20081126Comments.pdf

KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
2008 NOV 26 PH I: I 3
. IDAHO PUBLIC
UTILITIES COMMISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S )
INQUIRY ABOUT ENERGY AFFORDABILITY) CASE NO. GNR-U-08-1ISSUES AND WORKSHOPS. )
)
) STAFF COMMENTS
)
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, and in response to the Notice
of Public Workshops and Notice of Scheduling issued in Order No. 30644 on September 29,
2008, submits the following report.
INTRODUCTION
On September 29,2008, the Idaho Public Utilties Commission (Commission) initiated
Case No. GNR - U -08-01 to provide a foru for the exploration of issues related to the
affordabilty of energy in Idaho. The Commission noted that rising energy costs were affecting
utilties and their customers. Order No. 30644.
The Commission recognizes that there are a varety of factors contributing to significant
upward pressure on electric and natural gas rates in Idaho. Energy affordability has become a
central issue for many Idaho households and businesses.
STAFF COMMENTS 1 NOVEMBER 26, 2008
Two public workshops were conducted by Commission Staff at the Idaho Public Utilties
Commission on October 14 and October 22,2008. The purose of the workshops was to identify
issues and discuss solutions pertining to energy affordability and customers' ability to pay
energy bils. General topics included: 1) bil mitigation; 2) bil payment assistace; 3) bil
reduction; 4) reduction of customer costs; 5) bariers to obtaining or retaining service; and 6)
case management. Alternative strategies and solutions were identified and discussed.
A broad spectru of interests and viewpoints were represented at the workshops. In
addition to Commission Staff, representatives of Avista, Idaho Power, Intermountain Gas, and
Rocky Mountain Power were in attendance, as well as Representatives Nicole LaFavourl,
Wiliam Kilen, Phylis King, Anne Pasley-Stuar, and Donna Pence. Also participating in
discussions were representatives of several organizations: AARP Idaho, the Community Action
Parnership Association ofIdaho (CAPAI), the South Central Community Action Agency, the
Idaho Community Action Network (ICAN), the Salvation Ary, the Idaho Conservation League,
and the Snake River Allance. Representatives from the City of Meridian and several individuals
not affiliated with any particular organization also attended the workshops.
Paricipants shared their considerable knowledge, research, and insights about the topics
under consideration. The workshops and exchange of information undoubtedly helped all
paricipants to better understand the complexity of the issues surounding energy affordability.
In its comments, Staff has attempted to present the topics and alternatives discussed, identify
areas of agreement among paricipants, and make recommendations to the Commission.
ENERGY AFFORDABILITY AND INABILITY TO PAY
Customers today are facing serious economic challenges. The combination of
increasing rates for natural gas and electricity, higher food and fuel costs, rising unemployment
levels, and tuoil in the financial and housing markets are impacting customers' ability to pay
their utilty bils? Curent Idaho Department of Labor data (as of August 2008) shows an
upward trend in the State's unemployment rate (4.6%). Idaho's projected unemployment for
September 2008 is 5.0%, the State's highest unemployment rate in four years. An increase in the
i Now Senator LaFavour
2 See Appendix i (Energy Burden and Affordabilty GAP).
STAFF COMMENTS 2 NOVEMBER 26, 2008
unemployment rate can lead to an increase in the percentage of the state's population that falls at
or below 100% of the Federal Poverty Guidelines.
Federal and state governent agencies charged with the responsibilty to protect human
health and welfare generally set household income eligibilty limits for social service programs
at levels exceeding 100% of poverty. Since total household income is used to determine
eligibilty for most social services, the income of all wage earers in a household is combined.
The State ofIdaho has roughly 44,000 households at or below 100% ofpoverty.3
Low-income households are not the only ones affected. The current economic
conditions impact a diverse group of wage earers and fuher inhibit customers' abilty to pay
their utility bils. As a result, more strain wil be placed upon agencies that provide financial
assistace and more customers will fall behind in paying bils. Undoubtedly, the number of
customers whose service is subject to disconnection will increase as well.
In examining an individual's abilty to pay his/her utilty bil, "energy burden" is taken
into account. Energy burden is the percentage of a household's income that is spent on all
energy used for space heating and cooling, lighting, and water heating. For instance, an Idaho
household that is at 75-99% of the Federal Poverty Level typically spends 13.6% of the
household's anual income to pay for home energy. A household below 50% of the Federal
Povert Level typically spends 47.8% of its anual income to pay for home energy bils. The
energy burden on these households greatly impacts their abilty to meet other essential living
expenses such as food and clothing. According to federal guidelines, an energy burden of 6% of
anual household income is considered affordable.
By rule, the Commission established a safe haven for certain residential customers who
are unable to pay their winter energy utilty bils. Rule 306, Utility Customer Relations Rules
(UCRR). During the months of December, Januar, and Februar, utilties are prohibited from
disconnecting electric or natual gas service to any residential customer who declares that he or
she is unable to pay a utilty bil in full and whose household includes children, elderly or infirm
persons. The period during which disconnection is prohibited has become known as the
"moratorium." This provision does not protect all low-income customers, i. e., a low-income
customer who has no children, elderly or infirm in the household or those customers who are
3 See Appendices 2 (Idaho Demographic Discussion), 3 (Idaho Demographics), and 4 (Federal Povert Level
Guidelines).
STAFF COMMENTS 3 NOVEMBER 26, 2008
eligible for protection but do not contact the utilty to request it. Customers who have declared
eligibility for the moratorium are stil expected to pay their bils each month, but canot be
disconnected if they fail to do so. Payment of any past due balance or negotiation of a new
payment arangement is required on or before March 1.
Customers who have declared eligibilty for the moratorium can also enter into a Winter
Payment Plan, which provides an additional two months of protection (November and March).
Rule 306, UCRR. Under a Winter Payment Plan, customers agree to make monthly payments
equal to half of a regular level payment amount, which equates to the customer's anual bil
divided by 24. Customers with Winter Payment Plans must pay any past due balance or
negotiate a new payment arangement on or before April 1.
After the moratorium ends, many customers (whether or not they are on the Winter
Payment Plan) are unable to payoff their accrued balances in full or are unable to afford
previously negotiated payment arrangements. Though protected from disconnection in the
coldest winter months, many customers find themselves in a more severe financial situation after
the moratorium ends.
The following list represents the number of customers per utility who declared eligibilty
for the moratorium during the 2007/2008 winter heating season:
. 10,284 Idaho Power customers;
. 4,553 Intermountain Gas customers;
. 2,635 Avista customers; and
. 560 Rocky Mountain Power customers.
CURRNT ASSISTANCE PROGRAMS
There are several programs in Idaho that provide financial assistace to customers who
need help in paying their utilty bils and obtaining assistace to reduce utilty bils through
energy efficiency. Programs operate under a wide variety of guidelines and restrictions, with
fuding from both public and private resources.
STAFF COMMENTS 4 NOVEMBER 26, 2008
Low-Income Home Energy Assistance Program (LIHEAP)4
The Low-Income Home Energy Assistance Program (LIHEAP), also known as "Energy
Assistance," provides low-income customers with financial assistance designed to pay utilty
bils associated with primar heating source.s To be eligible for assistance, applicants must meet
income-criteria that is based on Federal Poverty Guidelines. Paricipants must apply for
LIHEAP assistace at a community action agency each program year.6 The LIHEAP program
year usually runs from November 1 through March 31st to correspond with Idaho's heating
season. The starting date varies based on the availabilty of federal fuds.
Last year, 101,000 Idaho households qualified for LIHEAP benefits. LIHEAP's
2007/2008 Energy Assistance fuding amount of $9,410,895 only provided benefits for32,843
households. The average benefit for those households that received funding assistace was $286
for the winter heating season. An additional $19,492,902 would have been needed to cover all
101,000 eligible households.
LIHEAP provides additional assistance for customers who are on the verge of having
their utilties disconnected. These "Crisis Funds" are allocated independent of regular LIHEAP
fuds and are tageted to help customers whose disconnection is imminent. "Crisis Funds" must
be used to pay energy bils for the household's primar heating source, and are available
regardless of whether or not the household has previously received a benefit. Presently, the
funds are very limited. In Idaho, LIHEAP "Crisis Funding" has only been available for the past
two heating seasons.
Fuel Funds
Fuel fuds are programs that help people pay home heating costs. The major programs
in Idaho - Project Share, Project Warth, and Lend A Hand - are administered by nonprofit
agencies.
Project Share 7
Project Share provides up to $300 anually per household regardless of the household
heating source. The program is a fuel-blind fud, i.e., monies are dispersed toward payment of
4 Appendix 6 contains a LIHEAP funding matrix.
5 A Federal Block Grant funds the LIHEAP program.
6 See Appendix 5 (Idaho Community Action Agencies).
7 Appendix 7,8 and 9 contains Project Share fuding and disbursement amounts.
STAFF COMMENTS 5 NOVEMBER 26, 2008
bils that are for any energy source (electric, natural gas, wood, coal, propane, kerosene or oil).
Project Share is fuded by contributions made by utility customers, employees and shareholders.
All money collected, with the exception of administrative costs, is returned to the community.
Funds for the program are administered by the Salvation Ary in southern Idaho. In northern
Idaho, Project Share funds are administered by the Community Action Parership and Spokane
Neighborhood Action Programs. A vista, Idaho Power and Intermountain Gas promote Project
Share and offer customers the opportunity to make contributions when paying their utilty bils.
Project Warmth8
Project Warth provides financial assistace to individuals regardless of the household
heating source. This program is a fuel-blind fud that was created for individuals who reside in
southeastern Idaho because Project Share fuding was not available in that region. The primar
source of fuding is derived through a yearly golf tourament. Intermountain Gas, Rocky
Mountain Power, the Southeastern Idaho Community Action Agency, Monsanto, Agrium,
Washington Group, City of Soda Springs, and Caribou County Indigent Services help organize
the tourament. All money collected, with the exception of administrative costs, is retued to
the community. To be eligible, recipients must be at or below 125% of the Federal Poverty
Guidelines and can receive an anual household benefit of up to $200. The program is modeled
after Project Share. Funds for the program are administered through the Southeastern Idaho
Community Action Agency.
LendA Hancf
Lend A Hand provides financial assistance to Rocky Mountain Power (RMP) customers
with electric space heat. Funding is provided through contributions by RMP customers,
employees, and shareholders. All money collected, with the exception of administrative costs, is
returned to the community. To be eligible, recipients must be at or below 150% of the Federal
Poverty Guidelines. Recipients can receive an annual household benefit of up to $400. Funds
for the program are administered through the Southeastern Idaho Community Action Agency and
the Eastern Idaho Community Action Parnership.
8 Appendix 9 contains Project Warmth fuding and disbursement amounts.
9 Appendix 10 contains Lend A Hand fuding and disbursement amounts.
STAFF COMMENTS 6 NOVEMBER 26, 2008
Keep Kids Warm10
Keep Kids War provides financial assistace to individuals regardless of the household
heating source. The fuel-blind program was started in 1996 by KIZN radio (Boise) to assist
households with their heating needs. Intermountain Gas parners with KIZN radio to assist in the
fundraising efforts through pledge cards and a yearly radio broadcast telethon. All money
collected is retued to the community; there are no administrative fees or other costs associated
with administering the program. Over $650,000 has been raised since the program's inception.
Benefit amounts are determined on a case-by-case basis. Funds for the program are administered
through El-Ada Community Action Agency, Western Idaho Community Action and the Malheur
C?uncil on Aging and Community Services in Oregon.
Low-Income Weatherization
Weatherization increases energy effciency by reducing heat loss and addressing air
infiltration issues. Measures taen to improve energy effciency include the following: attic,
floor and wall insulation; repairing or upgrading windows, ventilation, duct insulation and
sealing; caulking; and weather stripping. Additional measures may include switching the
customer to compact fluorescent light bulbs and furnace (or AC unit) repair or replacement.
Energy conservation education is provided to customers whose homes are weatherized.
Low-Income Weatherization Assistance is administered by community action agencies
throughout Idaho as well as the Canyon County Organization on Aging. Applicants who own or
rent single family, multi-family, or manufactued homes that qualify for LIHEAP fuding
automatically qualify for Weatherization Assistace. The administering agencies determine
income eligibility. Households with incomes at 160% of the Federal Poverty Guidelines or less
automatically qualify to receive weatherization services. An energy audit is performed by the
administering agency before a home is weatherized.
According to CAP AI, the average investment per weatherized home in 2007 was $3,674.
The number of homes that need to be weatherized greatly exceeds the fuding that is available.
10 Appendix 9 contains Lend A Hand funding and disbursement amounts. Additional guidelines for Project Share,
Project Warmth, Lend A Hand and Keep Kids War can be found in Appendices 10 and I I.
STAFF COMMENTS 7 NOVEMBER 26, 2008
Currently, only 10% of homes receiving LIHEAP benefits are weatherized because of the lack of
available fuds.
The table below reflects the total dollars spent on an anual basis for weatherization, the
number of households weatherized, and the average investment per household. ii
Average Home
Investment
$3,365
$3,674
Year
2006
2007
Dollars Spent
$4,913,645
$5,081,900
Homes
1,460
1,383
Funding for the Weatherization Assistace Program comes from several sources, including the
U.S. Deparment of Energy (DOE) and energy utilties.
Curent anual utilty funding levels for low-income weatherization are as follows:
. Idaho Power, $ 1 ,200,000;
. Avista, $465,000; and
. Rocky Mountain Power, $150,000.
Utilty Energy Efficiency Programsii
In addition to low-income weatherization programs, most of the utilities offer a variety of
different residential energy efficiency programs.
Rocky Mountain Power offers: 1) Refrgerator/Freezer Recycling; 2) Home Energy
Savings; 3) Idaho Time-of-Day Metering; and 4) On-line and Mail-in Energy Analysis.
Avista offers: 1) Senior Energy Conservation Workshops; 2) Energy Conservation
Education Programs for Children; 3) High Effciency Equipment Incentives; 4) CFL Lighting; 5)
Refrigerator Recycling Program; 6) Conversion from Electric Straight Resistance; 7) Energy Star
Appliances; 8) New Construction Energy Star Homes Program; 9) Multi-Family Energy
Efficiency Program; 10) Rooftop Dampers; and 1 1) Home Energy Analyzer.
Idaho Power offers: 1) Energy Star Home Products; 2) Energy Star Lighting; 3) Energy
Sta Homes; 4) Rebate Advantage; 5) Energy House Calls; and 6) Air Conditioning Cool Credit.
Intermountain Gas offers the High-Efficiency Gas Furace Rebate Program.
11 Appendix 12 outlines utilty weatherization program funding guidelines and amounts.
12 A summar of these programs can be found in Appendix 13.
STAFF COMMENTS 8 NOVEMBER 26, 2008
PROPOSALS TO ADDRESS ENERGY AFFORDABILITY
Bil Payment Assistance
During the workshops, paricipants discussed financial assistance that could be made
available to customers for the payment of energy bils. Five ways to provide new or additional
funds for bil payment assistance were discussed: 1) create utilty programs designed to to help
low-income customers pay energy bils fuded by all utilty customers through rates; 2) increase
voluntar contributions to nonprofit fuel fuds; 3) increase federal fuding for the Low-Income
Home Energy Assistance Program (LIHEAP); 4) increase LIHEAP fuding received by Idaho
through leveraging; and 5) create a program fuded by Idaho state tax revenue to provide
financial assistance to low-income households.
Implement Utilty Programs Designed to Provide Financial Assistance
Avista offers programs in Oregon and Washington to help customers pay energy bils.
The Low-Income Rate Assistance Program (LIRAP) is intended to ease the home energy
burden13 for Avista's residential customers who have limited incomes. The program serves as an
additional resource for financial assistance. In Oregon, LIRAP may be used in conjunction with
or in lieu of assistance provided by other programs such as LIHEP (Low-Income Home Energy
Program)14 and Project Share. In Washington, LIRAP can be used in conjunction with or in lieu
of assistance that is provided by other programs, such as Project Share, but canot be used in
conjunction with LIHEAP (Low-Income Home Energy Assistance Program).
Funding for LIRAP differs between Washington and Oregon. In May 2001, the
Washington Utilties and Transportation Commission approved a Public Purpose Rider
Adjustment to fund Avista's Demand Side Management services and LIRAP. The rider amount
varies by customer class and applies to both electric and gas usage on a per kWh and therm
basis. The LIRAP portion of the surcharge was designed to produce a fuding level of
approximately 0.79% of base rates under Schedule 91 and 19i.IS
The Public Utilties Commission of Oregon approved LIRAP as a stand-alone program
authorizing Avista to implement a surcharge of $0.00438 per therm for gas consumption. The
13 "Energy burden" is the percent of household income spent on all home energy expenses - this includes energy
used for heating and cooling, lighting, and hot water tanks.14 In Oregon, LIHEP is the term used to refer to the federal LIHEAP program.
15 See Appendix 14 for Washington's rate schedules.
STAFF COMMENTS 9 NOVEMBER 26, 2008
surcharge applies to residential customers and is designed to produce a fuding level of
approximately .05% of base rates under Schedule 493.16
In both states, A vista provides the collected LIRAP revenue to community action
agencies which administer the program in a similar maner to LIHEAP fud administration.
Factors such as anual household income, estimated anual home energy costs, and tye of
housing (i. e., single family or multi-family) are used to determine the amount of assistance
granted to customers. Typically, recipients ofLIRAP in both Washington and Oregon are well
below poverty leveL. To qualify for LIRAP in either state, a family of four who is at or below
100% of the Federal Povert Guidelines would have a household income of $ 1,760 or less per
month. Last year, approximately 75% of Washington and 65% of Oregon LIRAP recipients had
household incomes under $15,000. One-third ofLIRAP participants in both Washington and
Oregon have household incomes under $8,000.
Avista's LIRAP program also fuds its Senior Outreach Program and Energy
Conservation Program. Washington's Senior Outreach Program helps to identify senior citizens
who need assistance with their energy bils. Although some seniors may have incomes that
exceed the ceilng for LIHEAP or LIRAP grants, other major expenses, such as medical costs,
can leave seniors unable to pay their home energy bils. The Senior Outreach Program has
successfully assisted those who fall into this situation with a Senior Energy Outreach grant. The
grant funding amount is comparable to a LIHEAP or LIRA grant.
Conservation education is also fuded by the surcharge. Paricipants receive either
written material or classroom instruction through workshops and seminars. The education
program is being expanded to encourage school-aged children to conserve energy as well.
Neither the A vista Senior Outreach Program nor the Conservation Energy Program is
offered in Idaho due to lack of funding. ICAN and CAP AI support implementation of a LIRAP
for Idaho. A vista is willng to extend its program to Idaho with Commission approval.
Recommendation
The LIRAP program would be beneficial for Idaho's low-income utilty customers.
LIRAP would provide additional funds to supplement existing federal LIHEAP fuds, allowing
more people to obtain the financial assistance needed to pay their energy bils. Because LIRAP
16 See Appendix 15 for Oregon's rate schedules.
STAFF COMMENTS 10 NOVEMBER 26, 2008
is administered through community action agencies, the infrastructue for the program is already
in place in Idaho.
17
Implementing a LIRAP program in Idaho would likely require legislation. Idaho Code §
61-315. Also, utilties expressed concern that, should LIRAP be implemented in Idaho, a
surcharge appearng on customer biling statements could impact donations given to other
financial assistance programs such as Project Share. Aside from the fact that a surcharge or taiff
rider would not necessarily need to appear as a separate line item on a utility bil, it is Staffs
opinion that any decrease in voluntar contributions would be more than made up by fuding
derived from a LIRAP program targeted to helping customers pay their utilty bils and conserve
energy.
Staff recommends that the Commission support legislation to allow it to adopt a LIRAP
program. Specifically, the legislation should allow the Commission to:
· implement programs for the benefit of low-income residential customers,
including bil payment assistace.
· approve rates or charges designed to recover the costs of such programs.
It is Staffs understanding that CAPAI is sponsoring a bil curently before the Idaho
State Legislature. However, Staff does not have enough information to comment at this time on
CAP AI's bil.
Increase Customer Awareness oU Encourage Voluntary Contributions to Nonprofit Fuel
Funds
All workshop paricipants agreed that increasing customer and community awareness of
nonprofit fuel funds would be beneficiaL. Given the curent economic crisis, donations made to
financial assistance programs could potentially decrease at a time when the need for assistance is
even more criticaL. Utilties curently publicize programs such as Project Share, Project Warth,
Keep Kids War and Lend A Hand through their websites, newsletters, and monthly customer
bilings.
To raise public awareness and encourage volunta contributions in the past, A vista,
Rocky Mountain Power, and Idaho Power enlisted parners in the community. The businesses
17 As an example, the Community Action Parership Agency in nortern Idaho already administers LIRAP for
Avista customers in Washington State.
STAFF COMMENTS 11 NOVEMBER 26, 2008
offered products for sale, with a percentage of the proceeds donated to local fuel fuds such as
Project Share or Lend A Hand. Unfortunately, Rocky Mountain Power and Idaho Power have
discontinued their parnering programs. Intermountain Gas curently parners with KIZN radio
for a yearly telethon fudraiser and golf tourament for the Keep Kids Warm program.
Recommendation
All workshop participants were in agreement with the need to increase awareness about
nonprofit fuel fud programs in order to increase the amount of funding received. Increased
awareness improves the potential for donations, thereby assisting more individuals who are in
need. Efforts to increase awareness do not require legislåtive or Commission involvement.
Utilty companies are encouraged to continue with their creative efforts to make those in the
community more aware of nonprofit fuel funds. Staff also encourages each utilty to set goals
for fud raising and continue the implementation of programs that parner with local businesses.
Increase Federal Funding for LIHEAP
The 2009 LIHEAP Energy Assistace fuding available to the State of Idaho has been
budgeted at $17,439,570. This represents a one-time $8,028,675 increase from last year's
budgeted amount of $9,410,815. In response to increased fuding, average benefit amounts for
eligible paricipants is projected to increase to $386 from last year's average benefit amount of
$286. Additionally, by changing the level at which a household is eligible to receive assistance
from a maximum of 150% to 160% of the Federal Povert Guidelines, the number of eligible
households is projected to increase from last year's 101,000 to 111,100.
Leveraging is a process through which federal LIHEAP fuding can be increased.
Essentially, the Federal governent withholds a percentage ofLIHEAP money allocated to each
state as an incentive for that state to first acquire non-federal fuds for assistace to low-income
households. Grants are awarded to states that use their own or other non-federal governent
resources or private fuding to increase the total amount of assistance available, thereby
leveraging federal fuding. Last year, $52,000 in LIHEAP leveraging grants were provided to
the State of Idaho and were used by CAP AI and local community action agencies to provide bil
payment assistance and weatherization. All paricipants agreed that obtaining additional federal
STAFF COMMENTS 12 NOVEMBER 26, 2008
fuding for LIHEAP through leveraging would benefit both customers and utilties. In workshop
discussions, it was apparent that few participants were aware of the leveraging concept.
Recommendation
All workshop paricipants agreed that an increase in federal fuding for LIHEAP would
be beneficiaL. Additional LIHEAP funds would allow more utilty customers to obtain financial
assistace. While increased fuding for the curent heating season will certainly benefit
customers, the anual struggle for additional federal fuding for LIHEAP remains. Support by
Idaho's Congressional delegation is an important factor in securing Congressional budget
approval. Staff recommends that a dialogue be initiated with Idaho's Congressional delegation
regarding increased awareness ofLIHEAP's value and the critical need for additional program
funding.
Leveraging is a significant tool through which Idaho can increase its federal LIHEAP
fuds. Unfortunately, not everyone was aware of the program. Staff recommends that utilties,
Commission Staff, and other interested paries partner with CAP AI to identify ways in which to
leverage existing federal LIHEAP funding.
Create a State-Funded Financial Assistace Program
All workshop paricipants agreed that a program funded by state tax revenue to
supplement federal LIHEAP fuds would be beneficiaL. Additional fuding would have the
potential to increase the number of customers who would receive benefits and/or increase benefit
amounts.
Recommendation
A new state program to supplement federal LIHEAP fuding would require legislative
involvement and support. Given a projected decrease in State revenue this fiscal year, it appears
unlikely that such a program would be created and funded in the near term. Staff believes that
this proposal, though a good idea, should not be pursued at this time.
STAFF COMMENTS 13 NOVEMBER 26, 2008
Bil Reduction
Bil reductions can be realized by decreasing consumption, reducing prices, and changing
rate designs. During the workshops, the following topics were discussed: 1) offering reduced
rates to low-income customers; 2) encouraging energy effciency; and 3) designing rates to
encourage energy efficiency.
Reduced Rates for Low-Income Customers
One option for reduced rates is a fixed discount, usually expressed as a percentage off the
regular residential rate. The State of California implemented the CARE program (California
Alternative Rates for Energy). 18 It provides a 20% discount on monthly electric bils (rates and
basic charge) for qualified low-income or fixed-income households and housing facilities.
CARE is fuded through a rate surcharge ($0.399 kWh) paid by all other utilty customers.
Eligibility is based on household income.
19 Utilities administer the program and paricipants
enroll through a one page self-certification application. Utilties conduct a random audit
sampling of paricipants to ensure that they meet the program requirements. Recertification is
required every two years. There is no cap on the number of paricipants.
Another option is a tiered discount, with the discount varing by income. The State of
Washington implemented a program that provides a three-tiered discount on monthly electric
bils for qualified low-income and fixed-income customers?O Funding for the discount is
provided through a fixed monthly surcharge of $0.44 for all other residential customers and a
fixed monthly surcharge of $ 1 47.00 for industrial customers. Eligibilty is based on income
leveL. The credit received is based on customers' income using the Federal Poverty Guidelines
and is only applicable for usage greater than 600 kWh?1 Community action agencies determine
applicant eligibilty. A maximum of 4,475 customers are allowed to participate anually during
the four months that the program is in place (November-April). Benefits are provided on a "first
come, first served" basis for eligible applicants.
18 See Appendix 16 for Californa's rate schedule.
19 For example, to quality for the CARE Program, the maximum household income for a family of four is $43,200.
20 See Appendix 17 for Washington's rate schedule.
21 For usage over 600 kWh, customers with income 75% of
below of the Federal Povert Level (FPL) pay $0.3812
per kWh. For income 76-100% of povert, the amount paid is $0.2565 kWh, and for income 101-125% FPL, the
amount paid is $0.1603 kWh.
STAFF COMMENTS 14 NOVEMBER 26, 2008
Another option for assisting low-income customers is the elimination or reduction of the
customer's monthly service charge. However, this would result in a revenue deficiency for the
utility that must then be recovered from other customers. It is likely that the cost per kWh or
therm would have to be increased to make up for revenue lost from reduced monthly service
charges. This shift from deriving revenue through monthly service charges to energy charges
would most likely have a disproportionately negative impact on low-income customers because
they typically live in less energy-efficient homes and use relatively large amounts of energy.
ICAN was the most vocal in supporting elimination of the monthly service charge for
low-income customers.
Recommendation
Enactment of these or similar programs would require legislation and Commission
approvaL. Programs based on customers' incomes are diffcult for utilties to administer.
Information regarding customers' income is not routinely collected. The State of Washington's
three-tiered discount program is limited to 4,475 customers and is in effect for only four months
annually. Because of the cap placed on the number of paricipants, many eligible customers
might be prevented from receiving the program's benefits. Neither Washington or California's
programs promotes energy efficiency for those that are enrolled in the programs. However, it
may inadvertently encourage effciency among non-paricipants who are funding the subsidy.
Staff does not presently recommend the adoption of reduced rates for low-income
customers. There are other, preferable options available for the Commission to consider. The
utilties also do not support low-income rates and prefer increased awareness and funding of
energy efficiency to reduce customer costs.
Low-Income Weatherization. Conservation Education. and Other Energy Effciency Programs
During the workshops, many different methods to encourage energy effciency were
discussed. These methods included: weatherization, energy conservation education, programs
tageted to low-income customers and seniors, and overcoming bariers to investment in energy
efficiency measures for manufactured homes and rental housing.
STAFF COMMENTS 15 NOVEMBER 26, 2008
All workshop paricipants were in agreement that weatherization is an excellent way to
reduce energy costS.22 According to CAP AI, the average investment per home weatherized in
2007 was $3,674. As previously stated, currently only 10% of homes receiving LIHEAP
benefits are weatherized due to the lack of available fuds?3
Idaho Power recently created the Home Weatherization Pilot Program. This program is
targeted to customers who do not qualify for other weatherization assistance because their
income exceeds the allowable leveL. The Home Weatherization Pilot Program (HWP) will
provide weatherization services to twenty electrically heated homes served by Idaho Power in its
southern region. Program paricipants wil be selected from a list of Idaho Power customers who
apply for LIHEAP benefits through the South Central Community Action Partnership. To
paricipate in the HWP pilot, a residential customer's anual income must be between 151 % and
250% of the federal povert level and the household must use electricity to heat the home.
Weatherization efforts are often coupled with energy conservation education. Workshop
paricipants agreed that a need exists for fuher education. Unfortately, as with
weatherization, the fuding for energy conservation education targeted to low-income customers
is extremely limited.
In the State of Washington, energy conservation education is provided to Avista's
customers through the LIHEAP and LIRAP grant programs. Participants either receive written
material or classroom instruction through workshops and seminars. This past heating season,
A vista customers who received either a LIHEAP or LIRAP grant received a letter from A vista
with conservation tips and coupons for a free florescent light bulb and fuace fiter. A vista is
also providing, at the customer's request, a DVD on energy conservation. The conservation
education program is being expanded to encourage school-aged children to conserve energy.
The Children's Energy Conservation Education Program was designed by Avista to educate low-
income elementary age children and families about changing lifestyle habits and using energy
more efficiently.
As par of Avista's energy efficiency program in Idaho, this Commission recently
approved, as par of a settlement in Case No. A VU-E-08-0 1, $25,000 to be used by local
22 With the exception ofIdaho Power, the utilties fud low-income weatherization programs through energy
effciency tariff riders. Idaho Power's low-income weatherization funding is included in its base rates.
23 See Appendix 12 for a matrix that highlights the schedules and features of the utilty funded low-income
weatherization programs.
STAFF COMMENTS 16 NOVEMBER 26, 2008
community action agencies for low-income outreach and energy conservation education. In both
Washington and Idaho, Avista conducts Senior Energy Conservation Workshops at a variety of
different locations such as senior centers, senior nutrition meal sites, and non-profit
organizations. The goal of the workshops is to provide education on energy savings for seniors
while allowing for comfort and safety with home energy use. All workshop paricipants receive
an "Every Little Bit" Energy Conservation Kit which contain compact fluorescent light bulbs,
home weatherization supplies and energy saving tips. A vista began this program when it came
to the Company's attention that seniors on fixed incomes tend to reduce their use of heat in order
to cut monthly heating expenditures so that they are able to pay for medication and food.
Rebates are another example of energy efficiency programs offered by the utilties as an
incentive to customers. Idaho Power, Rocky Mountain Power, A vista, and Intermountain Gas
each have one or more energy efficiency rebate programs with varying degrees of incentives for
their customers.
Idaho Power provides incentives to residential customers for replacing low efficiency
appliances with high efficiency Energy Sta appliances, including clothes washers, refrigerators,
light fixtures and ceiling fans. A vista also provides rebates to customers for the replacement of
low effciency appliances, including clothes washers, freezers, dishwashers and refrigerators.
Rocky Mountain Power provides rebates to nonprofit groups that install conservation measures
for the purose of weatherizing low-income homes. Rocky Mountain also has a program entitled
"See Ya Later Refrigerator." This is a program that, free of charge, removes an old refrigerator
from a customer's address and dismantles it so the inefficient refrgerator won't be put back into
service again at another address. Intermountain Gas provides a $200 rebate to a customer that
installs a minimum of a 90% effcient fuace when converting from another energy source.
Unfortately for customers looking to improve efficiency, a gas-to-gas conversion does not
qualify to receive a rebate even if the customer is converting from an inefficient fuace to one
with a high efficiency rating.
All of the major electric utilities in Idaho provide rebates to builders and homeowners
who install certin high efficiency appliances in new homes.24 Builders who install energy
efficient equipment in new homes and aparment buildings not only increase the attactiveness of
24 Energy efficiency programs that offer builder incentives are fuded by tariff riders. The cost is borne by utility
customers as a whole.
STAFF COMMENTS 17 NOVEMBER 26, 2008
the property to prospective buyers and renters, but also have a long-term impact on energy
consumption within that home. Promoting energy effciency standards for new construction is
one way to assure that energy efficient housing will be built.
In addition, Idaho Power and Avista paricipate in Energy StarOO Homes Northwest. The
program promotes the construction and sale of new residential homes that are built to the
program's specifications in Washington, Oregon, Idaho and Montana. The program promotes
the purchase of homes that are 20% more energy efficient through high efficiency lighting,
windows, appliances, water heaters, insulation, and heating and cooling equipment. The
program also provides incentives to builders, suppliers, and subcontractors who construct energy
efficient homes.
Customers who live in multi-family, manufactured and single-family rental housing face
unque obstacles with respect to investing in energy efficiency measures. Energy House Call is a
program offered to Idaho Power customers who live in manufactured homes that are heated by
an electric fuace or heat pump. Through local certified contractors, at no cost to the customer,
a leak assessment is performed on the electrical heating system ducts. All leaks are sealed and
compact fluorescent light bulbs and air fiters are installed. Idaho Power's Energy Effciency
Rider funds this program.
Recommendation
Energy effciency measures save customers money. Unfortunately, some low-income
and limited income customers do not have the financial resources to weatherize their homes or
invest in new appliances. Even though weatherization programs are available in all areas, the
programs rarely have enough funding to meet the need. Weatherization programs are the most
direct way to reduce energy costs for low-income customers. In addition, energy conservation
education is most effective when offered in conjunction with bil payment assistace and
weatherization services. With increased fuding for weatherization and energy conservation
education for low-income customers, those most in need will be provided with valuable,
individualized assistance.
To the extent that existing utilty programs are not adequately funded, fuding should be
increased. The adequacy of program fuding is most appropriately addressed during utilty rate
or other formal cases. Therefore, Staff recommends that weatherization and conservation
STAFF COMMENTS 18 NOVEMBER 26, 2008
education program fuding be addressed in future cases before the Commission. Staff fuher
recommends that Idaho Power, Intermountain Gas, and Rocky Mountain Power develop a
conservation education program targeted to low-income customers that is modeled after Avista's
energy conservation education program.
Staff also recommends that all utilities examine how more incentives could be offered to
customers for conversion to higher efficiency appliances. In addition, Staff recommends that all
utilties consider providing no-interest/low interest loans to customers for the purose of adding
high effciency appliances - paricularly for those customers who fall just outside the income
guidelines to qualify for low-income weatherization.
Finally, Staff recommends that utilties advocate adoption and implementation of energy
efficient construction standards. Staff recommends that utilties encourage the Northwest Energy
Efficiency Allance to include multi-family and manufactured homes in the Energy Star Home
Program. Because few programs are available to assist customers living in multi-family,
manufactured, and single-family rental housing, Staff fuer recommends that the utilties
consider programs that could assist customers in overcoming the unique obstacles these types of
properties present.
Design Rates to Encourage Energy Effciency
Workshop paricipants were very interested in the concept of rate design and how it can
be used to promote energy effciency and benefit low-income and limited income customers. In
response to interest in the subject, Staff provided a brief tutorial on rate design at the workshop
on October 22, 2008.
Effective rate design promotes efficient consumption of energy through proper pricing.
There are many ways that rates can be designed to reflect the variable cost to serve utilty
customers. Tiered rates and time-of-use (TOU) rates are good examples of rates that provide
proper price signals that in tur encourage customers to change behaviors, which ultimately
affects the dollar amount of their utility bil. An important advantage to tiered rates over time-
of-use metering is that special metering equipment is not required. Tiered rates seek to lower
overall usage, which may delay the need for a utility to acquire highly capital-intensive base-load
facilities.
STAFF COMMENTS 19 NOVEMBER 26, 2008.
Tiered rates are biled in blocks, and if customers are provided with proper education
regarding tiered-rate structures, they wil become accustomed to how their consumption affects
their overall bil. Tiered rates are not necessarily low-income rates; they are efficiency-based
rates. Tiered rates provide lower basic prices for customers that use less energy. A higher rate
for energy in the third block (often referred to as the "tail block") provides a greater incentive to
utilze energy efficiency measures.
Tiered rates are not new to Idaho. Idaho Power currently has a two-tiered rate strcture
for residential customers during the sumer period. A vista also has a two-tiered rate structue
for residential customers in Idaho. Although Rocky Mountain Power has a flat rate structure in
Idaho, it has offered optional time-of-use metered rates to residential customers for many years.
During the workshops, Idaho Power expressed concern about a tiered rate structure
disproportionately affecting its customers with all-electric homes or low-income customers who
live in energy-inefficient homes.
Recommendation
Staff recommends that utilities consider tiered rates for residential customers as a way to
give customers control over their bils by providing an incentive to lower their energy
consumption. Due to the complexity of rate design issues and the potential for unintended
consequences, Staff recommends that tiered rate design be addressed within the context of future
rate cases.
Bil Mitigation
The objective of bil mitigation is to make energy bils more manageable by offering
flexible payment options or determining customer-specific affordable payment amounts.
During the workshops, two means by which to provide payment assistance were
discussed: 1) offer plans that allow payment of arrears (past due amount owed) over an extended
length of time (more than 12 months), and 2) offer a percentage of income payment plan.
Offr Plans that Allow Payment of Arrears Over an Extended Length of Time
All energy utilties offer payment arangements to customers who are experiencing
difficulty paying their utility bils in full. The Commission's rules require utilties to take into
STAFF COMMENTS 20 NOVEMBER 26, 2008
account the amount of the customer's arearage, past payment history, the circumstances and
reasons why the debt is outstanding, and the customer's abilty to pay. See UCRR 313.
However, if a customer fails to adhere to the payment arangement, the utilties are not obligated
to enter into a second such agreement. Each utility offers both short-term (30-45 days)2s and
long-term (up to 12 months) 26 payment arangements, though the terms of the arangements can
var from one utilty to another. It would be unusual for a customer to be allowed to make
payments over a period of time greater than 12 months. On average, about 50% of payment
arangements end in default. Many customers agree to payment arrangements that they know
they cannot meet in an attempt to prevent immediate disconnection.
Several of the workshop paricipants expressed a strong desire for the utilties to consider
payment plans that fit the customers' circumstances and needs as opposed to adhering to the
companies' more limited existing options.
Recommendation
As previously stated, customers are facing an array of issues that are impacting their
abilty to pay utility bils. It is likely that an increasing number of customers will need to make
payment arrangements. Staff recommends that utilities become more flexible in negotiating
payment arangements, offering extended payment timelines and working with each customer to
ensure that payments are affordable based on the customer's individual circumstances. Staff
recognizes the potential for utilities to incur higher bad debt if customers continue to default on
payment arrangements. However, by offering customers payment arangements that are more
flexible and tailored to the each customer's needs, utilties stad to benefit by a reduction in the
number of broken payment arangements and subsequent disconnections. Ultimately,
empowering customers to be successful in paying off arears benefits both customers and
utilties.
25 For example, Intermountain Gas requires that a customer pay a portion of their past due amount immediately, with
the remaining balance and the most recent bil being paid in installments during a 45 day time frame. Idaho Power
requires eligible customers to pay half of their past due balance or the 6 I -90 day balance, whichever is greater,
immediately with the remaining balance due within 30 days.26 For example, Rocky Mountain power has a Time Payment Program which allows customers to pay their past due
balance over an agreed upon period up to 12 months in addition to their current monthly biling based on actual
usage. A vista has a Levelized Payment Plan that allows customers to pay their past due balance over a i 2 month
period in addition to their curent monthly biling.
STAFF COMMENTS 21 NOVEMBER 26, 2008
Implementation of new payment arangement alternatives can be accomplished through
cooperation with the utilties and making modifications, if necessary, to the Commission's rules.
More investigation and study of alternative payments plans would be beneficial to all
paries. To that end, Staff recommends that Commission Staff and the utilties conduct fuher
workshops to confer and attempt to identify solutions.
Offr Percentage of Income Payment Plan
Under a percentage of income payment plan, customers pay a specified percentage of
their income toward their utilty bils, regardless of the amount actually owed to the utility. For
example, in Ohio, customers can sign up for the Percentage of Income Payment Plan (PIPP).
Under PIPP, customers with gas space heating pay 10% of their monthly household income to
their gas utilty and 5% to their electric utilty. If a household's income is at or below 50% of the
Federal Poverty Level, then only 3% of the household income is required for electricity. If a
household is served by the same company for both gas and electric service or if the household
heats with electricity, 15% of the monthly household income is paid to the utilty providing
service. The program is administered by community action agencies. Applicants must have a
total household income at or below 150% of the Federal Poverty Level and must apply for all
energy assistance programs for which the household is eligible. The program enables customers
to budget for their utilty bils, since they pay a set amount each month.
Recommendation
Although Staff agrees that a percentage of income payment plan would reduce in most if
not all instances the amount that low-income customers would have to pay for energy, there are
several major impediments. By separating actual usage from the amount a customer is required
to pay, a percentage of income plan does nothing to encourage energy conservation. In addition,
implementation of a percentage of income payment plan would require modification of utilities
biling systems. New legislation would likely be required in order to allow utilties to offer such
a plan, since it would establish disparate rates within the residential class based on income.
Finally, utilties do not support this type of payment plan. Due to significant obstacles including
utility opposition, Staff recommends that this option not be pursued at this time.
STAFF COMMENTS 22 NOVEMBER 26, 2008
Reduction of Customer Costs
The reduction of customer costs involves lowering or eliminating charges associated with
making a payment, reconnecting service following disconnection for non-payment, and interest
assessed on late payments.
Reduce/Eliminate Payment Charges and Educate Customers On No Cost/Low Cost Options
Customers are often charged "convenience fees" when paying utilty bils via telephone
or the Internet using credit or debit cards or electronic checks. Although customers often think
that utilties collect and keep the fees, it is actually third-pary vendors who process the payments
on behalf of the utilties that charge and retain the fees. Idaho energy utilty customers can pay
fees of up to $5.25 per transaction. Depending on the amount owing, more than one transaction
fee may be incured in order to pay a bil.
Unfortunately, customers sometimes delay making utilty payments until the last minute.
For customers with limited means, last minute payment options are a necessity, not merely a
convenience. Moreover, convenience fees fuher reduce the total amount of money available to
pay bils. Because so many customers now use these options to pay, Staff recommended in a
recent rate case that the utilty begin to explore options of how it can eliminate convenience fees.
Intermountain Gas provides a free web-based option for paying bils to customers with
checking accounts.
A customer has some options for payment of his or her utilty bil without charge.
Customers who live in close proximity to a local utilty offce can pay in person; however, not all
utilty offces accept payments. Although some utilties have drop boxes outside field offices,
payment by check or money order, not cash, is required, which poses a problem for customers
who do not have checking accounts or prefer to pay in cash. For a customer who needs to pay
his or her bil immediately to keep service connected, payments placed in drop boxes are not
processed timely enough to prevent disconnection.
Many utilties contract with local businesses to set up pay stations in varous locations
around their service areas. These are often found in grocery stores or small convenience stores.
Some, but not all, payment stations charge fees (usually $ 1.00 to $ 1.50) for processing payments.
STAFF COMMENTS 23 NOVEMBER 26, 2008
Recommendation
Utilties have an obligation to better inform customers of payment options and the fees
associated with some types of payments. Staff recommends that there be more study and in-
depth discussion among all interested parties regarding how convenience fees can be eliminated
or reduced.
Reduce or Eliminate Reconnection Charges and Interest Assessed on Late Payments
All energy utilities charge for reconnection of service. Charges vary according to when
reconnection takes place. All energy utilities also have provisions in their tariffs to assess 1 %
interest on past due balances each month (12% per anum). Some energy utilties assess interest
to balances owing under payment arangements that extend over a period of time. This practice
provides no incentive for customers to make payment arangements.
Recommendation
For low-income customers and customers with a limited abilty to pay, interest charges
on past due balances simply increase the amount owed. Implementing a policy to waive
reconnection or interest charges only for low-income customers could be considered
discriminatory. See Idaho Code § 61-315. In addition, these tyes of policies would require
Commission approval for tariff changes. Staff recommends that there be more study and in-
depth discussion among all interested paries regarding the circumstances, if any, under which
reconnection and interest charges could be eliminated.
Remove Barriers to Obtaining or Retaining Service
During the workshops, several ways to reduce bariers to obtaining or retaining service
were discussed: 1) modify deposit policies; 2) allow former customers to pay prior bils in
installments; and 3) offer arrearage forgiveness plans.
ModifY Deposit Policies
Deposits often pose an insurountable obstacle to customers who are low-income or
financially-constrained. A former customer who owes an unpaid bil from previous service may
be required to pay a deposit before new service is provided. An existing customer whose service
STAFF COMMENTS 24 NOVEMBER 26, 2008
is disconnected for non-payment may be required to pay a deposit before service wil be
reconnected. In addition to paying a deposit, the customer may be required to pay the amount
owed as well as a reconnection fee.
When faced with a situation where a large amount of money is required before service is
reconnected or provided, desperate customers sometimes look for ways to avoid the requirement,
such as using a roommate's, child's or other relative's name and social security number to obtain
service. Unfortunately, this poses problems down the road for the person whose name was used
and does nothing to address the most pressing problem of paying the prior or past due bilL.
If a utilty chooses to collect a deposit, the Commission's Utilty Customer Relations
Rules (UCRR) allow customers to pay the deposit in installments. Rule 105, UCRR, provides
for payment of one-half of the deposit at the time of sign up or reconnection and the other half
the following month. In accordance with its own tarff, Intermountain Gas allows the deposit to
be divided into three equal payments. Idaho Power is the only gas or electric utilty that has
chosen not to collect deposits. Idaho Power ceased collection of residential deposits more than
twenty years ago due to the high administrative costs associated with collecting and managing
deposits. Staff is not aware of any recent studies that demonstrate a correlation between
collection of residential deposits and improved customer payment habits and/or fewer utilty
wrtten-off accounts.
Alternatives to existing deposit policies explored durng the workshops include: 1)
allowing payment over an extended period of time; 2) reducing the dollar amount of deposits; 3)
waiving deposits under certin circumstaces; or 4) deferring collection of a deposit subject to
futue payment performance. These alternatives can be implemented by utilities voluntarily.
However, changes to the Commission's rules might be necessar.
Recommendation
Staff recommends a more in-depth discussion among all interested paries of the
alternatives identified above. Staff also recommends that one or more utilities conduct a study of
the effectiveness of collecting residential deposits.
STAFF COMMENTS 25 NOVEMBER 26, 2008
Allow Installment Payments on Prior Bils
A utility customer sometimes discovers, when attempting to sign up for new service, that
he or she has a prior unpaid bil. With the exception of Avista, Idaho's gas and electric utilties
require a customer's old bil to be paid in full prior to granting new service. The policy of
requiring full payment of an old bil prior to connecting new service is often an obstacle for low-
income customers.
The consequences of being denied service can lead to drastic and sometimes fraudulent
activity. Denied applicants have used other people's names and social security numbers to
obtain service. Utilties also report instances of applicants turning on their own service - a
potentially dangerous practice. It could also lead to legal action by the utilty for theft of service.
Allowing applicants, in some situations, to make payment arangements on old bils
instead of requiring full payment prior to new service would discourage fraudulent or dangerous
activity undertaken in an effort to obtain electricity or gas service. This alternative would also
allow the utilty an opportunity to recover monies that it otherwise might not have collected.
Staff acknowledges that the utilties would need to more closely monitor the accounts of
customers who are permitted payment arrangements for arearages in order to avoid additional
unpaid bils.
Recommendation
Staff recommends that utilties adopt new policies whereby lower risk applicants be
permitted to payoff old bils in installments while receiving new service.
Offr Arrearage Forgiveness Plans
Arearage forgiveness plans provide customers the opportity to have arearages
forgiven over a period of time if customers pay future bils on time. Such plans offer financially-
troubled customers an incentive to build a positive credit history with the utilty, since their debt
wil be forgiven only if payments are made as agreed. At the same time, it gives customers a
way to get out from under a debt they might not otherwise be able to pay. Arrearage forgiveness
plans work paricularly well for customers suffering from an acute financial crisis that poses a
present significant problem but does not appear to be chronic. Depending upon how an arearage
program is structured, it might require Commission approval prior to implementation.
STAFF COMMENTS 26 NOVEMBER 26, 2008
Recommendation
Staf recommends that all energy utilties develop arearage forgiveness plans. While
Staff acknowledges that this type of policy would not be appropriate in all instances, more in-
depth discussion among all interested paries is necessary to identify the circumstaces under
which arearage forgiveness should be offered.
Offer Case Management
The objective of good case management is to provide personalized customer assistance.
Ideally, case managers would identify both utilty and non-utilty programs and resources that
will help improve customers' abilty to manage finances, meet obligations, and pay energy bils.
Customers in crisis are often delinquent on more than just their utility bils. Frequently,
rent, mortgage payments or medical bils are also past due. As debts mount, customers become
overwhelmed and stop communicating with utilties. Through effective case management, a
utility can offer more specialized one-on-one customer assistace by trained customer service
employees. For example, a case manager can do a personalized assessment of a customer's
energy usage and provide advice on how to save energy by changing behaviors, taing advantage
of the utilty's energy effciency programs, or weatherizing his or her home. Case managers not
only provide basic budget counseling, but also refer customers to appropriate agencies and
coordinate available resources as necessary.
A vista has offered specialized case management for many years through its CARES
(Customer Assistance Referral and Evaluation Services) Program. Curently, Avista has four
full-time CARES Representatives who, together, handle a case load of approximately 4,400
customers located throughout Avista's service territory in Idaho, Washington and Oregon.
Avista maintains that the program is cost-effective because it directs resources toward keeping
customers on service by taking into consideration their abilty to pay, rather than forcing the
Company to pursue expensive collection efforts that result in disconnection rather than payment.
Intermountain Gas is in the process of implementing a Heating Education and Low-
Income Program (HELP). HELP specialists' duties wil include assisting customers who have
difficulty paying their utilty bils due to extenuating circumstances such as medical problems or
lost jobs. The specialists wil also provide assistance in identifying ways to conserve energy.
STAFF COMMENTS 27 NOVEMBER 26, 2008
The specialized duties wil be added to existing supervisory positions in Intermountain's local
offices in Idaho Falls, Pocatello, Twin Falls, Boise, and Nampa. The Company anticipates that
its program will be in place this heating season.
Recommendation
A vista and Intermountain should be commended for recognizing the need for case
management programs. One-on-one assistance provides a needed safety net for many at risk
customers. Customers are able to stay on service and establish a mutually-beneficial credit
relationship with utilities. Utilties benefit by avoiding wasting resources on unsuccessful
collection efforts, losing customers through involunta disconnection of service, and creating
bad debt by prematurely disconnecting service to customers who are willng to pay. Staff
recommends that those utilities without case management programs consider implementing such
programs.
Because Intermountain's program will be handled by supervisory personnel with already
established management duties, Staff has some concerns about the amount of specialized
assistace that they wil be able to provide to customers. After the Company has gained
experience with its program it can make any necessar modifications.
Staff notes that no prior Commission approval is necessary for a utility to implement a
case management program.
SUMMARY OF STAFF RECOMMENDATIONS
· Staff believes that a LIRAP program would be beneficial for Idaho low-income utilty
customers. Staff recommends that the Commission support legislation to allow it to
consider adoption of such a program.
· Staff encourages all utilties to increase awareness of and funding for nonprofit fuel
fuds.
· Staff recommends that a dialogue be initiated with Idaho's Congressional delegation
regarding increased awareness ofLIHEAP's value and the critical need for additional
program fuding. Staff also recommends that the utilties, Commission Staff, and other
interested paries parner with CAP AI to identify ways in which to fuher leverage
existing federal LIHEAP funding.
STAFF COMMENTS 28 NOVEMBER 26, 2008
. Staff recommends that additional fuding for weatherization and energy conservation
education programs be addressed in futue rate cases. Staff recommends that utilties
develop energy conservation education programs tageted to low-income customers.
Staff fuher recommends that utilities examine their incentive programs regarding higher
efficiency appliances, including consideration of no interest/low interest loans for
customers to purchase higher efficiency appliances and encourage the Northwest Energy
Efficiency Allance to include multi-family and manufactured homes in the Energy Sta
Home Program.
· Staff encourages utilties to actively advocate for adoption and implementation of energy
efficient construction standards, including provisions for single family rental, multi-
family, and manufactured homes.
. Staff recommends that utilities and the Commission consider tiered rates for residential
customers within the context of future rate cases.
· Staff recommends that utilties offer more flexibilty in negotiating payment
arangements. Staff further recommends that Staff and utilties fuher investigate
payment arangement alternatives.
. Staff recommends more investigation and discussion among all interested parties
regarding how convenience fees can be eliminated or reduced.
. Staff recommends more investigation and discussion among all interested paries
regarding the circumstances, if any, under which reconnection and interest charges could
be eliminated.
· Staff recommends further discussion of alternatives to existing deposit policies, including
an increase in installment payment plan timelines. Staff also recommends that one or
more of the utilties conduct a study of the effectiveness of collecting residential deposits.
· Staff recommends that utilties adopt new policies whereby lower risk applicants be
permitted to payoff old bils in installments while receiving new service.
. Staff recommends that all energy utilties develop arearage forgiveness plans.
· Finally, Staff recommends that all utilties implement case management programs if they
have not already done so.
STAFF COMMENTS 29 NOVEMBER 26, 2008
Respectfully submitted this
Technical Staff: Beverly Barker
Marilyn Parker
Curis Thaden
i:/umisc/comments/gnni08.lksbabmpct staff comments
STAFF COMMENTS
day of November 2008.
~. . f1 ~AA.~ì . -1AaA ,
stine A. Sasser
Deputy Attorney General
30 NOVEMBER 26, 2008
Summary:
Appendi 1
Appendix 2
Appendix 3
Appendix 4
Appendi 5
Appendi 6
Appendix 7
Appendix 8
Appendi 9
Appendix 10
Appendi 11
Appendi 12
Appendix 13
Appendix 14
Appendi 15
Appendix 16
Appendi 17
Aiendices
Energy Burden and Affordability GAP
Idaho Demographic Discussion
Idaho Demographics
Federal Pover Level Guidelines
Idaho Communty Action Agencies
LIHEAP "Energy Assistance" and "Crisis Funding" Matrx
Project Share Contrbutions/Grants - A vista
Project Share Contrbutions/Grants - Idaho Power
Project Share/Project Wartheep Kids Warm Contrbutions/Grants-
Intermountain Gas
Lend A Hand Contrbutions/Grants ~ Rocky Mountain Power
Fuel Fund Matrx
Low Income Weatherzation Programs Matrx
Other Energy Effciency Programs
LIRA/Washington (Avista Schedule 91 & 191)
LIRAP/Oregon (Avista Schedule 493)
CARE/Californa (pacificorp Schedule DL-6)
Tiered Rate/W ashington (pacificorp Schedule 17)
Appendix 1
Energy Burden and A(fordability GAP
In examining an individual's abilty to pay his/her utility bil, "energy burden"
is taken into account. "Energy burden" is the percentage of a household's income that is
spent on all home energy expenses, which includes all energy used for space heating and
cooling, lighting, and water heating.
The extent to which home energy costs are a burden is dependent upon numerous
variables. The "burden" imposed by the cost of home energy usage is greater for those
with lower incomes than those with larger incomes, since total home energy bils equate
to a larger percentage of household income. For instance, in Idaho, a household that is at
75-99% of the Federal Poverty Level, 13.6% of the household's income is used to pay for
home energy. For households below 50% of the Federal Poverty Level, 47.8% of anual
income is used to pay for home energy bils. This equates to nearly half of their annual
income being spent on energy that greatly impacts the household's ability to meet other
living essential expenses such as food and clothing. The table below reflects the various
energy burden percentages for low-income Idaho households:
Poverty Level (Idaho)
Households Below 50%
Households 50-74%
Households 75-99%
Households 100-124%
Households 125-149%
Households 150- 185%
Income - Family of 4
$0 - $10,600
$10,600- $15,688
$19,900- $20,998
$21,200- $26,288
$26,500- $31,588
$3 1,800- $39,220
Energy Burden
47.8%
19.1%
13.6%
10.6%
8.7%
7.1%
Appendix i
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page i of2
The "Home Energy Affordability Gap" is the difference between the actual home
energy bils and what is calculated as being "affordable" for home energy costs. Actual
home energy bils are estimates that differ for each county. Once the total energy bils
are estimated for each county, weighted percentages that are based upon state-specific
demographic information are calculated for each county. The weighted percentage is a
ratio between the number of persons who are below 185% ofthe Federal Povert
Guidelines in each county to the total state population who are below 185% of the
Federal Poverty Guidelines. The calculation used to determine what is "affordable" for
total home energy bils is set at 6% of anual household incomes. It is figued that
households can afford to spend 6% of their income on home energy. The difference
between this 6% amount (considered "doable") and the actual bil is a GAP.
The Home Energy Affordability Gap Index is a tool used to determine whether
the Home Energy Affordabilty Gap has either increased or decreased in any given year.
The year 2002 was designated as the "Base Year"; therefore, the Index for 2002 was set
at 100%. An Index greater than 100 indicates that the Affordability Gap increased, or
was greater, than was the Gap in 2002. Likewise, an Index less than 100 indicates that
the Affordability Gap was less than the 2002 Gap. In 2007, the Affordability Gap in
Idaho was 127.8, which is an increase of27.8% from the 2002 Base Year.
Source: On the Brink: 2007, The Home Energy Affordabilty Gap by Fisher, Sheehan & Colton, Public
Finance and General Economics, April 2008.
Appendix I
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page 2 of2
Appendix 2
Demographics
When looking at each county within the service territory, it is obvious that some
counties are better off than others. Blaine County has the state's highest median and
average income, a very low unemployment rate (2.5%), and the lowest poverty rate
(5.9%) in the state. In contrast, Madison and Owyhee Counties have very low median
and average incomes and the highest percentages (15.4% and15.6%) of individuals living
in poverty. Additionally, Owyhee County has the lowest unemployment rate (2.2%) in
the state and the second highest percentage (23%) of individuals that speak a language
other than English in the home.
Five counties (Benewah, Boundar Clearater, Idaho, and Shoshone) have
significantly higher unemployment rates (over 6%), high percentages of people living in
poverty (over 12.4%) and some of the lowest incomes in the state. Interestingly, these
counties are in Northern Idaho, where many mining and timber jobs have been lost over
the last decade. The high unemployment rate, high povert rate and low incomes suggest
that these counties suffer from diminished job opportunities and advancement. With
unemployment on the rise, the number of individuals needing assistance wil become
greater.
Four counties (Butte, Idaho, Shoshone, and Washington) have high percentages
of persons over 65 years of age (over 16.3%) and very high percentages of people living
in poverty (over 14.4%). Overall, there are twenty counties that exceed both the state
average of persons over 65 years of age (11.5%) and the state average of people living in
poverty (11.5%). Most notable is Adams, Clearater, Idaho, Lewis Shoshone and
Washington Counties where the senior population exceeds 18%. A correlation between
the percentage of seniors living withn a county and the percentage of a county's
population who are povert stricken may exist. The likelihood of seniors to be on fixed
incomes tends to make this portion of the populace the most vulnerable to increases in
living expenses.
Appendix 2
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page 1 of 2
In Gooding, Jerome, Latah, Madison, Owyhee, and Twin Falls Counties, the
unemployment rate is lower than the state average of 3.4% but the poverty rate is
significantly higher than the state average of 11.5%. With the exception of Madison and
Latah Counties, these counties have high percentages of individuals who speak a
language other than English in the home. The low unemployment rate coupled with high
povert rates suggests that these counties have a large percentage of "working poor",
individuals who are employed but unable to cover life's basic needs due to low wages,
inadequate benefits, and little opportunity of economic advancement. Relatively low-
paying jobs in these largely rual agricultural communties help explain this situation.
A very important point to higWight is that the Federal Poverty Level Guidelines
do not necessarily reflect an accurate gauge of povert in the United States and Idaho.
The 100% of poverty level is widely regarded as underestimating what it costs to
maintain a basic stadard of living. Federal and state governent agencies charged with
the responsibility to protect human health and welfare generally set household income
eligibility limits for social service programs at levels exceeding 100% of poverty. Since
total household income is used to determine eligibility for most social services, the
income of all wage earers in a household is combined. The state of Idaho has roughly
44,000 households at or below 100% of poverty. The total number of Idaho households
that qualify for LIHEAP benefits under last year's eligibilty threshold (150%) of poverty
is 101,000.
Customers who are living in povert and/or are unemployed have limited or
diminished financial resources with which to pay utility bils. Given the recent economic
turoil, Staff believes that the Census data, although somewhat stale, provides a fairly
good picture of Idaho today. In fact, there is probably reason to believe, as discussed
below, that customers may be worse off in the future. Staff is concerned that a signficant
number of customers will have problems paying their electric bil, especially when faced
with increasing rates.
Appendix 2
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page 2 of2
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Appendix 13
Other Energy Effciency Programs
Rocky Mountain Power offers additional residential energy effciency programs such
as: 1) Refrgerator/Freezer Recycling; 2) Home Energy Savings; 3) Idaho Time-of-Day;
and, 4) On-line and Mail-in Energy Analysis.
The Refrigerator/Freezer Recycling Program (aka See Ya Later Refrgerator Program) is
provided to Idaho residential customers who own either a new or existing home and
landlords who own appliances in rental properties where the tenant is biled. Older and
less effcient refrgerators and freezers are removed and recycled to prevent fuer use.
Serces that are offered include free removal and pickup of the unts, a $30 rebate, an
instant savings kit containing two compact fluorescent light bulbs, a "Bright Idea's"
booklet and information on other energy effciency programs.
The Home Energy Savings Program seres Idaho residential customers who live in new
or existing homes, multi-family unts or manufactued homes and landlords who own
rental properties where the tenant is biled under the same Rate Schedules. The program
provides incentives for purchase and installation of energy-efficient appliances, lighting,
electrc water heaters, space-conditioning equipment, widows, and insulation.
The Idaho Time of Day Program allows residential customers the option to switch to
what is called, "Rocky Mountai Power's Time of Day Option". Ths allows customer
more control of how much they spend on electricity by moving a substantial portion of
their power usage to non-peak hours.
On-line and Mail-in Energy Analysis allows residential customers to perorm free se1f-
audits on household energy usage. Ths can be accomplished by completing an online
audit form found on Rocky Mountain Power's website or by downloading a form, which
can then be sent to the company after having been filled out.
Appendix 13
Case No. GNR-U-08-1
Staff Comments
I 1/26/08 Page I of 4
A vista offers additional residential energy effciency programs such as: 1) Senor Energy
Conseration Workshops; 2) Energy Conseration Education Programs for Children; 3)
High Energy Equipment Incentives; 4) CFL Lighting; 5) Refrgerator Recycling
Program; 6) Conversion from Electrc Straight Resistance; 7) Energy Star Appliances; 8)
New Constrction Energy Star Homes Program; 9) Multi-Famly Energy Effciency
Program; 10) Rooftop Dampers; and, 1 1) Home Energy Analyzer.
The Senior Energy Conservation Workshops are par ofthe Senior Outreach Program that
helps to identify senior citizens who need assistance with paying their energy bils. The
workshops provide education on energy savings for senors while allowing for comfort
and safety with home energy use. All workshop paricipants receive an "Every Little Bit"
Energy Conseration Kit.
The Energy Conservation Education for Children Program is designed to educate 10w-
income elementar age children and families with the goal of changing lifestyle habits of
using energy efficiently. Wattson, the Energy Watchdog, is featued with the goal of
targeting children ages 4 to 8 with emphasis on reachig low-income children and their
families.
The High Energy Equipment Incentives Program offer rebates to customers who
purchase energy effciency equipment for their homes. Rebates ragig from $100 to
$ 1 500 are offered for items such as high effciency natural gas fuaceslboilers, heat
pumps, air conditionig unts, varable motors for heating systems, and electrc water
heaters.
The CFL Lighting Program provides customers with coupons for the purchase of
compact fluorescent bulbs (CFL) and also provides a list ofCFL recycling locations.
The Refrigerator Recycling Program is provided to Idaho residents who own a working
refrgerator or freezer that was manufactued in, or prior to, 1995. Though a local
parer, the unts are removed and recycled to prevent fuer use. The customer is then
given $30 for allowing removal ofthe unts. Additionally, rebates of$25.00 are offered
toward the purchase of a new energy efficient refrgerator and $ 1 00 toward the purchase
of a new energy effcient freezer.
Appendix 13
Case No. GNR-U-08- I
Staff Comments
I 1/26/08 Page 2 of 4
The Conversion from Electric Straight Resistance Program offers three customer
options: 1) a $ 1,000 rebate is provided to customers who replace electrc as their pnmar
heating source with a central natual gas heating system. The rebate can be claimed in
conjunction with the high-efficient natual gas fuace incentive. Additionally, a $500
incentive is available to replace electrc heat with a natual gas wall heater; 2) a $1,000
rebate is provided to customers who replace electrc as their pnmar heating source with
a heat pump. The rebate canot be combined with the electrc to natual gas heat
incentive. A $500 rebate is available to replace electrc heat with a natual gas wall
heater; and, 3) a $250 rebate is provided to customers who replace an electrc water
heater with a natual gas water heater. The rebate may be claimed in conjunction with
the high-effcient natual gas water heater incentive.
The Energy Star Appliances Program provides rebates ranging from $25 to $ 1 00 for the
purchase of an Energy Star appliances (refrgerator, freezer, dishwasher, or clothes
washer). The rebates only apply to customers who reside in single and multi-family
residences, including manufactued and modular homes.
The New Construction Energy Star Homes Program is a residential constrction program
providing incentives to builders, suppliers, and subcontractors who build energy efficient
homes. Energy Star homes are 30% more effcient that those homes that are built only to
Idaho's energy code. A $900 rebate is available to builders for new constrction homes
that use Avista electrc or Avista electrc and natual gas that meet the Energy Sta
Homes crtera and are verfied as an Energy Star Home. A $650 rebate is available for
homes that have A vista gas but not A vista electrc.
The Multi-F amity Energy Effciency Program is a brand new program that is designed to
increase energy effciencies and reduce water/sewer costs for proper owner of multi-
family dwellings while increasing tenant efficiencies and offerng saving opportties
for those who live in multi-family properties. A thid-par company (UCONS, LLC)
administers the program. The energy effciency measures include water heat pipe
installation, floor and ceiling insulation for under insulated buildings, the installation of
high quality shower head and aerators and the installation high quality compact
fluorescent bulbs. The program is free for both propert owner and tenant.
The Rooftop Dampers Program provides customers who heat pnmarly with electrc or
natual gas but also have a wood buring fireplace with the opportty to receive up to
$ 1 00 toward the installation of a rooftop damper to prevent energy loss though the
chimney.
The Home Energy Analyzer allows customers the ability to access their energy effciency
needs by using an interactive Home Energy Analyzer that is located on Avista's website.
-Appen-dix 13
Case No. GNR-U-08- I
Staff Comments
11126/08 Page 3 of 4
Idaho Power offers additional residential energy effciency programs such as: 1) Energy
Sta Home Products; 2) Energy Star Lighting; 3) Energy Star Homes; 4) Rebate
Advantage; 5) Energy House Calls; and, 6) Ai Conditioning Cool Credit.
The Energy Star Home Products Program offers rebates to residential customers who
live in single and multi-family residences and who also install cerai Energy Star rated
appliances. These appliances include refrgerators, ceiling fans, clothes washers, and
light fixtues.
The Energy Star Lighting Program is a relationship between Idaho Power,
manufactuers, and retailers, that offers promotional pricing on select, qualified compact
fluorescent light bulbs (CFLs). CFLs use approximately 75% less energy than regular
incandescent bulbs and last up to 10 times longer.
The Energy Star Homes Program is a residential constrction program providing
incentives to builders, suppliers, and subcontractors who build energy effcient homes.
Energy Star homes are 30% more effcient that those homes that are built only to Idaho's
energy code. In 2007, the program offered rebates that ranged between $750 and $1,000
for builders who constrcted energy efficient houses featued in the "Parade of Homes".
The Rebate Advantage Program offers incentives to eligible customers who purchase a
new electrcally-heated Energy Star manufactued home. Customers are able to receive
a $500 rebate.
The Energy House Calls Program is for residents living in manufactued homes. These
customers are able to get the following serces: 1) a test to deterine if ductwork is
leakng; 2) sealing of the leaks if found; 3) installation of compact fluorescent light bulbs;
4) replacement of air filters; and, 5) checking of hot water temperatue.
The Air Conditioning Cool Credit Program provides a $7 monthy credit to customers
who signup to allow Idaho Power to cycle off air conditioning systems durng the months
of June, July and August when demand is high, but never for more than 20 minutes at a
time.
Intermountain Gas offers one residential energy effciency program called the High-
Effciency Gas Furnace Rebate Program. The program offers a $200 cash rebate to be
used toward the purchase of a high-efficiency natual gas fuace for those customers
who conver from another hear source such as electrcity or propane to natual gas. The
home must be at least thee years old, the new fuace must meet a minum AFUE
effciency rating of 90% and Interountain Gas personnel must verify the installation.
Appendix 13
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page 4 of 4
WN U-28
Fifth Revision Sheet 91
Canceling
Fourth Revision Sheet 91
AVISTA CORPORATION
dba Avista Utilties
91
SCHEDULE 91
PUBLIC PURPOSES RIDER ADJUSTMENT - WASHINGTON
APPLICABLE:
To Customers in the State of Washington where the Company has electric
service available. This Public Purposes Rider or Rate Adjustment shall be
applicable to all retail customers for charges for electric energy sold and to the flat
rate charges for Company-owned or Customer-owned Street Lighting andArea
Ligliting- SérVice.:-This-Rate-Äaj~stment .is.. aèsignèdto..rëc(jvelCêêists-in~9i1"r~e~..5Y .
the Company associated with providing Demand Side Mana~er1~nt serviceS and
programs and Low Income Rate Assistance (L1RAP) to customers.(T)
(T)
MONTHLY RATE:
The energy charges of the individual rate schedules are to be increased by
the following amounts:
Schedule 1
Schedule 11 & 12
Schedule 21 & 22
Schedule 25
Schedule 31 & 32
Schedules 41-48
DSM Rate
$0.00181 per kWh (I)
$0.00256 per kWh (I)
$0.00189 per kWh (I)
$0.00124 per kWh (I)
$0.00167 per kWh (I)
.2.98% of base rates (I)
L1RAP Rate
$0.00048 per kWh (I)
$0.00068 per kWh (I)
$0.00050 per kWh (I)
$0.00033 per kWh (I)
$0.00044 per kWh (I)
0.79% of base tates(l)
(N)
SPECIAL TERMS AND CONDITIONS:
Service under this schedule is subject to the Rules and Regulations
contained in this tariff.
The above Rate is subject to increases as set forth in Tax Adjustment
Schedule 58. .
Issuecrecembr20,2007'--Effective January 1; 2008*-
*By authority of Commission Order No. 05 in Docket No. UE-070804
Issued by Avista Corporation
By Kelly Norwood Vice President, State & Federal Regulation
Appendix 14
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page 1 of 2
WN U-29
Seventh Revision Sheet 191
Canceling
Sixth Revision Sheet 191
AVISTA CORPORATION
dba Avista Utilities
SCHEDULE 191
PUBLIC PURPOSES RIDER ADJUSTMENT - WASHINGTON
APPLICABLE:
To Customers in the State of Washington where the Company has natural
gas service available. This Public Purposes Rider or Rate Adjustment shall be
applicable to all retail customers taking service -under Schedules 101, 111, 112,
-121, 122, 131, and 132. This Rate Adjustment is designed to recover costs
incurred by th-e Company associated with providing Demand Side Management (T)
services and programs, and Low Income Rate Assistance (L1RAP) to customers. (T)
(D)
MONTHLY RATE:
The energy charges of the individual rate schedules are to be increased by
the following amounts:
Schedule 101
Schedule 111 & 112
Schedule 121 & 122
Schedule 131 & 132
DSM Rate
$0.01795 per Therm
$0.01580 per Therm
$0.01479 per Therm
$0.01429 per Therm
L1RAP Rate
$0.00808 per Therm (I)
$0.00698 per Therm (I)
$0.00645 per Therm (I)
$0.00624 per Therm (I)
SPECIAL TERMS AND CONDITIONS:
Service under this schedule is subject to the Rules. and Regulations
contained in this tariff.
The above Rate is subject to increases as set forth in Tax Adjustment
Schedule 158.
Issued December 20, 2007 Effective January 1, 2008*
*By authority of Commission Order No. 05 in Docket No. UG-070805
Issued by Avista Corporation
By Kelly Norwood , Vice-President, State and Federal Regulation
AppendIx 14-
Case No. GNR-U-08- I
Staff Comments
11/26/08 Pa~e_2 of2_
P.U.C. OR. NO.5 Original Sheet 493
AVISTA CORPORATION
dba Avista Utilities
-----CH-ED-UL-E--93----------------- ---------
RESIDENTIAL LOW INCOME RATE ASSISTANCE PROGRAM (L1RAP)-
OREGON
PURPOSE:
The purpose of this schedule is to adjust rates in Schedule 410 - General
Residential Natural Gas Service - Oregon, to generate funds to be used for bill
payment assistance for Avista's qualifying low-income residential customers, in
accordance with ORS 757.315.
APPLICABLE:
To all residential Customers in the State of Oregon where the Company has
natural gas service available. This Residential Low Income Rate Assistance
Program (L1RAP) Adjustment shall be applicable to all residential customers taking
service under Schedule 410. This Rate Adjustment, set below is approximately0.5% of retail rates. -
MONTHLY RATE:
The energy charge of the residential rate Schedule 410 has been increased
by $0.00438 per thermo This rate adjustment is reflected in the present rate set forth
under Schedule 410.
SPECIAL CONDITIONS:
1. Each month, the Company wil bil and collect low-income bill payment
assistance funds from all Residential Customers. By the 10th of the month
following the billing month, using the Company's internal cashless voucher
system, the Company will determine and send the monthly voucher amount
showing the Program Payment funds available to each participating
Community Action Agency. By the 20th of the month following the biling
month, the Company will remit payment to each Agency for allowed
administrative and program delivery costs. Each agency wil process client
intake, authorize payments, and provide the Company with a client voucher
list. Based on this client voucher list, the Company wil transfer the
authorized payments to the individual customer's utility account.
( continued)
Advice No. 08-02-G
Issued March 31,2008
Effective For Service On & After
April 1, 2008
..
00 No ~;) ..I en Q)
i: ï= bJ
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.. 0 S ¡:
.~ ô § 00-g Z u ~& Q) ~ ~
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Issued by Avista Utilities
By Kelly O. Norwood, V.P., State and Federal Regulation
P.U.C. OR. No.5 Original Sheet 493A
~
AVIST A CORPORATION
dba Avista Utilties
--------_.--- --~---~-~-~SCHEDULE 493-Çcor:tii:ued)--------~----- -~ ~.-. I --- --~
RESIDENTIAL LOW INCOME RATE ASSISTANCE PROGRAM
(L1RAP)-OREGON
2. The Company wil compute interest each month based on the average
monthly fund balance undistributed at the company's currently
authorized rate of return.
3. The Company will be responsible for program administration and funds
distribution to qualifying local agencies in accordance with terms and
conditions established by the Company and the entity. All funds collected
under this program, less program administration and delivery costs paid to
the individual- agencies, wil be distributed to income-eligible Residential
Customers of Avista Utilties. Income Eligibility will be determined by the
respective agencies and wil be consistent with the eligibilty determinations
for state low-income energy assistance programs.
4. Total program administration and delivery costs shall not exceed 21.78
percent of the total low-income bil payment assistance funds collected.
Should actual administrative and program delivery costs be lower than
21.78 percent, the remaining funds shall be allocated into the program fund
to support direct services.
5. The Company will provide an annual summary evaluation report on the
progress of the L1RAP for review by the Commission by August 31st
following the end of eåch program year.
6. The L1RAP program year wil commence each July 1st through June 30th.
RULES AND REGULATIONS:
Service under this schedule is subject to the General Rules and Regulations
contained in the tariff of which this schedule is a part, and to those prescribed by
regulatory authorities.
Advice No. 08-02-G
Issued March 31,2008
Effective For Service On & After
April 1, 2008
Issued by Avista UtilitiesBy Kelly O. Norwood,Vice President, Rates & Regulation Appendix 15
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page 2 of 2
Pacific Power & Light Company
Portland, Oregon Canceling
Revised
Revised
Cal.P.U.C.Sheet No. 3083-E
Cal.P.U.C.Sheet No. 3048-E
Schedule No. DL-6
RESIDENTIAL SERVICE
CALIFORNIA ALTERNATIVE RATES FOR ENERGY (CARE)
OPTIONAL FOR QUALIFYING CUSTOMERS
APPLICABILITY
Applicable to residential low income households in single-family
dwellings and as specified further under special conditions of this Schedule,
and Residential Service Schedule No. 0, and for multiple dwelling units in
which each of the single-family dwellings receive service directly from the
utility through separate meters, and to multi-family accommodations which are
separately submetered.
TERRITORY
Within the entire territory served in California by the Utility.
MONTHLY BILLING
The Monthly Billing shall be the sum of the Basic and Energy Charges.
Direct Access Customers shall have their Monthly Billing modified inaccordance with Schedule No. EC-1 and Schedule No. TC-1. All Monthly Billings
shall be adjusted in accordance with Schedule ECAC-94.
FERC Calif.Gener-Public TotalDistrib.Trans.Trans.ation Purpose Rate
Basic Charge $5.49 ( $1.10)$4.39
Energy Charge:
All Baseline kWh 4.312ç 0.457ç 0.004ç 2.423ç (1. 706ç)5.490ç
All Non-Baseline kWh 5.582ç 0.457ç 0.004ç 2.694ç (2.015ç)6.722ç
Adjustments:
The above Total Rate includes adjustments for Schedule S-99, Schedule S-
191, and the CARE Adjustment which is equal to twenty percent (20%) of the
Residential Service Schedule No. 0 Basic Charge and twenty percent (20%) of
the Residential Service Schedule No. 0 Energy Charge Total Rate minus the
Schedule S-100 surcharge.
Minimum Charge:
The monthly Minimum Charge shall be the Basic Charge. A higher minimum may
be required under contract to cover special conditions.
SPECIAL CONDITIONS
1. Service under this schedule is subject to the General Rules and
Regulations contained in the tariff of which this schedule isa part and to
those prescribed by regulatory authorities.
Advice Letter No.364-E
(Continued)
Issued by
Andrea L. Kelly Date Filed
Name
VP, Regulation
July 14, 2008
Decision No.Effective August 23, 2008
Title
TF6 DL-6-1.E Resolution No.
Appendix-16
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page 1 of2
Pacific Power & Light Company
Portland, Oregon Canceling
Revised
Revised
Cal. P. U .C. Sheet No. 3070-E
Cal.P.U.C.Sheet No. 2862-E
SCHEDULE NO. DL-6
RESIDENTIAL SERVICE
CALIFORNIA ALTERNATIVE RATES FOR ENERGY (CARE)
OPTIONAL FOR QUALIFYING CUSTOMERS
SPECIAL CONDITIONS (Continued)
2. A Low-Income Household where the total gross income from all sources
is less than shown on the table below based on the numer of persons
in the household. Total gross income shall include income from all
sources, both taxable and nontaxable.
No. of Persons
In Household
1-2
3
4
5
6
Total Gross IncomeAnnually
$26,70031,300
37,800
44,300
50,800
For Households with more than six persons, add $542.00 monthly, or
$6,500 annually for each additional person residing in the household.
3. An application is required for each request of service under this
schedule. An eligible applicant will be placed on this schedule wi thin one
billing cycle of the receipt of their application. Renewal of a customer's
eligibility declaration will be required every two years and may be required
randomly at the utility's discretion. Submetered tenants of master metered
customers (Schedule DS-8) will be required to reestablish eligibility on an
annual basis. Customers are only eligible to receive service under this rate at
one residential location at anyone time.
4. It . is the customer's responsibility to notify the utility if there
is a change in eligibility status. Master meter customers (Schedule DS-8) with
submetered tenants are responsible for notifying the utility when enrolledtenants move. Master meter customers will not be held responsible should a
submetered tenant misrepresent his eligibility to the utility. However, if a
master meter customer has a good reason to suspect that the tenant is not
eligible, the master meter customer should, but is not required to, so advise
the utility.
5. Customers may be rebilled for periods of ineligibility under the
applicable rate schedule.
6. Price discounts or billing credits which may be available under
other rate schedules or tariffs may not be used in conjunction with the Low
Income Schedule No. DL-6.
7. The Basic Residential use
Residential Service Schedule D will apply
for electric space heating are qualified
baseline quanti ties for the use of a Life
special conditions of Residential Service
under this Schedule.
baseline allowance as defined in
unless baseline allowances available
and elected. The standard medical
Support device as defined under the
Schedule No. D shall be applicable
CONTINUING SERVICE
Except as specifically provided otherwise, the rates of this tariff are
based on continuing service at each service location. Disconnect and reconnect
transaction shall not operate to relieve a customer from minimum monthlycharges.
Advice Letter No. 361-E
Issued by
Andrea L. Kelly Date Filed May 14, 2008
Name
VP, Regulation
Title
Effective June 1, 2008Decision No.
TF6 DL-6-2. E Resolution No.
Appendix 16
Case No. GNR-U-08- I
Staff Comments
I 1/26/08 Page 2 of 2
WN U-74 Tenth Revision of Sheet No. 17.1
Canceling Ninth Revision of Sheet No. 17.1
PACIFIC POWER & LIGHT COMPANY
FOR COMMISSION'S RECEIPT STAMP
SCHEDULE 17
LOW INCOME BILL ASSISTANCE PROGRA - RESIDENTIAL SERVICE
OPTIONAL FOR QUALIFYING CUSTOMERS
AVAILABLE:
In all terri tory served by Company in the State of Washington.
APPLICABLE:To residential Customers only for all single-phase electric
requirements when all service is supplied at one point of delivery. For
three-phase residential service see Schedule 18.
MONTHLY BILLING:
The Monthly Billing shall be the sum of the Basic and Energy Charges
and the Low Income Energy Credit. All Monthly Billings shall be adjusted in
accordance with Schedules 96, 98 and 191.
Basic Charge:$6.00
Energy Charge:
Base
Rate
4.914'7.75H per kWh for the first 600 kWh
per kWh for all additional kWh
LOW INCOME ENERGY CREDIT*:
The credit amount shall be based on the qualification level for which
the customer was certified.
0-75% of Federal Poverty Level (FPL) :
(3.812ç) per kWh for all kWh greater than 600 kWh76-100% of Federal Poverty Level (FPL) :
(2.565ç) per kWh for all kWh greater than 600 kWh
101-125% of Federal Poverty Level (FPL):
(1. 603ç) per kWh for all kWh greater than 600 kWh
(continued)
Issued October 9, 2008 Effective October 15, 2008
Issued by
By
PACIFIC POWER & LIGHT COMPANY
Andrea L. Kelly Ti tle Vice President, Regulation
Advice No. UE-080220
AppendìxT7-
Case No. GNR-U-08-1
Staff Comments
11/26/08 Page 1 of2
TF2 17. 1E
Form F
WN U-74 Third Revision of Sheet No. 17.2
Canceling Second Revision of Sheet No. 17.2
PACIFIC POWER & LIGHT COMAN
FOR COMMISSION'S RECEIPT STAMP
SCHEDULE 17
LOW INCOME BILL ASSISTANCE PROGRA - RESIDENTIAL SERVICE
OPTIONAL FOR QUALIFYING CUSTOMERS
(Continued)
*Note: This credit applies to only the energy usage wi thin the
Winter months. Winter months are defined as November 1 through
April 30.
MINIMUM CHARGE:
The monthly minimum charge shall be the Basic Charge. A higher
minimum may be required under contract to cover special conditions.
SPECIAL CONDITIONS:
1. To qualify, a Customer must earn no more than 125% of the Federal Poverty
Level.
2. Qualifying Customers will be placed into one of three qualifying levels.
A maximum of 4,475 customers may participate annually.
3. Non-profit agencies will administer the program. They will determine if a
customer qualifies for the program and assign them to one of the three
income bands. The Company will authorize these agencies to certify
customer eligibility for the Program.
CONTINUING SERVICE:
Except as specifically provided otherwise, the rates of this tariff
are based on continuing service at each service location. Disconnect and
reconnect transactions shall not operate to relieve a Customer from monthly
minimum charges.
RULES AND REGULATIONS:
Service under this schedule is subj ect to the General Rules and
Regulations contained in the tariff of which this schedule is a part and tothose prescribed by regulatory authorities.
Issued June 26, 2007
PACIFIC POWER & LIGHT COMPANY
Andrea L. Kelly
Effective June 27, 2007
Issued by
By
TF2 17. 2E
Form F
Title Vice President, Regulation
Advice No. UE-061546/UE-060817
Appendix 17
Case No. GNR-U-08- I
Staff Comments
I 1/26/08 Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF NOVEMBER 2008,
SERVED THE FOREGOING STAFF COMMENTS, IN CASE NO. GNR-U-08-01, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BETSY BRIDGE
ENERGY EFFICIENCY ASSOC
ID CONSERVATION LEAGUE
POBOX 844
BOISE ID 83701
MICHAEL P McGRATH
INTERMOUNTAIN GAS CO
POBOX 7608
BOISE ID 83707-1608
TERRI SHOEN
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707-1608
MIKE KINGERY
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707-1608
MAGGIE BRILZ
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
RICK GALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
LINDA GERVAIS
AVISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
BRUCE FOLSOM
AVISTA UTILITIES
POBOX 3727
SPOKANE W A 99220
TED WESTON
ROCKY MOUNTAIN POWER
201 S MAIN STE 2300
SAL T LAKE CITY UT 841 1 1
BARBARA COUGHLIN
PACIFICORP
825 NE MULTNOMAH
STE 800
PORTLAND OR 97232
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
MARY CHANT EXE DIR
COMMUNITY ACTION
PARTNERSHIP ASSOC OF ID
5400 W FRANKLIN RD STE G
BOISE ID 83705
ROWENA PINEDA EXE DIR
ID COMMUNITY ACTION
NETWORK
3450 HILL RD
BOISE ID 83703
CERTIFICATE OF SERVICE
CARRIE TRACY
NW FEDERATION OF COMMUN
ORGANIZATIONS
1265 S MAIN ST #305
SEATTLE WA 98144
DEDE SHELTON
AARPIDAHO
3080 E GENTRY WAY
STE 100
MERIDIAN ID 83642
JULIA CAMPBELL
SOUTHEASTERN IDAHO COMMUNITY
ACTION AGENCY
641 N 8TH
POCATELLO ID 83201
KEN ROBINETTE EXE DIR
SOUTH CENTRAL
COMMUNITY ACTION PARTNER
PO BOX 531
TWIN FALLS ID 83303
RICHARD STELLING
EXECUTIVE DIRECTOR
C.C.O.A. WEATHERIZATION
304 N KIMBALL AVE
CALDWELL ID 83605
ROB CHRISTENSEN EXE DIR
WESTERN IDAHO COMMUNITY
ACTION PROGRAM
315-B S MAIN ST
PAYETTE ID 83661
DICK HENRY
EXECUTIVE DIRECTOR
EL-ADAINC
701 E 44TH ST #1
BOISE ID 83714
SENATOR NICOLE LeF A VOUR
1210N 11TH
BOISE ID 83702
JIM WORDELMAN
AARPIDAHO
3080 E GENTRY WA Y
STE 100
MERIDIAN ID 83642
LYN YOUNG
2786 S DENALI PLACE
MERIDIAN ID 83642
DEBRA HEMMERT EXE DIR
SOUTHEASTERN IDAHO
COMMUNITY ACTION AGENCY
641 N 8TH
POCATELLO ID 83201
RONCORTA
C.C.O.A. WEATHERIZATION
304 N KIMBALL AVE
CALDWELL ID 83605
RUSS SPAIN EXE DIR
EASTERN IDAHO COMMUNITY
ACTION PARTNERSHIP
357 CONSTITUTION WAY
IDAHO FALLS ID 83405
LISA STODDARD EXE DIR
COMMUNITY ACTION
PARTNERSHIP
124 NEW 6TH STREET
LEWISTON ID 83501
GENIE SUE WAPPNER
ID DEPT OF HEALTH & WELFARE
STATEHOUSE MAIL
REP. WILLIAM KILLEN
734 S CORAL PL
BOISE ID 83705
CERTIFICATE OF SERVICE
REP. PHYLIS KING
2107 PALOUSE
BOISE ID 83705
REP. ANNE PASLEY-STUART
749 HIGH POINT LANE
BOISE ID 83712-6561
REP. DONNA PENCE
1960 US HWY 26
GOODING ID 83330
TERI OTTENS
PO BOX 8224
BOISE ID 83707
--~
SECRETA
CERTIFICATE OF SERVICE