200402021st Request of Community Action Partnership to ID Power.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
bmpurdy(g)hotmail. com
Attorney for Petitioner
Community Action Partnership
Association ofldaho and
American Association of
Retired Persons.
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2004 FES - 2 Pr1 4: 42
UTILITiES COf1i'1ISSION
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-O3-
FIRST PRODUCTION
REQUESTS OF COMMU-
NITY ACTION P ARTNER-
SHIP ASSOCIATION OF
IDAHO
COMES NOW, Intervenor Community Action Partnership Association ofldaho
(CAP AI), by and through its attorney of record, Brad M. Purdy, requests that Idaho
Power Company provide the following information and documents in accordance with
the Idaho Public Utilities Commission s Rules of Procedure, and applicable scheduling
orders and notices issued by the Commission in this proceeding.
This production request is to be deemed continuing in nature and Idaho Power is
requested to provide, through supplementation, additional documents or information that
is responsive to this request that it, or any person acting on its behalf, may later come into
possession or become aware of
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
In answering each request, please provide the name of the person(s) preparing the
answers, along with the title and function such individual holds with the Company and
the witness who can sponsor the answer at the hearing. For all responses to the following
requests, please provide all work papers, diskettes and all underlying formulas in Excel
language.
You are further instructed that whenever the terms "you,
" "
your " or "Company
appear herein, they are all construed to refer to Idaho Power Company.
Request No.With respect to the Company s Low Income Weatherization
Assistance Program ("LIW A"), please provide the following information:
a. history of funding;
b. number of units weatherizedl
c. description ofLIW A program design, ftom 1984 to present;
d. identify and provide any cost-benefit analysis used to assess LIW A
and;
e. the percentage of Company gross operating revenues that were spent on
LIW A each year as well as shareholder and/or ratepayer funds spent each year in dollars
ftom beginning ofLIW A program to present, including corresponding number of
customers served.
Request No.Please provide corresponding data on types on allowable
measures (e., attic insulation, pipe wrap, water heater wrap, etc.) and dollars spent by
type of unit (single family, multi-family, mobile home) for LIWA.
1 The term "unit," as it appears herein, is defined as any single household whether a stand-alone structure
apartment, or part of a multi-living complex.
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
Request No.Please provide a history of funding and description of
program design, ftom 1984 to present, for the following:
a. low-income2 rate discounts offered by the Company;
b. low-income energy efficiency progr~;
c. low-income fuel funds (i.e., voluntary contributions by Idaho Power
shareholders and/or ratepayers for energy assistance);
d. any other low-income energy programs, and;
e. any special rates for other Idaho Power residential, commercial, or
industrial customers.
Request No.With respect to the preceding Request, please include
number of customers served each year and average amount paid on their behalf, as well
as the total amount ofIdaho Power gross operating revenue spent on each program per
year ftom 1984 to present.
In responding to this Request, please include a break-out of fuel type, income and
age, renter/owner ratios, or other demographics about these residential customers.
Include any internal analysis, studies, memos, etc., relevant to these customers.
Request No.In the event the Company utilizes criteria to define "low-
income" other than 150% of poverty level under the federal guidelines, please identify all
criteria used by the Company to categorize customers as "low-income" customers. In
doing so, separately describe each specific company procedure in which these criteria are
used to identify and categorize low income customers. Please provide a copy of each
2. The term "low-income" as it appears in these production requests, is defined as 150% of the federal
poverty guidelines as established by the federal Office of Management and Budget.
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
such procedure, including a copy of any staff training or operations manual in which the
procedure is set forth or otherwise discussed.
Request No.Please provide a copy of any written document in the
possession or control of the Company, whether or not prepared for the Company,
assessing, estimating or otherwise discussing the number oflow-income customers
served by the Company. To the extent that such document has been prepared by or for
the Company, include all source documents underlying the estimate of the number of
low-income customers.
Request No.Please provide a detailed written description of all
residential energy efficiency programs offered specifically to low-income customers of
the Company, including tariffs filed with the Idaho Public Utilities Commission.
Request No.Please provide any cost-benefit analysis, completed since
January 1; ,1996, of low-income energy efficiency program offered by the Company.
Request No.Please state the total number ofIdaho Power customers
receiving service within the state ofIdaho and how many ofthose are residential
customers.
Request No. 10:Please provide a break-out of the Company s Idaho
residential customers based on whether they rely upon electric space heat, or natural gas
heating. Please further break-out the number of low income customers by whether they
rely upon electric space heating or natural gas heating.
Request No. 11:Please provide the amount of gross operating revenues
(Idaho Jurisdiction) for the most recent year that information is available for Idaho
Power.
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
Request No. 12:Please provide the average residential bill by month for
each month January 1 , 1998 to present.
Request No. 13:Please provide a single copy of any study within the
possession or control of the Company, performed using Company customers, that
distinguishes between residential customers generally and low-income residential
customers in particular. Factors that might distinguish the two classes might include. but
not be limited to: (a) usage levels and patterns; (b) history of payment troubles; (c)
consumption of energy efficiency services; (d) credit and collection history; (e)
consumption of Company resources such as staff time; and the like.
Request No. 14:Please provide a copy of any study within the possession or
control of the Company that considers or calculates the average yearly number of kWh
for a typical low-income residential customer. Separately provide natural gas and electric
studies if available.
Request No. 15:Please provide all analyses that Idaho Power has generated
to predict the acquisition cost payback time amongst your customers for
weatherization/energy retrofits amongst your customers broken-out into residential and
low-income.
Request No. 16:Please provide the annual number of arrearages,
disconnects, and bad debt broken down by customer class.
Request No. 17:Regarding the preceding Request, please state the
percentage of annual arrearages, disconnects and bad debts are attributable to low-income
customers.
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
Request No. 18:Please explain the criteria the Company uses to assess, on
an ongoing basis, the cost-effectiveness of its current credit and collection activities.
Request No. 19:Please provide any written assessment, evaluation, report or
other written document of any nature that discusses the cost-effectiveness ofthe
Company s current credit and collection activities.
Request No. 20:Please state the total collection costs for the test year
utilized by the Company in its filing in this case, associated with handling low income
customer accounts, including administrative and overhead expenses, associated with
service termination activity including pre-termination notice by mail, pre-termination
personal contact, actual termination of service, post termination and restoration costs
negotiating payment arrangement requests, budget counseling, handling formal and
informal complaints, securing and maintaining deposits, tracking delinquent accounts
collection agency expenses, litigation expenses, dunning expenses, and winter survey
expenses.
Request No. 21:Of the total collection costs identified in response to
Request No. , state the total costs associated with low-income customers.
Request No. 22:Please provide the per-customer cost of each of the
following residential activities:
Disconnection of service for nonpayment;
The negotiation of a deferred payment arrangement (i., any
negotiated arrangement to pay past due bills over time);
Issuance of a written disconnect notice;
The reconnection of service;
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
A field collection visit;
A field visit to deliver a personal or written disconnect notice;
A telephone reminder of nonpayment.
Request No. 23:For each year since 1997, please provide the number of
each of the following:
Disconnection of service for nonpayment;
The negotiation of a deferred payment arrangement;
Issuance of a written disconnect notice;
The reconnection of service;
A field collection visit;
A field visit to deliver a personal or written disconnect notice;
A telephone reminder of nonpayment.
Request No. 24:Please provide a detailed description of each different type
of deferred payment plan offered by the company to residential customers. Separately
indicate to whom (or under what circumstances) each type of deferred payment plan is
offered.
Request No. 25:Please provide for each year for the past three years:
payment plan.
The total number of customers on each type of payment plan.
The total number of low-income customers on each type of
The total number oflow-income customers who have failed to
maintain one or more payment plans for each type of payment plan.
FIRST PRODUCTION REQUEST OF CAPAI TO IDAHO POWER COMPANY
Request No. 26:Please provide:
the total bad debt expense associated with low-income customers;
the total number of disconnects for nonpayment oflow-income
customers;
The total number of deferred payment arrangements with low-
income customers;
The total number of written disconnect notices to low-income
customers;
The total number of service reconnections for low-income
customers;
The total number offield collection visits to low-income
customers;
The total number of field visits to deliver a personal or written
disconnect notices to low-income customers;
The total number of telephone reminders of nonpayment to low-
income customers.
Request No. 27:Please provide every internal Company audit performed by
the Company within the past three years of an office or other company unit performing
collection functions, which audit examined issues relating to deferred payment plans
telephone credit and collection calls, the taking of deposits, field collection calls, or some
other collections-related function.
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
Request No. 28:Please describe the basic administrative process a customer
must "walk-through" in order to obtain a deferred payment arrangement. A response to
this Request should contain a description of the process ftom the point of initial contact
with the Company to the point where the Company and the customer document the
agreement.
Request No. 29:Please provide any written manual, operating procedures
staff training materials, or other written document of any nature that describes or
implements the Company s deferred payment plans.
Request No. 30:Please provide all studies, analyses, memos workpapers, or
written documents of any nature that disaggregate the source of bad debt to the Company
by the following:
bad debt);
debt);
By customer class;
By geography (e., zip code, census block, etc.) (for residential
By socia-economic status of the customer (for residential bad
By LIHEAP (the federal Low-Income Energy Home Assistance
Program) vs. non-LIHEAP customer (for residential bad debt).
Request No. 31:Please provide all studies, analyses, memos workpapers, or
written documents of any nature that disaggregate the source of arrears to the Company
by the following:
By customer class;
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
By geography (e., zip code, census block, etc.) (for residential
arrears);
By socio-economic status ofthe customer (for residential arrears);
By LIHEAP vs. non,:LIHEAP customer (for residential arrears).
Request No. 32:Please provide all "collectibility studies" performed by the
Company within the past three years. For purposes of this request, a "collectibility study
is a study which disaggregates customers into sub-classes and predicts or projects, based
on an empirical review, the percent of billed revenue that will be collected :from each sub-
class. Please provide such studies whether or not the Company happens to call them
collectibility studies.
Request No. 33:Ifno such "collectability studies" exist, please provide the
methodology for assessing allowances for doubtful accounts and describe in detail how
residential accounts receivable are evaluated to calculate the allowance.
Request No. 34:Please provide a detailed description of how the Company
calculates its uncollectible allowance (i., the amount of bad debt the Company
considers acceptable). Separately provide the most recent calculation of the uncollectible
allowance, including sufficient underlying workpapers and analysis to permit the
duplication ofthe calculation.
Request No. 35:Please provide the number of residential accounts with each
vintage of arrears on the first day of each month for each month since January 1998
inclusive. Provide the following vintages if available: (a) 30-60 days; (b) 61-90 days; (c)
91+ days. Ifnot available, provide what vintages are available.
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
Request No. 36:Please provide the dollars of arrears for the residential class
on the first day of each month for each month since January 1998 inclusive. Provide the
following vintages ifavailable: (a) 30-60 days; (b) 61-90 days; (c) 91+ days. Ifnot
available, provide what vintages are available.
Request No. 37:Please provide a single copy of any study within the
possession or control of the Company that considers or calculates:
the cost to the Company of nonpayment by residential customers;
the cost to the Company imposed by low-income residential
customers;
the cost to the Company of credit and collection activities engaged
in by the Company.
Request No. 38:Please provide any study, report, memo or other written
document of any nature in the possession or control ofthe CoJ;llpany, whether or not of
Company customers, that considers, evaluates or discusses the relationship between
residential payment-troubles and low-income status. Separately provide any such study,
memo, report or other written document that examines these relationships for Company
customers.
Request No. 39:Please provide any study, memo or written document of
any nature in the possession or control ofthe Company, that considers, evaluates or
otherwise discusses the relationship between payment troubles and:
Level of customer consumption;
Income of customer s household.
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
Request No. 40:Please provide any and all program manuals and other
written program descriptions detailing the operation of the company s outreach program
for the federally funded Low Income Energy Assistance Program (LlHEAP) or other
program directed toward providing assistance to low-income households.
Request No. 41:Please provide all studies, analyses, memos, workpapers, or
written documents of any nature examining the extent of accounts receivable associated
with LIHEAP recipients who are Company customers.
Request No. 42:Please provide the total number of customers receiving
LIHEAP grants for service provided by the Company in the:
2001-2 program year;
2001-2 program year.
Request No. 43:Please provide the amount of benefits (in dollars) receiving
in LIHEAP grants for eligible customers in the:
2001-2002 program year;
2001-2002 program year.
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DATED, this ~F;day of January, 2004.
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Brad M. Purdy
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
CERTIFICATE OF SERVIt:E
I HEREBY CERTIFY THAT I HAVE THIS X~!DAY OF JANUARY, 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF COMMUNITY
ACTION PARTNERSHIP ASSOCIATION OF IDAHO TO IDAHO POWER
COMPANY, IN CASE NO. IPC-03-, BY MAILING A COpy THEREOF
POSTAGE PREPAID, TO THE FOLLOWING:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ID. 83707
() u.S. Mail, postage prepaid
~:
lIand delivered
() Facsimile
(J Overnight mail
John R. Gale
Idaho Power Company
O. Box 70
Boise, ID. 83707
() u.S. Mail, postage prepaid
(,:y
Hand delivered
() Facsimile
() Overnight mail
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID. 83702
()f u.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Peter J. Richardson
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle, ID. 83616
()rU.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Don Reading
Ben Johnson Associates
6070 Hill Rd.
Boise, ID. 83703
N u.S. Mail, postage prepaid
t) Hand delivered
() Facsimile
() Overnight mail
Anthony Yankel
29814 Lake Road
Bay Village, OH. 44140
u.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
kl u.S. Mail, postage prepaid
() Hand delivered
() Facsimile
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey
201 E. Center
Pocatello, ID. 83204
FIRST PRODUCTION REQUEST OF CAPAI TO IDAHO POWER COMPANY
() Overnight mail
Lawrence A. Gollomp
1000 Independence Ave., SW
Washington, D.C. 20585
('l U.S. Mail, postage prepaid
Overnight mail
() Hand delivered
() Facsimile
Dennis Goins
Potomac Management Group
5801 Westchester St.
Alexandria, VA 22310-1149
rl U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
' U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Dean J. Miller
O. Box 2564
Boise, ID. 83701
Jeremiah 1. Healey
O. Box 190420
Boise, ID. 83719-0420
pI' u.s. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
William M. Eddie
O. Box 1612
Boise, ID. ' 83701
1)4 u.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
' U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Nancy Hirsch
219 First Ave. South, Suite 100
Seattle, W A. 98104
Conley E. Ward
601 W. Bannock St.
Boise, ID. 83702
M u.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Dennis Pesau
1500 Liberty St., Suite 250
Salem, OR. 97302
M U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
('4' U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
Michael L. Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY
36 E. Seventh St., Suite 2110
Cincinnati, OH 45202
() Overnight mail
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Brad M. Purdy
FIRST PRODUCTION REQUEST OF CAP AI TO IDAHO POWER COMPANY