20070207Response to Summons.pdf

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IDAHO~POWER~
An IDACORP Company
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Lisa D. Nordstrom
Attorney II ILi;:(, PU
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February 7 2007
Jean D. Jewell , Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. IPC-07-
Phillips v. Idaho Power
Dear Ms. Jewell:
Please find enclosed for filing an original and seven (7) copies of the Answer
Idaho Power Company in the above-referenced matter.
I would appreciate it if you would return a stamped copy of this transmittal letter in
the enclosed self-addressed , stamped envelope.
Very truly yours/7
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Lisa D. Nordstrom
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Enclosures
O, Box 70 (83707)
1221 W. Idaho St.
Boise, 1083702
LISA D. NORDSTROM ISB #5733
BARTON L. KLINE ISB #1526
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone No. [phone]
FAX Telephone No. [phone]
E-mail: Inordstrom
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idahopower.com
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Attorneys for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
JERENE PHilLIPS,
Petitioner
) CASE NO. IPC-07-
) ANSWER OF IDAHO POWER
) COMPANYIDAHO POWER COMPANY
Respondent.
COMES NOW Idaho Power Company ("Idaho Power" or the "Company
and , in accordance with IPUC R.P. 057 , hereby submits this Answer to the
Formal Complaint submitted on January 11 , 2007 by Jerene Phillips ("Ms.
Phillips ), the Petitioner in the above-entitled matter. Idaho Power hereby denies
all of the material allegations contained in Ms, Phillips' Complaint except as
specifically admitted by Idaho Power in this Answer. Pursuant to Idaho Public
Utilities Commission ("IPUC") Rule of Procedure 057.02(a), any material
ANSWER OF IDAHO POWER COMPANY - 1
allegation not specifically admitted in this Answer shall be considered by the
Commission to be denied.
FACTUAL BACKGROUND
Jerene Phillips is an Idaho Power customer and has taken continuous
service at 16625 Basin Way in Boise since it was constructed in 1994. Given the
service requirements of her all-electric home , the construction plan called for a
Current Transformer (CT) installation, thus requiring a meter multiplier (a.
meter constant) to calculate the actual kWhs for billing. On March 26 , 2006
during a periodic test Idaho Power visually inspected the CT wiring and
exchanged the meter at Ms. Phillips' address for testing as part of a planned
maintenance meter exchange. When processing the exchange order, the new
meter information and the correct multiplier of 40 were entered into the billing
software system.
Idaho Power sent the old meter to its Meter Test Facility and determined
that it accurately performed its role towards recording energy usage. After Ms.
Phillips called Idaho Power on June 13 , 2006 regarding the high energy use on
her bill , Idaho Power scheduled an appointment with Ms. Phillips on June 22nd at
the premises to help determine why her energy usage had doubled, On June
23rd it was determined a meter error had occurred when a multiplier of 20 rather
than 40 had been erroneously inputted into Idaho Power s billing system in 1994
when Ms. Phillips' service was initially established. As a result , Ms. Phillips was
charged for only half of her electric usage during the subsequent 12 years.
ANSWER OF IDAHO POWER COMPANY - 2
Later that same day on June 23 , the Company advised Ms. Phillips of the
error and that an Idaho Power employee would return to the premises to verify
that the multiplier of 40 was correct before a corrected billing would be sent.
Idaho Power confirmed that the CTs are the correct size, are installed correctly
and are still installed at the premises.
On July 12 , 2006, an Idaho Power representative called Ms. Phillips to
explain that the under-billed usage for the three-year period between April 2003
and March 2006 would be included on her August 8th bil1.1 The representative
also explained that payment arrangement options were available , including
increased payments over 36 months to pay the re-billed amount.
Ms. Phillips contested the amount of the corrected billing and attempts to
settle the matter were not successful. Idaho Power representatives have visited
with Ms. Phillips several times to help her better understand her power
consumption. The Company also conducted an energy audit of her home and
installed a survey meter that records 15-minute intervals to better identify areas
in which energy savings can be achieved. Idaho Power has visited the residence
several times to confirm the amount of energy the premises is using and provide
information promoting energy saving opportunities.
In the fall of 2006, Idaho Power investigated the root causes of incorrect
multipliers like the one used on Ms. Phillips' account. Idaho Power reviewed the
system data for all transformer rated metering installations (approximately
1 The August 8, 2006 bill attached as Exhibit "'A" to the Complaint reflects inclusion of the
$6,306.34 re-billed amount, which can be found by subtracting the "Account Balance
minus "Current Charges" (6613.79 - 307.45 = 6306.34). The $307.45 represents the cost
of current use from meter readings 07/06/2006 through 08/04/2006.
ANSWER OF IDAHO POWER COMPANY - 3
000) and identified nearly 500 installations with questionable meter multipliers
for which field verification orders were produced, The results of these field
inspections yielded nine (9) accounts with billing errors due to incorrect
multipliers and four (4) accounts with billing errors due to wiring installation
problems. As a result of this investigation , Idaho Power has corrected these
errors and changed its reporting and monitoring processes to improve billing
accuracy. In addition , Idaho Power is presently conducting field inspections to
independently verify that 62 previously un-inspected installations are receiving a
correct bill.
RESPONSE TO ALLEGATIONS
Except as specifically admitted by Idaho Power in this Answer, Idaho
Power Company hereby denies all of the material allegations contained in Ms.
Phillips' Complaint filed with the Commission on January 11 2007, The numbers
listed in the following paragraphs correspond to numbering used by Ms. Phillips
in her Formal Complaint.
Idaho Power admits the allegations contained in Paragraphs 1 , 2 , 3 , 4, 7
and 9 of the Complaint.
II.
Idaho Power denies allegations in Paragraphs 5, 8, 12 and 22 that the
Company installed the wrong CT and meter at Ms. Phillips' residence as well as
any claims that its equipment malfunctioned. In 1994 Idaho Power Company
installed the appropriate CTs and meter to serve Ms. Phillips' energy needs and
ANSWER OF IDAHO POWER COMPANY - 4
this equipment functioned properly.However, Idaho Power admits that an
incorrect multiplier of 20 was inadvertently entered into the Company s billing
system. As a result Idaho Power inaccurately prepared Ms. Phillips' bills, thus
billing her for only half of her actual usage since the account was opened in
1994.
III.
Idaho Power neither admits nor denies Paragraphs 11 , 14 and 21 of the
Complaint.The statutes , rules and cases referred to therein speak for
themselves.
IV.
Idaho Power denies allegations in Paragraphs 12 and 15 that it lacks
authority to issue a corrected billing to Ms. Phillips for the months of April 2003
through March 2006. The Company billing practices are governed by the
Commission and its Rules , specifically Utility Customer Relations Rules 204 and
313 (IDAPA 31.21.01.204 and -313), which the Commission promulgated
pursuant to the legislative authority vested in it by Idaho Code 961-507. Idaho
Power s actions are in keeping with these Rules and established Commission
practice. See Order Nos. 28212 and 28298 (finding Avista properly back billed
customers for the maximum three year period after use of an incorrect multiplier
was discovered).Accordingly, Idaho Power likewise denies the allegations
contained in Paragraphs 16, 18 and 19 of the Complaint.
ANSWER OF IDAHO POWER COMPANY - 5
CONCLUSION
Idaho Power respectfully requests that Ms. Phillips' Complaint be
dismissed and that, pursuant to the provisions of the Commission Utility
Customer Relations Rules 204.03 and 313, Ms. Phillips be ordered to pay Idaho
Power Company $6306.34 for electrical service received for the three-year
period between April 2003 and March 2006.
RESPECTFULLY SUBMITTED this ih day of February 2007.
ANSWER OF IDAHO POWER COMPANY - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 7th day of February 2007, I served a true
and correct copy of the within and foregoing Answer of Idaho Power Company
upon the following party by the methods indicated below and addressed to the
following:
Stanley J. Tharp
Eberle, Berlin, Kading, Turnbow
McKlveen & Jones , Chartered
O. Box 1368
Boise, 10 83701
Hand Delivered
L U.S. Mail
Overnight Mail
Electronic Mail
FAX
Jerene Phillips
16625 Basin Way
Boise, ID 83714
Hand Delivered
-X- U.S. Mail
Overnight Mail
Electronic Mail
FAX
Cecelia A. Gassner
Deputy Attorney General
Idaho Public Utilities Commission
O. Box 83720
Boise , ID 83720-0074
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Hand Delivered
S. Mail
Overnight Mail
Electronic Mail
FAX
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Lisa Nord trom
ANSWER OF IDAHO POWER COMPANY - 7