200402171st Response of ID Power to Community Action Part I.pdf

BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
P. O. Box 70
Boise , Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise , Idaho 83702
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 FORELECTRIC SERVICE.
CASE NO. IPC-03-
IDAHO POWER COMPANY'
RESPONSE TO FIRST
PRODUCTION REQUESTS OF
COMMUNITY ACTION PARTNER-
SHIP ASSOCIATION OF IDAHO
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and in response to the First Set of Production Requests of the 'Community Action
Partnership Association of Idaho ("CAP AI") received by Idaho Power, herewith submits
the following information:
REQUEST NO.1: With respect to the Company s Low Income
Weatherization Assistance Program ("LlWA") , please provide the following information:
history of funding;
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 1
RESPONSE TO REQUEST NO. 1(a): The history of funding for LlWA
provided by Idaho Power to weatherization agencies in Idaho is shown in the following
table. The expenditures listed include only payments to agencies and do not include the
Company s other costs to administer the program.
Year Funding Units Gross Operating
Revenues
1989 $156 861 148 Not Available
1990 $328 638 328 $406 773 538
1991 $337 976 350 $411 524 830
1992 $245 602 259 $426 612 561
1993 $297 808 378 $461 176 295
1994 $288 332 397 $469 686 115
1995 $259,496 445 $464 738 240
1996 $228 167 235 $507 095 727
1997 $196 900 282 $666 519 573
1998 $215 239 273 007 203 164
1999 $198 914 261 $596,458 052
2000 $211 273 213 $760 501 102
2001 $331 ,126 266 $841 902 029
2002 $187 318 272 $812 863 191
203 $278 029 265 Not Available
TOTAL 583 651 107
The 2002 totals include $55 966 for 75 units funded through the
Conservation and Renewables Discount from the Bonneville Power Administration.
The 2003 totals include $49 895 for 57 units funded through the Conservation and
Renewables Discount from the Bonneville Power Administration
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
number of units weatherized;
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 2
RESPONSE TO REQUEST NO. 1(b): The number of units weatherized
is shown in the previous table.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
description of LlW A program design, from 1984 to present;
RESPONSE TO REQUEST NO. 1(c): This information is found in the
Company s annual Conservation Plans. The information for 1993 through 2002 has
previously been provided in Idaho Power s Response to First Production Request of the
Industrial Customers of Idaho Power, Request No. 28. The information for 1989
through 1992 is voluminous and can be reviewed in the Company s discovery room.
Information prior to 1989 is not available. Any party desiring to review documents in the
discovery room should call Myrna Aasheim at 388-2558 to arrange a time for such
review.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
identify and provide any cost-benefit analysis used to assess LlW A
RESPONSE TO REQUEST NO. 1(d): The State of Idaho has developed
a DOE-approved audit methodology and cost-benefit analysis spreadsheet. The
Company relies on the weatherization agencies to use the State s analysis tools to
compute the savings-to-investment ratio for each measure.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 3
The coordinated program between EL-ADA Community Action Agency
and Idaho Power in 1992 was examined in Low-Income DSM Programs:
Methodological Approach to Determining the Cost-Effectiveness of Coordinated
Partnerships by Marilyn A. Brown and Lawrence J. Hill (May 1994 , Oak Ridge National
Laboratory Managed by Martin Marietta Energy Systems , Inc., for the United States
Department of Energy). A copy of this study is available for review in the Company
discovery room. Any party desiring to review documents in the discovery room should
call Myrna Aasheim at 388-2558 to arrange a time for such review.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
the percentage of Company gross operating revenues that were
spent on LlW A each year as well as shareholder and/or ratepayer funds spent each
year in dollars , from beginning of LlW A program to present, including corresponding
number of customers served.
RESPONSE TO REQUEST NO. 1(e): Please refer to the Company
response to Request No.1 (a).
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO.2: 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 LlW
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 4
RESPONSE TO REQUEST NO.2: The requested information is
enclosed.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO.3: Please provide a history of funding and description of
program design , from 1984 to present , for the following:
low-income rate discounts offered by the Company;
RESPONSE TO REQUEST NO. 3(a): The Company does not offer low-
income rate discounts.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
low-income energy efficiency programs;
RESPONSE TO REQUEST NO. 3(b): This information is found in the
Company s Conservation Plans. See response to Request No.1 (c).
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
low-income fuel funds (i., voluntary contributions by Idaho Power
shareholders and/or ratepayers for energy assistance);
RESPONSE TO REQUEST NO. 3(c): The requested information is
available from 1998 forward.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 5
Project Share . Each year, Idaho Power s shareholders make a $25 000
contribution to Project Share. In 2001 in recognition of the ongoing energy crisis , the
Company s shareholders made an additional contribution of $100 000. In addition to
the Company s annual contributions to Project Share , Idaho Power s shareholders also
provide administrative support funding to Project Share equal to 10% of the
contributions made by Idaho Power customers to Project Share.
Year IPCO Shareholder Shareholder Customers Dollar Amount of
Contribution Administrative Receiving Grants Grants
Support from Project Share
Contribution
1998 $25 000 $18,443
1999 $25 000 $17 063 909 $216 430
2000 $25 000 $15 973 573 $198 985
2001 $125 000 $14 300 031 $244 867
2002 $25 000 $17 782 111 $278,481
2003 $25 000 $18 175 1 ,465 $187 616
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
any other low-income energy programs, and;
RESPONSE TO REQUEST NO. 3(d): Other energy service programs
that were available for, but not restricted to , low-income customers included a Heat
Pump Tune-Up Program , Water Heater Finance Program, Customer Service Finance
Program, and Power Quality Financing Program.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 6
any special rates for other Idaho Power residential , commercial , or
industrial customers.
RESPONSE TO REQUEST NO. 3(e): Idaho Power does not offer rates
other than those submitted and approved by the Idaho Public Utilities Commission.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO.4: 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 of Idaho Power gross operating revenue spent on each
program per year from 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.
RESPONSE TO REQUEST NO.4: Please refer to the Company
response to Request No. 3(c) for Project Share and the Company s response to
Request No.1 (a) for gross operating revenue.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO.5: In the event the Company utilizes criteria to define
low-income" other than 150% of poverty level under the federal guidelines, please
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 7
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 such procedure, including a copy of any staff training or operations
manual in which the procedure is set forth or otherwise discussed.
RESPONSE TO REQUEST NO.5: The Company relies on the
community action agencies to follow the procedures in the State of Idaho
Weatherization Plan to qualify eligible recipients for LlW A funding.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO.6: 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 of low-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.
RESPONSE TO REQUEST NO.6: Idaho Power does not track low-
income customers. However, utilizing a set of LlHEAP criteria for the winter season of
2002-2003 as ordered by the I PUC , data was provided by the Company in response to
IPUC Staff 3rd Production Request , Request No. 40. This response has been provided
to all parties.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 8
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO.7: 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.
RESPONSE TO REQUEST NO.7: Please refer to the responses to
Requests No.1 and No.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO.8: Please provide any cost-benefit analysis, completed
since January 1 , 1996, of low-income energy efficiency program offered by the
Company.
RESPONSE TO REQUEST NO.8: Between 1996 and the program
modifications in 2000 , the Company s role in cost-benefit analysis was limited to
compiling the savings estimates as received from the weatherization agencies and
calculating the overall levelized cost per kilowatt-hour of savings achieved during the
year for reporting in the annual Conservation Plan. In 2000 , LlWA in Idaho became
fuel-blind and a limited amount of non-energy (health and safety) measures became
eligible for funding. Since the program now funds some jobs that do not save electricity
and some measures that do not save energy, the program is less focused on the
levelized cost per kWh and more focused on its primary objective: to make energy
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 9
services more affordable to low-income customers. The annual Conservation Plans are
available in the discovery room. Any party desiring to review documents in the
discovery room should call Myrna Aasheim at 388-2558 to arrange a time for such
review.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO.9: Please state the total number of Idaho Power
customers receiving service within the state of Idaho and how many of those are
residential customers.
RESPONSE TO REQUEST NO.9: As of December 31 2003, the
average number of customers receiving service within the Company s Idaho service
territory is 400 816. Of these , 336 204 are residential customers.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
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.
RESPONSE TO REQUEST NO.1 0: Idaho Power does not maintain the
type of space heat utilized by its customers in its records. As a result , the requested
demographic information is not available.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 1
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
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.
RESPONSE TO REQUEST NO. 11: Total gross operating revenues for
the Idaho Jurisdiction in 2002 were $812 863 191. This is comprised of actual Idaho
retail sales plus an allocation of opportunity sales and other operating revenues. This
Idaho jurisdictional amount ties to the total system value found in the Company s 2002
FERC Form 1 , page 114.
The response to this request was prepared by Phil A. Obenchain , Senior
Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline , Senior
Attorney, Idaho Power Company.
REQUEST NO. 12: Please provide the average residential bill by month
for each month January 1 , 1998 to present.
RESPONSE TO REQUEST NO. 12: The requested information is
enclosed with this response.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO. 13: Please provide a single copy of any study within the
possession or control of the Company, performed using Company customers, that
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 11
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.
RESPONSE TO REQUEST NO. 13: Idaho Power does not identify
customers by income and as such does not track information specific to low-income
customers. However, during 2002-2003 Idaho Power and other utilities participated in a
study ordered by the Commission and reported the findings to the IPUC. The
Company s results from that study are enclosed.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
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.
RESPONSE TO REQUEST NO. 14: : Idaho Power does not identify low-
income customers , therefore this information is not available.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 12
REQUEST NO. 15: Please provide all analyses that Idaho Power has
generated to predict the acquisition cost payback time amongst your customers for
weatherization/en~rgy retro fits amongst your customers broken-out into residential and
low-income.
RESPONSE TO REQUEST NO. 15: In 1992 , Idaho Power modified
LlW A to replace the payback criteria with the benefit-cost ratio analysis that the State
program was adopting in accordance with U.S. Department of Energy directives. Since
that time, LlW A analysis has emphasized the saving-to-investment ratio.
Current programs targeted to lower income customers funded by the
Bonneville Power Administration for the Conservation and Renewable Discount
Program are required to pass cost-effective tests as approved by the Regional
Technical Forum. Idaho Power does not generate its own cost-effective tests for these
programs.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 16: Please provide the annual number of arrearages
disconnects, and bad debt broken down by customer class.
RESPONSE TO REQUEST NO. 16: Customer account information prior
to November 2000 is not readily available. The Company tracks arrearages on a
monthly basis. Determining an annual number of arrearages is not practical because
monthly arrearages are not additive as the same account may be past due for several
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 13
months. Additionally past due categories are not additive as one account may have
past due balances in all past due categories.
The Company system-wide monthly average arrearages for 2001 through
2003 are as follows:
Year 31-60 day past 61-90 day past 91 + days past
due due due
2001 805 29,409 134
2002 896 22,409 637
2003 583 354 965
The number of customers disconnect for non-payment were as follows:
2001
2002
2003
023
934
874
This represents Company system-wide information and is not available by
customer class.
Company system-wide write-offs of the uncollectible account for 2002 and
2003 are as follows:
Category
Irrigation
Large General
Off street Lighting
Residential
Small General
Unmetered
Other
Total
2002 2003
$426 138.082 435.
$361 873.$266,423.
720.697.
872 361.45 803,471.
$107 310.$84 298.
649.($1 353.60)*
($89 604.56)*($55 965.23)*
688,449.182 003.
Funds received during the designated time frames , however debt occurred in previous
time frame.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 14
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO. 17: Regarding the preceding Request , please state the
percentage of annual arrearages, disconnects and bad debts are attributable to low-
income customers.
RESPONSE TO REQUEST NO. 17: The Company does not identify low-
income customers , therefore this information is not available.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, 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.
RESPONSE TO REQUEST NO. 18: Idaho Power Company monitors the
percentage of past due customers and write-off of uncollectible accounts as a
percentage of billed revenue.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 19: Please provide any written assessment, evaluation
report or other written document of any nature that discusses the cost-effectiveness of
the Company s current credit and collection activities.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 15
RESPONSE TO REQUEST NO. 19: The Company does not have any
such documents that are responsive to this request.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
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.
RESPONSE TO REQUEST NO. 20: The Company does not identify low-
income customers , therefore this information is not available.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO. 21: Of the total collection costs identified in response to
Request No. ,state the total costs associated with low-income customers.
RESPONSE TO REQUEST NO. 21: Idaho Power does not identify low
income customers so this information is not available.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 16
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 22: Please provide the per-customer cost of each of the
following residential activities:
Disconnection of service for nonpayment;
The following costs are calculated assuming that these activities are
performed during normal business hours and are for the year-end 2003.
RESPONSE TO REQUEST NO. 22(a): The average cost of
connect/disconnect transactions is approximately $27.65. This cost includes field and
call center personnel. Disconnects for nonpayment are not differentiated from customer
requested disconnections.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
The negotiation of a deferred payment arrangement (i.e., any
negotiated arrangement to pay past due bills over time);
RESPONSE TO REQUEST NO. 22(b): The average cost of a collection
call is approximately $5.77.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
Issuance of a written disconnect notice;
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 17
RESPONSE TO REQUEST NO. 22(c): The cost of written notice is
$0.40.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
The reconnection of service;
RESPONSE TO REQUEST NO. 22(d): The average cost of
connect/disconnect transactions is approximately $27.65 including field and call center
personnel. Idaho Power does not differentiate the cost of reconnects from disconnects.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
A field collection visit;
RESPONSE TO REQUEST NO. 22(e): The average cost for a field
collections visit is $27.65.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
A field visit to deliver a personal or written disconnect notice;
RESPONSE TO REQUEST NO. 22(f): The average cost for a personal
or disconnect notice is the same as a field collections visit and is $27.65.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 18
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
A telephone reminder of nonpayment.
RESPONSE TO REQUEST NO. 22(9): The average cost of an out
bound telephone call is $0.66. This does not include long distance charges.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO. 23: For each year since 1997, please provide the number
of each of the following:
Disconnection of service for nonpayment;
RESPONSE TO REQUEST NO. 23(a):
Disconnect of service for nonpayment;
1997 - 2000: In November of 2000 , Idaho Power migrated to a
new Customer Information System. Statistics regarding
disconnection events are only available beginning in 2001.
. 2001 , 15 023 disconnects for nonpayment
. 2002 , 25 934 disconnects for nonpayment
. 2003 , 19 874 disconnects for nonpayment
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
The negotiation of a deferred payment arrangement;
RESPONSE TO REQUEST NO. 23(b):
The negotiation of a deferred payment arrangement;
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 19
1997 - 2000: In November of 2000, Idaho Power migrated to a
new Customer Information System. Statistics regarding
payment arrangement events are only available beginning in
2001.
. 2.001 ,
. 2002
. 2003
107 190 deferred payment arrangements
177 645 deferred payment arrangements
182 655 deferred payment arrangements
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
Issuance of a written disconnect notice;
RESPONSE TO REQUEST NO. 23(c):
Issuance of a written disconnect notice;
1997 - 2000: In November of 2000 , Idaho Power migrated to a
new Customer Information System. Statistics regarding written
termination (involuntary disconnect) notices are only available
beginning in 2001.
. 2001 , 263 172 written notices of termination
. 2002, 282 311 written notices of termination
. 2003, 271 973 written notices of termination
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
The reconnection of service;
RESPONSE TO REQUEST NO. 23(d):
The reconnection of service;
1997 - 2000: In November of 2000 , Idaho Power migrated to a
new Customer Information System. Statistics regarding
reconnection events are only available beginning in 2001.
. 2001 , 10 364 reconnect orders
. 2002 , 18 691 reconnect orders
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 20
. 2003 , 13 518 reconnect orders
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
A field collection visit;
RESPONSE TO REQUEST NO. 23(e):
A field collection visit;
1997 - 2000: In November of 2000, Idaho Power migrated to a
new Customer Information System. Statistics regarding
payment arrangement events are available beginning in 2001.
Note: the following information represents visits made to a
customers residence with the intent of disconnecting for non-
payment, that the customer provided payment to avoid the
termination and a field collection charge was applied.
. 2001 , 7,424 field collection charges
. 2002 , 16 000 field collection charges
. 2003 , 11 783 field collection charges
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
A field visit to deliver a personal or written disconnect notice;
RESPONSE TO REQUEST NO. 23(f):
A field collection visit to deliver a personal or written disconnect
notice;
1997 - 2000: In November of 2000 , Idaho Power migrated to a
new Customer Information System. Statistics regarding field
visits events are only available beginning in 2001.
The following information represent the number of notices
mailed to customers. The number of field visits to deliver a 24
hour notice is not available.
. 2001 , 125 539 Final Disconnect Notices
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 21
. 2002 219 263 Final Disconnect Notices
. 2003, 201,417 Final Disconnect Notices
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
A telephone reminder of nonpayment.
RESPONSE TO REQUEST NO. 23(9):
A telephone reminder of nonpayment;
1997 - 2000: In November of 2000, Idaho Power migrated to a
new Customer Information System. Statistics regarding phone
reminder attempts are only available beginning 2001.
. 2001 , 163 268 Phone reminder attempts
. 2002 , 274,457 Phone reminder attempts
. 2003 , 256 529 Phone reminder attempts
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
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.
RESPONSE TO REQUEST NO. 24:
Arrangement Type 1. An agreement between Idaho Power and
the customer under which the customer is to pay the current amount due (total due)
within the next 10 days.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 22
Any customer who has not had previous arrangements on the same dollar
amount is eligible for this type of arrangement.
Arrangement Type 2. An agreement between Idaho Power and
the customer under which the customer is to pay 1/2 of the outstanding bill or the
61/91-day past due amount , whichever is greater, and pay the outstanding balance plus
current bill within 30 days (The amount of the current bill will be added to the installment
amount.), and pay all future bills as they come due.
Any customer who has not had previous arrangements on the same dollar
amount is eligible for this type of arrangement.
Levelized Pay. Levelized Pay is an agreement between Idaho
Power and the customer under which the customer is to:
a. Pay a down payment equal to the average monthly bill , including the
account balance divided by 12 , and
b. Pay a like payment each month for 11 months.
Levelized Pay is offered to Idaho customers with delinquent bills that have
not had previous arrangements on the same dollar amount.
Winter Pay (November through March). The Winter Payment
Plan is a payment arrangement offered in Idaho to qualified customers that are unable
to pay their utility bills in full each month during the months of November through
March.
Qualifications for Winter Pay are:
Household includes children , elderly, or infirm persons.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 23
Any Idaho residential customer whose account balance is $75.
or less , or has a current one-month bill.
For succeeding years the customer must follow the same criteria as
above, plus the customer must have kept up with the past year s arrangements.
Customers requesting Winter Pay are expected to:
Pay a down payment equal to half the average annual bill, including
the account balance divided by 24, and
Pay a like payment each month through March at which time they
will need to contact the Company and make new arrangements to cover the remainder
owing.
Medical Postponement. A Medical Postponement allows a
customer to postpone collection activity on an account if the customer cannot pay the
account due to a serious illness in the household or a medical emergency.
Medical certificate allows for a 30 day extension;
The arrangement is for current past due amount plus any
current bill amount due;
. A payment arrangement is necessary prior to the expiration of
the postponement to be in accordance with Rule 313
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 25: Please provide for each year for the past three years:
The total number of customers on each type of payment plan.
RESPONSE TO REQUEST NO. 25(a):
The total number of customers on each type of payment plan.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 24
2001 2002 2003
Type 123 036 102 190
Type 2 52,448 , 146 838
Levelized 087 818 991
Winter See note 178 See note
Medical 532 645 636
Note 1: In the ordinary course of business, Winter Pay Arrangements are
not tracked as a separate payment arrangement type. Idaho Power did manually track
the number of Winter Pay arrangements during the winter heating season of 2002/2003
in order to comply with the reporting requirements of IPUC Order No. 29165.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
The total number of low-income customers on each type of
payment plan.
RESPONSE TO REQUEST NO. 25(b): Idaho Power does not identify
low-income customers. In 2003 , Idaho Power responded to IPUC Order No. 29165 that
required the tracking of the number of customers that suspended payments under the
winter moratorium that also qualified for LlHEAP eligibility requirements based on
income and number of household residents. That information is enclosed.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
The total number of low-income customers who have failed to
maintain one or more payment plans for each type of payment plan.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 25
RESPONSE TO REQUEST NO. 25(c): Idaho Power does not separately
track low-income customers. Therefore , this information is unavailable.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, 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 of low-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 of field 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.
RESPONSE TO REQUEST NO. 26: The Company does not separately
track low-income customers. Therefore , this information is not available.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 26
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
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.
RESPONSE TO REQUEST NO. 27: Idaho Power has not performed
such an audit.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, 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 from the point of
initial contact with the Company to the point where the Company and the customer
document the agreement.
RESPONSE TO REQUEST NO. 28: A "walk through" of the process is as
follows:
1. Customer telephones Idaho Power and reaches the Interactive Voice
Response (IVR) and provides their account number;
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 27
If the customer s account qualifies to utilize the IVR , the customer is
offered a selection of payment arrangements with a description of
each arrangement. The customer s account payment history can
preclude the customer from utilizing the IVR;
3. The customer chooses an arrangement type:
Arrangement Type
Arrangement Type 2
Levelized (Accounts with balance over $500)
(Please refer to Request No. 24 for definitions)
4. The payment arrangement is documented within the customer
account record;
5. A copy of the agreed-upon payment arrangement is mailed to the
customer s mailing address.
If the customer s account does not qualify to use the IVR system , the
customer's phone call would be transferred out of the IVR to a credit
and collection customer service representative.
7. The customer service representative and customer agree upon an
arrangements plan for qualified customers.
8. The customer service representative enters the arrangement within
the customer s account.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 28
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.
RESPONSE TO REQUEST NO. 29: The requested information is
enclosed.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
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 socio-economic status of the customer (for residential bad
By LlHEAP (the federal Low-Income Energy Home Assistance
Program) vs. non-LiHEAP customer (for residential bad debt).
RESPONSE TO REQUEST NO. 30: The write-off uncollectible account
information is enclosed. The enclosed information is broken down by customer class
by taxing city, however the Company does not tract information by socio-economic
status or by LlHEAP and non-LiHEAP customers.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 29
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
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;
By geography (e., zip code , census block, etc.) (for residential
arrears) ;
By socio-economic status of the customer (for residential arrears);
By LlHEAP vs. non-LiHEAP customer (for residential arrears).
RESPONSE TO REQUEST NO. 31: The requested information on
Company arrearages is voluminous and as a result will be provided in the Company
discovery room for review. Any party desiring to review documents in the discovery
room should call Myrna Aasheim at 388-2558 to arrange a time for such review. The
Company does not differentiate customer accounts by socio-economic status or have
LlHEAP information by customer.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
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
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 30
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.
RESPONSE TO REQUEST NO. 32: Please refer to the enclosed
information for work papers containing forecasting of uncollectible accounts for
budgeting purposes.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO. 33: If no 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.
RESPONSE TO REQUEST NO. 33: The Company calculates the
percentage of write-offs on outstanding accounts receivable by aged category monthly.
The budget reserve for uncollectible accounts is calculated by multiplying the 12-month
moving average percentage of write-offs for each aged category times the applicable
outstanding accounts receivable balance.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO. 34: Please provide a detailed description of how the
Company calculates its uncollectible allowance (Le., the amount of bad debt the
Company considers acceptable). Separately provide the most recent calculation of the
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 31
uncollectible allowance , including sufficient underlying workpapers and analysis to
permit the duplication of the calculation.
RESPONSE TO REQUEST NO. 34: For residential and small
commercial accounts , Idaho Power calculates the percentage of write-offs on
outstanding accounts receivable by aged category monthly. The reserve for
uncollectible accounts is calculated by multiplying the 12-month moving average
percentage of write-offs for each aged category times the applicable outstanding
accounts receivable balance. For irrigation accounts , Idaho Power calculates the
historical percentage of write-offs as a percentage of past due outstanding balance in
May and December and multiplies that percentage times the outstanding Mayor
December balance as applicable. Workpapers showing the computations are
enclosed.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
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. If not available , provide what vintages are available.
RESPONSE TO REQUEST NO. 35: Information regarding residential
accounts with each vintage of arrears is available from the year 2000 forward. This
information is voluminous and will be made available for review in the Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 32
discovery room. Any party desiring to review documents in the discovery room should
call Myrna Aasheim at 388-2558 to arrange a time for such review.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, 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 if available: (a) 30-60 days; (b) 61-90 days; (c)
91 + days. If not available , provide what vintages are available.
RESPONSE TO REQUEST NO. 36: Information regarding residential
accounts with dollars of arrears is available from the year 2000 forward. This
information is voluminous in nature and will be made available for review in the
Company s discovery room.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
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 tow-income residential
customers;
the cost to the Company of credit and collection activities engaged
in by the Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 33
RESPONSE TO REQUEST NO. 37: The Company does not have any
documents that would respond to this request.
The response to this request was prepared by Sue Fullen, General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 38: Please provide any study, report, memo or other
written document of any nature in the possession or control of the Company, 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.
RESPONSE TO REQUEST NO. 38: The Company does not have any
documents that would respond to this request.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 39: Please provide any study, memo or written document
of any nature in the possession or control of the Company, that considers, evaluates or
otherwise discusses the relationship between payment troubles and:
Level of customer consumption;
Income of customer s household.
RESPONSE TO REQUEST NO. 39: The Company does not have any
documents that would be responsive to this request.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 34
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, 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 (LiHEAP) or
other program directed toward providing assistance to low-income households.
RESPONSE TO REQUEST NO. 40: The Company does not operate the
LlHEAP or Project Share and therefore does not maintain program outreach materials.
For LlHEAP and Project Share assisted customers, the Company processes the
payments received by the agencies. However, the Company promotes customer
contributions to Project Share through its customer bill enrollment opportunity, television
commercials as well as bill inserts. Upon inquiry by a customer, the customer call
center representatives discuss agency programs with customers and assist the
customer with appropriate agency contract information. Participating LlHEAP agencies
are also listed on our website.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 41: Please provide all studies , analyses, memos
workpapers , or written documents of any nature examining the extent of accounts
receivable associated with LlHEAP recipients who are Company customers.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 35
RESPONSE TO REQUEST NO. 41: The Company does not identify
customers as LlHEAP recipients. Please refer to Response No. 13 for further
information.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 42: Please provide the total number of customers
receiving LlHEAP grants for service provided by the Company in the:
2001-2 program year;
2001-2 program year.
RESPONSE TO REQUEST NO. 42: The number of customers receiving
LlHEAP grants are listed below. While Request No. 42, b , indicates 2001-2 program
year, the Company assumes the information requested is for 2002-2003. The data
spans the Health and Welfare defined program year of December through April 2002.
2001-2002 236 customers
2002-2003 - 9 592 customers
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 43: Please provide the amount of benefits (in dollars)
receiving in LlHEAP grants for eligible customers in the:
2001-2002 program year;
2001-2002 program year.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 36
RESPONSE TO REQUEST NO. 43: The number of customers receiving
LlHEAP benefit dollars are listed below. While Request No. 42 , b, indicates 2001-2002
program year, the Company assumes information requested is for 2002-2003. The
data spans the Health and Welfare defined program year of December through April
2003.
2001-2002 benefit amount equals $2 522 107
2002-2003 benefit amount equals $3 128 330
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
DATED at Boise, Idaho, this 13th day of February, 2004.
GJci
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAPAI)Page 37
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of February, 2004 , I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
RESPONSE TO FIRST PRODUCTION REQUEST OF CAPAI upon the following
named parties by the method indicated below , and addressed to the following:
Lisa D. Nordstrom
Weldon B. Stutzman
Deputy Attorneys General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
O. Box 1391; 201 E. Center
Pocatello, ID 83204-1391
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Anthony Yankel
29814 Lake Road
Bay Village , OH 44140
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Peter J. Richardson
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle, ID 83616
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise , ID 83703
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Lawrence A. Gollomp
Assistant General Counsel
U. S. Department of Energy
1000 Independence Avenue , SW
Washington , D.C. 20585
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria , VA 22310-1149
CERTIFICATE OF SERVICE , Page
Hand Delivered
S. Mail
Overnight Mail
FAX
Conley E. Ward
Givens, Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
Dennis E. Peseau , Ph.D.
Utility Resources, Inc.
1500 Liberty Street S., Suite 250
Salem, OR 97302
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, ID 83701
Jeremiah Healy
United Water Idaho , Inc.
O. Box 190420
Boise, ID 83719-0420
William M. Eddie
Advocates for the West
O. Box 1612
Boise , ID 83701
Nancy Hirsh
NW Energy Coalition
219 First Ave. South , Suite 100
Seattle, WA 98104
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise , ID 83702
Michael Karp
147 Appaloosa Lane
Bellingham , W A 98229
Michael L. Kurtz, Esq.
Kurt J. Boehm , Esq.
Boehm , Kurtz & Lowry
36 East Seventh Street, Suite 2110
Cincinnati , OH 45202
CERTIFICATE OF SERVICE, Page 2
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Kevin Higgins
39 Market Street, Suite 200
Salt Lake City, UT 84101
Hand Delivered
S. Mail
Overnight Mail
FAX
Thomas M. Power
Economics Department, LA 407
University of Montana
32 Campus Drive
Missoula, MT 59812
Hand Delivered
S. Mail
Overnight Mail
FAX
aM
kx-
BARTON L. KLINE
CERTIFICATE OF SERVICE , Page 3