20101116Coughlin Reb, Exhibits.pdf

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UTILITIES COf.,MISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNTAIN POWER FOR
APPROVAL OF CHANGES TO ITS
ELECTRIC SERVICE SCHEDULES
AND A PRICE INCREASE OF $27.7
MILLION, OR APPROXIMATELY
13.7 PERCENT
)
) CASE NO. PAC-E-10-07
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) Rebuttal Testimony of Barbara A. Coughlin
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ROCKY MOUNTAIN POWER
CASE NO. PAC-E-10-07
November 2010
1 Q.Please state your name, business address and present position with
2 PacifiCorp dba Rocky Mountain Power (the "Company")?
3 A.My name is Barbara A. Coughlin, 825 NE Multnomah, Portland, OR 97232. My
4 present position is Director, Customer and Regulatory Liaison.
5 Qualifications
6 Q.Please describe your educational and professional background?
7 A.fhave worked in the gas and electrc industr since 1978. I recived a Legal
8 Assistant Certificate from MarcrestCollege in 1991. From 1978 to 1997, I held
9 varous positions in increasing levels of responsibilty within the legalregulatory
10 deparent of Iowa-illinois Gas and Electrc Company, a predecessor company to
11 MidAmerican Energy Company. In 1997, I was promoted to a customer services
12 supervisor and in 1999 was promoted to customer services maager at
13 MidAmerican Energy Company. I worked as maager of regulatory projects at
14 PacifCorp from 2006 though 2008, when I was promoted to my current position
15 of Director of Customer and Regulatory Liaison.
16 Puse of Rebuttal Testimony
17 Q.What is the purpose of your rebutta testimony?
18 A.The purose of my rebuttal testimony is to respond to testimony of Ms. Marlyn
19 Parker and Mr. Curis Thaden of Idaho Public Utilities Commssion Staff
20 ("Sta') and respond to testimony of Ms. Teri Ottens representing Community
21 Action Parership Association of Idao ("CAPAI"). Specifcaly I wil address
22 the following issues raised by these pares:
23 .Landlord Interim Biling and Link Programs;
Coughlin, Di -Reb - 1
Rocky Mounta Power
1 .Red Flag Rules;
2 .Rebiling;
3 .Customer notification for rebillng;
4 .Unbiled usage;
5 .Meter upgrade;
6 .Moratorium and winter payment plan communications;
7 .Lend-A-Hand contrbutions;
8 .Energy conversation education;
9 .Low income weatherization funding; and,
10 .Low income weatheriation matching funds.
11 Landlord Programs
12 Q.Please explain the Company's landlord progras.
13 A.Rocky Mountain Power offers two landlord programs to mae it easier for
14 customer to do business with the Company. These programs provide resources
15 for landlords, property owners, and tenants. The first program is known as the
16 Landlord Interim Bilng Agreement, and the second program is known as the
17 Landlord Link program.
18 Q.What is a Landlord Interi Biling Agreement program?
19 A.A Ladlord Interim Billig Agreement is a contractual agreement that ensures the
20 contiuance of electrc service between tenants for renta propertes. Any
21 propert owner, landlord or a propert management company that has a site or
22 multiple sites is eligible.
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Please explain how a landlord participates in this progra
A Landlord Interim Biling Agreement form is completed and signed by the
landlord. Once the completed form is retued to the Company, the interim
biling is set up within our customer service system.
How does the program work?
When the tenant applies for electrc service at a rental propert where there is a
signed Landlord Interim Biling Agreement, the Company transfers responsibilty
for the biling from the landlord's name into the tenant's name. When the tenant
later moves out and closes their account, the biling responsibilty is automatically
transferred back into the landlord's name.
After the Company sets up the interim biling designation within its customer
service system, does it retain the agreement signed by the landlord?
Yes, the Company retains the Landlord Interim Biling Agreement for six years.
Please explain the Landlord Link program?
The Landlord Link program allows the Company to work together with property
owners, landlords or propert managers to efficiently handle requests by tenants
for service when they move in and out of rental units. Participation by the
landlord in the Landlord Interi Billing Agreement program is a prerequisite to
parcipate in the Ladlord Lin program.
Ths Landlord Lin program was originaly piloted a number of years ago
in a university town to make the anual move-in process with students more
efficient. The pilot program was well reived by the paricipating landlords and
was made avaiable thoughout al of the Company's service terrtories in 2003.
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While program paricipation is relatively small, 17 landlords with a total of 452
rental units in Idaho, we believe those landlords who paricipate are pleased with
the program.
How does a landlord participate in the Landlord Link program?
Information regarding the Landlord Link program is found on the Company's
website. A landlord who is interested in paricipating contacts the Company via
emai or by telephone. A small group of specially trined call center agents
respond to landlords by telephone to explain all aspects of the program. This
ensures the landlord has a thorough understanding of their responsibilties as
paricipants, which includes readig the meter as a tenant move in and out,
securng the appropriate electrc service application information, and verifying the
identification of a prospective tenant/customer.
How does Landlord Link work when tenants move in and out of a premise?
A parcipating landlord wil work with their tenant by providing them a Landlord
Link Application to be completed and signed by the tenant, along with the rental
unit's meter readig. This application form requires the same informtion any
other prospective Rocky Mountain Power customer would provide to secure
electrc servce. The form is then sent to the Company via facsime.
Alternatively, the tenant or landlord may submit the same applicant information
via an onle form found on the Company's website. The online application also
includes a field that captues whether it is the tenant or landlord providig the
informtion.
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How does the Company handle applications that are incomplete or other
issues are identifed with the information provided?
If an issue is found with the application, a contact is made to the applicant or
tenant. When a prior debt of the tenant's is discovered, or a deposit is required of
the tenant, the company wil contact the tenant diectly to resolve the issue or
work out a payment solution.
What notification is given to the tenant that they are now a Rocky Mountain
Power customer?
When the online application form is completed, an email confiration is sent
notifying of the activation of service for the specific site on a specifc effective
date. Since the form can be submitted by the tenant or landlord, the emal asks
the landlord to please provide a copy to the tenant. Additionaly, a tenant that has
not recently had an account, or was recently on an account with a different
revenue class, wil reeive a Welcome Aboard Kit including a welcome letter and
rate information. All tenants get notification with their first bil which is marked
Opening Bil.
Is there an additional notification the Compay wi implement to alleviate
some of Ms. Parker's concerns regardig a third party submittig
application information to the Company?
Yes, the Company is implementing a process to send a postcard to any new tenant
at a premise covered under the Ladlord Lin program, notiying the tenant that
electrc service has ben put in their name at that address.
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Rocky Mountai Power
1 Q.How long does the Company retain the faxed Landlord Link Application and
2 the information gathered through the online Landlord Link Application?
3 A.The Company retains the faxed applications and online information for six years.
4 Q.Ms. Parker states she has concern with the Company accepting applications
5 for service from third parties and is also concerned that the Company may
6 not have adequate checks and balance in place to meet the requirements of
7 the Federal Trade Commission's Red Flag Rule. Do you believe these
8 concerns are warranted?
9 A.No, I do not. As I indicated earlier, the customer information provided to the
10 Company, whether it comes via fax on the Landlord Link Application or though
11 the online Landlord Link Application, is the same as that required from any other
12 prospective customer reuesting electrc service from the Company. As a
13 paricipant in the program, landlords are asked to verify the informtion on the
14 form and check the tenant's identification.
15 Red Flag Rule
16 Q.Doe the Company have a process to address the proposed "Red Flag Rule"?
17 A.Yes. In October 2008, in anticipation of the passage of the Red Flag Rule, the
18 Company implemented a new process to review all new customer accounts for the
19 protection of personal identities. All new customer records are sent though a
20 nightly electronic fie process to Equifax for verification of the customer
21 identication. This includes accounts that were create via the phone, online, or
22 though the Landlord Lin program. Equifax retus a fie to the Company
23 indicatig potential and probable discrepancies in personal identifying
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1 information provided by the customer. These discrepancies are then investigated
2 by a specially trained team of specialists to follow-up with customers to correct
3 any errors or take other appropriate action.
4 Q.Has the Company made any changes to its Red Flag process since the 200
5 implementation?
6 A.Yes. Since 2008 the Company has continued to review and refine the process to
7 ensure it meets the intent of the rule and provides appropriate protections for our
8 customers. As par of Customer Service's ongoing process improvement efforts,
9 early in 2010, a Customer Services review was conducted by personnel not par of
10 the daly work flow. As a result of this review, recommendations for additional
11 account documentation and a tracking mechanism were made and have been
12 implemented. In addition, mid-year 2010, the Company's internal auditors
13 reviewed the process as par of their ongoing compliance review of Company
14 practices. If any findigs are identied, corrective actions wil be implemente
15 accordingly.
16 Rebiling
17 Q.Ms. Parker states she identifed some concerns in her investigation of the
18 Company's rebiling procedures under Rule 204 (UCRR) and indicates that
19 the Company does not follow an objecive or independent verifiable
20 methodology when preparing estimated bils. What methodology doe the
21 Company utilze to estimate bills when a meter is not read durg the
22 monthly meter reading window?
23 A.The Company utiizes system logic for estiating regular monthy bils. I wil
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describe the details of the system logic later in my testimony.
What methodology does the Company utilize to rebil a customer when a
meter malfunctions or fails, when the meter equipment was incorrectly
installed or programmed, or when bils were inaccurately prepared?
For all the conditions described above, the rebiled amounts are manually
calculated; system generated estimates are not used. The method used to
calculate the biling adjustment for each condition reference above vares.
Please provide a sample of the method used to calculate the usage for a meter
that has been unregistering consumption for a specifed period of time?
As an example, if a meter was tested and the results reflect a ninety-two percent
accuracy rate, the amount of the adjustment to the customer's monthly bil would
be eight percent of the usage in the allowed months for backbiling. Another
example would be if the meter was tested and the results reflect a 107 percent
accurcy rate, the amount of the adjustment would be a seven percent credit of the
usage in the allowed months for backbiling.
How does the Company rebil a customer in the situation where the
customer's meter stopped functioning?
A bilg adjustment in the situation of a stopped meter is based on a manual
calculation of historical usage of the site, using a per day average. If there is no
avaiable usage for the site to base the manual per day usage calculation, afer the
Company sets the new meter, a speial meter reading is obtaed in order to
determne an average per day usage for the alowed months of backbilg.
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Please explain how biling adjustments are calculated in a cross meter
situation.
A cross meter situation exists when tenant A is biled for the service used by
tenant B, and tenant B is biled for the service used by tenant A. Generally, this
circumstance occurs when an electrcian or propert maager has mislabeled the
meter bases.
In this circumstance the actual amount of usage for both paries is known.
To mae a biling adjustment tenant A would be credited for the usage biled
durng the appropriate time period and debited for the usage of tenant B durng
the appropriate time period; tenant B would be credted for the usage biled durng
the appropriate time period and debited for the usage of tenant A for the
appropriate time period.
Is there any time when the Company estimates usage for a billing adjustment
based on a neighboring property's usage?
No, there is not.
Pleas describe the methodology of the system logic the Company utilzes to
bil a customer when a monthly meter reading cannot be obtaned?
The Company's system logic for estiating a monthly meter reading is base
upon the kWh consumption from the same month last year, plus the usage from
the month before, and the month after that month. The kWh usage from the thee
months is use to calculate an average per day usage which is then used to
calculate the estited use for the curent month. Any varance in the estited
read to the actual customer usage would be adjusted for when the meter is read
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the following month.
Ms. Parker belieyes the Company's method of rebiling is problematic and
there are more accurate ways to prepare corrected bilings such as that
utilzed by both A vista Utilties and Intermountain Gas Company which
have implemented rebillng mechanisms that employ National Weather
Service's Heating and Cooling Degree Days. Please describe any known
issues or customer dissatisfaction the Company has experienced with its
system logic.
The Company has utilzed the system logic described above for over 14 years.
Customer feeback concerning estimated bils is minimal and the minimal
feedback mainly focuses on the fact that a meter was not read, rather than the
. estimate itself. When a customer expresses concern about an estimated read, we
ask the customer to read the meter and provide us a read, or we wil send someone
out to get a read, and we are more than wiling to make an adjustment.
What is the Company's experience with reading meters on a monthly basis?
Over the last several year the Company has consistently been reading ninety-
eight percent of Idaho meters with the designated monthly meter reading
window of one day prior to the scheduled meter reading day and up to five days
after the scheduled meter reading day, and eighty percent of Idaho meters in 2009
were read on the scheduled meter readig day. This means only two percent of
monthly bils are calculated using an estited meter readig.
Why doe the Company utiliz a meter reading window?
Having a meter reading window enables the Company to provide monthly bils
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calculated by using actual usage, yet allows for scheduling constraints such as
weather-related issues, training, or personnel on vacation or ilL.
Has the Company investigated or contemplated a change to its system logic
for estimation of monthly bils?
No. Because of very limted customer feedback, a continued decline in the
number of estimated reads, the fact that the Company is an electrc only utilty,
and electrcity is typically not the primar heat source for the majonty of our
customers, the Company has not found it necessar to investigate other estimation
methodologies.
Should the Company's current methodology be changed?
No. We believe our current methodology is reliable as it is specific to the
individual customer's premise and lifestyle. The Company believes that the cost
to develop a more complex estiating routine that would brig additional costs to
our customers to develop and maintain, is not in the best interest of our customers.
15 Also our curent estimating logic is straightforward and easy for customers to
16 understand.
17 Notifcation of Rebiling
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Ms. Parker, on page 11 of her tetimony also raised concern about
communications with customers whose meters malfunctioned and were
rebiled. How does the Company notify a customer when it is necessary to
rebil?
When a billg adjustment is made to a customer's account, the customer is
provided notification on their next regular bil.
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What does the notification on the customer's next regular bil include?
The adjustment section on the bil wil include the month of the adjustment,
reason for adjustment, dates of service, and the amount of the adjustment.
Documentation is added to the customer's account providing details of the billng
adjustment including the reason for the biling adjustment, in the event the
customer contacts the Company to discuss the adjustment.
Is there any other notifcation that the customer receives?
For complex biling adjustments such as corrections due to crossed meters,
adjustments associated with guarantee requests (which ar a result of a customer-
initiated contact), adjustments greater than $10,000, and adjustments for managed
accounts, the customer is notified of the adjustment diectly, either by phone or by
mai using the Company's biling adjustment letters. These contacts are made
prior to the customer receiving the adjusted bil. The letter sent to the customer
notiing them of a biling adjustment advises the customer of their option of an
interest free payment plan. Upon request of the customer, the Company also
provides the customer a spreadsheet with the detals of the billg adjustment.
What is a guarantee request?
When a customer has made a contact with us concerning a billg inqui or to
investigate a meter problem, the Company is commtted to investigate under its
customer guarantee progra these concerns and to respond within ten workig
days, with a full report of the investigation. When the Company has the results, a
Company representative wil cal and inform the customer. If the Company's
representative was not able to reach the customer via phone, a letter is sent to the
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customer with the results and any necessar biling adjustment.
Ms. Parker recommends that the threshold of $10,000 should be much lower
when it comes to calling a customer if the adjustment amount exceeds
$10,000. Do you support this recommendation?
Because of the categories of biling adjustments that currently receive telephone
calls or letters as outlined above (complex adjustments, customer-initiated
adjustment known as guarantee reviews, adjustments of $10,000, and maaged
accounts), we find the curent process meets the expectations of the majority of
customers. However, the Company is agreeable to changing the threshold for
sending letters for bilng adjustment of $5,000 or more, rather than $10,000 for
customers receiving an adjustment that is not covered in one of the other
categories outlned above. And, the Company wil continue to send spreadsheets
13 to those customers requesting the biling adjustment informtion in that format.
14 Unbiled Usage Due to Leavig Servce Connected
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Ms. Parker states that the Company's policy allowig service to remai
connected between customers doe not save time, mieage or costs and the
Company loses a considerable amount of revenue for electricity that went
unbiled. She states that the presumed net benefit of the policy may be more
myt than fact. Do you agree with Ms. Parker's determiation?
No, the Company believes its curent process is cost-effective.
Pleas explain.
In 2009, there were 12,701 disconnect read orders generated as reflected in
response to Stas Data Request IPUC 129. Of that 12,701 disconnect read
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orders created, there were a total of 7,837 customer-intiated account closures
where a new customer had not aleady taken responsibilty for the usage at a site
at the time account closure was requested. Not all customer-requested
disconnections ultimately result in the need for an order to be generated for the
field to disconnect service. Of the 7,837 accounts closed, there were only 835
instances where field orders to disconnect service were generated for unbiled
usage of 1,000 kWh or greater.
What happens once a field order is generated for a disconnection of service?
A field metering specialist (referred to as a "collectot') is dispatched to the site to
leave a notice of iml?ending disconnection or disconnect service depending upon
the immedate circumstances such as weather and occupancy.
For the 835 instances in 2009 where field orders were generated, how were
these accounts handled?
Of these 835 instances, approximately forty-two percent of the orders resulted in a
customer tang responsibilty for the unbiled usage after receiving a notice of
disconnection or having the service disconnected.
How many field orders to disconnect unbiled usge were completed in 209?
In 2009, the Company completed approximately forty-seven percent of the field
orders disconnecting power to premises without an active customer.
Can you quantify the amount of revenue that was lost as a result of the
remaing sites where unbiled usge was not recovered?
Yes. The unbiled usage for 2009 was 798,319 kWh. Based on an average of
eight cents per kWh, the unbiled revenue would be approximately $63,866.
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1 Q.Please describe the financial impact to the Company if it were to change its
2 process and follow Ms. Parker's recommendation to disconnect electric
3 service between tenants.
4 A.Again, using the same period as a baselie, there were a total of 7,837 customer-
5 initiated account closures where a new customer had not aleady taken
6 responsibilty for the usage at a site. Following Ms. Parker's recommendation,
7 the Company would need to dispatch an employee to disconnect the service.
8 Based on curent activity rates of the personnel needed to disconnect electrc
9 service, the approximate cost for completing the 7,837 requests would be
10 $178,183. Then, when a customer signs for service at the site, the Company
11 would again need to dispatch personnel to connect the service at the site. This
12 would increase the costs to $356,366.
13 Q.How does this compare to the costs incurred by following the current
14 process?
15 A.Assuming all 7,837 customer requests for disconnection (identified above)
16 required a closing read and an opening read, the total approximte operational
17 costs would be $110,621. This is based on a calculation of .16 hours to read the
18 meter at a meter reader's activity rate of $44.11 for each of the 7,837 requests.
19 Q.Doe that account for the unbiled usage?
20 A.No. If you add the unbiled usage to the operational costs, the tota cost for the
21 curent process is approximately $180,621.
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Would al 7,837 requests require a meter reader to obtaia closing or
opening read?
No. If a meter is scheduled to be read within five days of the customer's request,
or if it has been read in the five days prior to the customer's request, the Company
would use the actual meter readig taen and prorate the bil based on a per day
usage to allow for the one to five day addition or reduction in the bilng.
What is the main reason for the difference in costs?
The cost differences are priarly due to the type of personnel required to work
the request and the length of time required to perform the work. A disconnection
and reconnection of service requires a field metering specialist, and in cases
where the site has 3-phase service a joureyman linema is needed. However,
opening and closing meter reads can be performed by a meter reader, which has a
lower activity rate cost. The average time to disconnect or connect a service,
including travel, is 0.42 hours (approxiately 25 minutes), while the average tie
for an opening or closing read taes 0.16 hours (approximately 10 minutes).
Pleas desribe the difference in the work classifcations of meter reader and
collector.
A meter reader's traiing and focus is to accurately read the meters to ensure each
meter is read at regular monthly intervals. In the majority of cases, meter readers
are not electrcally trained to disconnect and connect meters. Many meter readers
wal their routes and they would not have the necessar tools and personal
protetive equipment with them in order to disconnect or connect a meter.
A collector has specific traig and is electrcally trained to remove or
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install a meter to disconnect or connect power. Personal protective equipment
must by worn by anyone disconnecting or connecting a meter. Collectors drve
from site to site and have tools and safety equipment readily available to them.
The collector's work is assigned by priority and is worked/mapped geographically
by the collector each day in order to complete as many orders as possible. The
work performed by the collector includes collection of past due bils, customer-
requested or company initiated disconnection of service, connection of service,
reconnection of service, and posting past due notice or other disconnection. of
service notice.
Has the Company looked at ways to reduce the amount of unbiled usage?
The Company continually looks for ways to reduce unbiled usage. In 2007, the
Company conducted a pilot in six cities with its six-state service terrtory. In
that pilot the Company left door hangers notifying the occupant of the impending
disconnection of service. Durng that pilot forty-eight percent of occupants who
received a notice became customers within thee to four days, and were back-
biled to the date of their occupancy for the previously unbiled service. In
addition to back-biling for the previous unbiled service, past due balances from
old accounts were also being collected. The pilot was determned to be succssful
and the process was updated accordingly and expanded thoughout all of the
Company's service terrtory.
What changes to the Company's processes have been implemente since
2O9?
In early 2010, a change was made to bettr enable the Company to trck the aging
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of the orders tied to unbiled usage. In addition, management diectives and goals
were established to set and work priority orders. While the lost energy use has
been identified as a risk of this process, it is continually being reviewed and
managed.
How would the Company recover the additional costs outlined above?
The Company would need to recover these costs through customer's rates and/or
fees.
Does the Company have other concerns with increaing the number of
service diconnections in between customers?
Yes. First and foremost there are inherent safety risks every time a field metering
specialist disconnects or connects a meter. Also it would require additional
manpower, could cause customer dissatisfaction, and could increase the number
of customer guarantee failures.
Ms. Parker recommends a $20 initiation fee. What is the Company's
position on this?
The Company does not believe adding a $20 initiation fee is appropriate at this
time. The Company believes it is effectively managing the unbiled usage orders,
and is workig to contiue to improve on those statistics. In addition, based on
the figues provided for 2009, a $20 fee would not have recovered the costs
incured by disconnecting between tenants.
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Ms. Parker believes the Company is sendig mixed signals to customers
when it encourages conservation but leaves service connecte when there is
no customer. Pleae address this comment.
The Company does not believe mied signals are sent. In most cases the energy
used between customers is far less expensive than what would be incured to
connect and disconnect the meter. One of the Company's goals is to educate our
customers on varous ways to reduce their electrcal usage and save energy. This
results in a lower bil for our customers and decreases the need to build more
power plants or purchase power on the open market. While the Company does
agree that efforts to reduce costs and strengthen accuracy should always be
explored and implemented as appropriate, the costs of disconnecting the power at
all premises outweigh the benefits.
Ms. Parker also mentioned that the Company has no plan to upgrade
meters to allow for remote reading or remote disconnection and reconnection
of service. Do you agree?
The Company actively researches new technologies and their cost-effectiveness.
At this time, the Company does not believe that upgradig to new technology
meters in its Idaho service terrtory is cost-effective.
Wht recommendations did Mr. Thaden include in his testimony?
Mr. Thaden recommends the Commssion accept the following recommendations:
. Direct Rocky Mounta Power to communicate information regardig the
Idao Moratorium and the Winter Payment Plan though revisions to the
anual Customer Information brochure and by attching bil inserts to
Coughlin, Di-Reb - 19
Rocky Mountan Power
1
2
3
4
5
6
disconnection notices;
.Encourge the Company to increase funding for the Lend-A-Hand
program though changes to the way customers can contrbute;
.Direct Commssion staf to convene a workshop to examne how best to
provide energy conservation education to low income customers; and
.Provide no additional funding for low income energy conservation
7 education at this time.
8 Moratorium and Winter Payment Plan Communications
9 Q.
10
11
12 A.
13
14
15
16
17
18 Q.
19
20 A.
21
22
23
Does the Company accept Mr. Thaden's reommendation to increase
communications related to the Idaho Moratorium and the Winter Payment
Pla by revising the Customer Information brochure?
Yes. The Consumer Informtion brochure distrbuted in residential bils annually
includes a paragraph on the Winter Payment Plan and information related to the
winter moratorium is included under the "Disconnection Notices" section. This
brochure is included as Exhibit No. 76. The Company wil revise the brochure in
an effort to make these two topics more promient. These changes wil be
incorporated in the next version that wil be prited in late 2010.
Doe the Company accept Mr. Thaden's recommendation to attach bil
insert to disconnection notices?
No. The Company's disconnect notice includes a paragraph describing the winter
moratorium. Refer to Exhbit No. 77. The Company wil look into a redesign of
the notice that wil include Winter Payment Plan information. The Company's
preference is to include this adtional informtion prominently on the notice as
Coughlin, Di-Reb - 20
Rocky Mountan Power
1 an alternative to creating and attaching a new bil insert. The Company curently
2 has a new supply of disconnection notices but wil complete a redesign for use in
3 the fall of 2011.
4 Lend-A-Hand program
5 Q.
6
7
8 A.
9
10
11
12
13
14 Q.
15
16
17 A.
18
19
20
21
22
23
What comments do you offer with respect to Mr. Thaden's recommendation
that the Company implement additional ways that customers can contribute
to the Lend-A-Hand progrm?
The Company promotes the benefits of the Lend-A-Hand program and provides
the opportnity for customers to donate regularly. This is accomplished through
thee donation envelope distributions in bils durig the months of November,
Februar and June as well as though the inclusion of program information on the
Company's home webpage, on-line payment webpage, in customer newsletters
and press releases.
Please refer to Mr. Thaden's Exhibit No. 120. Does the Company support
the chages to this envelope as suggested by Mr. Thaden on page 15 of his
testimony?
No, the Company is not supportve of changing the mailing addrss for
contrbutions to the Idaho Lend-A-Hand Program, as the address used goes
diectly to the Company's centr cash remittance operation center where the
donations are processed and funds are forwarded monthly to our parerig
agencies. However, the Company wil change the name on the envelope from
"Lend A Hand" to "Idao Lend-A-Hand" which may make it more evident that
the donations wil be direte entiely to assist households in Idaho.
Coughlin, Di-Reb - 21
Rocky Mountan Power
1 Q.
2
3 A.
4
5
6
7
8
9
10
11
12
13
14
15
16
17 Q.
18
19
20 A.
21
22
What other ways does the Company promote contributions to the Idaho
Lend-A-Hand?
The Company appreciates Mr. Thaden's positive feedback on our marketing of
the Lend-A-Hand program. We also promote the Fixed Donation component that
alows customers to contrbute a designated amount monthly on their bil, though
aricles in the Company's Voices customer newsletter and press releases. The
Company does not have the abilty to include a check box on biling statements
due to the limitations of our customer servce system and remittace processing
machines. However, as an alternative, we wil include the Fixed Donation details
on a tear away flap on payment remittance envelopes durng a monthly bil
distribution in early 2011. Customers interested in parcipating in the Fixed
Donation program wil be able to designate their monthly contrbution amount
and enroll by including the tear away porton, also caled a bangta, in the
envelope with their payment. If ths proves to be an effective means of obtaning
contrbutions, we wil distrbute the bangtail envelopes annually and expand their
use to our other state fuel funds.
What comments do you offer regarding Mr. Thaden's statement on page 10
of his testimony in which he mentions that state fundig is not available in
Idaho?
To obtain additional fundig to help customers pay their energy bils, the
Company believes the answers may be found in the Idaho legislatu rather than
at the utity.
Coughlin, Di- Reb - 22
Rocky Mounta Power
1 Energy Conservation Education
2 Q.
3
4
5 A.
6
7
8
9
10
11 Q.
12
13 A.
14
15
16
17
18
19 Q.
20 A.
21
22
23
Does the Company agree with Mr. Thaden's recommendation regarding a
workshop on providing energy conservation education to low-income
households?
Yes. The Company believes it would be wortwhile for Commssion staf to lead
a workshop with attendees representing electrc and gas utilities as well as staf
from the local agencies that work with limted income households on a daily
basis. It is importnt for gas suppliers to parcipate and provide fundig for this
effort as a large percentage of our residential customers' heating source is natual
gas.
Does the Company support Mr. Thaden's recommendation related to the
funding of low income energy conservation education.
Yes. We appreciate that Mr. Thaden recognizes that Rocky Mountain Power staff
has worked with CAP AI staff in developing a progra plan and goals in an effort
to implement this project. Rocky Mountai Power made a one-time commtment
of $50,000 to fund low income energy conservation education in Februar 2009
though a Stipulation in Case No. PAC-E-08-07. Those funds have yet to be used
by CAP AI for this effort.
What recommendations from Ms. Ottens wi you be addresing?
Ms. Ottens recommends the Commssion accept the following recommendations:
. Rocky Mountain Power should increase fundig of their Low Income
Weatheriation Progr to reflect a per customer level equal to that of
AVISTA; and,
Coughlin, Di-Reb - 23
Rocky Mounta Power
1 .Remove the matching requirement where seventy-five percent of each
2 dollar of funding comes from a non-utility source such as U.S. Deparent
3 of Energy LIHEAP funds.
4 Low Income Weatherization Funding
5 Q.Does the Company support Ms. Ottens recommendation to increase Low
6 Income Weatherization Progrm funding to equal that of A vista?
7 A.No. The Company's funding of the Low Income Weatherization Program
8 (Schedule 21) cannot be diectly compared with other utiities. For example,
9 A vista provides both electric and natul gas service in portions of Idaho, and the
10 Company provides electrc service only. A greater percentage of the Company's
1 1 residential customers use natual gas as a heating source. Since the largest
12 opportnity for energy savings is often related to heating efficiencies, it would be
13 necessar to include funding from the natual gas supplier serving the Company's
14 customers in a funding comparson.
15 Low Income Weatherization Matching Funds
16 Q.What comments does the Company offer with respect to Ms. Ottens
17 recommendation to remove the seventy-five percent fundig match
18 requiement in the Company's Low Income Weatherization Progrm?
19 A.Ms. Ottens misstates the matching requirement in effect though the Company's
20 Low Income Weatheriation Program (Schedule 21) on page 2 of her testimony.
21 Funding from the Company is avaiable to cover seventy-five percent of the cost
22 of the instaation of efficiency measures, and our parerig agencies use just
23 twenty-five percent of fundig from other governent sources to cover their
Coughlin, Di-Reb - 24
Rocky Mountain Power
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17 Q.
18
19 A.
20
21
22
23
costs. The Company believes it is appropriate for our customers to obtain benefits
from these federal funds as they pay taxes that support these programs. This is
accomplished by leveraging a porton, just twenty-five percent of these funds with
those obtained through the surcharge to the Company's customers.
We appreciate Ms. Ottens reference to the program as a cost effective
DSM program. A program evaluation is curently in progress by an external fir.
We anticipate this evaluation that wil include a cost effectiveness analysis wil be
completed in Februar 2011. Order No. 30239 in Case No. PAC-E-06-10
requires Rocky Mountain Power to conduct a study to determne the cost-
effectiveness of its Weatherization Program after March 31, 2009. The Company
initiated the evaluation process in 2010 in order to allow for more completions to
be studied under the current program guidelines which were effective Apri 1,
2007. A year or more of post consumption paricipation data wil be included in
the analysis. The Company believes it is appropriate for pares to review the
results of this evaluation before program changes, including funding revisions are
implemented,
Is it appropriate to make changes to the Low-Income Weatheriation
Program (Schedule 21) at this time?
No. The Company recommends that the program continue to operate under the
curent ta, including approved fundig levels. Program evaluation results can
be reviewed by the Company, staff and interested paries once avaiable. This
inormation wil be useful in determing if there are beneficial changes that could
be fied for the Commssion's consideration.
Coughin, Di-Reb - 25
Rocky Mounta Power
1 Q.
2 A.
Does this conclude your testimony?
Yes.
Coughlin, Di-Reb - 26
Rocky Mountan Power
Case No. PAC-E-I0-07
Exhibit No. 76
Witness: Barbar A. Coughin
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY,. MOUNTAIN POWER
Exhibit Accompanying Rebuttal Testimony of Barbara A. Coughl
Consumer Information Brochure
November 2010
Consumer Information
We think our customers deserve excellent service. But what do we mean by that? Giving you clear, straightforward
answers when you have questions. This brocure was written in cooperation with the Idaho Public Utilties Commission to give
you answers to some common questions about bils, credit, deposits and other parts of your electric service. If you'd like more
information on any ofthe topics we cover here, please call Rocky Mountain Power toll free at 1.888.221.7070 or visit
rockymountainpower.netlregulation. Si desen una copfa en español de este resumen de los derechs y responsabides del consumidOT,
pOT faor lIame aI1.888.225.2611. Su lIamada será gratuiia.
Summary of Idaho utilty consumer's
rights and responsibilties
Rocky Mountain Power has prepared ths summary of your
rights and resonsibilties when you apply for an account with,
or are a current customer of a utility company in Idaho.
Customer responsibilties
. Use services safely and pay for them promptly.
. Contact Rocky Mountain Power when you have a problem with
payment, service, safety, biling or custome service.
. Notify Rocky Mountain Power about biling or other errors.
. Cotact Rocky Mountain Power when you anticipate a
payment problem to try to set up a payment plan.
. Noti Roky Mount Power whe you are moving to
another location.
. Notify Rocky Mountain Powe about stopping serice in your
name or about stopping service altogether.
. Allow safe unobstructed access to your property for mete
reading, tree trimming and other essential Rocky Mountain
Power personnl and equipment.
. Provide notice to Rocky Mountai Power if you are making
any signicant chge that may affect the elecrical character
of your load affeti you or other.
Deposits
If you are a currt customer with a good payment reord or a
new cusmer who has good crt with your previous utilty
company, you wil not need to make a seit depost. If yo
don't meet these requirements, however, you may be asked to
make a secuty deposit. If a depost is reuired, it cannot be
more than two month' worth of the estimate yearly biling at
your sevice address, based on currt rates. If you can't pay all
the required deposit, you can arrnge to pay half of the deposit
when you apply for service and the ret the following month.
Rocky Moutain Power wil pay the curent intt rate set
yearly by th Idah Public Utilities Commission on al deposits
at the time the depost is reur.
Biling
You will receive a bil for electic service ea month, bad on
the numer of kilowatt-hour of elecicity registered on you
electri meter durng the bilin perod. Your bil wil show th
date on which you paymt is due, the applicable rate schedule
and the amount of the bil. You may ask that another person
receve your bills and noti if you are unble to receive or
underta them.
Payment plans
In decing on the reasonablenss of a payment pla the
company wil take into account your abilty to pay, the size of
the unpaid balan, your payment history, and the amount of
time and reasons why the debt is outstanding. There are' four
type of payment plans that may be available to you:
I. Payment arngements - If you pay on part of your tota bilL,
your pa wil be apli toard th oldes poon of your
ouing bala If yo cano pa a bil in fu we may be
able to make sp ar wi you. To dec if we ca
of yo th arts we ta into accnt your abilty to
pay. ho ln yo QM. yor pa hist and the re
wh yo ma no ha be able to pay. You ca make paymet
aren ov th ph or by ma. Your fi payment wil
be due on the net business day after th arrangemts have been
made. ¡fyou miss the first paymet, or the chec you write to
make th payment is not honored by the bank, your service may
be disconete after we make a dilge attempt to contact you
24 hours prior to disconnction of service.
2. Equal Payment Plan - Our Equal Paymen Pln is available
if you'd like to spread out your paymets evenly over a full year.
The plan divides the total cost of electricity used each year into
12 equal monthly payments. Every year your accunt is reiewed
to determin if your usage has changed. Any pric changes wil
automatically be figured in the Equal Payment amount.
3. Equal Time Payment Plan - Our Equal Time Payment Plan
works the same as our Equal Payment Plan. You are allowed to
pay your past due balace with the arrears rolled in to the plan's
monthly payments.
4. Winter payment plan - If you tell us that you are unable
to pay your electic bil in full and you have children, elderly
perso Or persons with medical needs living in your household,
you may qualify for our winter payment plan. This plan reuires
that your bil be paid in full, but allows for a lower monthly
payment from November to March. Your monthly payments
during ths time cannot be less than one-half of the amount you
would pay if you were using our Equal Payment Plan. You can
use any source of funds to make winter payment plan monthly
payments. If you have an outstanding balance under this
plan, you must either pay this balance or make a new payment
arrngeme on or after April 1. If you don't pay your balance
or don't make paymet arragements on or afte ths date, your
serice may be disconnected. You may participate in the winter
payment plan in following years if you have made payments
as arranged and the balance you owe as of Nov. 1 is not more
than $75 or not more th your bil for the previou 30 days,
whichever is greater.
Disconnection notices
Before we discone your service, in most instance, we wi sen
you a wrtt notic male at let seen calear days befre th
disnnect date. However, only a diliget attempt to contact you
wil be made 24 hour prior to disconnecon of serice when you
do not make a fist paymet accin to a payment arrgement,
whe you tender a paymt with a dishonored check; or make
an elic payment with ins fu. At let 24 hours
before the seic is discnnected, we wil attt to contact you
in persn or by phon and reeat th inmatn on th origl
notice If we do not shut off th sevice withi sev da aft th
prpos date, we wil make anothe attept to contact yo and
rend yo that your servic ca be disconected aft 24 hors.Duri Debe, Januar and February, we wil not disect
your seice if th are chdr, elerly perso or pe wit
medicl ne in th hous Rebe to notify us if any of thes
coitions ex, an we wi wor with you to set up a payment
pla Be diconeng yo seice, we will try to reach an
adult in you hoehold or anth peso you have told us to call
in ca yo ca be reahe. If soon in yo hohold is
sey il yo can get an exte of up to 30 days by giving
us a phys's or publc helth off's ceca of medical
em. Also, if sone in your hou us an ir lung,
reato, diysis ma or othe lifesung eqpment,
plee let us kn. We ca dis your sevi at an ti
wihot notig yo if: (a) a si exists that is immetey
danges to life physl safe of propety or to prevet a
viola of heal an safet co; (b) if th IPU, a cort or
ot autze publ agency orer a diecon; or (c) if you
Mountain Power
No. 76 Page 1 of 2
PAC-E-10-Q7
Barbara A. Coughlin
obtained service through fraud or without our permission. If you
cannot pay the total bil, installment payments may be arranged in
the form of a "deferred payment agreement." Ths agreement says that
you wil pay your past due bil in installments and keep your current
bils paid when due. If you keep the conditions of the agreement,
service wil not be discnnected.
Moving
You need to let us know as soon as possible if you plan to move.
It's a good idea to do this yourself and not depend on someone
else to do it for you. We can't close your account or process your
closing bil until you provide us with your move-out date.
":c'
Complaints and disputes
We wil promptly investigate every complaint or dispute we
receive, and we'll report to you on the results. Contact us through
our toll-free phone number at 1.888.221.7070. This number is also
printed on your bilL. If you're not satisfied with the assistance you
received from the first person you talked to at Rocky Mountain
Power, you have the right to request that your problem be handled
by that person's superviSór, and we'll give you the supervisor's
name and how he or she can be reached.
Mercury vapor
lamps
Sodium vapor
lamps
Initial
lumens Watts
7,000 175
20,000 400
5,600 70
9,500 100
16,00 150
27,500 250
50,000 400
16,00 150
27,SOO 25
50,000 400
::',:"
Rocky Mountain Power
Customer Seravice Center
toll free: 1.888.221.7070Consumer organizations
We have lists of consumer organizations that provide assistance
in the various communities we serve. If you would like a list of the p. I.Ç .
organizations in your community, call us toll free at 1.888.221.7070. ri ce n i 0 rm ati 0 n
Schedule I - Standard Service Schedule 7 A . Security Area lighting
Best for residential customers who use most of their power
during the weekdays.
Monthly bil:
Summei' $0.104093 per kilowatt-hour (kwh)
(May.October)Winter $0.080150 per kilowatt.hour (kwh)
(November.April)
Minimum bil:
Single-phase service $10.64 for permanent residences
$14.87 for vacation homes, cabins or
other dwellings not utilized year.round
as the principal place of residence
Three-phase service $31.92 for permanent residenæs
$44.61 for vacation homes, cabins or
other dwellngs not utilized year. round
as the principal place of residence
Seasonal bil: $178.44 minimum for metered house
or cabin useå on a seasonai basis
Schedule 36 - Optional
Time-of-Day Service
Good for residential customers who use most of their power
during off-peak hours.
On.peak hours": Summer - 8 a.m. to 11 p.m, Monday through
Friday, excet holidays. Winter - 7 a.m. to 10 p.m., Monday thugh
Friday, except holidays.
Off-peak hours: All other hours.
Holidays: New Year's Day, President's Day, Memorial Day,
Independence Day, Labor Day, Thanksgiving Day and
Christmas Day.
Monthly bil:
Summer (May-October)
Customer service charge
On-peak energy charge
Off.peak energy charge
Winter (November-April)
Custom servic charge
On.peak energ charge
Off-pek energy charge
$13.63 per customer
$0.1 1397 per kwh
$0.03873 per kwh
$13.63 per customer
$0.0995 per kwh
$0.03547 per kwh
Minimum bil:Customer service charge
$163.56 plu energy charges for
metered hours or cabin use on
a seasonal basis.
Senal bill:
Sodium vapor
flood lamps
Low pressure sodium
vaporlamps
(energy only)
8,000
13,50
22,500
33,000
55
90
135
180
Rate per lap
$26.40
$47.09
$16.77 w/support pole
$13.34 lamp only
$19.20 w /support pole
$15.77 lamp only
$25.29 w/support pole
$22.52 lamp only
$36.37 w/support pole
$32.94 lamp only
$50.84 w /support pole
$45.00 lamp only
$25.29 w / support pole
$22.52 lamp only
$36.37 w/support pole
$32.94 lamp only
$50.84 w / support pole
$45.00 lamp only
$3.60 per lamp
$5.32 per lamp
$7.40 per lamp
$9.01 per lamp
Explanation of terms:
Customer service charge: A fee charged that helps
pay for the costs of providing service.
Kilowatt.hour (kwh): A measure of electrical energy
equal to the amount of energy used by a 100-watt
light bulb for ten hours or one 1,000.watt hair dryer
for one hour.
Customer Service Guarantees
When we say we're going to give you a certan level of
serice we mean it. Our seve Customer Servic
Guarantee coer servic isue suh as retoring and
switchg on power, keeping appointments, reponding
to biling inquiris, relving meter problems and
notfying of planne interptions. If, for soe reason,
we cant live up to a comitmet, well pay you. To find
out mor about our Cumer Service Guarante,
please cal1 toll fre at 1.888.221.7070 or visit
rockymountanpower.net/guarantees.
. Due to th expansion of Daylight Saving Time, the on-peak ti me periods wil begin and end one hour later for the period between the second
Sunday in March and the first Sunday in ApriL, and for the period between the last Sunday in October and the first Sunday in November.
AJI cu are subje to additional charge/creits as set forth in Rocky Montain Power's ",tall tariffs aproed by th Idaho Public UtilitieCoiss incuding Adjusment Schedule 191. .
Ra_.,. In efect Dembe 1009 and are subject to change by commission order.
'l ra tabl do not includ spfic pricing infoatin for Schedules 9, 11, 12, 19, 24 or 3513A sinc relativey few customers are biled this
way. Hower. the scedule are availale by calling toll free at 1.888.22'.7070 or on our Web site .1 rokymounnpoer.netlraes.
lW9tD
Rocky Mountain Power
i;xhibit No. 76 Page 2 of 2
'Case No. PAC-E-10~07
Witness: Barbara A. Coughlin
Case No. PAC-E-1O-07
Exhibit No. 77
Witness: Barbara A. Coughlin
BEFORE THE IDAHO PUBLIC UTIITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhbit Accompanying Rebuttl Testimony of Barbar A. Coughlin
Disconnect Notice
November 2010
Today's date:
Meter #:
Time:
Address:
Ou employee was here today Employee #:
D Your electric service was connected today. Please:
D Check breakers D Check fuses D Other
D We are unable to connect your electrc service.*
D Your electric service was disconnected today* because:
D Past due D No applicant D Hazardous condition
D No acæss D Oter
D Your electrc service wil be disconnected* for non pay:
D Next day D 24 hours D 48 hours
To prevent interniption of your electrcal service your payment
is requid immediately.
D Your electic meter was replaced today.
D In response to your serice call,
D the sece wir ar propely inulated. There is no problem
D we have scheduled a replacement of your electric service.
D your equipment on site is damaged or out of place. It must
be reaire or relace before electic service can be restored.
D the proper inspecton agency (city or county) has not
approved wirg for electric service.
D We were here, and missed you for our scheduled appointment.
D Comments
-Plea cotat us toll free at 1-888-221-7070 (EspañoI1-888-225-2611
so we ca arange to receive payment/restore serce. It is our goal to
turn the power on within 24 hours after all required chages, including
fees and/or deosit, have bee paid.
If you have any problems or questions, please call our 24-hour
customer servce line toll fr at 1-888-221-7070.
Asisteci en ESPA1OL, 1-888-222611/ Lunes - Viemes,
8 a.m. to 7 p.m. MT.
10110CS Id ~ROCKY MOUNTAIN~POR
Rocky Mountain Power
Exhibit No. 77 Page 1 of 2
Case No. PAC-E-10-07
Witness: Barbara A. Coughlin
Today's date:
Meter #:
Address:
Ou employee was here today Employee #:
TIme:
D Your electric service was connected today. Pleae:
D Check breakers D Check fuses D Oter
D We ar unable to connect your elecric servîce.*
D Your electric servce was disconnected today* becase:
D Past due D No applicant D Hazrdous condition
D No access D Other
D Your electric service wil be disconnected* for non pay:
D Next day D 24 hours D 48 hours
To prevent interniption of your electical servce your payment
is required immediately.
D Your electic meter was replaced today.
D In response to your serce call,
D the sece wis ar prerly inated. There is no problem.
D we have scheduled a replacement of your electric service.
D your equipment on site is damaged or out of place. It must
be repaire or replaced before electc serice can be retored.
D the proper inspection agency (city or county) has not
approved wirig for electric servce.
D We wee here, and missed you for our scheduled appointment.
D Comments
-Plee cotact us toll free at 1-888-221-7070 (EspañoI1-888-22-2611)
so we can arrange to receive payment/restore serice. It is our goal to
turn the power on within 24 hours after all required charges, including
fees an/or deosit, hae been paid.
If you have any problems or questions, pleas ca our 24-hour
cutomer serce line toll fr at 1-888-221-7070.
Asistencia en ESPAi'OL, 1-888-22-2611/ Lunes - Viernes,
8 a.m. to 7 p.m. MT.
10/10CS3 Idaho
~ROCKY MOUNTAIN~POER
The following informaton is for residential customers only.
In accrdance with the rues and retions of the Idaho Public
Utilties Commsion, Rocky Mounta Power ca disconec servce
for non-payment durig the witer month of Dec., Jan. and Feb. with
rectons. Customer may qualify for a winter moratorium on
disconnecton of service for non-payment of their account.
Conta Rock Mountan Por toll free at 1.888.221.7070 if you
mee one of the follong qualifcans for the winter moratorium:
A chld 18 years old or younger living with a parent or guardian, an
elderly person thatis 62 years of age or older, or a person whose
physicai heaith or safety would be seriously impaired by
termation of service.
Bil payment assistce may be available
Low-Income Home Energ Assistance Program (LIHAP) and
Lend-A-Hand funds help households with incomes tht ar no
greater than the amounts lited below:
Household size Maximum monthly income
1.............................. .$1,575
2.............................. .$2,059
3.............................. .$2,544
4.............................. .$3,028
5.............................. .$3,513
6 .............................. .$3,997
If you believe you may qualfy, call the agency managig energ
assistance funds in your county and mention you receved a
Rocky Mountain Power notice on your door.
SoutEam Idao Communit Action Agency
Banock Couty, Bear La County, Bingha County, Cariou
Couty Fra Couty Onda Coty and Power County 232-114
Eastem Idaho Community Acton Parnership
Bonnevie County Butte County, Oark County, Fremont County,
Jefferson County, Lem Couty Madison County and Teton County
522-5391 or toll fr at 1-802-413
Assistace is dependent on the availailty of funds.
~.ROCKY MOUNTAIN~POER
Rocky Mountain Power
Exhibit No. 77 Page 2 of 2
Case No. PAC-E-1O-D7
Witness: Barbara A. Coughlin
The following information is for reidential customers only
In accordance with the rules and reguations of the Idaho Public
Utities Commsion, Rocky Mountain Power can diconnct service
for non-payment durg the witer months of Dec., Jan. and Feb. with
rerictons. Customers may qualify for a winter moratorium on
disconnecton of servce for non-paymt of their account.
Conta Rock Mountan Powr toll fr at 1.888.221.7070 ñ you
meet one of the folloing qualifcans for th wintr moratorium:
A child 18 years old or younger living with a paret or guardian, an
elderly person tht is 62 years of age or older, or a person whose
physical health or safety would be seriously impaired by
termtion of service.
Bil payent assistance may be availabe
Low-Income Home Energy Assistace Program (LIHEAP) and
Led-A-Hand fuds help households with incomes that ar no
grater than the amounts listed below:
Household size Maximum monthly income
1.............................. .$1,575
2.............................. .$2,059
3.............................. .$2,54
4.............................. .$3,028
5.............................. .$3,513
6.............................. .$3,997
If you believe you may qualify, call the agency maagig energy
assistance funds in your county and mention you receved a
Rocky Mountain Power notice on your door.
SoutEasem Idaho Communit Acton Agency
Bannock County, Bear Lae County, Bingham County, Carbo
Coty Fran Couty Oneida County and Power County 232-114
Eastern Idaho Communit Acton Partnership
Bonnevile County Butt County, Oark County, Fremont County,
Jefferson County, Lemhi County, Madison County and Teton County
522-5391 or toll fr at 1-800-632-4813
Asisce is dependent on the availabilty of funds.
~ROCKY MOUNTAIN~POR