20081022CAPAI to IPC 1-16.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th S1.
Boise,ID. 83702
[phone]
FAX: [phone]
bmpurdy(fhotmail.com
Attorney for Petitioner
Community Action Parnership
Association of Idaho
IN THE MATTER OF THE APPLICATION OF
OF IDAHO POWER COMPANY FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE TO ELECTRIC
CUSTOMERS IN THE STATE OF IDAHO
RECEiVED
2008 OCT 22 ~M \1: 34
mAHO
UTtUT1ES
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) CASE NO. IPC-E-08-10
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COMMUITY ACTION
PARTNRSHIP ASSOC-
TIATION OF IDAHO'S
FIRST PRODUCTTION
REQUESTS TO IDAHO
POWER COMPANY
CAPAI, by and through its attorney of record, Brad M. Purdy, requests that Idaho
Power Company provide the following documents and information as soon as possible in
compliance with the Rules of Practice and Procedure of the Idaho Public Utilities
Commission and all Orders and/or Notices issued by the Commission in this case.
This Production Request is to be considered continuing in nature and PacifiCorp
is requested to provide, by way of supplementation, additional documents or responses
that it or any person acting on its behalf may later obtain that will augment the documents
and responses already produced.
For each item, please indicate the name ofthe person(s) preparing the answers,
along with the job title of such person(s) and the witness who can support the answer at
hearing.
PRODUCTION REQUEST TO IDAHO POWER 1
REQUEST NO.1: Please provide the name and title of every Idaho Power
agent or employee who is involved with and/or works on the Company's Low-Income
Weatherization ("LIWA") program.
REQUEST NO.2: For each employee or agent identified in response to the
preceding Request, please specific precisely what tasks and functions said agent or
employee performs with respect to LIW A and provide a hierarchy char outlining levels
of authority and who reports to whom.
REQUEST NO.3: For each agent or employee identified in response to the
preceding Requests, please specify how much of their daily work is exclusively related to
LIW A as opposed to any other fuction.
REQUEST NO.4: How many different positions are allocated within the
LIWA program?
REQUEST NO.5: Of all allocated positions within LIW A, how many are
filled?
REQUEST NO.6: Are there any weatherization measures eligible for LIW A
according to u.s. Deparment of Energy criteria but that Idaho Power refuses to fud? If
the answer is yes, please specify all such measures and explain why the utilty does not
fud them.
REQUEST NO.7: What is the source document that Idaho Power relies upon
to determine which weatherization measures are eligible for Company funding under the
low-income weatherization program?
REQUEST NO.8: Please produce a copy of any source document identified in
response to the preceding Production Request.
PRODUCTION REQUEST TO IDAHO POWER 2
REQUEST NO.9: For each of the past ten years, please identify every year, if
any, that the Community Action Agencies ("CAP"s) who contract with Idaho Power for
LIWA fully exhausted the total anual amount of fuding appropriated for their program?
REQUEST NO. 10: In the case at hand, Idaho Power proposes increasing the
amount of usage subject to the first tier of residential rates for non-sumer months. In
this regard, has the Company made any calculations of the average residential customer's
monthly usage.
REQUEST NO. 11: Has Idaho Power made any calculations or conducted any
analyses of the amount and nature oflow-income residential usage as opposed to non-
low-income residential usage? In answering this, please consider "nature" to include any
identifiable factor such as time of day use, time of year use, purpose of use (e.g., air
conditioning versus hearng, etc.).
REQUEST NO. 12: If the Company has tracked low-income usage as
referenced in the immediately preceding Requests, please explain the criteria used to
define what constitutes a "low-income" customer.
REQUEST NO. 13: In addition to low-income weatherization, please identify
all programs Idaho Power offers that it perceives to be of assistace to its low-income
customers in paying their electrc bil and provide an explanation and itemization of the
nature and degree of assistace provided by any such program.
REQUEST NO. 14: Has the Company tracked its account arearages over the
past five years and, if so, are there any discernible trends (e.g., arearages are increasing
or decreasing). Specifically, please provide any and all calculations and/or analyses the
Company has performed with respect to month by month trends over the past five years.
PRODUCTION REQUEST TO IDAHO POWER 3
REQUEST NO. 15: Please provide the same information sought in Request No.
14 for disconnections due to non-payment and account write-offs including whether the
rate and frequency of these have increased and whether customers are trending toward
increasing untimeliness in paying their bils.
REQUEST NO. 16: Has Idaho Power conducted in cost studies to determine
increases or changes in costs attributable to the non-recovery of bad debt, disconnection
and reconnection fees? Please provide the results of any such studies.
DATED, this 26th day of September, 2008.
L3~-~Brad M. Purdy ~
""."''''
PRODUCTION REQUEST TO IDAHO POWER 4
. l
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of September, 2008, I caused to be
served the foregoing COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF
IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY via
facsimile. Hard copy via U.S. Mail wil follow.
Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington S1.
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: [phone]
Facsimile: [phone]
bkline(qidahopower.com
lnordstrom(qidahopower.com
dwalker(fidahopower.com
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
rgale(qidahopower.com
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson & O'Leary
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(qrichardsonandoleary.com
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
PRODUCTION REQUEST TO IDAHO POWER 5
, l . .
[phone] Tel
[phone] Fax
dreading(qmindspring.com
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
E-mail: rcb(qracinelaw.net
E-mail: elo(qracinelaw.net
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
Fax: [phone]
E-mail: yanel(qattbi.com
Michael L. Kurz, Esq.
Kur J. Boehm, Esq.
BOEHM, KUTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Telephone: [phone] Facsimile: 513-421-2764
E-mail: mkurz(fBKLlawf.com
kboehm(qBKLlawf.com
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lake City, Uta 84111
E-mail: khiggins(qenergystra1.com /7
13- &~~.e ~Brad M. Purdy,
PRODUCTION REQUEST TO IDAHO POWER 6