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HomeMy WebLinkAbout20040325FULLEN Direct PUC Original Scan.pdfBEFORE 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 SUSAN J. FULLEN Please state your name, address, and present occupation. My name is Susan J. Fullen.My business address is 1221 West Idaho Street, Boise, Idaho.I am General Manager of Customer Services and Metering for Idaho Power Company. What is your educational background? In 1988 I received a Bachelor of Science in Management Technology from Lewis-Clark State College, and in 1991 I received a Master of Business Administration from Portland State University.I am currently enrolled in the Doctor of Business Administration Program at the University 0 f Phoenix. Please outline your experience with Idaho Power Company. In July 1980,I began my career wi th Idaho Power Collections Clerk in Hailey,Idaho.Shortly after that relocated to the Southern Divlsion headquarters in Twin Falls and became a Customer Service Representative. In 1982 I was promoted to Customer Service Supervisor in the Boise Customer Service Department.In 1983, I relocated back to Twin Falls and was a Customer Service Representative until 1985 when I was again promoted to Customer Service Supervi sor .In 1987 I was promoted to Assistant Division Accounting Manager in the Idaho Power Western Division. FULLEN, DI Idaho Power Company 1991 I was promoted to the Ontario District Manager posi tion, and in 1992 I was promoted to the Southern Division Accounting Manager.From November of 1994 through August of 1995 I was assigned to work on the Distribution Department reorganization.In September of 1995, I was promoted to Manager of Energy Services of the Eastern Region.In 1997, my title was changed to Area Manager the Southern Region.In 1999, I was promoted to Customer Services Manager.In 2002, I was promoted to my current posi tion of General Manager of Customer Services and Metering.In this position, I oversee the customer care operations, the customer information system, the billing processes, including metering, the demand-side management activities, and the customer relations and research acti vi ties.I have been active in the Edison Electric Institute Customer Services Organization, serving as the Chair for this committee in 2002. What is the purpose of your testimony in this proceeding? I will describe customer service and community relations ' developments since Idaho Power s last general rate case. How have the Company s customer service operations changed since the last general rate case? The evolution of technology, improved FULLEN, DI Idaho Power Company processes wi thin the Company, and the change in customer lifestyles have required Idaho Power to implement a new business model that better serves customers.Tha t mode 1 includes changes that are identified as:(1) a move to centralized customer care transactions,(2) the installation of a new customer information system,(3) additional paYment options,(4) 24 hours a day, 7 days a week ac ces s to account information,( 5 ) improved outage management and communication systems,(6) improved customer service systems throughout the Company s service territory,(7) demonstrated performance of our metering and billing systems,( 8) improved facility siting process,(9) enhancements to community involvement activities,(10) additional customer assistance programs,(11) renewed focus on demand-side managemen t programs,(12) increased use of benchmarking and performance monitoring, and (13) continual emphasis on customer satisfaction measurements.I will elaborate on each of these changes. Please describe the move to centralized business transactions. Prior to the establishment of the Customer Service Center in 1994, Idaho Power operated with approximately 31 District Offices.These offices individually performed customer service functions.Those functions included taking and processing cash paYments, work FULLEN, DI Idaho Power Company associated with customer movement, billing, credit and collections, answering outage and trouble calls, and the administrative aspects of new construction.Offices operated Monday through Friday from 8:00 AM. to 5:00 PM with smaller offices closing at noon.The difficulties with this type of operation at Idaho Power were:(1) limited office hours,(2) high operating expenses to maintain the offices, (3) difficult and costly deploYment of customer service technology across 31 locations,(4) maintaining consistency ln operations,(5) multiple phone contacts for customers needing to conduct business with more than one Idaho Power district office, and (6) inability to effectively measure and track performance because of a lack of technology to capture the data. In order to address these issues, in 1993 Idaho Power embarked on a transition to a more centralized operation beginning with the closing of the Shoshone district office.This transition continued over several years and has benefited our customers in a number of ways. The benefits our customers experience from the new approach include:(1) expanded full service business office hours of 7:30 AM to 6:30 PM, Monday through Friday,(2) a single phone number for customers in the Treasure Valley and a toll-free 800 number for customers outside the Treasure Valley calling area,(3) consistency in service and FULLEN, DI Idaho Power Company information regarding our policies and procedures, and (4) prompt service with over 80 percent of our inbound calls answered wi thin 30 seconds. The Customer Service Center employs a well-trained staff with specific customer service skills and uses state of the art technology.Idaho Power monitors calls for quali ty and to provide on-going training support to personnel.All Customer Service Representatives (CSRs) have defined standard performance expectations.A performance management system is utilized that provides feedback to ensure that our customers receive superior customer service. Idaho Power employs bi-lingual CSRs that provide native language service to the Company s Spanish-speaking cus tomers .Addi tionally, we provide an outside language line service to help Idaho Power communicate with other non- English speaking customers. How has Idaho Power s Customer Information System changed since the last general rate case? In November of 2000, the Company installed a new Customer Information System (CIS) that provides many enhancements for customers as well as improved access to customer information for our CSRs, thus increasing our abili ty to be responsive.Bill presentation has been improved for easier customer understanding.The system is available nearly 24 hours a day, 7 days a week, and FULLEN, DI Idaho Power Company facilitates the use of self-service technologies such as Interactive Voice Response Units and integration with the Internet.Single account number and enhanced rate option capabili ty, integrated trouble orders, and improved customer relationship management documentation are now standard. The new CIS enables the Company to combine service at multiple locations into one bill for the customer. Residential and Small General Service accounts can be combined for Budget Pay purposes.Large General Service customers can combine all of their commercial services into one bill.One such customer has over 100 accounts combined into one bill. The new system also allows for a summary of all services to be displayed on the first page of the bill and for the printing of informative messages to customers directly on the bill. Another CIS improvement is the ability to retain permanent customer records.Now, when a customer is added to the customer system, his or her information is not deleted if he or she moves.Should that customer leave Idaho Power and then subsequently return to our service territory, his or her previous history can be retrieved. The system also has the ability to track all customers having service at a specific premises over time, or to track every service any specific customer has had on FULLEN, DI Idaho Power Company our sys tem in the pas t .This increased availability of information can assist in improving our response time in communicating with the customer. Should a cus tomer s bi 11 need to be revi sed or recalculated, the new system automatically calculates and prints a new bill, thus avoiding the manual calculations that were performed in the past. Also, the new CIS provides customers with the opportunity to have duplicate bills and notices sent to a third party of their choice. Please describe additional paYment options provided by the Company. Idaho Power offers various paYment options to customers including 61 pay stations dispersed throughout the Idaho service territory, electronic funds transfer, automatic deduction from the customer s bank account, internet paYment options, payroent by mail, check by phone, and credit card payroents. How has Idaho Power improved retail customer access to account information? Idaho Power provides customers with account information through an Interactive Voice Response Unit (IVRU) that allows customers to access their account information nearly 24 hours a day, 7 days per week.The IVRU provides customers with the capability to make paYment FULLEN, DI Idaho Power Company arrangements, retrieve billing, payroent, and meter reading information, sign up for Budget Pay, and access conservation and usage information.Idaho Power s telephone menu has been recognized by Enterprise Integration Group as "above average " for both the utility industry and call center industry for overall quality, voice quality, information delivery, user friendliness, and ease of operation.Idaho Power s telephone menu scores are shown on Exhibi t 51, a one-page exhibit entitled "Idaho Power Overall Score Has Idaho Power also improved its outage management and communication systems? Yes.Ten years ago Idaho Power s outage management system was not an integrated system. consisted of separate dispatch centers with limited telephone lines and limited use of technology to convey information.Al though 24 hours a day, 7 days a week coverage was available, it was often staffed by only one person with multiple urgent activities to respond to while keeping the electrical distribution system operational.The ability to provide relevant customer information was limited until additional help arrived.Idaho Power had no system to contact customers prior to a planned outage, and very little technology to identify an outage location unless customers called to tell us they were out of service.Today, Idaho Power provides 24 hour a day, 7 days a week coverage for FULLEN, DI Idaho Power Company outage calls.The IVRU provides up to date information for up to 144 customers simultaneously.In case of unplanned outages, the Company has at least one customer service specialist available at all times (along with dispatch personnel), a monitoring system that notifies the Company of outages, and a state of the art outage management system that identifies outages by locations.Addi tionally, there is an outbound calling system to inform customers of planned outages prior to their occurrence. Among 75 utili ties, Idaho Power was ranked tenth in the nation in a 2003 national survey conducted by J. D. Powers and Associates in the outage notification category. Exhibit 52, a one-page exhibit entitled "Providing Outage Information - Top Rated Utilities , shows the ratings for the top-rated utili ties in this category. How does Idaho Power provide customer service outside of the Customer Service Center? Idaho Power has operation centers throughout the service territory to build, operate, and maintain its transmission and distribution facilities.These centers are open Monday through Friday for general business acti vi ties primarily related to the lines operations. Idaho Power manages its operations to respond to emergency situations 24 hours a day, 7 days a week, and is staffed at designated locations throughout the service FULLEN, DI Idaho Power Company terri tory to ensure quick response, as well as a presence wi thin the communi ties it serves. As stated earlier, Idaho Power provides 61 pay stations serving 37 communities throughout the Idaho service terri tory to receive cash payments.In addition, each of the operation centers has a drop box available for check money order payments.The operation centers also provide assistance to customers (via a direct telephone line to our customer service center) for most customer inquiries, and can direct customers to the appropriate personnel for other inquiries. Idaho Power also has representatives staffed locally within the regions to accommodate customers at their home or business.Personal assistance is available for customers in all rate classes regarding billing inquiries, energy efficiency programs, power quality, and other inquiries best accommodated through face-to-face communication. Collection and service connection acti vi ties are performed out of the regional offices, and personnel are available 24 hours a day to respond to these requests. addition, meter reading activities allow for personal interaction at the customer I s premises.Idaho Power strives to provide information to all its employees in order to respond to customers ' inquiries through any of these interactions. FULLEN, DI Idaho Power Company Large industrial and commercial customers have a dedicated representative who actively manages their accounts.The representative is charged with ensuring that these customers are aware of any planned outages and changes to their service. How well are your metering and billing systems performing? Idaho Power s systems are performing very well.Even though our service territory is more rural than most, the Company cost per meter read is comparable to the EEl average (see Exhibit 53 entitled "Cost Per Meter Read" ) . The Company s meter reading accuracy rate is 99.8 percent. Addi tionally, Idaho Power's system-estimated meter reads, corrected meter reads, and meter reread requests are minimal as indicated by Exhibit 54, entitled "Meter Reading Quali ty " . In addition to the direct customer service activities previously described, has Idaho Power made improvements in the way it interacts with the communities it serves? Yes.The Company has implemented an improved facility siting process, it maintains an active community relations program, and provides substantial corporate and employee contributions of both time and money. Please describe Idaho Power s improved FULLEN, DI Idaho Power Company distribution and transmission facility siting process. In 2002, Idaho Power substantially revised its new distribution and transmission facility siting process to more actively promote community participation and gather public input.The primary obj ecti ves of this process are to develop, publish, and share long range plans with jurisdictional authorities and customers in order to foster an understanding of the facilities needed to meet electricity needs, to purchase substation sites, and to acquire transmission rights in advance of the need and before physical development in a given area overtakes our abili ty to economically provide necessary infrastructure. The overall goal is to ensure that we provide the needed infrastructure in a timely fashion and in a manner that is compatible with community needs. How else is Idaho Power involved wi th the communities it serves? Idaho Power continues to work with our communi ties and to encourage employee participation in local acti vi ties.Idaho Power has five community relations representatives and five community education representatives dedicated to working with the communities and schools to: (1) educate the public on energy usage, electrical safety, hydroelectric relicensing, and rate-related issues,(2) plan and manage growth, and (3) to promote the local economies. FULLEN, DI Idaho Power Company In addition, Idaho Power contributed over $640,000 in 2002 to community, civic, health, educational , and other non-profit organizations.These contributions are mad~ on behalf of our shareholders and are not part of our current rate request. The Company s employees are among the most giving in the region in both time and contributions.Idaho Power employees, families, and friends have a major impact in volunteering with several community proj ects and they have set the standard for several events.Idaho Power employees have consistently raised the most money per employee for Idaho Public TV and have had the highest employee participation rate for years.Company employees have raised the most money for the American Heart Association Heart Walk for 2002 and 2003.Idaho Power established a Boise citywide record in 2002 with Rake Up Boise, a program of the Neighborhood Housing Services, Inc., by raking 45 yards of senior citizens.Idaho Power has also provided energy boxes to the more than 600 homes of senior citizens whose yards were raked.The energy boxes contained a florescent light bulb, an energy calculator and information on efficient use 0 f energy. Company employees tied the record at four homes in 2003 for most homes painted as part of Paint the Town, a program of the Neighborhood Housing Services, Inc., which FULLEN, DI Idaho Power Company paints the homes of economically disadvantaged senior citizens and disabled persons.Idaho Power also participates in similar paint proj ects in pocatello and in Malheur County, Oregon. In November and December, employees participate in Take a Turkey to Work Day " which distributes turkeys, hams, and other food items to the Idaho Food Bank and other food distribution agencies throughout Idaho Power's service area. Idaho Power employees also participate in numerous civic and communi ty organizations, Chamber of Commerce events, scouting groups, and fund raisers. What has Idaho Power Company done to assist low-income customers? Idaho Power has actively promoted and managed the collection of contributions from customers for Proj ect Share and has made direct corporate contributions in the amount of $25,000 per year from 1999 through 2003 as well as an extra $100,000 was contributed during the recent high energy cost years.In addition, for each dollar that is collected via customer contributions, Idaho Power adds 10 percent to that amount for Salvation Army Project Share administrative costs.Our regulatory department has informed me that proj ect Share contributions are not part of the Company s rate request. In addition to Project Share, Idaho Power has spent FULLEN, DI Idaho Power Company approximately $252,000 per year for Idaho s Low Income Weatherization Assistance (LIWA) program since 1989.Like the proj ect Share Program, these funds were also supplemented during the energy crisis.LIWA expenses are included in existing rates and continue to be included in the current rate request.Besides its assistance to low- income families, LIWA activities provide conservation benefits to all customers and the Company. Please describe the Company s efforts in the area of conservation or demand-side management (DSM) since 1994. Idaho Power has been engaged in some form DSM activities since the last general rate case, although the emphasis, delivery mechanisms, and rate recovery have changed throughout the decade. In the early 1990s, deferred accounting was used for conservation programs and they initially appeared on the utility s books as regulatory assets.Recovery of DSM expenditures was deferred until regulatory authorization to begin amortizing the accumulated balances could be obtained and appropriate rates could be put into effect. At first, annual expenditures for energy efficiency rose steadily from $1.9 million in 1990 to a peak of $6. million in 1994.Please see Exhibit 55 for a summary of DSM spending from 1990 to 2002.In the last half of the decade, FULLEN, DI Idaho Power Company when it appeared that deregulation and increased competition might jeopardize the recovery of regulatory assets, the Company, with Commission approval, began winding down the tradi tional Company-administered DSM programs, and instead joined the Northwest Energy Efficiency Alliance (NEEA) to promote regional market transformation.Annual expendi tures for energy efficiency activities declined to $1.6 million by 2000. However, then came the California energy crisis that had dramatic ripple effects throughout the west including extraordinarily high wholesale market prices in 2000 and 2001.One of the reactions to these high energy prices was a renewed focus on DSM activities.In 2002, the Company, wi th Commission approval, established the Energy Efficiency Advisory Group (EEAG) and implemented the Energy Efficiency Rider that exists today.The rider is Schedule 91 of the Company s Idaho Tariffs. Since 2002, in addition to its continued participation in the NEEA , the Company has worked closely with the EEAG in reestablishing a broader portfolio of DSM activities at Idaho Power.Material progress has been made. The Compact Fluorescent Lighting (CFL) and the Energy Star room air-conditioning pilot program have been successfully completed.Ongoing energy efficiency programs for residential customers includes the air-conditioner cycling FULLEN, DI Idaho Power Company pilot program, Bonneville Power Administration (BPA) CFL packets, BPA Energy Check-ups, and BPA Super Good Cents/Energy Star manufactured homes incentives.Idaho Power s ongoing commercial programs are the school building operator training initiative conducted in partnership with the Northwest Building Operators Association and Air Care Plus Program, which is a Heating, Ventilating, and Air Conditioning Efficiency Program.We are currently implementing new programs for irrigation efficiency and for industrial efficiency.Additionally, we have a new residential construction program, a new commercial program for both existing and new construction, and a BPA program for multi-family construction in the planning stages. What is the purpose of the Northwest Energy Efficiency Alliance and how does it benefit Idaho Power customers? Idaho Power was one of the founders of the NEEA and has been a funder and an active participant since it's inception in 1997.NEEA I S mission is to catalyze the Northwest marketplace to embrace energy efficient products and services.This mission is accomplished through a portfolio of projects that works to generate financial return for consumers in the region by encouraging the acceptance of energy-efficient products and services in the marketplace.This acceptance, in turn, will transform FULLEN, DI Idaho Power Company markets in the region so that consumers purchase these products as a normal part of their buying habits. The primary benefit to Idaho Power customers is low- cost electricity savings.In 2002 alone, the NEEA has saved 45 average megawatts (aMW) in the region at a cost of about a penny per kilowatt-hour.NEEA estimates that Idaho Power customers have saved about 3 aMW of this energy.The savings have come about through the availability of more energy-efficient products in Idaho stores, through the adoption of newer efficient technologies and through education of customers on the ways to be more efficient. The following are examples of benefits provided to our customers over the past year facilitated by the coordination between NEEA-supported proj ects and Idaho Power. Compact fluorescent light bulb sales from the coupon promotion with local retailers totaled 42,642 (as of February 2003) We expect approximately 2.8 million kilowatt-hours saved each year for utility customers. The year 2002 closed with a market penetration of ENERGY STAR clothes washers of 27.52 percent in the state of Idaho, up from 11.47 percent during first quarter 2001. In November 2002, the Northwest Building Operators Association launched a Level l training series for FULLEN, DI Idaho Power Company Building Operator Certification in partnership with Idaho Power.As a result, 27 school operators were certified from 25 school districts within the Idaho Power service terri tory.The estimated savings from these 25 school districts is 750,000 kilowatt-hours annually. One NEEA measure, termed "commissioning , is the act of providing documented confirmation that building systems function in compliance with design criterion. incorporating commissioning into the construction of the Ada County Courthouse project in downtown Boise, the project is expected to use 20-30 percent less energy than if it had moved ahead without commissioning.The measure is saving about 460,000 kilowatt-hours per year at the 340,000 square- foot building. The 2000 International Energy Code, which includes the International Energy Conservation Code, was adopted in the state of Idaho in March 2002.NEEA contributed to this process through funding of liaison work, city and county education, and training for architects, engineers, and inspectors.Estimated additional costs to the residential sector will be $12.5 million, with a return- on-investment of $20.5 million in energy savings.On the non-residential side, the additional cost of $713,000 will result in $4.3 million in energy savings. Woodgrain Millwork, with plants in Fruitland FULLEN, DI Idaho Power Company and Nampa, has launched a complete motor inventory of their more than 500 motors and replaced some with energy efficient models.The replacement of just one 250 horsepower motor with a higher efficiency model has resulted in an annual electric savings of $600 a year for the company.The potential savings of upgrading the efficiency of the 500 motors as they fail is $300,000 a year. Henggeler Packaging in Fruitland, Henningsen in Twin Falls, and Idacold Storage in Nampa are saving over a million kilowatt-hours a year because of variable frequency drive installations in their fruit and cold storage facilities.That translates to about $50,000 annually for these companies. The city of Emmett, Idaho is saving over $37,000 a year in net operations costs at its wastewater treatment plant because of efficiency improvements insti tuted there by BacGen. Idaho also benefits from the NEEA's research into new innovative products and services.In addition, the NEEA brings together regional energy efficiency players in a collaborative effort so that ideas and methods can be shared.The NEEA provides a background and structure for Idaho Power to implement local delivery programs so that Idaho Power can bring DSM programs to customers faster and largely developed. FULLEN, DI Idaho Power Company Idaho Power continues to actively participate on the NEEA Board and will be evaluating continued participation once the present term expires in 2004. Is Idaho Power participating in other conservation activities? The Company has participated in Bonneville Power Administration s Conservation and Renewables Discount since 2001.This program will deploy $525,600 annually for programs targeted to Idaho low-income residential customers through 2006. How does DSM fit into the Company s planning process? The Company has submitted its 2002 Integrated Resource Plan (IRP) that identifies demand-side resources as a part of the overall resource portfolio.The 2002 IRP viewed demand-side activities as an alternative to help address future system deficiencies.At the same time, the document cautioned that conservation and demand-side measures must be carefully targeted to cost-effectively address the projected deficits due to the nature and timing of the proj ected peak deficits and transmission overloads. Idaho Power is actively engaged in the development of its 2004 IRP.It is my understanding, from discussions with Mr. Gale and Mr. Said, that this 2004 process will place a greater emphasis on a more collaborative approach FULLEN, DI Idaho Power Company than has been the case in recent IRP efforts.The process change is driven by the changing energy environment and by Commission direction.It is also my understanding that DSM activities will be evaluated and integrated with supply-side activities in the 2004 IRP. What is Idaho Power Company s corporate position with respect to conservation or DSM? In light of the changes in our industry, and the political, and regulatory landscape, Idaho Power has developed a new policy direction for demand-side management. This policy focuses on four core values:(1) customer efficiency and satisfaction,(2) resource planning and acquisi tion,(3) environmental ethics and stewardship, and (4) responsibility to all stakeholders.Idaho Power will pursue a balanced approach to DSM program selection that reflects these four core values. I s the Company truly commi t ted to pursuing that goal? Yes.I have fully reviewed our DSM activities and plans with senior management and have the complete support of Mr. Keen and the rest of the Idaho Power's executive management team. Does Idaho Power conduct benchmarking wi th other utilities and measure its customer service performance? FULLEN, DI Idaho Power Company Yes.Idaho Power actively moni tors its Customer Service Key Performance to ensure that excellent customer service is provided.One key performance indicator is "Automated Call Distribution" Service Level.Exhibi t 56 shows Idaho Power s performance in this area.Exhibit 57 is a "Call Handle Time Comparison " between Idaho Power and the 2002 average of EEl-surveyed companies.Exhibi t 58, entitled "Call Volume , is a breakdown of the number of calls handled by the customer service interactive voice response (CSIVR) unit, the outage interactive voice response (Outage IVR) unit, and customer service representatives calls (CSR calls) The customer care operation also benchmarks with peer utilities by utilizing the Edison Electric Institute DataSource Tool, which provides operating data from energy companies across the nation.This data indicates that the Company performs at a level comparable with or above our peers.A comprehensive breakdown of all of Idaho Power's benchmark statistics, that indicate how the Company performs in the areas of customer calls and billing and paYment statistics, is included in my workpapers. Does Idaho Power survey its customers for levels of customer satisfaction and, if so, what are the results of those surveys? Yes, it does.Idaho Power relies primarily FULLEN, DI Idaho Power Company on two studies for customer satisfaction measurement.Idaho Power has contracted with Burke Customer Satisfaction Associates (CSA) to conduct quarterly customer relationship surveys since 1995.In addition to the Burke CSA surveys, Idaho Power acquires the resul ts of the annual J. D. Powers and Associates Electric Utility Residential Customer Satisfaction Study.The J. D. Powers and Associates study is used primarily as a benchmark to other electric utilities. During the 2000-2001 energy crisis, Idaho Power satisfaction levels dropped in tandem with those of other western utilities.Upon implementation of the Company s new business model, Idaho Power began to experience improved customer satisfaction ratings from all customer segments. Idaho Power s customer satisfaction has steadily improved since 2001 and Idaho Power is hoping to exceed pre-energy crisis satisfaction levels. Idaho Power s primary measure for customer satisfaction in the Burke CSA surveys is the Customer Relationship Index (CRI).The CRI encompasses responses from all customer segments to five questions related to overall satisfaction, overall quality, overall value, likelihood to recommend, and Idaho Power s caring.Burke CSA's most recent survey results show Idaho Power s CRI at 82 percent which indicates a higher level of satisfaction than at any other time since Burke CSA has been conducting FULLEN, DI Idaho Power Company surveys for Idaho Power.According to this report, not only has Idaho Power improved its customer satisfaction level in every customer segment, but Idaho Power is also approaching customer satisfaction levels of what Burke CSA considers a Superior Performing Firm See Exhibit 59, which includes a "Summary of Overall Measures and Customer Relationship Index for Idaho Power " and "Strength of Customer Satisfaction " . In addition to the Burke CSA studies, J. D. Powers and Associates also surveys Idaho Power customers in its annual Electric Utility Residential Customer Satisfaction Study.In 1999, Idaho Power was ranked second in the nation and tied for first in the western region in the J. D. Powers and Associates ' customer satisfaction study.In the 2002 study, Idaho Power was reclassified as a medium-sized utility along with eighteen other utilities that have between 250,000 and 400,000 residential customers.The 2003 survey results indicate that Idaho Power rated eighth in the nation in the medium-sized utility group and was first among northwest utili ties.(See Exhibit 60).The 2 003 J. D . Powers and Associates study shows Idaho Power providing significantly high levels of customer satisfaction in the areas of Customer Service, Billing and Payment Options, Power Quality and Reliability (especially regarding keeping customers informed about an outage), Company Image, and FULLEN, DI Idaho Power Company Price and Value.Idaho Power is pleased with our current customer satisfaction performance and remains committed providing superior service to our customers. Does this conclude your direct testimony this case? Yes, it does. FULLEN, DI Idaho Power Company