20020422Graves Direct.pdf

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATIONOF )IDAHO POWER COMPANY FOR AN ENERGY )CASE NO.IPC-E-02-2COSTFINANCINGORDERANDAUTHORITY)TO INSTITUTE AN ENERGY COST BOND )CHARGE.
)
IN THE MATTER OF THE APPLICATIONOF )IDAHO POWER COMPANY FOR AUTHORITY )CASE NO.IPC-E-02-3TOIMPLEMENTAPOWERCOST)ADJUSTMENT (PCA)RATE FOR ELECTRIC )SERVICE FROM MAY 16,2002 THROUGH )MAY 15,2003.)
DIRECT TESTIMONY OF DAN GRAVES
IDAHO PUBLIC UTILITIES COMMISSION
APRIL 22,2002
1 Q.Please state your name and business address for
2 the record.
3 A.My name is Dan Graves.My business address is
4 472 West Washington Street,Boise,Idaho.
5 Q.By whom are you employed and in what capacity?
6 A.I am employed by the Idaho Public Utilities
7 Commission as a Utilities Compliance Investigator.
8 Q.What is your educational and professional
9 background?
10 A.I received a Bachelor of Science Degree in
11 Management from Tarkio College in 1987 and a Master of
12 Public Administration from the University of Missouri in
13 1990.I attended the MARUC Management Analyst training,
14 September 1987,the NARUC Basic Training for Management
15 Analysts,June 1988,and the NARUC Regulatory Studies
16 Program,August 1991.The Missouri Public Service
17 Commission from 1987 to 1992 employed me as a Management
18 Services Specialist for four years and Assistant to the
19 Chairman for one year.I have been in my current
20 position of Utilities Compliance Investigator since
21 December 2000.
22 Q.What is the purpose of your testimony in this
23 proceeding?
24 A.The purpose of my testimony is to discuss my
25 findings from a review of Idaho Power Company's (Company)
CASE NOS.IPC-E-02-2 GRAVES,D (Di)1IPC-E-02-3 STAFF4/22/02
1 public notices and address the Company's compliance with
2 the Idaho Public Commission's (Commission)Utility
3 Customer Relations Rules (UCRR),IDAPA 31.21.0100,et
4 seq.,and Utility customer Information Rules (UCIR),
5 IDAPA 31.21.0200,et seq.I will summarize the written
6 comments filed with the Commission by customers following
7 Idaho Power Company's Applications requesting authority
8 to issue energy cost recovery bonds,recover related
9 energy cost bond charges and change the Power Cost
10 Adjustment (PCA)Rate for electric service from May 16,
11 2002 to May 15,2003.I will discuss briefly some of the
12 comments made by customers who attended the public
13 workshops and hearings.I will also summarize and
14 discuss the informal complaints filed with the
15 Commission's Consumer Staff against Idaho Power Company
16 following the establishment of the tiered rate structure
17 in the 2001 PCA.I will describe briefly a number of
18 Demand Side Management (DSM)programs initiated by the
19 Company to encourage and promote energy conservation
20 among its customers.I will detail Idaho Power's efforts
21 to mitigate the impact of rate increases on its low-
22 income customers.
23 Q.Has the Company complied with Utility Customer
24 Information Rules (UCIR)with regard to customer notice
25 of the applications for authority to issue energy cost
CASE NOS.IPC-E-02-2 GRAVES,D (Di)2IPC-E-02-3 STAFF4/22/02
1 recovery bonds and recover the Company's 2002 PCA
2 expenses?
3 A.Yes,with some modifications approved by the
4 Commission.On March 29,2002,the Company filed a
5 request for wavier of the bill stuffer requirement for a
6 Power Cost Adjustment (PCA).The Company,on March 11,
7 2002,sent a special mailing to all its Idaho retail
8 customers notifying them of the application for
9 authorization to issue energy cost recovery bonds and the
10 impending application for the 2002 PCA.The Company
11 described the amount of the PCA application with and
12 without the issuance of energy cost recovery bonds.The
13 Company expressed concern that an additional bill stuffer
14 would lead to confusion rather than provide notification,
15 citing the fact that customers had already been notified
16 of the pending PCA application.The Company pointed out
17 that most customers would not receive a bill stuffer if
18 it were issued on a normal cyclical billing basis until
19 after scheduled hearings were held.
20 In Order No.28995 issued on April 5,2002,the
21 Commission determined that bill stuffers mailed during
22 the normal Idaho Power billing cycle would not allow
23 sufficient time for the Company's customers to file
24 comments.The option of doing a special direct mailing
25 to customers was considered,but rejected because
CASE NOS.IPC-E-02-2 GRAVES,D (Di)3IPC-E-02-3 STAFF4/22/02
1 customer might confuse it with the Company's earlier
2 mailing regarding its request for an energy cost
3 financing order.As a result,the Commission in Order
4 No.28995 granted the Company's request to waive the bill
5 stuffer requirements and directed the Company to use paid
6 advertisements to notify the Company's customers of the
7 scheduled hearings and written comment deadlines.
8 Q.What opinions did Idaho Power customers express
9 in the written comments submitted to the Commission in
10 Case No.IPC-E-02-03.
11 A.As of April 22,2002,the Commission received
12 200 written comments from customers.Slightly more than
13 half (52%)were opposed to the tiered rate structure.
14 Many of these customers indicated they lived in all-
15 electric homes and felt they were now being penalized for
16 it.They talked about the influence Idaho Power exerted
17 during the seventies to build "Gold Medallion"all-
18 electric homes.These customers are now experiencing
19 high electric bills and claim it is impossible to keep
20 usage under 2000 kWh,which in many cases puts the
21 majority of their usage in the third tier (8.4 cents per
22 kWh).Many also commented that they do not have access
23 to an alternative heat source like natural gas and are
24 consequently being singled out to bear the brunt of Idaho
25 Power's energy costs.Others commented that the three-
CASE NOS.IPC-E-02-2 GRAVES,D (Di)4IPC-E-02-3 STAFF4/22/02
1 tiered rate structure is discriminatory.One customer
2 commented,"I don't mind paying a fair share for
3 electricity-have been for nearly 70 years,but this 3
4 tiered rate fiasco is the ultimate 'rip-off.'"Another
5 comment read,"Those of us with electricity as our only
6 source of heat are subsidizing electricity users that
7 have other heating sources.This is unfair!"Finally,
8 one customer commented,"Reduce my rates and go back to
9 one flat rate."The few customers in favor of tiered
10 rates were generally customers who favored the PUC
11 directing Idaho Power to institute additional
12 conservation measures and believed that the three-tiered
13 rate structure sent a strong conservation message to
14 high-end users.
15 Q.Did you get the impression from customer
16 comments that the three-tiered rate structure has had a
17 positive impact on conservation?
18 A.Many customers,especially those living in all-
19 electric homes,expressed strong feelings about the
20 perceived punitive nature of the tiered rate structure,
21 which compelled them to conserve.However,these
22 customers indicated that tiered rates did not send any
23 conservation message to those customers who have
24 alternative heat sources.Again,customers expressed a
25 strong sense that the burden to conserve was shifted from
CASE NOS.IPC-E-02-2 GRAVES,D (Di)5IPC-E-02-3 STAFF4/22/02
i all Idaho Power customers to only those with all-electric
2 homes.
3 Q.Do you think these customers in all-electric
4 homes are aware of the increases experienced by customers
5 who heat with natural gas over the past twelve months?
6 A.None of the customers who indicated they lived
7 in all-electric homes acknowledged that natural gas
8 customers had experienced approximately a 50%increase in
9 rates.It is possible that a lack of awareness that both
10 gas and electric customers experienced sizable increases
11 in energy costs made electric space heating customers
12 feel singled out.
13 Q.You also reviewed customers'written comments
14 filed in this case regarding Idaho Power's request to
15 issue revenue bonds to recover the Company's power supply
16 costs.What were some of the concerns expressed by
17 customers?
18 A.The Commission received 26 comments addressing
19 the issue of energy bonds.Ten customers commented
20 favorably toward the PUC allowing Idaho Power to issue
21 revenue bonds.Sixteen customers emphatically opposed
22 the issuing of bonds,commenting that they would rather
23 see the debt paid off in a year rather than spreading it
24 over three years.Although the Commission approved
25 adoption of the load reduction costs for inclusion in the
CASE NOS.IPC-E-02-2 GRAVES,D (Di)6IPC-E-02-3 STAFF4/22/02
1 PCA,some customers believed these costs were solely the
2 result of poor decisions made by Idaho Power.For
3 example,one customer commented,"Now Idaho Power
4 threatens us with even higher bills unless we agree to
5 let them sell bonds to pay off their bad decisions."
6 Another customer stated,"The bond proposal appears to be
7 an effort by Idaho Power to cover up its poor management
8 decisions under the guise of an artificial rate
9 reduction."
10 Q.The Commission held workshops and public
11 hearings to gather public input on Idaho Power Company's
12 request to issue revenue bonds,the annual Power Cost
13 Adjustment (PCA),the tiered rate structure,and funding
14 of a comprehensive DSM program.What was the response
15 from the customers who testified on these issues?
16 A.Workshops and public hearings were held in Twin
17 Falls,Idaho,on April 10,2002,and in Pocatello,Idaho,
18 on April 15,2002.A total of forty-nine people attended
19 the workshops and forty-six people attended the hearings
20 that followed the workshop.Seventeen people testified
21 before the Commission.Ten spoke out against tiered
22 rates,but others admitted that they thought the three-
23 tiered rate structure sent a strong signal to customers
24 with high consumption to conserve.A majority of
25 customers testifying opposed authorization of energy
CASE NOS.IPC-E-02-2 GRAVES,D (Di)7IPC-E-02-3 STAFF4/22/02
1 bonds to pay off the power supply costs.Several
2 testified that while they preferred to pay it off in one
3 year,they thought spreading costs over multiple years
4 was necessary to alleviate the hardship to others.
5 Finally,there was almost an even split both for and
6 against the Commission allowing Idaho Power to fund its
7 DSM program through a small surcharge added to rates.A
e final public workshop and hearing is scheduled from April
9 25,2002,in Boise.
10 Q.Has the Commission's Consumer Staff received
11 many complaints from customers following last year's PCA
12 rate increase?
13 A.Yes.From May 2001 through April 19,2002,the
14 Consumer Assistance Staff has taken approximately 332
15 informal complaints regarding increased rates,the tiered
16 rate structure,and high bills and consumption.
17 Generally,many customers strongly opposed the three-
18 tiered rate structure and many saw their Budget Pay
19 amount increase significantly with relatively little
20 increase in consumption.As of April 22,2002,Staff
21 logged 119 complaints from customers who received
22 unexpectedly high bills resulting from a combination of
23 increased rates and higher consumption during the past
24 heating season.Many of these customers had not
25 experienced the rate shock from the rate increase until
CASE NOS.IPC-E-02-2 GRAVES,D (Di)8IPC-E-02-3 STAFF4/22/02
1 the weather turned cold enough to push their consumption
2 over the 2000 kWh level.In still other cases,a number
3 of customer complaints were a result of Idaho Power meter
4 readers that misread meters or estimated usage.
5 Q.Were there an unusual number of billings based
6 on estimated meter readings?
7 I A.The number of estimated bills for the year 2001
8 ·was 31,137,a significant increase over the prior year
9 when 17,000 were issued.The Company cautioned against
10 comparing the number of calendar year 2000 estimated
11 bills against the number of estimated bills issued in
12 calendar year 2001.Their reasoning was that under the
13 old Customer Information System (CIS)that was in place
14 until November 2001,seasonal and irrigation customers
15 were not read during the off-season.Instead,these
16 customers were billed at some pre-determined amount as
17 actual reads.The new CIS system now labels all those
18 accounts as "estimated."The Company indicated that
19 there is no way to determine the total number of seasonal
20 and irrigation accounts that were coded as actual reads
21 under the old CIS system and coded as estimated under the
22 new system.Thus,it is impossible to make an accurate
23 year-to-year comparison.
24 As of April 5,2002,the Commission Staff received
25 approximately 156 complaints from customers opposing the
CASE NOS.IPC-E-02-2 GRAVES,D (Di)9IPC-E-02-3 STAFF4/22/02
l higher rates and the three-tiered rate structure.Many
2 of these customers were elderly and on fixed incomes.
3 Some expressed deep concern that they were required to
4 make choices between paying power bills or buying food
5 and medicine.Some feared losing their homes due to an
6 inability to pay energy costs.
7 Q.One indication that customers are having
8 difficulty paying their electric bills may be the number
9 of disconnection complaints received by Consumer
10 Assistance Staff.Was there an increase in the number of
11 disconnection complaints this year over last year?
12 A.For calendar year 2000,the Consumer Assistance
13 Staff registered 250 complaints involving disconnections.
14 For calendar year 2001,a total of 368 complaints were
15 registered.This represents a 47%increase.The
16 Consumer Staff has registered 93 customer disconnection
17 'complaints from January 1,2002 to April 19,2002,
18 compared to 91 for the same period last year.
19 Q.To what do you attribute this increase?
20 A.Higher energy costs in general certainly
21 contributed to the increase in disconnection complaints.
22 However,during the 2000/2001 heating season 3,535
23 customers declared eligibility for protection from
24 disconnection under the Utility Customer Relations Rules
25 codified in IDAPA 31.21.01.306.During the 2001/2002
CASE NOS.IPC-E-02-2 GRAVES,D (Di)10IPC-E-02-3 STAFF4/22/02
1 heating season,7,872 customers declared eligibility.
2 Customers are eligible for protection from disconnection
3 if their household includes children,elderly or infirm
4 persons.Although these customers are required to pay
5 their bills,frequently they either pay nothing or make
6 partial payments that result in a large balance owing on
7 March 1"-the date when utilities can disconnect
8 service.
9 Higher rates no doubt increased the number of
10 customers who were unable to pay their bills in full,
I11whichresultedinasignificantincreaseinthenumberof
12 past due accounts.In anticipation of the increased need
13 for collection activities,the Company hired six
14 additional field collection staff to meet the anticipated
15 workload.With increased collection activities by the
16 Company,the Commission Consumer Staff witnessed an
17 increase in the number of customers calling and seeking
18 help to prevent disconnection of service.
19 Q.How are Idaho Power's low-income and elderly
20 customers on fixed incomes able to cope with the high
21 energy bills?
22 A.In calendar year 2001,10,360 of Idaho Power's
23 customers received a total of $2,185,905 in financial
24 assistance through programs such as Low Income Home
25 Energy Assistance Program (LIHEAP)and Project Share
CASE NOS.IPC-E-02-2 GRAVES,D (Di)11IPC-E-02-3 STAFF4/22/02
l funds.This represents a significant increase over
2 calendar year 2000,in which 7,985 customers received a
3 total of $1,490,785 in LIHEAP and Project Share funds.
4 LIHEAP is the primary source of financial
5 i assistance to customers who are unable to pay their
6 energy bills and requires that customers qualify under
7 federal income guidelines.Assistance amounts to a one-
8 time payment made directly to Idaho Power.Since the
9 LIHEAP grant is simply not enough to keep utility service
10 from being disconnected,customers often must seek
11 additional funds elsewhere.
12 Additional funds are often available through
13 the Project Share program.It is funded by donations and
14 is available on a case-by-case basis in emergency
15 situations.Idaho Power supports this fund through
16 donations.The Company and its shareholders contributed
17 $139,299 in 2001,a significant increase over the prior
18 years contribution of $40,972.Idaho Power customers
19 contributed $159,730 in year 2000 and slightly less,
20 $142,998,in year 2001 by adding an extra amount to their
21 monthly bills.Applicants need only to contact
22 organizations like the Salvation Army,American Red
23 Cross,or a local Community Action Agency to apply for
24 assistance.
25 Q.What other resources are available to
CASE NOS.IPC-E-02-2 GRAVES,D (Di)12IPC-E-02-3 STAFF4/22/02
1 customers?
2 A.County welfare benefits are often available,
3 but recipients may be asked to pay back a portion or all
4 of the assistance they receive.Local churches are
5 another source for funds and will often help when
6 contacted directly by the customer.
7 Q.Does Idaho Power offer a levelized payment
8 program to its customers?
9 A Yes,the Company offers Budget Pay to customers
10 who want to mitigate the impact of seasonal highs and
11 lows in energy bills.The plan allows customers to pay
12 their projected annual usage in twelve (12)monthly
13 installments.The payment amount is normally reviewed
14 and recalculated,when necessary,on the anniversary of i
15 the date the customer began the plan.Although some
16 customers stopped participating in the Budget Pay program
17 due to the increased monthly payments that resulted from
18 higher rates,others apparently found the plan helpful.
19 As of April 2002,the Company had 43,218 customers
20 participating in Budget Pay,a net increase of 2,655
21 customers over the same time last year when 40,563
22 customers were using Budget Pay.
23 Q.What is Idaho Power's policy regarding payment
24 arrangements for customers that have difficulty paying
25 their energy bill?
CASE NOS.IPC-E-02-2 GRAVES,D (Di)13IPC-E-02-3 STAFF4/22/02
1 A.Customers need to call the Company when they
2 know they will have difficulty paying their bill.Idaho
3 Power is required to make reasonable payment
4 arrangements.If the customer fails to make the agreed-
5 upon payment,the Company may make a second agreement but
6 is not obligated to do so.Idaho Power also offers
7 several payment options,e.g.,Preferred Pay,Check by
8 Phone and electronic or online payment.The key is that
9 customers must communicate with the Company when they
10 experience problems paying their electric bills before
11 they are disconnected.
12 Q.Energy Conservation can assist low-income
13 customers to reduce their energy consumption and thus
14 reduce their electricity bills.What is Idaho Power
15 doing to assist these customers?
16 A.Idaho Power participates in the Low-Income
17 Weatherization Assistance program through grants that
18 supplement federal funding to support weatherization
19 projects.This program is designed for low-income
20 customers whose homes are not energy efficient and cannot
21 afford to upgrade windows,doors,or insulation.
22 Qualified households are recruited by local non-profit
23 agencies using federal low-income eligibility guidelines.
24 Idaho Power pays 50%of the cost of qualifying
25 conservation measures plus a $75 administration fee per
CASE NOS.IPC-E-02-2 GRAVES,D (Di)14IPC-E-02-3 STAFF4/22/02
1 home.In year 2000,213 weatherization jobs were
2 completed in Idaho and cost the Company $211,273.In
3 year 2001,The Company completed 266 weatherization jobs
4 at a cost of $331,125.
5 Q.What other financial contributions has Idaho
6 Power made in the interest of energy conservation?
7 A.In 2001,Idaho Power contributed $1,246,818 to
8 the Northwest Energy Efficiency Alliance.The Company
9 also spent $567,253 on a Conservation Advertising
10 Campaign,which included newspaper ads,radio and TV ads,
11 outdoor billboards and a number of printed publications
12 that were mailed directly to customers.In addition,
13 Idaho Power created a compact florescent light (CFL)
14 packet.The packet contains one CFL bulb,an Energy Cost
15 Calculator,a tip sheet for home energy conservation and
16 literature on conservation.The initial mailing of these
17 packets was targeted to low-income customers and 7,608
18 were mailed in December 2001.In January 2002,Idaho
19 Power offered in a bill stuffer to provide a CFL packet
20 for those customers using 2000 kWh or more in a month.
21 The Company distributed 1,900 CFL packets in response to
22 the bill stuffer invitation.Idaho Power continues to
23 distribute the remaining 2,500 CFL packets.
24 The cost of the CFL packet program,$90,416 to
25 date,was not included as part of the cost of the Ad
CASE NOS.IPC-E-02-2 GRAVES,D (Di)15IPC-E-02-3 STAFF4/22/02
1 campaign or weatherization program.Instead,it was
2 funded separately through the Bonneville Power
3 Administration's (BPA)Conservation and Renewables
4 Discount (C&RD)Program.The C&RD credit of $525,000 per
5 year is available to Idaho Power through 2004.The
I6Companyplansonusingthesefundsforresidential
7 conservation programs,which includes a weatherization
8 program.
9 Idaho Power is now offering a new packet of
10 conservation information to the Company's Spanish-
11 speaking customers.The packet,also offered in English,
12 contains the "Home Energy Audit and Checklist,"a rates .
13 "question and answer"information sheet,a Energy Cost
14 Calculator for appliances and equipment,and an "Energy
15 Planner"brochure with 55 conservation tips.Customers
16 must contact Idaho Power via mail,email or by calling to
17 obtain the new packet.
18 Q.What else is Idaho Power doing to assist low-
19 income consumers in reducing energy consumption?
20 A.Idaho Power developed an "Energy Planner"or
21 home energy audit package that is sent out to customers
22 who have called regarding their high consumption.The
23 Energy Planner contains information and suggestions to
24 assist customers in lowering their home energy usage.
25 When a customer calls the Company,the Customer Service
CASE NOS.IPC-E-02-2 GRAVES,D (Di)16IPC-E-02-3 STAFF4/22/02
1 Representative (CSR)attempts to determine consumption
2 patterns and offers to send an Energy Packet.The Energy
3 Planner packet contains a printed history of the
4 customer's usage,an Energy Cost Calculator and the
5 business card of the Delivery Service Representative
6 (DSR)assigned to the customer.If the CSR and Energy
7 Packet do not satisfactorily answer the customer's
8 questions,the customer can contact the DSR directly.
9 Once the DSR is assigned to further address the
10 customer's concerns,he/she will then decide if a site
11 visit and home energy audit are appropriate.The DSR
12 then schedules an appointment with the customer in order
13 to conduct the audit.
14 Q.How many audits has the Company performed?
15 A.For calendar year 2001,Idaho Power conducted
16 1,118 energy audits,slightly more than the 1,110 audits
17 done in 2000.During the first three months of year
18 2002,the Company has performed 258 energy audits.When
19 asked why the number of energy audits performed had not
20 increased correspondingly with the significant increase
21 in customer contacts regarding high consumption,the
22 Company attributed it to the energy conservation packets
23 that were distributed to low-income customers and
24 customers who called about high bills.The Company
25 surmised that in an effort to conserve,more customers
CASE NOS.IPC-E-02-2 GRAVES,D (Di)17IPC-E-02-3 STAFF4/22/02
1 are conducting their own audit using the home energy
2 audit checklist contained in the energy packet.
3 Q.The Commission's Consumer Staff received a
4 number of complaints from customers upset when their
5 billing cycle exceeded 30 days,which in some cases
6 caused a portion of their usage to be charged at the
7 highest tiered rate.How has Idaho Power responded to
8 these complaints?
9 A.Since May 2001,the Commission's Consumer Staff
10 has investigated 24 complaints concerning billing cycles
11 in excess of 30 days.Customers complained that the
12 number of times they were billed for more days than the
13 normal 30-day billing cycle had increased.In some
14 cases,customers stated they were billed for to as many
15 as 34 days.Any customer with usage averaging around
16 2000 kWh in a 30-day period will likely have a portion of
17 his usage charged at the highest tiered rate for the 1-4
18 days beyond the 30 days.Some customers see this as an
19 opportunity for Idaho Power to increase revenue by
20 adjusting billing cycles.One customer in his complaint
21 suggested Idaho Power read meters on weekends and
22 holidays to insure the 30-day billing cycle is followed.
23 Idaho Power responded in writing to a recent
24 customer complaint with the following statement:
25 "Although customers may feel that we have tried to
CASE NOS.IPC-E-02-2 GRAVES,D (Di)18IPC-E-02-3 STAFF4/22/02
1 increase the number of days in each billing cycle in
2 order to collect more revenue,any increase during 2001
3 was due solely to the need of the Company to manage the
I4implementationofthenewbillingsystemwhilekeepingin
5 mind the other criteria considered when setting the
6 schedules (e.g.,avoiding holiday and weekend reads when
7 possible,trying to keep the billing within the 3-4 days
8 of the meter reading).Idaho Power's Tariff Rule D.6
9 (Sheet No.D-3)provides for meters to be read normally
10 at intervals of approximately 30 days.However,the
11 interval between meter reads can be as great as 45 days."
12 If the Commission decides to keep the tiered rate
13 structure,I recommend that it encourage the Company to
14 limit the instances of billing periods exceeding 30 days.
15 I also recommend that the Company's tariff be amended to
16 reflect a more reasonable range of number of days to be
17 included in a billing period.
18 Q.In your opinion,have tiered rates generally
19 succeeded in making customers more aware of their energy
20 usage?
21 A.A number of customers submitting comments and
22 filing complaints with the Commission admitted to having
23 taken measures to conserve and cut back on energy usage.
24 Most talked about replacing or adding insulation,closing
25 cracks under doors and around windows,replacing
CASE NOS.IPC-E-02-2 GRAVES,D (Di)19IPC-E-02-3 STAFF4/22/02
i inefficient windows and doors,and turning thermostats
2 down.
3 Q.In your opinion,do you think there were other
4 issues that customers opposed to tiered rates perhaps did
5 not consider when they filed their comments and
6 complaints with the Commission?
7 A.Oftentimes,when Consumer Staff investigated a
8 complaint,they found billing errors were the cause for
9 the customer's complaint and not tiered rates per se.
10 Billing errors included misreads and estimated reads,
11 which coupled with the tiered rate,would result in the
12 customer receiving an unnecessarily high bill.In many
13 cases the animosity towards tiered rates is misdirected.
14 In the Mini-Cassia area Idaho Power
15 investigated a problem that was created by an
16 inappropriate and unauthorized estimation of electricity
17 usage.The Company analyzed the records of more than
18 3,000 customers in the Mini-Cassia area to determine the
19 extent of the problem.The Company found that 225
20 customers were affected by the problem and made billing
21 adjustments totaling $1,568.The average adjustment per
22 account was $6.96,but for some individuals,the
23 adjustment was much greater.Each affected customer was
24 mailed a letter explaining the situation and indicating
25 the amount of the adjustment to expect on his or her next
CASE NOS.IPC-E-02-2 GRAVES,D (Di)20IPC-E-02-3 STAFF4/22/02
I
1 bill.In addition,all Oakley customers were mailed a
2 postcard offering an apology and an opportunity for
3 customers to discuss the bill in person with Company
4 personnel.
5 Q.Based on your review of all the written
6 comments in this case and the consumer complaints filed
7 with the Commission's Consumer Assistance Staff,do you
8 believe the energy crisis and the subsequent rate
9 increases have had any positive results?
10 A.Yes.It has made customers more atuned to
11 their actual energy consumption versus the dollar amount
12 they pay for energy.The Northwest has historically
13 benefited from having the lowest energy rates for energy
14 in the country,so customers have not received the sort
15 of price signals that encourage energy conservation.
16 Customers now appear to be more aware of their daily
17 energy consumption and how taking some basic conservation
18 steps can positively impact their energy bills.
19 Q.Does this conclude your direct testimony in
20 this proceeding?
21 A.Yes,it does.
22
23
24
25
CASE NOS.IPC-E-02-2 GRAVES,D (Di)21IPC-E-02-3 STAFF4/22/02
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF APRIL 2002.SERVED THE FOREGOING DIRECT TESTIMONY OF DAN GRAVES,IN CASENOS.IPC-E-02-02/IPC-E-02-03,BY MAILING A COPY THEREOF,POSTAGEPREPAID,TO THE FOLLOWING:
LARRY D RIPLEY JOHN R GALE VICE PRESIDENTSENIORATTORNEYREGULATORYAFFAIRSIDAHOPOWERCOMPANYIDAHOPOWERCOMPANYPOBOX70POBOX70BOISEID83707-0070 BOISE ID 83707-0070
PETER J RICHARDSON WILLIAM M EDDIERICHARDSON&O'LEARY PPLC LAND &WATER FUND OF THE ROCKIESPOBOX1849POBOX1612EAGLEID83616BOISEID83701
R SCOTT PASLEY DAVID H HAWK,DIRECTORASSISTANTGENERALCOUNSELENERGYNATURALRESOURCESJRSIMPLOTCOMPANYJRSIMPLOTCOMPANYPOBOX27POBOX27BOISEID83707-0027 BOISE ID 83707-0027
SECRETykY
CERTIFICATEOF SERVICE