20161216Zamora Direct.pdf

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Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
3 Boise, ID. 83702
[phone] (Land)
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[e-mail]
s Attorney for Petitioner
Community Action Partnership
6 Association of Idaho
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RECEIV ED
~: i :J OE-., I 6 PM 3: 4 I
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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9 IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMP ANY'S
APPLICATION TO CHANGE ITS RA TES
AND CHARGES FOR NATURAL GAS
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CASE NO. INT-G-16-02
IN THE STA TE OF IDAHO
COMMUNITY ACTION P ARTNERSIDP ASSOCIATION OF IDAHO'S
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 ofldaho at 3350 W. Americana Terrace, Suite 360, Boise, ID
83706.
On whose behalf are you testifying in this proceeding?
The Community Action Partnership Association of Idaho ("CAP Al") Board of Directors
asked me to present the views of an expert on, and advocate for, the low income
customers of Intermountain Gas Company (hereinafter, "Company," or
("Intermountain").
II. BACKGROUND & QUALIFICATIONS
Please describe CAP AI' s organizational structure and the functions it performs, relevant
to its involvement in this case.
CAP AI 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
Ada, Inc. (El Ada); 3) The Western Idaho Community Action Partnership (WICAP); 4)
The South Central Community Action Partnership (SCCAP); 5) The Southeastern Idaho
Community Action Agency, Inc. (SEICAA); 6 The Eastern Idaho Community Action
Partnership, Inc. (EI CAP); 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 CAP Al'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")
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along with CCI and MCS are referred to as "member agencies." For the purposes of the
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 CAP AI and the member agencies?
CAP AI is effectively the umbrella organization that provides a myriad of services to the
members to assist them in carrying out their individual missions throughout Idaho. Such
services include training and technical assistance, coordination of resources, program
planning and assistance with implementation, programmatic administrative oversight, an
advocacy for the low-income in Idaho, among other things.
Are the individual member agencies represented on CAP AI' 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 sit
on the CAP AI Board of Directors. Thus, there are currently 8 CAP AI Board members.
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Which of the eight member agencies provide low-income assistance to Intermountain's
service territory?
The member agencies whose service territory overlaps with the service territory of
Intermountain are WICAP, CCI, MCS, El Ada, SCCAP, SEICAA and EICAP.
Have you testified before this Commission in other proceedings?
Yes, I have testified on behalf of CAP AI in numerous cases involving United Water,
Idaho Power, AVISTA, and Rocky Mountain Power, among others.
III. SUMMARY
Would you please summarize your testimony in this case?
My testimony addresses CAPAI's position regarding the Company's proposed increase t
the fixed customer charge, Intermountain's proposal to consolidate its Residential classes
into a single customer class, a need for more extensive data tracking for low income
customers, and the implementation of a low income weatherization DSM program
Are there any exhibits to your testimony?
No.
IV. CAPAl'S RECOMMENDATIONS AND PROPOSALS
A. Consolidation of Residential Class.
What is CAPAI's position regarding the Company's proposal to combine the residential
class into a single class?
CAP AI agrees that there is no rationale for separating the residential class into the two
categories currently in existence: space heating only and space combined with water
heating. Consequently, CAPAI has no objection to this proposal.
B. Proposed Increase to Customer Charge.
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What is CAP AI' s position with respect to Intermountain' s proposed increase to the
Company's customer charge?
CAP AI submitted numerous discovery requests to Intermountain seeking data regarding
the Company's low income customers ranging from how many of its customers are low
income based on various criteria, the average consumption habits of low income
customers compared to non-low income and other data that would provide CAP AI with
the ability to determine whether a higher customer charge and resulting in bills that are
lower due to reduced commodity charges, but the Company has not historically tracked
the data necessary to make determinations such as those presented by this question.
Does the lack of data necessarily alter CAP AI' s position on the proposed increase to the
customer charge?
Not in this instance. Were the proposed increase significantly greater, then CAPAI might
have objections to it.
What would those objections be?
A higher fixed customer charge obviously sends a price signal that is contrary to the
objective of conservation. This is particularly problematic for low income customers
who could otherwise reduce their bills by reducing discretionary consumption. On the
other hand, as noted by the Company, some low income customers with gas heating
consume more gas than would be expected due to non-discretionary conditions such as
poorly insulated housing. Placing more of an overall rate increase on the commodity
charge, as opposed to the fixed customer charge, will obviously have a negative effect on
such customers. This is why CAP AI proposes that the Company begin tracking low
income data ranging from the percentage of its customers who are low income to their
consumption habits.
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C. Low Income Data Tracking
What type of low income data do you propose that Intermountain track?
As discussed below, I believe that question should be addressed collaboratively by an
advisory group. Generally speaking, it would be of significant help to obtain a better ide
of the percentage of the Company's customers who are low income and their
consumption habits. This type of data would be helpful to the Commission in, among
other things, understanding the true impact of certain residential rate design proposals on
the Company's customers.
Does the Company's lack oflow income data as you describe surprise you?
Not entirely. Due to the unique level ofregulatory oversight of natural gas utilities, and
the fact that Intermountain does not file general rate cases with the same frequency of
Idaho's electric utilities, it is not surprising that the Company has not historically tracked
this information. Consequently, it is fair to state that this is fairly new ground we are
covering in this proceeding.
Would you please elaborate on this point?
As Intermountain notes low income customers do not fall neatly into a high or low
consumption population of the residential class of customers. Some low income
consumers consume relatively high levels of natural gas due to a number of factors,
including housing stock that is poorly insulated, large families living in a relatively small
space, and so on. Other low income customers might include senior citizens who have
lived in relatively energy-efficient housing for many years, who live alone and are frugal
in their use of gas consuming appliances. Consequently, their consumption might be
lower than average.
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What effect do these factors have on CAP AI' s proposal to implement a low income
weatherization program for the Company?
It is essential that we begin tracking low income data for Intermountain so that we have a
better understanding of the specific needs of the Company's customers in order to create
a well-tailored program that provides access to energy conservation to the majority of
Intermountain' s customers.
How do you propose enhancing Intermountain's low income data tracking?
I believe that the creation of an advisory group outside the scope of this proceeding
involving the Company, CAPAI, the Commission Staff, and all other interested persons
to identify areas and issues where better data would be productive would be an efficient
method of identifying the data and how best to collect and track it. The outcome of this
effort could, conceivably, be used with respect to other utilities.
D. Low Income Weatherization Program
Have you had occasion to discuss the implementation of a low income weatherization
program with Intermountain?
Yes, I have.
What was the outcome of that discussion?
Although I cannot speak for the Company, my impression is that it is willing to consider
the implementation of a low income weatherization program outside of the scope of this
proceeding.
What is your proposal to the Commission in that regard?
CAP AI' s proposal is that the Commission order the creation of an advisory group
involving the Company, CAPAI, and, particularly, the Commission Staff, along with all
other interested persons, to commence a discussion of how to implement a low income
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weatherization program that is both effective in terms of helping low income customers
to reduce their bills through less consumption of gas in a way that they cannot otherwise
afford. A properly constructed program should be effective, conserve energy resources
and help those who could not otherwise afford to reduce their non-discretionary
consumption.
IV. SUMMARY
Would you please summarize your testimony?
Yes. I would like to thank the Company for meeting with CAP Al to discuss the
possibility of a low income weatherization program which CAP AI believes is highly
warranted. CAP AI sees no reason to oppose the Company's proposal to consolidate its
residential customers into a single class. CAPAI also does not oppose the Company's
proposed customer charge increase but believes that it is essential for Intermountain to
begin more enhanced data tracking so that the impact of future rate design proposals on
low income customers can be fully assessed.
Does this conclude your testimony?
Yes it does.
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CERTIFICATE OF SERVICE
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I, the undersigned, hereby represent that on this 16th day of December, 2016, caused a
true and correct copy ofthis Testimony of Christina Zamora to be served on the following both
electronically and via U.S. Mail, First Class, Postage Prepaid (unless otherwise indicated).
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IDAHO PUBLIC UTILITIES COMMISSION
(HAND DELIVERY)
Jean Jewell, Secretary:
Idaho Public Utilities Commission
472 W. Washington St.
P.O. Box 83720
Boise, Idaho 83720-0074
[e-mail]
Karl Klein
Sean Costello
( electronic delivery)
[e-mail]
[e-mail]
INTERMOUNTAIN GAS
Ron Williams
Williams Bradbury PC
1015 W. Hays St.
Boise, ID 83702
[e-mail]
Mike McGrath
P.O. Box 7608
Boise, ID 83707
[e-mail]
SNAKE RIVER ALLIANCE
Ken Miller
233 N. 6th St. Ste 317
Boise, ID 83 702
[e-mail]
AFLOA/JA-ULFSC
23 139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
2 4 Andrew. [e-mail]
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1 NORTHWEST INDUSTRIAL GAS USERS
Edward A. Finklea 2 545 Grandview Dr.
3 Ashland, OR 97520
[e-mail]
4 IDAHO CONSERVATION LEAGUE
Benjamin Otto
5 710 N. 61h St.
Boise, ID 83702
6 [e-mail]
7 F. Diego Rivas
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NW Energy Coalition
1101 81h Avenue
9 Helena, MT 59601
[e-mail]
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11 Chad M. Stokes
Tommy A. Brooks
12 Cable Huston LLP
Portland, OR 97204-1136
13 [e-mail]
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[e-mail]
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16 Clearwater Paper Corporation:
c/o Peter Richardson, Esq.
17 Richardson Adams, PLLC
515 N. 27th St.
18 P.O. Box 7218
Boise, ID 83 702
19 [e-mail]
20 Northwest Industrial Gas Users:
21 Chad Stokes
Tommy Brooks
22 Cable Huston, LLP
1001 S.W. 5th, Ste 2000
23 Portland, OR 97204-1136
[e-mail]
24 [e-mail]
25 DIRECT TESTfMONY OF CHRISTINA ZAMORA 10
1 Michael C. Creamer
2 Givens Pursley LLP
mcc(a),givensgursley.com
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5 DATED, this 16th day of December, 2016
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