20090225Ottens Testimony Supporting Stipulation.pdf

Brad M. Purdy
1 Attorney at Law
BarNo. 3472
2 2019 N. 17th St.
3 Boise,ID. 83702
[phone]
4 FAX: [phone]
bmpurdy¡ßhotmail.com
5 Attorney for Intervenor
Communty Action Parership
6 Association of Idao
iunq FEB 25 PM l.: \ 9
IDAHO
UT\UTIE.S
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION9 OF PACIFICORP DBA ROCKY MOUNTAIN
10 POWER FOR APPROVAL OF CHAGES TOITS ELECTRC SERVICE SCHEDULES
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) CASE NO. PAC-E-08-07
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COMMUNTY ACTION PARTNERSHI ASSOCIATION OF IDAHO15 DIRECT TESTIMONY OF
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I. INTRODUCTION
Please state your name and business addrss.
My name is Teri Otens. I am the Policy Director of the Communty Action Parership
Association ofIdaho headquaered at 5400 W. Franin, Suite G, Boise, Idaho, 83705.
On whose behalf are you testifying in this proceeding?
The Communty Action Parership Association of Idao ("CAP AI") Board of Directors
asked me to present the views of an expert on, and advocate for, low income customers 0
Rocky Mounta Power. CAPAI's paricipation in this proceeding reflects our
organzation's view that low income people are an importt par of Rocky Mountan
Power's customer base, and that these customers will be adversely impacted by the
proposed changes to the Company's electrc servce schedules.
Please describe CAP AI's organzation and the fuctions it performs, relevant to its
involvement in this case.
CAP AI is an association of Idaho's six Communty Action Parerships, the Communty
Council of Idaho and the Canyon County Organzation on Aging, Weatherization and
Human Services, all dedicated to promoting self-suffciency though removing the causes
and conditions of povert in Idaho's communties.
Wht are the Communty Action Parerships?
Communty Action Parerships ("CAPs") are private, nonprofit organzations that fight
povert. Each CAP has a designated servce area. Combinng all CAPS, every county in
Idaho is served. CAPS design their varous programs to meet the unque needs of
communties located within their respective service areas. Not every CAP provides all of
the following services, but all work with people to promote and support increased self.
suffciency. Progrs provided by CAPS include: employment preparation and dispatch,
education assistace child care, emergency food, senior independence and support,
DIRCT TESTIMONY OF TERI OTTENS 2
1 clothg, home weatherization, energy assistace, afordable housing, health car access,
2 and much more.
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Have you testified before ths Commssion in other proceedigs?
Yes, I have testified on behalf of CAP AI in numerous cases involving PacifiCorp, Idaho
Power Company, AVISTA, and United Water.
II. SUMMY
Please sumarze your testimony in ths case?
The purse of CAP AI's testimony in ths case is to support the negotiated settlement
stipulation previously fied with the Commission and to which each par is either a
signatory or has no objection. The detals of CAP AI's recommendations which were
accepted by all pares are set fort in the followig section..
III. RECOMMNDATIONS
By way of background, why has CAP AI intervened in ths paricular proceeding?
CAP AI is concerned that the combined proposed increases in fees and rates will add to
the already unwieldy energy cost burden that low income familes in Idaho face,
paricularly in these uncertin economic times. This is of signficant importce to low-
income Idao customers and those who must provide services to them.
Can you provide poverty statistics for Idaho?
According to the Idaho Deparent of Commerce, 12.6% of the State's population, when
using the 2006 Census data falls withn federal povert guidelines and an additional
12.4% fall withn the state gudelines set at 150% of povert levels. The 2006 Census
reveals that those living in povert are categorized as 8.7% elderly, 15.1 % children, 9.8%
all other familes, 28.5% single mothers and 26.4% all others.
How does this translate to energy "afordabilty?"
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According to the U.S. Deparent of Energy, the "affordabilty burden" for tota home
energy is set nationwide at 6% of gross household income and the burden for home
heating is set at 2% of gross household income. In Idaho, there was a gap in the
2006/2007 heating season of over $123 millon between what Idahoans can aford to pay
(based on federal stadards) for energy and what they actully paid. Whle ths gap
increased by $26.7 milion from the previous year, the LIHEAP fudig only increased
by $1.8 milion. Curently, the LIHEAP program sends approximately $12.2 millon
(for energy assistace, weatherization and adnistrtion) to Idaho.
Would you please provide an overall sumar of the settlement reached by the paries in
ths case?
The settlement is known as a "black box" settlement in which not every par necessarly
agreed to each component of the agrement, but that all pares support the proposed
overall increase to the Company's revenue requirement of $4,382,632, with an increase
to the residential class of3.53%, and that the Stipulation is in the public interest.
Did CAP AI actively paricipate in ths proceding?
Yes, beginnng with a thorough review of the lengty filing itself to becoming a formal
par and, ultimately, to filing this testimony and paricipating in the techncal hearng to
be conducted in ths case, CAP AI exercised all of its rights and responsibilities as a full
and formal par.
Wil you please identify those components of the settlement that were of paricular
concern and relevance to CAP AI?
Yes. First, CAP AI noted that unike A VISTA and Idaho Power, Rocky Mountain does
not have tiered rates. CAP AI strenuously argued for an enhancement or enlargement of
tiered rates in the recently concluded Idaho Power general rate case hearng. As the
Commission is aware, Idao Power was ultimately ordered to increase its tiered rates
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from a par-year basis to a ful year thee-tier rate. Given the lack of time for Rocky
Mountain Power to revise its application to propose tiered rates in advance of Sta and
Intervenor prefile deadlines, the paries agreed that it would be reasnable for the
Company to commt to "include an invertd tier rate design proposal or option for
residential customers in its next filed general rate case for the Commssion's
consideration." Stipulation, par.l 0, p.4.
Has Rocky Mountan committed to a specific filing date for its next general rate cas?
No, but the Company has clearly indicated that it will not be in the not-too-distat-futue.
What else did Rocky Mountan Power agree to in its Stipulation of paricular interest to
CAPAI and the Company's general body of ratepayers?
Following in the wake of AVISTA's proposal to fud a low-income specific conservatio
education program, and subsequently ordered by the Commission in Idaho Power's
recent rate case (IPC-E-08-10), Rocky Mountain Power agreed to fud a total of
$50,000.00 for the two CAP agencies operating in Rocky Mounta's certificated area.
This is relatively equivalent to the fuding levels of A VISTA and Idaho Power.
The Stipulation provides that it shall be the responsibilty of CAP AI to propose the
specifics of the conservation program to all the Company, and all paries, as well as how
the fuding will be distrbuted between the two CAP agencies, the Southeastern Idao
Community Action Agency and the Eastern Idaho Community Action Parership.
Does CAP AI intend to simply split equally the $25,000.00 allocated for each CAP
agency or is there some other allocation method CAP AI has in mind?
Based on discussions with the utilties, the preference seems to be to allocate the total
amount of fuding given by each utilty to the CAP agencies operating in the utility's
area based on the relative customer population of the CAP agency in question. This
would avoid the inequity of allocating the same amount of fuding to two literaly
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adjacent CAP agencies even though their customer populations might be significantly
different.
Are there any other requirements imposed on CAP AI regarding low-income energy
effciency education?
All of the conditions described herein on the par of CAP AI shall be concluded no later
th May 1,2009. In addition, CAPAI will explain in detal the objectives of the energy
effciency programs and will endeavor to provide savings estimates to assist the
Company in program evaluation and reporting requirements. It is understood, however,
that by virte of its very natue, estimatig the savings resulting from an educational
program is not amenable to a high degree of precision. In light of ths, all paries agree
that the low-income energy effciency education program is "in the public interest and is
determined to be cost effective even though the explicit quatification of benefits may
not be possible." Stip. Par.8, pA. All paries fuer support the justification and recove
of these costs.
Do you believe that this low-income energy effciency education program is in the public
interest and, if so, why?
Energy effciency is one of the most cost effective and long term methods to reduce
overall energy costs for both individual households and nationally. The effort can be
stymied, however, by a lack of knowledge, especially among a segment of population
that often can only concentrate on basic surval needs. An education program provided
by counselors that the low-income are already reaching out to through the LIHEAP
program can provide essential education on effective, low cost ways to achieve a
reduction in their energy bil when it is needed most.
V. CONCLUSION
Does that conclude your testimony?
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DIRCT TESTIMONY OF TERI OTTENS 7
CERTIFICATE OF SERVICE
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2 I HEREBY CERTIFY that on the 24th day of Febru, 2009, I caused to be served on
the individuas listed below, the foregoing document via electronic transmission and U.S.
Postage.3
4 PacifiCorp dba Rocky Mountain Power Ted Weston
Rocky Mounta Power
5 201 S. Mai Street, Suite 2300
Salt Lake City, UT 84 i 11
6 ted. weston¡ßpacificorp.com
7 Commission Sta Scott Woodbur
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Deputy Attorney General
Idaho Public Utilties Commission
9 472 W. Washington St.
Boise, ID 83702
10 scott. woodbur¡ßpuc.idaho.gov
11 Monsanto Company Randal C. Budge
Racine, Olson, Nye, Budge & Bailey
12 201 E. Center
PO Box 1391
13 Pocatello, ID 83204-1391
rcb¡ßracinelaw.net
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15 Electronic only:James R. Smith
Monsto Co.
16 PO Box 816
Soda Springs, ID 83276
17 jim.r.smith¡ßmonsanto.com
18 Idaho Irrgation Pumpers Assoc., Inc.Eric L. Olson
Racine, Olson, Nye, Budge & Bailey
19 20 i E. Center
PO Box 1391
20 Pocatello,ID 83204-1391
21 elo¡ßracinelaw.net
22 Anthony Yanel
29814 Lake Rd.
23 Bay Vilage, OH 44140
tony¡ßyanel.net
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Agrum, Inc.Conley E. Ward
25 Michael C. Creamer
DIRECT TESTIMONY OF TERI OTTENS 8
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DIRECT TESTIMONY OF TERI OTTENS
Givens, Pursley, LLP
601 W. Banock St. (83702)
PO Box 2720
Boise, ID 83701-2720
cew¡ßgivenspursley.com
Denns E. Peseau, Ph.D.
Utilty Resources, Inc.
1500 Libert St. SE, Suite 250
Salem, OR 97302
dpeseau¡ßexcite.com
D
Bra M. Pudy