200601124th 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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12 Fl!3:00
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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-
FOURTH 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
THURSDAY, JANUARY 26, 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.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 12, 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. 29: What is the Company s general record keeping or filing process
specific to the Continuous Service Program? What are the costs associated with maintaining
hard or printed copies of records specific to the Continuous Service Program?
REQUEST NO. 30: What were the fully-loaded annual administrative labor costs
associated with the Continuous Service Program in 2004 and 2005?
REQUEST NO. 31: Does the Company provide scripts for Customer Service
Representatives that provide guidance when discussing confidential account information with
property managers and/or customers who are tenants of property managers? Please provide a
copy of the script described in this request.
REQUEST NO. 32: What is the average annual mailing cost associated with the
Continuous Service Program?
REQUEST NO. 33: What letter is used by the Company to inform property managers
of a service denial? Please provide a copy ofthe letter template or form.
REQUEST NO. 34: How is the effective date on the Notification of Revert to Service
letter determined?
REQUEST NO. 35: For each letter relating to the Continuous Service Program, what
triggers the letter to be mailed and does it occur manually or automatically?
FOURTH PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 12, 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF JANUARY 2006
SERVED THE FOREGOING FOURTH 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~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
ASSIST ANT GENERAL COUNSEL
UNITED STATES DEPT OF ENERGY
1000 INDEPENDENCE AVE. SW
WASHINGTON, DC 20585
MAIL: lawrence.gollomp~hq.doe.gov
JOHN R GALE
VICE PRESIDENT REGULATORY
AFF AIRS
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
DENNIS GOINS
POTOMAC MANAGEMENT GROUP
PO BOX 30225
ALEXANDRIA VA 22310-8225
MAIL: dgoinspmg~ao1.com
CERTIFICATE OF SERVICE
WILLIAM M EDDIE
ADVOCATES FOR THE WEST
PO BOX 1612
BOISE ID 83701
MAIL: billeddie~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
SECRETARY
CERTIFICATE OF SERVICE
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DATED at Boise, Idaho, this /~ day of January 2006.
~~.
Cecelia A. ssner
Deputy Attorney General
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Technical Staff: Marilyn Parker
Beverly Barker
i:umisc:prodreqlipceO5.28ccbabmp pr 4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 12 2006