First Amended Code of Conduct
To establish, implement, monitor and improve a system of operations to prevent anti-competitive
activities that could result from SRP providing both competitive and noncompetitive services to
retail electric customers. This First Amended "Code of Conduct" will meet or exceed the required
elements of the Electric Power Competition Act (the "Act"). The Act requires a Code of Conduct
address:
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Policies for allocating costs between noncompetitive and competitive activities to avoid
cross-subsidization.
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Policies to prevent employees providing noncompetitive services from directing retail
electric customers to the public power entity's competitive services.
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Policies to prevent employees from transferring proprietary information gained in the
performance of noncompetitive services to employees engaged in performing competitive
services without the consent of the retail electric customer.
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Policies to provide retail electric customers with complete and accurate disclosure of which
services are competitive and which services are noncompetitive.
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Policies to prohibit preferential treatment when providing noncompetitive services based on
a retail electric customer's provider of competitive services.
This First Amended Code of Conduct reflects the action of SRP, as required by the Act, to make
competitive all energy, metering, meter reading and billing by December 31, 2000.
Effective January 1, 2001, this First Amended Code of Conduct replaces the Code of
Conduct adopted by the SRP Board on November 9, 1998.
SRP management is directed:
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To adopt the Code of Conduct principles set forth herein and to implement these principles
as soon as possible with substantial compliance by May 1, 2001.
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To complete where possible organizational, procedural, and computer system changes
necessary to implement this First Amended Code of Conduct no later than May 1, 2001.
If it is not feasible to complete final organizational, procedural and computer system changes
by May 1, 2001, interim procedures, managerial controls and employee training will be
employed to meet this code . Management shall thereafter report to the Board periodically
on the status of managing and implementing this First Amended Code of Conduct.
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To provide education and training no later than May 1, 2001 to all affected SRP employees to
instruct them on their obligations under this First Amended Code of Conduct. SRP will implement
a continued program of education and training to ensure that employees understand and perform
their obligations under this First Amended Code of Conduct.
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To report the status of these efforts to the Board no later than July 31, 2001.
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To monitor on a continuing basis the compliance with this First Amended Code of Conduct,
instituting additional procedures or training as may be needed to monitor and ensure proper
compliance.
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To provide annually an audit by an independent auditor of compliance with this First
Amended Code of Conduct. The purpose of the audit is to determine whether SRP has
complied in material respects with the requirements of this First Amended Code of Conduct.
Section 1. Definitions
As used in this First Amended Code of Conduct, the terms below have the following meanings:
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"Competitive services" are metering and meter reading ("metering services"),
billing and collection services ("billing services"), and electricity service.
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"Electric distribution facilities" means all property used in connection with the
distribution of electricity from an electric generating plant to retail electric customers, except
electric transmission facilities.
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"Electric distribution service" means the distribution of electricity to retail
electric customers through the use of electric distribution facilities.
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"Electric transmission service" means the transmission of electricity to
retail electric customers or to electric distribution facilities and that is so classified by the
Federal Energy Regulatory Commission or by SRP's Open Access Transmission Tariff.
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"Noncompetitive service" means electric distribution and transmission service.
Section 2. Cost allocation
SRP will allocate costs between the provision of competitive and noncompetitive services.
The objective of such cost allocation is the prevention of cross-subsidies between the services.
In performing cost allocations, SRP will utilize methodologies which are generally accepted in
the United States.
Section 3. Non-discrimination
No customer will receive any preference or will be discriminated against in the provision of
any noncompetitive service because of the customer's choice of supplier for any competitive service.
SRP will plan, engineer, construct, and maintain its electric distribution system without regard for the
commercial origin or ownership of the energy carried by the system.
SRP will operate its electric distribution system on the basis of sound utility operating principles
and without regard for the commercial origin or ownership of the energy carried by the system.
SRP will perform emergency restoration of electric service using sound utility operating principles
and without regard for the commercial origin or ownership of the energy carried by the system.
SRP will have procedures to limit access to the identities of customers' suppliers of electricity,
metering, or billing services on a need-to-know basis.
SRP will apply its standards for the installation of new distribution service equally to all similarly
situated customers, regardless of the customer's supplier of electricity, metering, or billing services.
SRP will establish service standards for metering and billing services which apply equally to all
similarly situated customers, regardless of the customer's supplier of electricity, metering, and
billing services.
SRP's standards and procedures relating to noncompetitive services such as
contributions-in-aid-of-construction, special facilities charges, and service connections and
terminations, will preclude preferences or discrimination on the basis of the customer's
choice of supplier of electricity, metering, or billing.
In processing and resolving customer complaints about distribution service, SRP will not discriminate
against or grant any preference to any customer due to the customer's choice of electricity, metering,
or billing service provider. SRP may, however, establish different, non-discriminatory complaint
procedures for handling different types of complaints.
Section 4. Marketing, sales and customer service activities
SRP will have procedures to provide customers contacting Customer Services with sufficient
information about which services are provided only by SRP, and which are available from SRP
and others.
Upon request, SRP will provide customers with the phone number or Web site of the Arizona
Corporation Commission for lists of suppliers of unbundled electricity, metering, and billing services.
SRP employees engaged in providing noncompetitive services will not direct customers to
employees engaged in selling electricity, metering, or billing services. For the convenience of
customers, such calls will be transferred to providers of electricity, metering, and billing services,
if such providers have contracted with SRP for such transfers.
SRP employees providing customer service for noncompetitive services will not provide evaluations
or recommendations of suppliers of competitive services, including SRP as a supplier of competitive
services. The choice among competitive service options will remain with the customer.
Sales organizations within SRP selling competitive services will be organizationally separate from
noncompetitive functions, except that SRP may, with appropriate safeguards to insure functional
separation, use single groups or centers such as telephone and billing services centers.
SRP will not release without written customer consent non-competitive information.
Employees engaged in providing noncompetitive services may conduct joint sales calls with
all competitive service providers, on the same terms, if requested by the customer involved.
SRP will include in written advertisements for competitive services a statement explaining that SRP
will not discriminate in noncompetitive service based on the customer's supplier of any competitive
service.
SRP will not state or infer in any advertisement for a service which is also available from
others that SRP is the sole supplier of that service or that purchase of that service from SRP will
result in any preference in noncompetitive service.