20081219Comments.pdf

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3450 Hil Road. Boise, 1083703. [phone]. fax [phone]
IDAHO FUBUÇ
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Re: CASE NO. GNR-U-08-1
The Idaho Community Action Network (lCAN) welcomes the initiative taken by the Idaho Public Utilities
Commission to find solutions to the problems consumers in Idao are having paying utilty bils. The
curent economic crisis has exacerbated a problem that ICAN has been working with the PUC to alleviate
for years. As the Staff comments so clearly show, Idaho residents in many pars of the state have been
strggling for some time to find living wage jobs that allow them to pay for housing, food, health care, and
other necessities. Rising utilty costs are squeezing family budgets even farher than in the past.
We are also very happy to see that the PUC Staffhas begun incorporating some of the recommendations in
this case into the Idaho Power rate case. We support the Staff recommendation to increase the number, and
size, ofIdaho Power's existing rate tiers. The changes proposed wil allow consumers at all income levels to
tae control of their bils, as well as encouraging conservations. The Staff recommendations for Idaho
Power to research the elimination of convenience fees and to develop ways to help customers strggling to
meet the terms of their payment plans show the Staffs commitment to implementing the solutions we have
talked about in the workshops for this case.
All of the solutions discussed show great promise, and we support all of the policies under consideration.
We have prioritized five policies that would make it substatially easier for low- and moderate-income
utility customers to pay their utility bils. Our top five priorities are:
1. Creation of programs like Avista's Low-Income Rate Assistace Program (LlRA) by all Idaho
utilities. This program, and others like it in other states, has been proven to make energy more
affordable to low-income customers. ICAN wil support the necessar legislation to allow the PUC
to adopt a LIRAP program. We urge the PUC and Idaho's utilties to support this legislation as welL.
2. Increasing Federal and State funding for the Low Income Home Energy Assistace 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 LIHAP,
including the LIHEAP Weatherization program. We wil continue to support this legislation and
urge the PUC and Idaho's utilities to support funding for the program in the State Legislature and in
Congress, as well as exploring other sources of fuding that can be leveraged.
3. We strongly support increased funding for weatherization and energy efficiency education programs.
Many low-income families live in housing that is inefficient, and have no ability to weatherize it on
their own. Increasing the contribution of utility companies as part of their conservation measures,
such as CAP AI's recommendations in the Idaho Power rate case, enables more families to live in
energy efficient homes, which benefits both them and the utility companies. We are also in favor of
expanding programs like the Idaho Power pilot project that wil provide weatherization assistance to
familes above the 150 FPL income leveL. Many families with incomes above that level are also
unable to weatherize their homes or keep up with utility bils.
We are supportive of increased fuding for education programs, but our experience has shown that
education alone is not enough - without funding for weatherition, many of the more effective
measures are not possible. We urge the PUC to require utilty companies to increase their funding
for both weatheriation and education progrs.
4. Eliminating payment charges. Many 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 utilzing payment methods that incur these charges, especially since utility
companies have reduced the number of locations at which customers can pay their bils. As the Staff
notes, a growing number of customers are choosing these options, which results in lower cost of
providing the service. We urge the PUC to eliminate these payment charges.
5. Eliminating deposit requirements. We support 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. They are, however, very effective at preventing low-
income customers from accessing utilty services. We urge the PUC to change the Utilty Customer
Relations Rules (UCRR) to end the practice of requiring customers to provide deposits.
While these five policies are our highest priorities, ICAN also supports other policy changes:
Reduced rates for low-income people: While we understad the Staffs concerns about the diffculty of
implementing these programs, we continue to support researching ways to implement them here in Idaho.
Similar programs have worked in many sttes, including Washington. We are confident that the PUC and
the utilty companies could make similar progrs work here.
Tiered rates: We strongly support the Staff recommendation to change the Idaho Power rate structue to
include a third tier, and increasing the size of the first and second tiers. We also strongly support making
this change in future rate cases initiated by Idaho's other regulated utilties. Pairng this rate structure with
increased fuding for weatherization, including funding for customers who do not qualify for LIHEAP
weatheriation fuding, wil provide relief for many low- and moderate-income customers.
Allow customers additional time to payoff arearages: ICAN strongly supports action by the PUC to require
utilities to create extended arrearage payment plans. We wil paricipate in future workshops to study this
issue and identify ways for utility companies to make more flexible arangements. We urge the PUC to
make these policies mandatory by incorporating them in changes to the Utility Customer Relations Rules
(UCRR).
Percentage of Payment Income plan: ICAN recognizes the diffculties that the Staff points out in
, implementing percentage of income payment plans. These programs have been very successful in other
: states, and we support continued research and discussion of ways to implement similar policies in Idaho.
. Reducing or eliminating réconnection fees and interest assessed on late payments: We support eliminating
reconnection charges and interest assessed on late payments. These create even larger bariers for families
who are already having diffculty, and are counter-productive to our shared goal of ensuring that families
are able to pay bils on time. We also urge the PUC to incorporate these changes in the Utilty Customer
Relations Rules (UCRR).
Allow Installment Payments on Pror bils: We support this policy recommendation, but urge the PUC to
make this policy par of the Utilty Customer Relations Rules (UCRR), rather than relying on the utilities to
voluntarily adopt the policy. We are also concerned that the policy would be restricted to "lower risk
applicants." Utilty companies are much more likely to consider low-income customers to be "high risk," so
the customers most in need of the assistace would be the least likely to benefit from it.
Arearage forgiveness plans: ICAN strongly supports implementing arearage forgiveness plans at all Idaho
utilties. These programs have shown that everyone benefits, from the utilties and the customers who are
directly affected, to other customers who benefit from lowered utility administrative costs. We urge the
PUC to include this policy in changes to the Utilty Customer Relations Rules (UCRR).
Case management: We support the proposal that utilty companies invest in case management programs.
Sincerely,
Rowena Pineda
Executive Director