20071025Howat rebuttal.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
bmpurdy~hotmail.com
Attorney for Petitioner
Community Action Partnership
Association of Idaho
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF P ACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROV AL OF CHANGES TO
ITS ELECTRIC SERVICE SCHEDULES.
CASE NO. PAC-07-
REBUTTAL TESTIMONY
OF JON HOWAT
PLEASE STATE YOUR NAME, OCCUPATION, AND BUSINESS
ADDRESS.
My name is John Howat, and I am a Senior Policy Analyst at the National
Consumer Law Center, 77 Summer Street, 10th Floor, Boston, MA 02110.
FOR WHOM ARE YOU TESTIFYING IN THIS PROCEEDING?
I am providing comments and testimony on behalf of Community Action
Partnership ofldaho ("CAP AI"
HAVE YOU PREVIOUSLY SUBMITTED TESTIMONY ON BEHALF OF
CAPAI IN THIS PROCEEDING?
Yes.
HAVE YOU HAD THE OPPORTUNITY TO REVIEW THE REBUTTAL
TESTIMONY IN THIS PROCEEDING OF ALL OTHER PARTIES?
Yes, the only other party that I am aware of who filed testimony regarding the
issues I addressed in my direct testimony is that of Daniel Klein on behalf of the
Commission Staff and I have reviewed that testimony.
PLEASE SUMMARIZE THE PURPOSE OF YOUR REBUTTAL
TESTIMONY.
The purpose of my rebuttal testimony is comment on Staff's recommendations
regarding the Company s proposed reconnection charges, after normal office
hours for reconnection, and collection agency fees or collection costs that the
Company proposes to pass along to individual customers.
DO YOU SUPPORT COMMISSION STAFF'S RECOMMENDATIONS AS
OUTLINED ON PAGE 2 OF MR. KLEIN'S TESTIMONY?
Yes.
DO YOU HAVE ADDITIONAL COMMENTS REGARDING THESE
RECOMMENDATIONS?
Yes, The Company s proposals to increase reconnection charges, to reduce the
hours offered for after hours reconnection of service, and to pass along collection
agency fees and related collection costs to individual customers would all
disproportionately burden low-income customers. As demonstrated in previous
testimony in this proceeding, low-income utility customers are more likely than
their higher-income counterparts to experience disconnection of service for non-
payment. Because reconnect ion charges, reconnection service quality and
proposed collection agency fees only apply, or are intended by the Company to
apply, to customers who have experienced loss of service, the Company
proposed changes would disproportionately impact low-income customers, Put
another way, low-income customers would be more likely than higher-income
customers to suffer adverse consequences of the Company s customer service
proposals. Low-income customers are least able to absorb these adverse financial
consequences while paying for necessities of life. For this reason, and for those
delineated in Mr, Klein's testimony, CAP AI supports the recommendations as
outlined on Page 2 ofMr, Klein's testimony,
DOES THIS CONCLUDE YOUR TESTIMONY?
Yes.