20110808Staff 153-170 to IPC.pdf

DONALD L. HOWELL, II
KARL T. KLEIN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NOS. 3366/5156
RECEIVED
lOll AUG -8 PM 3: S9
I'D". 11('.IIT 'Ji'.,n,,), 'I 11-1'..'"~., ¡ k i:.~)
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
NINTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities 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 MONDAY, AUGUST 29, 2011.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementar 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 preparng the documents. Please identify the name, job title, location and telephone
number of the record holder.
NINTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 8, 2011
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. 153: Please provide the number of Idaho accounts that received Low
Income Home Energy Assistance Program (LIHEAP) assistance and were signed up for
Moratorium protection from disconnection by month, for each of the past three winter heating
seasons (2008/2009, 2009/2010, 2010/2011).
REQUEST NO. 154: For those accounts identified in your response to Request No. 153
(previous question), please provide the number and percentage of those accounts that were
placed on the Winter Payment Plan by month.
REQUEST NO. 155: For those accounts identified in your response to Request No. 154
(previous question), please provide the number and percentage of those accounts that defaulted
on the Winter Payment Plan by month.
REQUEST NO. 156: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1,4,5 and 7: (a) the monthly and annual total number of
accounts in arrears, and (b) the monthly and anual total dollar amount in arears.
REQUEST NO. 157: For those accounts identified in your response to Request No. 156
(previous question) that received LIHEAP assistance, please provide: (a) the monthly and anual
total number of accounts in arears, and (b) the monthly and anual total dollar amount in
arrears.
REQUEST NO. 158: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1,4,5 and 7: (a) the monthly and anual total number of
accounts sent past due notices and, (b) the monthly and anual total past due dollar amount
owed.
NINTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 8, 2011
REQUEST NO. 159: For those accounts identified in your response to Request No. 158
(previous question) that received LIHEAP assistance, please provide: (a) the monthly and anual
total number of accounts sent past due notices, and (b) the monthly and annual total past due
dollar amount owed.
REQUEST NO. 160: 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 sent final disconnect notices.
REQUEST NO. 161: For those accounts identified in your response to Request No. 160
(previous question) that received LIHEAP assistance, please provide the monthly and anual
total number of accounts sent final disconnect notices.
REQUEST NO. 162: For each of the past thee calendar years (2008-2010), please
provide by rate schedule for Schedules 1, 4, 5 and 7 the monthly and annual total dollar amount
owed at disconnect.
REQUEST NO. 163: For those accounts identified in your response to Request No. 162
(previous question) that received LIHEAP assistance, please provide the monthly and anual
total dollar amount owed at disconnect.
REQUEST NO. 164: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1,4,5 and 7: (a) the monthly and annual total number of
accounts that were disconnected and reconnected the same day, and (b) monthly and annual total
number of accounts reconnected within one week.
REQUEST NO. 165: For those accounts identified in your response to Request No. 164
(previous question) that received LIHEAP assistance, please provide: (a) the monthly and anual
total number of accounts that were disconnected and reconnected the same day, and (b) monthly
and anual total number of accounts reconnected within one week.
NINTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 8, 2011
REQUEST NO. 166: For each of the past three calendar years (2008-2010), please
provide by rate schedule for Schedules 1,4,5 and 7: (a) the monthly and anual total dollars
written off (gross), and (b) the monthly and anual total dollars written off due to customer
banptcy.
REQUEST NO. 167: For those accounts identified in your response to Request No. 166
(previous question) that received LIHEAP assistace, please provide: (a) the monthly and anual
total dollars written off (gross), and (b) the monthly and anual total dollars written off due to
customer banptcy.
REQUEST NO. 168: 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 kWh biled.
REQUEST NO. 169: For those accounts identified in your response to Request No. 168
(previous question) please provide the monthly and anual total kWh biled for accounts that
received LIHEAP assistance.
REQUEST NO. 170: Pursuant to Utilty Customer Relations Rule (UCRR) 308.03, in
2008, 2009 and 2010, how many medical certificates were received by the Company? Of those
certificates received, how many requests for an extension of time to pay were granted in each of
those years?
DATED at Boise, Idaho, this &-t'!: day of August 2011.
::'(jliL
Karl T. Klein
Deputy Attorney General
Technical Staff: CT1153-169
MPI170
i:umisc:prodreq/ipcell.8dhk prod req 9
NINTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 AUGUST 8, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8TH DAY OF AUGUST 2011,
SERVED THE FOREGOING NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-11-08, BY
E-MAILING AND 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: lnordstrom(iidahopower.com
dwalker(iidahopower .com
jwillams(iidahopower .com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(Ðrichardsonandolear.com
greg(Ðrichardsonandolear .com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elo(Ðracinelaw.net
ARTHUR PERRY BRUDER
ATTORNEY -ADVISOR
US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: Arthur.bruder(ihq.doe.gov
GREGORY W SAID
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: gsaid(Ðidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(imindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(Ðyanel.net
DWIGHT ETHERIDGE
EXETER ASSOCIATES
10480 LITTLE PATUZENT PKWY
STE 300
COLUMBIA MD 21044
E-MAIL: detheridge(iexeterassociates.com
CERTIFICATE OF SERVICE
E-MAIL ONLY:
STEVE A PORTER
US DEPT OF ENERGY
E-MAIL: steven.porter(Ðhq.doe.gov
KURT JBOEHM
BOEHM KURTZ & LOWERY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: kboehm(ibkllawfrm.com
E-MAIL ONLY:
RICHARD E MALMGREN
SR ASST GENERAL COUNSEL
MICRON TECHNOLOGY INC
E-MAIL: remalmgren(Ðmicron.com
E-MAIL ONLY:
THORV ALD A NELSON
MARK A DAVIDSON
FRED SCHMIDT
HOLLAND & HART LLP
E-MAIL: tnelson(ihollandhar.com
madavidson(ihollandhar.com
fschmidt(ihollandhart.com
lnbuchanan(Ðhollandhart.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: botto(iidahoconservation.org
NANCY HIRSH
POLICY DIRECTOR
NW ENERGY COALITION
811 1 ST AVE., SUITE 305
SEATTLE W A 98104
E-MAIL: nancy(Ðnwenergy.org
E-MAIL ONLY:
JOHN R HAMMOND JR
BATT FISHER PUSCH
& ALDERMAN LLP
E-MAIL: jrh(Ðbattfisher.com
KEVIN HIGGINS
ENERGY STRATEGIES
215 S. STATE ST SUITE 200
SALT LAKE CITY UT 84111
E-MAIL: khiggins(ienergystrat.com
ELECTRONIC! CD! PAPER SERVICE
MARY V YORK
HOLLAND & HART LLP
101 S. CAPITAL BLVD., SUITE 1400
BOISE, ID 83702
E-MAIL: myork(Ðhollandhar.com
BRAD MPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ihotmaiL.com
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: kmiler(Ðsnakeriverallance.org
il.\~
SECRE ARY
CERTIFICATE OF SERVICE