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DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0312
IDAHO BAR NO. 3366
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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 BASE RATES AND
CHARGES FOR ELECTRIC SERVICE IN THESTATE OF IDAHO.
CASE NO. IPC-05-
FIRST 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
Donald L. Howell, II, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
TUESDAY, DECEMBER 6,2005.
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY NOVEMBER 22, 2005
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.
REQUEST NO.1: Please explain in detail the Property Owner/Manager Continuous
Service Program. Describe how a property owner or manager requests the service, what the
services and benefits are for participants, and how the service is cancelled. Also include a
description of all the Company benefits associated with the program.
REQUEST NO.2: Please provide a copy of the page(s) from the Customer Service
Training Manual regarding the Continuous Service Program.
REQUEST NO.3: Please provide copies of any contracts, letters, notices, or other
documents provided to property owners or managers who participate in the Continuous Service
Program.
REQUEST NO.4: How many property owners or managers now take advantage of the
Continuous Service Program? Please list the average number of program participants during
each of the last 3 years.
REQUEST NO.5: For Calendar Year 2004 and year to date in 2005, what was the
completion interval for actual, physical customer-requested disconnections of residential and
small commercial service points? Please provide the total number of actual disconnections for
both time periods. For both time periods, include the percent of the disconnection requests that
were completed for each of the following time frames: 1-3 days, 4-5 days, and more than 5 days.
REQUEST NO.6: In the Idaho Power Customer Service Center, what were the service
levels by month in 2004 and to date in 2005? (Service levels are the percent of calls answered
within 30 seconds). Also include for each month the total number of incoming calls.
REQUEST NO.7: For each month in 2004 and to date in 2005, how many calls to the
Customer Service Center were abandoned? (Abandoned calls are those calls that reach the
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY NOVEMBER 22, 2005
Company s incoming telephone system but where the customer hangs up or is otherwise
disconnected before speaking with a Customer Service Representative).
REQUEST NO.8: In the Idaho Power Repair and Management Call Center, what were
the service levels by month in 2004 and to date in 2005? (Service levels are the percent of calls
answered within 30 seconds). Also include for each month the total number of incoming calls.
REQUEST NO.9: For each month in 2004 and to date in 2005, how many calls to the
Company s Repair and Management Call Center were abandoned? (Abandoned calls are those
calls that reach the Company s incoming telephone system but where the customer hangs up or is
otherwise disconnected before speaking with a Customer Service Representative).
REQUEST NO. 10: Since the Company s last general rate case, what specific steps
have been taken to change how the Company handles or cares for its special needs customers?
Special needs customers could include low and fixed income customers, customers who speak
languages other than English, physically challenged, or mentally challenged customers.
REQUEST NO. 11: Please provide ajob description for the new program manager
position mentioned in Company witness Baggs' testimony on page 10.
REQUEST NO. 12: Has the Company website been enhanced since the last general rate
case to provide customers the option to sign up or disconnect utility service online?
REQUEST NO. 13: Idaho Power is proposing to modify eligibility criteria for
Schedules 7 and 9 , the result of which will be approximately 3900 customers currently served
under Schedule 7 moving to Schedule 9. If approved by the Commission, what specific actions
does the Company propose to take in order to accomplish this customer migration? Over what
period of time will this transition take place?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY NOVEMBER 22, 2005
REQUEST NO. 14: How many Schedule 41 customers have non-metered, customer-
owned systems installed before June 1 2004, which have the potential for variation in usage?
What is the aggregate estimated annual energy usage for these customers?
REQUEST NO. 15: According to Company witness Pengilly, 954 irrigation customers
with installed motors of 5hp or less are not demand metered. What is the Company
justification for not metering demand for these customers?
REQUEST NO. 16: Idaho Power is proposing to move irrigation customers currently
served under Schedule 24 and 25 to other rate schedules if the nature of their use is for other than
agricultural purposes. How many of the 954 irrigation customers who are not demand metered
have usage that would be considered non-agricultural?
REQUEST NO. 17: In accordance with Rule No. 403 of the Utility Customer Relations
Rules (UCRR), please provide the written records of complaints filed with the Company for the
year 2004 and to date in 2005.
DATED at Boise, Idaho, this Z 2- day of No v mber 2005.
Donald L. H ell, II
Deputy Attorney General
Technical Staff: Marilyn Parker
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FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY NOVEMBER 22, 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF NOVEMBER 2005
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER, IN CASE NO. IPC-05-, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
MONICA B MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
MAIL - bkline(~jdahopower.com
mmoen(~jdahopower.com
JOHN R GALE
VICE PRESIDENT REGULATORY
AFF AIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
MAIL - rgale~idahopower.com
CERTIFICATE OF SERVICE