14. Suburban and DisabRA Memorandum of Understanding on Access Issues

Suburban and DisabRA reached their memorandum of understanding on access issues in July 2007. A draft of the MOU was attached to DisabRA's testimony. (Exhibit 8.) Agreement was reached on near-term accessibility improvements, ongoing accessibility improvements and accessibility improvements associated with Suburban's Cornerstone Project, an overhaul of its billing, data and communication systems. Near-term and ongoing accessibility improvements expand on the TTY (teletypewriter) requirements contained in the Suburban/Joint Consumers settlement and include the provision of TTY and customer representative training on TTY. The billing, data, and communications systems improvements include providing key information on the customer bill in large type, tracking large type customers and providing notice to them in large type, ensuring Suburban's website meets the requirements of an accessible website, track customers with TTYs in its billing and data systems, and track and provide information by e-mail on outages, service issues, etc. to hearing impaired customers.

DisabRA requests that the Commission adopt and enforce the MOU. We generally adopt settlement agreements that are submitted to us under our rules. The parties did not notice a settlement conference and did not provide the MOU to us by motion. In addition, we have a draft of the MOU that largely captures its terms but needed minor revisions before it was final. Nonetheless, we support the goals of the MOU in its broadening of the accessibility obligations of Suburban. Customer outreach and education on conservation rate design and non-rate design proposals will be improved by the terms of the MOU.

DisabRA and Suburban also agreed that intervenor compensation should be awarded for implementation of the MOU. Although we do not examine compensation requests in this decision, we award compensation for participation in our proceedings, not for separate activities such as ongoing implementation of policies we approve.

Park also agrees to implement the near-term and ongoing accessibility improvements contained in the MOU. Specific remedies proposed by DisabRA include large print notation and TTY phone numbers on bills and inserts as well as complete notices available on Park's website. Park notes the Cornerstone Project is specific to Suburban and does not agree to follow those terms of the MOU. We support Park's efforts in implementing accessibility improvements.