20081222Comments.pdf

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'¿lrV'STAO100B DEC 22 PM 2: 49
Deember 19, 2008
Jea Jewell, Commssion Secreta
State of Idaho
Idaho Public Utities Commssion
Statehouse
Boise, ID 83720
Re: Comments of Avista Corpration in GNR-U-08-1
Dear Ms. Jewell:
Enclosed for filing is an electrnic copy of Avista's comments regarng ''Te
Commssion's Inquir about Energy Mfordbilty Issues and Workshops, Cas No.
GNR-U-08-1." The original and seven (7) copies ar being provide via overnght mai.
Copies are also being provided to the service list in ths case.
If you have any questions regarding ths filig, pleas feel fr to contact me at (509)
495-4975.
Sincerely,A~~
Linda Gervais
Manager, Reguatory Policy
State and Federa Regulation
A vista Utities
509-495-4975
linda. gervais (g avistacorp.com
RECEIVED
Kelly Norwood
Vice President, State and Federal Regulation
A vista Corporation
1411 East Mission Ave.
Spokane, W A 99202
Phone: [phone]
Fax: [phone]
kelly.norwood~avistacorp.com
zona DEC 22 PM 2= 50
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S )
INQUIRY ABOUT ENERY AFFORDABILITY )ISSUES AN WORKSHOPS )
)
)
)
)
CASE NO. GNR-U-08-1
COMMENTS OF AVISTA
CORPORATION
A vista Corporation ("A vista" or "Company") hereby submits comments in response to
the Idaho Public Utilities Commission's ("Commission") Case No. GNR-U-08-1 "Energy
Affordability Issues and Workshops. The Commission initiated these workshops to provide a
forum for the exploration of issues related to the affordability of energy in Idaho. A vista
paricipated in all the workshops.
The Company appreciates the opportnity to comment on the IPUC Staff Comments
dated November 26, 2008 and look forward to the outcome of these proceedings. The following
are comments on Staffs "Proposals to Address Energy Affordability:"
1) Staff believes that a LIRAP program would be beneficial for Idaho low-income
utilty customers. Staff recommends that the Commssion support legislation to
allow it to consider adoption of such a program.
AVISTA CORPORATION COMMENTS IN GNR-U~08-1 Page 1
The Company currently has the Low Income Rate Assistance Program (LIR) in both
Washington and Oregon. LIR, proposed by the Company and approved by the Washington
Commission in 2001, collects approximately $3.75 milion (natural gas and electrc combined)
per year through electric and natural gas tariff surcharges on Schedules 91 and 191. In Oregon, a
total of 3,758 energy grants totaling $1.1 milion have been provided since the LIR program
inception in 2002. These fuds are distributed by Community Action Agencies (CAAs) in a
maner similar to the Federal and State-sponsored Low Income Heating Energy Assistance
Program (LIHAP). The purpose of Avista's LIR program is to reduce the energy cost
burden among those customers least able to pay energy bills.
Over 6,290 electric and natural gas customers in the Company's Washington service
terrtory received 6,678 grants averaging $396 during the 07/08 heating season. Households
contacting Community Action Agencies (CAAs) for help on their utility bils comprise the
primary pool of potential paricipants. Avista's Customer Assistance Referral and Evaluation
Services (CARS) representatives refer customers in need to the CAAs. Additional targeted
marketing focuses on payment-troubled households - those experiencing a shutoff notice,
carying a large arrearage, etc.
For clients receiving "regular" assistance (i.e., LlRA Heat), the eligibility deterination
is the same as the Federal LIHEAP program. The amount of the assistance provided is based on
household income, energy costs (all electric or natural gas costs, used for space heating or base
load) and housing type (single family, multifamily, etc.) and then calculated using the Office of
Community Development's (OCD) mechanism. The benefits of using this mechanism include
leveraging systems and staff knowledge already in place at the agencies as well as using a system
that indexes assistance to income and need.
AVISTA CORPORATION COMMENTS IN GNR-U-08-1 Page 2
For clients receiving "emergency" assistance (i.e., LIR Project Share) or small benefit
amounts, the process is similar to that used for Project Share. The amount of emergency
assistance is determined on a case-by-case basis not to exceed $300. Emergency assistance
includes items such as imminent danger of disconnection. All energy costs resulting from
electrc or natural gas usage are eligible (including kWh and therm consumption, applicable
taxes, and arrearages).
Additional benefits to customers having LIR include The Senior Energy Outreach
provided through the Avista CARS, via Elder Services and Aging and Long Term Care of
Eastern Washington (ALTCEW), in-home caregivers, and case managers, as well as the CAAs.
Program guidelines are designed to help mitigate the impact of energy costs on vulnerable
seniors living in their own homes, yet who are over income guidelines for energy assistance.
Included in this program are conservation education workshops specifically designed for seniors.
Conservation education has proven to be a key component of energy assistance programs.
Teaching and demonstrating improved approaches to managing energy costs can reduce
customers' bils and increase customers' ability to pay. The CAAs, as part of their LIHEAP
activities, have active education components. However, participation in educational activities to
receive emergency assistance is no longer required. The Company has created a conservation
education kit that includes weatherization and conservation materials for distribution by the
agencies. Information on the value and use of the materials is included as well. The Company
originally directed some energy assistance program funds to the production of support materials
such as an updated video presentation that is curently used by the CAAs as part of their
educational activities. The Company continues to research and expand the Conseration
Education and Weatherization components of LIR with programs such as "Power to
AVISTA CORPORATION COMMENTS IN GNR-U-08-1 Page 3
Conserve" and "Wattson Avista's Energy Watchdog," the energy conservation program for
children.
Avista believes it would be "seamless" and in our customers' best interest to add LIR
to its Idaho service terrtory as the agencies serving A vista customers are already poised to
deliver the program. The Company agrees with Staffs recommendation to support legislation that
would allow the Commission to adopt programs such as LIR. The Company believes that the
legislation should allow the Commission to implement programs for the benefit of low-income
residential customers, proposed by the individual utilities and approve rates or charges designed
to recover the costs of such programs.
2.) Staff encourages all utilties to increase awareness of and funding for nonprofit fuel
funds.
Avista has taken the lead in promoting Project Share in the communities we serve and
supports Staffs recommendation for utilities to increase awareness of and funding for nonprofit
fuel fuds. The Company is curently 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 partnerships with local
businesses to help in this effort with the sale of Project Share branded products.
3.) Staff recommends that a dialogue be initiated with Idaho's Congressional delegation
regarding increased awareness of LIHEAP's value and the critical need for
additional program funding. Staff also recommends that the utilties, Commission
Staff, and other interested parties partner with CAP AI to identify ways in which to
further leverage existing federal LIHEAP funding.
AVISTA CORPORATION COMMENTS IN GNR-U-08-1 Page 4
The Company continues to support increased awareness of LIHEAP's value and
congratulates the Idaho delegation for their work to secure the increased funding level for this
heating season. Avista wil support the delegation's efforts to maintain these levels. The
Company wil also continue to work with CAP AI and others to seek legislative solutions that
wil allow for greater customer paricipation in these programs.
4.) Staff recommends that additional funding for weatherization and energy
conservation education programs be addressed in future rate cases. Staff
recommends that utilties develop energy conservation education programs targeted
to low-income customers. Staff further recommends that utilties examie their
incentive programs regarding higher efficiency appliances, including consideration
of no interest/low interest loans for customers to purchase higher efficiency
appliances and encourage the Northwest Energy Efficiency Alance to include
multi-family and manufactured homes in the Energy Star Home Program.
The Company historically has addressed weatherization funding levels in our rate cases.
Most recently, in the Settlement Agreement in Docket Nos. A VU-E-08-01 and A VU-G-08-01,
Avista increased its support of low-income weatherization and conservation education support
by almost 40% to a total of $485,000. Avista appreciates the partnership it has with the
Community Action Partnership of Lewiston, Idaho to deliver weatherization services to our
customers. The Company's approach has been to recognize that Community Action Agencies
(CAA) have several funding sources, each with specific requirements and obligations. Our
policy is to, while retaining our responsibility for the appropriate use of our CAA funding,
provide flexibility in program design so that CAAs can pool and thereby optimize their
resources. A vista anticipates that this beneficial relationship and program delivery model wil
continue.
A vista is an advocate for energy conservation education. We have sponsored and led
conservation education workshops, prepared written material for distribution, provided specific
A VIST A CORPORATION COMMENTS IN GNR-U-08-1 Page 5
measures (compact fluorescent lightbulbs, 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 2008, the Company introduced Wattson, the energy saving watchdog, for
visits to schools and children's events. Wattson is both animated for use in collateral material
and is a "live" version when dressed as a six-foot costumed mascot, and is another valuable tool
to attract attention to the energy efficiency message.
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).
In regards to low- or no-interest loans, we are 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. A vista would prefer to work with the existing financial
institution infrastrctures that have this function as their primary service. The Company prefers
to focus on our area of specialty, energy service provision, and rely on banks and other lending
institutions to assist with customer loans. A host of issues would need to be addressed if A vista
were to become a direct intermediar for customer loans, including the costly potential for bil
redesign, computer and data enhancements, and contractual liabilities. If the Company were to
"buy-down" the interest rate of consumer loans, this would likely decrease the amount of
AVISTA CORPORATION COMMENTS IN GNR-U-08-1 Page 6
incentive payments by a corresponding leveL. A vista recommends that the provision for low-cost
consumer loans be pursued with area lending institutions.
Avista strongly supports initiative(s) by the Northwest Energy Efficiency Alliance to
include multi-family and manufactured homes in the ENERGY STAR(\ Home Program. Avista
has contracted with UCONS, a third pary energy efficiency service provider, to increase our
energy efficiency savings in the hard-to-reach multi-family market. And, in 2008, we initiated a
market transformation program to increase the penetration of natural gas in multi-family new
construction. We estimate that less than 10% of new construction in our service terrtory has
installed natual gas heating; the national average is greater than 60%.
Avista's regular-income residential and commercial energy efficiency programs provide
a host of financial rebates and incentives. These programs are based on the principle that all
cost-effective efficiency should be acquired for measures installed by customers with a simple
pay-back of greater than one year. This includes over 300 measures that are packaged into over
30 programs for customer convenience. Avista's "Every Little Bit" campaign
(www.EveryLittleBit.com) is aimed at making customers more efficient in their use of energy
and provides tips on low-cost and no-cost measures, with additional information on rebates.
Further, customers can determine their energy efficiency needs by using the comprehensive
Home Energy Analyzer at www.avIstautilities.com. Avista's energy effciency programs are
funded by the Company's energy efficiency tarff riders Schedules 91 and 191, the first "system
benefit charge" in the country to fund demand-side management and now celebrating its
foureenth year.
5.) Staff encourages utilties to actively advocate for adoption and implementation of
energy efficient construction standards, including provisions for single famiy
rental, multifamiy, and manufactured homes.
AVISTA CORPORATION COMMENTS IN GNR-U-08-1 Page 7
A vista supports improved appliance and building standards and codes as the most cost-
effective means for energy efficiency delivery. A vista was a strong proponent for improved
appliance codes, as evidenced by testimony presented in August 2006. A vista wil continue to
advocate for enhanced energy efficiency codes and standards.
6.) Staff recommends that utilties and the Commssion consider tiered rates for
residential customers within the context of future rate cases.
As stated in Staff comments, the Company has a two-tiered residential rate structue. The
present rate strcture essentially provides a price-signal for all weather-sensitive usage (greater
than 600 kWhs per month). The Company had a three-tiered inverted rate strcture 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 low/limited income households who used
electrc heat.
7.) Staff recommends that utilties offer more flexibilty in negotiating payment
arrangements. Staff further recommends that Staff and utilties further investigate
payment arrangement alternatives.
A vista works with customers that are having diffculty paying their bil. At the earliest
sign that the customer may be unable to pay their bil, we encourage them to contact us. The
Company can usually work out special payment arangements or help them find other forms of
assistance during difficult times. For customers with special needs, Avista has a case
management program available.
A VIST A CORPORATION COMMENTS IN GNR-U-08-1 Page 8
The Company offers several convenience options for customers that are generally able to
pay, such as, automatic payment service, debit and credit card service, check by phone or over
the web, preferred due date and e-biling. This provides help for those who need more
flexibility. Self services on our Website or Interactive Voice Response system are also available.
The Company supports Staffs recommendation and wil continue to work with
customers and look forward to collaboration with parties to investigate alternatives.
8.) Staff recommends more investigation and discussion among all interested parties
regarding how convenience fees can be eliminated or reduced.
The Company is currently negotiating with a new vendor to reduce its convenience fees
for 2009. We look forward to more discussion with the interested parties regarding this issue.
9.) Staff recommends more investigation and discussion among all interested parties
regarding the circumstances, if any, under which reconnection and interest charges
could be eliminated.
The Company would not support the elimination of these charges; however, we wil work
with interested paries as they review these charges.
In Cast No. A VU-E-07-09 "Application to Implement a Pilot Program for Remote
Disconnects and Reconnects," the Company has reduced its reconnection charge by 50% for
participating customers. The measurement and evaluation process for this program wil provide
additional insight on the opportnity to reduce this cost.
10.) Staff recommends further discussion of alternatives to existing deposit policies,
including an increase in installment payment plan timelies. Staff also recommends
that one or more of the utities conduct a study of the effectiveness of collecting
residential deposits.
AVISTA CORPORATION COMMENTS IN GNR-U-08-1 Page 9
The Company supports further discussion of alternatives to existing deposit policies,
including an increase in installment payment plan timelines. The Company wil conduct a study
of the effectiveness of collecting residential deposits and wil provide its results to the
Commission in 2009.
11.) Staff recommends that utilties adopt new policies whereby lower risk applicants be
permitted to payoff old bils in installments while receiving new service.
A vista works with customers on a case by case basis. Customer Service Representatives
analyze each customer's curent situation and previous payment history to determine the best
arangement. If a customer is not able to agree to a payment arangement and has special needs,
customers are referred to our Customer Assistance Referral and Evaluation Services (CARS)
Our CARS representatives wil take time with customers experiencing situations that are out of
their control and cause difficulty for them to pay their utility bil. CARS representatives
attempt to reach a solution that is beneficial to both the customer and A vista.
12.) Staff recommends that all energy utilties develop arrearage forgiveness plans.
In an effort to offer bil payment solutions for our low income customers, A vista has
researched arrearage forgiveness plans. Based on this research, the Company's preference would
be to offer a LIR program for its Idaho customers. Arearage forgiveness programs can be
positive for some customers; however, the amount recovered from all other ratepayers when you
offer an arrearage forgiveness plan is unkown and would require additional research and
planing. As mentioned earlier, implementation of a LIR program could be achieved quickly,
since Avista currently offers the program in Washington and Oregon, and the infrastructure is
already in place to deliver the program through the Community Action Agencies.
AVISTA CORPORATION COMMENTS IN GNR-U-08-1 Page 10
13.) Finally, Staff recommends that all utilties implement case management programs
if they have not already done so.
The Company is very proud of its Customer Assistance Referral Evaluation Service
(CARS) program. Avista CARS representatives assist customers with special needs -- the
elderly, the disabled and customers who find themselves in diffculty due to health, employment,
family or other problems. They provide assistance in understanding energy bils, payient
arangements and advice on budgeting, and make referrals to community agencies that can also
help. They also administer the Life Support and Gatekeepers Programs. In Idaho, A vista is
currently working with over 1,255 special needs customers in the CARS program. Specially-
trained representatives provide referrals to area agencies and churches for customers with special
needs for help with housing, utilities, medical assistance, etc.
In conclusion, the Company appreciates the time and work that Staff has put in to the
workshops and generally supports their recommendations We look forward to participating in
more discussions regarding the issues addressed in Staffs comments and look forward to a
positive outcome to more effectively address the needs oflow-income customers.
Respectfully submitted this 19th day of December 2008.
A VISTA CORPORATION
~~ ~~KELL NÓRWOOD
Vice President, State and Federal Regulation
cc: Service List
AVISTA CORPORATION COMMENTS IN GNR-U-08-1 Page 11
REer:../LtlEt)ZOD8 ""
CERTIFICATE OF SERVICE ¡Dote 22 Ph 2: ..~
Ul¡L1r'Af(Q"eu). '., .,..
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF DECE~~f¡I::~! .
SERVED THE FOREGOING AVISTA COMMENTS, IN CASE NO. GNR-U~08-01, l-,v:OIV
BY MALING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BETSY BRIGE
ENERGY EFFICIENCY ASSOC
ID CONSERVATION LEAGUE
PO BOX 844
BOISE ID 83701
MICHAL P MCGRATH
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707-1608
TERR SHOEN
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707-1608
MIK KIGERY
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707-1608
MAGGIE BRILZ
IDAHO POWER COMPAN
PO BOX 70
BOISE ID 83707-0070
LISA NORDSTROM
IDAHO POWER COMPAN
POBOX 70
BOISE ID 83707-0070
RICK GALE
IDAHO POWER COMPAN
PO BOX 70
BOISE ID 83707-0070
LINA GERVAIS
A VISTA UTILITIES
POBOX 3727
SPOKA W A 99220
BRUCE FOLSOM
AVISTA UTILITIES
PO BOX 3727
SPOKAE W A 99220
TED WESTON
ROCKY MOUNTAIN POWER
201 S MAIN STE 2300
SALT LAK CIT UT 84111
BARAR COUGHLIN
PACIFICORP
825 NE MULTNOMAH
STE 800
PORTLAN OR 97232
BRA MPURY
ATTORNY AT LAW
2019 N 17TH ST
BOISE ID 83702
MAY CHAN EXE DIR
COMMITY ACTION
PARTNERSHIP ASSOC OF ID
5400 W FRAIN RD STE G
BOISE ID 83705
ROWENA PINDA EXE Dm
ID COMMUITY ACTION
NETWORK
3450HILLRD
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CARIE TRACY
NW FEDERATION OF COMMU
ORGANIZATIONS
1265 S MAIN ST #305
SEATTLE WA 98144
JIM WORDELMA
AAIDAHO
3080 E GENTRY WAY
STE 100
MERIAN ID 83642
DEDE SHELTON
AAIDAHO
3080 E GENTRY WAY
STE 100
MERIDIA ID 83642
LYN YOUNG
2786 S DENALI PLACE
MERIDIA ID 83642
JUIA CAMPBELL
SOUTHEASTERN IDAHO
COMMITY ACTION AGENCY
641 N 8TH
POCATELLO ID 83201
DEBRA HEMMERT EXE DIR
SOUTHEASTERN IDAHO
COMMITY ACTION AGENCY
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KEN ROBINETTE EXE DIR
SOUTH CENTRA
COMMICTY ACTION PARTNR
POBOX 531
TWIN FALLS ID 83303
RONCORTA
C.C.O.A. WEATHERIATION
304 N KIALL AVE
CALDWELL ID 83605
RICHAR STELLING
EXECUTIVE DIRCTOR
C.C.O.A. WEATHERIZATION
304 N KIALL AVE
CALDWELL ID 83605
RUSS SPAIN EXE DIR
EASTERN IDAHO COMMUITY
ACTION PARTNRSHIP
357 CONSTITUTION WAY
IDAHO FALLS ID 83405
ROB CHRSTENSEN EXE DIR
WESTERN IDAHO COMMUITY
ACTION PROGRA
315-B S MAIN ST
PAYETTE ID 83661
LISA STODDAR EXE DIR
COMMIT ACTION
PARTNRSHIP
124 NEW 6TH STREET
LEWISTON ID 83501
DICK HENRY
EXECUTIVE DIRCTOR
EL-ADAINC
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BOISE ID 83714
GENIE SUE W APPNER
ID DEPT OF HEALTH & WELFAR
STATEHOUSE MAIL
POBOX 83720
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SENATOR NICOLE LeFAVOUR
1210 N 11TH
BOISE ID 83702
REP. WILLIA KILLEN
734 S CORAL PL
BOISE ID 83705
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REP PHYLIS KIG
21 07 PALOUSE
BOISE ID 83705
REP. AN PASLEY-STUART
749 HIGH POINT LAN
BOISE ID 83712-6561
REP. DONNA PENCE
1960 US HW 26
GOODING ID 83330
TERIOTTENS
POBOX 8224
BOISE ID 83707
p~~
Rates Coordinator
December 19, 2008 CERTIFICATE OF SERVICE