20100909Funding Application.pdf

Brad M. Pudy
Attorney at Law
BarNo. 3472
2019 N. 17th S1.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdyWlhotmail.com
Attorney for Petitioner
Communty Action Parership
Association of Idao
,.,. C.. r'~.~..,.,.. -' 'j
20m SEP -9 PH 3: 57
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN TH MATTR OF TH APPLICATION
OF A VISTA CORPORATION DBA A VISTA
UTLITIES FOR AUTHORITY TO
INCREASE ITS RATES AN CHAGES FOR
ELECTRC AN NATU GAS SERVICE
IN IDAHO.
)
) CASE NO. AVU-E-IO-OI
) CASE NO. AVU-G-IO-OI
)
)
) COMMTYPARTNRSHIP
) ASSOCIATION'S APPLICA-
) TIONFORINTERVENOR
) FUNING
)
COMES NOW, Applicat Communty Action Parership Association ofIdaho (CAP AI)
and, puruat to Idaho Code § 61 -6 1 7 A and Rules 161 - 1 65 of the Commssion's Rules of
Procedur, IDAPA 31.01.01, petitions this Commission for an award of intervenor fudig in the
above-captioned proceedi.
Rule 161 Requirements:
A VISTA is a reguated, electrc and gas public utilty with gross Idao intrstate anua
revenues exceding thee millon, five hundred thousad dollar ($3,500,000.00).
Rule 162 Requirments:
(01) Itemized lit of Expenses
CAPAI APPLICATION FOR INTERVENOR FUNING 1
Consistent with Rule 162(01) of the Commssion's Rules of Predure, an itemied list of
all expenses incured by CAPAI in ths proceeding is attached hereto as Exhbit "A."
(02) Statement of Proposed Findings
The proposed fidings and reommendations of CAP AI are set fort in the dirct,
prefied testimony ofTeri Otens filed in ths mattr on Augu 5, 2010, and interwoven
throughout the settlement stipulation to which CAP AI was a signatory. CAP AI fuly parcipated
in ever aspect of the settlement negotiations conducted in ths case and, consistent with the
setlement ageement previously submitted to the Commssion for approval, makes the following
statement of proposed findings and recommendatons. i
Firt, CAPAI submits tht the negotiated increase to AVISTA's revenue requiment of
$21.25 millon, an incree of9.25%, compared to the $32 millon (14%) increase originally
propose is fai and reonable resolution in light of all circumtaces. The ''rte mitigation"
plan strctud by the paries reduces the impact of the rate increase by utilzig a defered
investment ta credit to phase the tota increase in through thre incrementa increases, the last
tag effect on October 1,2012.
Afer extensive analysis and negotiations, the signatory pares agreed tht there should
be additiona anysis of the Company's curent cost of servce methodology and, therefore,
contend that the equa percentage increas to all customer classes, moving them parially toward
"unty," is preferable until an agred upon workshop can be convened to anlyze revenue
allocation in greater detal and, if and when appropriate, submit the mattr to the Commission for
resolution. CAP AI, of coure, recommends a fiding tht ths is reasonable.
i For the sake of
brevity, this list is not an exhaustive sumation of villy ever issue resolved by the selement
agreement and for which CAP AI might have had a position.
CAP AI APPLICATION FOR INTERVENOR FUNING 2
CAPAI proposes tht the incre of the basic charge for electrc customers from $4.60 to
$5.00, less than origily proposed, is reasonable and should be approved.
CAPAI concur that the Compay's investments in energy effciency, pacularly low-
income weatherition, ar prudent and should be recovered as proposed.
CAPAI expressed its belief that AVISTA's existing residential tiered rate design should
be more thoroughy analyzed. For llOW, the settlement proposes that the fist block of
consumption be set at 600 Kwh, but CAP AI wishes to better undersd the issue. Thus, the
settlement states tht there will be a workshop convened for that purse pror to fiing the next
general rate ca, a resolution CAP AI recommends be found reasnable.
There were a number of "customer servce-related" issues agred upon by the pares and
which CAP AI proposes be accepted. Those of greatest concern to CAP AI ar:
1. CAP AI recmmends tht the Company's ageement to increae low-income
weatherization fudig from $465,000.00 anualy to $700,000.00 be approved. Though CAP AI
respectfly submts that this agreed upon fuding level is not adequate to fuly meet existig
need and begin to reduce the backlog of eligible low-income residences that qualify for ths
progr, it is an adble step in tht dition, is a cost-effective energy resource and, as such,
provides system-wide benefits.
2. A VISTA believes that its conservation education ("outrach") progr has been
very successfu. CAPAI agees and support AVISTA's agreement to increase fudig of that
progr from $25,000.00 to $40,000.00. Thoug additiona fuding could be supported for a
number of compelling reasons, CAP AI submits tht ths increase is fai and reasonable for the
time being and proposes that the fuding level be re-examed in the futue.
CAP AI APPLICATION FOR INTERVENOR FUING 3
3. Other miscellaneous but signficant customer serice issues tht CAP AI propose
be adopted include the Company's agrement to review the process by which its landlord/tenant
accounts ar managed, that related cost reovery be addressed, that Contat Center servce
stadads be examed and tht AVSTA's residential customer deposit policies be reviewed to
determne if bad debts are being mized to the greatest extent possible.
4. CAPAI proposes that the Company's proposal to conduct five Senior Energy
Conservation workshops is a relatively new and reasonable objective for A VISTA in Idao.
(03) Statement Showing Costs
CAP AI submits tht the cost and fees incurd in ths case, and set fort in Exhbit "A,"
ar reasonable in amount.
CAP AI has historically made a concerted effort to mize its expenses and maximie
the effect th its effort have in proeeings before ths Commssion. Though ths matter was
settled, because of the broad scope of issues rased by all paries, and due to the level of
CAP AI's involvement, it requied the investent of considerable tie and resoures by CAP AI
to effectively paricipate and address issues of concern to the general body of ratepayers.
Negotiations in ths proceg took plac, inormally, over an extended peod of time
and, formally, over the coure of two separte, lengty face-to-face sessions at the Commssion's
offces. CAPAI's expert Teri Otens was present durg negotiations and pre-filed and presented
direct testiony at the tehncal hearg conducted in ths docket.
Becaus of its commtment to the issues raised by A VISTA's application, CAP AI
maximd its limted resources to the greatest extent possible. Borne out of necessity, CAP AI
often must employ a practice of forgoing retanig expert witnesses and consultats in highy
techncal areas and, intead, adopt a reourcefu approach using what lited resources tht are at
CAPAI APPLICATION FOR INTERVENOR FUNDING 4
its disposa. Thus, CAP AI respectfly submits that the costs incured, and requested in Exhbit
"A," ar reasonable in amount.
(04) Explanation of Cost Statement
CAP AI is a non-profit corpration overseing a numbe of agencies who fight the causes
and conditions of povert thoughout Idao. CAPAI's fudig for any given effort might come
from a different varety of soures, including governenta. Many of those fudig sources,
however, are unpredictable and impose conditions or limtation on the scope and natu of work
eligible for fuding. CAP AI, therefore, has relatively little "discretiona" fuds available for all
projects. Some matters before ths Commssion, fuermore, do not quaify for intervenor
fuding by virte of their natue.
Thus, were it not for the availabilty of intervenor fuds and past awards by ths
Commssion, CAP AI would not be able to parcipate in cases before ths Commssion. Even
with intervenor fuding, pacipation in Commssion caes constitutes a signficant ficial
hardship becaus CAP AI must pay its expenses as they are incured, not if and when intervenor
fudig becomes available.
(OS) Statement of Diference
Althoug Sta provided valuable input regardig most ever issue to ths matter, CAP AI
is the only par who proposed an increase to low-income weatherition and conservation
education fudig and raised signficant issues regarding the Company's tiere residential rate
design.
06) Statement of Recommendation
As explaied thoughout ths Application, CAP AI addressed issues tht are not
exclusively related to low-income customers, e.g. overal revenue requiement. Furermore,
CAP AI APPLICATION FOR INTERVENOR FUNING 5
CAPAI has long submitted tht providing asistace to a utility's low~income customers
provides system-wide benefits in numerous respects including, but not limited to, the fact that
low-income weatherization programs constitute cost-effective energy resources and that
progrs designed to assist low-income customers though education and by other means
reduces the percentage of those customers who might be lost to the Company's system due to
inabilty to pay their bils. Therefore, the proposas and reommendations made by CAP AI are
"of concern to the general body of utilty users or consumers."
(07) Statement Showin Class of Customer .
To the extent that CAP AI represents a specific A VISTA customer class, it is the
residential class.
RESPECTFULLY SUBMITTD, ths Lth day of 5 c.qfelO l(, 2010.
fl'C?... )Bra M. Pudy .~.
CAP AI APPLICATION FOR INTERVENOR FUNING 6
CERTIFCATE OF SERVICE
Q ,,'"
I, the undersigned, hereby certfy that on the -- day of 5 e. lñ 2010, I served
a copy of the foregoing document on the followig by electronic fo at (where available) and
U.S. mail, fist class postage.
Kelly Norwood
A vista Corpration
PO Box 3727
Spokane, VV)\ 99220-3727
David Meyer
A vista Corporation
PO Box 3727
Spokae, VV)\ 99229-3727
Donald L. Howell, II
Krstine A. Sasser
Idao Public Utilties Commssion
472 W. Washington St.
Boise,ID 83702
Served via copies rIled with Commission.
Peter J. Richadson
Greg M. Adams
515 N. 27th St.
PO Box 7218
Boise,ID 83702
Howard Ray
POBox 1126
Lewiston, ID 83501
Dean J. Miler
420 W. Banock St.
Boise,ID 83702
Lar )\. Crowley
5549 S. Cliffsedge Ave.
Boise, ID 83716
Rowena Pineda
3450 Hil Rd.
Boise,ID 83703-4715
LeeAnHall
CAPAI APPLICATION FOR INTERVENOR FUNING 7
3518 S. Edunds St.
Seattle, VV 1\ 98118
Benjamin J. Otto
710 N. Sixth St.
Boise, ID 83702
Ken Miler
PO Box 1731
Boise,ID 83701
Rob Pluid
PO Box 571
Moyie Springs, ID 83845
Chrs Faichild
PO Box 571
Moyie Sprigs, ID 83845
Electronic only:
Tom Oxford
Nort Idao Energy Logs, Inc.
Box 571
Moyie Sprigs, ID 83845
oxford.meadowcrk.com
~~~
CAPAI APPLICATION FOR INTERVENOR FUNING 8
EXHBIT" A"
ITEMIED EXPENSES
Costs:
Photocpies/poste $43.50
Total Costs $43.50
Fees:
Legal (Brad M. Pudy -74.5 hour (g $130.00/h.) $9,685.00
Total Fees $9,685.00
Expert Witness (Ter Ottns - 20.5 hour (g $50.00/h.) $1,025.00
Total Expenses $10,753.50
CAP AI APPLICATION FOR INTERVENOR FUNING 9