20080910ICAN Comments.pdf

08: 56p .kJ CAN
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ratfkA" t?n(I(lt-in,itf1 I\ctivn 'Ne.twgrk~ ;
3450 Hill Road · Boise, ID 83703. [phone] · fax [phone]
P.O. Box 2254. Post Falls, 1083877. [phone]
www.idahocan.org
14 AJ.,Iq.,.F~~997 p. 1Sep 04 08
~.. i~ en-)i ,.m:i -0(10 iSeptember 3, 2008 g"Q (J
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I am submitting these comments to the Idaho Public Utilities Commission regarding ca~rn\irs
AVU-E-08-01 and AVU-G-08-01 on behalf of the Idçiho Community Action Network (ICJi;). Z
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ieAN opposes the rate hike and the settlement agreement, and urges the PUC to continue with the
rate case process, including investigation and preparation of testimony by PUC staff and public
hearings after staff testimony has been made public.
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The settlement process, used in this spring's Idaho Power rate case and now in this case, is unfair to
residential customers and in particular to low-income residential customers. Although the PUc covers
some of the costs of intervention, it is a time- and resource-intensive process that few organizations
can afford. The role of the PUC is to protect the interests of the customers, rather than the utility
companies' shareholders.
One critical stage of the rate case process is the investigation and publication of the staff testimony.
Few consumers can understand and analyze the utility company's testimony, and the PUC has hired
experts to take on that role. When the PUC allows the utility companies to negotiate a settlement
agreement with intervening parties before the PUC staff has had time to review the filng, it abdicates
this critical responsibility.
Rate cases are expensive propositions for the PUC as well as the utilties and other parties. Allowing
the utilty companies to settle does not really save the PUC resources, however. As we have seen,
Idaho Power has used the settlement process to raise rates once this year, and has filed a second rate
increase in the same year. This is unprecedented. Unfortunately, other utility companies mElY follow
Idaho Power's lead in this as well, wasting PUC reSOurces with multiple filings in short succession.
AvÎsta plans to initiate ¡¡mother rate case in early 2009.
While the CAP agencies and other organizations may speak for some consumers, they cannot speak
for ¡;ll consumers. The settlement process, while including some consumer advocates, prevents other
organizations and individual consumers from participating fully.
Increasing the base rates
In previous rate caSeS, ICAN and consumers have opposed increasing the base rates, which
disproportionately impact low-income customers and customers on fixed incomes. Customers are
unable to avoid these rate increases by cutting down on their power usage. The PUC has listened to
consumers in the past, rejecting attempts by Avista and other utilties to raise base rates. This issue is
one example of how a settlement agreement written by parties that can afford to intervene, without
PUC st;;ff testimony or an opportunity for consumers to sit at the settlement table, results in an
agreement skewed in favor of the utility and large customers.
Lowwïncorne weatherï%atïon assïstance
Sep 04 08 08: 56p ICAN 2083360997 p.2
With rates increasing by $95 a year for the average electricity customer, low-income home energy
assistance and weatherizçition assistance will be the key to keeping the power on for many low-income
families this year. Families arc already struggling to keep up with utility rates, gas and food prices that
have risen sharply in recent years. More households than ever will find their power shut off this year.
Avista has a responsibility to offset this rate hike with low-income weatherization assistance. The
proposed $115,000 increase is a good start, but not enough. Avista will be receiving an additional $23
million in annual electric revenue alone. In 2005, weatherization benefits cost an average of $3,366
per household.; Even it weatherization costs have not increased at all in three years, the $115,000
would only serve an additional 34 households. ieAN urges the PUC to double Avista's weatherization
contribution to the CAP ;;gendes from $350/000 to $700,000 annually. This amount would do more to
meet the increased need created by the Avista's rate hike.
"-~a.?~
Rowena Pîneda
Executive Director
Idaho Community Action Nétwork
i Communíty Action Partnership Association ofIdaho.
Sep 04 08 08: 56p
Idaho Coiiiniuiiily Actio.
Network (ICAN,
ICAN 2083360997 p.3
The Idaho Community Aclion Network (ICAN) serves as a IIO\lerllil. eon$olidaieil
vDjce for low-and moderato-incomo Idiihoaiis. with chapters aiiiliiombership
chisters in loiirleen Idaho cOlliniunîlies. including tile state's three largesl cities
aiidiiimeroiis rural areas. TIiroligh ICAN. low-income Idaho laniileii havo II voice
in the decisions: that impact IlHiir lives. In addilion to its ilirecll'cllon work,
ieAN n.ll$ :I SUii,wlde, lIohinteer-drí\'h food program thallièllls low-income
fani î lies supiilemont their nio nthly blidgets.
ICAN'$ çn.iinimily orgiiiiiziiil model integrates the provision 01 tooll with traini iig.
loadiirshiii development, and actioii 011 imies to wiii eoncrelc chaugeii in peol_le's
liveuiiil ad\lnCelhe cause 01 social. racial and economic jiistii;e lor all Idahoans.