20171103Zamora Direct.pdf

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Brad M. Purdy
Attomey at Law
Bar No. 3472
2019 N. lTth St.
Boise,ID. 83702
[phone] (Land)
(208) 484-e980 (Cell)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
RECEIVED
?Blt t{0V -3 plt 3: 32
lD;1H0 PUBLIC
i]TILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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9 IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC AND NATURAL GAS
SERVICE IN IDAHO
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CASE NO.AVU-E-17-01
AVU-G-17-0110
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COMMT]NITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO'Sl4
15 DIRECT TESTIMOIYY OF CHRISTINA ZAMORA
16 IN SUPPORT OF SETTLEMENT STIPULATION
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125DIRECT TESTIMONY OF CHRISTINA ZAMORA
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25 DIRECT TESTIMONY OF CHRISTINA ZAMORA
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I.INTRODUCTION
Please state your name and business address.
My name is Christina Zamora. I am the Executive Director of the Community Action
Partnership Association of Idaho at 3350 W. Americana Terrace, Suite 360, Boise, ID
83706.
On whose behalf are you testiffing in this proceeding?
The Community Action Partnership Association of Idaho ("CAPAI") Board of Directors
asked me to present the views of an expert on, and advocate for, the low income
customers of Avista.
II. BACKGROUND
Please describe CAPAI's organizational structure and the functions it performs, relevant
to its involvement in this case.
CAPAI is an association of the following private, nonprofit organizations that fight
poverty in Idaho: 1) The Community Action Partnership (CAP-N & CAP-NC);2)El
Ad4 Inc. (El Ada); 3) The Western Idaho Community Action Partnership (WICAP); )
The South Central Community Action Partnership (SCCAP); 5) The Southeastem Idaho
Community Action Agency, Inc. (SEICAA); 6 The Eastem Idaho Community Action
Partnership, Inc. (EICAP); 7) The Community Council of Idaho, Inc. (CCI), and; 8)
Metro Community Services (MCS) formerly named the Canyon County Organization on
Aging, Weatherization and Human Services, Inc. The last two agencies, CCI and MCS,
are designated in CAPAI's Bylaws as "special purpose agencies." These agencies are
focused on providing services to migrant and senior populations, respectively.
Collectively, the six Community Action Agencies (sometimes referred to as "CAPs")
along with CCI and MCS are referred to as "member agencies." For the purposes of the
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Stipulation at issue in this proceeding, there is no relevant distinction between a
Community Action Agency and a special purpose agency.
Each member agency has a designated service area. Combining all agencies,
every county in Idaho is served. The agencies design their various programs to meet the
unique needs of communities located within their respective service areas. Not every
agency provides all of the following services, but all work with people to promote and
support increased self-sufficiency. Programs provided by CAPS include: employment
preparation and retention, education assistance, child care, emergency food, senior
independence and support, clothing, home weatherization, energy assistance, affordable
housing, health care access, and much more.
What is the relationship between CAPAI and the member agencies?
CAPAI is effectively the umbrella organization that provides a myriad of services to the
member agencies to assist them in carrying out their individual missions throughout
Idaho. Such services include training and technical assistance, coordination ofresources,
program planning and assistance with implementation, programmatic administrative
oversight, and advocacy for the low-income in Idaho, among other things.
Are the individual member agencies represented on CAPAI's Board of Directors and, if
so, how?
Yes, they are. Each agency has an Executive Director and its own Board of Directors
that establishes policy for that agency. The Executive Director manages the day to day
functions of the agency. In addition, each Executive Director of each member agency sits
on the CAPAI Board of Directors. Thus, there are currently 8 CAPAI Board members.
Which of the eight member agencies provide low-income assistance to Avista's service
territory?
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A The Community Action Partnership ("CAP") serves North Idaho including all of Avista's
Idaho service territory.
Have you testified before this Commission in other proceedings?
Yes, I have testified on behalf of CAPAI in numerous cases involving United Water,
Idaho Power, AVISTA, and Rocky Mountain Power, to name a few.
Would you please describe CAPAI's involvement in this case?
CAPAI participated fully throughout the entirety of this case and participated in all
settlement negotiations.
III. SUMMARY
Please summarize your testimony in this case?
The purpose of my testimony is to support the settlement stipulation entered into between
CAPAI, Avista, the Commission Staff, Clearwater Paper Corporation, and the Idaho
Forest Group. The Idaho Conservation League declined to join in the settlement in its
entirety and still has issues it wishes to raise during the hearing scheduled for this matter
on December 8,2017. The Settlement Stipulation was filed with the Commission on
October 20,2017 by way of a Motion for Approval submitted by Staff pursuant to Rule
274 of theCommission's Rules of Procedure, IDAPA 31.U.01.214. As discussed later
in my testimony, the parties settled for a reduced rate increase and agreed to, among other]
things, meet (at their discretion) with CAPAI to consider a funding increase for Avista's l
Low Income Weatheri zationProgram (LIWA). I also provide the rationale for CAPAI's
support of the settlement. Finally, I will explain why I believe that the settlement is in
the interests not only of Avista's low-income customers, but the general body of
ratepayers as well.
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Is CAPAI's support for the Settlement Stipulation unconditional?
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Yes it is.
Are there any exhibits to your testimony?
No.
IV. ESSENTIAL ELEMENTS OF SETTLEMENT
A. Revenue Requirement:
Please identifu the primary aspects or elements of the settlement from CAPAI's
perspective.
CAPAI agreed that due to various factors, the Company was entitled to a rate increase in
both the production and sale of electricity and gas but believed that the amount originally
requested was excessive. The Company agreed to a significantly lesser amount that
CAPAI believed was justified and would like prevail if the issue of revenue requirement
were to go before the Commission at hearing. The reduced amount was further made
more palatable given Avista's willingness to agree to a two year stay-out period.
Consequently, CAPAI agreed to the revenue requirement ultimately incorporated into the
settlement stipulation. All in all, CAPAI believed the revenue requirement to be fair, just
and reasonable.
B. Monthly Basic Charse:
What is CAPAI's perspective on the agreement to increase the fixed, monthly residential
basic charge by twenty-five cents?
The monthly basic charge is intended to cover the costs directly attributable to individual
residential customers and includes, among other things, items such as a customer's
service drop and meter. CAPAI is aware that the costs recovered by the basic charge do
increase over time and believes that a twenty-five cent increase is not excessive. Further,
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an increase in the basic monthly charge, as proposed, won't necessarily be contrary to the
interests of low income customers on the whole.
Why is this?
Because, depending on whether a low income customer is a relatively high user due to
circumstances beyond their control (e.g., they rent a poorly insulated dwelling with
electric baseboard heating), other things being equal, their monthly bill will be higher
with a lower basic charge because the revenue collected from them will come more from
the commodity rate (e.g., number of kWh used during the month). Conversely, low
income customers with relatively low usage will possibly pay higher bills because their
bills are based more on a higher fixed basic charge.
So, what is your position in response to Avista's request to recover revenues from
customers through a relatively modest twenty-five cents per month increase through the
basic charge will not have a substantial effect on low income ratepayers on the whole.
Given the mixed effect a modest increase such as twenty-five cents/month, CAPAI
supports the proposed increase to its monthly basic charge to residential customers.
C. Low Income Issues:
Are there any provisions contained in the Stipulation exclusive to low income concerns
and considerations?
Yes. Paragraph 18 of the Stipulation contains the following provision:
The Company and interested parties will meet and confer to
consider whether the Low Income Weatherization Program and
Energy Conservation Education Program funding should be
increased from the current Commission-approved levels of
$700,000 and $50,000, respectively. Discussion topics will
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include the need for additional funding, how additional funds will
be used, how much additional funding will be necessary, and
what impact the increase will have on the energy efficiency tadff
rider (Schedules 9 and 191 balance. If participants agree that a
funding increase is necessary, the Company agrees to make any
necessary filing(s) with the Commission on or before December
31,2017.
Would you please provide your opinion of this provision and why it is acceptable to
CAPAI?
Avista specifically called out the issue of funding its LIWA program and stated that it
would generally be supportive of an increase in funding. Thus, CAPAI has proposed
such an increase.
Is there any adamant opposition to a LIWA funding increase for Avista's program?
As paragraph 18 of the stipulation indicates, there is no outright opposition at this point tc
a funding increase by a.ry paffy.
Then why is there no proposal for a specific funding increase contained in the
stipulation?
Staff has questions of both CAPAI and Avista before it is willing to sign off on any
particular increase. CAPAI is in the process of seeking clarification from Staff regarding
what information will be useful in determining a specific funding increase in this case in
preparation to meeting with Staff, Avista personnel and other interested parties.
Has a meeting been scheduled to discuss this issue?
Yes. Avista personnel are traveling to Boise on November 20,2017 - Staff will, of
course, be there along with CAPAI and any other interested parties.
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DIRECT TESTIMONY OF CHzuSTINA ZAMORA '7
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.E DIRECT TESTIMONY OF CHRISTTNA ZAMORA
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What do you hope to accomplish during this meeting?
My goal is, first and foremost, to answer or address any questions or concerns that Staff
has. Beyond that, CAPAI clearly seeks to increase in the funding. This program not only
provides benefits to low-income Avista customers, but to the general body of ratepayers.
This is achieved by increasing energy affiordability which then results in Avista
experiencing more retention of its low-income customers. Additionally, providing
weatherization assistance to low income customers can result in a commensurate
reduction in costs for the Company including collection, past due notices, legal fees, and
a number of other consequences that will help to provide Avista with customers who
could not afford to remain as such unless and until they are given the benefit of
in helping to reduce their gas and electricity consumption. By reducing costs for Avista,
the general body of the Company's ratepayers benefit. Finally, although it wasn't
possible for the aforementioned parties to address and resolve this issue to a level of
specificity to fully address in the stipulation or this testimony, CAPAI is hopeful that an
accord can be reached in time for presentation during the December 8, 2017 hearing
through live testimony on the stand.
V. CONCLUSION
Do you have any concluding remarks?
Yes. I would like to express gratitude to Avista for its dedication to the Company's
LIWA program in a cost-effective manner and its support of a funding increase. I would
also like very much to thank the Commission Staff for its willingness to work with
CAPAI in discussing this issue and in their reasonable approach to this issue. Staff has
been helpful and it is my sincere hope that we can continue to work collaboratively.
Does this conclude your testimony?
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DIRECT TESTIMONY OF CHRISTINA ZAMORA
A: Yes, it does.
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25 DIRECT TESTIMONY OF CHRISTINA ZAMORA 10
CERTIFICATE OF' SERVICE
I, the undersigned, hereby certiff that on the 3rd day of November, 2017,I served a copy
of the foregoing document on the following by electronic mail and U.S. postage or hand
delivery.
COMMISSION STAFF:
Brandon Karpen
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington St.
Boise,ID 83702
brandon. karpen@puc. idaho. gov
AVISTA CORPORATION:
Kelly Norwood
Vice President State & Federal Regulation
Avista Corporation
POBox3727
Spokane, WA99220-3727
kelly.norwood@.avistacorp. com
David Meyer
Vice President and Chief Counsel
of Regulatory & Governmental Affairs
Avista Corporation
P0Box3727
Spokane, WA99220-3727
david.meyer@ avistacom. com
CLEARWATER PAPER CORPORATION:
Peter J. Richardson
Gregory Adams
Richardson Adams, PLLC
515 N.27th St.
Boise,Idaho 83702
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peter@richardsonadams. com
Dr. Don Reading
6070 Hill Rd.
Boise,ID 83703
[e-mail]
IDAHO FOREST GROUP, LLC:
Ronald L. Williams
Williams Bradbury PC
P.O. Box 388
Boise,lD 83702
[e-mail]
Larry A. Crowley
The Energy Strategies Institute, [nc.
5549 S. Cliffsedge Ave.
Boise,ID 83716
[e-mail]
IDAHO CONSERVATION LEAGUE:
Benjamin J. Otto
Matthew A. Nykiel
Idaho Conservation League
710 N. 6th St.
Boise,ID 83702
botto @ idahoconservation. ore
mnykie I @ idahoconservation. org
Siena Club
Travis Ritchie
2101 Webster St., Ste 1300
Oakland, CA 94612
Travis. ritchie@,sierraclub. ors
25 DIRECT TESTIMONY OF CHRISTINA ZAMORA
Purdy
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