HomeMy WebLinkAbout20110727Staff 34-76 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
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
RECEI\/ED
2011 JUl27 Ai" 9= 28
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
FOURTH 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 17,2011.
This Production Request is to be considered as continuing, and the 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 wil 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
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 27, 2011
In addition to the wrtten copies provided as response to the requests, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 34: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1, 4, 5 and 7 the monthly and anual total number of
accounts.
REQUEST NO. 35: For those accounts identified in your response to Request No. 34
(previous question), please provide the monthly annual total number of accounts that received
Low Income Home Energy Assistance Program (LIHEAP) assistance.
REQUEST NO. 36: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1, 4, 5 and 7 the anual total number of accounts
disconnected from service for non-payment. If the Company is unable to provide the number of
accounts disconnected for non-payment, please explain.
REQUEST NO. 37: For those accounts identified in your response to Request No. 36
(previous question), please provide the annual total number of accounts that received LIHEAP
assistance.
REQUEST NO. 38: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1,4,5 and 7: (a) the anual total number of accounts
with payment arangements, and (b) the annual total number of payment arangements made on
accounts.
REQUEST NO. 39: For those accounts identified in your response to Request No. 38
(previous question), please provide: (a) the total anual number and percentage of accounts that
defaulted on payment arangements, and (b) the total anual number and percentage of payment
arangements that were not kept.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 27, 2011
REQUEST NO. 40: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1,4,5 and 7: (a) the anual total number of accounts
with payment arangements that received LIHEAP assistance, and (b) the anual total number of
payment arangements made on accounts that received LIHEAP assistance.
REQUEST NO. 41: For those accounts identified in your response to Request No. 40
(previous question), please provide: (a) the total annual number and percentage of accounts that
defaulted on payment arangements, and (b) the total anual number and percentage of payment
arangements that were not kept.
REQUEST NO. 42: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1, 4, 5 and 7 the anual total number of accounts that had
payment arrangements: a) less than six months, and b) 6-12 months. How many and what
percentage of those accounts defaulted on payment arangements anually? Of those accounts
that defaulted, how many were subsequently disconnected for non-payment annually?
REQUEST NO. 43: For those accounts identified in your response to Request No. 42
(previous question), please provide the anual total number of accounts that received LIHEAP
assistace that had payment arangements for each of the following time periods: a) less than six
months, and b) 6-12 months. How many and what percentage of those accounts defaulted on
payment arangements anually? Of those accounts that defaulted, how many were subsequently
disconnected for non-payment anually?
REQUEST NO. 44: Please describe in detail any new payment plans and/or payment
arangement options that the Company has offered to residential customers over the past three
calendar years (2008-2010) and YTD 2011. If the Company has not offered such plans or
options, please state whether the Company has considered implementing payment plans and/or
payment arrangement options with greater flexibilty for those customers with high arearages
coming out of the winter heating season. If the Company has not considered implementing such
plans and/or options, please explain why not.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JULY 27, 2011
REQUEST NO. 45: During the past three calendar years (2008-2010) and YTD 2011,
did the Company terminate or modify any payment plans or payment arangement options? If
yes, please explain.
REQUEST NO. 46: Please explain in detail any new initiatives and/or communications
that have been undertaken by the Company to assist customers who are having trouble paying
their bils. If none, please explain.
REQUEST NO. 47: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1,4,5 and 7: (a) the anual total number of accounts with
deposits; (b) the average annual percentage of accounts with deposits; and (c) the deposit dollar
amount on accounts.
REQUEST NO. 48: For each of the past three calendar years (2008-2010) for those
accounts that received LIHEAP assistance, please provide by rate schedule for Schedules 1, 4, 5
and 7: (a) the anual total number of accounts with deposits; (b) the average anual percentage
of accounts with deposits; and (c) the deposit dollar amount on accounts.
REQUEST NO. 49: By month, for each of the past three winter heating seasons
(2008/2009,2009/2010,2010/2011), how many Idaho accounts were signed up for Moratorium
protection from disconnection?
REQUEST NO. 50: For those accounts identified in your response to Request No. 49
(previous question) by month, how many and what percentage of those accounts were placed on
the Winter Payment Plan?
REQUEST NO. 51: For those accounts identified in your response to Request No. 50
(previous question) by month, how many and what percentage of those accounts defaulted on the
Winter Payment Plan?
REQUEST NO. 52: Please explain the Company's efforts to promote Project Share.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JULY 27, 2011
REQUEST NO. 53: Please identify and explain the Company's types of advertising
(radio, tv, bil insert, welcome kit, etc.) in Idaho to inform and educate customers about: 1)
energy assistance and bil payment options; 2) Project Share, 3) energy conservation; and 3)
Winter Moratorium and the Winter Payment Plan. In addition, please provide copies of any
written brochures or documents sent or otherwse provided to customers for each defined
category listed in this question.
REQUEST NO. 54: Does the Company feel it adequately addresses the needs of its low
income, special needs and elderly customers? Please explain.
REQUEST NO. 55: For each of the past three calendar years (2008-2010), please
provide the following: (a) the total number of Idaho homes weatherized using Idaho Power
funds, and (b) the total dollar amount paid by Idaho Power to each of the five Community Action
Agencies for weatherization and administrative costs.
REQUEST NO. 56: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1 and 7 the number of accounts that were determined to
be on the incorrect rate schedule. Of those accounts, how many were rebiled?
REQUEST NO. 57: Does the Company routinely physically disconnect service after a
customer requests closure of an account? If so, in 2010, what were the average and maximum
intervals in days between the receipt of the customers' requests and the actual disconnections of
service? Please provide this information by rate schedule.
REQUEST NO. 58: Please provide the number of Idaho customer-requested account
closures in 2010. Please provide this information by rate schedule.
REQUEST NO. 59: In 2010, how many meters did the Company physically disconnect
following a customer-requested account closure? Please provide this information by rate
schedule.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 JULY 27,2011
REQUEST NO. 60: For those customer-requested account closures in 2010, what
percent did the Company complete: a) within 3 calendar days; b) within 4-5 calendar days; and,
c) took longer than 5 calendar days? Please provide this information by rate schedule.
REQUEST NO. 61: If the Company leaves on meters between occupants following a
customer-requested account closure, is a meter reading taen when a new tenant moves in? If
not, please explain.
REQUEST NO. 62: In situations when the Company does not physically disconnect a
meter between occupants, does the ending meter reading date given on the bil for the deparing
customer correspond to the actual date the meter was read? If not, please explain.
REQUEST NO. 63: In situations when the Company does not physically disconnect a
meter between occupants, does the beginning meter reading date given on the bil for the new
customer correspond to the actual date the meter was read following the new customets request
to initiate service? If not, please explain.
REQUEST NO. 64: The IPUCs Utilty Customer Relations Rules (UCRR) allow a
utilty to rebil a customer for no more than 6 months. This includes instances where bils have
been prepared using estimated usage due to the Company's inabilty to obtan a meter reading.
Please provide copies of letters, notices, messages on biling statements, or telephone scripts
whereby the Company attempts to notify the customer that an actual meter reading has not been
used to calculate the customets bil.
REQUEST NO. 65: When the Company bils a customer using an estimated meter
reading, does the Company highlight or indicate anywhere on the customets biling system that
the usage is estimated? Please provide a sample copy of a customets bil where the Company
estimated meter usage.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 6 JULY 27, 2011
REQUEST NO. 66: What measures does the Company have in place to reduce the
number of consecutive months of estimated meter readings? What is the maximum number of
consecutive months that the Company wil estimate usage?
REQUEST NO. 67: How many customers did the Company rebil in 2010? Please
provide this information by rate schedule, the reason for the rebiling, and the number of months
the customers were rebiled.
REQUEST NO. 68: In 2010, how many customers did the Company rebil for more
than six months?
REQUEST NO. 69: Please provide the job title and associated job description for
Company employees who are authorized to connect or disconnect meters. Can a meter reader
also disconnect or reconnect a meter? If the Company requires that its employees who
disconnect or reconnect service possess a certin level of expertise, please explain what the
required level of expertise entails.
REQUEST NO. 70: What criteria does the Company use to determine if it will grant a
customer a second postponement of disconnection pursuant to UCRR 308.03?
REQUEST NO. 71: Does the Company limit the number of medical certificates to
which a customer or member of the customer's household is entitled over a defined time period?
If so, please explain.
REQUEST NO. 72: The Company recently created a "Customer Representative"
position. These representatives work with customers one-on-one dealing with circumstances that
require special handling. Please provide a job description for this position. How many
Customer Representatives does the Company employ? Where is the employment location of
each Customer Representative?
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 7 JULY 27,2011
REQUEST NO. 73: How many energy audits did Customer Representatives conduct in
2010? Please provide this information by rate schedule and reason for the audit. Do other
Company employees perform energy audits? If so, please provide the same detail requested in
Production Request No. 72 above.
REQUEST NO. 74: Please describe the protocol and provide any written material that a
Customer Representative would use when conducting an energy audit.
REQUEST NO. 75: Does the Company track any demographics regarding the energy
audits completed, such as whether the customers audited are low income, elderly, all electrically
heated homes, residential or commercial? If so, please provide that information for 2010.
REQUEST NO. 76: What criteria does the Company use to determine if it will conduct
an energy audit?
DATED at Boise, Idaho, this 2.':~ day of July 2011.
M~1!
Karl T. Klein
Deputy Attorney General
Technical Staff: Curis Thaden/34-56
Marilyn Parker/57-76
i:umisc:prodreq/ipce i i .8dhkk prod req 4.doc
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 8 JULY 27,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF JULY 2011,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-11-08, 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: lnordstromcmidahopower.com
dwalkercmidahopower.com
jwiliamscmidahopower .com
CBearrcmidahopower.com
myoungbloodcmidahopower.com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: petercmrichardsonandolear.com
gregcmrichardsonandoleary.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204
E-MAIL: eiocmracinelaw.net
ARTHUR PERRY BRUDER
ATTORNEY -ADVISOR
US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: Arthur.brudercmhq.doe.gov
E-MAIL ONLY:
STEVE A PORTER
US DEPT OF ENERGY
E-MAIL: steven.portercmhq.doe.gov
GREGORY W SAID
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: gsaidcmidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadingcmmindspring.com
ANTHONY Y ANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
E-MAIL: tonycmyankel.net
DWIGHT ETHERIDGE
EXETER ASSOCIATES
10480 LITTLE PATUZENT PKWY
STE 300
COLUMBIA MD 21044
E-MAIL: detheridgecmexeterassociates.com
JOHN R HAMMOND JR
BATT FISHER PUSCH
& ALDERMAN LLP
POBOX 1308
BOISE ID 83701
E-MAIL: jrhcmbattfisher.com
CERTIFICATE OF SERVICE
KURT JBOEHM
BOEHM KURTZ & LOWERY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: kboehmcmbkllawfirm.com
RICHARD E MALMGREN
SR ASST GENERAL COUNSEL
MICRON TECHNOLOGY INC
800 S FEDERAL WAY
BOISE ID 83716
E-MAIL: remalmgrencmmicron.com
BRAD M PURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdycmhotmail.com
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: kmilercmsnakeriveralliance.org
KEVIN HIGGINS
ENERGY STRATEGIES
215 S. STATE ST SUITE 200
SALT LAKE CITY UT 84111
E-MAIL: khigginscmenergystrat.com
MARY V YORK
THORV ALD A NELSON
FRED SCHMIDT
HOLLAND & HART LLP
6380 S FIDDLERS GREEN CIR
STE 500
GREENWOOD VILLAGE CO 80111
E-MAIL: myorkcmhollandhar.com
tnelsoncmhollandhart.com
fschmidtcmhollandhart.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: bottocmidahoconservation.org
~Jo~SEcRÊTAr
CERTIFICATE OF SERVICE