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HomeMy WebLinkAbout200403151st Response of Community Action to ID Power.pdfBrad M. Purdy Attorney at Law Bar No. 3472 2019 N. 17th St. Boise, ID. 83702 (208) 384-1299 FAX: (208) 384-8511 b mpurd y~hotmail. co Attorney for Petitioner Community Action Partnership Association of Idaho and American Association of Retired Persons. F~ECfJVED .. LED 2004 HZ;;? J '.'! ..-, n : 31 !17/LI, ;,. /y:L1CI i Ie) CUi"ii"1ISSiON BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY) TO INCREASE ITS INTERIM AND BASE RATES AND CHARGES FOR ELECTRIC SERVICE CASE NO. IPC-O3- COMMUNITY ACTION PARTNERSHIP ASSOCIA- TION OF IDAHO'S RES- PONSE TO IDAHO POWER COMPANY'S FIRST INTER- ROGATORIES AND PRODUCTION REQUESTS COMES NOW, Community Action Partnership Association ofIdaho, by and through its attorney of record, Brad M. Purdy, and in response to Idaho Power Company s First Interrogatories and Production Request to the Community Action Partnership Association ofIdaho (CAP AI), provides the following: REQUEST NO.On Page 7 of his testimony, Mr. Robinnette (sic, Robinette) testifies that LIW A annual funding should be increased to $1.2 million. Please provide copies of any documents or analysis that shows how that amount was computed or otherwise supports a funding level of $1.2 million. RESPONSE:Please see Attachment No.1 hereto. CAPAI'S RESPONSE TO IDAHO POWER'S FIRST INTERROGATORIES AND PRODUCTION REQUEST. REQUEST NO.2: . On Page 8 of his testimony, Mr. Robinette testifies to a total return on investment for weatherization. Please provide copies of the ORNL analysis that he cites to support the $3.71 benefit amount contained in his testimony. RESPONSE:Please see Attachment No.2 hereto which constitutes a summary of a voluminous report that can be obtained in its entirety by visiting http://www.eere.energy.gov/weatherization. REQUEST NO. 3:In Ms. Ottens testimony on Page 6 she describes a "gap" in energyaffordability. Please provide copies of the studies, analyses and calculations supporting the $96 million gap in 2002 and $113 million gap in 2003 she cites in her testimony. RESPONSE:Please see Attachment No.3 hereto which is the Home Energy Affordability Gap Idaho Fact Sheet. The Home Energy Affordability Gap analysis is voluminous and can be found at http://www fsconline.com -I'"" DATED this i2.- day of March, 2004. ,. 1, .- '"1, //(--. 1..-c/!!'.. /--- Brad M. Purdy CAPAI'S RESPONSE TO IDAHO POWER'S FIRST INTERROGATORIES AND PRODUCTION REQUEST. CERTIFICATE OF SERVICE -I L-., I HEREBY CERTIFY THAT I HAVE THIS /J-DAY OF MARCH, 2004 SERVED THE FOREGOING CAP AI'S RESPONSE TO IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS, IN CASE NO. IPC-03-, BY MAILING A COpy THEREOF, POSTAGE PREPAID TO THE FOLLOWING: Barton L. Kline Monica B. Moen Idaho Power Company O. Box 70 Boise, ID. 83707 () u.S. Mail, postage prepaid KHand delivered () Facsimile () Overnight mail John R. Gale Idaho Power Company O. Box 70 Boise, ID. 83707 () u.S. Mail, postage prepaid Di Hand delivered () Facsimile () Overnight mail Lisa Nordstrom Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington St. Boise, ID. 83702 (,;ru.S. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail Peter J. Richardson Richardson & O'Leary 99 East State Street, Suite 200 O. Box 1849 Eagle, ID. 83616 u.S. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail Don Reading Ben Johnson Associates 6070 Hill Rd. Boise, ID. 83703 N u.s. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail ('1 u.s. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail Randall C. Budge Racine, Olson, Nye, Budge & Bailey 201 E. Center Pocatello , ID. 83204 Anthony Yanke (.1' u.S. Mail, postage prepaid CAPAI'S RESPONSE TO IDAHO POWER'S FIRST INTERROGATORIES AND PRODUCTION REQUEST. 29814 Lake Road Bay Village, OH. 44140 () Hand delivered () Facsimile () Overnight mail Lawrence A. Gollomp 1000 Independence Ave., SW Washington, D.C. 20585 M. u.S. Mail, postage prepaid () Overnight mail () Hand delivered () Facsimile Dennis Goins Potomac Management Group 5801 Westchester St. Alexandria, VA 22310-1149 Dean 1. Miller O. Box 2564 Boise, ID. 83701 u.S. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail N' u.s. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail Jeremiah J. Healey O. Box 190420 Boise, ID. 83719-0420 f-J u.S. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail William M. Eddie O. Box 1612 Boise, ID. 83701 ~) u.S. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail r'J ' u.s. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail Nancy Hirsch 219 First Ave. South, Suite 100 Seattle, W A. 98104 Dennis Pesau 1500 Liberty St., Suite 250 Salem, OR. 97302 M U.S. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail (xi U.S. Mail, postage prepaid () Hand delivered () Facsimile () Overnight mail Conley E. Ward 601 W. Bannock St. Boise, ID. 83702 Michael L. Kurtz (4 u.s. Mail, postage prepaid CAPAI'S RESPONSE TO IDAHO POWER'S FIRST INTERROGATORIES AND PRODUCTION REQUEST. Kurt 1. Boehm Boehm, Kurtz & Lowry 36 E. Seventh St., Suite 2110 Cincinnati, OH 45202 () Hand delivered () Facsimile () Overnight mail ! -- -,,-- ;)fc~~' ::'~ Brad M. Purdy - ')..-;/ CAP AI'S RESPONSE TO IDAHO POWER'S FIRST INTERROGATORIES AND PRODUCTION REQUEST. CAP AI RESPONSE TO IDAHO POWER COMPANY' INTERROGA TORIES AND REQUEST FOR PRODUCTION ATTACHMENT No. IDAHO POWER COMPANY CASE NO. IPC-O3- IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND PRODUCTION REQUEST TO THE COMMUNTIY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAP AI) REQUEST NO. Request No. Idaho Power requests copies of any documents or analysis that shows how the amount was computed or otherwise supports a funding level of 1. million dollars. Response to Request No. On May 7 2003 , an Energy Strategic Planning Session was held in Boise Idaho to determine the needs for the future of Idaho s Low-Income Weatherization Programs. This meeting was attended by: Community Action Executive Directors, Weatherization Managers, Energy Auditors Energy Assistance Program Managers and Staff from the Community Action Partnership of Idaho. Michael Karp from AW.I.S.H facilitated this meeting. (See attachment). The meeting was to determine the consensus on a future plan with an overview picture of the energy situation in Idaho. Discussions encompassed all low-income weatherization funding sources, which included Federal funding sources from Department of Energy (DOE), Health and Human Services (HHS), along with the utility funding sources from A VISTA, BPA, PacificCorp., and Idaho Power. Goals were then set based on Agency s projected waiting lists and their ability to complete their contractual requirements with DOE, HHS and the additional homes from the utility companies without having to increase their current infrastructure. With the uncertainty of Federal funding, weatherization programs are reluctant to ramp up their crews, which would include the purchasing of expensive equipment such as vehicles, diagnostic equipment, and standard tools of the trade (i., duct blasters, blower doors, insulation equipment). Agencies felt they could successfully complete the additional requirements from the utility companies by hiring and training new energy technicians using current equipment and vehicle inventories. Energy Strategic Planning, Session May 7, 2003 Introductions: Ken Robinette, Michael Karp, Kevin Viggers, Teresa Nelson, Carol Gentile, Jenifer Scott, Marie Eilers, Jim Hall, Brad Simmons, John Danks, Randy Wright, Larry Stanford Ron Corta, Debbie Bloom-Staff, Mary Chant-Staff, Teri Ottens-Staff. Karp talked about the agenda and what we were expecting for the day. included: Consensus on a future plan Look for more money for weatherization and energy assistance Overview picture of the energy situation in Idaho Working with the utilities Thoughts State of the State: Energy Funding Sources Idaho A vista BPA Pacificorp Idaho Power HHS DOE Intermountain Gas PVE (included in DOE) (Petroleum Violation Escrow) WAf 155 000 283 000 000 260 000 EAP 1 m (DOE and HHS) Trends are headed towards energy based funding, not just heating and cooling. In order to get funds, we will need to invest funds. These expenditures (leveraging) are allowed off the top of the DOE dollars if it is written into our state plan. Some successes in other states Rate based energy assistance BP A Weatherization program Intervention in rate cases Goals: A vista - PacifiCorp Idaho Power BPA WAf 900 000 150 000 1.2 m EAP 1.6 m 1 m Tribal Centralized strategy 100 000 CAP AI RESPONSE TO IDAHO POWER COMPANY' INTERROGATORIES AND REQUEST FOR PRODUCTION ATTACHMENT No. IDAHO POWER COMPANY CASE NO. IPC-O3- IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND PRODUCTION REQUEST TO THE CO MMUNTIY A CTI 0 N P AR TNE RS HIP ASSOCIATION OF IDAHO (CAP AI) REQUEST NO. DOE Weatherization Assistance Program: Non-Energy Benefits of Weatherization'" . , ;it"" " ;.- ;:'i"::I::- ~~ s. Department of Energy ; ! k lft Energy Efficiency and Renewable Energy (;~t ;;Ji,'f. Page 1 of. EERE HornE ~ Weatherization Home About the Weatherization Assistance Program 27 Years of Service Reducing the Energy Burden on Low-Income Families Improving the Economies of LOIN-Income Communities Weatherization Assistance Program History What Is Weatherization? How Are We Organized? Program Goals & Metrics Program Evaluations DOE Guidelines Weatherization Technologies State Activities State Contacts Weatherization Information Resources Training Centers Search Help!: More Search Options !:.. Ask an Energy Expert Non-Energy Benefits of Weatherization January 2003 There are substantial non-energy benefits from DOE's Weatherization Assistance Program, according to a recent study by Oak Ridge National Laboratory (ORNL). The study documents benefits to utility ratepayers, the economy, and the environment that are in addition to the energy benefits that reduce the energy bills of low-income families by increasing the energy efficiency of their homes. Energy and Non-EnergyBenefits of Weatherization $1. Energy Non-Ener1jyBenefits BeneFits Each dollar of DOE investment inOW 0 va ue non-energy weatherization returns $3.71 inbenefits of energy- and non-energy-relatedweatherization? benefits. The U.S. Department of Energy (DOE) issued a press release on August 28 , 2002 announcing a report documenting considerable non-energy benefits from low-income weatherization. The report summarizes existing literature on how to value such benefits for participating households, utility ratepayers, the local economy, and the environment. While there is a large range of potential monetary values for these benefits, there is no question they are important for the communities that receive weatherization services. Furthermore, ORNL's analyses are useful for developing overall cost-benefit ratios. Researchers conclude that for every dollar of DOE investment, there are non-energy benefits worth $1.88. These benefits are in addition to energy savings, which reduce energy bills an average of $275 per year in more than 105 000 low- income homes in 2002. The cost-benefit ratio of energy reduction is $1.83 for each dollar of DOE investment. When the energy- and non-energy-related benefits are added together, the DOE Weatherization Assistance Program returns $3.71 for every dollar invested by DOE. Among others, the non-energy benefits of weatherization include: . For participating households, there are reduced water consumption and accompanying water and sewer fees, and an increase in property values. http://www.eere.energy.gov/weatherization/ne - benefits.html 03/02/200 ~OE Weatherization Assistance Program: Non-Energy Benefits of Weatherization. , Page 2 of . For utility ratepayers there are reduced costs for bill collection and service shut-offs. And because weatherization addresses the safety of major appliances, the utility has fewer emergency calls. . For the local economy, DOE's investment in energy efficiency generates a whole range of jobs in local home services industries. Nationwide, the Weatherization Assistance Program generates 8 000 jobs, which increases the tax base in communities throughout the country and indirectly supports other jobs. Furthermore, weatherization reduces the burden of unemployment payments for taxpayers and local businesses. . For national security, weatherization decreases U.S. energy use the equivalent of 15 million barrels of oil every year. . For the environment the reduction in energy consumption by low-income clients reduces the need for combustion of fossil fuels and the resulting emissions into the atmosphere. The report noted that there are additional benefits from weatherization that are not covered in the study because a monetary value cannot be assigned to them. Read this and other reports by Oak Ridge NationalLaboratory Non-Energy Benefits from the Weatherizati0n Assistance Program- A Summary of Findings from Recent Literature PDF 235 KB Download Acrobat Reader. Martin Schweizer and Bruce Tonn; Oak Ridge National Laboratory report number ORNL/CON-484; 41 pp.; April 2002. Recent Studies and Publications The Oak Ridge National Laboratory (ORNL) Weatherization and SEP Support Program have published dozens of reports over the past 17years, many of which are available online. Some hard copies of reports are also available from ORNL. Printable Version Webmaster Security & Privacy Weatherization & Interqovernmental Proqram Home EERE Home S. Department of Energy Content Last Updated: 08/13/2003 http://www.eere.energy.gov/weatherization/ne - benefits.html 03/021200~ uv.t.'., W Gamenzanon AssIstance program: Program EvaluatIOns Page 1 of s. Department of Energy - Energy Efficiency and Renewable EnergyWeatherization & Intergovernmental Program Weatherization Assistance Program Evaluations The U.S. Department of Energy (DOE) regularly conducts evaluations of the Weatherization Assistance Program in order to verify energy savings and maximize service to weatherization clients. These evaluations are conducted by DOE's Oak Ridge NationalLaboratory (ORNL The evaluations have been critical to establishing the efficacy of energy efficiency measures for establishing cost-benefit ratios for the program as a whole. In terms of energy savings, weatherization clients save $1.83 for every dollar of DOE investment. Foradditional benefits, see Non-Energv Benefits of Weatherization Webmaster Security & Priyacy Weatherization & Interqoyernmental Prouram Home EERI;J::IQIJ1~ S. Department of Energy Content Last Updated: 08/13/2003 http://www.eere.energy.gov/weatherizationiprog- eval.html ?print 02/12/2004 CAP AI RESPONSE TO IDAHO POWER COMPANY' INTERROGA TORIES AND REQUEST FOR PRODUCTION ATTACHMENT No. The Home Energy Affordability Gap: Putting Data to Work . - __ II'III II' Roger D. Colton Fisher, Sheehan & Colton National Fuel Funds Network June 2003 ;... Defining the "affordability gap : ;': ~: Actual home energy bills - Affordable home ~Jle Home Energy Affordability Gap '(J~/lll L'(J'(JQ 1': L.:J LI:Ri.:JLl QtH ';:j t"'Atit.'(J.:J ON THE BRINK The Home Energy Affordability Gap in IDAHO APRIL 2003 50% P 20"- ! 10% FindiDR #1 Home Energy Burdena for Houllholda at Varloua Federal Poverty levela , ~....~. " ~'- ~... "t ...... ~... , ,~~ L.-a Home energy is a crippling financial burden for low-income Idaho households. Idaho households with incomes of below 50% of the Federal Poverty Level pay 45% or more of their annual income simply for their home energy bills. Home energy Wtaffordability, however, is not simply the province of the very poor. Bills for households between 50% and 100% of Poverty take up 16% of income. Even Idaho households with incomes between 150% and 185% of the Federal Poverty Level have energy bills above the percentage of income generally considered to be affordable. fiwYDI #2 Number of Low-Income Idaho Households by Federal Poverty Level - - ~~ .. ....... ~ p DWIt)' I.8wI The number of households facing these energy burdens is staggering. More than 21 ,000 Idaho households live with income al or below 50% of the Federal Poverty Level and thus face a home enerS)' burden of 45% of income or maR. 000 additional Idaho households live with incomes between 50% and 74% of Poverty (home energy burden of 18%). 19,000 more Idaho hougeholds live with incomes between 75% and 99% of theFederal Povc1'ty Level (home energy burden of 13%). $35 $30 j 525 ~ $20 I $15 i $'0 !!! FlndtnK #3 A $98 Million Energy Affordabillty Gap (2001/2002 Heating Fuel Prices) ~ .ii'd., ~ .ii' \I?n. v, .. ~ J'. "Y.(J'. ... -:t ~ ~ pov.rty l.4Yt, Existing sources of energy assistance do not adequately adkkess ~e energy affordability gap in Idaho. AcIDal low-income energy bills exceeded affordable energy bills in Idaho by more than $96 million at 2001/2002 winter beating fuel prices. In contrast, Idaho received II gross allotment of federal energy assistance funds of $10.5 million for Fiscal Year 2003. Some of those funds will be used for administralive costs, weatherization, and other non-cash assistance. mding #4 A $113 MIllion Gap at 2002/2003 Winter Heating Price. $50 ....... ... "' -t ' ... Powrty lAY., Increases in the prices of natural gas, propane and fuel oil during the 2002/2003 winter heating season dOve the unaffordability gap up to more ~an $113 miJlion. While the gap for the lowest income households (0-50% Poverty) increases by nearly 94Yo (from $30 million to $32million). ~e gap for thehighest income households (150-185% of Poverty) increases by nearly 65% (from $7 million 10 $12 million). 03/11/200417:232083214819PAGE FiodlolE #S Low-Income Energy Bills In Idaho by End U.. (2001/2002 Winter Heating Prices) The energy atTordability gap in Idaho is not created exc1W1ively. or even primarily, by home heating and cooling bills. 811*,,'"8MGtWewOH"'ln,IIJCeoIIng At 200112002 winter heating prices, while home heating bills were $576 of a $1607 bill (35,9%), electric bitts (other than cooling) were $491 (30.5%). Annual cooling bills represented 553 expenditures (3.3% of the total bill), while domestic hot water represented $487 in expendibnes (30.3%). ... Fiodin! #6 The W18ffordabitity of home energy bills frequently causes low-income: households to take drastic actions that are detrimental to their health, safety and welfare, A swvey of energy assistance recipients by the Iowa Depanment of Human Rights found that: Over 12 percent of the surveyed energy assistance recipients went without food to pay their borne heating bilt. More than one-in-6ve went without medical care to pay for heating bills, including not seeking medical assismnce when it was needed, not filling prescriptions for medicine when a doctor has prescribed it, and/or not taking prescription medicines in the dosage ordered by the doctor. )0 Almost 30 percent reponed that they did not pay other bill!!, but did not elaborate as to which bills were not paid. In addition to not paying other bills, many low-income howeholds incw:red debt in order to pay both their home heating bills and other basic necessities: bonowed from fiiends and'or neighbors; wed credit cards to pay for food and other necessities, or did not pay the heating bill. A publicalio" of FISHER, SHEEHAN CatrON PUflUC FINANCE ANJJ GENERAL ECONOMICS Belmo"'. MOSIDchusettl Aprii 2003 (S ) ... . . ... . . (S ) (S ) .. . ID A H O En e r g y G a p R a n k i n g s (s c a l e o f 1- 5 1 ) ... . . -. I AV D A G I I n o W o U n n I c s AC ' r U A . L I I C 8 B DI D G 1 ' a I L L S DC B K D B D A P P O B D U I L B B D I I B I I I I 1 D I G r 8I L L S re a . o v 8 BI I O I . I ) S BB 1 D W " 1 8 5 ' 0 P P o v J u r r y L I I V B L . (S ) ... . . .. . ... . . A' I X I t & f a " I O T A ! . .. . ID I I D I O Y B U B D B I f l O a 8O 1 J S S I I O L D B U L O I r 50 \ DI ' P o v u n L n 8 L . $6 7 2 p e r h o u s . h o l d 45 . 3\ o f h o u s e h o l d i n c Q 8 8 RA N K : 1 3 3 RA H l t : # 3 6 PU C ' D T o r I1 I D J V I O O A L S BI I l . O W 10 0 \ o r P o v u n r. q r . . CO I I B I D D b A T D l G / C o o L D I G A l ' r o R D A B l t . J n GA P C O V B U D 8 ' I ' D U A L lI O I I 8 D K J K : r A 8 8 1 8 t A J I C B . 11 . B \ o f al l i n d i v i d u a l s 23 . 0\ o f g a p i . c o v e r e d RA N K : ' 2 9 RA N K : t : Z 7 G'I IT 1 (S ) 0" ' DIPIMITZON8 8xP~TIQM8 Each state (along \\'ith the District af Colwnbia) has been ranked (from 1 to 51) in \enns of four separate meallures of the extent of the energy affordability gap facing its low-income customers: (l) The percent of individuals with annual incomes at or below t 00% of the Federal Poverty Level. This data is obtained directly ftolU the 2000 U.S. Census. (2) The average total home energy bt'rden for households with income at or below 50% of theFederal Poverty Level shows the percentage of income which households with these incomesspend on home energy, "Total home energy" includes all energy usage, not merely heating andcooling. A home energy bill is calculated on a county-by-county basis. The statewide average is a population-weighted average of county-by-COUDty data. (3) The average affordability gap (in dollars per household) for all households with income at orbelow 185% of Poverty is the dollar difference between actual total home energy bi11s and billsthat are set equal to an affordable percentage of income. Affordability for total home energy bills is set at 6% of household income. (4) The extent to which federal energy assistance Covers the combined heating/cooling affordabilitygap for each state, The combined heating/cooling affordability gap is the difference between actual heating/cooling biUs and bills that are set equal to an affordable percentage of income.Affordability for combined heating/cooling bills is set at 2% of income, This measure thusexamines the proportion of the heating/cooling gap that is covered by the gross federal Low- Income Home Energy Assistance Program (LIHEAP) allocation to the state assuming that the entire LIHEAP allocation is used for cash benefits, In the state s rankings, a higher ranking indicates better conditions while a lower ranking indicates worse conditions relative to other states. Thus, for example: (I) The state with the rank of # 1 has the lowest percentage of individuals living in households with income at or below 100% of the Federal Poverty Level while the state with the rank. of #51 hasthe highest percentage. (2) The state with the rank of #1 has the lowest average home energy burden for households withincome below 50% of the Federal Poverty Level while the state with the rank of #51 has the highest average borne energy burden. (3) The state with the rank of #1 has tbe lowest average affordability gap (dollars per household)while the state with the f'BI1k of#SI has the highest dollar gap. (4) The state with the rank of,,1 has the highest percentage of its heating/cooling affordability gapcovered by federal energy assistance while the state with the rank of #5 I bas the lowest percentage ofits heating/cooling gap covered. All references to "states" include the District of Columbia as a "state." Low.income home energy billsare calculated using average residential revenues per unit of energy, State financial resources and utility- specific discounts are not considered.