20081219Reply Comments.pdf

~~l~OUNTAIN
December 19,2008
VL OVERNGHT DELIVERY
Idaho Public Utilties Commission
472 West Washington
Boise, ID 83702-5983
Attention:Jean D. Jewell
Commission Secreta
RECEiVE
ZOOS GEe \ 9 PM 2: 28
UT,~R~f~)¿J~\~~Ä\(ŠS10¡"¡
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Re: Case No. GNR-U-08-1, In the Matter of the Commssion's Inquiry About Energy
Affordabilty Issues and Workshops.
Rocky Mountain Power's Response to Staf Comments
Dear Ms. Jewell:
Enclosed please find an original and seven (7) copies of Rocky Mountain Power's Response to
Staf Comments in the above captioned docket. Rocky Mountain Power appreciates the
opportty to provide input to the Commission on this importt issue that has far-reachig
effects for Idaho ratepayers.
Please contact me directly at [phone] if you have any questions concerng this filing.
llT;;~1
Rocky Mountain Power
Idaho Reguatory Affairs Manger
Danel E. Solander
Senior Attorney
ROCKY MOUNTAI POWER
201 South Mai, Suite 2300
SALT LAK CITY, UT 84111
[phone]
[phone]
Attorney for Rocky Mountain Power
RECE\VED
20ua GEe \ 9 PM 2: 28
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMSSION'S
INQmRY ABOUT ENERGY AFFORDABILITY
ISSUES AND WORKHOPS
) CASE NO. GNR-U-08-1
) REPLY COMMENTS OF
) ROCKY MOUNTAIN
) POWER
COMES NOW PacifiCorp, dba Rocky Mounta Power ("the Company" or
"RMP"), by and through its attorney, provides the followig Reply Comments in
response to Stas Comments of November 26,2008, in the above-captioned Docket.
On September 29,2008, the Idaho Public Utilties Commssion ("Commssion")
initiated Case No. GNR-U-08-1 to explore issue~ related to energy affordabilty in Idaho.
The Commssion noted that rising energy costs were affecting public utilties in Idaho
and their customers. The Commission fuer recognzed that there are a number of
factors that contrbute to rising electrc and natul gas rates, and that energy affordabilty
has become a central issue for utilty customers in Idaho.
On November 26, 2008, Commission Staff provided comments to the
Commission addressing a number of energy afordability issues. RM appreciates the
extensive review and analysis of the issues by Commission Sta The Company submits
the following comments for consideration by the Commission.
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- i -DECEMBER 19,2008
General Comments
RMP appreciates the Commission's and Staffs efforts in addressing the many
issues surounding energy affordabilty, and the opportty to paricipate in the October
Energy Affordabilty Workshops in this Case. Due to a varety of reasons, there are
housholds that are not able to pay for necessities such as housing, food, medicine and
energy. In developing policies and progrs to assist these households, RMP believes it
is importt for the Commission and the utilities to strve for a balance by recognzing
that all customers will be impacted by adding or shifting the costs incurred for new
programs and policies. The Company submits the following comments for consideration
by the Commssion.
Specific Comments on Recommendations
1. Staff believes that a LIRA program would be beneficial for Idaho
low-income utility customers. Staff recommends that the Commission support
legislation to allow it to consider adoption of such a program.
RM does not believe that establishing a LIR program is the most effective
way to reach all low income citizens in the State ofIdaho. To reach all low income
citizens regardless of what entity provides gas and or electrc service, and regardless of
heat source, we believe it would be more appropriate for the legislatue to implement
a state energy assistace ta.
Alternatively, if the Commssion determines it will encourage and support
legislation to offer rate relief, RMP requests that the legislation allow the utilties to be
flexible as to the tye of programs they offer, recognzing the unque circumstaces of
each utilty and service area, that any legislation allow for recovery of program costs
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 2 -DECEMBER 19,2008
through a separate rider or other mechansm on customer bils and that such programs be
volunta offerigs by the utilties.
RM curently offers a bil discount program in Uta and its sister utility, Pacific
Power, has bil discount progrs in two state jursdictions. RM believes bil discount
programs are less costly or burdensome to administer and can be designed to provide on-
going reliefto low-income customers. The bil discount programs are available to
income eligible customers regardless of their priar heat source. The programs have
been well received by eligible customers and partering/communty agency staffs in three
of our state jursdictions.
In addition, the Company commissioned a Low-Income Arearage Study
completed by Quatec, LLC and submitted to the Commission in March 2007, which
includes positive findings related to the Company's bil discount progrs. On page 22
of ths report, Quatec states that rate discount programs lower home energy burdens by
reducing the amount paid by low-income households. In the three states with rate
discount progras Quatec observed the highest customer bil coverage ratio, whereas
the average customer bil coverage ratios for states without a low-income rate discount
are signficantly lower.
The Company is required by Oregon's SBl149 to collect fuds that are forwarded
to the state to be used for energy assistace payments. Bil payment assistace frm
these additional fuds does not seem to favorably affect the bil coverage as well as a bil
discount program. Quantec reported Oregon has bil coverage of 66 percent. The bil
coverage in the states where a bil discount is in place was 92 percent in Californa, 80
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 3 -DECEMBER 19, 2008
percent in Uta and 75 percent in Washigton, respectively. Idaho's bil coverage was 65
percent.
The Company has experience curently in three states with different approaches to
bil discount programs. The program in Californa provides a 20 percent discount on all
monthly bils and the Uta progr provides an $8 per month discount plus an additiona
$10 per month to households with a famly member with life support equipment. Neither
the Californa or Uta programs cap paricipation. The program available in Pacific
Power's Washington service area was designed by an advisory group and offers a thee
tiered discount with a larger discount assessed to the lowest income households. The
advisory group wanted the discount to apply to heating month (November though
April) as there are a large percentage of customers with electrc heat. There is a cap on
the number of paricipants in Washigton in order to maintain the surcharge at a
reasonable amount. RM would like the flexibilty to explore the option best suited for
its customers.
2. Staff encourages all utilties to increase awareness of and funding for
nonprofit fuel funds.
RMP agres with Stas recommendation. RM actively strves to increase
customer awareness and fuding for the Lend-A-Hand program. RMP distrbutes Lend-
A-Hand donation envelopes in November, Februar and June bils. The third mailing in
June was added to our distrbution process in 2008 and thus far has proved to be
successfuL. Along with the envelope distrbution, RM distrbutes news releaes,
includes program detals in its customer newsletter, and over the past year began placing
REPLY COMMNTS OF
ROCKY MOUNTAIN POWER
- 4-DECEMBER 19, 2008
programcontrbution information on the website landing page used by customers that
pay their bils electronically.
Lend-A-Hand fuds are not fuel blind, these fuds are used to assist customers
with their electrc bils. It is estimated that only about 30 percent of RM residential
customers heat with electricity. Local agency staffhave stated they appreciate that Lend-
A-Hand fuds are available specifically to help with RMP bils because without them.,
they would be tug people in need away.
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
utilities, Commission Staff, and other interested partes partner with CAP AI to
identify ways in which to further leverage existing federal LIHEAP funding.
RMP will support efforts to educate and work with Idaho representatives to raise
awareness of LIHEAP benefits. The Company believes the increase in LIHEAP fuding
for the 2008/2009 heating season is a positive step in obtaing recogntion by the
congressional delegation of the importce of the LIHEAP program. RM would
propose a change in state policy that would allow income eligible residents to determine
which energy bil they would like their LIHEAP fuds be applied to and/or allow
LIHAP assistace be divided with a percentage going to more than one energy provider.
The Idaho congressional delegation may want to paricipate in the 2009
Washington Action Day for LIHEAP in Washington D.C. On Februar 11,2009, the
National Fuel Funds Network (NFFN) will hold its seventh anua Washington Action
REPLY COMMENTS OF
ROCKY MOUNTAI POWER
- 5 -DECEMBER 19,2008
Day for LIHEAP where NFFN members will trvel to the Capital to lobby Senators and
Representatives for increased LIHEAP fuding.
4. Staff recommends that additional funding for weatheriation and
energy conservation education programs be addressed in future rate cases. Staff
recommends that utiities develop energy conservation education programs targeted
to low-income customers. Staff further recommends that utities examine their
incentive programs regarding higher efficiency appliances, including consideration
of no interest!low interest loans for customers to purchase higher effciency
appliances and encourage the Northwest Energ Effciency Allance to include
multi-family and manufactured homes in the Energy Star Home Program.
RMP believes that weatherization programs are the most direct way to reduce
energy costs for low-income customers.
RM provides $150,000 anually to fud the Low-Income Weatherization
Program though Schedule 21. Until recently agency sta has not requested rebates up to
the anual maximum of $150,000. If this fuding amount is not sufcient to cover their
anua expenses related to weatherization sèrvices they provide RM customers, the
Company would be open to discussing a fuding increase for the agencies along with
effectiveness criteria for an energy education component.
RMP offers incentives for appliances through the Home Energy Savings program
in Idao (and other states) and regularly reviews incentive levels for all measures,
including appliances. To increase paricipation, RM provided information regarding the
Idaho Offce of Energy Resources low interest loans to contractors active in the Home
Energy Savings program. To fuher increase paricipation in all energy effciency
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 6-DECEMBER 19,2008
programs, RMP requested proposals for financing in the Company's Demand Side
Management Request for Proposals released on November 26, 2008.
In addition to being an Energy Sta parer, RM paricipates in the Nortwest
Energy Effciency Allance residential sector meetings. RMP will forward staff
recommendations regarding Energy Sta ratings for multi-family and manufactued
homes to our representative.
5. Staff encourages utilties to actively advocate for adoption and
implementation of energy effcient constrction standards, including provisions for
single family rental, multi-family, and manufactured homes.
RM agrees with Stas recommendation. RMP's existing Nortwest Energy
Effciency Alliance fudig supports energy code work including education and traing
for building professionals and offcials on existing codes as well as paricipation in the
state code adoption processes across the region, including Idaho. RM supports the
Consortium for Energy Effciency (CEE) which helps shape and move the national
stadads market. Whle CEE does not develop constrction stadads per se, an
importt par of improvig energy utilization is the improved efficiency of components
within a house.
Finally, at a more local level, RMP energy efficiency programs support the code
improvement process by providing incentives for above code measures and practices
which serves to increase their penetration which in tu lowers costs and reduces other
barers. As par of the interaction between energy efficiency programs and the code
cycle, measures move from the program into the codes. This has been the case with
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 7 -DECEMBER 19,2008
higher performance widows, heating equipment effciencies and duct leakage
requiements.
6. Staff recommends that utilties and the Commission consider tiered
rates for residential customers within the context of future rate cases.
RM is concerned that tiered rates could have unexpected consequences and may
or may not benefit low-income customers. A tiered rate design without the ability to
inform customers on a real time basis of their usage may not send any more of a price
signal than flat rates. RM offers a residential time-of-use rate in Idaho which gives
customers the ability to save on monthy bils if they move usage to off-peak times.
7. Staff recommends that utilities offer more flexibilty in negotiating
payment arrangements. Staff further recommends that Staff and utilities further
investigate payment arrangement alternatives.
RM offers flexible payment arangements to customers that contat us. Ths
includes a plan allowing customers tht default on a payment argement to "catch-up"
the missed installments and then complete the remainder of the arangement. The
Company does not support allowing arearages to increase beyond curent levels due to
the increased diffculty customers might experience in ultimately becomig curent with
their bils. RMP would be interested in paricipating in fuher investigation and
discussion of the benefit and risks of alternatives to existing payment arangements.
At page 22 of Staff s Comments, Sta recommends a Percentage of Income
Payment Plan not be pursued due to signficant obstacles such a program would present.
RM supports Staffs recommendation for the same reasons stated by Staf.
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 8 -DECEMBER 19, 2008
8. Staff recommends more investigation and discussion among all
interested parties regarding how convenience fees can be eliminated or reduced.
RM is interested in working with Staff and interested paries on fuer
investigation and discussion of convenience fees. However, the Company believes
lowerig or eliminating convenience fees assessed to low-income customers would likely
be considered discriminatory and would require legislation to be enacted.
9. Staff recommends more investigation and discussion among all
interested parties regarding the circumstances, if any, under which reconnection
and interest charges could be eliinated.
RMP acknowledges the Staffs recommendation to fuher investigate and discuss
circumstaces in which reconnection and interest charges could be elimated. The
Company believes that legislation would be necessar to reduce or elimate these
charges for low-income customers and is concerned that the elimiation of these charges
would increase the burden on customers with good payment history, and remove an
incentive for makng consistent payments on their electrc bil.
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 utilities conduct a study of the effectiveness of
collectig residential deposits.
RM is interested in paricipating in fuer discussion related to alternatives to
existing deposit policies.
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 9-DECEMBER 19,2008
11. Staff recommends that utilties adopt new policies whereby lower risk
applicants be permitted to payoff old bils in installments while receiving new
service.
RMP's curent policy for all customers is to obta one-half of the outstading
amount upfront and one-half withi 30 days, and we are willing to work with these
customers to make payment arangements. RMP does not consider any customer with an
old bil to be lower risk and treats all of these customers unformly. The Company is
concerned that changing ths policy could result in an increase in wrte-offs.
12. Staff recommends that all energ utilities develop arrearage
forgiveness plans.
RMP does not support ths recommendation. RMP believes ths would also
requie legislation to be enacted. There have been such programs intiated by other
utilties that were deemed to be unsuccessfu and termted.
For example, in 2007 Portland General Electrc (PGE), an electric utilty in
Portland, Oregon conducted a pilot arearage program. The program was open to the first
600 residential customers who were eligible for energy assistace and had either a past
due balance of $1 00 or greater or at least $100 on a Time Payment agreement. The goals
of the program were to help low-income customers reduce their past due balances and
provide them with energy education. Only 290 customers were enrolled in the program
even though they worked dilgently to obta more paricipants. Arearages would be
forgiven on accounts where customers paid their curent bils on time for 12 months.
Results indicated that only 39 customers (13.5 percent) completed the program. The
main reason for removal from the program (89 percent) was paricipant's receiving a 15
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 10-DECEMBER 19,2008
day notice. PGE waived a tota of $6,707 (an average of $ 172/customer) in arearges
from the accounts of the 39 customers that completed the pilot. The cost to administer
the progr was over $40,000 and the program proved to be far more labor intensive and
costly than PGE anticipated as they estimated the program would cost $25,000.
13. Staff recommends that all utities implement case management
programs if they have not already done so.
RM does not endorse Stas recommendation for all utilities to have a formal
case management progr. Whle RM does not have a specific designation of a "case
mangement" program, the Company believes it has a process in place to work with
individual customers on a case-by-case basis. Our contact center agents have the trainig
and resources available to discuss payment options, energy assistace, energy
weatherization, energy efficiency inormation and energy saving tips. In addition, subject
matter experts are available to the agents to refer to for fuher assistace and an
escalation process is in place for assistace with critical situations.
Respectfully submitted this 19th day of December 2008.
D!l~~/u;
Senior Attorney
Rocky Mountain Power
REPLY COMMENTS OF
ROCKY MOUNTAI POWER
- 11 -DECEMBER 19, 2008
CERTIFICATE OF SERVICE
I hereby certify that on this 19th day of December, 2008, I caused to be served, via U.S.
mail, a true and correct copy of the foregoing Rocky Mountain Power's Reply Comments
in Case No. GNR-U-08-1 to the following:
BETSY BRIDGE
ENERGY EFFICIENCY ASSOC
ID CONSERVATION LEAGUE
POBOX 844
BOISE ID 83701
MICHAEL P McGRATH
INTERMOUNTAIN GAS CO
POBOX 7608
BOISE ID 83707-1608
TERR SHOEN
INTERMOUNTAIN GAS CO
POBOX 7608
BOISE ID 83707-1608
MIKE KINGERY
INTERMOUNTAIN GAS CO
POBOX 7608
BOISE ID 83707-1608
MAGGIE BRILZ
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707.0070
LISA NORDSTROM
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707.0070
RICK GALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
LINDA GERVAIS
A VISTA UTILITIES
POBOX 3727
SPOKANE W A 99220
BRUCE FOLSOM
A VISTA UTILITIES
POBOX 3727
SPOKANE W A 99220
TED WESTON
ROCKY MOUNTAIN POWER
201 S MAIN STE 2300
SALT LAKE CITY UT 841 1 1
BARBARA COUGHLIN
PACIFICORP
825 NE MUL TNOMAH
STE 800
PORTLAND OR 97232
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
MARY CHANT EXE DIR
COMMUITY ACTION
PARTNERSHIP ASSOC OF ID
5400 W FRANKLIN RD STE G
BOISE ID 83705
ROWENA PINEDA EXE DIR
ID COMMUNITY ACTION
NETWORK
3450 HILLRD
BOISE ID 83703
CARRE TRACY
NW FEDERATION OF COMMUN
ORGANIZA TIONS
1265 S MAIN ST #305
SEATTLE WA 98144
JIM WORDELMAN
AARPIDAHO
3080 E GENTRY WAY
STE 100
MERIDIAN ID 83642
DEDE SHELTON
AARPIDAHO
3080 E GENTRY WAY
STE 100
MERIDIAN ID 83642
LYN YOUNG
2786 S DENALI PLACE
MERIDIAN ID 83642
JULIA CAMPBELL
SOUTHEASTERN IDAHO COMMUNITY
ACTION AGENCY
641 N 8TH
POCATELLO ID 83201
KEN ROBINETTE EXE DIR
SOUTH CENTRAL
COMMUNITY ACTION PARTNER
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EXECUTIVE DIRECTOR
C.C.O.A. WEA THERIZA TION
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ROB CHRISTENSEN EXE DIR
WESTERN IDAHO COMMUNITY
ACTION PROGRAM
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DICK HENRY
EXECUTIVE DIRECTOR
EL-ADAINC
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SENA TOR NICOLE LeF A VOUR
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GOODING ID 83330
DEBRA HEMMERT EXE DIR
SOUTHEASTERN IDAHO
COMMUNITY ACTION AGENCY
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POCA TELLO ID 83201
RONCORTA
C.C.O.A. WEA THERIZA TION
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RUSS SPAIN EXE DIR
EASTERN IDAHO COMMUITY
ACTION PARTNERSHIP
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LISA STODDARD EXE DIR
COMMUNITY ACTION
PARTNERSHIP
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GENIE SUE W APPNER
ID DEPT OF HEALTH & WELFARE
450 W. State St. 2nd FIr.
P.O. Box 83720
Boise, ID 83720-0036
REP. WILLIAM KILLEN
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REP. ANNE PASLEY-STUART
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TERI OTTENS
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(,
Carre Meyer
Coordinator, Administrativ