20040319Fullen Rebuttal.pdf

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re; i S S ION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION,
CASE NO. IPC-O3-
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS INTERIM
AND BASE RATES AND CHARGES FORELECTRIC SERVICE.
IDAHO POWER COMPANY
DIRECT REBUTTAL TESTIMONY
SUSAN J. FULLEN
Please state your name and business address.
My name is Susan J. Fullen and my business
address is 1221 West Idaho Street, Boise, Idaho 83704.
Are you the same Susan J. Fullen who has
previously presented direct testimony in this case?
Yes, I am.
What is the scope of your rebuttal testimony?
My testimony will focus on issues raised by
Commission Staff relating to customer service and by the
Community Action Partnership Association of'Idaho relating
to the Company s Low Income Weatherization Assistance
Program.
Are you sponsoring any exhibi ts wi th your
direct rebuttal testimony?
I am sponsoring Exhibit No. 78.Yes.
StaffinG
In her direct testimony, Staff Witness Ms.
Parker discussed her concern regarding the ability of the
Company s customer service staff to handle the expected
increase in customer phone calls wi th the adoption of
While she commented that the Company hasseasonal rates.
modified its staffing since tiered rates were in effect, can
you describe how the Company is prepared to handle
addi tional, sporadic call volume fluctuations?
The Company has made staffing modifications
FULLEN, Di-Reb
Idaho Power Company
to the Customer Service Center since the 2001 tiered-rates
time frame Ms. Parker discussed.As noted by Staff, the
Company now has more part-time employees.In addition, the
Customer Service Center has developed a contingency plan to
handle increased call volumes.The contingency plan
includes the ability to make staffing adjustments by
shortening lunch hours and extending work hours for both
shift and part-time employees.These adjustments are
outlined in a detailed deployment plan based on critical
call volume criteria.I am confident this plan will allow
the Company to manage any increase in calls resulting from
the implementation of seasonal rates.
Prorated Bills
Is the Company taking any steps to address
the issue of bill presentation for prorated bills to help
alleviate customer confusion?
The Company acknowledges that prorated bills
have caused customer confusion.In an attempt to make the
bill presentation less confusing to customers, the Company
is investigating a number of options.Because of the time
needed to fully investigate and test these options, the
Company cannot detail a specific modification at this time.
However, the Company is committed to finding a solution to
make prorated bills less confusing for customers.
FULLEN, Di-Reb
Idaho Power Company
Customer Relations
Staff points out that two significant
functions that are not available through the Company s web
site are customer requests to connect and disconnect
service.Does the Company have plans to incorporate these
types of customer requests in the capability of its web
si te?
Yes.The Company is currently dev~loping
addi tional customer services through our web site.
Staff recommends the CQmpany add a sentence
in Spanish on bills and disconnect notices to inform Spanish
speakers that if help is ,needed in understanding what the
notice or statement says, he or she may call the Company for
assistance.Does the Company agree with Staff'
recommendation and if so, what steps have been taken to
accommodate this recommendation?
The Company agrees with Staff'
recommendation.After consulting with the Company s local
multilingual translator, the Company has initiated the
addition of Spanish text near our telephone numbers in the
heading of our bills and notices.The Company anticipates
completing this change before April 1, 2004.Exhibi t No.7 8
is a sample bill showing the additional text.
Staff recommends adding an ~on-hold" message
in Spanish informing customers that a Spanish-speaking
FULLEN, Di - Reb
Idaho Power Company
Does the Company agree wi representative is available.
this recommendation?
The Company agrees that providing Spanish-
speaking assistance to Spanish-speaking customers is
As Staff points out, the Company always has atimportan t .
least one Spanish-speaking representative available on any
If this representative is assisting anothergiven shift.
customer at the time Spanish assistance is needed, the
Company utilizes its third-party inte~pretation service to
The Company recently installed anassist the custom~r.
upgraded voice activated response unit to enhance customer
We are currently working with the Powerinteractions.
Assistance Line (PAL) vendor to implement the Spanish assist
option that is available through this system.Thi s option
will allow customers to select Spanish-speaking assistance
through the initial menu offering.Because this option will
provide front-line service to customers, I do not believe
that an ~on-hold" message is necessary.
Does the Company agree with Staff'
recommendation to evaluate the need for bills and delinquent
notices to be printed in Spanish?
Yes, the Company will continue to monitor
customer requests for Spanish and other language assistance.
Presently, the Company has not had such requests from
The Company will explore thecustomers or agencies.
FULLEN, Di-Reb
Idaho Power Company
opportuni ty to work wi th other groups to enhance our
services.
Out-of-Cvcle Meter Readinqs
Staff expressed concern regarding the
Company s presentment of out-of-cycle meter reading dates on
customer bills.Specifically, Staff recommended that the
meter reading date for an out-of-cycle meter reading should
reflect the date the meter was actually read not tAe' date
what steps are beingthe customer requested the service.
taken to address this issue.
The Company has thoroughly assessed the
process involved in the reported meter read date represented
on the customer s bill.As a result of this assessment, the
Company ,will modify its process so that the actual date the
final meter reading was taken or service was disconnected,
not the date the customer requested the service, will be
recorded in the Company s Customer Information System and
will be printed on the customer s bill.This process change
will also result in the service starting date printed on the
customer s bill corresponding to the actual date the service
connection or meter reading took place.Changes to the
Company s out-of-cycle meter reading process are targeted
for completion by June 1, 2004.
Non-compliance
In her direct testimony Ms. Parker stated the
FULLEN, Di-Reb
Idaho Power Company
Company is out of compliance with UCRR 401, 402, and 403.
Do you agree with this assertion and if so, what action is
being taken to comply?
The Company concurs it is not in compliance
wi th UCRR 403. However, the Company respectfully suggests
that it meets the requirements of UCRR 401 and 402.UCRR
401 provides customers the right to complain or request a
conference, that the Company will promptly investigate the
complaint, and that the applicant or ~ustomer ' s service will
, "
not be terminated , during an investigation.The Company
adheres to this rule as can be demonstrated through the
customer contact notes within the Customer Information
System and through correspondence with the consumer staff at
the Commission.
UCRR 402 provides customers and applicants the
defini tion of Commission authority over complaints.The
Company s partial non-compliance with UCRR 403 does not
impact UCRR 402 as this rule establishes the Commission
authori ty and procedures.
With regard to UCRR 403, Record of Complaints, the
Company agrees it is not in full compliance.While the
Company does maintain records of all complaints submitted
through the Commission, it has not been fully tracking
complaints received by the Company which do not involve
Commission Staff.The Company has taken steps to improve
FULLEN, Di-Reb
Idaho Power Company
monthly reporting and categorization of customer contacts
Addi tional training will beentered as a ~complaint" type.
conducted to improve awareness of the complaint procedure
and the review, recordkeeping and reporting aspects of the
process.
A Company-wide study is underway to determine the
best method for collecting complaints that reach the Company
through various departments outside the Customer Service
The Company expects to have a plan to address thearea.
collection of the~e complaints by May 1, 2004.
Staff also found the Company to be out of
compliance with UCRR 701.Please detail steps taken to
provide customers with a Summary of Utility Customer
Relations Rules (UCRR 701).
A Summary of Utility Customer Relation Rules
has been distributed to residential customers annually for
several years.The Company has developed two new consumer
information brochures for irrigation, commercial, and
industrial customers that provide a summary of the Utility
Customer Relation Rules.A brochure was mai led to all
existing irrigation, commercial, and industrial customers
with their February billing.The brochures contain a
Spanish sentence indicating the brochure information is
available in Spanish.
In addition, a process was implemented in March 2004
FULLEN, Di-Reb
Idaho Power Company
that provides brochures to all new customers in accordance
with UCRR 701.
Low Income Weatherization Assistance ProGram
In his direct testimony on behalf of the
Community Action Partnership Association of Idaho (CAPAI),
Mr. Robinette proposes design changes to the Company s Low
Income Weatherization Assistance (LIWA) program.
Specifically, Mr. Robinette proposes changes to the current
50 percent funding, the administrative fee paid through LIWA
to the participating agencies, and the tot~l funding for the
In addition, Mr. Robinette comments on theLIWA program.
negative consequences of the required 1.1 savings to
Please comment on Mr. Robinetteinvestment ratio (SIR).
proposal regarding the Company s funding match for each
weatherization job.
The Company currently funds 50 percent of the
Mr. Robinet cost of qualifying weatherization measures.
recommends that the Company fund up to the full cost for the
The Company opposes funding the full costswork performed.
of weatherization jobs.While the Company does fully fund a
limi ted number of special weatherization jobs for tax-exempt
organizations, an essential requirement of the current LIWA
program is that regular weatherization jobs qualify for and
recei ve governmental funding.This requirement allows the
Company to hold the administrative costs of the program to a
FULLEN, Di-Reb
Idaho Power Company
reasonable level while assuring that our retail customers
The Company believes that afunds are used effectively.
continuation of matching funding from LIWA for qualifying
measures is appropriate.
Please comment on Mr. Robinette s proposal
regarding the administrative fee paid through LIWA to the
participating agencies and his comments on the SIR.
Mr. Robinette proposes the administrative fee
paid through LIWA to the participating agencies be increased
to $150 per unit., The Company is willing to consider an
increase in the administrative fee and is willing to reduce
The Company proposes thatthe required SIR from 1.1 to 1.
both these matters be addressed with the weatherization
agencies during the preparation of next year s contracts
and, if necessary, be brought to the Commission for
appropriate action under a separate proceeding.
Mr. Robinette also proposes an increase in
Please comment on thisLIWA funding to $1.2 million.
recommendation.
The Community Action Partnership Association
of Idaho recommends a 426% increase in LIWA funding above
the 2003 level of non-BPA expenditures.However, the
Company has not included increased funding for the Low
Income Weatherization Assistance program in its current
application before the Commission.Accordingly, it may be
FULLEN, Di-Reb
Idaho Power Company
more appropriate to investigate funding levels and funding
mechanisms outside of this proceeding.
The Company proposes reviewing these topics
as well as other program design issues with the Energy
Efficiency Advisory Group (EEAG).The EEAG is a forum that
allows Idaho Power customers, regula tory staff and other
interested stakeholders to offer advice to the Company in
formulating, implementing, and evaluating energy efficiency
and demand reduction programs and I believe that the group
could contribute significantly to the ,disctission.If the
Company, wi th support from the EEAG, determines that changes
to the LIWA program design , funding levels, or funding
mechanism are appropriate,' the changes would be brought to
the Commission, if necessary, for appropriate action under a
separate proceeding.
Does this conclude your direct rebuttal
testimony?
Yes.
FULLEN, Di-Reb
Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-O3-
IDAHO POWER COMPANY
EXHIBIT NO. 78
S. FULLEN
Sample Bill
Spanish Text
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IMHO
POWER
An IDACORP Company
www.idahopoWer.cmil
Qucsliom'! Conine I us 3\:
O. Box 30, Boise, ID 83721
Oreal! usal388c2323lTrc.asurc Valley)
or (80()) 488,615 I Sc habln cspaiioJ
Fodastcrsc..vice plcnsecall
Tuesday ibrougbFriday. 7:30a.m, 10 6;30 p.
Service Agreement No:
Service l...A)c~lfi()n: 1
Customer N~me:
Account Number:
Page: 2 of 2
Billing Date:
Print Date:
Q3lJ 4/2003
Q31 1112004
Next Re41d Date: 04/11/2003
Meter Service Period Number Reading Meter Readings Meter kWh
!\J\Jmber From of Days Type Previous Current Constlmt Used
0021892260119 02/10/03-m/12J03 R.:gi.llar 21714 23375 166:1
Residential
Rate Schedule
101
02/10/2003,
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03/12/2003 30 d~ys '
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Customer Charge; per met.erper'ffiPntb..
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' $2.
Energy Charge 1;66Jk\Vh (ij). , $O.Op8673 per kWh....
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FranchiseFee.l% ....
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$1.1,
Conservation PrbgmmFundihg'Charge.... .......... ................. ...... ,......m..
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$0.30
Fe(ieml 'ColUl)1bia River BenefitsSu.ppJiedby, BPA .........,.............
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kWltI!illef!=1418
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If writinginformationhelow, please cheek Jbe' appropriate bo'ton the rev~rse side.
Account Number:
J\TEW CONT ACT 1NFO~iATION:
DoesJdaho Power have your correct mailing address
and phone number? If not, please write any changes below:
New T~lephone Number:
PR O.JECT SHARE PLEDGE
Please add the amount indicated to my monthly bill.0$2 0$5 0$10
I would like to make aone...time contribution in the
amountof$
Please round-up my month.1y blllamoullt to the
nearest dollar .md contriqutethedifference to Pro~tShare.
Thank you and please remember to track your
tax-deductible donations.
Exhibit No. 78
Case No. IPC-O3-
S. Fullen, IPCo
Page 1 of 2
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IMHO
POWER
Page: of2
An IDACORPCompany
Questions ! umlacl IIs.a1;
1';0, Box 30. Boise. 11) 83721
Orcallus,n 3&1:I"232:~ rrrcasurc Valley)
or (800) 488-615 J Sc hahla espai\o!
Fort'aslCncrvicc please call
Tucsday through Friday. 7:30,1.01. lo6:30p,m.
Customer Name:
ACCOUI;i Number;
Billing Date:
Print Date:
O'l.!J J 4/2003
03/J 1/2004WVl'VI' .idahopower .com
Due Date:Please Pa :
03131/2003 114.
Account
Acdvity
Previous Balance...........
,...............,...........................................,..........
$123.
Payments - Thank YOl.l.....
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............,........ $123.28CR
Balanc.e Forward..........................................................""
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Current Charges......................
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Account ,Balance......
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Please Note: Any unpaidhalanccs ..",iUbcassesscd,11 monthlychargcofonepercem (1%) for Idaho customers. RcLUrncdcbceks may be resubmitted
eleclronical!y for paymcnt. Checks remaining unp~id willl~clir.uged-aS20(ec.
Harness the Wind: GoG-reen!
Join IdahQpowercustO.mers"Who:~~s1;lppPrt~IIg' new, renewa1;ile" powetfr()m re..,ources s(jc9,~:wi#d,
ors()1~,;Enr911 on the Energy C~nl~W~\1.P"geat wwwJdahpvP",er.C()JDor call, ()urCJ,i!\~9.merServi(;~C~nrer.
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Green, I~ower
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Please rei urn this portion willI your pnymcnl and write youraccollnillumber 011 yourcheckormoncy order made payable to Idaho Power.
Plcase bl;ng entire bill when paying alII Pay Stillion. Tha:nkyou!
Please P3)'$1l4~50Due Date: 03131/2003
Anumnt Enclosed:
Accounl Number:ProFclSbarepledgc .O()\cdon ",ve~esidc
Addresslpbonccoricdiori .. printed on revcrscsi~
Idaho Power
O. Box 30
Boise, ID 83721
1111111111,1111111 11111111111 Exhibit No. 78
Case No. IPC-03-
S. Fullen, IPCo
Page 1 of 2
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