20081112CAPAI to IPC 1-3.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th S1.
Boise,ID. 83702
[phone]
FAX: [phone]
bmpurdy(fhotmail.com
Attorney for Petitioner
Community Action Parnership
Association of Idaho
Rt:bl:IVED
2068 NOV' 2 PM 3: 25
U., 1DAHO PUBUC. i tLlTIES COMMíSSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
OF IDAHO POWER COMPANY FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE TO ELECTRIC
CUSTOMERS IN THE STATE OF IDAHO
)
) CASE NO. IPC-E-08-10
)
)
)
)
)
)
)
)
)
COMMUITY ACTION
PARTNRSHIP ASSOC-
TIATION OF IDAHO'S
RESPONSE TO IDAHO
POWER COMPANY'S FIRST
AND SECOND PRODUCTION
REQUESTS.
COMES NOW, Community Action Parnership Association ofIdaho and, in response to
Idaho Power Company's First and Second Production Requests, provides the following
information:
REQUEST NO.1 TO CAPAI WITNESS OTTENS: In response to the Company's proposal
to set the first tier of energy consumption at 600 kWh, Ms. Ottens states: "If the purose of the
tier was to promote conservation, it should be set at a higher level so as to be attainable." At
what level does Ms. Ottens propose the first tier be set?
RESPONSE TO REQUEST NO.1: In the testimony ofIdaho Power witness Ms. Courney
Waites, she states that the average monthly residential customer energy usage is 1065 kWh. If
CAPAI RESPONSE TO FIRST AND SECOND PRODUCTION REQUESTS OF IDAHO
POWER
this is the average consumption, there is very little chance for an average household to reduce its
energy usage, no matter what energy efficiency measures it might undertake, to come in at or
below the first tier block of 600 kWh. CAP AI believes that if this is meant to be an incentive, it
should be an achievable leveL. CAP AI fuher asserts that reducing average consumption by
40% to derive a first tier is not a reachable goal, however, cutting usage by 20% might be. Thus,
CAPAI, through witness Ottens, recommends that the first tier be set at 850 kWh.
REQUEST NO.2 TO CAP AI WITNESS OTTENS: On page 6, lines 20-21, Ms. Ottens
indicates that "(currently only 10% of the homes receiving a LIHEAP benefit are weatherized)."
Please provide the data underlying the analysis of electric-only LIHEAP versus weatherization
recipients, and an explanation of how this percentage was determined.
RESPONSE TO REQUEST NO.2: Shown below is the data for those households that
receive weatherization services under the Community Action Parnership programs versus those
that receive LIHEAP. In the testimony of Ms. Teri Ottens, she indicated that an average of 10%
of the homes that receive LIHEAP assistance receive weatherization services. In fact, in the past
three years, the percentage is even less due to the increasing demand for LIHEAP assistance and
the limitations on weatherization funding.
Program Year
LIHEAP recipients
Weatherization recipients
Program Year
LIHEAP recipients
Weatherization recipients
Program Year
LIHEAP recipients
Weatherization recipients
06
32,300
1,466 (4.5% ofLIHEAP paricipants).
07
33,160
1,388 (4.2%)
08
34,697
1,456 (4.2%)
CAP AI RESPONSE TO FIRST AND SECOND PRODUCTION REQUESTS OF IDAHO
POWER
REQUEST NO.3 TO CAPAI WITNESS OTTENS: On page 9, Ms. Ottens proposes that
Idaho Power compile a monthly arearage report to be provided to CAP AI and other interested
paries. Please explain how CAP AI would benefit from receiving a monthly arearage report and
what impact it would have on CAP AI's operations.
RESPONSE TO REQUEST NO.3: CAPAI seeks this monthly report for the following
reasons. The report, which allows CAP AI to track monthly trends, has been made available to
CAP AI by Pacifi Corp (dba Rocky Mountain Power), for the past year and has provided valuable
information in the following areas:
1. The information enables CAP AI to tie monthly arearage trends to need and budget
both appropriate funding levels and personnel when these are most needed.
2. CAP AI has found a need, and will continue to do so, to use this data in seeking
additional fuding resources to meet the trends.
3. These trends provide a good snapshot of the "bigger picture" affecting low-income
familes. CAP AI is able to correlate utility arearage trends to milestones such as increased
utilty rates, economic factors, and more. This assists CAP AI to better prepare to meet service
demands in the future.
DATED, this 12th day of November, 2008.
~LDIQ~./~æ~-= 4~Brad M. Purdy',~_
__....,_.~...__._':
CAPAI RESPONSE TO FIRST AND SECOND PRODUCTION REQUESTS OF IDAHO
POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of November, 2008, I caused to be served the
foregoing COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO'S
RESPONSE TO IDAHO POWER COMPANY'S FIRST AND SECOND PRODUCTION
REQUESTS via emaiL. Hard copy via U.S. Mail wil follow.
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilties Commission
472 W. Washington S1.
Boise,ID 83702
Neil Price
Deputy Attorney General
Idaho Public Utilties Commission
472 W. Washington S1.
Boise,ID 83702
BARTON L. KLINE, ISB #1526
LISA D. NORDSTROM, ISB #5733
DONOVAN E. WALKER, ISB #5921
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
bkline~idahopower.com
lnordstrom~idahopower.com
dwalker(fidahopower .com
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
rgale~idahopower.com
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson & O'Leary
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
CAP AI RESPONSE TO FIRST AND SECOND PRODUCTION REQUESTS OF IDAHO
POWER
peter~richardsonandolear .com
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
[phone] Tel
[phone] Fax
dreading~mindspring.com
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
E-mail: rcb~racinelaw.net
E-mail: elo~racinelaw.net
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
Fax: [phone]
E-mail: yanel~attbi.com
Michael L. Kurz, Esq.
Kur J. Boehm, Esq.
BOEHM, KUTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Telephone: [phone] Facsimile: 513-421-2764
E-mail: mkurz(fBKLlawfr.com
kboehm~BKLlawf.com
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lake City, Uta 84111
E-mail: khiggins~energystrat.com
Conley Ward
Michael C. Creamer
Givens Pursley, LLP
601 W. Banock Street
CAPAI RESPONSE TO FIRST AND SECOND PRODUCTION REQUESTS OF IDAHO
POWER
P.O. Box 2720
Boise, ID 83701-2720
Email: cew~givenspursley.com
208-388-1200
Dennis E. Pesseau, Ph.D.
Utilty Resources, Inc.
1500 Liberty Street SE, Suite 250
Salem, OR 97302
CAPAI RESPONSE TO FIRST AND SECOND PRODUCTION REQUESTS OF IDAHO
POWER