Loading...
HomeMy WebLinkAbout200311213rd Request of Staff to Idaho Power.pdfLISA NORDSTROM DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 BAR NO. 5733 !~ECEIVED FILED 2n03 NO\! 21 PM 3: 44 ,U . ;; UTILlT!ES COt"jf'lISSION Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS INTERIM AND BASE RATES AND CHARGES FOR ELECTRIC SERVICE. CASE NO. IPC-03- THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Lisa Nordstrom, Deputy Attorney General, requests that Idaho Power Company (Idaho Power; Company) provide the following documents and information on or before FRIDAY, DECEMBER 19, 2003. The Staff requests the Company place special priority on answering Request Nos. 39 40 and 76 as soon as possible. In recognition that some questions require less time to answer than others, Staff asks that the Company file responses in batches as they are completed rather than wait for the most time-intensive questions to be finished. The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name location and phone number of the record holder. Reference IDAPA 31.01.01.228. THIRD PRODUCTION REQUEST TO IDAHO POWER NOVEMBER 21 , 2003 This Production Request is to be considered as continuing, and Idaho Power 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 produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations, and the name and telephone number of the person preparing the documents. Please identify the name, location and telephone number of the record holder. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing if need be. Request No. 32: Please explain why the Company established its call answering goal at 80% of inbound calls within 30 seconds. Request No. 33: For purposes of measuring call performance, how is answering time measured? Define the precise points at which measurement begins and ends. Request No. 34: Please explain why the internal Company goal of answering 80% of inbound calls within 30 seconds was not met in January through July of2002. (Reference Exhibit No. 56, Fullen). Request No. 35: Please explain why the internal Company goal of answering 80% of inbound calls within 30 seconds was not met in January through June and September through December of2001. (Reference Exhibit No. 56, Fullen). Request No. 36: Please explain what measures the Company took to successfully answer at least 80% of its inbound calls within 30 seconds between July of 2002 and August of 2003. Request No. 37: Does the Company intend to take further steps to improve its call answering performance level? If so, please explain what steps the Company intends to take. not, please explain why. Request No. 38: In each of the months of January 2001 through August 2003 , how many calls were answered by the Company s call center representatives? How many calls were not answered or abandoned? (For purposes of this question , " not answered" and "abandoned" calls refer to customers that reach the Interactive Voice Response (IVR J but hang up or are disconnected before reaching a live representative). Request No. 39: Does the Company have call-answering standards for its Repair and Outage Management Center? If so, please provide monthly performance figures for 2002 and year-to-date 2003. If there are no standards, please explain why they do not exist. THIRD PRODUCTION REQUEST TO IDAHO POWER NOVEMBER 21 , 2003 Request No. 40: Please provide studies or other evidence to support Maggie Brilz testimony stating that the increase in the customer charge from $2.51 to $10.00 per month will not be detrimental to low income customers. (Reference page 36, line 18, Direct Testimony). Request No. 41: Company witness Fullen stated in her testimony that Idaho Power gave an additional $100 000 to Project Share during recent high energy cost years. On what date(s) was the additional money given to Project Share? Were there any conditions or restrictions for its use? If so, please explain. Request No. 42: For the years 1999 through 2002 and to date in 2003, please indicate the total dollar amount that Idaho Power s customers contributed to Project Share by paying an additional amount on their monthly bills. For this same time period, what was the total dollar amount contributed by shareholders? For this same time period, what was the total dollar amount contributed by the Company? Request No. 43: Other than Project Share, were any additional shareholder dollars contributed to community-based organizations for the purpose of providing services to or paying bills of low-income Idaho Power customers? Request No. 44: In accordance with Rule No. 403 of the Utility Customer Relations Rules (UCRR), please provide the written records from January 2003 through October 2003 of customer complaints and requests for conferences. Request No. 45: Does Idaho Power employ specially-trained customer service representatives to work with customers who are disabled, under protective orders, have diminished mental capacity, or are otherwise in need of additional assistance? If so, please describe. If not, please explain why Idaho Power does not employ such representatives. Request No. 46: Please provide a sample copy of the Rules Summary required by Rule 701 (UCRR) sent to customers served under Schedules 1 , and 24. How and when are customers given the summary? Request No. 47: Please provide a sample copy of a written denial of service letter and deposit request letter as required by Rule 104 (UCRR). Request No. 48: Please provide a sample copy of the initial receipt for the first deposit installment as required by Rule 109 (UCRR). Provide a copy of the receipt for the second installment, if such receipt is different from the first. Request No. 49: Please provide sample bills that are current and NOT past due for customers served under Rate Schedules 1 , 7, 9, and 24. Request No. 50: Please provide a sample Schedule 1 bill with a past due balance. THIRD PRODUCTION REQUEST TO IDAHO POWER NOVEMBER 21, 2003 Request No. 51: Please provide a sample copy of the written transfer notice, as required by Rule 206 (UCRR), used when transferring amounts between customers when the lapse in service exceeds 60 days. Request No. 52: Please provide a sample copy of the notice left at the customer premises following disconnection of service for non-payment. If customers served under different Rate Schedules receive a different type of notice, include a sample copy of each notice for each of Schedule Nos. 1, 7, 9, and 24. Request No. 53: Please provide a sample copy of the Annual Rate Summary provided to customers as required by Rule 101 , Utility Customer Information Rules (UCIR). Request No. 54: Does Idaho Power make available to customers a pre-printed form for the medical emergency certificate required by Rule 308 (UCRR)? If so, please provide a sample copy of the form. Request No. 55: For Schedule 1 customers who are in jeopardy oflosing service provide a sample copy of the 7 -Day Notice required by Rule 312 (UCRR). Request No. 56: Please provide a sample copy of any brochure or other printed material regarding the Company s Third-Party Notice program. How and when is this material provided to customers? Request No. 57: Please provide a sample copy of any brochure or other printed material regarding the Company s Level Pay Plan. How and when is this material provided to customers? Request No. 58: Please provide a sample copy of any brochure or other printed material regarding the Company s Winter Payment Plan. How and when is this material provided to customers? Request No. 59: How are residential customers made aware of the protection from disconnection (i.e. the winter disconnection Moratorium) that is available to qualifying customers during the months of December through February? Please provide brochures or other printed material explaining to customers how to declare eligibility for protection from disconnection. Request No. 60: Are any ofldaho Power s brochures, notices, forms and/or bills available in Spanish or other languages? If so, please indicate the language(s) and information available. How are customers made aware that there are bills, forms, and brochures available in languages other than English? Request No. 61: How many customer service representatives in the Call Center speak Spanish? Is there always at least one Spanish-speaking representative available during the Call Center s hours of operation? What provisions are made for assisting customers who speak languages other than English or Spanish? THIRD PRODUCTION REQUEST TO IDAHO POWER NOVEMBER 21 , 2003 Request No. 62: How many attempts are made to contact customers either in person or by telephone prior to disconnection as required by Rule 304.02 (UCRR)? Request No. 63: Under what circumstances would a personal visit be made to satisfy the requirements of Rule 304.02 (UCRR)? Request No. 64: Does the Company use an automated system to make outgoing calls to satisfy the requirements of Rule 304.02 (UCRR)? If so, during what hours are calls made to customers? Request No. 65: If the Company uses an automated system and someone answers the phone, are they connected to a live customer service representative or is a pre-recorded message played? If a message is used, please provide the text of that message. Request No. 66: If the Company uses an automated system and an answering machine picks up the call, does the automated system leave a message? If so, please provide the text of that message. Request No. 67: Please describe how the budget pay amount for a Schedule I customer is calculated. Request No. 68: Under what circumstances would a budget pay amount for a Schedule customer be revised prior to the 12-month anniversary of enrollment in such a plan? Request No. 69: What alternative payment planes) are available for a Schedule customer who has an arrearage and wishes to establish a levelized monthly payment? Please describe how the levelized monthly payment would be calculated. Could such an alternative plan be converted to a budget pay plan after 12 months of usage history is established? Could the conversion take place even if an arrearage exists? Request No. 70: Does the Company routinely physically disconnect service after customers request closure of an account or disconnection of service? If so , what are the average and maximum intervals between receipt of the customers' requests and actual disconnection of service? Request No. 71: What percentage of out-of-cycle meter readings are completed within the maximum interval? Request No. 72: If the Company is unable to read meters within the maximum interval please describe how estimated bills are calculated. Are such bills received by the customer identified as being estimated? Request No. 73: If the Company s policy is not to physically disconnect service to a location in between customers, what are the average and maximum intervals before meters are read? Are separate meter readings taken for both customers who are discontinuing service and customers initiating service? Do customers' bills reflect the actual meter reading date(s)? Ifthe THIRD PRODUCTION REQUEST TO IDAHO POWER NOVEMBER 21 2003 Company uses a single meter reading for both customers who are discontinuing service and initiating service, is usage pro-rated to reflect the amount of time each customer was served? Please describe the process used and how such pro-rated bills are calculated. Request No. 74: With respect to landlord-tenant agreements under which service is not disconnected routinely in between tenants, what are the average and maximum intervals before customers' meters are read? Are separate meter readings taken for both customers who are discontinuing service and customers initiating service? Do customers' bills reflect the actual meter reading date(s)? If the Company uses a single meter reading for both customers who are discontinuing service and initiating service, is usage pro-rated to reflect the amount of time each customer was served? Please describe the process used and how such pro-rated bills are calculated. Request No. 75: Please provide a billing comparison (comparing bills under existing rates with the Company proposed rates) in Excel format (for Schedules 1, 7, 9, 19, and 24) similar to Exhibit No. 37 in Idaho Power Case No. IPC-94- Request No. 76: Please provide a bill frequency analysis for Service Schedules 1 and 7 for each month with incremental blocks of 100 kWh for usage from 0 to 1200 kWh; then 1200 to 1500 kWh; 1500 to 2 000 kWh; 2 000 to 2 500 kWh; 2 500 to 3 000 kWh; 3 000 to 4 000 kWh; 000 to 5 000 kWh and over 5 000 kWh. Include both number of bills in the block and energy use in the block. Please provide this in Excel 2000 format. Request No. 77: Please provide a bill frequency analysis for Service Schedule 9. Include both the number of bills in the block and energy use in the block for January, July, October and Annual totals. The usage blocks are from 0 to 1 000 kWh; 1 000 to 2 000 kWh; 000 to 5 000 kWh; 5 000 to 10 000 kWh; 10 000 to 25 000 kWh; 25 000 to 50 000 kWh; and over 50 000 kWh. Please provide this in Excel 2000 format. Request No. 78: Please provide a bill frequency analysis for Service Schedule 19. Include both the number of bills in the block and energy use in the block for January, July, October and Annual totals. The usage blocks are from 0 to 500 000 kWh; 500 000 to 1 000 000 kWh; 1 000 000 to 2 000 000 kWh; 2 000 000 to 5 000 000 kWh; 5 000 000 to 8 000 000 kWh; and over 8 000 000 kWh. Please provide this in Excel 2000 format. Request No. 79: Please provide a bill frequency analysis for Service Schedule 24 for each month April through October and Annual totals. Include both the number of bills in the block and energy use in the block. The usage blocks are from 0 to 1 000 kWh; 1 000 to 5 000 kWh; 5 000 to 10 000 kWhs; 10 000 to 25 000 kWh; 25 000 to 50 000 kWh; 50 000 to 100 000 kWh; 100 000 to 350 000 and over 350 000 kWh. Please provide this in Excel 2000 format. Request No. 80: Please provide a copy of the affiliate/subsidiary report filed with the Oregon PUC for the years 2001-2002. Request No. 81: Please provide the correct depreciation and amortization adjustment based on the Stipulation approved in Order No. 29363. Provide all supporting documentation. THIRD PRODUCTION REQUEST TO IDAHO POWER NOVEMBER 21, 2003 Request No. 82: Please provide a narrative explaining how the Company accounts for its relicensing costs. Include account numbers and ratemaking implications. Request No. 83: Please provide copies of the plan documents for both the Company pension and 40 1 (k) plans. Include copies of the most recent Summary Plan Descriptions, all amendments to the plans and any Summaries of Material Modifications. Request No. 84: Please provide copies of the compliance tests for the 401(k) plan for the years 1999-2003. The tests should illustrate compliance with Sections 401(a)(17), 402(g), 404(a), 415(c) and 416 of the Internal Revenue Code. Please also provide copies of the ADP/ACP Non-discrimination test for the years mentioned. Request No. 85: Please provide an account-by-account analysis comparing the actual account balances at 9/30/2003 to the projected account balances at 9/30/2003 included in the IPC-03-13 filing. Request No. 86: Please provide a schedule of Danskin s performance. Since plant operation began, provide total hours used, percentage of time available for use, total MW s produced, and any other information that would be useful to determine that the plant is a prudent investment and has been prudently operated. i ~day of November 2003.Dated at Boise, Idaho, this Technical Staff: Marilyn Parker Dave Schunke Alden Holm j :umisc/prodreq/ipce03. 1 31nkhrps3 THIRD PRODUCTION REQUEST TO IDAHO POWER NOVEMBER 21, 2003 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF NOVEMBER 2003 SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-03-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: BARTON L KLINE MONICA MOEN IDAHO POWER COMPANY PO BOX 70 BOISE, ID 83707-0070 JOHN R GALE VICE PRESIDENT - REGULATORY AFFAIRS IDAHO POWER COMPANY PO BOX 70 BOISE, ID 83707-0070 .Jo~ARY CERTIFICATE OF SERVICE