20020415IPC Nos. 1-16 to Staff.pdf

LARRY D.RIPLEY ISB #965IdahoPowerCompany
P.O.Box 70
Boise,Idaho 83707Telephone:[phone]
FAX Telephone:[phone]
Attorney for Idaho Power Company
Street Address for Express Mail:
1221 West ldaho Street
Boise,Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF IDAHO POWER COMPANY FOR AN )CASE NO.IPC-E-02-02ENERGYCOSTFINANCINGORDERAND)IPC-E-02-03AUTHORITYTOINSTITUTEANENERGY)COSTBONDCHARGE.)
)IDAHO POWER COMPANY'S
)RESPONSE TO FIRSTINTHEMATTEROFTHEAPPLICATION)PRODUCTIONREQUESTOFIDAHOPOWERCOMPANYFOR)AND SECOND PRODUCTIONAUTHORITYTOIMPLEMENTAPOWER)REQUEST OF COMMISSIONCOSTADJUSTMENT(PCA)RATEFOR )STAFFELECTRICSERVICEFROMMAY16,2002 )THROUGH MAY 15,2003.)
COMES NOW,Idaho Power Company ("Idaho Power"or "the Company"),
and in response to the First Production Request of the Commission Staff dated April 5,
2002,and the Second Production Request of the Commission Staff dated April 10,2002,
herewith submits the following information:
IDAHO POWER COMPANY'SRESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 1
REQUEST NO.1:Please provide the number of 7-day disconnect notices
mailed to Idaho Power customers,per month,for the period of November 01,2000
through March 31,2001.
Response to RequestNo.1:The number of 7-day notices mailed to
Idaho Customers for the period November 24,2000 through March 31,2001 was
40,323.
December,2000 8,804
January,2001 19,521
February,2001 4,368
March,2001 7,630
The requested information does not directly relate to the testimonyof any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.2:Please provide the number of 24-hour notices mailed
to ldaho Power customers,per month,for the period of November 01,2000 through
March 31,2001.
Response to RequestNo.2:The number of 24-hour Notices mailed to
Idaho Customers for the period November 24,2000 through March 31,2001 was
35,467.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 2
December,2000 7,943
January,2001 17,261
February,2001 3,675
March,2001 6,588
The requested information does not directly relate to the testimonyof any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of RegulatoryAffairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.3:Please provide the number of actual field disconnects,
per month,for the period of November 01,2000 through March 31,2001.
Response to Request No.3:The number of field disconnects authorized
for the period November 24,2000 through March 31,2001 was 2,328.
December,2000 55
January,2001 361
February,2001 411
March,2001 1,501
The requested information does not directly relate to the testimonyof any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
AND SECOND PRODUCTION REQUEST OF COMMISSION STAFF,Page 3
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.4:Please provide the number of Idaho Power customers
receiving Low-Income Home Energy Assistance Program (LlHEAP)Funds,and the total
dollar amount received for calendar years 2000 and 2001.
Response to Request No.4:In 2000,there were 7,065 customers who
received an estimated $1,362,735,and in 2001 there were 9,012 customers who
received an estimated $1,983,704.
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of RegulatoryAffairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.5:Please provide the number of Idaho Power customers
receiving Project Share Funds,and the total dollar amount received for calendar years
2000 and 2001.
Response to Request No.5:
2000 2001PROJECTSHARE
Idaho Power Customer/Families 920 1,348AssistedbyProjectShare*
Project Share Funds Allocated to $138,050.08 $202,201.50IdahoPowerCustomers
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 4
*The number of families assisted was estimated,assuming that each familyreceived$150,the maximum annual Project Share gift.
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.6:Please provide the number of Idaho Power customers
on Budget Pay as of April 2001 and as of April 2002.
Response to Request No.6:The number of Budget Pay Customers as
of April 2001 was 40,563.The number of Budget Pay Customers as of April 2002 was
43,218.
The requested information does not directly relate to the testimonyof any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 5
REQUEST NO.7:Please provide the number of energy audits performed
for Idaho Power customers for each of the calendar years 2000,2001 and January-
March 2002.
Response to Request No.7:
January -March 2002 258 energy audits
January -December 2001 1,118 energy auditsJanuary-December 2000 1,100 energy audits
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of RegulatoryAffairs,and Larry D.
Ripley,Senior Attorney,ldaho Power Company.
REQUEST NO.8:Please provide the dollar amount contributed by Idaho
Power to Project Share for the calendar years 2000 and 2001.
Response to Request No.8:
PROJECT SHARE 2000 2001
Idaho Power Customer Contribution $159,729.81 $142,998.26IDACORPShareholderContribution25,000.00 125,000.00ldahoPowerCompanyAdministrationContribution15,972.98 14,299.83
Total Contributions $200,702.79 $282,298.02
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 6
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.9:Please provide the number of weatherizationjobs
performed for calendar year 2001 and the total associated cost.
Response to RequestNo.9:The 2001 weatherization jobs (LlWA Jobs)
was as follows:
Idaho 266
Oregon 21
Total 287
See also the Response to RequestNo.10.
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.10:Please provide the dollar amount contributed by
Idaho Power to the Low-income Weatherization Program for calendar year 2001.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 7
Response to Request No.10:the 2001 LlWA contribution was:
Idaho $331,125.58Oregon23,677.99Total$354,803.57
The Company contributed an additional $118,592 to the Low-Income
Weatherization program in 2001.
The requested information does not directly relate to the testimonyof any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,pleaseadvise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of RegulatoryAffairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.11:Please provide the dollar amount contributed by
Idaho Power to Northwest Energy Efficiency Alliance (NEEA)for calendar year 2001.
Response to Request No.11:In 2001,Idaho Power contributed
$1,246,818.18 to the Northwest Energy Efficiency Alliance.
The requested information does not directly relate to the testimonyof any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 8
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUESTNO.12:Please provide the dollar amount spent on the
ConservationAdvertising Campaign for calendar year 2001 and provide details of how
funds were allocated.
Responseto Request No.12:
2001 Energy Conservation Advertising
Activity:Description:Cost:
Newspaper Ads Weekly "advertorials"in five service area production in-house =n/apapers;27 weeks 3/28-9/30/01 media buy =$65,835
Radio and TV Ads Radio and network television air time production =$179,652throughoutserviceareaMarch--July and media buy =$252,238October2001;produced five ads subtotal =431,890
Outdoor Billboards Boise,Twin Falls and Pocatello areas May -production =$8,400July2001mediabuy=$15,251
subtotal =$23,651
Printed Energy Planner brochure (20,000 qty)production =$8,000Publicationsenergyuseinformation,conservation tips,print cost =$4,615glossary,etc.subtotal =$12,615
Energy Cost Calculator slider (20,000)production in-house =n/aelectriccostestimatesofapplianceslequip.print cost =$20,732
"10 Ways to Conserve 10%"booklet (5,000)production in-house =n/abusiness-orientedconservation info print cost =$5,000
Various Energy Papers (7,000)production in-house =n/aenergycrisisrecap,company information,print cost =$7,530PUCdescription,conservation info
TOTAL =$567,253
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 9
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of RegulatoryAffairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.13:Please provide the total number of Energy Packets
mailed to customers to date and the total associated cost.Was the cost included as
part of the Ad Campaign or Weatherization cost?
Response to Request No.13:The CFL bulb packet effort mailed 7,608
packets that included a CFL bulb to low income customers in December 2001.In
January 2002 Idaho Power advertised in a bill stuffer an offer to provide a CFL packet
for those customers using 2000 kWh or more in a month.The Company sent out 1,900
CFL bulb packets in response to the bill stuffer invitation.Total CFL bulb packets sent
out were 9,508.Idaho Power is continuing to distribute the remaining 2,500 packets.
To date,the total charges to the work order amount to $90,416.07.The cost of the CFL
packet effort was not included as part of the Ad campaign or weatherization cost,but
was funded through the BPA C&RD.
In addition,when customers call the Company's call center and ask for
additional information about ways to reduce their electricity bill,the Company mails
packets to those requesting it.As of April 15,2002,2,952 packets have been sent at a
cost of $7,500.These costs have been charged to the operating expenses of the
Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 10
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.14:Please provide the number of heating degree-days
between November and March for the winter heating seasons of 2000-01 and 2001-02.
Please report numbers for Boise,Twin Falls,and Pocatello areas.
Response to Request No.14:
Calendar Month Heating DegreeDays
Boise Pocatello Twin Falls
November 2000 960 1,170 1,073December20001,044 1,239 1,108January20011,165 1,475 1,237February20018671,162 957March20015858156944,621 5,861 5,069
November 2001 626 817 694December20011,056 1,338 1,181January20021,034 1,304 1,170February20028631,294 1,099March20027479968754,326 5,749 5,019
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 11
Mr.Gale is generallyfamiliar with the information requested,but if detailed information
is required,pleaseadvise Idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.15:Please provide the number of Idaho Power
customers'bills that were estimated during each of the calendar years 2000 and 2001.
Estimated means showingas estimated on customer's bills using the billing codes "F",
"L",and "Y".
Response to RequestNo.15:The number of estimated bills in 2000
was 17,100.The number of estimated bills in 2001 was 31,137.
The Company would caution that the two numbers are not comparable.
Underthe old CIS system,the Companyover the years had reached accommodations
with seasonal and irrigation customers that the meters would not be read due to their
remote location and low energy consumption.When the new CIS system was
implemented,the old CIS accommodation procedures were lost as far as
documentation of these accommodations was concerned,and the new CIS system
recorded these accounts as being estimated.
The requested information does not directly relate to the testimonyof any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generallyfamiliar with the information requested,but if detailed information
is required,pleaseadvise Idaho Power Company in advance and an appropriate
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 12
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUESTNO.16:Please explainhow Idaho Power increased its efforts
to aggressivelypursue delinquentaccounts in 2002 versus 2001.How many additional
employeeswere hired to pursue collection of delinquentaccounts?What factors are
considered currently in deciding which delinquentaccounts to pursue?
Response to RequestNo.16:The Company does not believe that it
pursued any extraordinary or aggressive measures in 2002 concerning delinquent
accounts.During the implementationof the CIS system in early 2001,there was a
reduction in the level of normal efforts concerning the collection of delinquentaccounts
due to work associated with the new CIS.During the year 2001 and the 2002 heating
season,there was an increase in past due accounts and an increase in customers
declaring for the moratorium.(See Response to RequestNo.17)The Companydid
increase its field collection staff by six employees beyond the normal "seasonal"staffing
increase to respond to the additional work load associated with collection activities.The
factors that the Companyconsiders in pursuing delinquentaccounts is proprietaryand
confidential information,and the Company will discuss these factors directly with Staff.
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,pleaseadvise Idaho Power Company in advance and an appropriate
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 13
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of Regulatory Affairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
REQUEST NO.17:Please provide the number of customers who
declared eligibility for protection from disconnection during the 2000-2001 and the 2001-
2002 heating seasons.
Response to Request No.17:
2000/2001 3,535
2001/2002 7,872
The requested information does not directly relate to the testimony of any
witness that the Company is sponsoring in docket numbers IPC-E-02-2 and IPC-E-02-3.
Mr.Gale is generally familiar with the information requested,but if detailed information
is required,please advise idaho Power Company in advance and an appropriate
witness or witnesses will be made available.The responses to the request for
information were obtained from various individuals within the Company under the
general guidance of John R.Gale,Vice President of RegulatoryAffairs,and Larry D.
Ripley,Senior Attorney,Idaho Power Company.
Dated at Boise,Idaho,this 15th day of April,2002.
LARRY DMIPLEY *
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFF,Page 14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th day of April,2002,I served a trueandcorrectcopyoftheaboveandforegoingIDAHOPOWERCOMPANY'SRESPONSETOFIRSTPRODUCTIONREQUESTANDSECONDPRODUCTIONREQUESTOFCOMMISSIONSTAFFuponthefollowingnamedpartiesbythemethodindicatedbelow,and addressed to the following:
Lisa D.Nordstrom _x_Hand DeliveredDeputyAttorneyGeneralU.S.MailIdahoPublicUtilitiesCommissionOvernight Mail472W.Washington Street FAXP.O.Box 83720
Boise,Idaho 83720-0074
R.Scott Pasley Hand DeliveredAssistantGeneralCounselxU.S.MailJ.R.SimplotCompany OvernightMail999MainStreetFAXP.O.Box 27
Boise,Idaho 83702
Peter J.Richardson Hand DeliveredRichardson&O'Leary,PLLC U.S.Mail99EastStateStreet,Suite 200 OvernightMailP.O.Box 1849 FAXEagle,Idaho 83616
William M.Eddie Hand DeliveredLandandWaterFundoftheRockiesU.S.MailP.O.Box 1612 OvernightMailBoise,Idaho 83701 FAX
LÆRY D.RIPLEÝ
CERTIFICATEOF SERVICE