20060123IPC response 3rd staff request.pdf

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IDAHO POWER COMPANY
O. BOX 70
BOISE, IDAHO 83707
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BARTON L. KLINE.
Senior Attorney
An IDACORP Company
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January 23, 2006
HAND DELIVERED
Jean D. Jewell , Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. IPC-05-
Idaho Power Company s Response to the
Third Production Request of Commission Staff
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of the
Company s Response to the Third Production Request of Commission Staff regarding
the above-described case.
I would appreciate it if you would return a stamped copy of this transmittal
letter to me in the enclosed self-addressed stamped envelope.
Very truly yours~JCL-
Barton L. Kline
BLK:jb
Enclosures
Telephone [phone] Fax [phone] E-mail BKlinefii1idahopower.com
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BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise , Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
BKline (g) idahopower.com
MMoen (g) idahopower.com
Attorneys for Idaho Power Company
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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 BASE
RATES AND CHARGES FOR ELECTRIC
SERVICE IN THE STATE OF IDAHO
CASE NO. IPC-05-
IDAHO POWER COMPANY'
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF
COMMISSION STAFF
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and in response to the Third Production Request of the Commission Staff to Idaho Power
Company dated January 9,2006, herewith submits the following information:
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?
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD
PRODUCTION REQUEST OF COMMISSION STAFF Page
RESPONSE TO REQUEST NO. 26: Of the 3 900 Schedule 7 customers
expected to migrate to Schedule 9 under the proposed eligibility requirements, an
estimated 2 535 , or 65%, currently have demand meters.
The response to this request was prepared by Peter Pengilly, Senior
Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior
Attorney, Idaho Power Company.
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?
RESPONSE TO REQUEST NO. 27: Idaho Power plans to install demand
meters for all Schedule 7 customers that do not currently have one and that are
expected to qualify for Schedule 9 under the proposed eligibility requirements. The
demand meter installations are planned to occur during March and April 2006.
approved by the Commission, the migration of customers from Schedule 7 to Schedule
9 will occur coincident with each customer s first regular billing cycle following the
effective date of the approved revisions, as described in the direct testimony of
Company witness, Mr. Pengilly, pages 21-22. In order to effectively manage this
migration strategy, the Company determined that the majority of the demand meters
would have to be in place prior to the effective date indicated in the Commission
order. In an effort to keep costs at a minimum, many of the demand meters that will be
installed as part of this effort have been removed from other locations determined to no
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD
PRODUCTION REQUEST OF COMMISSION STAFF Page 2
longer require a demand meter.
The response to this request was prepared by Peter Pengilly, Senior
Pricing Analyst , Idaho Power Company, in consultation with Barton L. Kline, Senior
Attorney, Idaho Power Company.
REQUEST NO. 28: In the chart entitled "ACD Data" included in the
Company s 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?
RESPONSE TO REQUEST NO. 28: Inbound customer ACD calls , which
are calls answered by Customer Service Representatives, increased by 7 947 calls or
4.40 % in the months of August, September, and October 2005 , as compared to those
same months in 2004. Several factors contributed to the increase in call volume in
addition to normal customer growth. The Company has historically seen a spike in
inbound calls relating to the connection , disconnection and transfer of service during
the late summer and early fall. However, during the months of August through October
of 2005, the Customer Service Center handled 4 233 more calls of this type than in
2004. During the same three months of 2005, construction related calls were also up by
674 calls over the previous year. Furthermore, due to the Company s expanding
Demand-Side Management (DSM) program offering, the Customer Service Center has
observed an increasing amount of DSM related calls. As a result, the Company began
specifically tracking this call type in April of 2005. During August, September, and
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD
PRODUCTION REQUEST OF COMMISSION STAFF Page 3
October of 2005 the Company received 2 714 calls related to DSM programs. Finally, in
an isolated event, outage related calls were higher than normal in September 2005.
The Company experienced a dip in its Service Level during the months of
August , September, and October of 2005 primarily resulting from an increase in call
volume coupled with greater than normal employee attrition during July and August of
2005.In August of 2005 , the Customer Service Center had 7 vacant Customer
Service Representative positions, which were subsequently filled in September 2005.
Another factor that impacted the Service Level during this time was an
increase in the average call duration , referred to by the Company as "handle time.
The average handle time for calls received in the months of August , September, and
October of 2005 increased by 6 seconds per call as compared to the same months in
2004. This means that the average time that Customer Service Representatives spent
with each customer increased thereby reducing the overall availability of
representatives to answer inbound calls.
The response to this request was prepared by James L. Baggs , General
Manager, Strategic Initiatives and Compliance, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
DATED this 23rd day of January, 2006.
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BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD
PRODUCTION REQUEST OF COMMISSION STAFF Page 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23rd day of January, 2006, I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
RESPONSE TO THIRD PRODUCTION REQUEST OF COMMISSION STAFF upon the
following named parties by the method indicated below , and addressed to the following:
Donald L. Howell , II
Cecelia A. Gassner
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise , Idaho 83720-0074
don.howell (g) puc.idaho.qov
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Randall C. Budge
Eric L. Olsen
Racine, Olson , Nye, Budge & Bailey
O. Box 1391; 201 E. Center
Pocatello, ID 83204-1391
rcb (g) racinelaw.net
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racinelaw. net
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Anthony Yankel
29814 Lake Road
Bay Village , OH 44140
yankel ~ attbLcom
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Peter J. Richardson
Richardson & O'Leary
51 5 N. 27th Street
O. Box 7218
Boise,. ID 83702
peter(g) richardsonandolearv.com
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Dr. Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
dreadinq ~ mindsprinq.com
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Lawrence A. Gollomp
Assistant General Counsel
United States Dept. of Energy
1000 Independence Avenue , SW
Washington, D.C. 20585
Lawrence.Gollomp(g) hq.doe.qov
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CERTIFICATE OF SERVICE, Page
Dennis Goins
Potomac Management Group
5801 Westchester Street
O. Box 30225
Alexandria , VA 22310-1149
dqoinsPMG (g)aol.com
Conley E. Ward
Givens , Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
cew (g) qivenspursleV.com
Dennis E. Peseau , Ph.
Utility Resources, Inc.
1500 Liberty Street S., Suite 250
Salem , OR 97302
dpeseau ~ excite.com
William M. Eddie
Advocates for the West
1320 W. Franklin Street
O. Box 1612
Boise, ID 83701
billeddie
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rmci. net
Ken Miller
NW Energy Coalition
5400 W. Franklin , Suite G
Boise, ID 83705
kenmiller1 (g)cableone.net
Michael L. Kurtz
Kurt J. Boehm
Boehm , Kurtz & Lowry
36 East Seventh Street , Suite 1510
Cincinnati, Ohio 45202
mkurtz(g) bkllawfirm.com
kboehm ~ bkllawfirm.com
CERTIFICATE OF SERVICE, Page 2
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BARTON L. KLINE