The initial request from Dunn asked for a review of of disconnection rules and policies, and specifically those in the Arizona Administrative Code that spell out when a utility can and cannot cut power to a customer. Olson subsequently filed a letter in the docket in support of Dunn's request.
Dunn also asked Commission-regulated utilities to share copies of their disconnection policies in order to see how utilities are actually implementing those rules. The Commission regulates 16 electric utilities in Arizona, but Dunn's letter specifically mentioned Arizona Public Service, the state's biggest electric utility with more than 1.2 million captive customers.
In his letter, Olson asked staff to evaluate what happened before and after APS disconnected Pullman's power, and to figure out whether APS complied with CorpComm rules and its own disconnection policy in shuttering her service.
In 2018, APS cut off power to customers more than 110,000 times, the utility's own data show, with more than 39,000 of those instances taking place during the scorching months of May through September.
Dunn asked CorpComm staff to assess rules in the Arizona Administrative Code regarding termination of service (see page 70 of the code) and to "recommend appropriate changes to these rules."
Those rules say that if customers can't pay their bill, a utility cannot shut off power under a short list of circumstances.
Yet those situations are either onerous to the customer or downright vague. They include:
• If customers can provide medical documentation proving that the loss of power would be "especially dangerous" to their health.
• If they use life-support equipment that requires electricity.
• "Where weather will be especially dangerous to health as defined or as determined by the Commission."
The way the Corporation defines "weather ... especially dangerous to health" (see page 60 of the administrative code) seems wildly inappropriate for regions of Arizona where summer temperatures regularly eclipse 100 degrees. The code says that such weather is when the National Oceanic and Atmospheric Administration forecasts that temperatures will not rise above 32 degrees the following day.
It concludes, without explicitly mentioning heat, "The Commission may determine that other weather conditions are especially dangerous to health as the need arises."
Dunn asked staff to review that definition, too. So did Olson.
CorpComm spokesperson Holly Ward said that New Times' queries about Pullman's death were brought to Commissioners on Wednesday evening, after the open meeting, and that Dunn "took action by filing that letter."
"We need to ensure that our disconnection policies are reasonable, fair, and just," Olson wrote in his letter backing Dunn, adding, "I am concerned with how our utilities implement their disconnection policies."
Jill Hanks, a spokesperson for APS, said the company welcomed the docket and "will cooperate with the Commission."