20051027Comments.pdf

IDAHO
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IDAHO POWER COMPANY
PO. BOX 70
BOISE, IDAHO 83707 ~0L U -O4-
An IDACORP Company
October 26, 2005
Monica Moen
Attorneyc" f"
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Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise , Idaho 83720-0074
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Re:Docket No. 31-2101-0402
Proposed Customer Relations Rules
Dear Ms Jewell:
Enclosed herewith for filing with the Commission are the original and seven (7)
copies of Idaho Power Company's Comments regarding the above-described docket.
I would appreciate it if you would return a stamped copy of this transmittal letter
for our files.
Yours very truly,
Monica Moen , Attorney
Idaho Power Company
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Enclosu res
Telephone [phone] Fax [phone] E-mail MMoen(8)idahopower.com
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MONICA MOEN , ISB # 5734
Idaho Power Company
1221 West Idaho Street
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
31.21.01 - CUSTOMER RELATIONS RULES
FOR GAS, ELECTRIC AND WATER PUBLIC
UTILITIES REGULATED BY THE IDAHO
PUBLIC UTILITIES COMMISSION (THE
UTILITY CUSTOMER RELATIONS RULES)
DOCKET NO. 31-2101-0402
IDAHO POWER COMPANY'
COMMENTS
COMES NOW Idaho Power Company ("Company ) and hereby submits the
following comments regarding the Idaho Public Utilities Commission s ("Commission
proposed changes to the Utility Customer Relations Rules , specifically to Rule 305
Rule 306 , Rule 311 and Rule 701.
Rule 305 The Commission s proposed revisions to this rule require gas and
electric utilities to provide an explanation of the restrictions on service termination and
the availability of the Winter Payment Plan with both oral and written termination notices
provided to customers during the months of November, December, January, and
February. The Company supports this rule revision but requests the proposed rule by
modified to specify that the information need be provided to residential customers only.
IDAHO POWER COMPANY'S COMMENTS, Page
The Company recommends the following language for Rule 305.02 (clarifying language
in italics):
02.Additional Requirements for Gas and Electric Utilities.
During the months of November, December, January and February, oral
and written notices provided by gas and electric utilities to residential
customers shall include or be accompanied by an explanation of
restrictions on termination of service and the availability of the Winter
Payment Plan described in Rule 306.
Rule 306.01 and Rule 306.03. In general , the Company supports extending
protection from service termination to residential customers who declare that they are
unable to pay in full for utility service and whose household receives financial
assistance through the Low Income Home Energy Assistance Program (LiHEAP) during
the current program year as proposed by the Commission in revised Rule 306.01 and
306.03. However, the Company believes it would be beneficial to define "the current
program year" to ensure a clear understanding of the rule. Consistent with the
Commission s proposed revision to Rule 305.02 requiring utilities to provide customers
with information on restrictions on service termination and the Winter Payment Plan
during the months of November through February, the Company recommends the
current program year" be defined to coincide with these four months. Accordingly, the
Company proposes a new definition be added to Rule 306.02 as follows:
IDAHO POWER COMPANY'S COMMENTS , Page 2
Current Program Year" means the months of November
December, January and February.
Rule 306.06, Rule 306., and Rule 306.08. The Company supports the
Commission s proposed revisions to Rules 306.06 and 306.07. The Company also
supports the proposed addition of Rule 306.08.
Rule 306.09. The Company does not support the addition of this rule. The
Commission s Rule 005.02.b currently defines a customer as someone who has
received service within the past ten calendar days prior to service termination. The
Company believes that it is important to preserve the clear distinction that currently
exists between a customer and an applicant. The proposed Rule 306.08 provides
adequate protection for continued service for a customer who has declared for
moratorium protection and who moves during the months of December, January, or
February. The Company supports the added protection afforded customers through
Rule 306.08. However, the Company does not believe it is either necessary or prudent
to create a new rule that extends to applicants a guarantee of service , regardless of
any outstanding balance owed , for up to 20 days beyond the expiration of customer
status.
Rule 311. The Company supports the Commission s proposed revisions to Rule
311.01 to specify that service shall not be terminated on any Friday after 12 noon or on
IDAHO POWER COMPANY'S COMMENTS , Page 3
any day immediately preceding any legal holiday and notes that the Company currently
does not terminate service on any day immediately preceding any legal holiday.
Rule 701.The Company supports the proposed revisions to Rule 701 as its
current practices follow the provisions of the proposed rule changes. The Company
would like to note that, although the proposed rule specifies that the Commission will
provide Spanish translations for residential customers, the Company currently makes its
Summaries for all customer classes available in Spanish.
DATED at Boise , Idaho, this 26th day of October 2005.
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MONICA B. MOEN, Attorney for Idaho Power
IDAHO POWER COMPANY'S COMMENTS, Page 4