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Home My WebLink About20110720Staff 6-30 to IPC.pdfDONALD L. HOWELL, II KARL T. KLEIN DEPUTY ATTORNEYS GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NOS. 3366/5156 RECE ED 1m I JUL 20 PM 2: 38 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorneys 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 IN IDAHO. ) ) ) ) CASE NO. IPC-E-11-8 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilties Commission, by and through its attorneys of record, Donald L. Howell, II and Karl T. Klein, Deputy Attorneys General, requests that Idaho Power Company (Company; IPC) provide the following documents and information as soon as possible, but no later than WEDNESDAY, AUGUST 10,2011. This Production Request is to be considered as continuing, and Idaho Power Company 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 or information 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 SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY JULY 20, 2011 the person preparing the documents. Please identify the name, job title, location and telephone number of the record holder. In addition to the written copies provided as response to the requests, please provide all Excel and electronic fies on CD with formulas activated. REQUEST NO.6: Please provide executable electronic copies of Idaho's monthly energy usage by class and rate schedule from 2000 through 2010. As part of your response, please include median and average energy usage by class and rate schedule over the same time frame. REQUEST NO.7: Please provide executable electronic copies ofIdaho's monthly customer count by class and rate schedule from 2000 through 2010. REQUEST NO.8: Please provide all executable electronic models used to arive at the "2011 Unadjusted Test Year" revenue. As par of the response, please include a detailed explanation of all the modeling variables, and provide the descriptive statistics used to evaluate the predictive accuracy of each modeL. If third party economic or demographic projections were utilzed, please provide all the data used for the forecasts and the names of the primar data vendors. REQUEST NO.9: On page 3 of Larkin's testimony, he describes how the number of customers and energy were developed for the 2011 test year. He states, "the 2011 test year customer and kWh sales forecast is based upon the Sales and Load Forecast prepared for the 2011 Integrated Resource Plan ("IRP"), to be fied with the commission in June 2011." Please provide: a. An explanation of why the Company chose to use the 2011 IRP to develop the 2011 test year energy biling determinants. b. An explanation of why the Company used more than weather related variables to develop the 2011 test year energy billng determinants. c. All executable electronic models used to adjust Idaho's actual 2010 number of customers and kWh sales. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 JULY 20, 2011 d. An explanation of all the modeling variables and descriptive statistics used to evaluate the predictive accuracy of each modeL. e. All third pary economic or demographic data used for the forecasts and the names of the primary data vendors. REQUEST NO. 10: On pages 4-5 of Exhibit No. 27, the Company describes how it adjusts its system forecast based on jursdictional split factors that were calculated using only the largest schedules in each class; please provide a detailed explanation of why it chose not to calculate the split factors based on all the schedules within each class. In addition, please provide: a. All the executable electronic models used to develop the jurisdictional split factors. b. Exhibit No. 45 with the jurisdictional split factors calculated using all the rate schedules within each class. c. Exhibit No. 38 with the jurisdictional split factors calculated using all the rate schedules within each class. REQUEST NO. 11: Please explain how the Company adjusted the test period loads, incentive payments, and administrative costs to account for changes to the Irrgation Peak Rewards Program (Order No. 32200). REQUEST NO. 12: Please provide by month from August 2008 through December 2010, the total number of incoming calls handled by the Customer Service Call Center (CSC). Please identify separately the calls routed through the Automated Call Distribution (ACD), as well as the Interactive Voice Response Unit (lVRU). REQUEST NO. 13: Please provide by month the actual service levels for the CSC attained from August 2008 through December 2010. Please provide ACD and IVRU separately. REQUEST NO. 14: Please provide by month from July 2007 through December 2010 the total number of abandoned calls for the CSC. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 JULY 20, 2011 REQUEST NO. 15: Please provide by month from July 2007 through December 2010, the percentage of calls abandoned by the CSC. REQUEST NO. 16: Please provide by month from August 2008 through December 2010 the average speed-of- answer, in seconds, by customer service representatives in the CSC. REQUEST NO. 17: Please provide by month from August 2008 through December 2010 the total number of emails received by the Company's Webmail group in the CSC. Also provide the average response time in those months. REQUEST NO. 18: Please provide by month from July 2007 through December 2010 the total number of Outage Management Department calls handled by the ACD. Please provide separately the total number of calls handled by the IVRU. REQUEST NO. 19: Please provide by month from July 2007 through December 2010 the total number of calls abandoned by the Outage Management Deparment. REQUEST NO. 20: For those same months referenced in Production Request No. 20, please provide the percent of calls that are abandoned. REQUEST NO. 21: In Case No. IPC-E-08-1O, Idaho Power responded to Staff Production Request No. 36 that it had selected Western Union's Speedpay, Inc. to begin processing electronic payments as of January of2009. According to Idaho Power, at that time, the new fee per transaction for residential customers was going to be $2.50 for check-by-phone, credit cards or debit cards for up to $500. Has Idaho Power changed any of its transaction fees or payment processing options or vendors since that time? If so, please provide those details. REQUEST NO. 22: How many customers in 2008, 2009, and 2010 used Idaho Power's on-demand electronic payment options? Please provide the information by type of payment SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 JULY 20,2011 option, i.e. credit card, debit card, check by phone. This information can be provided in yearly totals. REQUEST NO. 23: Please provide the Company's written record of complaints and requests from the years 2008, 2009, and 2010 kept pursuant to Rule 403 of the Commission's Utility Customer Relations Rules (UCRR) IDAPA 31.21.01.403. The following questions pertain to the testimony of Company Witness Waren Kline: REQUEST NO. 24: On page 4 Witness Kline states that investments in Advanced Metering Infrastructure (AMI) and Mobile Workforce Management (MWM) have allowed IPC to alter procedures and focus on interactions with customers. Please explain in detail what procedures have been altered and the resulting changes which allowed more focus on interactions with customers. REQUEST NO. 25: On page 11 Witness Kline states that once the Outage Management System (OMS) is fully integrated with AMI, valuable data wil be available that wil result in more efficient and timely restoration of power to customers. Please explain in detail what "valuable data" wil be available and how this data wil be used by the Company and/or customers. REQUEST NO. 26: On page 12 Witness Kline says the Customer Information System (CIS) project upgrades and enhances existing functions and adds key capabilties that will faciltate more flexible pricing options. Please describe in detail the pricing options referenced. REQUEST NO. 27: On page 20 Witness Kline states that IPC intends to offer more automated customer service options in the future? Please provide examples of those services. REQUEST NO. 28: On page 25 Witness Kline discusses the 3rd pary Language Line utilzed by IPCO. In 2008, 2009, and 2010 how many times was this service utilzed by SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 JULY 20,2011 customers? Please provide the totals by language. What was the cost of this service per call in each of those years? REQUEST NO. 29: On page 28 Witness Kline refers to "virtual hold" and "call me". Please describe in more detail these two features. REQUEST NO. 30: On page 28 Witness Kline says that a no fee online ban debiting payment option wil be available in August of 20 11. Please describe the steps a customer would take to use this option. DATED at Boise, Idaho, this ZÓ-fL day of July 201 1. ~~t ;7 Kî.'Kïein Deputy Attorney General Technical Staff: Matt Elam6-11 Marilyn Parker/12-30 i:umisc:prodreq/ipcel 1 .8dhkk prod req 2.doc SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 6 JULY 20,2011 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF JULY 2011, SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-II-08, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: LISA D NORDSTROM DONOV AN E WALKER JASON B WILLIAMS IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: lnordstromØ2idahopower.com dwalker((idahopower.com jwilliams((idahopower.com CBearyØ2idahopower .com myoungblood((idahopower.com PETER J RICHARDSON GREGORY MADAMS RICHARDSON & O'LEARY PO BOX 7218 BOISE ID 83702 E-MAIL: peter((richardsonandolear.com gregØ2richardsonandoleary.com ERICLOLSEN RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204 E-MAIL: eloØ2racinelaw.net ARTHUR PERRY BRUDER ATTORNEY -ADVISOR US DEPT OF ENERGY 1000 INDEPENDENCE AVE SW WASHINGTON DC 20585 E-MAIL: Arthur.bruder((hq.doe.gov E-MAIL ONLY: STEVE A PORTER US DEPT OF ENERGY E-MAIL: steven.porter((hq.doe.gov GREGORY W SAID VP REGULATORY AFFAIRS IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: gsaid((idahopower.com DR DON READING 6070 HILL ROAD BOISE ID 83703 E-MAIL: dreading((mindspring.com ANTHONY Y ANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 E-MAIL: tony((yankel.net DWIGHT ETHERIDGE EXETER ASSOCIATES 5565 STERRTT PL STE 310 COLUMBIA MD 20144 E-MAIL: detheridge((exeterassociates.com JOHN R HAMMOND JR BATT FISHER PUSCH & ALDERMAN LLP PO BOX 1308 BOISE ID 83701 E-MAIL: jrh((battfisher.com CERTIFICATE OF SERVICE RICHARD E MALMGREN SR ASST GENERAL COUNSEL MICRON TECHNOLOGY INC 800 S FEDERAL WAY BOISE ID 83716 E-MAIL: remalmgren((micron.com BRAD M PURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ID 83702 E-MAIL: bmpurdy(ihotmail.com KEN MILLER SNAKE RIVER ALLIANCE BOX 1731 BOISE ID 83701 E-MAIL: kmiler((snakeriverallance.org MARY V YORK THORVALD A NELSON MARK A DAVIDSON HOLLAND & HART LLP 6380 S FIDDLERS GREEN CIR STE 500 GREENWOOD VILLAGE CO 80111 E-MAIL: myork(ihollandhart.com tnelson((hollandhar.com mdavidson((hollandhar.com BENJAMIN J OTTO ID CONSERVATION LEAGUE 710N 6TH ST BOISE ID 83702 E-MAIL: botto(iidahoconservation.org KURT JBOEHM BOEHM KURTZ & LOWERY 36 E SEVENTH ST STE 1510 CINCINATI OH 45202 E-MAIL: kboehm((bkllawfrm.com It00 .~ SECRETAR CERTIFICATE OF SERVICE