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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