20101015Ottens Di.pdf

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2010 OCT 14 PH~: 0 I
1 Bra M. Pudy
Attorney at Law2 Bar No. 3472
3 2019N.17thSt.Boise, ID. 83702
4 (208) 384- i 299 (Lad)
[phone] (Fax)
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Attrn for Petitioner
6 Communty Action Parerhip
Asiation of Idao
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BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
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) CASE NO. PAC-E- 10-07
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) COMMITY ACTION
) PARTNRSHI ASSOCIA-
) TION'S PETITION TO
) INTERVENE
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9 IN TI MATTR OF TI APPLICATIONOF PACIFICORP DBA ROCKY MOUNAI
10 POWER FOR APPROVAL OF CHAGES TO
ITS ELECTRC SERVICE SCHEDULES
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COMMITY ACTION PARTNRSHI ASSOCIATION OF IDAHO
DIRCT TESTIMONY OF
TERIOTTS
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DIRCT TESTIMONY OF TERI OTTENS
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I. INODUCTION
Plea identify for whom you ar testfying.
I am testifyg as an expert on behaf of the Communty Action Parership Assoiation
of Idao on issues pertent to low-income cusomers, including how utlity rates and
servce afect the lives of the poor. I am not an expert in utility ratemg and do not
purrt to possess the attendat skills of tht parcular profession. CAP AI is a statewide
agency representig the six Communty Acton Parerhip Agencies, the CCOA and the
Communty Council of Idao, Inc. These agencies recive federa, sta, local and
private dollars to aid the almost 25% of Idao residents who are in the 150% of povert
or below income levels.:
ll. SUMY OF ISSUES AN POSITIONS
Would you pleas outline the issues you intend to rase in your testiony and your
positions on those issues?
1) CAP AI proposes tht Rocky Mountain Power's (R) fuding for its Low-Income
Weatherition Progr (LIW A) be increased in to reflect a per customer level equa to
tht of AVISTA which is $6.64. For example, ifRM's averge number of residential
customers for the test year is 56,715 reidential cusmer in Idao, its tota LIW A
fuding should be $376,588.00.
2. CAP AI proposes that RM's curt LIW A progr desgn th requies 75% of
eah dollar ofLIWA fuding come from a non-utilty source such as U.S. Deparent of
Energy LIHAP fuds. CAP AI proposes removig ths "matchig" reuiment and tht
communty acon agencies rensible for inling LIW A meases in quaifying
homes be given the lattude and flexibilty to allocate their fudig sources in the maner
that best matches existing resources with need. To acomplish ths, CAP AI proposes
tota elimon of the 75/25 split describe above.
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3. Regarg RM's proposa to replace its curnt monthy mium with a two-
tier inverted block rae with the fi block consumption level se at 800 kWh it is
CAPAI's position that the fit block consumption level should be set at 875 kWh in light
of the fact tht RM itslf sttes that the "averge" residential consption level is 839
kWh and that some low-income residential cusomers might excee 800 kWh.
4. CAPAI opposes RM's proposa to estlish a basic monthy "fixed" charge of
$12.00.
ID. DISCUSSION
A. LIWAFUDING
Plea iluste the "needs" oflow-income cusomer in Idao?
Accordg to the Idao Depaent of Commerce, 12.6% of the Stae's population, when
using the 2006 Census data falls with federa pover gudelines and an additional
12.4% fall with the stte gudelines se at 150% of pover levels. The 2006 Census
reveas tht those livig in pover are categorize as 8.7% elderly, 15.1% childrn, 9.8%
all other famlies, 28.5% single mothers and 26.4% all other.
How does ths trlate to energy "afordbility?"
Accrdig to the U.S. Deparent of Energy, the "afordability burden" for tota home
energy is set nationwide at 6% of grss houshold income and the burden for home
heatig is set at 2% of grss household income. In Idao, ther wa a gap in the
2008/2009 heati seasn of over $75 millon between what Idaoan ca aford to pay
(bas on federa stdads) for energy and what was actuly paid. Curently, the
LIHAP progr sends approxitely $25.6 millon (for energy assistce,
weatherition and adsttion) to Idao.
Regading RM's level of low-income weatherization assistace (LIW A) fuding, is
ther a backlog on homes tht nee and ar eligible for weathertion in Idao?
DIRCT TESTIMONY OF TERI OTTENS
Yes. Ths figue is a movin taget since each year more homes reach the age and
deterioration level to be eligible, and espeially in ths ecnomic downtu, we have an
increasing number of Idao's population who meet either the age or income reuiments
to be consider for the weatherzation program. Despite ths, all of our agencies agree
th they have identified at least a five year backlog in the number of homes identied for
the progr versus those they have been able to weatherie, despite the increases in
AR (Amercan Recovery and Reinvestment Act) fudig.
Would you pleas elabrae on CAP AI's proposa to incree LIW A fudig?
Yes, historically, RM fuded its LIWA progr at only $35,500.00 until 2004 when it
wa increas to $100,000.00 until 2006, and then to its curnt level of$150,000.00.
How does ths fuding level compa to Idao Power and AVISTA's Idao low-income
customers?
Idao Power has fuded its progr at $ 1.2 millon since the ealy pa of ths centu.
A VISTA recetly incr its fuding to $700,00.00 (Case No. AVU-E-10-01).
How do thes population and fuding numbers ofRM, Idao Power and AVISTA
compare?
On a per capita basis, A VISTA fuds at $6.64 per residential cusomer, Idaho Power
fuds at $3.05 and RM (bas on an estimated 2009 residential class numbe of 56,715)
fuds at $2.64.
Wht ar the respetive populations of Idaho Power and AVISTA's Idaho residential
customers?
Idao Power ha 393,890 reidential cusomer. A VISTA has 105,487 electrc
cusomers.
Ar you proposing that the thee mai electrc public utilities offer the sae pe capita
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Yes. There exist as much disparty between LIW A need and existng resources in
RM's sece terrtory as in Idao Power's and AVISTA's. It stes me as
fudaentaly fai to al th of the utiities, who serve the vas majority of public
utiity-served cusomers in this stte, and fai to their ratepayer that their fuding levels
of ths valuable DSM reource be relatvely equa.
What then is your speific proposa for RM in ths case?
I propose tht RM's LIW A fudig level be incrased frm its existg level of
$150,00.00 to $6.64 per residential cusomer, bas on an anua averae of thoughout
the test year.
Is there a reason tht you propose that RM's fuding level match AVISTA's and not
Idao Power's?
Yes. A VISTA's fudig level was just recently incr in Case No. A VU-E-l 0-0 1.
Idao Power's LIW A fuding, on the other hand, ha not ben adse since May 4,
200 to its curnt level, nealy seven year ago (Case No. IPC-E-03-13, Order No.
29595). CAP AI intends to sek an incras in Idao Power's LIWA fuding level in the
nea futu.
Ar ther reasns why the Commssion should consider LIW A as a desirble objective in
genera terms?
Yes. As the Commssion ha note on numerous occasions, effciently ru low-income
weatherion progrs, like any cost-effective DSM progr constitute a valuable
resource with system-wide benefits. With respet to a low-income basd DSM program,
ther is the added benefit tht derves from keeing cusomers on the system and
improvig the timeliness of their bil payments. Tht is, when cusmer are in such
ficially dire staits that they canot pay their utilty bils, let alone pay them in a
timely fashion, and they might end up in shelters or otherse leavig the systm with an
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outsding baance and no mean of repayment, progrs such as LIW A tht help
reuce their bils ca literaly mae the differce between keeping thes cusomers on
the system and avoiding the costs of bad debt and lost income. Cusmers with
disposable income can aford to implement their own weatherition measures, helping
defer the date by which additiona, higher-cost magial resources, ar required. Low-
income customers, however, tyically live in the poret of housing stock and stggle to
pay for life's basic necessities such as ret, food utilties, and car for their childrn.
Even if they own their own home, weatherition for peple livig on the margi of
society is nothing short of a luxur they canot aford.
Why is it relevant whether these cusomer own their own homes?
Becaus renters tyically do not even have the right to inl weatheron measurs.
Whle the CAP agencies work with owner of multi-family dwellings such as aparents,
there oftn ar not sucient ficial incentives for such individuas to intal
weatheriion measures on their own frm a cost-benefit stadpoint.
Would you pleas elaborate on the "system-wide benefits" you referr to?
As I alluded to, reducing the utlity bils of the por thoug weatherzation measurs
allows them to shift their inequae fmancial resoures from one necessity to others.
Ths, in tu, wil incre the likelihood tht low-income customers will make their
utility payments more tiely therby imprvig the utilties' cash flow, keep them from
leaving the system, increasing the utilties' overal revenues, and avoidig walg away
frm an outstadig bil, reducing the utlities' costs of bil collection and bad debt wrte-
off that they likely would not reover. Ths obviously benefits all other utlity ratepayers.
Finly, lie any effectve DSM progr it benefits all cusomers to defer the point in
tie at which new resources mus be acquid whether by consctg new generation
resour, or purhaing power on the ope maket price higher th embeded cost.
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Ar there other reans why RM should increase its LIW A fudig in ths cas?
We are at a semal moment in time with respe to low-income weaerition. In 2009,
Congress passed The American Recover and Reinvestent Act (AA) providing CAP
agencies with a limted but substtial incras in fuding for, among other thgs,
weatherig low-income housholds. In Idao, those AA fuds mus be completely
spnt by Mach, 2012. Though it is impossible to predict, there is curently no basis to
believe that Congrss will tae action to extend or relace AA. In fac there is
concern among the low-income advocate communty th the feder governent might
reduce other federal weaterization fudig resources such as LIHAP to pre-2009
levels.
Wht are the consequences of ths?
As a condition of AA, CAP agencies were requi to fuly invest the increased
fudi by early 2012. In order to accomplish ths, most CAP agencies needed to rap
up their capacity for deliverg low-income weatheron serces including everyg
from instaling actu energy savings measures to adstrtion of the progr. Ths
creted a large inct capable of investng vasly grter fuds and weatherzing
more housholds th previously possible. For example, additiona personnel or
contrtors were employed or retaed and properly tred to inl, rert on, and
otherwse adister the varous low-income weatherition prgrs conducted by the
CAP agencies. The CAP agencies also improved their contrctg, reporting, and
audtig processes, etc. Once AA fuds are exhaus, however, and espially if
other feder resures are reduced, ther will be nothg to fill the void created by the
loss of these fuds and the existig intrtue will collapse and disappar.
What specific concerns does ths caus you?
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CAP AI views the loss of ths incte as a lost opportty cost. As I have testified
numerous times before ths Commssion involvig all th of Idao's investor-owned
electrc utilties, there exist a trmendous baklog of households eligible for LIWA
fuding but for whch sad fudig is incient. Increased LIW A fuding authoried
by ths Commssion helped reduce the backlog, but AA injected such substtial
resoures into the problem that the possibilty of substtially reucing the backlog
became quite real. With the loss of AA and other fudig soures it sems likely that
we will revert to fightig an uphill battle. It would not only be unortate for the CAP
agencies to lose the impressive increased capacity to reuce weatherization-eligible
households, but would consitute a lost opprtty for all rateayers to lose the ability to
acqui a cost-effective resource with system-wide benefits. Ths is why it is essential
tht the utilties step in to at leat paially fill the void that will result when AA
expires. Any shortmig or delay in tht effort could have irverible consequences.
Without fuding to contiue matag the inctue, the increas pennel and
other resours applied to invest AA fuds will simply disappear. Whle AA was
a desrately neeed insion of capita into low-income weatherzation, it was never
intended to be a fi solution. Rather, it was intended to, and successfuly did, stulate
the CAP intues to gai an upper hand on the problem. Tht is why I characterie
ths moment in tie as critical and rectlly urge ths Commssion to not delay in
filling the gap tht will be created in the near futu. In order to propely budget and
esblish their weatherition objectives, the CAP agencies need to know today what
their resources will be tomorrw.
Are therè any other reasns why you believe th RM's LIW A fudig should be
increaed in the imediate futu?
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Yes. As discusse below, althoug CAP AI does not oppose the implementaion of a
tiere inver block residential ra design seing a fi block level of consumption
below the averae residential consumption, with a signficatly higher second tier
commodity rate, especially when coupled with RM's seana rae differetial, creates
the risk th some low-income cusmers who excee tht fi block of consption will
realiz a heavy rate impact, espeially durg the higher priced "sumer" seaon. Ths
ruer jusfies the need for increasd low-income weatherzation to give these cusomer
a chace to keep the majority of their consumption withi tht fi block.
B. 75125 SPLIT OF LIW A FUNDS
Would you pleas provide a brief background and explantion of ths issue.
Ths ha ben an issue of contention for PacifiCorp, openg thugh RM or its
preecessors, for quite some tie. In fact, ths Commssion intiated a separte
proceing specifically to addrs the issue (Case No. P AC-E-06- 1 0). Without delvig
into the intrcate detals of ths issue, the Company ha argued tht it should be allowed t
condition low-income weatherization fudig with the reuiement tht for every dollar
spnt on a weatherization measur, a cert pecentae of that dollar come frm other
source such as U.S. Deparent of Energy LIHAP funds. Regardless of what RM's
rationae for ths is, it hastgs the CAP agencies in sever ways. For example,
beause each low-income weatheriation fudin sour comes with its own conditions
and litations, depnvi the CAP agencies from using their discretion to utiliz those
resources in a maer that is best suted to any given project impedes their abilty to
maimi the energy savigs obtaed frm tht prject. As a pracal matt, the utility
should be indiffernt to how the CAPs mi and match their fudig sources so long as
they do so with the confes of the varous conditions and limtations of those sources.
The CAP agencies opeting in RM's sece tertory spend their ful allotment of
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1 utlity fuds every year. Thus, it makes no economic difference to the utlity how the
2 fudig soures ar allocated on a project by prject bais.
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Wht was the history of the contention between PacifiCorp and CAP AI?
Intially, PacifCorp insisted tht 500Æi of ever dollar comes from non-utity resources
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6 to fud 100% of a weatherition mease.
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Wh is the curent progr design in ths regar?
As a result of a compromised settlement in Cas No. PAC-E-06-10, PacifiCorp ageed to
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Do other utilities have simlar matchig reuiements built into their LIW A progrs?
Idao Power origily asked for a higher level of matchig, but ultiately settled for its
12 curnt matchig of 85% utility fuds and 15% fudig from other soures. A VISTA
13 allows 100% of ever dollar ofLIW A fuding to be spt on any given project or
meaure until its total fuds have ben exhused. CAP AI intends to sek an agent
to elite the 85/15 split from Idao Power at the next opportty.
Ar there any final reasns why ths case would be an opporte tie to elimite RM'
matchig requiment?
Yes. For all of the reons I have discussed in support of the nee for incread LIWA
fudig, including the expiron of AA, it is essential to equip the CAP agencies with
the greatest latitude and flexibilty possible to address the disparty between low-income
weatherzation need and resources.
Wht is your spific proposa regarding ths issue?
CAPAI proposes that RM's matchig requiement be eli entily. Our rationae
is that if the Company has try commtted to fudig a project, it should have no reason
to haper the effort of the CAP agencies to maxize the energy savigs derived from
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any given project. Ths defeats the very purse of LIW A or any DSM progr. In no
event is CAP AI suestg that RM money be invested unnably or tht RM be
held responsible for fuding more than the tota amount agee to under the progr.
Ar there other reasns to elimte RM's mathing requirement?
Yes. It ha always ben CAP AI's position th ther exist no valid ren to trat
PacifiCorp differently than Idao Power or AVISTA. In the interests of party, therefore,
CAP AI believes that the matchig requient, to the extent ther was ever an arguble
basis for it in the fi place, is a prgr design featu th seres no usfu purse and
there is no reasn to allow RM to insist on ths condition, espeially to the extent it
does. As I sad, CAPAI will sek to elimte Idaho Power's lesse matching of 85/15%.
C. TIRED BLOCK RATE
Wht is RM's proposal on ths issue?
As a reult of the setlement rehed in Cas No. PAC-E-08-07, RM is proposin a
tiered residential rate design in ths ca. Specificaly, RM prpose a two tier,
inverted block, residential rate design strctue tht would price the fit 800 kWh of
reidential class consumption at a lower commodity rate and a signficantly higher
commodity rate for all consumption in excess of 800 kWh. RM proposes to mainta its
existing seasnal rate differntial. RM witness Willam Grffth testfies tht the 800
kWh fit block consumption level was chosen beaus the Compay believes th its
average monthy residential class consption is 839 kWh. Testimony of Willam R.
Grifth, p.4.
Wht is CAP AI's respnse to this prposa?
CAP AI support, in theory, the concept of an inverted block rate design for the residentia
clas. Though, as stated, I am not an expert on rate design, I do have some concern
regaring how such a rate design would impact low-income cusomer. CAP AI has long
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ben intested in deterinig what the average monthy consumption is for low-income
cusmers. Ths data is not as eaily obtaed as might be imaged. Ths is due, in par
to the need to protect the privacy of individuas, and the fact tht utilities do not trck ths
ty of data. Along these lines, A VISTA ageed in settling its most recent general rate
cae (A VU-E-10-0l), to work with CAPAI prior to its next gener rate case to analyze
ths issue. The issue is complicated by the fact that although low-income customers
tyicaly have less discetionar usge, they live in the wors housing stock and often are
force to rely upon electrc baeboard heat. Ths fact drves up their usage per squae
foot of housing.
How does ths concern you in the context ofRM's ra design proposal?
My concer is tht for the reons jus sted there might be low-income cusomer
whose usge exceed 800 kWhmonth. Given the substially higher commodity rate
propose for the second block of consption, and iflow-income cusomers exceed the
fit consumption block durg the higher priced non-heatig sen, the consequences 0
an invered block rate design could result in a heavy rate shock for those cusomers.
Do you have a soluton tht addrsses your concern?
Yes, at leas parally. Assumng Mr. Grffth's asserton tha the "average" residential
customer's monthy use is 839 kWh then CAPAI believes tht the fit block
consumption level should be set slightly higher at 875 kWh. Ths would prvide a slight
bufer to hopefuly captue those low-income cusomers whose use fals very close to
the consumption level cutoff. Though ths is not a perfect solution, it would hopefuly
cover the majority oflow-income cusomers' monthy consumption whle stll seding
the appropriate price signals to those with relatively high levels of discreonar usage
and who have some degree of control over their consumption.
Do you have any other propoals regarding the inverted block rate design?
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Yes. I propose that RM agee to work with CAP AI, Staff and all other interested
pens to conduct a workshop with one year from the date of the Commssion's fi
order in ths cas to examine whether there are obvious problems with the new rate
design, assug that a block rate design is approved by the Commssion.
D. FID MONTHLY CHAGE
What is CAPAI's position on ths issue?
CAPAI stngly opposes RM's proposa. Firs, CAPAI is confd by Company
witness Grffth on ths issue. On pae 4 of his testiony, Mr. Grth testes:
"Curntly, residential cusmers served on Schedule 1 (residential class) pay a flat,
seonally differentiated energy charge applied equaly to all kWh. In addition, a
monthy mimum chage can apply." (Emphais added). It is unclea what Mr. Grth
meas by the statement tht a "monthly mium chage can apply." It is my
understading tht RM cutly does charge a monthy mium in the amount of
$10.64 and tht ths charge applies regardless of whether a cusomer has any use. Ths
chage is assessed agait all residential cusomers, thus makg Mr. Grffth's us of the
word "can" confsing. The matt is fuer confsed when Mr. Grffth testfies that:
"The Compay proposes tht the curent monthy mium chage be eliminted and
replaced with a proposed fixed Monthy Cusomer Servce Charge of $12.00." Testimony
of Willam R. Grifth at p.5 (Emphasis added). Ths suest tht RM is not curntly
imposing a fied monthy charge, but tht its minimum chage is being replac with a
"fixed" charge.
Wht is your underding of the Company's proposa to impose a "fixed" monthy
chage?
Again, it appear that RM alreay does collect a baic monthy charge of $10.64, a very
high chage in relation to other reguated public utilities. Perhps the distction lies in
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the fact tht the charge is now supposedly designed to captue a porton of the "fixed"
cost the Compay incurs to serve its residential customer. Support for ths supposition
is found on pages 5-6 of Mr. Grffth's testony where he sttes tha "(t)he residential
Cusomer Service charge should recover cusomer-related costs defied in Mr. C. Crag
Paice's cost of servce sty includig Distbution~Meter, Distbution-Servce,
Distbution~P&C, Distbution-Traformer, and Retal costs." Becaus neither Mr.
Grffth or any other Compay witness that I am aware of, explai wht the existg
monthy "mium" chage supposedly recovers, it is diffcult to know whether the
$12.00 monthy chage in ths ca is try being "elimiated and replaced," (Testimony
of Willam R. Grifth, p. 5), or jus being increasd by approxiately 200.1.
Wht is CAP AI's position on the imposition of any ty of fied monthy chage?
CAP AI opposes such charges for numerous reasns. Firt, it is diffcult to explai to
low-income cusomers why they ar chaged a substtial fee each month regardless of
whether they so much as flip a light switch. Thus, any fixed chaes not tied to energy
consumption send the wrong price signal to customers and rob them of any incentive to
conse energy. Ths dimishes the effcacy of all DSM progrs in genera and low-
income cusomers in paricular due to the fact tht they literaly must count their pennes
each month.
Plea identify your other bas for opposing fixed monthy chaes?
Agai from the perspeive of a low-income expe and not tht of a ratemag
speialist it is diffcult for me to conceptuize how the cost identified by Mr. Grffth,
as opposed to other costs, ar "cusomer-related." It would seem tht every cost incured
by an electrc utilty such as RM is relate to providig electrcity to a residential
customer. Though my underding of cost of service studies is limite, I am of the
belief tht such stdies are only one factor taen into considertion by the Commssion in
DIRCT TESTIMONY OF TERI OTTENS 14
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alocatig rates among cusomer classes. Furer, cost of sece stdies are generaly
considere to be faily subjective. I simply caot undersd how anyone, analyzg the
semingly inte costs incur by a utilty, can speify which of those costs ar
"cusmer-related" as opposed to those that are not. As an expe on low-income issues,
ca stte that inquires received by CAP AI on ths matter reveal tht low-income
customers are equaly bafed and concerned by what the fixed chage on their monthy
bil pert to. Rhetorically spakg, isn't the cost to build a power plant one tht is
necess to serve cusomer? Wht abut power lines and repair crews, and virly
everg else? It strkes me that a utility could argubly include the vas majority of its
cost into the category of "custmer-related" cost. As I said, the questons that CAPAI
receives from low-income cusomers suggest that those customers believe they should
only be chaged for how much electrcity they us. Anytg beyond that is diffcult to
comprehend from a logical stdpoint.
Are there other concer you have about fied monthy chages?
Yes. My concern about the possibilty tht most any cost could be considered "customer-
relate" is highighted by the tesony ofRM witness Mr. Grffth who testfies:
"Ultitely, the Monthy Cusmer Serice Charge should reover all residential fixed
costs. Ths will assur recovery of fixed costs regardless of usage..." lId Pp. 5-6.
Emphasis added). Mr. Grffth concludes: "The inclusion of thes fixed costs in the
monthy serce charge would result in a rate of approxiately $29.86 pe month." Id p.
6. Ths las remark is quite distbing to me. To even suggest chargig low-income
cusomers nealy $30 pe month regardless of how much energy they use could have
severe consequences. Bas on my expeise worki with the por, I stongly believe
tht they will quickly lose all incentive to control their energy consumption and be
inslled with a sens of hopelessness regarding their utlity bils. Compar to the past,
DIRCT TESTIMONY OF TERI OTTENS 15
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electrc utilities file general rate cases quite frequently, even those who have some form
of power supply cost adjustent mechansm in place. It has also beme common for
utilties to increingly recover more of its cost though a fixed chage, rather th a
commodity rate. The appeal of ths to utlities is faily obvious. It reduces risk and
enhces their overall rate of retu. For the reasons stated herin it is CAP AI's position
tht such request be denied.
Is there anytg else about RM's stted rationale for its proposed fixed monthy charge
tht you object to?
RM attempts to justify its proposa by comparg the proposed $12.00 monthy chage
to purrtedly similar charges levied by ten other "Idaho utilities." On p. 6 of his
testiony, Compay witness Wiliam Griffth refers to a "stdy" conducted by RM
makg ths comparson but the stdy is not included as par of the Compay's cas and
all of the ten utilities are not identified. Inead, Mr. Grffth list only th utilities, all
of which ar relatively small "coopetives." Though I am not an attorney, it is my
undersding tht cooperatives are not "public utilities" and are not reguated by the
Commssion. Becuse RM's proposed fixed chae is supposey cost-based, it seems
irlevant wht other utilities chage. Regardless, it also seems intutive tht a large
company such as RM might have drcaly differnt cost in serving its customers th
a smal, ru coopetive. RM could have more approprately compar its proposed
chage to Idao Power's or AVISTA's. RM could have even compaed its proposal to
its own sist companes such as Pacific Power & Light (PPL) in Washigton stte which
seres a servce tertory not dissimlar to RM's Idao tertory. Though I do not know
the specifics involved I am aware that there is curently pendig before the Washigton
Utilities Trasporttion Commssion Docket No. 100749 in which PacifCorp, though
PPL, is proposing to increas its existg fixed monthy chage whch is curently only
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$6.00 per month. PPL is proposing to increae that chage to $9.00, substtially below
the $12.00 propose in Idao.
Wht is your speific proposa regarding RM's proposed fixed monthy charge?
CAP AI proposes tht RM fi be required to explai what its existg monthy
"mium" charge pert to and, asng tht chage is even legitiate, that any
propose increa to it be denied in ths case.
IV. CONCLUSION
Would you pleas sumare your testimony?
1. CAP AI proposes tht RM's LIW A fudig level be incre from its curent
level of $150,000.00 to an anua level that is $4.08 per residential customer, based on a
test year averae;
2. The existig 75/25% LIWA fuding matchig requiement be completely
elimiated;
3. Tht RM's proposed two-tier, invert block, residential rate design be
approved, but with the fist block consumption level set at 875 kWh per month, and;
4. That the Commssion Order RM to fuly explai its existg monthy mium
chage and tht it be proven reonable as is, or be reduced or elim, and;
Does ths conclude your testimony?
Yes, it does.
DIRCT TESTIMONY OF TERI OTTENS 17
1 CERTIFICATE OF SERVICE
2 I, the undersigned, hereby cer tht on the 14th day of October, 201 0, I served a copy 0
the foregoing document on the followig by U.S. mail, fit class postae and electronic maiL.3
4 Ted Weston
Rocky Mounta Power
201 South Main Suite 2300
Salt Lae City, UT 8411 1
5
6
7 Paul J. Hickey
Hickey & Evan, LLP
1800 Cary Ave., Suite 700
Box 467
Cheyenne, VVyomig, 82003
8
9
10
Mark Moench
Danel E. Solander
Rocky Mountan Power
201 South Mai Suite 2300
Salt Lake City, UT 84111
11
12
13
14 Data Request Respons Cente
PacifiCorp
825 NE Multnomah Suite 2000
i 6 Portland, OR 97232
15
17 Tim Buler
Agrum Inc.
3010 Conda Rd.
Soda Sprigs, ID 83276
18
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20 Benjam J. Ot
Idao Conservation Leage
710N. 6th St.
Boise, ID 83702
21
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Don Reaing
6070 Hill Rd.
Boise, ID 83703
dreading~dspring.com
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DIRCT TESTIMONY OF TERI OTTENS 18
1 Melinda J. Davison
Davison Van Cleve, P.C.
333 S.W. Taylor, Suite 400
Portland, OR 97204
2
3
4 Ronald L. Willams
Wiliams Brabur, P.C.
10 15 Hays St.
Boise, ID 83702
5
6
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Eric L. Olsen
Racine, Olson, et al
201 E. Center
Pocatello, ID 832018
9
10 Anthony Yanel
29814 Lae Rd.
11 Bay Vilage, OH 44140
12
13
Radal C. Budge
Racine, Olson, et al
201 E. Center
Pocatello, ID 8320114
15
16 James R. Smith
Monsanto Company
P.O. Box 816
Sod Sprigs, ID 83276
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DATED, ths 14th day of October, 2010
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DIRCT TESTIMONY OF TERI OTTENS i