20081219Reply Comments.pdf

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An IDACORP Company
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LISA D. NORDSTROM
Senior Counsel
December 19,2008
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. GNR-U-08-01
Energy Affordability Issues and Workshops
Dear Ms. Jewell:
Enclosed for filing please find an original and seven (7) copies of Idaho Power
Company's Reply Comments in the above matter.
I would appreciate it if you would return a stamped copy of this letter for Idaho
Power's file in the enclosed stamped, self-addressed envelope.
Very truly yours,~lj.'1~
Lisa D. Nordstrom
LDN:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
LISA D. NORDSTROM, ISB No. 5733
BARTON L. KLINE, ISB No. 1526
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: 208-338-6936
Inordstrom((idahopower.com
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200n DEC 19 PM 2: 52
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TIER OF THE
COMMISSION'S INQUIRY ABOUT
ENERGY AFFORDABILITY ISSUES
AND WORKSHOPS.
)
) CASE NO. GNR-U~08-01
)
) IDAHO POWER COMPANY'S REPLY
) COMMENTS
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company") and
submits the following Comments in response to the Comments filed by the Commission
Staff on November 26, 2008.
i. GENERAL COMMENTS
Idaho Power commends the Commission Staff on their facilitation of the
Affordability Workshops ("Workshops") and the completeness of their initial draft
Comments. The draft contains an accurate depiction of the parties' positions during the
Workshops. Idaho Power also commends the Staff for recounting the existing energy
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
assistance programs that are presently available to those customers that are
economically challenged. While the topic is timely and action is urgent, it is beneficial to
start with a foundation of what activities already exist.
The Company tends to view the various alternatives in a hierarchy. Idaho Power
is a strong advocate for Project Share, rate design that encourages the wise use of
energy, and energy effciency education and programs; Idaho Power has already taken
significant steps in these areas. Idaho Power is not an advocate for a reduced rate for
low-income customers. Idaho Power also believes that additional energy assistance
funds are better supplied under a state-supported tax basis than a utilty-supported rate
basis.
II. IMPLEMENT UTILITY PROGRAMS DESIGNED TO
PROVIDE FINANCIAL ASSISTANCE
Idaho Power does not endorse the Staffs recommendation that legislation be
supported to allow the Commission to adopt utility programs to provide financial
assistance to low-income customers for several reasons. As a matter of public policy,
should the State of Ida.ho decide additional funds for energy assistance are in the public
interest, Idaho Power believes an explicit state tax to fund the assistance is preferable
to an additional utility charge. A state-wide tax would provide the means for customers
of all utilities in Idaho, not just those regulated by the Commission, to benefit from
financial assistance.
II. INCREASE CUSTOMER AWARENESS/ENCOURAGE VOLUNTARY
CONTRIBUTIONS TO NONPROFIT FUEL FUNDS
Idaho Power fully agrees with Staffs recommendation to increase customer
awareness of and contributions to nonprofit fuel funds.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
Since the conclusion of the Workshop, the Company has participated with KTVB
Channel Ts Season of Hope campaign in promoting Project Share contnbutions
through a televised public service announcement, actively promoted Project Share
donations through various means to its employees, promoted Project Share to its
customers through information included in November bitls, and increased its
shareholders' donation for this heating season in recognition of the current economic
conditions.
IV. INCREASE FUNDING FOR LlHEAP
Idaho Power fully agrees with Staffs recommendation that a dialogue be initiated
with Idaho's Congressional delegation and that interested parties partner with CAPAI to
identify ways in which to leverage existing federal L1HEAP funding.
V. CREATE A STATE-FUNDED FINANCIAL ASSISTANCE PROGRAM
Idaho Power agrees with Staff that it could be diffcult to create and fund a state-
supported financial assistance program in the near term due to the current economic
circumstances and the State's financial situation. Nevertheless, as a matter of public
policy, if the State of Idaho wishes to pursue additional sources of energy assistance,
the Company strongly believes that it should be funded explicitly through taxes and not
through rate adders. This approach is much more straightforward and transparent to
the public and does not carry the equity issues previously described above regarding
assistance programs funded solely by Commission-regulated utilities.
Vi. REDUCED RATES FOR LOW-INCOME CUSTOMERS
Idaho Power agrees with Staffs recommendation not to recommend adoption of
reduced rates at this time because there are other preferable options available to the
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
Commission to consider. The Company feels strongly that the issue of product pricing
and product affordability are two separate policy issues. All customers should see an
economic price signal on their usage. Moreover, many low-income rate designs
eliminate this signaL. Therefore, Idaho Power advocates for a separation between the
billng for utility. service and the energy assistance used to pay those bils.
ViI. LOW-INCOME WEATHERIZATION, CONSERVATION EDUCATION, AND
OTHER ENERGY EFFICIENCY PROGRAMS
Idaho Power fully supports weatherization and energy effciency education as the
highest priority for providing assistance to low-income customers. Dollars spent
weatherizing and performing other energy effciency measures to the target customer
group provide much more long-term value to the customer and to the energy system
than direct assistance by a factor of two for the customer and three for the avoided
system cost.
Idaho Power has been an active proponent for the adoption of energy effcient
construction standards and supports Staffs recommendation that efforts in this area, as
well as efforts targeting multi-family and manufactured housing, continue. Idaho Power
does not support Staffs recommendation that utilities consider loans to customers for
the purpose of adding high effciency appliances. The Company believes that loans
should be managed by financial institutions and that other approaches to encourage the
adoption of energy effcient appliances should be investigated.
VII. DESIGN RATES TO ENCOURAGE ENERGY EFFICIENCY
Idaho Power fully agrees with Staffs recommendation to consider tiered rate
designs for residential customers as a way to give customers control over their bils by
providing an incentive to lower their energy consumption. Idaho Power has filed to
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
implement year-round tiered rates in its residential customer class in its pending general
rate case (IPC-E-08-10) and is also completing its second year in a Fixed Cost
Adjustment mechanism (decoupling) that is applicable to both the residential and small
general customer classes.
IX. OFFER PLANS THAT ALLOW PAYMENT OF ARREARS
OVER AN EXTENDED LENGTH OF TIME
Idaho Power agrees with Staffs recommendation to have further discussions
with Staff and other interested parties to investigate payment arrangement alternatives.
Successful arrangements should be tailored to meet the needs of individual customers
and should be designed to keep current bils paid, as well as to reduce account
balances over time. Idaho Power is not convinced that extending payment
arrangements beyond twelve months wil result in more customers keeping their
payment arrangements. Staff correctly identified higher bad debt as a possible result of
extending the length of time over which arrears can be paid. This issue, as well as
others that may be identified through further discussion, need to be fully investigated.
X. OFFER PERCENTAGE OF INCOME PAYMENT PLAN
Idaho Power concurs with Staffs recommendation that a percentage of income
payment plan not be pursued at this time. Idaho Power agrees with Staff that the major
impediments associated with this option are the lack of encouragement for energy
conservation, the costs associated with modifying billng systems, and the need for
legislation in order for utilities to offer such a plan. In addition, another significant
impediment associated with this option is the lack of an established process for
qualifying customers for this type of payment plan. Developing and supporting a
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
continuing process for qualifying customers for such a program could be quite costly for
CAP agencies.
Xl. REDUCE/ELIMINATE PAYMENT CHARGES AND EDUCATE
CUSTOMERS ON NO COSTILOW COST OPTIONS
Idaho Power supports Staffs recommendation that more discussions be held
among all interested parties regarding convenience fees for credit card and electronic
check payments.
XII. REDUCE OR ELIMINATE RECONNECTION CHARGES AND
INTEREST ASSESSED ON LATE PAYMENTS
Idaho Power believes that legislation is necessary in order for these fees to be
reduced or eliminated only for low-income customers. However, the reduction or
elimination of these fees removes an incentive that is currently in place for customers to
pay their bils on time and to pay their bils in order to avoid service termination. Idaho
Power encourages customers to contact the utility and work through payment
arrangement plans, and believes that removal of these fees may also remove the
incentive for customers to contact the utility. For these reasons, Idaho Power does not
support this option.
XII. MODIFY DEPOSIT POLICIES
As recommended by Staff, Idaho Power is supportive of more in-depth
discussion among the parties regarding deposit policies.
XIV. ALLOW INSTALLMENT PAYMENTS ON PRIOR BILLS
Idaho Power considers any customer who has not paid the balance owing on
prior bils to be a risky customer. However, the Company does take the amount of the
unpaid prior bil into account when assessing risk and considers those customers with
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
unpaid bils greater than $100 to be a higher risk than those customers with unpaid bils
under $100. Currently, Idaho Power allows customers who have old bils under $100
and who are moving into premises that currently have active service to payoff the old
bils in installments. Idaho Power would be willng to consider changing its practices
and allow all customers with old bils under $100 the option to pay the balance in
installments in order to receive new service.
Idaho Power believes that income cannot be used to identify customers who
would be permitted to pay old bils in installments. Therefore, any change to the
Company's practice would apply to all customers. Due to the increased risk of
additional write-off-balances that would likely occur should this approach be taken,
Idaho Power recommends that Staff and the other parties explore changes to Rule 310
that would allow service to be terminated for non-payment of the payment arrangement
for the old bil regardless of the amount remaining unpaid.
XV. OFFER ARREARAGE FORGIVENESS PLANS
Idaho Power is opposed to Staffs recommendation that all energy utilities
develop arrearage forgiveness plans. In addition, Idaho Power believes that identifying
a select group of customers for preferential treatment requires legislative action.
XVI. OFFER CASE MANAGEMENT
Although Idaho Power does not have an advertized case management program
such as Avista's CARES program, Idaho Power does have an effective case
management process in place for the neediest of its customers. Current case
management support comes from a coordinated effort from the following employees:
1. Customer Service Support Specialists
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
2. Customer Service Representatives
3. Customer Service Supervisors
4. Customer Representatives in the Regions
5. A Program Specialist in its Customer Relations and Energy
Effciency Department
These employees work with individual customers who are experiencing unordinary
situations, consulting with CAP agencies and other organizations, making on-site visits
to the customers' premises, and identifying workable payment solutions. Idaho Power
is willng to consider other ways in which it can augment its current case management
process.
Respectfully submitted this 19th day of December 2008.
~/J.~~äNORDSf M
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 19th day of DECEMBER 2008 I served a true
and correct copy of IDAHO POWER'S REPLY COMMENTS upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
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-. Email Kristine A. Sasser((puc.idaho.gov
Idaho Conservation League
Betsy Bridge
Energy Effciency Associate
Idaho Conservation League
P.O. Box 844
Boise, Idaho 83701
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FAX
Email
Intermountain Gas Company
Michael P. McGrath
Intermountain Gas Company
P.O. Box 7608
Boise, Idaho 83707-1608
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Email
Terri Shoen
Intermountain Gas Company
P.O. Box 7608
Boise, Idaho 83707-1608
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Mike Kingery
Intermountaih Gas Company
P.O. Box 7608
Boise, Idaho 83707-1608
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Email
AVIST A UTILITIES
Linda Gervais
Avista Utilities
P.O. Box 3727
Spokane, Washington 99220
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IDAHO POWER COMPANY'S REPLY COMMENTS - 9
Bruce Folsom
Avista Utilities
P.O. Box 3727
Spokane, Washington 99220
Rocky Mountain Power
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
PacifiCorp
Barbara Coughlin
PacifiCorp
825 NE Multnomah, Suite 800
Portland, Oregon 97232
Brad M Purdy
Attorney At Law
2019 North 17th Street
Boise, Idaho 83702
Community Action Partership
Association of Idaho
Mary Chant, Executive Director
Community Action Partnership
Association of Idaho
5400 West Franklin Road, Suite G
Boise, Idaho 83705
Idaho Community Action Network
Rowena Pineda, Executive Director
Idaho Community Action Network
3450 Hil Road
Boise, Idaho 83703
NW Federation of Community
Organizations
Carrie Tracy
Northwest Federation of Community
Organizations
1265 South Main Street #305
Seattle, Washington 98144
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IDAHO POWER COMPANY'S REPLY COMMENTS - 10
AARP Idaho
Jim Wordelman
AARP Idaho
3080 East Gentry Way, Suite 100
Meridian, Idaho 83642
Dede Shelton
AARP Idaho
3080 East Gentry Way, Suite 100
Meridian, Idaho 83642
Lyn Young
2786 South Denali Place
Meridian, Idaho 83642
Southeastern Idaho Community
Action Agency
Julia Campbell
Southeastern Idaho Community Action
Agency
641 North Eighth
Pocatello, Idaho 83201
Debra Hemmert, Executive Director
Southeastern Idaho Community Action
Agency
641 North Eighth
Pocatello, Idaho 83201
South Central Community Action
Partner
Ken Robinette, Executive Director
South Central Community Action
Partner
P.O. Box 531
Twin Falls, Idaho 83303
C.C.O.A. Weatherization
Ron Corta
C.C.O.A. Weatherization
304 North Kimball Avenue
Caldwell, Idaho 83605
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IDAHO POWER COMPANY'S REPLY COMMENTS - 11
Richard Stellng, Executive Director
C.C.O.A. Weatherization
304 North Kimball Avenue
Caldwell, Idaho 83605
Eastern Idaho Community Action
Partnership
Russ Spain, Executive Director
Eastern Idaho Community Action
Partnership
357 Constitution Way
Idaho Falls, Idaho 83405
Western Idaho Community Action
Program
Rob Christensen, Executive Director
Western Idaho Community Action
Program
315-B South Main Street
Payette, Idaho 83661
Community Action Partership
Lisa Stoddard, Executive Director
Community Action Partnership
124 New Sixth Street
Lewiston, Idaho 83501
EL-ADA, Inc.
Dick Henry, Executive Director
EL-ADA, Inc.
701 East 44th Street #1
Boise, Idaho 83714
Genie Sue Wappner
Idaho Department of Health & Welfare
Statehouse Mail
Senator Nicole LeFavour
1210 North Eleventh
Boise, Idaho 83702
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IDAHO POWER COMPANY'S REPLY COMMENTS - 12
Representative Willam Kilen
734 South Coral Place
Boise, Idaho 83705
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Representative Phylis King
2107 Palouse
Boise, Idaho 83705
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Representative Anne Pasley-Stuart
749 High Point Lane
Boise, Idaho 83712-6561
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Representative Donna Pence
1960 U.S. Highway 26
Gooding, Idaho 83330
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Teri Ottens
P.O. Box 8224
Boise, Idaho 83707
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£I)!t~Lisa D. Nordstrom .
IDAHO POWER COMPANY'S REPLY COMMENTS - 13