20080911Staff to IPC 64-88.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
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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
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
FIFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties 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
THURSDAY, OCTOBER 2,2008.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 SEPTEMBER 11, 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 hearng if need be. Reference ID AP A 3 1.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil 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 fies on CD with formulas activated.
REQUEST NO. 64: How many customers utilzed a pay station in each of the past three
calendar years (2005-2007)?
REQUEST NO. 65: How many customers paid their bil at a pay station but then failed
to call in their payment receipt number to Idaho Power and were subsequently disconnected in
each of the past three calendar years (2005-2007)?
REQUEST NO. 66: How are customers who are scheduled for disconnect made aware
of the need to call Idaho Power with a payment receipt number when making a payment at a pay
station?
REQUEST NO. 67: Please provide by rate schedule for Schedules 1 and 7 a monthly
and annual total number of customers for each of the past three calendar years (2005-2007).
REQUEST NO. 68: Please provide by rate schedule for Schedules 1 and 7 a monthly
and anual total number of customers disconnected from service in each of the past three
calendar years (2005-2007).
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 SEPTEMBER 11, 2008
REQUEST NO. 69: What new initiatives have been taen by the Company to provide
assistance to customers who are having trouble paying their bils?
REQUEST NO. 70: Please provide by rate schedule for Schedules 1 and 7 a monthly
and anual total number of customers who entered into a payment arangement agreement for
each ofthe past three calendar years (2005-2007).
REQUEST NO. 71: Please provide by rate schedule for Schedules 1 and 7 a monthly
and anual total number of customers who defaulted on a payment arangement in each of the
past three years (2005-2007)?
REQUEST NO. 72: Please provide by rate schedule for Schedules 1 and 7 a monthly
and anual total number of payment arrangement agreements entered into by the Company for
each ofthe past three calendar years (2005-2007).
REQUEST NO. 73: Please provide by rate schedule for Schedules 1 and 7 a monthly
and anual total number of defaulted payment arangements for each of the past three calendar
years (2005-2007).
REQUEST NO. 74: Please provide by rate schedule for Schedules 1 and 7 a monthly
and annual total number of customers that participated in the Budget Pay Program in each of the
past three calendar years (2005-2007)?
REQUEST NO. 75: Please provide by rate schedule for Schedules 1 and 7 a monthly
and annual total number of customers that dropped out of the Budget Pay Program in each of the
past three calendar years (2005-2007)?
REQUEST NO. 76: Please provide by rate schedule for Schedules 1 and 7 a monthly
and anual number of customers that paricipated in the Levelized Pay Program in each of the
past three calendar years (2005-2007).
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 SEPTEMBER 11, 2008
REQUEST NO. 77: Please provide by rate schedule for Schedules 1 and 7 a monthly
and anual total number of customers that were unable to keep their levelized payment
arangement and were subsequently disconnected from service in each of the past three calendar
years (2005-2007).
REQUEST NO. 78: For each of the past three calendar years (2005-2007), please
provide the total dollar amount contributed to Project Share for Idaho customers by: a) Idaho
Power shareholders; b) Idaho Power employees; c) contributions from Idaho customers; and, d)
other sources.
REQUEST NO. 79: What was the total dollar amount received by Idaho Power Idaho
customers from Project Share in each of the past three calendar years (2005-2007)?
REQUEST NO. 80: What was the total dollar amount raised for Project Share through
your parnership with a local coffee company in each of the past two calendar years (2006-
2007)?
REQUEST NO. 81: Other than Project Share, did the Company or its shareholders
contribute to community-based organizations for the purpose of providing services to or paying
energy bils of low-income customers in Idaho? If so, please identify the organization and the
dollar amount contributed by Idaho Power in each of the past three calendar years (2005-2007).
REQUEST NO. 82: Does Idaho Power have any in-house programs that assist low-
income customers or customers needing more personalized attention? If yes, please describe the
programs and the dollar amount, if any, that have been collected for bil payment assistance in
each of the past three calendar years (2005-2007)?
REQUEST NO. 83: What programs, if any, are offered by Idaho Power that wil assist
customers who wil have higher bils under the proposed tiered rate structure than under the
curent rate structure?
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 SEPTEMBER 11, 2008
REQUEST NO. 84: What programs will be implemented to offer targeted assistace for
customers with electric space heat?
REQUEST NO. 85: How many Idaho customers were signed up for moratoriumwinter
protection from disconnection in each of the last three calendar years (2005-2007)?
REQUEST NO. 86: How many of those customers who declared the need for
moratoriumwinter protection were placed on the Winter Payment Plan?
REQUEST NO. 87: How many customers on the Winter Payment Plan were not able to
meet the monthly payment in each of the last three calendar years (2005-2007)?
REQUEST NO. 88: How does Idaho Power educate and inform customers of the
availabilty of protection from disconnection during winter months and availabilty of the Winter
Payment Plan? Please provide copies of any wrtten brochures or documents sent or otherwse
provided to customers.
DATED at Boise, Idaho, tI~ ~ day of September 2008.
A~(-
Neil Price
Deputy Attorney General
Technical Staff: Curtis Thaden/64 - 88
i: umisc:prodreqfipce08.1 Owsnpct prod req5
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 SEPTEMBER 11, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11 TH DAY OF SEPTEMBER 2008,
SERVED THE FOREGOING FIFTH 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(gidahopower.com
lnordstrom(gidahopower .com
dwalker(gidahopower.com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(grichardsonandoleary.com
RANDALL C BUDGE
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(gracinelaw.net
elo(gracinelaw.net
MICHAEL L KURTZESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurtz(gBKLlawfrm.com
kboehrn(gBKLl awfirrn. corn
BRAD M PURDY
ATTORNEY AT LAW
2019N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(ghotrnail.com
JOHNRGALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: rgale(gidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(grnindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: yankel(fattbi.com
KEVIN HIGGINS
ENERGY STRATEGIES LLC
PARKS IDE TOWERS
215 S STATE ST STE 200
SALT LAKE CITY UT 84111
E-MAIL: khiggins(genergystrat.com
LOTH COOKE
ARTHUR PERRY BRUDER
UNITED STATE DEPT OF ENERGY
1 000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: lot.cooke(ghq.doe.gov
arhur. bruder(fhq.doe. gov
CERTIFICATE OF SERVICE
DWIGHT ETHERIDGE
EXETER ASSOCIATES INC
5565 STERRTT PLACE, SUITE 310
COLUMBIA MD 21044
E-MAIL: detheridge(Ðexeterassociates.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
1500 LIBERTY STREET SE, SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(Ðexcite.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 WBANNOCKST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(Ðgivenspursley.com
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kriler(fsnakeriverallance.org
..~SECRETARY -
CERTIFICATE OF SERVICE