20090120Final Report.pdf

BEFORE THE IDAHO PUBLIC UTILITIES cOif~§§t(jN
2009 JAN 16 PH 5: 0 I
IN THE MATTER OF THE COMMISSION'S )
INQUIRY ABOUT ENERGY AFFORDABILITY )ISSUES AND WORKSHOPS. )
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CASE rJllJti~ìSSIOI'¡
STAFF'S FINAL REPORT
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 variety of factors contributing to significant
upward pressure on electric and natual gas rates in Idaho. Energy affordabilty has become a
central issue for many Idaho households and businesses.
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 pertaining to energy affordabilty and customers' abilty to pay
energy bils. Staff submitted comments on November 26, 2008. Numerous responsive
comments were received. A broad spectru of interests and views were represented. A matrix
is attched as Appendix 19 which briefly sumarizes the various views of those submitting
comments in this case. Those views are discussed in greater detail within this report.
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 turoil in the financial and housing markets are impacting customers' abilty to pay
their utilty bils. Idaho's unemployment rate has risen to the highest rate in over twenty years.
Recent Idaho Department of Labor data shows a shar rise in the State's unemployment rate.
Two years ago the unemployment rate was 2.7%. In Januar 2009, Idaho's unemployment rate
reached 6.6%. The total number of workers without jobs has hit a record high (50,000), which is
more than double the number of those unemployed last year. Job loss rose in forty ofIdaho's
STAFF'S FINAL REPORT 1 JANUARY 16,2009
forty-four counties. Such a significant increase in the unemployment rate is likely to lead to an
increase in the percentage of the state's population that falls at or below 100% of the Federal
Povert Level Guidelines. The State of Idaho curently has roughly 44,000 households at or
below 100% of poverty. i
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 Poverty Level typically spends 47.8% of its anual income to pay for home energy
bils. These figures represent the household's "energy burden."i 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. According to federal guidelines, an energy burden of 6% of
anual household income is considered affordable.
Rule 306 of the Commission's Utility Customer Relations Rules (UCRR) protects
certain residential customers who are unable to pay their winter energy bils. During the months
of December, Januay, and Februar, households with children, elderly or infrm who declare
eligibility for the "moratorium" canot have their electric or natural gas service disconnected for
failure to pay a utilty bil in full. However, this provision does not protect a low-income
customer who has no children, elderly or infirm in the household or those customers who are
eligible for protection but do not contact the utilty. Customers who have declared eligibilty for
the moratorium are stil expected to pay their bils each month, but canot be disconnected for
failure to pay. Payment of any past due balance or negotiation of a new payment arrangement is
required on or before March 1. During the 2007/2008 winter heating season, over 18,000
customers declared eligibility for the moratorium.3
Customers who have declared eligibilty for the moratorium can also enter into a Winter
Payment Plan. Under a Winter Payment Plan, customers agree to make monthly payments equal
to half of a regular level payment amount. The plan allows for an additional two months of
protection (November and March). Customers with Winter Payment Plans must pay any past
due balance or negotiate a new payment arangement on or before April 1. Though protected
1 See Appendices 2 (Idaho Demographic Discussion), 3 (Idaho Demographics), and 4 (Federal Povert Level
Guidelines).2 See Appendix i (Energy Burden and Affordabilty GAP).
3 This includes 10,284 Idaho Power customers, 4,553 Intermountain Gas customers, 2,635 Avista customers, and
560 Rocky Mountain Power customers.
STAFF'S FINAL REPORT 2 JANUARY 16,2009
from disconnection in the coldest winter months, many customers are unable to payoff their
accrued balances when the moratorium ends.
CURRNT ASSISTANCE PROGRAS
There are several programs in Idaho that provide financial assistance to customers who
need help paying their utilty bils and assistance with energy effciency measures. Programs
operate under a wide variety of guidelines and restrictions and are fuded by both public and
private resources.
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 assistace designed to pay utilty
bils associated with the customer's primary heating source.5 Applicants must meet income-
criteria based on Federal Poverty Guidelines. To be eligible, paricipants must apply for
LIHEAP benefits at a community action agency each program year.6
Last year 101,000 Idaho households qualified for LIHEAP benefits. LIHEAP's
2007/2008 Energy Assistance fuding amount of$9,410,895 provided benefits for 32,843 of
101,000 eligible households. The average benefit received was $286 per household for the
2007/2008 winter heating season. Based on that average benefit amount, an additional
$19,492,902 would have been needed to cover all of Idaho's eligible households.
LIHEAP provides additional assistace for customers whose disconnection is imminent.
These "Crisis Funds" are allocated independent of regular LIHEAP funds. Crisis Funds must be
used to pay energy bils for the household's primary heating source, and are available regardless
of whether the household has previously received a benefit. In Idaho, Crisis Funds are very
limited and have only been available for the past two heating seasons.
4 Appendix 6 contains a LIHEAP funding matrix.
5 A Federal Block Grant funds the LIHEAP program.
6 Appendix 5 lists the community action agencies in Idaho.
STAFF'S FINAL REPORT 3 JANUARY 16,2009
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 Share7
Project Share provides up to $400 annually per household regardless of the household's
heating source, i.e., the program is fuel-blind. Monies are dispersed toward payment of bils for
any energy source (electric, natual gas, wood, coal, propane, kerosene or oil). Project Share is
fuded with contributions made by utilty customers, employees and shareholders. All money
collected, with the exception of administrative costs, is retured to the community. Funds for the
program are administered by the Salvation Army in southern Idaho. In northern Idaho, Project
Share fuds are administered by the Community Action Parnership 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 also provides financial assistace to individuals regardless of the
household heating source. This program was created for individuals residing in southeastern
Idaho where Project Share fuding was not available. The primar source of fuding for Project
Warth 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 to organize the
tourament. All money collected, with the exception of administrative costs, is retured to the
community. To be eligible, recipients must be at or below 125% of the Federal Poverty
Guidelines. An eligible household can receive an anual 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.
7 Appendix 7, 8 and 9 contains Project Share fuding and disbursement amounts.
8 Appendix 9 contains Project Warmth fuding and disbursement amounts.
STAFF'S FINAL REPORT 4 JANUARY 16, 2009
LendA Hancf
Lend A Hand provides financial assistace to Rocky Mountain Power customers with
electric space heat. Funding is provided through contributions by Rocky Mountain Power
customers, employees, and shareholders. All money collected, with the exception of
administrative costs, is retured to the community. To be eligible, recipients must be at or below
150% of the Federal Poverty Guidelines. Recipients can receive an anual 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.
Keep Kids WarmlO
Keep Kids Warm provides financial assistance to individuals regardless ofthe household
heating source. The fuel-blind program was stared in 1996 by KIZN radio (Boise) to assist
households with their heating needs. Intermountain Gas parners with KIZN radio in the
fudraising efforts though pledge cards and a yearly radio broadcast telethon. All money
collected is retured to the community. There are no administrative fees or other costs
associated with administering this 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 Council on Aging and Community Services in Oregon.
Low-Income Weatherization
Weatherization increases energy efficiency by reducing heat loss and addressing air
infitration issues. Measures taken to improve energy effciency include the following: attic,
floor and wall insulation; repairing or upgrading windows; proper ventilation; duct insulation and
sealing; caulking; and weather stripping. Additional measures may include switching the
customer to compact fluorescent light bulbs and fuace (or AC unit) repair or replacement.
Energy conservation education is provided to customers whose homes are weatherized.
9 Appendix i 0 contains Lend A Hand funding and disbursement amounts.
lO 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 1.
STAFF'S FINAL REPORT 5 JANUARY 16,2009
Low-income weatherization assistance is provided 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 manufactured homes that qualify for LIHEAP fuding
automatically qualify for Weatherization Assistace. The administering agencies determine
income eligibilty. Households with income at or below 160% of the Federal Poverty Guidelines
automatically qualify to receive weatherization services. An energy audit is performed by the
administering agency before a home is weatherized.
According to a report provided by CAP AI, the average investment per weatherized home
in 2007 was $3,674. The number of homes needing weatherization greatly exceeds the funding
that is available. Currently only 10% of homes receiving LIHEAP benefits also obtain
weatherization assistace because of the lack of available funds.
Funding for weatherization comes from several sources, including the U.S. Department
of Energy (DOE) and energy utilties. The table below reflects the total dollars spent from all
funding sources on an annual basis for weatherization. 1 1
Average Home
Year Dollars Spent Homes Investment
2006 $4,913,645 1,460 $3,365
2007 $5,081,900 1,383 $3,674
The curent Commission-approved 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 Programs
In addition to low-income weatherization, most utilties offer a variety of different
residential energy effciency programs, e.g., do-it-yourself home energy audits, energy efficient
lighting, appliance and equipment incentives, and improved energy effciency standards for new
constrction.
12
i 1 Appendix 12 outlines utilty weatherization program fuding guidelines and amounts.
12 A summary of these programs can be found in Appendix 13.
STAFF'S FINAL REPORT 6 JANUARY 16,2009
Inabilty to Meet the Need
Although there are resources available to help customers pay their energy bils and
become more energy efficient, those resources are insufficient to meet the curent and future
need. As previously indicated, during the 2007/2008 heating season, 101,000 Idaho households
met the income guidelines (at that time, 150% of the Federal Povert Level) for LIHEAP. Only
one-third of those households (32,843) actually applied for and received benefits totaling
$9,410,895. An additional benefit of $19,492,902 would have been needed to provide the
remaining two-thirds of Idaho households who met income guidelines but did not receive energy
assistance benefits.
LIHEAP benefit amounts are based on a funding matrix, not customers' actual heating
bils or total energy costs. The average benefit amount was $286 during the 2007/2008 heating
season. As of May 1, 2008, 136,602 gas and electric residential customer accounts (16% of all
residential accounts) were past due, with a total of$13,381,884 owing.
Fuel fuds are a valuable resource for bil payment assistance, but despite the generosity
of utilty shareholders and customers, and other contributors, the dollars available fall far short of
meeting the remaining need. Taken together, Idaho fuel fuds disbursed $481,274 to a total of
2,909 recipients. Assuming that households receiving LIHEAP benefits and those who receive
grants from fuel funds are mutually exclusive groups (which is not necessarily the case), a
shortfall of over $19 milion stil exists, leaving over 65,000 low income households without bil
payment assistance. These totals do not take into account the increasing cost of energy, the rapid
increase in unemployment, or the total outstanding balances owed by qualified customers already
receiving assistance.
PROPOSALS TO ADDRESS ENERGY AFFORDABILITY
Bil Payment Assistance
Durng 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
fuds for bil payment assistance were discussed: 1) create utilty programs designed to help
low-income customers pay energy bils fuded by all utilty customers through rates; 2) increase
voluntar contributions to nonprofit fuel funds; 3) increase federal fuding for the Low-Income
Home Energy Assistance Program (LIHEAP); 4) increase LIHEAP fuding received by Idaho
STAFF'S FINAL REPORT 7 JANUARY 16,2009
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
In both Oregon and Washington, Avista offers a Low-Income Rate Assistace Program
(LIRAP) intended to ease the home energy burden for Avista's residential customers with
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 assistace provided by other
programs such as LIHEP (Low-Income Home Energy Program)13 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 Assistace Program).
Funding for LIRAP differs between Washington and Oregon. In May 2001, the
Washington Utilities and Transportation Commission approved a Public Purose Rider
Adjustment to fud 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 LIRA portion of the surcharge was designed to produce a fuding level of
approximately 0.79% of base rates under Schedule 91 and 191.14
The Public Utilties Commission of Oregon approved LIRAP as a stad-alone program
authorizing A vista to implement a surcharge of $0.00438 per therm for gas consumption. The
surcharge applies to residential customers and is designed to produce a fuding level of
approximately .05% of base rates under Schedule 493.15
In both states, A vista provides the collected LIRAP revenue to community action
agencies which administer the program in a similar maner to LIHEAP fund administration.
Factors such as anual household income, estimated annual home energy costs, and type of
housing (i.e., single family or multi-family) are used to determine the amount of assistance
granted to customers. Typically, recipients ofLIRAP in both Washington and Oregon are well
below poverty leveL. To qualify for LIRAP in either state, a family of four who is at or below
13 In Oregon, LIHEP is the term used to refer to the federal LIHEAP program.
14 See Appendix 14 for Washington's rate schedules.
15 See Appendix 15 for Oregon's rate schedules.
STAFF'S FINAL REPORT 8 JANUARY 16,2009
100% ofthe Federal Povert Guidelines would have a household income of$I,760 or less per
month. In 2007, approximately 75% of Washington and 65% of Oregon LIRAP recipients had
annual household incomes under $15,000. One-third ofLIRAP paricipants in both Washington
and Oregon have anual household incomes under $8,000.
Avista's LIRAP surcharge 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. Some seniors may have incomes that exceed the
ceilng for LIHEAP or LIRAP grants. However, 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 LIRAP grant.
Conservation education is also funded by the surcharge. Paricipants receive either
wrtten material or classroom instruction through workshops and seminars. Avista's 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 fuding.
Increase Customer Awareness of! Encourage Voluntary Contributions to Nonprofit Fuel
Funds
All workshop participant s agreed that increasing customer and communty awareness of
nonprofit fuel fuds 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 websites, newsletters, and monthly customer
bilings.
To raise public awareness and encourage voluntar contributions in the past, A vista,
Rocky Mountain Power, and Idaho Power enlisted parners in the community. Businesses
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 partnering programs. Intermountain Gas curently parners with KIZN radio
for a yearly telethon fudraiser and golf tourament for the Keep Kids Warm program.
STAFF'S FINAL REPORT 9 JANUARY 16,2009
Increase Funding for LIHEAP
The 2009 LIHEAP Energy Assistance 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 funding, 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 a maximum of 160% of the Federal Poverty Guidelines, the
number of eligible households is projected to increase from 101,000 last year to 111,100 this
year.
LIHEAP fuds can be increased through a process called "leveraging." Essentially, the
Federal governent withholds a percentage of LIHEAP money allocated to each state as an
incentive for that state to first acquire non-federal fuds for assistance 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 assistace 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 workshop paricipants agreed that obtaining
additional federal funding for LIHEAP through leveraging would benefit both customers and
utilties. In workshop discussions, it was apparent that few paricipants were aware of the
leveraging concept.
Create a State-Funded Financial Assistance 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 andlor increase benefit
amounts.
Staff Comments:
The LIRAP program would be beneficial for Idaho's low-income utilty customers.
LIRAP would provide additional fuds to supplement existing federal LIHEAP fuds, allowing
STAFF'S FINAL REPORT 10 JANUARY 16,2009
more people to obtain the financial assistace needed to pay their energy bils. Because LIRAP
is administered through community action agencies, the infrastrcture for the program is already
in place in Idaho.16 However, implementing a LIRAP program in Idaho would likely require
legislation. Idaho Code § 61-315 provides that, "No public utilty shall...make or grant any
preference or advantage to any corporation or person or subject any corporation or person to any
prejudice or disadvantage."
During the workshops, utilties expressed concern that, should LIRAP be implemented in
Idaho, a surcharge appearing on customer biling statements could impact donations given to
other financial assistance programs such as Project Share. It is Staffs opinion that any decrease
in voluntar contributions would be offset by funding derived from a LIRAP program.
Staff recommends that the Commission support legislation to allow it to adopt a LIRAP
program. Specifically, the legislation should modify existing statutes to allow the Commission
to implement programs for the benefit of low-income residential customers and allow for rates or
charges designed to recover the costs of such programs.
All workshop paricipants were in agreement with the need to increase awareness about
nonprofit fuel fund programs in order to increase the amount of fuding received. Efforts to
increase awareness do not require legislative or Commission involvement. Utilty companies are
encouraged to continue with their creative efforts to make those in the community more aware of
nonprofit fuel fuds. Staff also encourages each utilty to set goals for fud raising and continue
the implementation of programs that parner with local businesses.
All workshop paricipants agreed that an increase in federal fuding for LIHEAP would
be beneficiaL. Additional LIHEAP funds would allow more utility customers to obtain financial
assistance. While increased funding for the curent heating season will certainly benefit
customers, the anual struggle for additional LIHEAP fuding 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 to increase
awareness ofLIHEAP's value and the critical need for additional prograr funding.
Leveraging is a significant tool through which Idaho can increase its federal LIHEAP
fuds. Unfortunately, not everyone is aware of the program or how it works. Staff recommends
16 As an example, the Community Action Partership Agency in nortern Idaho already administers LIRAP for
Avista customers in Washington State.
STAFF'S FINAL REPORT 11 JANUARY 16,2009
that utilties, Commission Staff, and other interested paries partner with CAP AI to identify ways
in which to fuher leverage existing federal LIHEAP fuding.
A new program fuded by Idaho state ta revenue 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 fuded in
the near term. Staff believes that this proposal, though a good idea, should not be pursued until
an environment exists that would make such a proposal viable.
Rocky Mountain Power Response Comments:
Rocky Mountain Power does not believe that establishing a LIRAP program is the
most effective way to reach all low income citizens in the State of Idaho. Rocky
Mountain Power believes it would be more equitable and appropriate for the legislature to
implement a state energy assistance tax. Alternatively, if the Commission determines it
wil encourage and support legislation to offer rate relief, Rocky Mountain Power requests
that the legislation allow the utilties flexibilty in the programs they offer, recognizing the
unique circumstances of each utilty and service area. Further, Rocky Mountain Power
maintains that any legislation would allow for recovery of program costs through a
separate rider or other mechanism on customer bils and that any programs be voluntary
offerings by the utilties.
Rocky Mountain Power curently offers a bil discount program in Utah. Rocky
Mountain Power believes bil discount programs are less costly and less burdensome to
administer and can be designed to provide on-going reliefto low-income customers.
Rocky Mountain Power agrees with Staffs recommendation regarding increased
awareness of and funding for nonprofit fuel funds. Rocky Mountain Power actively strives
to increase customer awareness and funding for the Lend-A-Hand program by distributing
donation envelopes in November, Febru and June bils. Along with the envelope distribution,
Rocky Mountain Power distributes news releases, includes program details in its customer
newsletter, and places programcontrbution information on the website landing page used by
customers who pay their bils electronically.
Rocky Mountain Power wil support efforts to educate and work with Idaho
representatives to raise awareness ofLIHEAP benefits. The Company believes the
STAFF'S FINAL REPORT 12 JANUARY 16,2009
increase in LIHEAP funding for the 2008/2009 heating season is a positive step in
obtaining recognition by the Congressional delegation of the importance of the LIHEAP
program.
Northwest Industrial Gas Users (NWIGU) Response Comments:
NWIGU agrees that the Commission should educate Idaho's Congressional delegation
of the need for increased federal funding for LIHEAP. It also agrees that fuher leveraging of
LIHEAP funds in Idaho should be pursued. NWIGU does not, however, support Staffs
recommendation that a LIRAP program be instituted in Idaho. NWIGU members believe that a
social program to provide financial assistace to low-income households should be considered by
the legislature only in the context of funding by Idaho state tax revenue and should not be
recovered through rates.
NWIGU members support voluntary contributions to non-profit fuel funds as well as
cost-effective conservation programs. NWIGU agrees with Staffs recommendation that
the consideration of low-income weatherization efforts as part of a utility's cost-effective
conservation program should be considered in future rate cases.
While NWIGU realizes that the focus of this proceeding is on low-income
residential consumers, NWIGU urges the Commission to take a supportive role in
proceedings before the Federal Energy Regulatory Commission and other forums by
providing visible support to natural gas resource development and infrastructure proposals
that benefit Idaho (e.g., by intervening in support of pipeline proposals that benefit Idaho
natural gas customers or by intervening in the next round of expected natual gas pipeline rate
cases that will impact Idaho consumers). NWIGU suggests that a more active role by the
Commission in these proceedings would benefit all energy consumers, whether residential
or industriaL.
Intermountain Gas Company Response Comments:
Intermountain Gas supports Staff's recommendation that a dialogue be initiated
with Idaho's Congressional delegation regarding increased awareness of
LIHEAP's value and the critical need for additional program fuding. The
Company also supports Staff's recommendation that the utilties, Commission
STAFF'S FINAL REPORT 13 JANUARY 16,2009
Staff, and other interested paries parner with CAP AI to identify ways in which to
further leverage existing federal LIHEAP funds. The Company states that it has and
will be an active paricipant in supporting the need for increased LIHEAP funding.
Alternatively, Intermountain believes that any LIRAP legislation should recognize and
acknowledge its potential harful effects, e.g., higher rates to the majority of customers,
economic deficiencies, and overuse by subsidized customers.
Intermountain Gas Company believes it is meeting its corporate responsibility
regarding the visibilty and funding of nonprofit fuel funds. Intermountain curently
distributes six (6) separate bil inserts each year regarding fuel funds. In the past, the
Intermountain Industries Foundation has provided funding each year to both Project
Share and Project Warmth. Intermountain has promoted a bil program whereby
customers can pledge dollars on their monthly statements. The Company provides
media coverage for these funds several times a year, including the most recent Season of
Hope campaign with Channel 7 and Idaho Power.
Idaho Power Response Comments:
Idaho Power fully agrees with Staff s recommendation that a dialogue be initiated
with Idaho's Congressional delegation and that interested paries partner with CAP AI to
identify ways in which to furer leverage existing federal LIHEAP funding.
Idaho Power does not endorse Staff's recommendation of legislation allowing
the Commission to adopt utilty programs for financial assistance to low-income
customers. As a matter of public policy, should the State of Idaho decide additional
funds for energy assistance are in the public interest, Idaho Power believes an explicit
state tax is preferable to an additional utilty charge. A state-wide tax would provide the
means for customers of all utilties in Idaho, not just those regulated by the
Commission, to benefit from financial assistance.
Idaho Power fully agrees with Staff's recommendation to increase customer
awareness of and contributions to nonprofit fuel funds. Since the conclusion of the
workshop, the Company has paricipated with KTVB Channel 7's Season of Hope
campaign, actively promoted Project Share donations to its employees, included
information on Project Share in customers' November bills, and increased its
STAFF'S FINAL REPORT 14 JANUARY 16,2009
shareholders' donation for this heating season in recognition of the current economic
conditions.
A vista Response Comments:
Avista supports increased awareness of LIHEAP's value and congratulates
the Idaho delegation for its work to secure the increased funding level for this heating
season. The Company wil continue to work with CAP AI and others to seek
legislative solutions that would allow for greater customer participation in these programs.
In addition to LIHEAP, Avista currently has the Low Income Rate.Assistance
Program (LIRAP) in both Washington and Oregon. Washington's LIRAP program
collects approximately $3.75 milion (natural gas and electric combined) per year through
tariff surcharges. Over 6,290 electric and natural gas customers in the Company's
Washington service territory received grants averaging $396 during the 2007-2008
heating season. In Oregon, a total of3,758 energy grants totaling $1.1 milion have been
provided since the LIRAP program inception in 2002. The purpose of A vista's LIRAP
program is to reduce the energy cost burden among those customers least able to pay energy
bils.
Avista believes it would be "seamless" and in its customers' best interest to add
LIRAP to its Idaho service territory. The Company agrees with Staffs recommendation
to support legislation that would allow the Commission to adopt programs such as
LIRAP. The Company believes that the legislation should allow the Commission to
implement programs for the benefit of low-income residential customers as proposed by
the individual utilties and approve rates or charges designed to recover the costs of such
programs.
A vista promotes Project Share in the communities it serves and supports Staffs
recommendation for utilties to increase awareness of and funding for nonprofit fuel
fuds. The Company is currently making enhancements to the promotion of Project
Share in conjunction with Spokane Neighborhood Action Programs (SNAP), the
recipient and administrating agency for Project Share. A vista has also formed
parnerships with local businesses to help in this effort with the sale of Project Share
branded products.
STAFF'S FINAL REPORT 15 JANUARY 16,2009
AARP Response Comments:
AARP agrees with Staffs recommendation that additional workshops should be
held with the participants in this docket to address the leveraging of LIHEAP funds.
Furhermore, AARP strongly supports the adoption of a bil payment assistance program
for Idaho. AARP recommends the Commission send a clear message to the Legislature that
such legislation is necessary and should be adopted. AARP points out that many states
have payment assistance programs for low income customers, including rate reductions.
AARP maintains that these programs have been found to reduce the number of collection
actions and terminations, and to help customers pay down arrearages.
AARP agrees that it would be difficult for the State to fund a new financial
assistance program through tax revenue given the curent budget projections. However,
AARP believes that this is an option that should be explored in the future.
AARP states that while fuel funds meet only a small portion of the need, they are
necessar to help address energy affordabilty. AARP recommends that the Commission
increase awareness of these fuel funds through an anual news release prior to the winter
heating season.
ICAN Response Comments:
ieAN supports increasing Federal and State funding for the Low Income Home
Energy Assistance Program (LIHEAP). Many ICAN leaders and their neighbors rely on the
LIHEAP program each year. ICAN has supported legislation on both the State and Federal level
to increase fuding for LIHEAP, as well as weatherization programs. ICAN will continue to
support this legislation and urges the Commission and Idaho's utilties to support fuding for the
program in the State Legislature and in Congress. ICAN also believes that the Commission and
utilties should explore other sources of fuding that can be leveraged.
ICAN supports the creation of programs like Avista's Low-Income Rate Assistance
Program (LIRAP) by all Idaho utilties. ICAN will support the necessar legislation to allow the
Commission to adopt a LIRAP program and urges the Commission and Idaho's utilties to support
this legislation as well.
STAFF'S FINAL REPORT 16 JANUARY 16,2009
CAP AI Response Comments:
CAP AI strongly agrees with Staffs general recommendation that LIRAP would be
beneficial for Idaho's low-income utilty customers. CAP AI believes that bil payment
assistance is the most effective and powerful means to address the disparity between need
and resources proposed thus far in this case. Though Staff favors a LIRAP type of
assistance, there is any number of other mechanisms for providing bil payment assistance.
A vista and Rocky Mountain Power curently offer varying bil payment assistance programs
in other states in which they provide service. However, implementation of such a program
would require changes to the Idaho Code as it currently exists. Thus, CAP AI is proposing,
for the 2009 legislative session, legislation that would remove existing general statutory
prohibitions against bil payment assistance programs.
While CAP AI fully supports any effort to obtain additional federal LIHEAP funds
for the State of Idaho, such an endeavor is speculative at best given the fact that all states
compete for federal LIHEAP funds and given the current state of the economy and the
possibilty that curent funding levels might even be decreased. CAP AI recommends that
while the substance of this proposal is worthy, it should not be relied upon to the exclusion
of other proposals more likely to come to fruition.
CAP AI states that the proposal to create a state-funded financial assistance
program with state tax revenues shouldn't be ruled out as a possibilty. However, given
the current economy and the Governor's recent request that all state agencies trim their
respective budgets in response to the current economic crisis, such a proposal is not likely
to prove successful in the near future.
Snake River Allance Response Comments:
The Allance expressed concern that existing funds in the Low Income Home
Energy Assistance Program (LIHEAP) are insufficient to meet the growing demand for
fuds, and recommends that the current workshop process continue with a goal to identify
sources of additional LIHEAP resources. The Allance believes that ensuring all Idahoans
have access to reliable and affordable electricity and natural gas is a fundamental
responsibilty of the State and that the Commission should make that case before the
Idaho Legislature regardless ofthe state's obvious financial challenges. The Allance
STAFF'S FINAL REPORT 17 JANUARY 16,2009
agrees with staff that a LIRAP program would require state legislation, and encourages the
Commission to raise the issue with the Legislature.
STAFF FINAL RECOMMENDATION
Staff recommends that the Commission support legislation to allow it to adopt programs,
policies, and rates for the benefit of low income residential customers. Legislation should allow
the Commission and utilties broad flexibility in determining the parameters of such programs,
policies or rates. Finally, legislation should authorize the Commission to approve rates or
charges designed to recover the costs of such endeavors. While Staff prefers a LIRAP-type of
program because of its simplicity and ease of implementation, it is certainly wiling to consider
other approaches to addressing the problem of energy affordability.
Staff believes it is premature for the Commission to determine what type of rate
mechanism to use or which rate classes should pay for low income programs. Until the
Commission is granted the necessar authority by the State Legislature, it would more beneficial
for the Commission and interested parties to focus on steps that can be taken now to address
energyaffordabilty.
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). 17 It provides a 20% discount on monthly electric bils (rates and
basic charge) for qualified low-income or fixed-income households and housing facilties.
CARE is fuded through a rate surcharge ($0.399 kWh) paid by all other utilty customers.
17 See Appendix 16 for Californa's rate schedule.
STAFF'S FINAL REPORT 18 JANUARY 16,2009
Eligibility is based on household income.18 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.19 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$147.00 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.2o 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.
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 forthe
utilty 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 rates
would most likely have a disproportionately negative impact on low-income customers because
they typically live in less energy-effcient homes and use relatively large amounts of energy.
Low-Income Weatherization, Conservation Education, and Other Energy Effciency Programs
During the workshops, many different methods to encourage energy efficiency were
discussed. These methods included: weatherization, energy conservation education, programs
targeted to low-income customers and seniors, and overcoming bariers to investment in energy
efficiency measures for manufactured homes and rental housing.
18 For example, to quality for the CARE Program, the maximum household income for a family of four is $43,200.
19 See Appendix 17 for Washington's rate schedule.
20 For usage over 600 kWh, customers with income 75% or below the Federal Povert Level (FPL) pay $0.3812 per
kWh. For income 76-100% FPL, the amount paid is $0.2565 kWh; and for income 101-125% FPL, the amount paid
is $0.1603 kWh.
STAFF'S FINAL REPORT 19 JANUARY 16,2009
All workshop paricipants were in agreement that weatherization is an excellent way to
reduce energy costS?1 According to CAPAI, the average investment per home weatherized in
2007 was $3,674. As previously stated, curently only 10% of homes receiving LIHEAP
benefits are weatherized due to the lack of available fuds.22
One example of an innovative program is Idaho Power's Home Weatherization Pilot
Program targeting customers whose income exceeds the qualification guidelines used for low
income weatherization. The Home Weatherization Pilot Program (HWP) wil 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 Parnership.
Weatherization efforts are often coupled with energy conservation education. Workshop
participants agreed that a need exists for fuher education. Unfortunately, as with
weatherization, the funding 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. Paricipants either receive wrtten
material or classroom instruction through workshops and seminars.23 As par of Avista's energy
efficiency program in Idaho this Commission recently approved $25,000 to be used by local
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. Avista 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 expenditues so
that they are able to pay for medication and food. The goal of the workshops is to provide
21 With the exception of Idaho Power, the utilties fud low-income weatherization programs though energy
efficiency tariff riders. Idaho Power's low-income weatherization funding is included in its base rates.
22 See Appendix 12 for a matrix that highlights the schedules and featues of the utilty funded low-income
weatherization programs.23 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 furnace 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 A vista to educate low-income elementary age children and familes about changing
lifestyle habits and using energy more effciently.
STAFF'S FINAL REPORT 20 JANUARY 16,2009
education on energy savings for seniors while allowing for comfort and safety with home energy
use.
Rebates are another example of energy efficiency programs offered by the utilities 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 varing degrees of incentives for
their customers?4 All of the major electric utilties in Idaho also provide rebates to builders and
homeowners who install certain high efficiency appliances in new homes?5 Promoting energy
efficiency 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 Sta(R Homes Northwest. 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 in Washington, Oregon, Idaho and Montana. The program also provides incentives to
builders, suppliers, and subcontractors who construct energy efficient homes.
Customers who live in multi-family, manufactued and rental housing face unique
obstacles with respect to investing in energy effciency 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 filters are installed.
Design Rates to Encourage Energy EfJciency
Workshop paricipants were very interested in the concept of rate design and how it can
be used to promote energy efficiency and benefit low-income and limited income customers. In
response to demonstrated interest, 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
24 Specific programs are outlned in greater detail in Staffs comments fied on November 28,2008.
25 Energy efficiency programs that offer builder incentives are fuded by taiff riders. The cost is borne by utilty
customers as a whole.
STAFF'S FINAL REPORT 21 JANUARY 16,2009
customers. Tiered rates and time-of-use (TOU) rates are examples of rates that provide price
signals that encourage customers to modify behavior because it wil ultimately affect the dollar
amount of their utilty 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, thereby
delaying the need for highly capital-intensive projects to increase base-load facilities.
Tiered rates are biled in blocks. When customers are provided the proper education
regarding tiered-rate structures, they become accustomed to how their consumption affects their
overall bil. Tiered rates are not necessarly low-income rates; they are effciency-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 less energy.
Tiered rates are not new to Idaho. Idaho Power currently has a two-tiered rate structure
for residential customers during the summer period. A vista also has a two-tiered rate strcture
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.
Staff Comments:
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.
Enactment of these or similar programs would require legislation and Commission approval.
Furhermore, programs based on customers' incomes are difficult 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
anually. Because of the cap placed on the number of paricipants, many eligible customers
might be prevented from receiving the program's benefits. Moreover, reduced rates do not
promote energy efficiency. However, the programs may inadvertently encourage effciency
among non-paricipants who are fuding the subsidy.
Energy efficiency 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 fuding to meet the need. Weatherization programs are the most
STAFF'S FINAL REPORT 22 JANUARY 16,2009
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 fuded, fuding should be
increased. The adequacy of program funding is most appropriately addressed durng utility rate
or other formal cases. Therefore, Staff recommends that weatherization and conservation
education program fuding be addressed in future cases before the Commission. Staff fuher
recommends that Idaho Power, Intermountain Gas, and Rocky Mountan 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 utilties examine how additional incentives could be
offered to customers for conversion to higher effciency appliances. Staff recommends that all
utilties consider providing no-interest/low interest loans to customers for the purpose of adding
high efficiency appliances. This would be particularly beneficial 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
effcient construction standards. Staff recommends that utilties encourage the Northwest Energy
Efficiency Allance to include multi-family and manufactued homes in the Energy Sta Home
Program. Because few programs are available to assist customers living in multi-family,
manufactued, and single-family rental housing, Staff fuher recommends that the utilties
consider programs that could assist customers in overcoming the unique obstacles these types of
properties present.
Staff recommends that utilties 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.
STAFF'S FINAL REPORT 23 JANUARY 16,2009
Rocky Mountain Power Response Comments:
Rocky Mountain Power believes that weatherization programs are the most direct
way to reduce energy costs for low-income customers. Rocky Mountain Power provides
$150,000 annually to fund the Low-Income Weatherization Program through Schedule 21.
If this fuding amount is not sufficient to cover annual expenses related to weatherization
services, the Company would be open to discussing a funding increase along with
effectiveness criteria for energy education.
Rocky Mountain Power offers incentives to purchase efficient appliances through
the Home Energy Savings program in Idaho (and other states) and regularly reviews
incentive levels. To increase paricipation, Rocky Mountain Power provided information
on low interest loans to contractors active in the Home Energy Savings program. To
further increase participation in all energy efficiency programs, Rocky Mountain Power
requested proposals for financing in the Company's Demand Side Management Request for
Proposals released on November 26, 2008.
In addition to being an Energy Star partner, Rocky Mountain Power paricipates in
the Northwest Energy Efficiency Allance residential sector meetings. Rocky Mountain
Power agrees with Staff s recommendation to encourage utilties to actively advocate
for adoption and implementation of energy efficient construction standards, including
provisions for single family rental, multi-family, and manufactured homes. Rocky
Mountain Power's existing Northwest Energy Efficiency Allance funding supports
energy code work including education and training for building professionals and officials
on existing codes as well as participation in the state code adoption processes across the
region, including Idaho. Finally, at a more local level, Rocky Mountain Power energy
efficiency programs support the code improvement process by providing incentives for
above code measures and practices.
Rocky Mountain Power is concerned that tiered rates could have unexpected
consequences and mayor may not benefit low-income customers. A tiered rate design
without the abilty to inform customers on a real time basis of their usage may not send
any more of a price signal than flat rates. Rocky Mountain Power offers a residential time-of-
use rate in Idaho which gives customers the abilty to save on monthly bils if they adjust
usage to off-peak times.
STAFF'S FINAL REPORT 24 JANUARY 16,2009
Intermountain Gas Response Comments:
Intermountain is presently exploring ideas and programs for low income
weatherization for customers who may not have the means to fund weatherization on their
own. Intermountain intends to have a list of potential programs and/or activities by March
2009. Many weatherization measures are low in initial cost and can pay for themselves in
savings on energy bils in just a few short months. Intermountain Gas offered no/low-
interest financing in the past, but terminated those financing programs for lack of use.
However, the Company would consider renewing such a loan program for high-
efficiency gas appliances.
As part of consumer outreach in the wake of the Fall 2008 price
increases, Intermountain's field personnel in Boise, Nampa, Twin Falls, Hailey,
Pocatello, and Idaho Falls have made over 75 presentations to various groups regarding
natural gas pricing and efficiency/conservation measures and practices. In addition,
Intermountain Gas Company has been an Energy Star Partner since 2007. In 2008,
Intermountain received the ENERGY STAR for Homes Leadership in Housing Award
presented by the U.S. Environmental Protection Agency for sponsoring more than
250 ENERGY STAR qualified homes. The Company supports and encourages minimum
ENERGY STAR standards in all residential living units including multi-family housing.
Intermountain Gas Company believes that tiered rates, as they pertain to higher
prices for each increment of usage, are applicable in helping to avoid, or otherwise delay,
the construction of incremental electric generation but have limited benefits in the
natural gas industr. Tiered rates might also further exacerbate the abilty of some low-
income customers to pay their natural gas utility bil.
Idaho Power Response Comments:
Idaho Power fully supports weatherization and energy efficiency education as the
highest priority for providing assistance to low-income customers. Dollars spent
weatherizing and performing other energy efficiency measures to the target customer
group provide much more long-term value to the customer and to the energy system
than direct financial assistance.
.
STAFF'S FINAL REPORT 25 JANUARY 16,2009
Idaho Power has been an active proponent for the adoption of energy efficient
construction standards and supports Staffs recommendation that efforts in this area, as
well as efforts targeting multi-family and manufactured housing, continue. Idaho Power
does not support Staffs recommendation that utilties consider loans to customers for
the purpose of adding high-efficiency appliances. The Company believes that loans
should be managed by financial institutions and that other approaches to encourage the
adoption of energy efficient appliances should be investigated.
Idaho Power agrees with Staff's recommendation not to recommend adoption of
reduced rates at this time because there are other preferable options available to the
Commission to consider. All customers should see an economic price signal on
their usage. Many low-income rate designs eliminate this signaL. Therefore, Idaho
Power advocates for a separation between the biling for utility service and the energy
assistance used to pay those bils.
Idaho Power fully agrees with Staff's recommendation to consider tiered rate
designs for residential customers as a way to give customers control over their bils by
providing an incentive to lower their energy consumption. Idaho Power has fied to
implement year-round tiered rates in its residential customer class in its pending general
rate case (IPC-E-08-10) and is also completing its second year in a Fixed Cost
Adjustment mechanism (decoupling) that is applicable to both the residential and small
general customer classes.
Avista Response Comments:
A vista has a two-tiered residential rate structure. The present rate strcture
essentially provides a price-signal for all weather-sensitive usage greater than 600
kWh's per month. The Company had a three-tiered inverted rate structure in effect
from 1980-1999. The Commission approved the Company's proposal to move from three
to two tiers in 1999 partly because of the high proportion of lowllimited income
households who used electric heat.
Last year A vista increased its support of low-income weatherization and
conservation education support by almost 40% to a total of $485,000. Avista is an
advocate for energy conservation education. The Company has sponsored and led
STAFF'S FINAL REPORT 26 JANUARY 16,2009
conservation education workshops, prepared written material for distribution, provided
specific measures (compact fluorescent light bulbs, caulking, gaskets, etc.) free-of-
charge, responded to requests for speaking engagements and worked closely with our
agencies to educate customers on the wise use of energy and options they have for
no-cost and low-cost energy saving improvements.
In regards to low- or no-interest loans, A vista is examining expansion of current
customer options. In 2008, A vista worked with the Sustainable Lending Investment
Partnership (SLIP), a consortium of local banks that desire to offer customer
loans for energy efficiency improvements. SLIP's initial focus is on commercial
customers; however, offerings to residential customers is under consideration. Avista
would prefer to work with the existing financial institution infrastructues that have this
function as their primary service. If the Company were to "buy-down" the interest rate of
consumer loans, this would likely decrease the amount of incentive payments by a
corresponding leveL. A vista recommends that the provision for low-cost consumer loans
be pursued with area lending institutions.
A vista continues to review our incentive programs and the level of incentive
amounts on an ongoing basis. For example, in 2008 the Company increased our
support of ENERGY STAR~ appliance rebates and increased our Washington cap on
incentives from 30% on natural gas to 50% (as we had previously established in Idaho).
Avista strongly supports initiative(s) by the Northwest Energy Efficiency
Allance to include multi-family and manufactured homes in the ENERGY STAR~
Home Program. A vista has contracted with DCONS, a third part energy efficiency
service provider, to increase our energy effciency savings in the hard-to-reach multi-family
market. In 2008, A vista initiated a market transformation program to increase the penetration of
natural gas in multi-family new constrction. The Company estimates that less than 10%
of new constrction in its service territory has installed natual gas heating; the national
average is greater than 60%. Avista supports improved appliance and building standards
and codes as the most cost-effective means for energy efficiency delivery.
STAFF'S FINAL REPORT 27 JANUARY 16,2009
AARP Response Comments:
AARP supports tiered rate structures, also called an "inclining block" rates,
provided the first tier of usage is priced affordably and contains sufficient usage to meet
basic needs.
AARP supports reduced rates for low income customers. Such rate programs have
been adopted in other states and have been successfully implemented by utilties. In fact,
utilties serving Idaho offer reduced rates, including PacifiCorp (Rocky Mountain Power)
in California and Washington. AARP states that while increased awareness and funding
of energy efficiency is a necessar component of affordabilty, it is not sufficient alone.
Rate assistance is also essential for the lowest income customers to close the "energy
affordabilty gap." Finally, AARP believes it is inappropriate for Staff to limit an option
for affordabilty because the utilties do not support it. Commission Staff should judge
policies and proposals in terms of whether they achieve the goal of this workshop.
An argument raised during the workshops was that other customers or non-
residential customer classes should not experience rate increases in order to fund a
discount. However, AARP states that all customers benefit when arrearages and collection
costs are reduced because lower income households can better afford their bils. Spreading the
cost of a low income rate across all customers is the same as Idaho Power seeking
Commission approval to socialize the cost of a program that wil give bil credits to
irrigators who agree to cut usage during peak periods. Idaho Power argues that all
customers benefit when irrigators are paid to reduce usage.
AARP agrees that energy efficiency should make energy more affordable by
helping consumers to lower both usage and bils and that these programs should be made
more available. However, the Commission should ensure that funding for energy efficiency
programs is cost effective. Customers should see lower bils if they engage in energy
efficiency and lower usage. AARP recommends the Commission specifically direct
utilties to take action, and, further, that the utilities periodically report on their progress to
participants in this proceeding.
STAFF'S FINAL REPORT 28 JANUARY 16,2009
ICAN Response Comments:
ICAN strongly support increased funding for weatherization and energy
efficiency education programs. Many low-income familes live in housing that is inefficient,
and have no abilty to weatherize it on their own. Increasing the contribution of utilty companes
as par of their conservation measures enables more familes to live in energy efficient homes,
which benefits both them and the utilty companes. ICAN also favors expanding programs like
the Idaho Power pilot project that will provide weatherization assistance to familes above the 150
Federal Povert LeveL. Many familes with incomes above that level are unable to weatherize
their homes or keep up with utility bils.
ICAN supports increased fuding for education programs, but its experience has shown
that education alone is not enough; without fuding for weatherization, many of the more
effective measures are not possible. ICAN urges the Commission to require utilty companies to
increase their fuding for both weatherization and education programs.
ICAN strongly supports Staffs recommendation to change the Idaho Power rate strcture
to include a third tier, and increase the size of the first and second tiers. Pairing this rate
structure with increased funding for weatherization, including funding for customers
who do not qualify for LIHEAP weatherization fuding, will provide relief for many low-
and moderate-income customers.
CAP AI Response Comments:
With respect to reduced rates for low-income customers, CAPAI reiterates its
comments made regarding bil payment assistance through utilty-funded programs. That
is, whether bil payment assistance is achieved though a LlRAP, discounted rates, or any
other means, a change to existing legislation is likely required. Though CAP AI's
recommendation is to give public utilties the authority to propose and implement
whatever form of bil assistance that a utilty deems best suited to its customers, CAP AI in
no way proposes mandating discounted rates, as opposed to other forms of assistace.
CAP AI recommends a tiered residential rate design that incorporates a "lifeline"
level of usage priced at a lower rate, which not only allows low-income customers to
consume the basic level of utilty service needed to live a healthy existence, but also
promotes energy efficiency, something that ultimately proves beneficial to all utilty
STAFF'S FINAL REPORT 29 JANUARY 16,2009
customers by lowering overall rates.
F or tiered rates to be effective in assisting customers to achieve energy
affordability, however, the tiered rate design must be strctured appropriately. The design
must serve the dual purpose of assisting low energy consumers and sending proper pricing
signals regarding the cost of supplying gas and electricity. For those utilties who do not
have tiered residential rates, CAP AI strongly urges the Commission to mandate said tiers.
CAPAI observes that in regards to conservation education, most if not all of the public
utilties participating in this case have some form and level of conservation education
program already in place. What CAP AI believes is missing are conservation programs
that specifically target low-income customers.
In its most recent rate case, A VISTA agreed to fud a progra that would enable the CAP
agencies to provide conservation education to customers who apply for LlHEAP.
Providing these customers with information on how they can reduce their utility consumption
with relative ease at little or no cost, particularly when they are meeting face to face with
CAP employees during the LIHEAP application process, wil very likely result in reduced
utilty consumption and cost. CAP AI strongly urges all other public utilties to
acknowledge the benefits, both to low-income customers and to the overall system, of this
type of program and to provide sufficient funding to the CAP agencies to implement it.
Snake River Allance Response Comments:
The Allance believes the Commission and Idaho's regulated utilities should
consider implementation of rate designs that allow lower-income energy consumers to
benefit from a tiered rate structue that sends strong price signals to all consumers.
Specifically, a year-round tiered rate strctue would provide lowest-cost rates to consumers
using less energy than those using more. The Allance urges the Commission to tae a
broader examination of how rate design can be used to encourage energy efficiency and
conservation and also to reduce consumers' utilty costs.
The Allance also believes Idaho law must be changed to allow for within-class
rate discrimination, i. e., allowing utilties to request that they be allowed to offer lower
residential rates to lower-income consumers. The Allance urges the Commission and Staff
to continue to work with low income advocates such as CAP AI and the utilties to negotiate
STAFF'S FINAL REPORT 30 JANUARY 16,2009
language that is satisfactory and present it to the Idaho Legislatue during the 2009 session.
With regard to energy efficiency and conservation, the Allance appreciates the
significant progress made by Idaho utilties in expanding their demand-side management
programs and initiating new programs in all rate classes. However, weatherization and other
DSM programs targeted at the residential class must be enhanced and further funding
(through increased energy efficiency tariff riders) must be provided. Idaho's community
action agencies have performed admirably in weatherizing as many qualified homes as
possible with existing funds, but it is clear that those funds are inadequate. The State of
Idaho and its regulated utilities must commit to weatherizing all qualified homes.
STAFF FINAL RECOMMENDATION
Staff continues to recommend that weatherization and conservation education program
fuding be addressed in future cases before the Commission. Staff also recommends that all
utilties examine how additional incentives could be offered to customers for conversion to
higher efficiency appliances. While Staff encourages utilities to consider providing no-
interest/low interest loans to customers for the purpose of adding high efficiency appliances, it
recognizes that there may be other alternatives, particularly for those customers who fall just
outside the income guidelines to qualify for low-income weatherization. In addition to exploring
financing options, Staff recommends that all utilties examine how more cost-effective incentives
can be offered to customers for conversion to higher effciency appliances.
Staff continues to recommend that utilties advocate adoption and implementation of
energy efficient construction standards. Staff recommends that utilties encourage the Northwest
Energy Effciency 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 fuher recommends that utilties consider
programs that could assist customers in overcoming the unique obstacles these types of
properties present.
Staff continues to recommend that utilties consider tiered rates for residential customers
as a way to provide an incentive to lower their energy consumption. Staff recommends that
tiered rate design be addressed within the context of future rate cases. Staff does not presently
STAFF'S FINAL REPORT 31 JANUARY 16,2009
recommend the adoption of reduced rates for low-income customers until the statutory
impediment to consideration of such rates is removed.
Bil Mitigation, Reduction of Customer Costs, and Removal of Barriers to Obtaíníng or
Retaining Service
Utilties' credit and collection policies have a direct impact on customers' abilty to pay.
Determining how and when customers must pay, the conditions under which charges associated
with payment or non-payment are assessed, and the requirements for obtaining or retaining
service are all critical components of credit and collection policies. Taken as a whole, the
policies govern the daily interaction of utilties and their customers.
It is easier for customers to manage their bils if utilties offer flexible payment options
and determine customer-specific affordable payment amounts instead of rigidly adhering to pre-
determined formulas. During the workshops, two payment options were discussed: 1) offer
plans that allow payment of arears (past due amount owed) over an extended length of time
(more than 12 months), and 2) offer a percentage of income payment plan.
Charges associated with certain transactions impose additional costs on customers
independent of their energy usage. Customer costs can be reduced by lowering or eliminating
charges associated with making a payment, reconnecting service following disconnection for
non-payment, and interest assessed on late payments.
Finding ways to make it easier for customers to obtain service or avoid disconnection is
.an important component of customer-focused credit and collection policies. 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
arearage forgiveness plans.
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 utilty bils in full. The Commission's rules require utilties to tae into
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
STAFF'S FINAL REPORT 32 JANUARY 16,2009
to enter into a second such agreement. Each utility offers both short-term (30-45 daysi6 and
long-term (up to 12 months)
27 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 canot meet in an attempt to prevent immediate disconnection.
Staff Comments:
As previously stated, customers are facing an aray of issues that are impacting their
ability to pay utility bils. It is likely that an increasing number of customers will need to make
payment arrangements. Staff recommends that utilties 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 utilties to incur higher bad debt if customers continue to default on
payment arangements. However, by offering customers payment arangements that are more
flexible and tailored to the each customer's needs, utilties stand 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
utilities.
Implementation of new payment arangement alternatives can be accomplished through
cooperation with the utilties and making modifications, if necessar, 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 further
workshops to confer and attempt to identify solutions.
26 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 61-90 day balance, whichever is greater,
immediately with the remaining balance due within 30 days.
27 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. Avista has a Levelized Payment Plan that allows customers to pay their past due balance over a 12 month
period in addition to their current monthly biling.
STAFF'S FINAL REPORT 33 JANUARY 16,2009
Avista, Idaho Power and Rocky Mountain Power Response Comments:
Avista, Idaho Power, and Rocky Mountain Power agree with Staff's
recommendation to have further discussions with Staff and other interested paries
regarding payment arrangement alternatives. Neither Idaho Power nor Rocky
Mountain Power are convinced that extending payment arangements beyond
twelve months wil result in more customers keeping their payment arrangements.
Intermountain Gas Response Comments:
Intermountain Gas Company believes payment plans should be set in order to
repay arears in a timely manner and foster on-time payment of future bils.
AARP and ICAN Response Comments:
AARP and ICAN support providing greater flexibilty in payment arrangements
alternatives and encourage further discussion on that topic among all interested parties.
AARP recommends the Commission also request the utilties to report on payment
arrangements curently offered, the number of customers on each type of plan, and the
success of the payment plans. ICAN urges the Commission to make these policies
mandatory by incorporating them in changes to the Utilty Customer Relations Rules
(UCRR).
Offer 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 utilty. 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 utility 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. Ifa
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
STAFF'S FINAL REPORT 34 JANUARY 16,2009
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.
Staff Comments:
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. Inaddition,
implementation of a percentage of income payment plan would require modification of most
utilties' 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 utilities' opposition, Staff recommends that this option not be pursued at this time.
Idaho Power and Rocky Mountain Power Comments:
Idaho Power and Rocky Mountain Power concur with Staff's recommendation
that a percentage of income payment plan not be pursued at this time. Idaho Power
agrees with Staff that the major impediments associated with this option are the lack
of encouragement for energy conservation, the costs associated with modifying
billng systems, and the need for legislation in order for utilties to offer such a plan.
In addition, Idaho Power indicated that another significant impediment associated
with this option is the lack of an established process for qualifying customers for
this type of payment plan.
AARP and ieAN Response Comments:
AARP and ieAN support Percentage of Income Payment Plans (PIPP). Both
point out that several states have implemented these plans, which enhance affordabilty by
capping payments for low income customers at a certain percentage of their income. ICAN
supports continued research and discussion of ways to implement similar policies in Idaho.
STAFF'S FINAL REPORT 35 JANUARY 16,2009
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 incurred in order to pay a bil. Intermountain Gas and Rocky Mountain Power
provides a free web-based option for paying bils to customers with checking accounts.
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.
A customer has some options for payment of his or her utility 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 utilities 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 utilities 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) for processing payments.
Curently, customers ofIntermountain Gas and Rocky Mountain Power are required to pay $1.00
to process their payments at authorized payment stations; Idaho Power and A vista customers are
not required to pay convenience fees.
Staff Comments:
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-
STAFF'S FINAL REPORT 36 JANUARY 16,2009
depth discussion among all interested paries regarding how convenience fees can be eliminated
or reduced.
A vista, Idaho Power and Rocky Mountain Power Response Comments:
A vista, Idaho Power and Rocky Mountain Power are wiling to participate in
further discussions regarding convenience fees with Staff and other interested parties.
However, Rocky Mountain Power believes lowering or eliminating convenience fees
assessed to low-income customers would likely be considered discriminatory and would
require legislation to be enacted. A vista indicated that it is currently negotiating with a new
vendor to reduce its convenience fees for 2009.
Intermountain Gas Response Comments:
Intermountain Gas notes that there are several low cost and no cost payment
options available for customers who are concerned with the cost of convenience fees.
ICAN Response Comments:
ICAN leaders have reported that payment charges are a serious barrier to
affordabilty. Rural customers in paricular report that it is very diffcult to make timely
payments without utilizing payment methods that incur these charges, especially since utility
companies have reduced the number of locations at which customers can pay their bils. ICAN
urges the Commission to eliminate these payment charges.
Reduce or Eliminate Reconnection Charges and Interest Assessed on Late Payments
All energy utilties charge for reconnection of service. Charges vary according to when
reconnection takes place. All energy utilties 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.
STAFF'S FINAL REPORT 37 JANUARY 16,2009
Staff Comments:
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 types 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.
Idaho Power and Rocky Mountain Power Response Comments:
Idaho Power and Rocky Mountain Power believe that legislation is necessar in
order for reconnect charges and interest assessed on late payment to be reduced or
eliminated only for low-income customers. However, the reduction or elimination
of these fees removes an incentive that is curently in place for customers to pay their bils
on time and to avoid service termination. Idaho Power states that removal of these
fees may also remove the incentive for customers to contact the utilty to make
payment arangements. Idaho Power does not support reduction or elimination of
reconnection fees and interest charges.
Intermountain Gas Response Comments:
Intermountain Gas Company believes reconnection fees and late interest
charges are a fundamental aspect of the biling process in helping to promote
responsible payment habits. Reconnection fees help recover costs incurred by the
utilty in order to restore service. If these fees were eliminated, these reconnection
related costs would then need to be passed on to, or subsidized, by the remaining bil
paying customers. Eliminating late interest charges would encourage late paying
customers to forego or delay the timely payment of their energy bil in lieu of paying
other outstanding debts that have higher fees and consequences. Additionally, biled
interest charges help to offset the caring charges borne by the company. Forgiving
these offsets would create the need for further subsidy by the remaining "on-time" bil
paying customers.
STAFF'S FINAL REPORT 38 JANUARY 16,2009
A vista Response Comments:
A vista does not support the elimination of reconnection and interest charges, but is
wiling to work with interested parties as they review these charges. The Company
reduced its reconnection charge by 50% for customers participating in Avista's Remote
Disconnectionieconnection Pilot Program, and notes that the evaluation process for this
program wil provide additional insight on the opportity to reduce reconnection costs.
AARP Response Comments:
AARP agrees with Staffs recommendations regarding reconnection charges and
interest assessed on late payments. It recommends the topic be included in ongoing
dialogue among the participants in this proceeding.
ICAN Response Comments:
ICAN supports eliminating reconnection charges and interest assessed on late
payments. These create even larger bariers for families who are already having difficulty, and
are counter-productive to the shared goal of ensurng that familes are able to pay bils on time.
ICAN also urges the Commission to incorporate these changes in the Utilty Customer Relations
Rules (UCRR).
Snake River Allance Response Comments:
The Allance agrees with low-income advocates that disconnects and reconnects,
which are particularly problematic for low-income customers, must be avoided as much as
possible and policies must be implemented to do so. It has been established that the costs
associated with disconnects and reconnects are not only a fiancial burden to afected customers,
but are also borne by all ratepayers. The Allance believes a combination of bil-pay assistance,
rate reduction, more flexibility in paying off arearages, and the elimination of reconnection fees
wil greatly reduce the burdens facing many of Idaho's low-income utilty consumers.
Modify Deposit Policies
STAFF'S FINAL REPORT 39 JANUARY 16,2009
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
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 bil.
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 tariff, 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
written-off accounts.
Alternatives to existing deposit policies explored during the workshops include: 1)
allowing payment over an extended period of time; 2) reducing the dollar amount of deposits; 3)
waiving deposits under certain circumstances; or 4) deferrng collection of a deposit subject to
futue payment performance. These alternatives can be implemented by utilties voluntarly.
However, changes to the Commission's rules might be necessar.
STAFF'S FINAL REPORT 40 JANUARY 16,2009
Staff Comments:
Staff recommends a more in-depth discussion among all interested paries of the
alternatives to existing deposit policies identified above. Staff also recommends that one or
more utilties conduct a study of the effectiveness of collecting residential deposits.
A vista, Idaho Power and Rocky Mountain Power Response Comments:
A vista, Idaho Power, and Rocky Mountain Power will paricipate in fuher discussion
related to alternatives to existing deposit policies. A vista offered to conduct a study of the
effectiveness of collecting residential deposits and provide its results to the
Commission in 2009.
Intermountain Gas Response Comments:
Intermountain Gas believes that obtaining financial security from at risk
customers is an essential practice in mitigating bad debt losses and in controlling
potential rate increases to all customers. Realizing that an additional cash deposit can
be difficult for struggling customers, Intermountain Gas indicates that it offers alternative
security solutions, such as a guarantor, where no cash transaction is needed to satisfy the
deposit request. The administrative costs associated with deposits are, by far,
outweighed by the potential bad debt losses that are prevented through the Company's
deposit practices. Deposit polices act in the interest of all ratepayers because these
customers are the ones that ultimately bear the burden of higher rates when bad debt
losses are not controlled. Intermountain's deposit practices were a focal point of a
recent credit and collections audit conducted by the Idaho Public Utilties
Commission. The findings of that audit concluded that Intermountain was not
sufficiently mitigating potential bad debt with its current deposit strcture and
recommended strengthening financial security measures.28
28 Intermountain Gas does not accurately characterize the Stafls audit findings. Staff found that the Company's
methodology used to predict who should pay a deposit had a significantly high error rate. For example, of the
customers who were identified as credit risks and required to pay a deposit, 46% proved not to be a credit risk and
were refunded their deposits with interest. Only 50% of the customers turned off for non-payment had been
previously identified as a credit fisk and required to pay a deposit. For those customers with higher usage, the
deposit amounts that were collected were in many instaces not sufficient to cover the amount owing.
STAFF'S FINAL REPORT 41 JANUARY 16,2009
AARP Response Comments:
AARP agrees with Staffs recommendations regarding deposits. It recommends the
topic be included in ongoing dialogue among the participants in this proceeding. Utilties
should be encouraged to voluntarily modify deposit requirements and to report to the
Commission on their offerings.
ICAN Response Comments:
ICAN supports eliminating deposit policies by the utilty companies that stil
require customers to provide deposits. Idaho Power has successfully eliminated deposits,
concluding that they are not cost-effective. Deposits are, however, very effective at preventing
low-income customers from accessing utilty services. ICAN urges the Commission to change
the Utilty Customer Relations Rules (UCRR) to end the practice of requiring customers
to provide deposits.
Allow Installment Payments on Prior Bils
A utilty 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 securty numbers to
obtain service. Utilties also report instaces 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 otherwse might not have collected.
Staff acknowledges that the utilities would need to more closely monitor the accounts of
customers who are permitted payment arrangements for arearages in order to avoid additional
unpaid bils.
STAFF'S FINAL REPORT 42 JANUARY 16,2009
Staff Comments:
Staff recommends that utilities adopt new policies whereby lower risk applicants be
permitted to payoff old bils in installments while receiving new service.
Rocky Mountain Power Response Comments:
Rocky Mountan Power's curent repayment policy for all customers is to obtain one-half
of the outstanding amount up front and one-half within 30 days. The Company does not
consider any customer with an old bil to be lower risk and treats all of these customers
uniformly. The Company is concerned that changing this policy could result in an
increase in write-offs.
Idaho Power Response Comments:
Idaho Power considers any customer who has not paid the balance owing on
prior bils to be a risky customer. However, the Company does take the amount of the
unpaid prior bil into account when assessing risk and considers those customers with
unpaid bils greater than $100 to be a higher risk than those customers with unpaid bils
under $100. Currently, Idaho Power allows customers who have old bils under $100
and who are moving into premises that currently have active service to payoff the old
bils in installments. Idaho Power would be wiling to consider changing its practices
and allow all customers with old bils under $100 the option to pay the balance in
installments in order to receive new service.
Idaho Power believes that income cannot be used to identitY customers who
would be permitted to pay old bils in installments. Therefore, any change to the
Company's practice would apply to all customers. Due to the increased risk of
additional write-off-balances that would likely occur should this approach be taken,
Idaho Power recommends that Staff and the other parties explore changes to Rule 310
that would allow service to be terminated for non-payment of the payment arrangement for
the old bil regardless of the amount remaining unpaid.
STAFF'S FINAL REPORT 43 JANUARY 16,2009
Intermountain Gas Response Comments:
Intermountain Gas Company does not support Staff's recommendation to
allow customers to payoff old bils in installments while receiving new service.
Risk is inherent with the existence of a prior outstanding bil by the customer. To
fuer delay payment would jeopardize both the old debt as well as any new
debt created from the establishment of a new service.
AARP Response Comments:
AARP agrees with Staff that installment payments would be an effective means of
allowing customers to catch up on past due bils and maintain service. However, AARP
suggests that the Commission and interested parties should be involved in development of
such plans. For example, the term "lower risk" could be applied differently across utilties
if there is no guidance from the Commission. AARP recommends the topic be included in
ongoing dialogue among the participants in this proceeding. In the short term, utilties
should be encouraged to voluntarily offer these plans and to report to the Commission on
their offerings.
ICAN Response Comments:
ICAN supports Staff's recommendation to allow installment payments on prior
bils, but urges the Commission to make this policy part of the Utility Customer
Relations Rules (UCRR), rather than relying on the utilities to voluntarly adopt the policy.
ICAN is also concerned that the policy would be restrcted to "lower risk applicants." Utilty
companes are much more likely to consider low-income customers to be "high nsk," so the
customers most in need of the assistance would be the least likely to benefit from it.
Offr Arrearage Forgiveness Plans
Arearage forgiveness plans provide customers the opportunity to have arearages
forgiven over a period of time if customers pay futue bils on time. Such plans offer financially-
troubled customers an incentive to build a positive credit history with the utilty, since their debt
will 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
STAFF'S FINAL REPORT 44 JANUARY 16,2009
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:
Staff recommends that all energy utilties develop arearage forgiveness plans. While
Staff acknowledges that this type of policy would not be appropriate in all instaces, more in-
depth discussion among all interested paries is necessary to identify the circumstaces under
which arrearage forgiveness should be offered.
Idaho Power and Rocky Mountain Power Response Comments:
Idaho Power and Rocky Mountain Power do not support Staff's recommendation
for arrearage forgiveness plans. Both companies believe this would also require legislation
to be enacted. According to Rocky Mountain Power, arearage forgiveness programs initiated by
other utilties have been deemed to be unsuccessfu and terminated.
Intermountain Gas Response Comments:
Intermountain Gas Company is supportive of any effort that can help a customer
pay, or become current, with their energy utilty bil in a responsible fashion. To
'forgive" a customer's obligation to pay for the energy that they have consumed and
benefited from creates upward price pressure on the remaining customers of the
utilty.
A vista Response Comments:
In an effort to offer bil payment solutions for our low income customers,
A vista has researched arrearage forgiveness plans. A vista states that although arrearage
forgiveness programs can be positive for some customers, the amount recovered from all
other ratepayers under an arrearage forgiveness plan is unknown and would require
additional research and planning.
STAFF'S FINAL REPORT 45 JANUARY 16,2009
AARP Response Comments:
AARP agrees with Staff that arrearage forgiveness plans would be an effective
means of allowing customers to get out from under past due bils and maintain service.
However, AARP suggests that the Commission and interested parties should be involved in
development of such plans. AARP recommends the topic be included in ongoing dialogue
among the paricipants in this proceeding. In the short term, utilties should be
encouraged to voluntarily offer arrearage forgiveness and to report to the Commission on
their offerings.
ICAN Response Comments:
ICAN strongly supports implementing arrearage forgiveness plans for all Idaho
utilities. I CAN maintains that these programs have shown that everyone benefits, from the
utilities and the customers who are directly affected, to other customers who benefit from lowered
utilty administrative costs. ICAN urges the Commission to include this policy in changes to the
Utilty Customer Relations Rules (UCRR).
STAFF FINAL RECOMMENDATION
Staff recommends that there be further discussion involving Staff, the energy utilties,
and other interested parties regarding all of the alternatives previously identified. The best
approach is to explore in greater depth the benefits, costs, and disadvantages of each
alternative, recognizing that each one must fit into a unified and reasonable credit and
collection policy that balances the interests of both utilties and their customers. Staff does
not recommend immediate adoption of any particular alternative at the present time. To
ensure that all interested parties use their time effectively, Staff recommends that discussion
of percentage of income plans be postponed until the statutory obstacle to income-based plans
is overcome. Staff recommends that the Commission accept Avista's offer to conduct a study
to determine the effectiveness of deposits.
STAFF'S FINAL REPORT 46 JANUARY 16,2009
Offer Case Management
The objective of good case management is to provide personalized customer assistace.
Ideally, case managers would identify both utility and non-utilty programs and resources that
wil 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 communcating with utilties. Through effective case management, a
utility can offer more specialized one-on-one customer assistance 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, taking 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 Assistace 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.
A vista maintains that the program is cost-effective because it directs resources toward keeping
customers on service by taing 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 will include assisting customers who have
difficulty paying their utilty bils due to extenuating circumstances such as medical problems or
lost jobs. The specialists will also provide assistance in identifying ways to conserve energy.
The specialized duties wil be added to existing supervisory positions in Intermountain's local
offces in Idaho Falls, Pocatello, Twin Falls, Boise, and Nampa. The Company anticipates that
its program wil be in place during the 2008/2009 heating season.
Staff Comments:
A vista and Intermountain Gas should be commended for recognizing the need for case
management programs. One-on-one assistance provides a needed safety net for many at risk
STAFF'S FINAL REPORT 47 JANUARY 16,2009
customers. Customers are able to stay on service and establish a mutually-beneficial credit
relationship with utilties. Utilties benefit by avoiding wasting resources on unsuccessful
collection efforts, losing customers through involuntar disconnection of service, and creating
bad debt by prematurely disconnecting service to customers who are willng to pay. Staff
recommends that those utilties 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
assistance that they will be able to provide to customers. After the Company has gained
experience with its program it can make any necessary modifications.
Staff notes that no prior Commission approval is necessar for a utilty to implement a
case management program.
Rocky Mountain Power Response Comments:
Rocky Mountain Power does not endorse Staffs recommendation for all utilties to have
a formal case management program. While Rocky Mountain Power does not have a
specific designation of a "case management" program, the Company believes it has a
process in place to work with individual customers on a case-by-case basis.
Intermountain Gas Response Comments:
Intermountain Gas Company is in full support of case management and
empowers all employees to make decisions that can provide solutions and service for
customers having difficulty paying their bil in fulL. Intermountain continues to expand its
case management processes and has implemented a program that provides specialized
help for customers with extenuating circumstances.
Idaho Power Response Comments:
Although Idaho Power does not have an advertised case management program
such as A vista's CARES program, Idaho Power does have an effective case
management process in place for the neediest of its customers. Current case
management support comes from a coordinated effort among its employees. Employees
STAFF'S FINAL REPORT 48 JANUARY 16,2009
)
work with individual customers who are experiencing unordinary situations,
consulting with community action agencies and other organizations, making on-site
visits to the customers' premises, and identifying workable payment solutions. Idaho
Power is wiling to consider other ways in which it can augment its current case
management process.
Avista Response Comments:
The Company is very proud of its Customer Assistance Referral Evaluation
Service (CARES) program. Avista CARES representatives assist customers with
special needs -- the elderly, the disabled and customers who find themselves in difficulty
due to health, employment, family or other problems.
AARP and ICAN Response Comments:
AARP and ICAN agree that utilties should implement case management
programs. AARP recommends that the Commission request utilties to report on whether
they curently have case management programs or when they do implement such
programs.
STAFF FINAL RECOMMENDATION
Staff recommends that those utilties without case management programs implement such
programs. Furher review is necessary to determine if existing practices and "informal"
programs provided effective case management.
Dated at Boise, Idaho this 16th day of Januar 2009.
Technical Staff: Beverly Barker
Marilyn Parker
Curtis Thaden
i:/umisc/comments/gnru08. I ksbabmpct staff final report
STAFF'S FINAL REPORT 49 JANUARY 16,2009
Summary:
Appendi 1
Appendi 2
Appendi 3
Appendix 4
Appendix 5
Appendi 6
Appendi 7
Appendi 8
Appendi 9
Appendi 10
Appendi 11
Appendi 12
Appendi 13
Appendi 14
Appendi 15
Appendix 16
Appendi 17
Appendi 18
Aiendices
Energy Burden and Affordabilty 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 Warth/Keep Kids War Contrbutions/Grants-
Interountai 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)
LIRA/Oregon (Avista Schedule 493)
CAR/Californa (pacificorp Schedule DL-6)
Tiered Rate/Washington (pacificorp Schedule 17)
MATRIX
Appendix 1
Energy Burden and Affordability GAP:
In examinig an individual's ability to pay hislher 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
varables. The ''burden'' imposed by the cost of home energy usage is greater upon 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 Pover Level, 13.6% of the household's income is used to pay for
home energy. For households below 50% of the Federal Povert Level, 47.8% of anual
income is used to pay for home energy bils. This equates to nearly half of their anua
income being spent on energy that greatly impacts the household's ability to meet other
living essential expenses such as food and clothig. The table below reflects the varous
energy burden percentages for low-income Idaho households.
Povert Level Odaho)Income - Famiy of 4 Energy Burden
Households Below 50%$0 -$10,600 47.8%
Households 50-74%$10,600- $15,688 19.1%
Households 75-99%$19,900- $20,998 13.6%
Households 100-124%$21,200- $26,288 10.6%
Households 125-149%$26,500- $31,588 8.7%
Households 150-185%$31,800- $39,220 7.1%
Appendix I
Case No. GNR-U-08-1
Staff Comments
01/16/09 Page 1 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% of the Federal Pover
Guidelines in each county to the total state population who are below 185% of the
Federal Povert Guidelines. The calculation used to deterine 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% oftheIr 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 deterine whether
the Home EnergyAffordability 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 1 00%. An Index greater than 1 00 indicates that the Affordabilty 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 Gap in Idaho was 127.8,
which is an increase of27.8% from the 2002 Base Year.
Source: On the Bri: 2007, The Home Energy Affordability Gap by Fisher, Sheehan & Colton, Public
Finance and General Economics, Apri 2008.
Appendix I
Case No. GNR-U-08-1
Staff Comments
01/16/09 Page 2 of2
Appendix 2
Demographics:
When looking at each county within the serce terrtory, it is obvious that some
counties are better off than others. Blaie County has the state's highest median and
average income, a ver low unemployment rate (2.5%), and the lowest pover rate
(5.9%) in the state. In contrast, Madison and Owyhee Counties have ver low median
and average incomes and the highest percentages (15.4% and15.6%) of individuals living
in povery. Additionally, Owyhee County has the lowest unemployment rate (2.2%) in
the state and the second highest percentage (23 %) of individuals that speak a languge
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 Nortern 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 dimiished job opportties and advancement. With
unemployment on the rise, the number of individuals needing assistance wil become
greater.
Four counties (Butte, Idaho, Shoshone, and Washigton) have high percentages
of perons over 65 years of age (over 16.3%) and ver high percentages of people living
in pover (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
povert (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 within a county and the percentage of a county's
. population who are povert strcken may exist. The likelihood of seniors to be on fixed
incomes tends to make ths portion of the populace the most vulnerable to increases in
living expenses.
Appendix 2
Case No. GNR-U-08-1
Staff Comments
01116/09 Page i of2
In Gooding, Jerome, Latah, Madison, Owyhee, and Twin Falls Counties, the
unemployment rate is lower than the state average of3.4% but the pover 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 opportity of economic advancement. Relatively 10w-
paying jobs in these largely rual agrcultual communties help explain ths situation.
A ver important point to highight is that the Federal Pover Level Guidelines
do not necessarly reflect an accurate gauge of povert in the United States and Idaho.
The 100% of pover level is widely regarded as underestimating what it costs to
maintain a basic standard ofliving. Federal and state goverent agencies charged with
the responsibilty to protect human health and welfare generally set household income
eligibilty limits for social servce programs at levels exceeding 100% of pover. Since
total household income is used to deterne eligibilty for most social serices, the
income of all wage earers in a household is combined. The state of Idaho has roughy
44,000 households at or below 100% of povert. The total number of Idaho households
that qualify for LIHEAP benefits under last year's eligibilty theshold (150%) of povert
is 101,000.
Customers who are living in povert and/or are unemployed have limted~r
diminished financial resources with which to pay utility bils. Given the recent economic
turmoil, Staff believes that the Census data, although somewhat stale, provides a fairly
good pictue ofIdaho today. In fact, there is probably reason to believe, as discussed
below, that customers may be worse off in the futue. Staff is concered that a significant
number of customers wil have problems paying their electrc bil, especially when faced
with increasing rates.
Appendix 2
Case No. GNR-U-08-1
Staff Comments
01/16/09 Page 2 of2
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Appendix 4
Case No. GNR-U-08- 1
Staff Comments
01/16/09
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-
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 territory 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
4.914ç7.75H 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 Title Vice
Advice No.
President, Regulation
UE-080220
-Apperidix 13
Case No. GNR-U-08- 1
Staff Comments
01/16/09 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 COMPAN
FOR COMMISSION'S RECEIPT STAMP
LOW INCOME
SCHEDULE 17
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 Novemer i 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 to
those 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
Ti tle Vice President, Regulation
Advice No. UE-061546/UE-060817
Appendix 13
Case No. GNR-U-08-1
Staff Comments
01/16/09 Page 2 of2
Pacific Power & Light Company
Portland, Oregon Canceling
Revised
Revised
Cal.P.U.C.Sheet No. 31SS-E
Cal.P.U.C.Sheet No. 312S-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. D, and for multiple dwelling units in
which each of the single-family dwellings receive service directly from the
utili ty through separate meters, and to multi-family accommodations which are
separately submetered.
TERRITORY
Wi thin the entire terri tory 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-Pulic TotalDistrib.Trans.Trans.ation Purpose Rate
Basic Charge $5.70 ($1.14)$4.56
Energy Charge:
All Baseline kWh 4.479ç 0.457ç 0.004ç 2.516ç (1.729ç)5.727ç
All Non-Baseline kWh 5.79Sç 0.457ç 0.004ç 2.79Sç (2.049ç)7.00Sç
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. D Basic Charge and twenty percent (20%) of
the Residential Service Schedule No. D Energy Charge Total Rate minus the
Schedule S-IOO 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 subj ect 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 Letter No.373-E
(Continued)
Issued by
Andrea L. Kelly Date Filed
Name
VP, Regulation
December 30, 200S
Decision No.Effective January 1, 2009
Title
TF6 DL- 6- 1. E Resolution No.
Appeiidix14
Case No. GNR-U-08- 1
Staff Comments
01/16/09 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 Income
Annually
$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 quantities 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 theSchedule 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 monthly
charges.
Issued by
Andrea L. Kelly Date Filed May 14, 2008Advice Letter No. 361-E
Decision No.
Name
VP, Regulation
Title
Effective June 1, 2008
TF6 DL-6-2.E Resolution No.
Äpptmdíx14
Case No. GNR-U-08- 1
Staff Comments
01/16/09 Page 2 of2
WN U-28
Fifth Revision Sheet 91
Canceling
Fourth Revision Sheet 91
AVISTA CORPORATION
dba AvistaUtilties
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 and Area
Lighting SerVice. -This Rate-Adjustrìéíitis desigíiéd to re-covet ê6sts-iíiêúrrêfd bY
the Company associated with providing Demand Side Management services and cn
programs and Low Income Rate Assistance (L1RAP) to customers. (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 rates (I)
(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.
- . Issu ed--ecember20 , 2eoi ---Effctive - --January1; 2Ð08*-
*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 15
Case No. GNR-U-08-1
Staff Comments
01/16/09
WN U-29
Seventh Revision Sheet 191
Canceling
Sixth Revision Sheet 191
AVISTA CORPORATION
dba Avista Utilties
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 ttfe Company associated with providing Demand Side Management
services and programs, and Low Income Rate Assistance (L1RAP) to customers.
(T)
(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 Therr (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 16
Case No. GNR-U-08-1
Staff Comments
01116/09
P.U.C. OR. NO.5 Original Sheet 493
AVISTA CORPORATION
dba Avista Utiltiès
. . ~- ....- .--SCHED-lJbE49~---._._-_._---
RESIDENTIAL LOW INCOME RATE ASSISTANCE PROGRAM (URAP)-
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 approximately
0.5% 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 bill 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 wil 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 will 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. 08-02-8
Issued March 31,2008
Effective For Service On & After
April 1, 2008
Issued by Avista Utilities
By Kelly O. Norwood, V.P., State and Federal Regulation
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Appendix 13
Other Energy Effciency Programs
Rocky Mountain Power offers additional residential energy efficiency programs such
as: 1) Refrgerator/Freezer Recycling; 2) Home Energy Savings; 3) Idaho Time-of-Day
Meterng; 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 fuher use.
Serices that are offered include free removal and pickup of the units, a $30 rebate, an
instant savings kit containing two compact fluorescent light bulbs, a "BrightIdea'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 units 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, windows, and insulation.
The Idaho Time of Day Program allows residential customers the option to switch to
what is called, "Rocky Mountain Power's Time of Day Option". Ths allows customers
more control of how much they spend on electrcity by moving a substatial portion of
their power usage to non-peak hours.
On-line and Mail-in Energy Analysis allows residential customers to perorm free self-
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 18
Case No. GNR-U-08-1
Staff Comments
01/16/09 Page I of 4
A vista offers additional residential energy efficiency programs such as: 1) Senior Energy
Conseration Workshops; 2) Energy Conseration Education Programs for Children; 3)
High Effciency Equipment Incentives; 4) CFL Lighting; 5) Refrgerator Recycling
Program; 6) Conversion from Electrc Straight Resistace; 7) Energy Star Appliances; 8)
New Constrction Energy Star Homes Program; 9) Multi-Family Energy Effciency
Program; 10) Rooftop Dampers; and, 11) Home Energy Analyzer.
The Senior Energy Conservation Workshops are par of the 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 seniors while allowing for comfort
and safety with home energy use. All workshop paricipants receive an "Ever Little Bit"
Energy Conseration Kit.
The Energy Conservation Education for Children Program is designed to educate low-
income elementar age children and families with the goal of changing lifestyle habits of
using energy effciently. Wattson, the Energy Watchdog, is featued with the goal of
targeting children ages 4 to 8 with emphasis on reaching low-income children and their
familes.
The High Effciency Equipment Incentives Program offers rebates to customers who
purchase energy effciency equipment for their homes. Rebates ranging from $100 to
$1500 are offered for items such as high efficiency natual gas furnaces/boilers, heat
pumps, air conditionig units, 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 units are removed and recycled to prevent fuer use. The customer is then
given $30 for allowing removal of the unts. Additionally, rebates of $25.00 are offered
toward the purchase of a new energy efficient refrgerator and $100 toward the purchase
of a new energy effcient freezer.
Appendix 18
Case No. GNR-U-08- 1
Staff Comments
01116/09 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 primar
heating source with a central natual gas heating system. The rebate can be claimed in
conjunction with the high-efficient natural 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 priar heatig 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 electric 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 $100 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 A vista electrc or A vista electrc and natual gas that meet the Energy Star
Homes crteria and are verified as an Energy Star Home. A $650 rebate is available for
homes that have A vista gas but not A vista electrc.
The Multi-Family Energy Effciency Program is a brand new program that is designed to
increase energy effciencies and reduce waterlsewer costs for proper owners of multi-
family dwellings while increasing tenant effciencies and offering saving opportties
for those who live in multi-family properies. A thd-par company (UCONS, LLC)
administers the program. The energy efficiency measures include water heat pipe
installation, floor and ceilng 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 primarly with electrc or
natual gas but also have a wood burng fireplace with the opportty to receive up to
$100 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.
--- ----
Appendix 18
Case No. GNR-U-08-1
Staff Comments
01116/09 Page 3 of 4
Idaho Power offers additional residential energy efficiency programs such as: 1) Energy
Star 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 cerain 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 reguar
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 efficient homes.
Energy Star homes are 30% more efficient 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 livig in manufactued homes. These
customers are able to get the followig serices: 1) a test to determine if ductwork is
leakng; 2) sealing of the leaks if found; 3) installation of compact fluorescent light bulbs;
4) replacement of air fiters; 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 durg 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 Fitrnace 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 heat source such as electrcity or propane to natual gas. The
home must be at least thee years old, the new fuace must meet a mium AFUE
efficiency rating of 90% and Interountai Gas personnel must verfy the installation.
.-
Appendix 18
Case No. GNR-U-08-1
Staff Comments
01/16/09 Page 4 of 4
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!
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF JANUARY 2009,
SERVED THE FOREGOING STAFF'S FINAL REPORT, 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
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LISA NORDSTROM
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RICK GALE
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LINDA GERVAIS
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TED WESTON
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NETWORK
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CERTIFICATE OF SERVICE
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ORGANIZATIONS
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MERIDIAN ID 83642
JULIA CAMPBELL
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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 WAY
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 COMMUITY
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
TERIOTTENS
POBOX 8224
BOISE ID 83707
SECRETARY
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CERTIFICATE OF SERVICE