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HomeMy WebLinkAboutgraves.pdf 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 1 Q. Please state your name and business address for the record. A. My name is Dan Graves. My business address is 472 West Washington Street, Boise, Idaho. Q. By whom are you employed and in what capacity? A. I am employed by the Idaho Public Utilities Commission as a Utilities Compliance Investigator. Q. What is your educational and professional background? A. I received a Bachelor of Science Degree in Management from Tarkio College in 1987 and a Master of Public Administration from the University of Missouri in 1990. I attended the NARUC Management Analyst training, September 1987, the NARUC Basic Training for Management Analysts, June 1988, and the NARUC Regulatory Studies Program, August 1991. The Missouri Public Service Commission from 1987 to 1992 employed me as a Management Services Specialist for four years and Assistant to the Chairman for one year. I have been in my current position of Utilities Compliance Investigator since December 2000. Q. What is the purpose of your testimony in this proceeding? A. The purpose of my testimony is to discuss my findings from a review of Idaho Power Company’s (Company) IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 2 public notices and address the Company’s compliance with the Idaho Public Commission’s (Commission) Utility Customer Relations Rules (UCRR), IDAPA 31.21.0100, et seq., and Utility customer Information Rules (UCIR), IDAPA 31.21.0200, et seq. I will summarize the written comments filed with the Commission by customers following Idaho Power Company’s Applications requesting authority to issue energy cost recovery bonds, recover related energy cost bond charges and change the Power Cost Adjustment (PCA) Rate for electric service from May 16, 2002 to May 15, 2003. I will discuss briefly some of the comments made by customers who attended the public workshops and hearings. I will also summarize and discuss the informal complaints filed with the Commission’s Consumer Staff against Idaho Power Company following the establishment of the tiered rate structure in the 2001 PCA. I will describe briefly a number of Demand Side Management (DSM) programs initiated by the Company to encourage and promote energy conservation among its customers. I will detail Idaho Power’s efforts to mitigate the impact of rate increases on its low- income customers. Q. Has the Company complied with Utility Customer Information Rules (UCIR) with regard to customer notice of the applications for authority to issue energy cost IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 3 recovery bonds and recover the Company’s 2002 PCA expenses? A. Yes, with some modifications approved by the Commission. On March 29, 2002, the Company filed a request for wavier of the bill stuffer requirement for a Power Cost Adjustment (PCA). The Company, on March 11, 2002, sent a special mailing to all its Idaho retail customers notifying them of the application for authorization to issue energy cost recovery bonds and the impending application for the 2002 PCA. The Company described the amount of the PCA application with and without the issuance of energy cost recovery bonds. The Company expressed concern that an additional bill stuffer would lead to confusion rather than provide notification, citing the fact that customers had already been notified of the pending PCA application. The Company pointed out that most customers would not receive a bill stuffer if it were issued on a normal cyclical billing basis until after scheduled hearings were held. In Order No. 28995 issued on April 5, 2002, the Commission determined that bill stuffers mailed during the normal Idaho Power billing cycle would not allow sufficient time for the Company’s customers to file comments. The option of doing a special direct mailing to customers was considered, but rejected because IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 4 customer might confuse it with the Company’s earlier mailing regarding its request for an energy cost financing order. As a result, the Commission in Order No. 28995 granted the Company’s request to waive the bill stuffer requirements and directed the Company to use paid advertisements to notify the Company’s customers of the scheduled hearings and written comment deadlines. Q. What opinions did Idaho Power customers express in the written comments submitted to the Commission in Case No. IPC-E-02-03. A. As of April 22, 2002, the Commission received 200 written comments from customers. Slightly more than half (52%) were opposed to the tiered rate structure. Many of these customers indicated they lived in all- electric homes and felt they were now being penalized for it. They talked about the influence Idaho Power exerted during the seventies to build “Gold Medallion” all- electric homes. These customers are now experiencing high electric bills and claim it is impossible to keep usage under 2000 kWh, which in many cases puts the majority of their usage in the third tier (8.4 cents per kWh). Many also commented that they do not have access to an alternative heat source like natural gas and are consequently being singled out to bear the brunt of Idaho Power’s energy costs. Others commented that the three- IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 5 tiered rate structure is discriminatory. One customer commented, “I don’t mind paying a fair share for electricity-have been for nearly 70 years, but this 3 tiered rate fiasco is the ultimate ‘rip-off.’” Another comment read, “Those of us with electricity as our only source of heat are subsidizing electricity users that have other heating sources. This is unfair!” Finally, one customer commented, “Reduce my rates and go back to one flat rate.” The few customers in favor of tiered rates were generally customers who favored the PUC directing Idaho Power to institute additional conservation measures and believed that the three-tiered rate structure sent a strong conservation message to high-end users. Q. Did you get the impression from customer comments that the three-tiered rate structure has had a positive impact on conservation? A. Many customers, especially those living in all- electric homes, expressed strong feelings about the perceived punitive nature of the tiered rate structure, which compelled them to conserve. However, these customers indicated that tiered rates did not send any conservation message to those customers who have alternative heat sources. Again, customers expressed a strong sense that the burden to conserve was shifted from IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 6 all Idaho Power customers to only those with all-electric homes. Q. Do you think these customers in all-electric homes are aware of the increases experienced by customers who heat with natural gas over the past twelve months? A. None of the customers who indicated they lived in all-electric homes acknowledged that natural gas customers had experienced approximately a 50% increase in rates. It is possible that a lack of awareness that both gas and electric customers experienced sizable increases in energy costs made electric space heating customers feel singled out. Q. You also reviewed customers’ written comments filed in this case regarding Idaho Power’s request to issue revenue bonds to recover the Company’s power supply costs. What were some of the concerns expressed by customers? A. The Commission received 26 comments addressing the issue of energy bonds. Ten customers commented favorably toward the PUC allowing Idaho Power to issue revenue bonds. Sixteen customers emphatically opposed the issuing of bonds, commenting that they would rather see the debt paid off in a year rather than spreading it over three years. Although the Commission approved adoption of the load reduction costs for inclusion in the IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 7 PCA, some customers believed these costs were solely the result of poor decisions made by Idaho Power. For example, one customer commented, “Now Idaho Power threatens us with even higher bills unless we agree to let them sell bonds to pay off their bad decisions.” Another customer stated, “The bond proposal appears to be an effort by Idaho Power to cover up its poor management decisions under the guise of an artificial rate reduction.” Q. The Commission held workshops and public hearings to gather public input on Idaho Power Company’s request to issue revenue bonds, the annual Power Cost Adjustment (PCA), the tiered rate structure, and funding of a comprehensive DSM program. What was the response from the customers who testified on these issues? A. Workshops and public hearings were held in Twin Falls, Idaho, on April 10, 2002, and in Pocatello, Idaho, on April 15, 2002. A total of forty-nine people attended the workshops and forty-six people attended the hearings that followed the workshop. Seventeen people testified before the Commission. Ten spoke out against tiered rates, but others admitted that they thought the three- tiered rate structure sent a strong signal to customers with high consumption to conserve. A majority of customers testifying opposed authorization of energy IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 8 bonds to pay off the power supply costs. Several testified that while they preferred to pay it off in one year, they thought spreading costs over multiple years was necessary to alleviate the hardship to others. Finally, there was almost an even split both for and against the Commission allowing Idaho Power to fund its DSM program through a small surcharge added to rates. A final public workshop and hearing is scheduled from April 25, 2002, in Boise. Q. Has the Commission’s Consumer Staff received many complaints from customers following last year’s PCA rate increase? A. Yes. From May 2001 through April 19, 2002, the Consumer Assistance Staff has taken approximately 332 informal complaints regarding increased rates, the tiered rate structure, and high bills and consumption. Generally, many customers strongly opposed the three- tiered rate structure and many saw their Budget Pay amount increase significantly with relatively little increase in consumption. As of April 22, 2002, Staff logged 119 complaints from customers who received unexpectedly high bills resulting from a combination of increased rates and higher consumption during the past heating season. Many of these customers had not experienced the rate shock from the rate increase until IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 9 the weather turned cold enough to push their consumption over the 2000 kWh level. In still other cases, a number of customer complaints were a result of Idaho Power meter readers that misread meters or estimated usage. Q. Were there an unusual number of billings based on estimated meter readings? A. The number of estimated bills for the year 2001 was 31,137, a significant increase over the prior year when 17,000 were issued. The Company cautioned against comparing the number of calendar year 2000 estimated bills against the number of estimated bills issued in calendar year 2001. Their reasoning was that under the old Customer Information System (CIS) that was in place until November 2001, seasonal and irrigation customers were not read during the off-season. Instead, these customers were billed at some pre-determined amount as actual reads. The new CIS system now labels all those accounts as “estimated.” The Company indicated that there is no way to determine the total number of seasonal and irrigation accounts that were coded as actual reads under the old CIS system and coded as estimated under the new system. Thus, it is impossible to make an accurate year-to-year comparison. As of April 5, 2002, the Commission Staff received approximately 156 complaints from customers opposing the IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 10 higher rates and the three-tiered rate structure. Many of these customers were elderly and on fixed incomes. Some expressed deep concern that they were required to make choices between paying power bills or buying food and medicine. Some feared losing their homes due to an inability to pay energy costs. Q. One indication that customers are having difficulty paying their electric bills may be the number of disconnection complaints received by Consumer Assistance Staff. Was there an increase in the number of disconnection complaints this year over last year? A. For calendar year 2000, the Consumer Assistance Staff registered 250 complaints involving disconnections. For calendar year 2001, a total of 368 complaints were registered. This represents a 47% increase. The Consumer Staff has registered 93 customer disconnection complaints from January 1, 2002 to April 19, 2002, compared to 91 for the same period last year. Q. To what do you attribute this increase? A. Higher energy costs in general certainly contributed to the increase in disconnection complaints. However, during the 2000/2001 heating season 3,535 customers declared eligibility for protection from disconnection under the Utility Customer Relations Rules codified in IDAPA 31.21.01.306. During the 2001/2002 IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 11 heating season, 7,872 customers declared eligibility. Customers are eligible for protection from disconnection if their household includes children, elderly or infirm persons. Although these customers are required to pay their bills, frequently they either pay nothing or make partial payments that result in a large balance owing on March 1st - the date when utilities can disconnect service. Higher rates no doubt increased the number of customers who were unable to pay their bills in full, which resulted in a significant increase in the number of past due accounts. In anticipation of the increased need for collection activities, the Company hired six additional field collection staff to meet the anticipated workload. With increased collection activities by the Company, the Commission Consumer Staff witnessed an increase in the number of customers calling and seeking help to prevent disconnection of service. Q. How are Idaho Power’s low-income and elderly customers on fixed incomes able to cope with the high energy bills? A. In calendar year 2001, 10,360 of Idaho Power’s customers received a total of $2,185,905 in financial assistance through programs such as Low Income Home Energy Assistance Program (LIHEAP) and Project Share IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 12 funds. This represents a significant increase over calendar year 2000, in which 7,985 customers received a total of $1,490,785 in LIHEAP and Project Share funds. LIHEAP is the primary source of financial assistance to customers who are unable to pay their energy bills and requires that customers qualify under federal income guidelines. Assistance amounts to a one- time payment made directly to Idaho Power. Since the LIHEAP grant is simply not enough to keep utility service from being disconnected, customers often must seek additional funds elsewhere. Additional funds are often available through the Project Share program. It is funded by donations and is available on a case-by-case basis in emergency situations. Idaho Power supports this fund through donations. The Company and its shareholders contributed $139,299 in 2001, a significant increase over the prior years contribution of $40,972. Idaho Power customers contributed $159,730 in year 2000 and slightly less, $142,998, in year 2001 by adding an extra amount to their monthly bills. Applicants need only to contact organizations like the Salvation Army, American Red Cross, or a local Community Action Agency to apply for assistance. Q. What other resources are available to IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 13 customers? A. County welfare benefits are often available, but recipients may be asked to pay back a portion or all of the assistance they receive. Local churches are another source for funds and will often help when contacted directly by the customer. Q. Does Idaho Power offer a levelized payment program to its customers? A Yes, the Company offers Budget Pay to customers who want to mitigate the impact of seasonal highs and lows in energy bills. The plan allows customers to pay their projected annual usage in twelve (12) monthly installments. The payment amount is normally reviewed and recalculated, when necessary, on the anniversary of the date the customer began the plan. Although some customers stopped participating in the Budget Pay program due to the increased monthly payments that resulted from higher rates, others apparently found the plan helpful. As of April 2002, the Company had 43,218 customers participating in Budget Pay, a net increase of 2,655 customers over the same time last year when 40,563 customers were using Budget Pay. Q. What is Idaho Power’s policy regarding payment arrangements for customers that have difficulty paying their energy bill? IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 14 A. Customers need to call the Company when they know they will have difficulty paying their bill. Idaho Power is required to make reasonable payment arrangements. If the customer fails to make the agreed- upon payment, the Company may make a second agreement but is not obligated to do so. Idaho Power also offers several payment options, e.g., Preferred Pay, Check by Phone and electronic or online payment. The key is that customers must communicate with the Company when they experience problems paying their electric bills before they are disconnected. Q. Energy Conservation can assist low-income customers to reduce their energy consumption and thus reduce their electricity bills. What is Idaho Power doing to assist these customers? A. Idaho Power participates in the Low-Income Weatherization Assistance program through grants that supplement federal funding to support weatherization projects. This program is designed for low-income customers whose homes are not energy efficient and cannot afford to upgrade windows, doors, or insulation. Qualified households are recruited by local non-profit agencies using federal low-income eligibility guidelines. Idaho Power pays 50% of the cost of qualifying conservation measures plus a $75 administration fee per IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 15 home. In year 2000, 213 weatherization jobs were completed in Idaho and cost the Company $211,273. In year 2001, The Company completed 266 weatherization jobs at a cost of $331,125. Q. What other financial contributions has Idaho Power made in the interest of energy conservation? A. In 2001, Idaho Power contributed $1,246,818 to the Northwest Energy Efficiency Alliance. The Company also spent $567,253 on a Conservation Advertising Campaign, which included newspaper ads, radio and TV ads, outdoor billboards and a number of printed publications that were mailed directly to customers. In addition, Idaho Power created a compact florescent light (CFL) packet. The packet contains one CFL bulb, an Energy Cost Calculator, a tip sheet for home energy conservation and literature on conservation. The initial mailing of these packets was targeted to low-income customers and 7,608 were mailed in December 2001. In January 2002, Idaho Power offered in a bill stuffer to provide a CFL packet for those customers using 2000 kWh or more in a month. The Company distributed 1,900 CFL packets in response to the bill stuffer invitation. Idaho Power continues to distribute the remaining 2,500 CFL packets. The cost of the CFL packet program, $90,416 to date, was not included as part of the cost of the Ad IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 16 campaign or weatherization program. Instead, it was funded separately through the Bonneville Power Administration’s (BPA) Conservation and Renewables Discount (C&RD) Program. The C&RD credit of $525,000 per year is available to Idaho Power through 2004. The Company plans on using these funds for residential conservation programs, which includes a weatherization program. Idaho Power is now offering a new packet of conservation information to the Company’s Spanish- speaking customers. The packet, also offered in English, contains the “Home Energy Audit and Checklist,” a rates “question and answer” information sheet, a Energy Cost Calculator for appliances and equipment, and an “Energy Planner” brochure with 55 conservation tips. Customers must contact Idaho Power via mail, email or by calling to obtain the new packet. Q. What else is Idaho Power doing to assist low- income consumers in reducing energy consumption? A. Idaho Power developed an “Energy Planner” or home energy audit package that is sent out to customers who have called regarding their high consumption. The Energy Planner contains information and suggestions to assist customers in lowering their home energy usage. When a customer calls the Company, the Customer Service IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 17 Representative (CSR) attempts to determine consumption patterns and offers to send an Energy Packet. The Energy Planner packet contains a printed history of the customer’s usage, an Energy Cost Calculator and the business card of the Delivery Service Representative (DSR) assigned to the customer. If the CSR and Energy Packet do not satisfactorily answer the customer’s questions, the customer can contact the DSR directly. Once the DSR is assigned to further address the customer’s concerns, he/she will then decide if a site visit and home energy audit are appropriate. The DSR then schedules an appointment with the customer in order to conduct the audit. Q. How many audits has the Company performed? A. For calendar year 2001, Idaho Power conducted 1,118 energy audits, slightly more than the 1,110 audits done in 2000. During the first three months of year 2002, the Company has performed 258 energy audits. When asked why the number of energy audits performed had not increased correspondingly with the significant increase in customer contacts regarding high consumption, the Company attributed it to the energy conservation packets that were distributed to low-income customers and customers who called about high bills. The Company surmised that in an effort to conserve, more customers IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 18 are conducting their own audit using the home energy audit checklist contained in the energy packet. Q. The Commission’s Consumer Staff received a number of complaints from customers upset when their billing cycle exceeded 30 days, which in some cases caused a portion of their usage to be charged at the highest tiered rate. How has Idaho Power responded to these complaints? A. Since May 2001, the Commission’s Consumer Staff has investigated 24 complaints concerning billing cycles in excess of 30 days. Customers complained that the number of times they were billed for more days than the normal 30-day billing cycle had increased. In some cases, customers stated they were billed for to as many as 34 days. Any customer with usage averaging around 2000 kWh in a 30-day period will likely have a portion of his usage charged at the highest tiered rate for the 1-4 days beyond the 30 days. Some customers see this as an opportunity for Idaho Power to increase revenue by adjusting billing cycles. One customer in his complaint suggested Idaho Power read meters on weekends and holidays to insure the 30-day billing cycle is followed. Idaho Power responded in writing to a recent customer complaint with the following statement: “Although customers may feel that we have tried to IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 19 increase the number of days in each billing cycle in order to collect more revenue, any increase during 2001 was due solely to the need of the Company to manage the implementation of the new billing system while keeping in mind the other criteria considered when setting the schedules (e.g., avoiding holiday and weekend reads when possible, trying to keep the billing within the 3-4 days of the meter reading). Idaho Power’s Tariff Rule D.6 (Sheet No. D-3) provides for meters to be read normally at intervals of approximately 30 days. However, the interval between meter reads can be as great as 45 days.” If the Commission decides to keep the tiered rate structure, I recommend that it encourage the Company to limit the instances of billing periods exceeding 30 days. I also recommend that the Company’s tariff be amended to reflect a more reasonable range of number of days to be included in a billing period. Q. In your opinion, have tiered rates generally succeeded in making customers more aware of their energy usage? A. A number of customers submitting comments and filing complaints with the Commission admitted to having taken measures to conserve and cut back on energy usage. Most talked about replacing or adding insulation, closing cracks under doors and around windows, replacing IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 20 inefficient windows and doors, and turning thermostats down. Q. In your opinion, do you think there were other issues that customers opposed to tiered rates perhaps did not consider when they filed their comments and complaints with the Commission? A. Oftentimes, when Consumer Staff investigated a complaint, they found billing errors were the cause for the customer’s complaint and not tiered rates per se. Billing errors included misreads and estimated reads, which coupled with the tiered rate, would result in the customer receiving an unnecessarily high bill. In many cases the animosity towards tiered rates is misdirected. In the Mini-Cassia area Idaho Power investigated a problem that was created by an inappropriate and unauthorized estimation of electricity usage. The Company analyzed the records of more than 3,000 customers in the Mini-Cassia area to determine the extent of the problem. The Company found that 225 customers were affected by the problem and made billing adjustments totaling $1,568. The average adjustment per account was $6.96, but for some individuals, the adjustment was much greater. Each affected customer was mailed a letter explaining the situation and indicating the amount of the adjustment to expect on his or her next IPC-E-02-3 STAFF 4/22/02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NOS. IPC-E-02-2 GRAVES, D (Di) 21 IPC-E-02-3 STAFF 4/22/02 bill. In addition, all Oakley customers were mailed a postcard offering an apology and an opportunity for customers to discuss the bill in person with Company personnel. Q. Based on your review of all the written comments in this case and the consumer complaints filed with the Commission’s Consumer Assistance Staff, do you believe the energy crisis and the subsequent rate increases have had any positive results? A. Yes. It has made customers more atuned to their actual energy consumption versus the dollar amount they pay for energy. The Northwest has historically benefited from having the lowest energy rates for energy in the country, so customers have not received the sort of price signals that encourage energy conservation. Customers now appear to be more aware of their daily energy consumption and how taking some basic conservation steps can positively impact their energy bills. Q. Does this conclude your direct testimony in this proceeding? A. Yes, it does.