20110527Coughlin Di.pdf

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20BHAY 27 AM If: 09
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) CASE NO. PAC-E-l1-12
MOUNTAIN POWER FOR )
APPROVAL OF CHAGES TO ITS ) Direct Testimony of Barbara A. Coughlin
ELECTRIC SERVICE SCHEDULES )
AN A PRICE INCREASE OF $32.7 )
MILLION, OR APPROXIMATELY )15.0 PERCENT )
ROCKY MOUNTAIN POWER
CASE NO. PAC-E-11-12
May 2011
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. My business address is 825 NE Mu1tnomah,
4 Portland, OR 97232. My present position is Director, Customer and Regulatory
5 Liaison.
6 Qualifications
7 Q.Please describe your educational and professional background?
8 A.I have worked in the gas and electrc industr since 1978. I received a Legal
9 Assistat Certificate from Marcrest College in 1991. From 1978 to 1997, I held
10 vanous positions in increasing levels of responsibilty within the legal/regulatory
11 departent of Iowa-I1inois Gas and Electric Company, a predecessor company to
12 MidAencan Energy Company. In 1997, I was promoted to a customer services
13 supervisor and in 1999 was promoted to customer services manager at
14 MidAmencan Energy Company. I worked as manager of regulatory projects at
15 PacifiCorp from 2006 through 2008, when I was promoted to my curent position
16 of Director of Customer and Regulatory Liaison.
17 Purpose of Your Testimony
18 Q.What is the purpose of your testimony?
19 A.The purose of my testimony is to address miscellaneous consumer and customer
20 service issues referenced in the Commission's Order No. 32196 in Case No. PAC-
21 E-1O-07 (the "2010 General Rate Case"). I wil also address Rocky Mountain
22 Power's fuding of the Low-Income Conservation Education program as directed
23 by the Commission in Order No. 32224 in the 2010 General Rate Case.
Coughlin, Di - 1
Rocky Mountain Power
1 Miscellaneous Consumer and Customer Servce Issues
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What miscellaneous consumer and customer service issues wi you' be
addressing in your testimony?
I will be addressing five issues that the Commission sumanzed On page 62 of
Order No. 32196. The issues are:
1. Disconnect Policy as it pertains to the physical disconnection when servce
is voluntanly terminated and connection of service for new customers,
2. Estimated Bils pertaining to the meter reading used to calculate the
electrc bil when an account is closed or when an account is opened,
3. Tenant Notice of service activation, specifically when activated for tenants
as par of Rocky Mountain Power's Landlord Link program,
4. Rebillng Policy as it pertins to the calculation of a bil in the situation of
a meter failure; and the verbal or wntten communication made with a
customer when an adjustment has been made to their account, and
5. Moratorium and Winter Payment Plan as it pertins to the clanty of the
presentation of information in published customer communications.
What has the Company done to respond to the Commission's Order?
The Company met with Idaho Public Utilties Commission Staff ("Staff) by
telephone on March 15,2011, and provided wntten responses on April 15, 2011,
to a Staff information request addressing the issues summarized above. On Apnl
26, 2011, Company representatives met in person with Staff, providing detailed
information regarding the Company's curent practices and processes regarding
all five issues and why the curent Disconnect Policy is the most cost effective
Coughlin, Di - 2
Rocky Mountain Power
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approach for customers.
What is the current status of the issues being reviewed with Staff
It is my understanding that the information provided to Staff regarding Estimated
Bils (Issue 2), Tenant Notice (Issue 3), and Moratorium and Winter Payment
Plan (Issue 5) has resolved Staffs concerns.
What is the status of discussions on the Disconnect Policy?
With regard to the Disconnect Policy, pertining to the physical
disconnection/connection of electrc service between customers, the Company
and Commission Staff are continuing discussions.
Please explain the Company's Disconnect Policy.
When a customer calls in and requests closure of their account, the Company
issues a closing bil based on the date of the customer requested account closure.
If a new customer does not sign up for service at that site, the electrc service
remains active. Once the site reaches an accumulated usage of 1000 kWh, the
Company sends a technician to the site to either leave a notice of disconnection of
service or terminate the service.
What is the Company's position on this issue and why should it be adopted
by the Commission?
The Company's curent Disconnect Policy is the most cost effective and safest
method for handling customer account changes at a site. The Company's
analysis, based on 2010 data, shows operational cost of $186,311 with the
existing process. In addition to the operational costs there are unecovered
revenues from usage between customers of $36,317 for total costs of $222,628
Coughlin, Di - 3
Rocky Mountain Power
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from the Company's curent policy. This compares to a cost of $408,553 if
service was terminated and then reactivated at all sites where there was a
customer requested account closure and subsequent account opening. The
difference between the existing process and a process where all services would be
terminated is a savings of$185,925 to customers.
In addition to the net operating costs savings from the existing process,
there is also a reduction in the safety nsks associated with disconiecting and
connecting a meter, it avoids propert damage such as frozen water pipes,
maintains curent staffng, vehicle and equipment levels, and allows a new
customer a second chance to sign up for service when moving.
What is the status of the discussions on the Rebilling Policy?
With regard to the Rebiling Policy the scope of the issues have been narrowed to
the appropnate communications with customers who have had a biling
adjustment made to their account. Discussions between the Company and
Commission Staff are also continuing on this issue.
Please explain the Company's Rebiling Policy.
The Company uses thee methods to communicate to customers when an
adjustment has been made to their bil. The methods are: the bil adjustment code
which is published on the monthly biling statement; a telephone call placed to the
customer by the agent workig on the billng adjustment; and/or a letter sent to
the customer. Rocky Mountain Power has revised a number of its bil adjustment
codes as they would appear on a customer's bil and provided that list to Staff for
their review. Rocky Mountain Power representatives wil continue to work with
Coughlin, Di - 4
Rocky Mountain Power
1 Staff to develop an agreeable protocol for the verbal and wntten communications
2 following a billng adjustment.
3 Low Income Energy Conservation Education
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Is there an additional matter concerning the funding of low income energy
conservation education you would like to address in your testimony?
Yes. In Order No. 32224, the Commission stated! that it is reasonable and
appropnate to revisit Low Income Conservation Education fuding durg the
Company's next rate case.
What is the status of Rocky Mountain Power's funding of Low Income
Conservation Education?
As part of an overall stipulation resolving Case No. PAC-E-08-07, the Company
committed to a total payment of $50,000. The stipulation states the following:
8. The Paries agree that the demand-side management
programs proposed by Rocky Mountain Power in Docket
No. PAC-E-08-01 are prudent. Furer, the Paries agree
that a total of $50,000 of demand-side management
program fuds wil be made available to SouthEastern
Idaho Community Action Agency and Eastern Idaho
Community Action Partership to be used to support
conservation education as a component of Rocky
Mountain Power's low income weathenzation program,
Schedule 21. Parties agree that it is the responsibility of
the Community Action Parership Association of Idaho
to propose said education program to Rocky Mountain
Power by May 1, 2009 and that the proposal will contain
fuding proportioning the $50,000 between the two
agencies, objectives and any savings estimates to assist in
program evaluations and reporting requirements. The
Parties agree that the low income weathenzation program
(Schedule 21) and the conservation education component
of the program is in the public interest and is determined
to be cost-effective even though the explicit quatification
i Order No. 32224 page 5, issued Apri118, 2011.
Coughlin, Di - 5
Rocky Mountain Power
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of benefits may not be possible, and fuhermore, the
Parties agree to support the justification and recovery of
these costs through the demand-side management
surcharge fuding. (Emphasis added.)
How much has been invoiced to Rocky Mountain Power to date?
Rocky Mountain Power has paid a total of $50,000 though three payments.
Rocky Mountain Power received and paid its first invoice from Community
Action Partership Association of Idaho (CAPAI) for $7,500 for energy
efficiency kits in May 2010. In late November 2010, Rocky Mountain Power
received invoices in the amount of $21,250 each from the two agencies,
SouthEastern Idaho Community Action Agency and Eastern Idaho Community
Action Partership, to cover their associated administrative and delivery costs.
The invoices from the two agencies were paid in Apnl 2011 upon confiration
that education curculum was completed and agencies were prepared to launch
the education program.
Has Rocky Mountain Power fulfiled its commitment made in the stipulation
in Case No. PAC-E-08-07?
Yes. The stipulation in Case No. PAC-E-08-07 clearly states a total of $50,000
would be paid and that has been accomplished. In reading paragraph 8 of the
stipulation in its entirety, nowhere is the word "annual" used. Nor did any part
reference an anual payment in their testimony fied with the Commission in
support of the stipulation. The record is clear that the Company agreed to a total
payment of $50,000, not a payment that would continue on in perpetuty with no
termination date.
Coughlin, Di - 6
Rocky Mountain Power
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Has CAP AI provided any documentation or information to Rocky Mountain
. Power to substantiate its claim in the 2010 General Rate Case that the
commitment made in paragraph 8 of the stipulation was for an annual
payment of $50,000?
No, they have not.
How many Rocky Mountain Power customers have partcipated in the Low
Income Conservation Education program?
CAP AI has informed Rocky Mountain Power that one of the agencies
admistenng the program had its first participants in mid-May 2011. At this
point in time, if that commitment had been an annual commitment, Rocky
Mountain Power would have paid the participating agencies for kits and fees for
the years 2009, 2010, and 2011, a total of $150,000 with its first customers
receiving kits in mid-May 2011.
What does the Low Income Conservation Education program consist of for
Rocky Mountain Power's customers and what are the eligibilty
requirements for a customer to participate?
Participants wil be compnsed of households served by Rocky Mountain Power
having obtained Low Income Home Energy Assistance fuds in the 2010/2011
heating season, and had not previously received weathenzation program services.
These households wil participate in' one group education session, one in-home
session, and wil receive an energy effciency kit. The energy efficiency kits
contain easy to install measures including three compact fluorescent light bulbs, a
refrigerator temperatue card, outlet gaskets, a kitchen aerator, and a night light.
Coughlin, Di - 7
Rocky Mountain Power
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How many households are expected to be educated through this program
from the funds made available to the agencies?
Each agency wil educate 250 households, for a total of 500 households.
What is the cost per household?
Rocky Mountain Power provided $50,000 in fuding to cover the 500 households.
The average cost per participant wil be $100 with $15 covenng the cost of the
kit.
Is Rocky Mountain Power interested in providing funding for energy
education in the future?
The Company wil be meeting with representatives from SouthEastern Idaho
Community Action Agency, Eastern Idaho Community Action Parnership,
CAP AI and Commission Staff in mid-June 2011. One of the meeting agenda
items wil be a discussion related to the futue of the project.
Do you have any concerns with funding the project in the future?
Yes. We would like to work closely with staff from the two agencies to
determne if the curent format and participant goals are appropriate and what
tye of fuding may be needed in the futue. It may be diffcult for agencies to
sustain a goal of 500 partcipating households annually. Less than 2,000 Rocky
Mountain Power customers in Idaho received energy assistance in 2010, so the
pool of eligible households is limited.
Do you believe there is a need to have a more consistent state-wide approach
for a low income conservation education program?
Yes. Program costs and resulting benefits vary greatly between utilties in the
Coughlin, Di - 8
Rocky Mountain Power
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state. Rocky Mountain Power believes these are important issues that should be
discussed with the agencies, CAP AI, and Staff. Rocky Mountain Power is
interested in providig services that benefit Rocky Mountain Power customers in
a cost effective manner.
Does this conclude your testimony?
Yes.
Coughlin, Di - 9
Rocky Mountain Power