 22, 2006, Ash Hill Signs (Complainant) filed a complaint (Complaint) against

Portland General Electric Company (PGE) with the Public Utility Commission of Oregon

(Commission). On May 23, 2006, the Commission served the Complaint on PGE. Pursuant to

OAR 860-021-0015(5), PGE is required to file an Answer to the Complaint by June 7, 2006,

15 days from service of the Complaint.

PGE responds to the Complaint as follows: After a history of non-payment and past due

account, Complainant was disconnected on May 17, 2006. Prior to disconnection, Complainant

received written 15-day and 5-day disconnection notices, and spoke with a PGE Customer

Service Representative (CSR) about his past due account. Complainant was informed of the

requirements for continued service and did not tender payment. PGE fully complied with its

tariffs and all applicable rules and regulations for disconnecting service.

Complainant suggests that the total amount due on his bill does not accurately reflect the

amount he owes. This suggestion appears to stem from a $200 deposit required by PGE and

charged to Complainant’s account. PGE Tariff Rule D(4) Section B(4) provides that the

company may require a customer to provide a deposit if the customer does not satisfy the

Page 2 – ANSWER OF DEFENDANT

utility’s credit criteria. Due to the history of non-payment on this account and repeated 15-day

and 5-day disconnection notices, Complainant did not satisfy the credit criteria. Complainant

received two separate notices regarding the deposit requirement and spoke with a PGE CSR prior

to the deposit amount being charged to his account. Again, Complainant was fully informed

about the deposit requirement, and PGE’s actions complied fully with its duty under its tariffs

and all applicable Commission rules and regulations. This complaint should be dismissed.

FACTS

Complainant opened an account with PGE on September 25, 2004. Between that time

and July 12, 2005, Complainant made only two payments toward its account. See Account

History, attached as Exhibit A.1 Due to this history of non-payment and disconnection notices,

PGE found that Complainant no longer met credit requirements. See PGE Tariff Rule D(4)

Section B(4). Thus on July 12, 2005, PGE sent a letter notifying Complainant that its account

would need to be paid in full immediately or PGE would require Complainant to pay a deposit.

See Letter from PGE Credit Department to Ash Hill Inc., dated July 12, 2005, attached as

Exhibit B.

On July 14, 2005, Complainant made a payment in the amount of $308.00 to PGE’s Field

Connect Representative (FCR) and avoided disconnection of service on the past due amount.

Because of this payment, PGE did not assess a deposit. However, Complainant continued not to

pay its bills. On November 28, 2005, Complainant received another 15-day notice of

disconnection for non-payment, and received a 5-day notice in writing and via telephone on

December 6, 2005. This prompted a payment on December 15, 2005.

1 Complainant received a 15-day written notice of disconnection on May 25, 2005 and a verbal notice by

telephone on June 10, 2005, per PGE’s practice at the time. Similarly, Complainant received a 15-day written notice of disconnection on June 24, 2005, and a verbal notice by telephone on July 8, 2005. Subsequent to this time, PGE changed its practice to deliver the 5-day notices both in writing and verbally by telephone.

Page 3 – ANSWER OF DEFENDANT

After the December 15, 2006, payment, Complainant stopped paying its bills and

received a 15-day notice of disconnection on February 27, 2006 and a 5-day notice on March 7,

2006. On March 13, 2006, PGE issued a new letter informing Complainant that due to its unpaid

balance and history of non-payment, a deposit in the amount of $200.00 would be required to

ensure uninterrupted electrical service. See Letter from PGE Credit Department to Ash Hill Inc.,

dated March 13, 2006, attached as Exhibit C. On March 15, 2006, a PGE CSR spoke with a

representative of Complainant, Mr. Brian Ashby. Mr. Ashby promised to pay $332.11, which

was the amount due at the time the February 27, 2006 notice was posted. The pending

disconnection was cancelled.

A new 15-day notice of disconnection was sent on March 28, 2006. On April 3, 2006,

Complainant made a payment of $332.11. In between the time Complainant received its

February 27, 2006, notice of disconnection and the date of his payment, however, two more

months of service had been billed to his account, along with the $200.00 deposit to the account

as described in the March 13, 2006 letter. Thus after the April 3, 2006 payment, Complainant

still owed $381.83 on its account.

Complainant failed to pay the outstanding balance and new bill for service, and was

issued a 15-day notice of disconnection on April 26, 2006 and a 5-day notice on May 4, 2006.

On May 10, 2006, Mr. Ashby spoke with a PGE CSR and was informed that he was required to

pay the arrears on his account no later than May 12, 2006, to avoid disconnection. Mr. Ashby

asserted that he should be up to date on his payments because of the $332.11 payment he had

made in April. The CSR informed Mr. Ashby that $200.00 of the payment made in April went to

the deposit, and that Complainant still had a significant unpaid balance. Complainant did not

make any additional payment on the account after that time.

Page 4 – ANSWER OF DEFENDANT

On May 17, 2006, a PGE FCR traveled to Complainant’s location to collect the past due

amount on the account or disconnect the service. Complainant did not make the payment, so the

PGE FCR disconnected service.

Following the filing of the complaint and the payment made by the Complainant in the

amount of $170.00 to protect the utility from further losses, service was reconnected at 3:20 p.m.

on May 23, 2006.

DISCUSSION

PGE complied with its tariff and all applicable rules and regulations with regard to

Complainant’s account. As the Account History shows, Complainant made only sporadic

payments on its account, generally after the history of non-payment triggered a 15-day or a 5-day

disconnection notice. Complainant received numerous 15-day and 5-day notices of

disconnection. See Exhibit A.

Per PGE Tariff Rule D(4) Section B(4) the Company may verify a nonresidential

Consumer’s creditworthiness at any time. If the Consumer does not satisfy the credit criteria, the

Consumer may be required to provide a deposit equal to a maximum of two months’ billing. In

July 2005, after Complainant failed to pay its bills for a number of months, PGE sent a letter

notifying Complainant that a deposit would be applied to the account if Complainant did not

immediately pay the past due amount. See Exhibit B. Complainant initially complied, but then

proceeded to run up another large past due amount. In March 2006, PGE sent Complainant

another letter informing it that due to its history of non-payment, a deposit of $200.00 was

required for continued service. See Exhibit C. A representative of Complainant was also

informed about this deposit requirement in a telephone conversation with a PGE CSR prior to the

Page 5 – ANSWER OF DEFENDANT

deposit being charged to the account. This amount was charged to Complainant’s account on

March 28, 2006.

PGE has provided a detailed record of Complainant’s account and copies of letters sent to

Complainant regarding the deposit requirement that demonstrate that PGE complied with its

tariff and all applicable rules and regulations. There can be no genuine dispute that PGE

properly billed Complainant and provided it with proper notice of the deposit requirement.

CONCLUSION AND RELIEF REQUESTED

PGE complied with its tariff and all applicable rules and regulations with regard to

Complainant’s account. PGE therefore respectfully requests that this Complaint be dismissed.

DATED this 7th day of June, 2006.

Respectfully submitted,

/s/ INARA K. SCOTT_______________________Inara K. Scott, OSB # 01013Portland General Electric Company121 SW Salmon Street, 1WTC1301Portland, OR 97204(503) 464-7831 (telephone)(503) 464-2200 (telecopier)inara.scott@pgn.com

Page 6 – ANSWER OF DEFENDANT

CERTIFICATE OF SERVICE

I hereby certify that I have this day caused the foregoing ANSWER OF DEFENDANT

PORTLAND GENERAL ELECTRIC COMPANY to be served by First Class US Mail, postage

prepaid and properly addressed, and by electronic mail, upon the following party in this docket:

Bryan Ashby21633 S Highway 99 ECanby OR 97013ashhillsigns@aol.com

Dated at Portland, Oregon, this 7th day of June, 2006.

/s/ INARA K. SCOTT_______________________Inara K. Scott