20081219Comments.pdf

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Dec. 19,2008 RECEIVEn
TO: Jean Jewell
Idaho Public Utilties Commission Secreta
472 West Washington
Boise,ID 83702
zuoe DEC' 9 PM i.: 53
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FROM: Ken Miler
Snake River Allance
Box 1731
Boise,ID 83701
Ph: [phone]
RE DOCKET GNR-U-08-01: IDAHO PUBLIC UTILITIES COMMISSION'S ENERGY
AFFORDABILITY CASE
COMMENTS FROM THE SNAKE RIVER ALLIANCE
DearMs. Jewell:
Please accept the following comments on behalf of the Snake River Allance relative to the
Commission's docket, GNR-U-8-01.
The Snake River Allance is an Idaho-based non-profit organization established in 1979 to
address Idahoans' concerns about nuclear safety issues. In early 2007, the Alliance expanded the
scope of its mission by launching its Clean Energy Program. The Allance's energy initiative
includes advocacy for renewable energy resources in Idaho; expanded conservation and demand-
side management programs offered by Idaho utilities and the Bonnevile Power Administration;
and local, state, regional, and national policies and initiatives that promote sustainable and
affordable energy policies. The Allance is pursuing these programs on behalf of its members,
many of whom are customers of Idaho's regulated utilties, who are interested in promoting
clean and affordable energy initiatives.
The Allance appreciates the efforts by the Commission, its staf, and stakeholders to date in
addressing the significant consequences of rising utility rates and their impacts on low-income
utilty customers - and for that matter all of Idaho's electricity and gas ratepayers. The timing of
this docket is criticaL. As the Commission is aware, the National Association of Regulatory
Utility Commissioners (NARUC) reported just this week on the alarng trends rising utility
rates are having on ratepayers, particularly those with lower incomes. In Idaho, 19.4 percent of
electric utilty residential accounts were past-due as of May 1,2008, and the average arearage
was $81.75.The percentage of natural gas residential accounts listed as past-due in Idaho was
12.4 percent. Clearly, the sequence of recent rate hikes and power cost adjustments continue to
take a toll on those Idahoans for whom utility expenses occupy a greater proportion of their
household budgets. Moreover, the Commission heard compellng public testimony on Dec. 10 in
Idaho Power's pending rate case in which witnesses told Commissioners that fuher increases in
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their electric bils wil place them and their families in jeopardy as they struggle to balance their
food, medical, transportation, and other needs against rising utility costs.
The Allance commends Commission staf for accurately defining the problem at hand. We are
concerned, however, that some solutions advanced by staff do not reflect the urgency demanded
by the magnitude of the challenges presented to the Commission and Idaho's utilities. We agree
with the 2007 Idaho Energy Plan's conclusions that clean and affordable energy must be a
priority for all Idahoans, and we believe this issue demands a combination of immediate and
effective solutions.
ALLIANCE RECOMMENDATIONS
The Allance offers the following recommendations for the Commission's consideration:
. We believe the Commission and Idaho's regulated utilities should consider addressing
this issue in par through rate designs that allow lower-income energy consumers to
benefit from a tiered rate strctue that sends strong price signals to all consumers.
Specifically, a year-round tiered rate strcture would provide lowest-cost rates to
consumers using less energy than those using more. We understad this issue may be
addressed in par in the pending Idaho Power rate case, but we urge the Commission to
take a broader examination of how rate design can be used to encourage energy
effciency and conservation, and also to reduce consumers' utilty costs.
. The Alliance also believes Idaho law must be changed to allow for within-class rate
discrimination, i.e., allowing utilities to request to the PUC that they be allowed to offer
lower residential rates to lower-income consumers than those paid by the overall class.
This wil require a change in statute, and we understand neither staff nor Idaho's
regulated utilities support such a change, but believe it can be a vital tool in addressing
rate challenges for low-income ratepayers. We encourage the Commission to embrace a
proposal by low-income advocates to change existing statute to allow for lower
("lifeline") rates, which as the Commission is aware are used successfully in many other
jursdictions, including some served by Idaho's regulated utilities. The Community
Action Parerships of Idaho are well positioned to work with the Commission and the
utilties to develop appropriate languge for such legislation, and we urge the
Commission and staff to continue to work with the CAPs and the utilities to negotiate
language that is satisfactory and present it to the Idaho Legislature in the coming 2009
session.
. The Allance is also concerned that existing fuds in the Low Income Home Energy
Assistace Program (LIHEAP) are insuffcient to meet the growing demand for energy
assistance funds. Staff correctly points out the chronic deficiency in LIHEAP fuds to
meet demand, noting that "Curently, only 10 percent of homes receiving LIHEAP
benefits are weatherized because of the lack of available fuds." We believe the curent
workshop process in GNR-U-08-1 should continue with a goal to identify sources of
additional LIHEAP resources. We appreciate that Idao like all states faces economic
challenges, but we also believe that ensuring all Idahoans have access to reliable and
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affordable electricity and natual gas is a fudamental responsibility of the state and that
the PUC should make that case before the Idaho Legislatue regardless of the state's
obvious financial challenges. Furhermore, as staff observes, A vista already paricipates
in the Low-Income Rate Assistance Program (LIRA) to provide bil-pay assistace. The
Allance agrees with staff that a LIRAP program would require state legislation, and we
encourage the PUC to raise the issue with the Legislature.
. With regard to energy efficiency and conservation, the Allance appreciates the
signficant progress made by Idaho utilities in expanding their demand-side management
programs and initiating new ones in all rate classes. However, weatherization and other
DSM programs targeted at the residential class must be enhanced and further fuding
(through increased energy efficiency tarff riders) must be provided to do so. Idaho's
Community Action Partnership agencies have performed admirably in weatherizing as
many qualified homes as possible with existing fuds, but it is clear those funds are
inadequate for the task at hand. The state of Idaho and its regulated utilties must commit j
to weatherizing all qualified homes. Doing so wil not only provide relief in energy costs
for customers, but will also benefit all ratepayers by reducing average energy as well as
capacity demands.
. The Allance agrees with low-income advocates that disconnects and reconnects, which
are paricularly problematic for low-income customers, must be avoided as much as
possible and policies must be implemented to do so. It has been established that the costs
associated with disconnects and reconnects are not only a financial burden to affected
customers, but are also borne by all ratepayers. We agree with the unanmous views
expressed during the workshops that disconnects can be minimized by existing utilty-
supported measures, such as averaging bils over the course of a year and the moratorium
on winter disconnects, but we also believe a combination of bil-pay assistance, rate
reduction as mentioned above, more flexibility in paying off arearages (as recommended
by the Idaho Communty Action Network and others), and the elimination of
reconnection fees wil greatly reduce the burdens facing many ofIdaho's low-income
utility consumers.
In sumar, the Allance again appreciates the Commission and staff s attention and dedication
to solving this difficult issue, as well as the creativity and openness on the par of our regulated
utilities. We urge the Commission to keep the workshop process open into 2009, as we believe
there remain a number of issues '- and solutions - that can be explored by the impressive
assembly of stakeholders that has taen par in the process to date.
Respectfully submitted,£:~
Ken Miler
Clean Energy Program Director
Snake River Allance