20080905Staff to IPC 25-41.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
RECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE TO ITS )
CUSTOMERS IN THE STATE OF IDAHO. )
)
)
)
CASE NO. IPC-E-08-10
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,
Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
FRIDAY, SEPTEMBER 26, 2008.
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 SEPTEMBER 5, 2008
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 25: Please provide all the details that comprise the amounts set forth on
page 6 of 6 of Exhibit No. 31, offered as par of Smith's Testimony and titled "Operation and
Maintenance Reduction for Known Spending Containment". Please explain each item that is
par of the Company's proposed spending containment by stating the amount of each items
contribution to the $3,834,000, the nature of the containment, a description of the reduction, and
state if the reduction is expected to be permanent or a method of reduction because of timing the
expense. If the cost containment effort was allocated to various deparments, please provide
spreadsheets or other documentation that explains the allocation methodology.
REQUEST NO. 26: Please provide a description of all cost containment programs the
Company has instituted over the last 5 years and a description of all cost containment programs
the Company is currently or anticipates instituting through 2009. Include in this description any
company directive or policy that directs the reduction of expenses incurred by the Company.
Please document the results of prior-year cost containment programs and explain how the
Company determined whether these cost containment programs were effective. Explain in detail
any cost containment efforts initiated in 2008 or 2009 that are intended to reduce 2009 expenses.
Include in this explanation the nature of this effort and provide all documentation (email
communications, memoranda, etc.) that specifically directs the magnitude of cost containment.
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 SEPTEMBER 5, 2008
In addition, please describe any Company bonuses or rewards given to individual employees
who suggest a method of cost containment.
REQUEST NO. 27: Please provide average CAIDI, SAIDI, SAIFI and MAIFI service
quality statistics, by service area, for each month during Calendar Year 2007.
REQUEST NO. 28: Please provide a list of measurements and reports generated with
the Outage Management System. Please provide examples of the reports.
REQUEST NO. 29: Please provide the process used at the time an account is first
established to assign the customer to the appropriate rate schedule. Does this process vary
depending on whether the customer's premises is newly constructed (no previous service) or
establishing new service at an existing location? If so, please explain.
REQUEST NO. 30: How does Idaho Power monitor customer energy usage to ensure
that the assigned rate schedule continues to be appropriate?
REQUEST NO. 31: Please provide the Company's written record of complaints and
requests from the year 2007, kept pursuant to Rule 403 of the Commission's Utilty Customer
Relations Rules (UCRR) IDAPA 31.21.01.403.
REQUEST NO. 32: Ifany of Idaho Power's forms required by the UCRR have been
revised since July of 2007, please provide a copy of those forms and indicate what changes were
made.
REQUEST NO. 33: Company Witness Brilz states in her testimony on page 7 that each
month the Customer Service Administrator prepares complaint reports detailing all contacts with
customers in which the customers were dissatisfied. Please provide copies of that monthly report
for the year 2007 showing the trends and issues that were identified along with the suggested
process or changes that were made as a result.
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 SEPTEMBER 5, 2008
REQUEST NO. 34: Company Witness Brilz on page 10 of her testimony stated that a
position entitled "Customer Service Specialist" was created to facilitate focused communication
with customers during outages and to allow dispatch personnel to more fully focus on
communications with field personnel during outages. How many Customer Service Specialist
positions were created? Are all positions currently filled? Please provide a job description of
that position.
REQUEST NO. 35: Please provide data demonstrating that Idaho Power's Outage
Management Tool is able to restore service more quickly after an outage, e.g. a comparison of
restoration times for twelve months after installation with the twelve months immediately
preceding installation.
REQUEST NO. 36: Please provide justification for allowing a third-part vendor to
charge customers convenience fees to process payments using a credit card or check by phone.
In light of the requested rate increase, has the Company considered increasing the dollar amount
cap per transaction (i.e. some customers currently are required to initiate multiple transactions
and pay multiple vendor fees in order to pay one bil)? If so, please explain. If not, why not?
Additionally, please provide by month the average number of monthly users in 2007 and how
many of those users were paying more than one fee to pay one bilL.
REQUEST NO. 37: On page 17 of Company Witness Brilz testimony, there is a
reference to the new tools that Idaho Power purchased to assist in the development of more
reliable infrastructue designs. What are those tools, and how have those tools brought about
more reliable service?
REQUEST NO. 38: Please explain the factors that have, according to Company witness
Waites, page 7, contributed to the average non-summer marginal power supply cost rising faster
than the average marginal power cost in the summer since 2003.
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 SEPTEMBER 5, 2008
REQUEST NO. 39: Please provide separate bil frequency analyses that support the
tiered rates proposed for each of the residential customer classes referenced in Company witness
Waites' testimony.
REQUEST NO. 40: Please provide any analysis the Company has performed in support
of the on-, mid-, and off-peak rate differentials for Schedule 5 customers
REQUEST NO. 41: In light of the Company's proposal to implement tiered rates in
non-summer months, what rate mitigation or assistance options has the Company considered to
assist low income customers, specifically those using electric heat in the winter?
DATED at Boise, Idaho, this 5..1, day of September 2008...
~-=~,N~ ""
Deputy Attorney General
Technical Staff: Joe Leckie/25 - 26
John Nobbs 27 - 28
Marilyn Parker/29 - 37
Bryan Lanspery 38 - 41
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THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 5 SEPTEMBER 5, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF SEPTEMBER 2008,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-08-1O, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bkline(ßidahopower.com
lnordstrom(ßidahopower .com
dwalker(ßidahopower .com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(ßrichardsonandoleary.com
RANDALL C BUDGE
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(ßracinelaw.net
elo(ßracinelaw.net
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurz(ßBKLlawfrm.com
kboehm(ßBKLlawfirm.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(ßhotmail.com
JOHNRGALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: rga1e(ßidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(ßmindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: yanel(ßattbi.com
KEVIN HIGGINS
ENERGY STRATEGIES LLC
PARKS IDE TOWERS
215 S STATE ST STE 200
SALT LAKE CITY UT 84111
E-MAIL: khiggins(ßenergystrat.com
LOTH COOKE
ARTHUR PERRY BRUDER
UNITED STATE DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: lot.cooke(ßhg.doe.gov
arhur. bruder(ßhg .doe. gov
CERTIFICATE OF SERVICE
DWIGHT ETHERIDGE
EXETER ASSOCIATES INC
5565 STERRTT PLACE, SUITE 310
COLUMBIA MD 21044
E-MAIL: detheridge(ßexeterassociates.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
1500 LIBERTY STREET SE, SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(ßexcite.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 WBANNOCKST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(ßgivenspursley.com
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmiler(ßsnakeriverallance.org
SECREi:y~~""
CERTIFICATE OF SERVICE