20040325DRAKE Direct PUC Original Scan.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE STATEOF IDAHO.
CASE NO. IPC-O3-
IDAHO POWER COMPANY
DIRECT TESTIMONY
THERESA DRAKE
Please state your name and business address.
My name is Theresa Drake.My business
address is 1221 West Idaho Street, Boise, Idaho.
By whom are you employed and in what
capaci ty?
I am employed by Idaho Power Company as a
Senior Pricing Analyst.
Please describe your educational background
and work experience.
In May of 1990 I received Bachelor of Science
Degree in Marketing with emphasis in Finance from
Jacksonville State University in Jacksonville, Alabama.
From June 1990 through February 1993, I was employed by the
Federal Reserve Bank in Birmingham, Alabama.During
February 1993, I relocated to Boise and was employed by West
One Bank managing the Marketing Customer Information System,
researching customer purchase behavior and designing
marketing campaigns around customers ' needs.I also formed
a marketing database consulting firm prior to becoming
employed by Idaho Power.I joined Idaho Power in January
1997 as a Pricing Analyst.In July 2001 my position evolved
into a Senior Pricing Analyst.My duties as a Senior
Pricing Analyst include involvement in preparing the cost-
of-service studies, unbundling studies, development of the
Company s tariffs, and managing the Company s Green Power
DRAKE, DI
Idaho Power Company
Program.I also act as a regulatory liaison for customer
service related issues.
What is the purpose of your testimony?
My testimony addresses proposed updates and
changes to several of the Company s service provisions,
including numbering and organization changes and changes to
non-recurring charges, such as service establishment,
reconnection, returned checks and customer deposits.
Have you prepared any exhibi ts?
Yes, Exhibi t No.5 0 explains how the proposed
charges relating to service establishment and reconnection
were derived.
Do you intend to discuss every proposed
change to the tariff at this time?
No.While a few of the changes I discuss are
substantive in nature, a significant number of changes are
form " or "housekeeping " in nature only and do not change
the scope, effect or application of the various tariffs.
The specific changes to the service provisions I address are
detailed in Ms. Brilz ' s Exhibit No. 48, pages 1 through 52.
These revisions are shown in legislative format in Exhibit
No. 48 so that parties reviewing them will be able to
readily identify the proposed changes.
Let's begin wi th the changes being proposed
to the numbering of the Company s General Rules and
DRAKE, DI
Idaho Power Company
Regulations.Would you please explain the nature the
changes and why the Company is proposing them?
First,on pages through Ms.Brilz ' s
Exhibit No. 48, the Rules and Regulations have been more
specifically separated by category than in the previous
tariff.The change in format is intended to make specific
topics easier to locate by creating more categories in the
Rules and Regulations.
Second, Rule F is now labeled, "Service
Establishment and Discontinuance " and clearly identifies
activities involving initiating and ceasing service.
Billing-related items have been moved to Rule G, formerly
Corrected Billing , which is now labeled "Billings
Deposit provisions have been assigned a separate rule,
Rule L.
What are the substantive changes proposed to
the Company s "General Rules, Regulations, and Rates
The current Account Processing Charge,
Reconnect Fee, and Field Collection Charge have been updated
to reflect current costs.In addition, the Company has
elected to adopt deposit criteria for large commercial and
special contract customers as provided in IDAPA 31.21.
Rule 601.
What provisions are included under Rule
Service Establishment and Discontinuance?
DRAKE, DI
Idaho Power Company
Requirements described in Rule F include
Service Establishment, Service Reconnection, Di scontinuance
of Service, Termination Practices, and Field Collection.
Please describe Service Establishment.
Service establishment describes the condition
where a customer desires to activate an account with the
Company and the service is currently energized.When a
customer contacts the Company and requests service at a
specified service point, the Company will determine if the
requested service point is currently energized.If the
service point is energized, the Company performs the work
necessary to complete the transaction; the customer s name,
address, and other pertinent information are entered or
updated into the Customer Information System and the Company
dispatches personnel to the service point to collect an
ini tial meter read.The proposed Service Establishment
Charge reflects the costs of performing these tasks.
Does the Company currently have a charge
associated with establishing service?
Yes. The Account Initiation Charge is
currently assessed.However, no distinction is currently
made regarding whether the line is currently energized
not.
Will the Service Establishment Charge apply
if a customer requests service establishment at a non-
DRAKE, DI
Idaho Power Company
metered service point?
The Service Establishment Charge is not
applicable to non-metered service points.Non-metered
service points such as cable TV power supplies, telephone
booths, street lighting, etc., are unique in respect to the
degree of account establishment work, as described above,
the Company may perform.In particular, no meter reading is
required. Therefore, the costs to establish service for non-
metered accounts are recovered through the standard service
schedule charges.
What if the customer requests service at a
location where the service line is not currently energized?
Service Reconnection describes the condition
where service was once energized, has been disconnected, and
is presently requested by the customer to be re-energized.
The Service Reconnection Charge reflects the costs of tasks
performed to physically reconnect the service and update the
pertinent information in the Customer Information System.
Will a customer be charged both the Service
Establishment Charge and the Service Reconnection Charge?
No.The Service Reconnection Charge includes
the costs associated with the tasks of service establishment
plus the costs of physically reconnecting a service line.
What are the fees associated with these
transactions?
DRAKE, DI
Idaho Power Company
The Service Establishment Charge as detailed
on page 140 of Ms. Brilz ' s Exhibit No. 48, is $20 for all
metered service points.The Service Reconnection Charge,
also detailed on page 142 of Exhibit No. 48, varies with the
skill level required of the employee dispatched to perform
the work.The skill level required is determined by the
line voltage typically serving the customer class.
Customers taking service under Schedules 1, 7, and 9
requesting reconnection during normal business hours will be
charged $ 20 .Customers taking service under Schedules 15,
19, 24, 25, 40, 41, and 42 requesting reconnection during
normal business hours will be charged $40.The higher fee
for the latter schedules represents the required expertise
of the dispatched employee to work with the typically higher
voltage at the point where service is reconnected.Exhibi t
No. 50, page 2, details the derivation of these charges.
Can reconnection service be obtained outside
of normal business hours?
Yes.The charges by rate schedule outlined
on page 142 of Exhibit No. 48 include two additional block-
hours and associated charges.The block-hour structure is
the same as that currently in place.However the charges
have been updated to reflect current costs.
Please explain why the Company proposes the
block-hour charges.
DRAKE, DI
Idaho Power Company
As detai led on Exhibi t No.5 0, page 2, the
charge has been updated in two ways; first, to delineate by
the type of skilled employee required to perform the work
and second, to recognize the higher cost to serve those
customer requests for reconnection after normal working
hours due to the overtime hourly rate paid to employees.
most cases, during the third block-hours of 9: 01 p.m. to
7:29 a., two employees are dispatched for safety reasons.
The proposed charges reflect the costs to serve the customer
requests based on the time the customer requests service
reconnection.
In looking at the second and third block-
hours for reconnection of customers taking service under
Schedules 1, 7, and 9 on page 1 of Exhibit No. 50, the
current costs are slightly lower than the charges currently
approved.Please explain why you are proposing the charges
remain unchanged.
Service provided during the after-hour time
frames poses safety concerns for our employees.The Company
proposes keeping the charges at their current level to
encourage Reconnection Service during the lower-priced first
block-hours.
Are any changes made to the Termination
Practices section?
No.The Termination of Service provision
DRAKE, DI
Idaho Power Company
remains unchanged from our current tariff.The provision
states the termination practices as provided by the IPUC
Utility Customer Rules and Regulations will be enforced.
What updates have been made to the Field
Collection provision?
The Field Collection Charge is designed to
recover the costs incurred when Company personnel are
dispatched to terminate service and the Customer elects to
make a paYment or paYment arrangement to the dispatched
personnel to avoid termination. If the customer chooses not
to pay the necessary amount to avoid termination, the
dispatched Company personnel will perform the termination
service at no charge. The Field Collection Charge as
detailed on page 1 of Exhibit No. 50, has been updated to
account for the variation of skill level required of the
7loyee dispatched to perform the work.
required is determined by the line voltage typically serving
The skill level
the customer class.
In his testimony on page 14, Mr. Obenchain
refers to an adjustment to other revenue to recognize
additional revenue to be collected from the Service
Establishment Charge, Service Reconnection Charge, and the
Field Collection Charge.Would you please explain the basis
for this adjustment?
Yes.Page 3 of Exhibit No. 50 details the
DRAKE, DI
Idaho Power Company
difference in revenues from the current charges to the
proposed charges.
Other than consolidating the billing related
items into one rule, are there any other changes to Rule
Billings?
Yes.The Company is proposing to include a
description of its policy dealing wi th checks or other
paYments returned non-paid by a customer s financial
institution.The Company has an established returned check
policy operated in conformance with the provisions of the
Idaho Code, and includes notification of the applicable
charge to customers on the monthly billing statement.
listing the Returned Check Charge within the Company s Rules
and Regulations, the provision is clarified for customers
and is easier to reference for PUC staff and Company
employees.The corresponding Returned Check Charge of $20
is listed in Schedule 66 (page 142 of Exhibit No. 48).
You mentioned earlier a new Rule L was
developed to address customer deposits.In addi tion
creating a new Rule for deposits, has the criteria for
deposi ts changed?
Rule L was created to isolate and identify
deposi t provisions for residential, small commercial, large
commercial, and special contract customers.Other than
moving the language from Rule F to Rule L, the provision for
DRAKE, DI
Idaho Power Company
residential and small commercial customers has not changed.
However, the Company has elected to establish deposit
cri teria for large commercial customers and special contract
customers as provided under IDAPA 31.21.01 Rule 601.
Briefly describe the deposit criteria for
existing large commercial and special contract customers.
For existing commercial and special contract
customers, a deposit may be required when the customer fails
to make a payment on the due date or the current status of
the customer s business does not pass an objective credit
screen.
What are the deposit condition criteria for
new large commercial and special contract applicants?
A deposit may be required for service if the
applicant is applying for service for the first time, or the
nature of the applicant's business is speculative or is the
type of business that is subj ect to a high incidence of
failure, or if the applicant has an outstanding prior
service account debt with the Company.
What is the proposed deposit amount?
The requested deposit amount will not exceed
two times the customer s actual or the applicant's estimated
highest monthly bill and is payable in two installments.
Why is the Company now seeking to implement
the deposit provision for large commercial and special
DRAKE, DI
Idaho Power Company
contract customers?
In recent years, the Company has become
increasingly exposed to the effects of certain businesses
falling delinquent on paying their accounts and to an
increased number of businesses claiming bankruptcy.Some
instances have occurred where an existing business customer
who has historically made consistent timely paYments has
filed for bankruptcy and ceased business.Even one month'
worth of unpaid billing can amount to a sizable impact on
uncollectible amounts.For these reasons, the Company plans
to implement deposit criteria for large commercial and
special contract customers.
Has the Commission previously approved
similar deposit provisions for any other utility serving
customers in Idaho?
Yes.Utah Power and Light has a similar
Commission approved provision listed under Sheet No. 9R.
in the UP&L tariff.
Are there any other updates to non-recurring
charges?
Yes.Fractional Period Minimum Billings
specifies the minimum bill requirements for each service
schedule when service is taken for a partial month.The
minimum bill amounts have been updated to be more reflective
of the costs associated with bill preparation.While the
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Idaho Power Company
minimum bill amounts do not equal the total cost of
preparing, producing, and delivering a bill and recording
subsequent payments, they reflect a portion of those costs
associated with providing service.The specific minimum
bill amounts for each service schedule are detailed on page
143 of Exhibit No. 48.
Please explain the proposed change to Rule
Rule B, Definitions, includes clarification
of what is considered to be a normal Billing Period.While
a typical billing period is 30 days, the normal billing
period is considered to be 27-33 days.
Is 27-33 days new for a normal billing
period?
No.The Company has a long standing practice
of considering a normal billing period to be 27 -33 days.
The Company proposes to add language to the definition so
that this practice is explicitly stated.
Is there any other change proposed to Rule
Yes.The definition of Connected Load
currently included in Rule B is pertinent only to Schedule
72.Therefore, the definition is moved to Schedule 72.
Are any changes proposed. to Rule D , Metering?
The only proposed update is to state that the
Company has the right to modify meter reading schedules as
required by changing condi tions .Certain events can trigger
DRAKE, DI
Idaho Power Company
a meter reading schedule to be modified, such as holidays or
efficiencies.
the alignment of meter read routes for better operating
to customers.
The update to Rule D provides clarification
Does this conclude your testimony?
Yes.
DRAKE, DI
Idaho Power Company