20240703Staff 34-54 to PAC.pdf

RECEIVED
Wednesday, July 3, 2024 3:33:47 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR ) CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES IN IDAHO AND APPROVAL ) SECOND PRODUCTION
OF PROPOSED ELECTRIC SERVICE ) REQUEST OF THE
SCHEDULES AND REGULATIONS ) COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that PacifiCorp d/b/a Rocky Mountain Power
("Rocky Mountain Power" or the "Company")provide the following documents and information
as soon as possible,but no later than WEDNESDAY,JULY 24, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 3, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 34: Please identify how many Customer Service Representatives
("CSR's") are employed by the Company.
REQUEST NO. 35: Please list how many CSR's work in the Customer Service Call
Center(s) and how many work remotely.
REQUEST NO. 36: Please list the operating hours of the Customer Service Call
Center(s).
REQUEST NO. 37: Please list the locations of the Customer Service Call Center(s).
REQUEST NO. 38: Please describe the initial (top tier menu) self-help options that are
available to customers using the Company's Interactive Voice Response system. Please provide
the utilization rate for each available option for the past three years and YTD 2024.
REQUEST NO. 39: Please describe the self-help options that are available to customers
using the Company's website. Please provide the utilization rate for each available option for the
past three years and YTD 2024. What percentage of Idaho customers have established an online
account?
REQUEST NO. 40: Please provide the service level for the Customer Service Call
Center(s)by month for each of the past three years and YTD 2024. "Service Level" is the
percentage of calls answered within a certain number of seconds, e.g., 80% of calls answered
within 60 seconds.
REQUEST NO. 41: Please provide the number of incoming calls handled by the
Customer Service Call Center(s)by month for each of the past three years and YTD 2024.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 3, 2024

REQUEST NO. 42: Please provide the number of abandoned calls to the Customer
Service Call Center(s)by month for each of the past three years and YTD 2024. "Abandoned
calls" are calls that reach the Company's incoming telephone system, but the calling party
terminates the call before speaking with a customer service representative.
REQUEST NO. 43: Please provide the average speed of answer for the Customer
Service Call Center(s)by month for each of the past three years and YTD 2024. "Average speed
of answer" is the interval (typically measured in seconds)between when a call reaches the
Company's incoming telephone system and when the call is picked up by a customer service
representative.
REQUEST NO. 44: Please provide the average handling time for the Customer Service
Call Center(s)by month for each of the past three years and YTD 2024. "Average handling
time" is the average amount of time (usually expressed in minutes) it takes for a customer service
representative to talk with a customer plus and additional "off-line"time it takes to complete the
transaction or fully resolve the customer's issue(s).
REQUEST NO. 45: Please provide the first call resolution rate for the Customer
Service Center(s)by month for each of the past three years and YTD 2024. "First call resolution
rate" is the percentage of calls where the transaction, inquiry, or complaint is resolved upon
initial contact with the Company.
REQUEST NO. 46: Please provide the average response time for email transactions for
the Customer Service Call Center(s)by month for each of the past three years and YTD 2024.
"Average response time" is the average number of hours from receipt of an e-mail by the
Company to sending a substantive response; auto-response acknowledgements do not count as a
substantive response.
REQUEST NO. 47: Please provide the Company's primary performance objective(s)
for handling incoming calls.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 3, 2024

REQUEST NO. 48: What steps does the Company take if it fails to meet its
performance objective(s)?
REQUEST NO. 49: Please explain the efforts put forth by the Company to promote
Lend-A-Hand.
REQUEST NO. 50: Please provide the types of advertising (radio, tv, bill insert,
welcome kit, etc.) conducted in Idaho to inform and educate customers about the following:
a. Energy assistance and bill payment options; and
b. Winter Moratorium and the Winter Payment Plan.
In addition,please provide copies of any written brochures or documents sent or otherwise
provided to customers for each defined category listed in this question.
REQUEST NO. 51: Please describe in detail the type of standard payment
plans/arrangements the Company offers its customers.
REQUEST NO. 52: Did the Company make permanent its two alternative payment
plan/arrangements offered(6-month and 12-month) to its customers during COVID-19? Please
explain the answer.
REQUEST NO. 53: For each of the past three winters (2021-2022, 2022-2023, and
2023-2024), how many participants were under Winter Moratorium each year? Of that amount,
how many participants agreed to be placed on the Winter Payment Plan and how many were
unable to meet their monthly payment?
REQUEST NO. 54: Meredith Direct on page 10 proposes to limit the base rate increase
for all classes to be at or below 27%. Please explain and provide documentation showing how
the Company determined the cap of 27%, and how the Company determined the allocation of
base revenue increases exceeding the 27% cap among the classes that did not meet the cap.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 3, 2024

DATED at Boise, Idaho, this 3rd day of July 2024.
Adam Triplett
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#2.docx
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 3, 2024

? CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF JULY 2024, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-04, BY E-
MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL: mark.alder&pacificorp.com PORTLAND OR 97232
E-MAIL: joseph.dallas&acificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@,pacificop2.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance@ae isg insi t.com
E-MAIL: eloaechohawk.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: [e-mail] [e-mail] E-MAIL:
[e-mail]
THOMAS J BUDGE BRIAN C COLILINS
RACINE OLSON PLLP GREG MEYER
PO BOX 1391 BRUBAKER&ASSOCIATES
POCATELLO ID 83204-1391 16690 SWINGLEY RIDGE RD#140
E-MAIL: tina,racineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollinsaconsultbai.com
[e-mail]
Electronic Service Only: RONALD L WILLIAMS
KEVIN HIGGINS BRANDON HELGESON
NEAL TOWNSEND HAWLEY TROXELL ET AL
ENERGY STRATEGIES LLC 877 W MAIN ST
E-MAIL: [e-mail] BOISE ID 83701
[e-mail] E-MAIL: [e-mail]
bhel eg [e-mail]
CERTIFICATE OF SERVICE

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: brmullinsgmwanalytics.com E-MAIL: Val.steiner(agitafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamskgb u
PA RICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE