200601093rd staff request to IPC.pdf

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CECELIA A. GASSNER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO, 6977
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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-
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
Cecelia A. Gassner, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
MONDAY, JANUARY 23 , 2006.
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.
THIRD PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 9, 2006
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. 26: 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. Customers served under Schedule 7 are billed for
energy only, whereas customers served under Schedule 9 pay for energy and demand. How
many of the 3900 Schedule 7 customers who will migrate to Schedule 9 currently have demand
meters?
REQUEST NO. 27: For Schedule 7 customers who are moved to Schedule 9 but do not
have demand meters, how does Idaho Power propose to bill these customers for the demand
component of Schedule 9? Does the Company intend to install demand meters for these
customers? If so, over what period of time would that take place?
REQUEST NO. 28: In the chart entitled "ACD Data" included in the Company
response to Request No.6 of the First Production Request, the months of August, September
and October of 2005 show a significant increase in the number of incoming telephone calls to the
customer service center. Along with the increase in telephone calls in those three months, the
service level dropped below 80%. What was the reason for the increase in calls and the decrease
in service level?
DATED at Boise, Idaho, this 9 ~day of January 2006.
Cecelia A. Gassner
Deputy Attorney General
Technical Staff: Marilyn Parker
Beverly Barker
i:umisc:prodreqlipceO5.28ccbabmp pr 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 9, 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF JANUARY 2006
SERVED THE FOREGOING THIRD 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
E- MAIL: bkline~idahopower.com
mmoen~idahopower,com
RANDALL C BUDGE
ERIC L OLSEN
RACINE, OLSON, NYE , BUDGE, BAILEY
201 E CENTER
PO BOX 1391
POCATELLO, ID 83204-1391
MAIL: rcb~racinelaw.net
elo~racinelaw ,net
PETER J. RICHARDSON
RICHARDSON & O'LEARY LLP
515 N 27TH ST
PO BOX 7218
BOISE ID 83702
MAIL: peter~richardsonandoleary.com
CONLEY E WARD
GIVENS PURSLEY LLP
601 W BANNOCK ST
PO BOX 2720
BOISE ID 83701-2720
MAIL: cew~givenspursley.com
LAWRENCE A. GOLLOMP
ASSISTANT GENERAL COUNSEL
UNITED STATES DEPT OF ENERGY
1000 INDEPENDENCE A VB. SW
WASHINGTON, DC 20585
MAIL: lawrence,gollomp~hq,doe.gov
JOHN R GALE
VICE PRESIDENT REGULATORY
AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
MAIL: rgale~idahopower.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
MAIL: yankel~attbi.com
DR. DON READING
6070 HILL ROAD
BOISE ID 83703
MAIL: dreading~mindspring,com
DENNIS E. PESEAU, PH.
UTILITY RESOURCES INC
1500 LIBERTY STREET S.
SUITE 250
SALEM, OR 87302
MAIL: dennytemp~yahoo.com
DALE SWAN
EXETER ASSOCIATES INC
5565 STERRET PLACE, SUITE 310
COLUMBIA, MD 21044
MAIL: dswan~exeterassociates.com
CERTIFICATE OF SERVICE
WILLIAM MEDDlE
ADVOCATES FOR THE WEST
PO BOX 1612
BOISE ID 83701
MAIL: billeddie0)rmci.net
KEN MILLER
NW ENERGY COALITION
5400 W FRANKLIN STE G
BOISE ID 83705
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINNATI OH 45202
MAIL: mkurtz~bkllawfirm,com
kboehm~bkllawfirm,com
CERTIFICATE OF SERVICE