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HomeMy WebLinkAbout20101014Thaden Di.pdfBEFORE THE ri. F¥vi.=:D 2am OCT 1ft Pr; l: 3 l IDAHO PUBLIC UTILITIES COMNl~~~~eili(!c:,L!t1L ¥ i l.... j iè...V .'..Vrr~¡:'gi IN THE MATTER OF THE APPLICATION OF ) PACIFICORP DBA ROCKY MOUNTAIN ) CASE NO. PAC-E-10-07 POWER FOR APPROVAL OF CHANGES ) TO ITS ELECTRIC SERVCE SCHEDULES ) ) ) ) ) ) DIRECT TESTIMONY OF CURTIS THADEN IDAHO PUBLIC UTILITIES COMMISSION OCTOBER 14, 2010 1 2 for the record. Q.Please state your name and business address 3 A.My name is Curtis Thaden. My business address 4 is 472 West Washington Street, Boise, Idaho. 5 6 Q.By whom are you employed and in what capacity? A.I am employed by the Idaho Public Utilities 7 Commission as a Utili ties Compliance Investigator. I 8 accepted that position with the Consumer Assistance Staff 9 in July 2007. 10 Q.What is your professional and educational 11 background? 12 A.Prior to my employment with the Idaho Public 13 Utilities Commission, I had eighteen years experience 14 working in private industry for Hewlett Packard in a 15 variety of manufacturing positions. I received an 16 Associate of Science Degree in Electronic Engineering 17 Technology from Links School of Business (now known as ITT 18 Technical Institute) in Boise, Idaho, in September of 1983. 19 Additionally, I am a licensed real estate agent in the 21 20 State of Idaho. 22 Commission? Q.Have you previously testified before the 23 24 A.Yes, I have. Q.What is the purpose of your testimony in this 25 proceeding? CASE NO. PAC-E-10-0710/14/10 THADEN, C. (Di) 1 STAFF 1 A.i will be addressing the following: 2 (1) demographics of the 13 Idaho counties in Rocky Mountain 3 Power's (RMP) service territory; (2) factors affecting 4 customers' ability to pay their bills; (3) programs 5 offering financial assistance to RMP's Idaho customers; 6 (4) programs, payment plans and payment arrangements 7 offered by RMP to its customers; (5) energy conservation 8 education for low income customers; and (6) Low-Income 9 Weatherization and other Energy Efficiency Programs. 10 Q.Please summarize your recommendations to the 11 Commission as discussed in your testimony. 12 A.Staff recommends that the Commission: 13 (1) direct Rocky Mountain Power to ensure that the Company 14 more effectively communicates information regarding the 15 Idaho Moratorium and the Winter Payment Plan to its 16 customers by revising its annual Customer Information 17 brochure and providing bill inserts with disconnect 18 notices; 2) encourage the Company to increase funding for 19 the Lend-A-Hand program by making changes to the way 20 customers can contribute; 3) direct Staff to convene a 21 workshop to examine how best to provide energy conservation 22 education to low income customers; and 4) provide no 23 additional funding for low income energy conservation 24 education at this time. 25 CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 2 STAFF 1 Demographics and Factors Affecting Bill Payment 2 Q.Has the Staff prepared a demographic profile 3 of Rocky Mountain Power's service territory in Idaho? 4 A.Yes. Exhibit No. 115 includes both 5 demographics obtained from the most recent Census Bureau 6 data and unemployment data obtained from the Idaho 7 Department of Labor for each of the counties served by 8 Rocky Mountain Power. For comparison, this Exhibit also 9 includes statistics for the State of Idaho and the United 10 States. Exhibit No. 116 shows the 2010 Federal Poverty 11 Level (FPL) Guidelines. For purposes of Staff's analysis, 12 income at or below 100% of poverty was used. A map of the 13 13 counties served by Rocky Mountain Power can be found in 14 Exhibit No. 117. 15 Q.In reviewing the data, what stands out as 16 particularly noteworthy? 17 A.The 13 counties that comprise the area that 18 Rocky Mountain Power serves have the state's lowest average 19 unemployment rate (7.3%) i. Seven counties have poverty 20 rates exceeding the statewide average (12.5%). The low 21 unemployment rate coupled with high .poverty rates suggest 22 that these counties have a large percentage of "working 23 poor", individuals who are employed but unable to meet 24 life's basic needs (food, clothing, shelter...) due to low 25 lThough RMP's region has the lowest average unemployment rate in the state, the region's unemployment has doubled during the past two years. CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 3 STAFF 1 wages, inadequate benefits, and little opportunity of 2 economic advancement . Relatively low paying jobs in these 3 largely rural and agricultural communi ties help explain the 4 situation. 5 Twelve out of the 13 counties within the 6 service territory are below the July 2010 seasonally 7 adjusted state average unemployment rate of 8.8%.2 Five of 8 these 12 counties (Bear Lake, Butte, Franklin, Oneida and 9 Teton) have unemployment rates less than 6.8%, ranking 10 among the lowest unemployment rates in the state. 11 Regarding the region's average poverty rate, 12 seven of the 13 counties exceed the state average of 12.5%. 13 Five counties (Bannock, Butte, Clark, Lemhi, and Madison) 14 have poverty rates in excess of 14 %, ranking them in the 15 state's top twenty counties with the highest poverty rates. 16 Three of these counties (Clark, Lemhi, and Madison) rank in 17 the top ten. Madison County has the highest poverty rate 18 in the state, a staggering 25.1%, although that may be 19 affected by the BYU Idaho student population. The poverty 20 data used in this demographic profile dates back to 2008. 21 Current poverty rates are likely to be much higher due to 22 the sharp rise in unemployment that has occurred in the 23 region and across the state during the last two years. 24 Those who fall below the Federal Poverty Levels are now 25 2 At the time this testimony was written, the most recent unemployment data available was from July 2010. CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 4 STAFF 1 likely to be full-time workers who are unable to earn 2 enough to meet life's basic needs or are middle class wage 3 earners who have either lost their job or had diminished 4 incomes. 3 These individuals face high energy burdens. 4 5 Q. Do the Federal Poverty Level Guidelines 6 reflect an accurate gauge of poverty in the United States 7 and Idaho? 8 A.Not necessarily. The 100% of poverty level is 9 regarded by social service organizations as underestimating 10 what it costs to maintain a basic standard of living. 11 Realizing this, federal and state agencies charged with the 12 responsibility to protect human health and welfare set 13 household income eligibility limits for social service 14 programs at levels that exceed the Federal Poverty 15 Guideline's benchmark of 100% of poverty. 16 As previously stated in my testimony, seven of 17 the 13 counties in Rocky Mountain's service terri tory 18 exceed the state average poverty rate of 12.5%. However, 19 since the Federal Poverty Guideline is regarded as an 20 underestimation, the actual number of those who live in 21 poverty in Rocky Mountain Power's service territory is even 22 greater. 23 24 3 Source: Idaho Statesman (9/17/10), article titled, "Census: 1 in 7 Americans lives in poverty."4 Energy Burden is the percentage of a household's income that is spent on all home energy expenses, which includes all energy used for space heating and cooling, lighting, and water heating. 25 CASE NO. PAC-E-10-0710/14/10 THADEN, C. (Di) 5 STAFF 1 An example of the underestimation of those 2 living in poverty can be seen by comparing the Federal 3 Poverty Level Guideline's (FPL) estimation of Idaho 4 households living in poverty to the state's LIHEAP (Low 5 Income Home Energy Assistance Program) estimation of those 6 living in poverty and eligible for financial assistance. 7 Under the FPL, 54,829 households in Idaho are below 100% of 8 poverty. 5 Under Idaho's LIHEAP Program calculations (which 9 were based upon 150% of poverty), 106,481 households 10 qualify for benefits6. The difference between these two 11 estimates is 51,562 households statewide. 12 Q.What conclusion can be drawn from these 13 demographics? 14 A.Customers who are living in poverty and/or are 15 unemployed have limited or diminished financial resources 16 with which to pay utility bills. Given the ongoing 17 economic turmoil, Staff believes that the Census data, 18 al though somewhat lagging, provides a fairly good picture 19 of RMP' s customers today. In fact, there is reason to 20 believe that customers may be worse off in the future. 21 Staff is concerned that a significant number of RMP's 22 customers will have problems paying their electric bills, 23 24 5 Source: LIHEAP Home Energy Notebook for FY 2007: Appendix B: Income Eligible Household Estimates. Average of 2006, 2007, 2008 State-level estimates for Idaho.6 Source: On the Brink 2009 i The Home Energy Affordability GAP April 2009 ¡published 2010 Fisher, Sheehan & Coltron. 25 CASE NO. PAC-E-10-0710/14/10 THADEN, C. (Di) 6 STAFF 1 especially when faced with increasing rates. 2 Q.What do you see as the greatest threat that 3 could impact the ability of customers to pay their utility 4 bills? 5 A.Unemployment continues to be a great concern. 6 Current Idaho Department of Labor data as of July 2010 7 shows a continued and sustained high unemployment rate, 8 which now stands near the highest levels in 27 years 9 (8.8%). 10 An increase in the unemployment rate can lead 11 to an increase in the percentage of RMP customers who fall 12 below the Federal Poverty Level. As a result, more strain 13 will be placed upon agencies that provide financial 14 assistance for payment of utility bills. The number of 15 disconnections has the potential to increase as people 16 experience difficulty paying their bills. Even people who 17 were high wage earners can find themselves in a tight 18 financial situation following a layoff. Higher 19 unemployment, rising fuel costs and increasing food costs 20 are additional stresses that will have an impact on 21 people's finances. 22 Q.Has the number of Past Due and Final Notices 23 sent to customers increased or decreased? 24 A.The total number of Past Due and Final Notices 25 sent to Idaho residential customers has fluctuated over the CASE NO. PAC-E- 10 - 0710/14/10 THAEN, C. (Di) 7 STAFF 1 past 3 calendar years (2007-2009), with the net result 2 being an overall increase. Past Due notices sent to 3 customers increased by 8.5% and Final Notices sent to 4 customers increased by 11%. In comparison, Past Due 5 notices sent to low income customers (defined here as 6 customers who have received energy assistance benefits 7 within the past 12 months) increased by 49% and Final 8 Notices sent to customers receiving energy assistance 9 increased by 50%. The two tables below reflect the amount 10 of Past Due and Final Notices sent to customers. 11 12 13 14 15 16 Year 2007 2008 2009 Past Due Notices Sent Non Low Income 56,141 61,927 59,961 to Residential CustomersLow Income Total2,427 58,5683,229 65,1563,615 63,576 Year 2007 2008 2009 Final Notices Sent to Non Low Income 46,389 51,501 50,529 Residential CustomersLow Income Total2,069 48,4582,771 54,2723,118 53,647 17 The increase in notifications is indicative of customers 18 struggling to make their payments in a timely manner or to 20 19 even be able to make their payments at all. Q.Has the number of customers who have been 21 disconnected for non-payment increased or decreased? 22 A.The total number of Idaho Rocky Mountain Power 23 residential customers disconnected for non-payment has 24 steadily increased over the past three calendar years 25 (2007-2009) from 2,021 to 2,490. This represents a 23% CASE NO. PAC-E-10-0710/14/10 THADEN, C. (Di) 8 STAFF 1 increase in the number of disconnections. During the same 2 time period, the number of customers receiving energy 3 assistance who were disconnected for non-payment increased 4 from 160 to 245, a 53% increase. Customers who received 5 energy assistance comprise a small percentage of the total 6 number of disconnections in each calendar year. This 7 suggests that disconnection of service due to non-payment 8 is not an issue for low income customers only. The table 9 below reflects the number of customers who were 10 disconnected during the last three years. 11 12 13 Year 2007 2008 2009 Disconnections for Residential Customers Non Low Income Low Income 1,861 (92%) 160 (8%)1,992 (91%) 196 (9%)2,245 (88%) 296 (12%) Total 2,021 2,188 2,490 14 As the economic downturn continues and more customers 15 struggle financially, it is apparent that there is a 16 greater need to provide help for those seeking financial 17 assistance within the community. This also presents an 18 opportuni ty for RMP to address the issue of disconnects due 19 to non-payment. As discussed later in this testimony, RMP 20 has taken a first step to address the issue of disconnects 21 resulting from non-payment. Staff encourages RMP to 22 continue its efforts. 24 23 Programs Offering Financial Assistance Q.What resources are available to help customers 25 pay their energy bills? CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 9 STAFF 1 A.The Low Income Home Energy Assistance Program 2 (LIHEAP) is funded by the federal government through a 3 grant to the State of Idaho. Unlike the situation in other 4 states, state government funding is not available in Idaho 5 to help customers pay energy bills at any time of year. 6 For the 2009/2010 heating season, Staff 7 anticipated a decrease in federal funding for LIHEAP. 8 During the previous heating season (2008/2009), what was 9 thought to be a one-time funding increase to the yearly 10 LIHEAP grant occurred?, allowing for larger benefit amounts 11 to be given to each participant. In addition, eligibility 12 guidelines changed to allow for more households to 13 participate in the LIHEAP program. The level at which a 14 household was eligible to receive assistance changed from a 15 maximum of 150% to 160% of the Federal Poverty Level 16 Guidelines. 17 Instead of returning to the normal historical 18 funding level, federal funding for LIHEAP for the 2009/2010 19 winter heating season remained the same as that of the 20 2008/2009 heating seasons. Due to the ongoing economic 21 downturn in the economy, eligibility guidelines were 22 23 7 An increase in LIHEAP Funding for 2008/2009 heating was authorized on September 30, 2008, by HR 2638, The Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009. As a result, funds available to state of Idaho for the winter heating season increased from $12,376,499 to $29,939,480.8 Funding for the 2009/2010 heating season continued to fund at a record level of $26,939,480 which was authorized on December 19, 2009 by HR 3288, The Consolidated Appropriations Act of 2010. 24 25 CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 10 STAFF 1 changed to be in alignment with the Weatherization 2 Assistance Program eligibility guidelines. The level at 3 which a household is eligible to receive assistance changed 4 from a maximum of 160% of the Federal Poverty Level 5 Guidelines to 60% of the estimated state medium income9. 6 (Estimated state income is close to 175% of the Federal 7 Poverty Guidelines). The higher funding level and change 8 in the eligibility guidelines allowed for more households 9 to participate in the LIHEAP program. 10 At this time, Staff is uncertain whether 11 future LIHEAP funding will increase, decrease or stay at 12 current funding levels. 13 For the 2009/2010 winter heating season, 14 $1,058,386 in LIHEAP funding was distributed to 1,474 Rocky 15 Mountain Power customers in Idaho to help pay home heating 16 bills. The average amount paid to each participant was 17 $598. Both the benefit amount given to each participant 18 and the number of participants were at an all time high. 19 The table below reflects the number of Rocky Mountain Power 20 customers in Idaho who received LIHEAP benefits and the 21 average dollar amount allocated during the last three 22 heating seasons. 23 24 25 9 60% of estimated state medium income: 1 person family $19,985, 2 person family $24,708, 3 person family $30,522, 4 person family $36,366, 5 person family $42,150, 6 person family $47,964. CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 11 STAFF 1 2 3 4 5 LIHEAP Program Year Funding 2007/2008 $374,385 2008/2009 $661,2652009/201010 $1,058,386 Funding Participan ts 1,1781,4741,769 Avg. Benefit $318 $449 $598 6 needs of low income customers. Therefore, Crisis Funding LIHEAP does not sufficiently meet the energy 7 benefits are available to customers whose circumstances 8 qualify them for additional financial assistance under 9 LIHEAP. Money is not always available for Crisis Funding. 10 Even when funds are available, the number of people who can 11 be helped is quite small. For the 2009/2010 winter heating 12 season, $5,643 in Crisis Funding benefits was distributed 13 to 16 Rocky Mountain Power customers in Idaho. The average 14 amount paid to each participating customer in 2009/2010 was 15 $353. 16 Q.Are there other programs in place that can 17 help Idaho customers? 18 A.Yes. In Rocky Mountain Power's service 19 territory, two CAP Agencies-Southeastern Idaho Community 20 Action Agency (SEICA) and Eastern Idaho Community Action 21 Partnership (EICAP) -administer both the LIHEAP and Lend-A- 23 22 Hand Programs. The Lend-A-Hand Program provides financial 24 25 10 First year of new Pilot Proj ect that has allowed customers to apply for LIHEAP benefits throughout the year or until funds run out. Each year the heating season ends on March 31st which is reflected in the LIHEAP Chart above. As of 7/30/10, LIHEAP funding is $1,185,395, the number of participants is 1,960, .and the average benefit amount is $605. CASE NO. PAC-E- 10 - 0710/14/10 THADEN, C. (Di) 12 STAFF 1 assistance to RMP customers who use electric space heat as 2 their primary heat source. To be eligible, recipients must 3 be at or below 150% of the Federal Poverty Level 4 Guidelines. Recipients can receive an annual household 5 benefit of up to $600. All money collected, with the 6 exception of administration costs, goes back to the 7 communi ty . 8 In the past three program years (2007-2009), 9 RMP shareholders donated $97,269 to Lend-A-Hand for Idaho; 10 RMP customers in Idaho donated $22,112 and "other sources" 11 donated $907.11 Of the total amount collected ($120,000), 12 $3,000 was paid to the two CAP agencies for administering 13 the program ($500 each annually). The table below reflects 14 total dollar amounts donated by RMP customers and its 15 shareholders in the past three program years (July 1 - 16 June 30) . 17 18 19 20 Fiscal Year 2007/2008 2008/2009 2009/2010 Lend-A-Hand DonationsCustomer\Other Shareholders $6,413 $33,587$9,283 $30,717$7,035 $32,965 Total Grants $40,000 140 $40,000 173 $40,000 188 Q.What efforts does Rocky Mountain Power put 21 forth to make its customers and the community aware of 22 Lend-A-Hand? 23 24 25 A.Rocky Mountain Power publicizes Lend-A-Hand 11 "Other Sources" consist of employee donations through the Company's annual giving campaign and the associated Pacific Corp Foundation match. Donations: 2007/2008 -$82, 2008/2009-$207, 2009/2010-$618. CASE NO. PAC-E-10-0710/14/10 THADEN, C. (Di) 13 STAFF 1 through its home webpage, on-line payment webpage, customer 2 newsletters, press releases, and monthly customer billings, 3 which include donation envelopes for the months of 4 November, February and June. The program is also part of 5 the Company's annual Employee Giving Campaign. In 6 addition, the Company's call center staff directs customers 7 in need of assistance to SEICA and EICAP. 8 RMP is doing a good job in marketing Lend-A- 9 Hand. Staff encourages the Company to continue promoting 10 the program. Examples of the Company's marketing efforts 11 can be found in Exhibit Nos. 118 and 119. Staff encourages 12 the Company to investigate additional ways to increase the 13 total funding amount, which would also include an increase 14 in shareholder donations, especially in these challenging 15 economic times when more of the Company customers are in 16 greater need of financial assistance and are struggling to 17 pay their utility bills. 18 Q.Does Staff have any suggestions as to how RMP 19 can increase customer donations for the Lend-A-Hand 20 program? 21 A.The donation envelopes that RMP includes with 22 the bills during the months of November, February and June 23 have an Oregon mailing address (Exhibit No. 120). An out 24 of state address might be perceived by Idaho customers as 25 meaning that donations are not necessarily helping Idaho CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 14 STAFF 1 RMP customers, thus potentially decreasing the number of 2 contributions. RMP should consider changing the donation 3 envelope mailing address to an Idaho mailing address. 4 The Company currently provides customers with 5 the option of adding monthly donations in a fixed dollar 6 amount ($1, $2, $5, $10) to each of their electric bills. 7 To do so, the customers must first take the initiative to 8 contact the Company before the next billing cycle to ensure 9 the donation amount is added to the monthly billing 10 statement. To make a one-time donation, the customer has 11 the option of simply increasing their payment amount by a 12 fixed dollar amount when paying their bill. There is a 13 sentence in small print on the billing statement that 14 informs customers of this option. To better bring 15 attention to the opportunity to donate on the monthly 16 billing and to make it easier for customers to make 17 donations, RMP should consider adding a separate Lend-A- 18 Hand section on the monthly billing statement with a 19 donation check off box. A good example of this can be 20 found in Exhibit No. 121. 21 Programs, Payment Plans and Payment Arrangements 22 Q.What utility programs are in place to help 23 customers avoid being disconnected during the winter 24 months? 25 A.Besides LIHEAP and Lend-A-Hand, the Idaho CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 15 STAFF 1 Moratorium and Winter Payment Plan also address this issue. 2 Idaho's Moratorium allows residential 3 customers whose household includes children, elderly or the 4 infirm to be protected from disconnection during the months 5 of December through February if they declare that they are 6 unable to pay their utility bill in full. However, 7 customers are not absolved of paying their utility debt. 8 The Winter Payment Plan allows customers who 9 have declared eligibility for the Moratorium an additional 10 two months of protection (November and March) if they agree 11 to accept and follow through on monthly payments that are 12 equal to half of the normal level pay mount (monthly 13 average of the previous 12 months' billings). 14 A brochure entitled "Consumer Information", 15 wi th information on both the Idaho Moratorium Program and 16 Winter Payment Planì is sent to all residential customers 17 annually. All customers that receive a Final Disconnection 18 Notice during the months of November through February are 19 made aware of the Idaho Moratorium Program via a small 20 printed statement located on the second page of the bill. 21 Staff believes that both the annual brochure and billing 22 statement do not sufficiently focus customers' attention on 23 the critical information being provided. 24 Staff recommends that all residential 25 customers who receive a Final Disconnection Notice during CASE NO. PAC-E-10-0710/14/10 THADEN, C. (Di) 16 STAFF 1 the months of November through February be made aware of 2 the Idaho Moratorium and the Winter Payment Plan through a 3 bill insert with the notice. For those customers who have 4 declared eligibility for the Moratorium, Staff recommends 5 that an insert on the Winter Payment Plan be provided with 6 the December, January and February billings. A good 7 example of a bill insert can be found in Exhibit No. 122. 8 Lastly, concerning the RMP's Consumer Information brochure, 9 the current format contains Idaho Moratorium information in 10 the Disconnection Section. Staff recommends that the 11 Company revise its brochure so that the Idaho Moratorium 12 information is a separate section, similar to the stand 13 alone section for the Winter Payment Plan, thereby 14 decreasing the possibility that this information will be 15 overlooked by customers. 16 Q.Has the number of customers who have declared 17 eligibility for the Moratorium increased or decreased? 18 A.The number of RMP customers in Idaho who 19 declared eligibility for the Moratorium during the 20 2009/2010 winter heating season totaled 929. This 21 represents an 11% increase in comparison to the previous 22 winter heating season (2008/2009) and a 63% increase in 23 comparison to the 2007/2008 winter heating season. The 24 increase in the number of those requesting winter 25 protection could be attributed to more people struggling CASE NO. PAC-E-10-0710/14/10 THADEN, C. (Di) 17 STAFF 1 financially, as was previously discussed in this testimony. 2 Staff anticipates that the number of 3 individuals who declare eligibility for the Moratorium will 4 increase next winter heating season if LIHEAP funding 5 levels are reduced or economic conditions do not improve. 6 Exhibit No. 123 reflects the total number of Moratorium 7 participants in the past three winter heating seasons. 8 Q.Has the number of customers participating in 9 the Winter Payment Plan increased or decreased? 10 A.Of the 929 participants who declared 11 eligibility for the Moratorium in the 2009/2010 winter 12 heating season, only 9% elected to be placed on the Winter 13 Payment Plan. This is significantly lower than the 14 previous winter heating season when 20% of Moratorium 15 participants had a Winter Payment Plan. The number of 16 participants in the Winter Payment Plan over the past three 17 winter heating seasons has averaged only 14 %. The most 18 recent decrease in participation could be attributed to 19 more participants receiving LIHEAP benefits and larger 20 grants, customer inability to make a payment, or a lack of 21 effort by the Company to promote and get customers signed 22 up on the Winter Payment Plan when a customer declares the 23 need for winter protection. Exhibit No. 123 reflects the 24 total number of plan participants and the percentage of 25 customers who signed up for the plan after declaring CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 18 STAFF 1 eligibili ty for the Moratorium in the past three winter 2 heating seasons. 3 Q.Have customers on the Winter Payment Plan been 4 able to successfully pay down their outstanding account 5 balances before the end of the winter protection period on 6 March 31? 7 A.Of the 81 participants who elected to be 8 placed on the Winter Payment Plan during the 2009/2010 9 winter heating season, 100% were not able to meet their 10 monthly payment. In the previous winter heating season, of 11 the 167 participants who elected to be placed on the Winter 12 Payment Plan, 100% were unable to meet their monthly 13 payment. Such high default percentages cause concern about 14 the effectiveness and success of the Winter Payment Plan. 15 Q.Have the number of residential payment 16 arrangement agreements and defaulted payment arrangements 1 7 increased? 18 A.Yes. Although the number of Idaho RMP 19 residential customers increased by over 10% over the past 20 three calendar years (2006-2009), the number of payment 21 arrangements agreements and defaulted payment arrangements 22 increased by much higher percentages. The number of 23 payment arrangement agreements increased by 31% and the 24 number of defaulted payment arrangements increased by 44%. 25 A customer can have more than one payment CASE NO. PAC-E-10-0710/14/10 THADEN, C. (Di) 19 STAFF 1 arrangement in a given month for an account and customers 2 can have more than one account. Because of this, the 3 number of payment arrangement agreements and payment 4 arrangement defaults do not correlate to the actual number 5 of customers. The table below reflects the number of 6 customers, payment arrangements, and payment arrangement 7 defaults. 8 9 Year 2007 2008 2009 Arrangemen ts 6,1317,999 8,032 Defaults 4,6056,2986,650 Percentage of Defaults 75% 79% 83% 10 11 Q.What can be done to help reduce the number of 12 customers who default on their payment arrangement 13 agreements? 14 A.At this time, Staff is not sure why customers 15 are not meeting the terms of payment arrangements. It may 16 be that a more diligent effort by RMP to provide monthly 17 customer reminder calls would be beneficial, allowing the 18 Company to assess each customer's situation and reinforce 19 to each customer the importance of making the agreed upon 20 payment. However, it may be that customers do not have the 21 money to make payments and have found that agreeing to a 22 payment arrangement is simply a way to delay a pending 23 disconnection. Whether customers are doing so because they 24 feel they have no choice but to agree to terms suggested by 25 the Company, are using payment arrangements as a means to CASE NO. PAC-E- 10 - 0710/14/10 THAEN, C. (Di) 20 STAFF 1 defer disconnection, or some other reason, more study is 2 required to determine why so many arrangements result in 3 defaul t. During the last three years, the percentage of 4 payment arrangement defaults has remained relatively high, 5 ranging between 75% and 83%. Unless an effort is put forth 6 by the Company to address the reason as to why so many 7 payment arrangements end in default, the number will remain 8 high. 9 Q.What payment options are in place to assist 10 customers who have fallen behind on their monthly payments 11 and are struggling to pay down their arrearages? 12 A.In addition to the Winter Payment Plan, RMP 13 offers the Time Payment Program and the Equal Time Payment 14 Program to customers with arrearages. Both payment plans 15 allow customers up to 12 months to payoff a past due 16 balance. The Time Payment Plan, which is used most often, 17 allows customers the flexibility to pay a past due balance 18 over a 12-month period in addition to their current monthly 19 bills which are based on actual usage. This option differs 20 from the Equal Time Payment Program in that monthly bills 21 are based on arrearage and estimated annual usage with the 22 monthly payment being the same amount each month. Just as 23 with the Time Payment Plan Program, the Equal Time Payment 24 Program allows customers the flexibility to pay a past due 25 balance over a 12 -month period. CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 21 STAFF 1 RMP has shown great flexibility in allowing 2 its customers to take up to twelve months to payoff 3 arrearages. For example, of the 5, 314 accounts that were 4 signed up for the Time Payment Program in 2009, 73% (3,894) 5 had arrangements greater than six months. Exhibit No. 123 6 shows the number and percentage of accounts on the Time 7 Payment Program with payment arrangements under six months 8 and at six months or greater. 9 Staff believes that by providing customers 10 with greater flexibility, especially in these challenging 11 economic times, customers who are financially stressed are 12 benefited by being offered a better opportunity to payoff 13 past due balances. As previously stated, more study by RMP 14 is required to determine why so many arrangements result in 15 default. A brief summary of each payment plan offered by 16 RMP can also be found in Exhibit No. 124. 17 Q.What new effort has Rocky Mountain Power taken 18 to educate its customers about the available programs 19 intended to help both lower and pay energy bills? 20 A.In 2009, due to the ongoing recession, RMP 21 stepped up its educational efforts to assist customers. 22 The Company focused on 3 key areas: 1) bill reduction; 23 2) bill management; and 3) financial assistance. 24 The Company's website as well as customer 25 service representatives provide customers with additional CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 22 STAFF 1 energy efficiency tips to help reduce usage, explanations 2 of payment plan options, financial assistance information, 3 and referrals to local agencies. 4 The Company also further publicized its Gift 5 Giving Program by providing information more frequently in 6 the Company's newsletters and monthly bills. The program 7 allows an individual to donate by making a payment on 8 another customer's RMP account. Exhibit No. 125 contains a 9 copy of RMP's "Voices" newsletter that contains a brief 10 summary detailing the program. 11 In February 2009 and February 2010, RMP 12 President Rich Walje wrote a letter to the Editor, which 13 was published by the Post Register in Idaho Falls, Idaho, 14 to encourage customers to contact the Company at the first 15 sign that the customer was having difficulty in paying 16 their bills. Both letters outlined the Company's concern 17 and effort in providing assistance to its customers during 18 the economic downturn. The letters were also sent to local 19 television and radio stations in Idaho. A copy of the 20 February 2010 letter to the Editor can be found in 21 Exhibit No. 126. 22 Q.What other steps has the Company taken to 23 further assist its customers? 24 A.In an effort to help prevent customers from 25 being disconnected, RMP modified its disconnect CASE NO. PAC-E-10-07 10/14/10 THAEN, C. (Di) 23 STAFF 1 notification process. In addition to the required process 2 that a utility must follow prior to disconnecting a 3 customer12, RMP added 2 additional notification steps to 4 the process. An outbound call is made to the customer 96 5 hours prior to the disconnect date and a 48-hour notice is 6 hand-delivered to the customer's residence. 7 Energy Conservation Education 8 Q.What is the status of the Energy Conservation 9 Education program that was approved by Commission Order 10 No. 30783 in RMP's previous rate case (PAC-E-08-01)? 11 A.As part of the rate case settlement 12 (PAC-E-08-01), RMP agreed to support an Energy Conservation 13 Education program in Idaho by providing $50,000 in annual 14 funding through its DSM tariff rider to SEICA and EICAP. 15 As of October 1, 2010, the program has not yet been 16 implemented. 17 The purpose of the program is to provide 18 conservation education to LIHEAP participants who have not 19 yet received weatherization services. Though RMP is not 20 responsible for the implementation of the program, the 21 Company has attempted to work with Community Action 22 Partnership of Idaho (CAPAI) in developing the program 23 24 12 Rule 309 states that an initial written notice must be mailed to a customer 7 days prior to disconnection and a final notice must be mailed 3 day's before the proposed date of termination. 24 hours before the proposed date of termination, the utility shall attempt to contact the customer either in person for by phone. 25 CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 24 STAFF 1 design, goals, and evaluation criteria. According to RMP, 2 SEICA and EICAP were participating in the development and 3 implementation of both energy conservation education and 4 energy conservation kit distribution for Idaho Power 5 customers, and CAPAI wanted to ensure that the 2 CAP 6 agencies were not overwhelmed by instituting two separate 7 programs. For that reason, CAPAI decided to delay 8 implementation for RMP customers. 9 Staff is concerned that CAPAI, SEICA and EICAP 10 are looking at energy conservation education for RMP and 11 Idaho Power customers as two different and distinct 12 programs. Approaching the program as two separate programs 13 rather than one has the potential to increase the overall 14 cost while reducing the effectiveness of the program. This 15 situation raises the question of whether low income energy 16 conservation education should be provided on a localized 17 utility by utility, CAP by CAP basis. Staff recommends 18 that the Commission direct Staff to hold a workshop with 19 utilities and other interested parties to determine how 20 best to provide energy conservation education targeted to 21 low income customers throughout the state. 22 Q.Of the $50,000 in Energy Conservation 23 Education Funding that was allocated in 2009 and again in 24 2010, how much money has been utilized for the program? 25 A.To date, RMP has been billed for and paid CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 25 STAFF 1 $7,500 to be used for the purchase of 500 energy 2 conservation kits that will be distributed by the two 3 agencies to qualifying RMP customers at some future date. 4 Staff is concerned that the money that has 5 been allocated for Energy Conservation Education for 2009 6 and 2010 ($100,000 total) has not been utilized in a timely 7 manner. Staff recommends that while the annual funding 8 amount should be maintained at its current level of 9 $50,000, the funding level should not be increased at this 10 time. Furthermore, Staff recommends that RMP include this 11 funding amount in its budget but that no further 12 expenditures be made until a workshop is held and a 13 decision made on how to best provide energy conservation 14 education statewide. 15 Low Income Weatherization and Energy Efficiency 16 Q.What other RMP programs are available to 17 assist low income customers? 18 A.Energy efficiency programs can make bills more 19 affordable by decreasing usage, thereby lowering energy 20 costs. The Low Income Weatherization Program offers 21 financial assistance to qualifying low income customers 22 with both natural gas and electrically-heated homes for 23 weatherization of their homes. A household whose income is 24 60% of the estimated state medium income or less qualifies 25 to receive weatherization services. This program is CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 26 STAFF 1 administered by SEICA and EICAP in RMP's service territory. 2 In Case No. PAC-E- 05 - 01, the Commission approved annual 3 funding for low income weatherization of $150,000. Funding 4 for the low income weatherization program comes from the 5 Company's existing DSM tariff rider (Schedule 21). The 6 total number of dwellings weatherized in Idaho from 2007- 7 2009 was 257; the amount billed by the CAP agencies totaled 8 $434,06113. This amount includes CAP administration costs 9 but does not include RMP' s administrative costs. A 10 breakdown of the totals for each of the three years can be 11 found in Exhibit No. 127. 12 Funding for the Federal Weatherization 13 Assistance Program (WAP) that came from the American 14 Recovery and Reinvestment Act (ARRA) will be expiring on 15 March 31, 2011. Although Staff anticipates a return to 16 normal funding levels for WAP after ARRA funds are 17 exhausted, the enhanced service delivery capacity that was 18 made possible by ARRA will enable CAPs throughout the state 19 to readily expand their utility-funded weatherization 20 programs if additional funds are made available. 21 RMP offers its Idaho customers additional 22 energy efficiency programs that are available to households 23 of all income levels. Such programs include: 1) Home 24 25 13The CAP agencies are allowed to bill RMP up to $150,000 for each program year which runs from April 1 through March 31. On a calendar year basis, the payments may be greater than the $150,000. CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 27 STAFF 1 Energy Savings; 2) Refrigerator/Freezer Recycling; 3) Idaho 2 Time-of-Day Metering; and 4) On-line and Mail-in Energy 3 Analysis. More detailed summaries of the programs can be 4 found in Exhibit No. 128. 5 Q.Does Rocky Mountain Power adequately address 7 6 the needs of its customers through its various programs? A.Although there is always more that can be 8 done, RMP's programs do help customers in a variety of 9 different ways. 10 Q.Will an increase in Rocky Mountain Power's 12 11 rates affect customers' ability to pay their bills? A.Yes. There are many factors affecting 13 customers' ability to pay, and a rate increase will add to 14 the financial difficulties faced by customers. The Company 15 will need to continue to be flexible in making payment 16 arrangements. It will need to work with the customers to 17 ensure that payments can be made based upon schedules that 18 fit the customers' individual circumstances and needs. 19 Staff recommends that the Company be 20 encouraged to look for new and creative ways to increase 21 energy efficiency and provide assistance to customers, 22 particularly those customers who are economically 23 disadvantaged. 24 25 Q.Does this conclude your testimony? A.Yes, it does. CASE NO. PAC-E-10-0710/14/10 THAEN, C. (Di) 28 STAFF ..-.!!rtõii:Q)'*'*'*'*'*'*'**'*'*'*'*'*'*'*'~*'i:Q)E S rt r-1.0'rr C!-..-I'-.LI O'1.,.oq M 0'w ~0 m ,.ó ,.i 0 :c 1.rr ,.I.LI ,.rr OÓ rr N cñ I'cñi:.-rr .-.-.-0 0- Z LI .. Q)::II0..*'*'*'*'*'*'*'*'*'*'*''**'~*''**'II ;:-rr ~0 1.LI .-Lf 0'rr I'.-rr ,.Q 00i:+Q)Ó .-Ó I.i..-N OÓ I',.ii I'N N0LI1.rr i.LI aiII1..-.-.-.-.-.-.-.-.-.-.--......-.. Q)ci .. 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RMP Servce Area (13 Counties) ._IW ~ Counties Served (1I:¡¡ì:~':I): Bannock, Bear Lake, Bingham, Bonnevile, Butte, Caribou, Clark, Franklin, Freemont, Lemhi, Madison, Oneida, Teton. Exhibit No. 117 Case No. PAC-E-10-7 Thaden, C., Staff 10/14/10 Take charge of your energy use Looking to cut your energy use to save money and help the environment? Here ar some easy thngs to do. Lighting With shorter days ahead, it wil pay to switch to compact fluorescent light bulbs. They use one-quarer the amount of electcity as incandescent bulbs. Also, turn off lights in empty rooms and use task lightig at a desk or workbench. Watet- heating Water heating uses a significant amount of energ in the home. Water heaters typicaly last about 10 to 15 years, so consider replaàng older, inefficient unts. Set the water heater temperature to 120"F to save energy. Take showers instead of baths. The average bath uses hvice as much hot water as a five-minute shower. Appiiances Set the temperature of your refrgerator between 37" and 40"F and your freezer at oaF for efficiency and food safety. Wash only £Ullioads in the dishwasher on the shortest wash cycle. Use the micrwave when possible rather than the oven. Wash clothes in warm or cold water and rise them in cold water. Clean the dryer lint filter after each use. Tur off computers, printers, DVD players and other electronics when not in use. Our Web site at rockymountain power. net/save has more tips on saving energy and information on cash incentives to mae your home more energy effcient. Or just call us toll fre at 1-888-221-7070. Lend a helping hand to neighbors Life's cicumstances can sometimes play havoc with the famly budget and create financial hardships. That's why we partner with nonprofit energy assistace programs, such as Lend A Hand, to help those facing economic emergencies pay their electric bils. Our customers, shareholders and employees donate to Lend A Hand throughout the year. It's simple to provide year-round help to those less fortunate by adding a monthly donation to your electric bil. When you pay your bil, you'll be helping your neighbors too. Just tell us the amount you want to contrbute monthly ($1, $2, $5 or $10) and it wil be added to your bil. Your donation wil be forwared to the Lend A Hand local agency nearst you (Eastern Idaho Communty Acton Partership in Idaho Falls or SouthEastern Idaho Community Acton Agency in Pocatello), which determines eligibilty and allocates funds to those needing help. To enroll in the fied donation program, call us toll free at 1-888-221-7070 and tell us the amount you want added to your bil each month. We also have information on programs and tips to help you cut your energy use on our Web site at rockymountanpower.net/save. Or call us toll fr at 1-888-221-7070. r-io-~~~ 'S_UU'~Ò ~ Uz 0 ~o .':Z i:-.. (1 "'. _ (1 "" -...rnro-~ ro.. "' U4 U ¡. 8 - " ' ( J m O: : ~ ~ -~ v . : : :¡ 0 . ( l c ; ;: g Z : : , : O~ ? 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Exhibit No. 120 Case No. PAC-E-10-7 Thaden, C., Staff 10/14/10 ;:IIW-. POR.. An IDACORP company Questions? Contact us at: PO BOX 70. Bois. ID 83707. Or call (208 38 (Treasure Valley). Se habla esñol. For faster serve please call Tueday - Friday, 7:30 a.m. to 6:30 p.m. Customer Name: Account Number: Biling Date: Print Date: i . 09128/2010 09128/2010 .Page 2 of 2 ww.idahopower.com Serv.ice Agrement No:?Next Read Date:10/26/2010 Service Location: Meter Service Period Number Readin Meter Readings Mer kWh. .. Number From To of Days Type Preous Current Const Used'.' .5ò2Áno3051 081251Q I 09124/10 30 Regular 4701 I 5014 1 313 . -.., ."~. , I BLC o BOling J( 6 . Residential ."Rate; Schedüie..101' . 08/25/2010 . 09/24/2010 30 days Service Charge ................................................................................... Non-Summer Energy Charge 0-800 kWh ~ $0..065262 per kWh; 24 days Summer Energy Charge 0-800 kWh ~ $0.069899 per kWh, 6 days .... ..... . ....'~PÇA~ $O:003U4per kWh......:.................:,........ .........,...................... i=i;~Ch i~ i=e~ 1'0/0' " . . .. . .:.;. . . .. :'" . : :" .:,~;.~,; :~~;;:i:~ :". .; ... . ~ .. . . . ... . .. ..... . . . . . : .~. .. . . . .,. Energy: Eff~iencySerVices . ..;....:. ,.::.,,: :;0: :'. ;.: ~~ ;; . ,',C ....., .. .....,;.; ."... . . .., ;...... . . ''Ç.urrl1t Charges,. Electric SerVice $4.00 $16.34 $4.38 $O,fl7 . . SO,2f), , , $1;55 . $2i~50' BLC': BàsicLoadCape. ....;':''-:- ':'_,". ~IDA..PO.If writing information below, please check the appropriate box on the reverse side.Account Number:I I An lD Company NEW CONTACT INfORMATION: Does Idaho Power have your correct mailng address and phone number? If not please write any changes. below: PROJECT SHAR.E PLEDGE Please add the amount indicated to my monthly biil. . ..,.-:,': $2~~,. '"'; $5 ::.: ;:~~$10 Name "''-.:. "'" Street Apt./Suite :-.' '~",I would li!(8 to make a one-time comribution in the amount of: S.:;..~::: City State Zip Code Teiephone Number : ~ '::. Please round-up my monthly bill amount to the nearest dollar and contribute the difference to Project Share. .:-; . '.:~, 1PCO1 ppr wc ii:rnn: RT nnnn1 ~M I nMA1R.a7 Than!. 1JDU and ~ieasß ,ememher to ira;:!: 'four tax-¡Jefiuetilile donations. ExhihitNo. 121 Case No. PAC-E-10-7 Thaden, C., Staff 10/14/10 E.mail Address IPCP ~~ ~ ' V ' S T A . Wi n t e r P a y m e n t P l a n Mo r a t o r i u m I n f o r m a t i o n If y o u a r e u n a b l e t o p a y y o u r b i l i n f u l l a n d h a v e c h i l d r e n , eld e r l y o r i n f i r m i n t h e h o u s e h o l d , y o u m a y q u a l i f y f o r pr o t e c t i o n f r o m d i s c o n n e c t i o n o f s e r v i c e w i t h t h e W i n t e r Pa y m e n t P l a n o r M o r a t o r i u m d u r i n g t h e w i n t e r m o n t h s . Wi n t e r P a y m e n t P l a n Th e W i n t e r P a y m e n t P l a n o f f e r s a m o n t h l y p a y m e n t a r r a n g e . me n t e q u a l t o o n e . ha l f o f y o u r l e v e l p a y a m o u n t d u r i n g t h e mo n t h s o f N o v e m b e r , D e c e m b e r , J a n u a r y , F e b r u a r y a n d Ma r c h . T h e l e v e l p a y a m o u n t i s b a s e d o n t h e a v e r a g e m o n t h l y bi l i n g + 1 / 1 2 o f y o u r a c c o u n t b a l a n c e . Y o u m u s t m a k e yo u r m o n t h l y p a y m e n t e a c h m o n t h a n d b y A p r i l 1 y o u m u s t eit h e r p a y y o u r a c c o u n t b a l a n c e o r n e g o t i a t e a n e w p a y m e n t ar r a n g e m e n t . Wi n t e r M o r a t o r i u m Th e W i n t e r M o r a t o r i u m w i l p r o v i d e p r o t e c t i o n f r o m d i s c o n n e c . ti o n d u r i n g t h e m o n t h s o f D e c e m b e r , J a n u a r y a n d F e b r u a r y . Du r i n g t h i s t i m e , a n y p a y m e n t t o w a r d y o u r u t i l i t y b i l w i l h e l p re d u c e t h e b a l a n c e d u e b y M a r c h 1 . W e e n c o u r a g e y o u t o co n t i n u e t o m a k e r e g u l a r m o n t h l y p a y m e n t s . Ot h e r P a y m e n t A r r a n g e m e n t s We c o n t i n u e t o o f f e r a v a r i e t y o f o t h e r t y p e s o f a r r a n g e m e n t s to h e l p y o u p a y y o u r u t i l i t y b i l . Fi n a n c i a l A s s i s t a n c e Yo u m a y a l s o b e e l i g i b l e f o r a s s i s t a n c e p a y i n g y o u r u t i l i t y bi l f r o m a l o c a l a g e n c y i n y o u r a r e a . V i s i t a v i s t a u t i l t i e s . c o m to f i n d a g e n c i e s i n y o u r a r e a ( k e y w o r d s e a r c h : a s s i s t a n c e ag e n c i e s ) . Fo r m o r e i n f o r m a t i o n , p l e a s e c a l l 1. 8 0 0 . 2 2 7 . 9 1 8 7 o r v i s i t av i s t a u t i l i t i e s . c o m . Ex h i b i t N o . 1 2 2 Ca s e N o . P A C - E - 1 O - 7 Th a d e n , C . , S t a f f 10 / 1 4 / 1 0 P a g e 1 o f 2 AV A 2 8 1 - 2 4 0 0 0 ~~ ~ ' V ' S T A . Wi n t e r P a y m e n t P l a n Mo r a t o r i u m I n f o r m a t i o n If y o u a r e u n a b l e t o p a y y o u r b i l i n f u l l a n d h a v e c h i l d r e n , el d e r l y o r i n f i r m i n t h e h o u s e h o l d , y o u m a y q u a l i f y f o r pr o t e c t i o n f r o m d i s c o n n e c t i o n o f s e r v i c e w i t h t h e W i n t e r Pa y m e n t P l a n o r M o r a t o r i u m d u r i n g t h e w i n t e r m o n t h s . Wi n t e r P a y m e n t P l a n Th e W i n t e r P a y m e n t P l a n o f f e r s a m o n t h l y p a y m e n t a r r a n g e . me n t e q u a l t o o n e . ha l f o f y o u r l e v e l p a y a m o u n t d u r i n g t h e mo n t h s o f N o v e m b e r , D e c e m b e r , J a n u a r y , F e b r u a r y a n d Ma r c h . T h e l e v e l p a y a m o u n t i s b a s e d o n t h e a v e r a g e m o n t h l y bi l l n g + 1 / 1 2 o f y o u r a c c o u n t b a l a n c e . Y o u m u s t m a k e yo u r m o n t h l y p a y m e n t e a c h m o n t h a n d b y A p r i l 1 y o u m u s t ei t h e r p a y y o u r a c c o u n t b a l a n c e o r n e g o t i a t e a n e w p a y m e n t ar r a n g e m e n t . Wi n t e r M o r a t o r i u m Th e W i n t e r M o r a t o r i u m w i l p r o v i d e p r o t e c t i o n f r o m d i s c o n n e c . ti o n d u r i n g t h e m o n t h s o f D e c e m b e r , J a n u a r y a n d F e b r u a r y . Du r i n g t h i s t i m e , a n y p a y m e n t t o w a r d y o u r u t i l i t y b i l w i l h e l p re d u c e t h e b a l a n c e d u e b y M a r c h 1 . W e e n c o u r a g e y o u t o co n t i n u e t o m a k e r e g u l a r m o n t h l y p a y m e n t s . Ot h e r P a y m e n t A r r a n g e m e n t s We c o n t i n u e t o o f f e r a v a r i e t y o f o t h e r t y p e s o f a r r a n g e m e n t s to h e l p y o u p a y y o u r u t i l i t y b i l L . Fi n a n c i a l A s s i s t a n c e Yo u m a y a l s o b e e l i g i b l e f o r a s s i s t a n c e p a y i n g y o u r u t i l i t y bi l f r o m a l o c a l a g e n c y i n y o u r a r e a . V i s i t a v i s t a u t i l i t i e s . c o m to f i n d a g e n c i e s i n y o u r a r e a ( k e y w o r d s e a r c h : a s s i s t a n c e ag e n c i e s ) . Fo r m o r e i n f o r m a t i o n , p l e a s e c a l l 1. 8 0 0 . 2 2 7 . 9 1 8 7 o r v i s i t av i s t a u t i l i t i e s . c o m . AV A 2 8 1 - 2 4 0 0 0 ~~ ~ ' V ' S T A . Wi n t e r P a y m e n t P l a n Mo r a t o r i u m I n f o r m a t i o n If y o u a r e u n a b l e t o p a y y o u r b i l i n f u l l a n d h a v e c h i l d r e n , el d e r l y o r i n f i r m i n t h e h o u s e h o l d , y o u m a y q u a l i f y f o r pr o t e c t i o n f r o m d i s c o n n e c t i o n o f s e r v i c e w i t h t h e W i n t e r Pa y m e n t P l a n o r M o r a t o r i u m d u r i n g t h e w i n t e r m o n t h s . Wi n t e r P a y m e n t P l a n Th e W i n t e r P a y m e n t P l a n o f f e r s a m o n t h l y p a y m e n t a r r a n g e . me n t e q u a l t o o n e . h a l f o f y o u r l e v e l p a y a m o u n t d u r i n g t h e mo n t h s o f N o v e m b e r , D e c e m b e r , J a n u a r y , F e b r u a r y a n d Ma r c h . T h e l e v e l p a y a m o u n t i s b a s e d o n t h e a v e r a g e m o n t h l y bi l i n g + 1 / 1 2 o f y o u r a c c o u n t b a l a n c e . Y o u m u s t m a k e yo u r m o n t h l y p a y m e n t e a c h m o n t h a n d b y A p r i l 1 y o u m u s t ei t h e r p a y y o u r a c c o u n t b a l a n c e o r n e g o t i a t e a n e w p a y m e n t ar r a n g e m e n t . Wi n t e r M o r a t o r i u m Th e W i n t e r M o r a t o r i u m w i l p r o v i d e p r o t e c t i o n f r o m d i s c o n n e c . ti o n d u r i n g t h e m o n t h s o f D e c e m b e r , J a n u a r y a n d F e b r u a r y . Du r i n g t h i s t i m e , a n y p a y m e n t t o w a r d y o u r u t i l i t y b i l w i l h e l p re d u c e t h e b a l a n c e d u e b y M a r c h 1 . W e e n c o u r a g e y o u t o co n t i n u e t o m a k e r e g u l a r m o n t h l y p a y m e n t s . Ot h e r P a y m e n t A r r a n g e m e n t s We c o n t i n u e t o o f f e r a v a r i e t y o f o t h e r t y p e s o f a r r a n g e m e n t s to h e l p y o u p a y y o u r u t i l i t y b i l . Fi n a n c i a l A s s i s t a n c e Yo u m a y a l s o b e e l i g i b l e f o r a s s i s t a n c e p a y i n g y o u r u t i l i t y bil f r o m a l o c . a l a g e n c y i n y o u r a r e a . V i s i t a v i s t a u t i l i t i e s . c o m to f i n d a g e n c i e s i n y o u r a r e a ( k e y w o r d s e a r c h : a s s i s t a n c e ag e n c i e s ) . Fo r m o r e i n f o r m a t i o n , p l e a s e c a l l 1. 8 0 0 . 2 2 7 . 9 1 8 7 o r v i s i t av i s t a u t i l i t i e s . c o m . AV A 2 8 1 . 2 4 0 0 0 Fi n a n c i a l A s s i s t a n c e Yo u m a y b e e l i g i b l e f o r a s s i s t a n c e p a y i n g y o u r u t i l i t y bil l f r o m y o u r l o c a l C o m m u n i t y A c t i o n P a r t n e r s h i p o f . fi c e . T o f i n d o u t i f y o u r h o u s e h o l d q u a l i f i e s f o r e n e r g y as s i s t a n c e , p l e a s e c o n t a c t y o u r l o c a l o f f i c e . I n c o m e gu i d e l i n e s a r e s h o w n b e l o w . Co m m u n i t y A c t i o n P a r t n e r s h i p o f f i c e s : Bo n n e r s F e r r y 2 0 8 . 2 6 7 . 3 6 6 3 Co e u r d ' A l e n e 2 0 8 . 6 6 4 . 8 7 5 7 Gr a n g e v i l e 2 0 8 . 9 8 3 . 0 4 3 7 Ka m i a h 2 0 8 . 9 3 5 . 2 4 1 2 Ke l l o g g 2 0 8 . 7 8 3 . 4 9 0 1 le w i s t o n 2 0 8 . 7 4 6 . 3 3 5 1 Mo s c o w 2 0 8 . 8 8 2 . 3 5 3 5 Or o f i n o 2 0 8 . 4 7 6 . 4 9 4 9 Sa i n t M a r i e s 2 0 8 . 2 4 5 . 9 0 9 0 Sa n d p o i n t 2 0 8 . 2 5 5 . 2 9 1 0 En e r g y A s s i s t a n c e G u i d e l i n e s Fa m i l y Mo n t h l y Th r e e M o n t h Si z e In c o m e L i m i t In c o m e L i m i t 1 $1 , 5 7 5 $4 ) 2 4 2 $2 , 0 5 9 $6 , 1 7 7 3 $2 , 5 4 4 $7 , 6 3 1 4 $3 , 0 2 8 $9 , 0 8 4 5 $3 , 5 1 3 $1 0 , 5 3 8 6 $3 , 9 9 7 $1 1 , 9 9 1 7 $4 , 0 8 8 $1 2 , 2 6 3 8 $4 , 1 7 9 $1 2 , 5 3 6 9 $4 , 2 6 9 $1 2 , 8 0 8 10 $4 , 3 6 0 $1 3 , 0 8 1 Ex h i b i t N o . 1 2 2 Ca s e N o . P A C - E - 1 0 - 7 Th a d e n , C . , S t a f f 10 / 1 4 1 1 0 P a g e 2 o f 2 Fi n a n c i a l A s s i s t a n c e Yo u m a y b e e l i g i b l e f o r a s s i s t a n c e p a y i n g y o u r u t i l i t y bi l f r o m y o u r l o c a l C o m m u n i t y A c t i o n P a r t n e r s h i p . o f . fi c e . T o f i n d o u t i f y o u r h o u s e h o l d q u a l i f i e s f o r e n e r g y as s i s t a n c e , p l e a s e c o n t a c t y o u r l o c a l o f f i c e . I n c o m e gu i d e l i n e s a r e s h o w n b e l o w . Co m m u n i t y A c t i o n P a r t n e r s h i p o f f i c e s : Bo n n e r s F e r r y 2 0 8 . 2 6 7 . 3 6 6 3 Co e u r d ' A l e n e 2 0 8 . 6 6 4 . 8 7 5 7 Gr a n g e v i l e 2 0 8 . 9 8 3 . 0 4 3 7 Ka m i a h 2 0 8 . 9 3 5 . 2 4 1 2 Ke l l o g g 2 0 8 . 7 8 3 . 4 9 0 1 le w i s t o n 2 0 8 . 7 4 6 . 3 3 5 1 Mo s c o w 2 0 8 . 8 8 2 . 3 5 3 5 Or o f i n o 2 0 8 . 4 7 6 . 4 9 4 9 Sa i n t M a r i e s 2 0 8 . 2 4 5 . 9 0 9 0 Sa n d p o i n t 2 0 8 . 2 5 5 . 2 9 1 0 En e r g y A s s i s t a n c e G u i d e l i n e s Fa m i l y Mo n t h l y Th r e e M o n t h Si z e In c o m e L i m i t In c o m e L i m i t 1 $1 , 5 7 5 $4 , 7 2 4 2 $2 , 0 5 9 $6 , 1 7 7 3 $2 , 5 4 4 $7 , 6 3 1 4 $3 , 0 2 8 $9 , 0 8 4 5 $3 , 5 1 3 $1 0 , 5 3 8 6 $3 , 9 9 7 $1 1 , 9 9 1 7 $4 , 0 8 8 $1 2 , 2 6 3 8 $4 , 1 7 9 $1 2 , 5 3 6 9 $4 , 2 6 9 $1 2 . 8 0 8 10 $4 , 3 6 0 $1 3 , 0 8 1 Fi n a n c i a l A s s i s t a n c e Yo u m a y b e e l i g i b l e f o r a s s i s t a n c e p a y i n g y o u r u t i l i t y bi l f r o m y o u r l o c a l C o m m u n i t y A c t i o n P a r t n e r s h i p o f . fi c e . T o f i n d o u t i f y o u r h o u s e h o l d q u a l i f i e s f o r e n e r g y as s i s t a n c e , p l e a s e c o n t a c t y o u r l o c a l o f f i c e . I n c o m e gu i d e l i n e s a r e s h o w n b e l o w . Co m m u n i t y A c t i o n P a r t n e r s h i p o f f i c e s : Bo n n e r s F e r r y 2 0 8 . 2 6 7 . 3 6 6 3 Co e u r d ' A l e n e 2 0 8 . 6 6 4 . 8 7 5 7 Gr a n g e v i l l e 2 0 8 . 9 8 3 . 0 4 3 7 Ka m i a h 2 0 8 . 9 3 5 . 2 4 1 2 Ke l l o g g 2 0 8 . 7 8 3 . 4 9 0 1 le w i s t o n 2 0 8 . 7 4 6 . 3 3 5 1 Mo s c o w 2 0 8 . 8 8 2 . 3 5 3 5 Or o f i n o 2 0 8 . 4 7 6 . 4 9 4 9 Sa i n t M a r i e s 2 0 8 . 2 4 5 . 9 0 9 0 Sa n d p o i n t 2 0 8 . 2 5 5 . 2 9 1 0 En e r g y A s s i s t a n c e G u i d e l i n e s Fa m i l y Mo n t h l y Th r e e M o n t h Si z e In c o m e L i m i t In c o m e L i m i t 1 $1 , 5 7 5 $4 , 7 2 4 2 $2 , 0 5 9 $6 , 1 7 7 3 $2 , 5 4 4 $7 , 6 3 1 4 $3 , 0 2 8 $9 , 0 8 4 5 $3 , 5 1 3 $1 0 , 5 3 8 6 $3 , 9 9 7 $1 1 , 9 9 1 7 $4 , 0 8 8 $1 2 , 2 6 3 8 $4 , 1 7 9 $1 2 , 5 3 6 9 $4 , 2 6 9 $1 2 , 8 0 8 10 $4 , 3 6 0 $1 3 , 0 8 1 coCI(\ CUVI DOC:;(\ CU:i co ai 0o 0 ..000N N N.. .. ..I' CO ai000-000N N N "- I' CO ai(\000CUOOO:iNNN Exhibit No. 123 Case No. PAC-E-10-7 Thaden, C., Staff 10/14/10 "-cu..c § RMP Payment Plan Options1 Equal Payment Plan assists customers with being able to budget for their utilty bils throughout the year by leveling out seasonal highs and lows in their monthly utility bils. To qualify for this plan a customer must not have a past due balance (no arears). The monthly payment is the average of 12 monthly bilings based on historical charges or an estimate of futue charges based on curent rate. The payment amount is reviewed at least once a year against actual usage and an adjustment may be made to factor in changes in the customer usage. The monthly payment is made either up or down. Equal Time Payment Program is typically a long ter payment plan that allows customers to pay their past due balance over an agreed time period up to 12 months in equal monthly installments. For example, a customers payment can be l/12th of the past due balance in addition to their curent monthly biling which is based on the Equal Payment Plan. Customer Serce Representatives work with the customer, depending on his or her circumstance, to set up an arangement to bring the account curent. Time Payment Program is an arangement that allows a customer to pay their past due balance over an agreed time perod up to 12 months in addition to their curent monthy bil which is based on actual usage. Customer Serce Representatives work with the customer, depending on his or her circumstance, to set up an arangement to brig the account current. i Source of information obtained by phone conversations with RM and a Company handout at the Energy Affordability Workshops (GNR-U-08-01). Exhibit No. 124 Case No. PAC-E-10-7 Thaden, C., Staff 10114/10 Treat yourself to energy savings Halloween is trck or treat time, but it also means colder temperatures - and higher energy use - are on the way. If the thought gives you the chils, here ar some simple tips. Weatherize Don't let energy vampires suck the heat out of your home. Add insulation in ceilngs and . crawlspaæs. Don't forget to seal ductork and especially air leaks around doors, windows and where utilities enter. Leaking ductork can reduæ your heating system's effciency by as much as 20 percent. The state of Idaho also offers low-interst loans for energ effciency improvements. Call toll fre 1-800-3347283 or visit www.energy.idaho.gov I financialassistance to learn more. Heating The amount of energy wasted by an inefficient heating system can be scary. Get your system tuned up and clean or change its fiters regularly. Set the thermostat a few degrees lower at night or install a programmable thermostat. Lighting Switch to ENEGY STAR~ qualified compact fluorescent lighting. CFLs use 75 perænt less energ than incadesænt bulbs and last 10 times longer. They come in many shapes and sizes to fit a varety of fitures. Let's tum the answer-s on Rocky Mountain Power's Home Energy Savings program can help you beat the energy vampires this season. It offers cash incentives on product and serviæs to make your home more energ efficient. Visit our Web site at rockymountainpower.netfhes or call toll free 1-800-942-0266 for more information. It's easy to give a powerful gift Looking to help a financially strapped student away at college this fall Or maybe an elderly neighbor who could use a helping hand? Why not mae a payment to their Rocky Mountain Power acrount? You choose the amount you'd like to give and whether you want the gift to be anonymous. For security reasons, we wil not reveal the recipient's account balance, but we wil apply your gift directly to his or her Rocky Mountain Power account. Make your gift payment by mailing a check with "gift payment" in the memo line and an accompanying note with your contact information, the name and address of the recipient and whether the gift is anonymous. Or make the gift payment over the phone with a check, credit card or debit card. There is a small fee charged by a third pary if you make a payment over the phone. Just call us toll free at 1-888-221-7070 or visit our Web site at rockymountainpower.netlgift for more details. r-io..~~(l I ~C'U ,.-- ~ r/: o p. .Z .Uo,. 0 i:f...- Z ~--~ ~'"::..tZ~__X ~.. 0~ U Eo.. Economic crisis calls for a concentrated effort Updated from previous year for Feb. 2010 To the Editor: News reports contiue alost daily on how people are strggling though the economic recession. At Rocky Mountain Power, we talk with our customers every day and understad the challenges many are facing as global and national economic conditions stre closer to home. Though difficult for our customers, we are happy to offer help. We have experenced and conscientious people available 24 hours a day who can help customers manage their bils. This might mean working out a payment plan, selectig some energy efficiency measures or maybe referrg a customer to a local agency for help with their energy bills. In economic conditions ths severe, our special concer is for customers who may have suddenly lost their jobs, people who never expected to fid themselves and their famlies in ths position and who may not know of options available for them. Under these unexpected circumstaces, the tendency may be to put off payig some bils in the hope tht thgs wil be better next month. Unfortately, ths natual reluctace to seek help can snowball into a much bigger problem. We urge any of our customers in ths position to call in as soon as they th there might be a concern and let us help. To help keep these concerns from developing into even bigger problems, we're making a concentrated effort to let people know about their options. We'll be putting more information in bils, distrbuting flyers locally, drawing renewed attention to inormation on our Web site and talkg to the news media to get the word out. And, as always, we're here to help anytime of any day when you call. Ou company and our employees are a big par of the communties we serve, and no one is imune from our nation's current economic difficulties. We understad and we can help. Call us toll-free 1-888-221-7070. Sincerely, Richad Walje President, Rocky Mountain Power Exhibit No. 126 Case No. PAC-E-10-7 Thaden, C., Staff 10/14/10 0)- c: E .- ca"C ~ c: 0) :: eLL D- c. c :æ .2c: ~N .s .¡:~ CD ~ :5 ca "C CD G) 3:N.- CD '- EG) 0 ; uco c G) - 3: ~l/ ..G) 0 E J:o .g:i :: ,-,.'- rn ~ ~¡:d ~ 13N.¡: Q) ~ ~ rnQ) §:i4-o å) i ta Q)~ ta "5dU 00 ~ ~ ~ C" M 6 \Ô t-~0\ II 00fA ~ ~ C" M C"II 0\ :: ,- ,-~ ~ t- 00 0\000000C" C" C" .. CDQo: ~fl ..ItN (/ I§oi-s à 1u o~-e- ~ ~~ ~ !~i:o...Õ~à Ioui-e- rn~.~ ,0 ta~ ta "5 ~d 8 5+- ~Q) ~orf .8 rn ~ ~i: Q)~ Q);;... ~ °2 ~-e § rn Q) ta ~ ..M ~ ~ :: ~~ '"~~ rno ... .s "8.¡: .. Q)'2 i: ~ ~e ;;o M~ .~ oS ~ ~ t ~ ~ ~ ta ~Q) d;; ~ § § 5h Q) 8 oS i: +- .. ~u ,0d ~Q) 0I- 0 tS o~oo II0..o fA6 §II .... +-fA i- o Q)+- ta §- ~i- tS ., S ~,0 e § rnU i: rn Q) 'G ~i: d~ i:d d Q) +- E5 .8 ci ~ ~¡:i:o- ....s õo ~t-,-~ 'S~ § :: § 5h 8¡: Q)eo g- ¡:o.. ¡: ~-- Q)i ~ ~ Q) o: Q. ~orf Exhibit No. 127 Case No. PAC-E-1O-7 Thaden, C., Staff 10/14/10 Residential Energy Efficiency Programs Rock.y Mountain Power offers the following residential energy effciency programs in Idaho: 1) Home Energy Savings; 2) Refrgerator/Freezer Recycling; 3) Idaho Time-of- Day Meterng; and 4) On-line and Mail-in Energy Analysis. Note: Programs, rebates and incentives are subject to change. Please access the Company's website for the most up-to-date information: http://ww.rockyountainpower.net/env/ epi.htm The Home Energy Savings Program serves Idaho residential customers who live in new or existing homes, multi-family unts or manufactued homes and landlords who own rental properies where the tenant is biled under the same Rate Schedules. The program provides cash incentives for the purchase and installation of energy-effcient appliances and equipment and is marketed on the Company's website under the name of WattS mar Energy Programs. Incentives are offered under the following categories: Lighting & Ceiling Fan Incentives provides rebates of $20 for energy star lighting fixtues and ceiling fans. Energy Effcient Light Bulbs Incentive provides customers with discount pricing on compact fluorescent bulbs (CFLs) when purchased from paricipating retailers. The Company's website contains a list of both qualified bulbs and paricipating CFL Retailers. The Company also offers information on how to dispose of (CFLs). New Appliances Incentives provide rebates ranging from $20 to $100 for the purchase of energy effcient appliances (dishwasher-$20, refrgerator-$20, washer (MEF 1.72-1.99)- $50, washer (MEF 2.0 or higher)-$l 00, water heater-$50, or evaporative coo1er-$1 00. Heating and Cooling Incentives provide rebates to customers who purchase either an energy effcient central air conditioning unt or heat pump for their home. A $250 rebate is provided for the purchase of a central air conditioner (minimum 15 SEER, 12.5 EER &TXV), an additional $50 rebate is provided for "best practices" installation but the installation must be done by a "Program Qualified Contractor" and another $50 rebate is provided for proper sizing (load calculation) of the unt. A $250 rebate is provided for a heat pump-to-heat pump upgrade (minimum 8.2 HSPE, 14 SEER, 11.5 EER &TXV) and a $350 rebate is provided for an electrc system-to-heat pump conversion. A $100 rebate is offered for a tue-up of both a central air conditionig unt ($100) and a heat pump ExhibÍt No. 128 Case No. P AC-E-1 0-7 Thaden, C., Staff 10114/10 Page 1 of2 ($100). The tue-up must be perormed by a "Program Qualified" Contractor. Lastly, a $150 rebate is offered for duct sealing. The sealing must be done by a "Program Qualified" Contractor. Insulation & Window Incentives provides rebates with a cap of$350 for all insulation incentives for the life ofthe home. The home must either have an electrc heating system or central air!heat pump serving at least 80 percent of the floor area. If the home is electrcally heated: 1) Attic insulation (must be minimum ofR-19). Rebate up to 30 cents per squae foot that results in an R-39 factor or greater; 2) Wall insulation (must be minimum or R-11 or fill wall cavity) rebate up to 45 cents per square foot; and 3) Floor insulation (mimum ofR-19 or greater) rebate up to 25 cents per squae foot. If the home has a central air conditioner or heat pump: 1) Attic insulation (must be minimum ofR-19) rebate up to 15 cents per square foot that results in an R-39 factor or greater; 2) Wall insulation (must be minimum or R-11 or fill wall cavity) rebate up to 30 cents per square foot. Installation of windows with a V-Factor of .32 or lower qualifies for a rebate of up to $1.50 per square foot. The Refrigerator/Freezer Recycling Program (aka "See Ya Later Refrgerator" Program) is provided to residential customers who own either a new or existing home and landlords who own appliances in rental properties where the tenant is biled. Through JA YO Environmental, older and less efficient refrgerators and freezers are removed free of charge and recycled to prevent fuer use. In addition a $30 rebate is provided for removal of the unit(s), an instant savings kit containng two compact fluorescent light bulbs, a "Bright Idea's" booklet, a refrgeratorlfreezer therometer, and information on other energy effciency programs. The Idaho Time of Day Program allows residential customers the option to switch to what is called, "Rocky Mountain Power's Time of Day Option." This allows customers more control of how much they spend on electricity by moving a substantial portion of their power usage to non-peak hours. To record time periods of electrcity used in the program installation of a special meter is required. On-line and Mail-in Energy Analysis allows residential customers to perorm free se1f- audits on household energy usage. Ths can be accomplished by completing an online audit form found on Rocky Mountain Power's website or by downoading a form, which can then be sent to the company after having been filled out. Exhibit No. 128 Case No. PAC-E-10-7 Thaden, C., Staff 10/14/10 Page 2 of2 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF OCTOBER 2010, SERVED THE FOREGOING DIRECT TESTIMONY OF CURTIS THADEN, IN CASE NO. PAC-E-10-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: TED WESTON ID REGULATORY AFFAIRS MANAGER ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2300 SALT LAKE CITY UT 84111 (FED EX) E-MAIL: ted.westonaYacificorp.com E-MAIL: ONLY MARK C MOENCH DANIEL E SOLANDER ROCKY MOUNTAIN POWER E-MAIL: mark.moenchCipacificorp.com daniel.solanderCipacificorp.com RANDALL C BUDGE RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 (FED EX) E-MAIL: rcbCiracinelaw.net E-MAIL: ONLY JAMES R SMITH MONSANTO COMPANY E-MAIL: jim.r.smithCimonsanto.com ANTHONY Y ANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 (FED EX) E-MAIL: tonyCiyanel.net PAUL J HICKEY HICKEY & EVANS LLP 1800 CAREY AVE., SUITE 700 PO BOX 467 CHEYENNE WY 82003 (FED EX) E-MAIL: phickeyCihickeyevans.com E-MAIL: ONLY KATIE IVERSON BRUBAKER & ASSOCIATES E-MAIL: kiversonCiconsultbai.com ERIC L OLSEN RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 (FED EX) E-MAIL: eloCiracinelaw.net CERTIFICATE OF SERVICE TIM BULLER JASON HARRS AGRIUMINC 3010 CONDA RD SODA SPRINGS ID 83276 (FED EX) E-MAIL: tbuller¡£agrium.com j aharris¡£agrium. com BENJAMIN J OTTO IDAHO CONSERV A nON LEAGUE 710 N 6TH STREET POBOX 844 BOISE ID 83702 (HAND CARRIED) E-MAIL: botto¡£idahoconservation.org E-MAIL: ONLY DR. DON READING E-MAIL: dreading¡£mindspring.com MELINDA J DAVISON DAVISON VAN CLEVE, P.C. 333 SW TAYLOR, SUITE 400 PORTLAND, OR 97204 (FED EX) E-MAIL: mjd¡£dvclaw.com RONALD L WILLIAMS WILLIAMS BRADBURY, P.C. 1015 WHAYS STREET BOISE ID 83702 (HAND CARRIED) E-MAIL: ron(fwillamsbradbury.com BRAD MPURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ID 83702 (HAND CARRIED) E-MAIL: bmpurdy¡£hotmaiL.com .~~ CERTIFICATE OF SERVICE