20081219Comments.pdf

NORTHWEST INDUSTRIAL GAS USERS
4113 Wolf Berry Court
Lake Oswego, OR 97035-1827
Phone: [phone]
Facsimile: [phone]
Paula E. Pyron
Executive Director E-mail: ppvmni?nwigu.oi'g
December 19,2008
VIA ELECTRONIC FILING to: jean.jewell(apuc.idaho.gov
Ms. Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, il 83702-5983
RE: Matter ofthe Commission's Inquiry about Energy Affordabilty Issues and
Workshops, Comments ofthe Northwest Industrial Gas Users
Dear Ms. Jewell:
In response to the Idaho Public Utilities Commission's September 29,2008 Notice of
Public Workshops and Notice of Scheduling in Order No. 30644, and as modified by Order
30685, in the above-captioned proceeding, the Northwest Industrial Gas Users ("NWIGU")
respectfully submits its comments for the Commission's consideration.
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NWIGU is a non-profit trade association comprised of thirty-eight end-users of natural
gas with major facilities in the States of Oregon, Washington, and Idaho. NWIGU members
include diverse industrial interests, including food processing, pulp and paper, wood products,
aluminum, steel, chemicals, electronics, and aerospace. The association provides an
informational service to its members and participates in various regulatory matters that affect
member interests. NWIGU member companes purchase transportation services from Northwest
Pipeline GP, and from TransCanada's Gas Transmission Northwest Corporation ("GTN") either
directly or through capacity release from marketers, and purchase sales and transportation
services from regional local distribution companies, including Intermountain Gas Company
("Intermountain"), that acquire service from these interstate pipelines.
NWIGU appreciates this opportunity to provide comments in this proceeding and
requests that communications in reference to these comments are addressed to:
GNR-U-08-01 Comments of the Northwest Industrial Gas Users Page 1 of 3
Paula E. Pyron
Executive Director
Noithwest Industrial Gas Users
4113 Wolf Berry Court
Lake Oswego, OR 97035-1827
Phone: [phone]
Facsimile: 503.636-0703
E-Mail: ppyron~nwigu.org
In this proceeding, the IPUC has provided a foru for the exploration of issues related to
the affordabilty of energy for consumers, including bil mitigation payment plans, bil payment
assistance, bil reduction (including conservation and weatherization), reduction of consumer
costs, bainers to service (e.g., deposits), and case management. The Commission's express
objective is to identify new programs, policies and/or legislation, procedures, and/or resources
that could be implemented to address energy affordability. As a follow up to workshops held by
the Commission in October, Staffhas now released its Comments outlining its recommendations
to the Commission to which NWIGU wishes to respond.
In its comments, the Staff identified five ways to provide new and additional funds for
bil payment assistance to low-income consumers: 1) create utility programs designed to help
low-income customers pay energy bils funded by all utility customers through rates (a low
income rate assistance program or "LIRAP"); 2) increase voluntary contributions to non-profit
fuel funds; 3) increase federal funding for the Low-Income Home Energy Assistance Program
("LIHEAP"); 4) increase LIHEAP funding received by Idaho through leveraging; and, 5) create
a program fuded by Idaho state tax revenue to provide financial assistance to low-income
households.
NWIGU applauds the Commission and its Staff for examining ways to improve energy
affordabilty. In paricular, industrial customers support and partner with the utilities to make
voluntary contributions to non-profit fuel funds and to assist the utilities in raising community
awareness of these programs to assist those in need in our communities with support for their
winter heating bils. NWIGU urges the utilties to also contribute to these voluntary programs
with the utilities' shareholder dollars as well. NWIGU also believes that the Commission can
play an impoitant role itself in raising additional public awareness of voluntary contribution
programs.
NWIGU agrees with Staffs recommendation that the Commission review increased
federal fl.mding for LIHEAP in conjunction with Idaho's Congressional delegation and that the
leveraging of LIHEAP funding in Idaho should be pursued. Industrial customers do not,
however, support Staffs recommendation that a LIRAP program be instituted in Idaho by the
Commission's advocacy for legislation to surcharge other customers for the benefit of low
income customers with bil assistance. NWIGU members support voluntary contributions to
non-profit fuel funds, but do not support legislation that would provide for cross subsidies in
other customers' rates to support low income consumers through this Commission. NWIGU
GNR-U-08-01 Comments of the Northwest Industrial Gas Users Page 2 of 3
members believe that a social program to provide financial assistance to low.income households
should be considered by the legislature only iii the context. of funding by Idaho state tax revenue,
just like LIHEAP at the federal level, and should not be accomplished by charges on other
customer bils through this Commission.
NWIGU also supports cost-effective conservation programs for a gas utility's sales
customers as the sales customers collectively benefit from the. utilty's conservation efforts
thrcugh reduced con.1Uiodity purchases that the utility makes 011 their behalf. NWIGU agrees
with Staffs recommendation that the consideration oflow-income weatherization efforts as part
ofa utilty's cost~effective conservation program for its sales customers should be considered in
future rate cases.
In addition to those issues identified by the workshops and Staff in this docket. NWIGC
also tLrges the Commission to focus on its role in promoting energy affordability by suppoiiing
natural gas resource development and infrastructure access for Idaho consumers at reasonable
costs. While NWIGtJ realizes that the. focus of this proceeding is on low-income residentialconsumers, NWIGU would urge the Commission to take a $uppoitive role in proceedings before
the Federal Energy Regulatory Commission. and other forums by providing visible support to
natural gas resource development and infrastructure proposals that benefit Idaho (e.g., by
intervening in support of pipeline proposals that benefit Idaho natw'aJ gas customers) or by
intervening in the next round of expected natural gas pipeline rate cases that will impact Idaho
consumers to help keep charges reasonable that are passed through to all Idaho consumers in
their utility bils. A more active role by the Commission in these proceedings woulò benetit all
energy c.onsumers, whether residential or industriaL.
If additional issues are brought forward in this docket, NWIGU respectfully reserves
the right to make additional comments.
With the hard copy original of this filing, NWIGU is subniìtting an original and seven
copies of the Northwest Industrial Gas Users' Comments for fiing in the above-referenced case.
If you have any questions, please call me at 503.636-2580. Thank you for YOur assistance with
this matter.
Ytry truIYY.9\lJS,. .t~t.P~
Executive Director
Northwest Industrial Gas Users
cc Chad Stokes via e-mail tocstokes§cablehuston.com
Mike McGrath via e-mail tommcgrathtiintgas.com
Kris Sasser via e-iiiail to Kris.SasseræJpuc.ídaho.gov
GNR-U-OB-01 Comments ofthe Northwest Industrial Gas User$ Page 3 of 3