Electricity and Gas Rules Review Workshop
Docket Nos. UE-990473 and UG-990294
June 24, 1999
9:30 a.m. - 2:00 p.m.

Attendees:

 Bruce Folsom, Avista
 Renee Webb, Avista
 Lynn Logen, PSE
 Lois Douglass, NW Natural
 Lisa Rasmussen, PSE
 Phillip Popoff, PSE
 Karl Karzmar, PSE
 Royal Drager, PacifiCorp
 Robin Cross, PacifiCorp
 Onita King, NW Natural
 Gene Cardon, PacifiCorp
 Evan Sheffels, Public Counsel Law Clerk
 Matt Stevenson, Public Counsel
 Michael Karp, Energy Project

WUTC Staff:

 Dennis Moss, Facilitator
 Tani Thurston
 Pam Smith
 Penny Hansen
 Graciela Etchart
 Marjorie Schaer
 Jim Russell

DM: Introduction:  This is a continuation of the stakeholder meeting that we 
started a couple of weeks ago.  We got through most of the rules, but we had 
five left over items that we didn’t touch on at all.  In addition to those five 
we’ll talk today about one that we also talked about last time and that is WAC 
480-90-046 and the corresponding electric rules is WAC 480-100-046 that’s 
Application for Service.  I have been asked that we touch on that one today as 
well as these other five.

Last time, when Jeffrey Showman was the facilitator I know he went over a set 
of ground rules for participation and I’ve looked over those this morning and 
just will quickly re-state the ground rules for success in this type of a 
meeting. (went over ground rules).

LR: Do we have an agenda?
DM: I can give you an agenda very quickly.  The agenda is fairly simple today.  
We didn’t publish a separate agenda.  We have the agenda from the original 
meeting and that was available.  We will be looking at rules 90 and 100-046.  
Then we’ll look at five other rules.  We will look at 90-072 and corresponding 
rule on the electric side of 100-072 - Payment Arrangements.  We will look at 
90-96 and 100-96 which concerns Complaints and Disputes.  Next we will look at 
90-106 and 100-101 and that’s Form of Bills.  Then we will look at 90-116 and 
100-111 - Refunds of Inaccurate Metering.  The last one is 92-211 and 100-311 
which concerns Business Offices.  We’re limited to that part of the agenda 
today.  If we have time at the end, we can revisit issues that have been 
discussed earlier.

We’re scheduled until 2:00 p.m.  We may be able to move through this by noon 
and break at lunch and not return.  Is that something everybody else would like 
to shoot for as a goal?  Or should we just keep more relaxed?

LR: I think we should take as much time as needed.

DM: OK

WAC 480-90-046 and 480-100-046 - Application for Service

TT: We talked about this rule last time and we talked more on what is required 
to identify the customer.  When I was looking at this rule again, I had 
questions about what kind of information is actually required to establish a 
service order. I know the name and address and the customer’s phone number.  
But, are there other things the company looks for from the customer and needs 
from the customer to order a service?

RW: On our application for service we will ask for their employer.  That’s one 
of the conditions of waiving a deposit.  If they’ve been employed, we ask them 
where and how long, in case there was need for verification of that.  There are 
also times when we’ll ask for nearest relative information.  That is a 
follow-up or a contact person in the event that we can’t get a hold of the 
customer of record.

TT: Do you ask for the type of service, residential and commercial or that type 
of thing?  Or, does that not matter?

RW: If it’s a commercial account we will ask for some additional information.  
We’re going to set it up in the name of the business versus the customer of 
record.  We ask who the key people are that will be responsible for payment of 
the bills, then also, how to get a hold of them.

GC: We will ask for social security number, we won’t require that but we’ll ask 
for it and we will also ask for a driver’s license number.  That not only helps 
us establish the identity but for tracking them down later for refunds.  That 
also helps out if we need to turn them over to a collection agency.
TT: Is the driver’s license required?  If they don’t give their social security 
number, do you require their driver’s license number?

GC: I don’t know that we require that.  But we try to get that.

TT: Do you actually use application forms?  Because the rule speaks to the 
company may require an application form to be completed.  Are we into that or 
not?

RW: We do not have a form that the customer fills out.  Our computer system is 
designed so that the customer can answer the questions that are asked and we 
fill it in on line as they are speaking with us over the phone.

GC: We pretty well do the same thing inasmuch as we have business centers 
rather than local offices.  I believe in the last one we also talked about the 
ability for a field person to verify....

TT: Yes I had that.  So someone to actually go out to verify who’s actually out 
there.  But I didn’t know about the forms.  I’d like to know if we needed to 
update that.  We may need to.

DM: Maybe we can define the question this way.  Does anybody use forms?

Lois: We do use forms.  We would like to continue to have that.  We like to 
have the signature on file.

TT: Is that a requirement for you to have that signature on file?

Lois: It’s not always a requirement.  If we have a situation where there may be 
fraud, or we think there is fraud, then we will ask for a signature or some 
form of ID.  But we do have customers come in and fill out forms.

LL: We don’t require forms if it’s an existing service.  But if they’re 
requesting a new service to be constructed, especially a large commercial 
service, we do require a rather extensive form with loading and that type of 
thing, if you’re dealing with an office building or something like that or 
motor sizes.  We need it to do the engineering.

DM: So, if I’m hearing you right, there may be special circumstances where a 
form is required and other circumstances where it’s simply not needed?

LL: That’s right.  If we have, for example, a single family residence on a 
street that already has power on the street and we are just going to run from 
the transformer to the house, I don’t believe there’s any written application 
required for that.  It’s done over the telephone.  But, if it’s a parcel of 
property and it’s going to be developed for a residential plat, then we would 
require an application for that, specifying how many lots and of course 
attached to that would be a copy of the plat that was filed so we would know 
where all the property lines are and things like that.

DM: If I’m hearing her then from Northwest Natural and PSE as well is that it’s 
an option that you would like to have available and open to you on a continuing 
basis.

DM: Anything else on that?

WAC 480-90-072 and 480-100-072 - Payment Arrangements

DM: The Commission had previously received some comments from Cascade and 
Northwest Natural on the gas side of this particular rule.

PS: The payment arrangements and responsibilities.  There are a few issues that 
have come up due to the mergers and the combined billings.  I wanted to address 
with partial payments, what happens when a customer makes a partial payment? 
How have you guys handled and then of course, along with that is if the 041, 
what do you do about the other, how they’re allocated?

DM: How do we handle duel billing at the companies where there’s a deficiency?

LR: Currently, I don’t know if you’re aware or not, at PSE we’re still 
operating off two separate customer systems due to the merger.  We’ve been able 
to perform, what I call, a miracle.  We’re able to take information from both 
systems and allow the customer to receive one bill.  So, in the event the 
customer pays a partial payment, that partial payment is allocated based on the 
percentage of each energy bill.  For example, let’s say a customer owes us a 
total of $100, $75 is electric and $25 is gas.  Then they send us $50.  Twenty 
percent of that $50 payment would be allocated to gas and 75% of that payment 
would be allocated to electric.

That’s currently how it’s handled.  We had to handle it that way because of the 
nature of the two separate systems.  What we look forward to doing in the 
future, when we have one CIS system, which should be available mid next year.  
We kind of looked at what Pacific Gas and Electric was doing in California.  
They applied partial payments to the customer’s account balance, because they 
believe that, if the customer owes $100, regardless of $25 is owed on gas and 
$75 owed on electricity, they still owe the company $100. The partial payment 
of $50 is applied to the $100 and that’s split between the two energy types.

PS: Under that system what happens if it’s delinquent, do you disconnect both 
services?

LR: Exactly.  Normally the electric is disconnected first if it’s not paid and 
the gas is disconnected second.  With other gas and electric utilities that we 
have talked to about how they handle this partial payment, combined utilities 
have told, this is what we do.

DM: And you’re looking to that practice for the future?
LR: Yes.

RW: Our current billing system bills separately for the electric and gas and 
combines it onto one bill currently also.  Payments that come in are applied to 
account balances, similar to what Lisa was referring to.  However, our practice 
of disconnection is in reference to the electric.  The reason for that is, what 
we’ll do is we’ll go out and disconnect the electric meter, for the most part, 
and leave the gas on.  If we were to disconnect the gas, the arrangements for 
the customer to be home and schedule and make sure there is an adult there is a 
very challenging thing to meet.  If you just disconnect the one service it 
makes it lot easier on the customer getting the re-connection completed.

LR: Let me make my statement a little clearer too with Pacific Gas and 
Electric.  They disconnect the electric first.  Then they wait seven to ten 
days.  If the customer does not call for re-connection of service, they make 
the assumption that customer is no longer there.  Then they follow up with the 
disconnection of gas.  You absolutely are correct bringing up the issue of 
restoration of gas service is a lot more difficult.

BF: I would just like to add that we would be concerned if we had to divide our 
billing system up into two different fuels, gas and electric, and then split 
stream revenues to one of those, because that would cause us to incur a lot of 
cost to change the system we currently have.  So, we are hopeful that the 
current system would remain the same, otherwise we would have quite a cost 
attached to making any necessary changes to reflect any changes in this rule.

DM: I want to be sure that everyone understands because I find myself a little 
confused.  I thought I had heard from Renee that you do maintain a separate gas 
and electric, but then you send a single bill.  Maybe I misunderstood how you 
do it.

BF: That’s exactly right and that’s what she said.  When it comes to monies 
coming in it goes into one pool.  It isn’t segregated.

DM: So that’s an accounting issue within the company?

BF: It would be an accounting issue within our information system inside our 
computer programming and we would need to change some practices at some 
actually great expense to reflect to separate pots of money coming in.

DM: Let me be sure I understand one last point and this goes back to what you 
said Renee.  You said that your practice is similar to PSE’s practices.  Lisa 
was explaining that you do allocate between, using the mathematical example she 
used where the $100 is owed, you don’t do that?

BF: No, but it would have the same effect.  In both instances the customer 
would have payment owed in both fuels.  While we don’t have the straight 
percentage split, it would have the same end result that PSE has.
DM: OK

MS: What would you do if you had a customer that sent in $50 and wrote a note 
that said, “Please apply this first to my gas and not my electric?”.

BF: We would apply it to the gas account as the customer requested.

MS: So, that they are trying to manage the fact that they are out of money and 
they may have to go without...(tape is unclear)

BF: It’s our understanding that the common practice is that customers can 
dictate where their money goes.  So, we’re following that general philosophy.

MS: Is that true for PSE also?

LR: Yes it is.  At this time it is, yes.

MS: The place I’ve been involved in has just become...(tape is unclear)....we 
would be looking at them as both a basic service provider and as someone who is 
selling a phone services...(tape is unclear)...we’ve taken a position there 
that, as long as the basic phone is paid for they cannot be 
disconnected....(tape is unclear)  .as long as the basic phone is paid 
for...somewhere in your...(tape is unclear)...at some future point....(tape is 
unclear)... particularly with gas customers paid for basic service and 
purchased from you or from someone else their other gas.  What do you do in 
those circumstances?

BF: I have three responses and I’ll try to make each brief.  When it came to 
our pilot program More Options for Power Services (MOPS) and we had a third 
party energy provider, they ended up cutting their own bills to the customers 
for that very reason.  That’s answer number one.  Answer number two.  When we 
offer new products and services, the payment hierarchy has that coming in 
last.  If a customer makes a partial payment, the payment goes to the regulated 
services first.  My third response is, we are going to sit down and chat with 
staff, in the very near future, because we are examining, what we call the one 
bill concept, convergence of Telco, electric, gas, new products and services.  
With that comes a whole host of issues, including payment hierarchy and the 
like.  We do want to sit down with you, sometime in the next month, before we 
go much further.  We’re just starting this concept, maybe looking at the year 
2000, but we do want to sit down and go through some of the details.

PP: I just wanted to ask one clarifying question with the telephone example.  
If you fail to pay your long distance part of the bill, then who’s caught 
short?  Is it local phone company that’s caught short, or who takes the loss?

MS: It’s my understanding that the local phone company is providing a billing 
service and they get paid for their billing service but that ATT and whoever’s 
out there not getting the money is the one that has the collection burden.  Is 
that correct?
PS: Yes that’s correct.

TT: Normally the local service is covered as long as there’s enough payment to 
pay that.  Then the long distance part isn’t, but the customer may be totally 
restricted.  So there may be some disconnection issues there.

PP: So then it’s the long distance provider that’s caught short?

TT: But there are times when the local phone company pays that anyway.  They’ve 
already paid the long distance company.  Then it’s the local phone company that 
still gets caught short because they’re to recoup their payments to the long 
distance company.

PS: They have elaborate billing contracts.  For example, these figures are not 
quite correct but say they will get anything over 98% that they collect as or 
whatever.  It’s to their favor to collect as much as possible.

TT: It depends on how the contract is....

PP: So it’s not that easy to address that issue.  It would seem to make a huge 
difference if, say in the gas example, a transport customer, I can’t think of 
where we actually do this, but if we were to bill for some gas supplier and 
that we somehow pay the gas supplier for the customer and then the customer 
doesn’t pay us....

PS: And the recourse is to the other provider then they can pursue collection?  
So they might just say forget it, it’s going back to that company and if they 
want to pursue collection they can, whether they choose to or not.

MS: So if you site a contract with that company to do their facility and 
collection that’s something that you do think about.  But what do we need in 
the rule about that?  Do we need to put in....(tape is unclear)... I know we’ve 
changed the rule in Telecom.  I thought we had about four or five years ago.  
They were allocating to...

TT: Basically just it says that the local service can’t be disconnected for 
nonpayment of the long distance.

DM: Bruce that does bring us back to the question that’s in my mind.  Based on 
what you said, you said you wanted to open this dialogue with the staff and I 
want to know, do you mean in the context of this rulemaking or in another 
context?  I guess I should say, should we be opening these sorts of issues up 
as part of this rulemaking process?  What do you contemplate?

BF: We contemplated outside this rule process to sit down with staff and say, 
under the existing rules or the then current rules this is how we propose doing 
it, what should we be aware of?  Do you have any concerns with our proposal?  
We think this fits under your rules and conditions be they now or updated.  So 
outside of this forum.
DM: Does anybody have any comments on should we be considering broader these 
broader issues? Staff?

TT: It might be something that we want to take under consideration.

DM: That’s something that could be taken up, perhaps, outside the context of 
our meeting today.  Maybe it breaks some new ground and should be given some 
thought as we move forward.  Anything else?

PS: This is something that we don’t have in the gas rules and it’s something 
that we have considered and that is offering customers, prior to being 
disconnected, one time six month payment arrangements. I wanted some comments.  
We do it in telephone and it just allows an opportunity to the customers so 
that they don’t have to be disconnected. Then they have to pay the 
re-connection fee.  It gives them a one chance, an opportunity.

LR: On all the notices we send to customers we always say, please call us for 
payment arrangements in order to avoid that disconnect.  That’s something that 
we don’t want to do.  It creates, certainly expense to the company as well as 
an inconvenience for the customer.  I would prefer if we could continue to do 
it that way, continuing offering these payment arrangements to customers.  We 
do, I know on the electric side, about 45,000 to 60,000 payment arrangements 
per month.  So we do a sizable number of payment arrangements.  If we can have 
that flexibility and just leave that notation on the notices I think that would 
suffice.

TT: Lisa are there times when a customer may call and they are not allowed to 
make a payment arrangement?

LR: I would have to say that’s a rare occasion.  There must be some really 
valid reasons why we would not make a payment arrangement.  To give an example 
when this possibly could happen, because we track how customers have completed 
prior arrangements.  If we see a whole page on the PC of delinquent payment 
arrangements, we probably would not be as open to making payment arrangements 
because of the customers prior performance in this area.  But with the volume 
of payment arrangements that we do make, my gut would tell me that 99 9/10% of 
them we do make a payment arrangement with.

PS: I guess I think all of the companies do very well with payment 
arrangements.  But I think at times they may be too steep, and usually you want 
to clear up the bills in, what two or three months, and I think sometimes that 
might be too much for the consumer.  They call us and many times we are able to 
work with you guys and make six month....

LR: I really believe that’s an exception though and not the rule.

DM: Anything else?  Robin?

RC: We work with our customers as well as PSE does for making payment 
arrangements.  The exception would be a customer that has used prior obligation 
and defaulted on prior arrangements.  Those customers we are not going to work 
with.

RW: When I first read that question I failed to notice that this was prior to 
disconnecting service and my first comment was, or first thought was, it makes 
sense to definitely work with a customer who’s been disconnected to work out 
how they are going to make payment on the delinquent balance and to work with 
them on that payback of their unpaid bill.  We definitely agree to working out 
a specific set format of arrangements.  However, I feel though it’s very 
important that in the event that a customer defaults on a payment arrangement 
that it’s agreed upon that we should have the right to disconnect for that.  
Even though they’ve been disconnected, if we reconnect the account and agree to 
an arrangement of six months or three months or four months to pay back this 
delinquent balance and they default and do not make the payment that the 
account should be disconnected again and the customer should be required to pay 
that default of what they had agreed to for either reconnect or for a condition 
of leaving the service on in either case.

DM: OK

MS: What do you think about the specific comment Pam made of having in the 
rules a one time six month payment arrangement before disconnect?  Would anyone 
have problems with that?

RW: I would agree in the event that we could require the amount that they were 
delinquent for as a condition of reconnect.

LR: Renee are you saying though that you’re agreeing with this six-month 
payment arrangement in the event that the customer has been disconnected and to 
get the service reconnected again to make a six-month payment arrangement?  No, 
open up a six-month payment arrangement to all delinquent customers.

PS: This is prior to being disconnected.  So the person owes $150 and they’re 
about to be disconnected and they call us and they say I can’t do it in three 
months, say if I have six, so I call the company.  A lot of times it happens 
informally.  And I say how about six months and they say, OK current plus six 
months to get it paid off.....

LR: Just to state my opinion on having a blanket payment arrangement for six 
months that the utility is required to offer to all delinquent customers.  I 
disagree with that.  As again, I stated earlier, on a number of payment 
arrangements we make on a monthly basis.

GC:  One of the problems that might occur if we look at a mandatory six 
months.  We need to look at the customer’s ability to pay.  If they’re in a 
delinquent status because they are not able to pay then we need to look at that 
and it’s in our best interest also, to make the arrangements that they can keep 
so that we don’t incur additional costs to disconnect and sending notices and 
that difficulty.  But if it’s because they are unwilling to pay and we are 
required to go out six months, then I can see possibilities of our accounts 
receivable increasing for no particular need.  I think we have done at 
PacifiCorp a pretty good job of looking at customers ability to pay and I would 
not like to see us required to go six months on every single first payment 
arrangement.

TT: What about the scenario of six months, but if they miss one payment then a 
disconnection can take place?

RW: I’ll repeat it again.  As long as you could require the amount of money 
that they are delinquent for a condition of reconnect would make sense.

OK: We offer time payment plans to anyone who is having difficulty paying their 
bill and we actually provide a full year payment plan option.  But I don’t know 
that we would necessarily want to have a mandatory six month plan contained 
into the rule.

PS: So, what you’re saying is, if they went into a six-month arrangement and 
missed it and they owed $100 they absolutely don’t get reconnected unless they 
paid the $100?

RW: Correct.

BF: This is embodied in our original comments on page five where we actually 
have language to pick that up.  You set up some sort of payment plan and then 
if there’s a missed payment there is language to disconnect service for failure 
to comply with the payment plan that they had agreed to.  Be it two months or 
six months or twelve months.

DM: So you actually sent some language to staff on that?

BF: Yes.  And it follows the Oregon rule to some extent.

LR: Again, just for my clarification.  This is an arrangement for a customer 
that’s been disconnected? No it’s everything.  OK

RW: Originally I was referring to this question.  “As a payment arrangement 
responsibility from a delinquent disconnected customer to start with.”

LL: I just have a clarifying question.  The one time six-month, is that once in 
a customer’s lifetime, or is it once every year, once at each location that 
they live at?  There’s a lot of options.

PS: That’s hard to...  I would say it would not be once a year.  I’m sure you 
could track the customer down and say something like “six year s ago “ I think 
that would be something we’d have to look at.  One per year definitely not.  
Depending, they have a way of moving around.  I think they usually know what’s 
going on.

LL: I guess I would have a concern that I really haven’t heard voiced here but 
inferred to.  If we had a mandatory six months, anybody that’s going to move 
and didn’t like paying their bills, would call up and make those arrangements, 
unless we were allowed to disconnect or something like that.  If you knew there 
was a rule out there that you could get six months arrangements you’d not pay 
as long as you can then get six months arrangement and then move out at some 
point.  Then you have service until you move out.  Because we don’t serve the 
whole state or the whole region, any particular company, in our case anyway, 
they can move to Tacoma or Seattle or Snohomish county and get electric service 
somewhere else and we don’t see them again.  Because of privacy, we can’t share 
that information with the customers, plus the rule wouldn’t apply to those 
other utilities anyway.

BF: I think this brings up an interesting point.  Staff has talked about having 
some sort of electronic subcommittee to draft the rule.  This will be a classic 
case of a lot of iteration going back and forth because as Lyn and Lisa and 
Renee and others deal with this on a real time basis, we’re going to need to 
pick up all of these nuances.  So just kind of a heads up that there may be a 
lot of iteration needed as we draft this and I think all of us would like to 
help to make it a reality and reflect reality.

DM: It doesn’t sound likely that we’re going to have a specific proposal today 
as to how we want to implement this aspect of it, if at all.  This would be a 
subject, for example, that would fall within that sort or procedure.

BF: Excellent

PS: Then there’s another thing that we have always done unofficially, but it’s 
never been in the rules and that’s,  if you’re delayed in billing, if the 
customer doesn’t get a bill for a couple of months, we have always given them, 
and you guys have always been very good about giving them, the opportunity to 
pay it back in the same amount of time.  So everyone’s fine with that.

Then Cascade and Northwest Natural had brought up the moratorium.  The winter 
moratorium.  I thought I would ask you guys if you could clarify your position.

OK: I’m not really hands on with this so maybe Lois is better to address the 
problems that we’ve had.  But, like I said, we do actually offer a payment 
arrangement to all of our customers.  In our minds that is sufficient 
flexibility even for customers with low income issues.  And it is more 
difficult to find the funding and to get to the agencies and the complications 
of processing that kind of account is becoming more cumbersome these days.

LD: What you find too is some seniors that will not go and apply for assistance 
just because they’re too proud.  So if you have this type of growth here and if 
we were required to offer payment plans to those people that applied for 
assistance then you would loose those customers that you are really trying to 
help.
PS: I don’t know that the rule would prohibit you from giving arrangements to 
people.

LD: Yes, but the way it is written is what we’re ....We would like to offer 
plans to everyone and if we could eliminate these three and four and just say 
we offer plans to all customers whether they are low income or they need energy 
assistance.  Then not having to go through and figure out whether it’s 7% of 
their wages and kind of communicate with the agencies to verify all of this 
information.  To just open it up and say that we offer plans to everyone and 
make it easier for the customer and for us to manage.

DM: Lois is that something that would work for you as an option to the present 
rule?  In other words if there were a provision added that would give the 
company the option of offering the plans to everyone?  Is that something that 
would satisfy your need?

LD: That would help.  Yes

DM: That’s a possibility then.  Anybody else have any ideas on this subject?  
Anybody else want to comment on this rule?

MS: We just had public counsel join us.  This is the kind of rule...(tape is 
unclear)

WAC 480-90-096 and 480-100-096 Complaints and Disputes

DM: We’ll have an opportunity to return to that at the end.  I think for right 
now we need to just go ahead and move forward to the next rule.  We’re doing 
072 so this will take us up to 480-90-96 and corresponding electric rule 
480-100-96.  This concerns complaints and disputes.  There were some comments 
received earlier.  In fact I suspect that the set I’m looking at is maybe even 
a little behind what has been received by now.

TT: I’ll start off with Avista who had some comments about defining the word 
“complaint.”  If you could go with that.

BF: This may simply be an issue of interpretation.  It may not need to be 
embodied in a rule.  But, it seems to us that there have been customers that 
have called the Commission staff and said “rates seem high.”  Should that be 
considered an inquiry or a complaint?  That’s the basis for our comments.  We 
think a complaint should be simply that which is an alleged violation of a 
rule.  Our concern is, looking at the big picture down the road, if we get into 
service quality issues and there’s any historically look at trends and 
complaints, we would hate to see a trend and complaints go up because of 
definition broadening to include inquiries about high bills, etc.

DM: How’s that been handled so far?  Bruce, as far as classifying, an inquiry 
versus a complaint?  Do you have some parameters that you imply now that could 
perhaps be incorporated into rule language?

RW: Currently the way that the process has been handled is everything is 
handled as a formal complaint.  Anytime the Commission contacts Avista.  There 
is a lot of paperwork and process involved to respond to, for instance, a 
customer’s inability to payment on the bill, we’re required to go in and 
provide the entire billing history of the customer, meaning his initial date of 
service, and his deposit requests and anything like that that went on.  When, 
in reality, the customer may ha