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Home My WebLink About20081016IPC to Staff 116, 119.pdfBARTON L. KLINE Lead Counsel 1SIDA~POR~ An IDACORP Company October 15, 2008 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-08-10 General Rate Case Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power Company's Supplemental Response to the Seventh Production Request of the Commission Staff. Upon receipt of this filing, I would appreciate it if you would return a stamped copy of this letter for my file in the enclosed stamped, self-addressed envelope. Very truly yours,~fJ'1~~ Barton L. Kline Lead Counsel for Idaho Power Company BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise. ID 83702 BARTON L. KLINE, ISB #1526 LISA D. NORDSTROM, ISB #5733 DONOVAN E. WALKER, ISB #5921 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 Facsimile: (208) 388-6936 bkline(âidahopower.com Inordstrom(âidahopower.com dwalker(âidahopower.com RECEI 0 2008 OCT 15 PH 5: 02 IOAH'O P'I':"L""'"'/', ì .rl.~)¡v UTILITIES COMMISSION Attorneys for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MA TIER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC SERVICE. ) ) CASE NO. IPC-E-08-10 ) ) ) ) ) ) ) IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"), and in supplemental response to the Seventh Production Request of the Commission Staff to Idaho Power Company dated September 26, 2008, herewith submits the following information: IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 SUPPLEMENTAL REQUEST NO. 116: In IPC-E-08-10, Idaho Power's response to staffs P.R. 116 regarding the Rebate Advantage program said that four denial letters were sent because the home was not Energy Star, three denial letters were sent because the home was not electrically heated, and four letters were sent because the home was not located in IPC's service territory. Sample denial letters were provided on a CD, but with dealer, customer and IPC program specialist names excluded. Please provide "confidential" copies of each of the 11 denial letters sent by Idaho Power with all names included. (From e-mail dated October 10, 2008.) SUPPLEMENTAL RESPONSE TO REQUEST NO. 116: Please find enclosed confidential copies of the 11 denial letters. In keeping with Company policy, these are marked as confidential to maintain the privacy of program participants. The response to this Request was prepared under the direction of Theresa Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 SUPPLEMENTAL REQUEST NO. 119: In IPC-E-08-10, Idaho Powets response to staffs P.R. 119 included complaints from AC Cool Credit participants who claimed that their AC units required a service call (or their bird died) due to faulty installation of the AC switch and/or inappropriate inclusion of their home in this program. Are Idaho Powets payments for such claims distinctly listed in response to staffs P.R. 89? If so, please identify such. If not, please provide this information. Also, please provide the costs of damages and customer-initiated return visit calls incurred by Idaho Power's contractors for which Idaho Power did not reimburse those costs, to the extent this information is available to Idaho Power. SUPPLEMENTAL RESPONSE TO REQUEST NO. 119: In Staffs Request No. 119, it requested complaints and inquiries to Idaho Power or its contractors in 2007 and 2008 regarding the AlC Cool Credit. In 2007 and 2008 Idaho Power has paid very few of the actual mitigation cost incurred by the AlC Cool Credit program because of customer service calls, faulty switch installation, and/or inappropriate inclusion of the home in the program. As stated in the Response to Staffs Request No. 119, Idaho Power has contracted with a third-part contractor ("Contractor") to install cycling switches and supply call center support for the program. Idaho Power's Contractor assumes the liability for problems caused by their installation or customer service. Occasionally Idaho Power pays the customer directly and then is reimbursed by the Contractor. Idaho Power does reimburse or partially reimburses customers for an installation or customer service problem that is assessed as being caused by Idaho Power and outside of the Contractor's control or responsibility. According to Idaho Power's records, in 2007 the Company paid $195.88. These funds were accounted for IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 under Other Expenses in the spreadsheet, Demand Side Management Expenses Re Idaho Rider, provided in response to Staffs Request No. 89. In 2008, according to Company records, Idaho Power paid $385 to customers for mitigation. These funds were not included in the response to Staffs Request No. 89 because Staff asked for the costs associated with the programs included in Appendix 4 of Idaho Power's Demand- Side Management 2007 Annual Report which span 2003 to 2007. Idaho Power does not track the costs of damages and customer-initiated return visit calls incurred by Idaho Power's contractors for which Idaho Power or the Contractor did not reimburse those costs. The response to this Request was prepared under the direction of Theresa Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 15th day of October 2008. ~ ittlrddM l BARTON L. KLIN Attorney for Idaho Power Company LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 15th day of October 2008 I served a true and correct copy of IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Weldon B. Stutzan Deputy Attomey General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Neil Price Deputy Attomey General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson, Esq. RICHARDSON & O'LEARY PLLC 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 Dr. Don Reading Ben Johnson Associates 6070 Hil Road Boise, Idaho 83703 Idaho Irrigation Pumpers Association, Inc. Randall C. Budge Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 201 East Center Pocatello, Idaho 83204-1391 -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Weldon.stutzman(âpuc.idaho.gov -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Neil.price(âpuc.idaho.gov Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email peter(ârichardsonandoleary.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email dreading(âmindspring.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email rcb((racinelaw.net elo((racinelaw. net IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Kroger Co. I Fred Meyer and Smiths Michael L. Kurt Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 The Kroger Co. Attn: Corporate Energy Manager (G09) 1014 Vine Street Cincinnati, Ohio 45202 Kevin Higgins Energy Strategies, LLC Parkside Towers 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Micron Technology Conley Ward Michael C. Creamer GIVENS PURSLEY, LLP 601 West Bannock Street P.O. Box 2720 Boise, Idaho 83701-2720 Dennis E. Peseau, Ph.D. Utility Resources, Inc. 1500 Libert Street SE, Suite 250 Salem, Oregon 97302 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email tony((yankel.net Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email mkurt((BKLlawfrm.com kboehm((BKLlawfrm.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX Email Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email khiggins((energystrat.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email cew((givenspursley.com mcc((givenspursley.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email dennvtemp((yahoo.com IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 Departent of Energy Lot R. Cooke Arthur Perry Bruder Offce of the General Counsel United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Routing Symbol GC-76 Hand Delivered U.S. Mail -- Overnight Mail FAX -- Email Lot.Cooke((hg.doe.gov Arthur.Bruder((hg.doe.gov Dwight D. Etheridge Exeter Associates, Inc. 5565 Sterrett Place, Suite 310 Columbia, MD 21044 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email detheridge((exeterassociates.com Community Action Partership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 17th Street Boise, Idaho 83702 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email bmpurdy((hotmail.com Snake River Alliance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email kmiler((snakeriverallance.org cL ll 7b~fx tBarton L. Kline. IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7