20220503Smith Declaration.pdf

LISA D. NORDSTROM (lSB No. 5733)
ldaho Porer Company
1221 \filaEt ldaho Sfioet (83702)
P.O. Box 70
Boiee, ldaho 83707
Tolephone: (208) 38&5825
Facsimile: (208) 388€936
lnordstrom@idahooower. com
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BEFORE THE IDAHO PUBLIC UflLMES COMMISSION
Karen Eilckson,
Comphhant,
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ldaho Power Company,
Repondent.
Case No. IPC€-zz-W
DECI.ARANON OF DAN SMITH
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DECLARATION OF DAI{ SMITH
DECLARATION
I, DAN SMITH, under penalty of perjury of the law of the State of ldatro, and pursuant to
Rule 2.7, Idaho Rules of Civil Procedure, and Idaho Code $ 9-1406, declare as follows:
l. I am over eighteen (18) years ofage.
2. I am onployed as a Residential & Commercial Energy Advisor ("Energy Advisor")
for Idaho Power Company (*Idaho Power").
3. As an Energy Advisor, I interact with Idaho Power customers and advise customers
on energy consumption and billing issues and help resolve sensitive issues with residential
customers. In this role, I have visited Karen Erickson's residence on multiple occasions in an
attempt to respond to her requests for assistance and accommodations from Idaho Power for her
electric utility account. To the best of my knowledge, Idaho Power has been working with Ms.
Erickson for years to resolve this issue.
4. On February 22, 2022,I visited Ms. Erickson's residence to discuss her past
accommodation requests, Idaho Power's proposals set forth in a letter dated November 22,2021,
as well as Ms. Erickson's ac,count status. At that time, Ms. Erickson had a past-due balance and
was facing disconnection of service after winter protection ended if she did not make a timely
payment.
5. I had prepared talking points to read to Ms. Erickson during my February 22 visit.
While I was reading aloud my pre,parod comments, Ms. Erickson stopped me and indicated she
could not understand me if I was not looking directly at her while I spoke. I stopped glancing at
my notes and discussed Ms. Erickson's payment of her bill. She offered to provide me cash for
her payment, but I did not have the appropriate paperwork to accept a cash payrnent. I made
arrangements with her to return on February 25,2022.
DECLARATION OF DAN SMITH - Page I of 2
6. During the meeting on February 22,Ms, Erickson indicated that she had visual and
auditory disabilities, and that she believed Idaho Power had not been willing to accommodate her
disability requirements. She further requested a case rnanager, and I infonned her I would share
that request with Idaho Power but did not make a commitment regarding any accommodations.
7. On February 25,2022,1 returned to Ms. Erickson's residence to take her payment.
When I arrived at the residence, Ms. Erickson was present along with several women who observed
the rneeting and appeared to be taking notes about the conversation.
8. Ms. Erickson again asked to have an ADA appointed case worker present and
suggested that it was Idaho Power's responsibility to ensure a case worker was available. She
appeared upset that a "case worker" had not accompanied me to her home.
9. To the best of my knowledge, Idaho Power does not have employees with the title
of "case worker." However, ernployees in the Energy Advisor role frequently respond to customer
concerns about bills and help residential custorners resolve issues and cornplaints.
10. Ms. Erickson provided me with a cash payment for the past due balance on
her account, and she also presented me with a letter to ldaho Power restating her concerns about
Idaho Power and her need for accommodations. I provided the letter to the Canyon West
Regional Manager.
I I . I declare under penalty of perjury under the laws of the State of ldaho that the
foregoing is true and correct to the best of my knowledge and belief.
DATED this n.L
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DECLARATION OF DAN SMITH - Page 2 of 2
N SMITH