20110811IPC to Staff 6-30.pdf

JASON B. WILLIAMS
Corporate Counsel
jwilliamscæidahopower.com
'lllWa3POR~
An IDACORP Company
August 10, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
Boise, Idaho 83720
Re: Case No. IPC-E-11-08
General Rate Case
Dear Ms. Jewell:
Enclosed for filng are an original and one (1) copy of Idaho Power Company's
Response to the Second Production Request of the Commission Staff to Idaho Power
Company in the above matter.
Also enclosed are three (3) copies of a non-confidential disk and three (3) copies of
a confidential disk containing information being produced in response to Staffs Second
Production Request.
Please handle the enclosed confidential information in accordance with the
Protective Agreement executed in this matter.
JBW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
R en. b',,....i;.i..
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstromcæidahopower.com
dwalker(Cidahopower.com
jwilliams(Cidahopower.com
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Attorneys for Idaho Power Company
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-11-08
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff to Idaho Power
Company dated July 20, 2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
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.
RESPONSE TO REQUEST NO.6: The attached Excel file contains 11 tabs for
the years 2000 through 2010. For each year, the Idaho monthly energy usage, the
annual total, the median and average energy usage are provided for each rate
schedule.
The response to this Request was prepared under the direction of Mike
Youngblood, Manager, Rate Design, Idaho Power Company, in consultation with Lisa
D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO.7: Please provide executable electronic copies of Idaho's
monthly customer count by class and rate schedule from 2000 through 2010.
RESPONSE TO REQUEST NO.7: The attached Excel file contains 11 tabs for
the years 2000 through 2010. For each year, the Idaho monthly customer count is
provided for each rate schedule. Please note the irrigation customer counts include
inactive irrigation accounts as Idaho Power does not maintain a count of the inactive
irrigation accounts by jurisdiction.
The response to this Request was prepared at the direction of Mike Youngblood,
Manager, Rate Design, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO.8: Please provide all executable electronic models used to
arrive at the "2011 Unadjusted Test Yeat' revenue. As part 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 primary data vendors.
RESPONSE TO REQUEST NO.8: Please see the attached Excel file containing
Exhibit Nos. 28 and 29 in electronic format with supporting workpapers included and
formulas intact. This fie is identical to that provided in the Company's response to the
Idaho Irrigation Pumpers Association Inc.'s Data Request No. 26, with the exception of
an additional worksheet that has been provided at the request of the Idaho Public
Utilties Commission Staff. As demonstrated in the attached Excel file, the "2011
Unadjusted Test Yeat' revenue amount of $850,501,733 was derived by applying the
most current effective base rates to forecasted test year biling components. As
described on page 2 of the Direct Testimony of Company witness Matthew T. Larkin,
lines 22 through 25, "These billng components are derived by applying historical
relationships to the Company's customer and kilowatt-hour ("kWh") sales forecast."
Further, on page 3 of Mr. Larkin's testimony, lines 13 through 15, 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 . . .." The attached Excel file also
contains the entire revenue forecasting process described in Mr. Larkin's testimony,
including the input of the sales and load forecast, the determination of test year biling
components, and the application of rates to derive final test year revenues.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
Modeling variables, descriptive statistics, and third-party data utilzed in the
derivation of the sales and load forecast are addressed in the Company's response to
Staffs Production Request Nos. 9.d and 9.e.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
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 filed 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 billng 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.
d. An explanation of all the modeling variables and descriptive
statistics used to evaluate the predictive accuracy of each modeL.
e. All third part economic or demographic data used for the forecasts
and the names of the primary data vendors.
RESPONSE TO REQUEST NO.9:
a. The sales and load forecast that was prepared for the 2011 Integrated
Resource Plan ("IRP") was the most recent sales forecast to be completed prior to the
filing of Case No. IPC-E-11-08 ("2011 Rate Case"). Because preparation for the 2011
Rate Case coincided with preparation of the 2011 IRP, and because the methodology
for preparing sales and load forecasts for the respective filings does not differ, the
Company was able to utilize the same sales and load forecast for both purposes. The
2011 IRP sales forecast represents the Company's best and most current estimate of
future year sales and customer counts at the time the 2011 Rate Case was prepared.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
b. The sales and load forecast in all future years (including 2011) is
dependent upon both weather and non-weather variables. The most common non-
weather variables are economic time series that are used as drivers to determine future
year sales and customer counts. As shown in the descriptive statistics provided in the
attachments to the Company's response to Staffs Production Request No. 9.d, there
are a number of non-weather variables that are statistically significant in predicting
future sales and customer values.
c. The information requested entails large amounts of data found in
disparate and numerous executable softare applications utilzed to develop the
forecast. Idaho Power's primary and third-part data sources are compiled into multiple
Oracle databases, which occupy approximately 800 megabytes of disk space.
Regression modeling and development of the final forecast occurs primarily in
MetrixND, TSP, and Oracle Express. The executable files associated with data and
modeling require specific database engine and application softare, without which the
files would be unusable. Consequently, Idaho Power wil make these models available
for review at its corporate headquarters. Please contact Doug Jones at [phone]
or Camila Victoria at [phone] to arrange a time to review the requested materiaL.
d. The attached PDF file, "Model Description," provides a narrative
description of the modeling variables utilzed in each regression model in the sales and
customer forecast. The confidential attachments provided on the confidential CD
contain the modeling variables, associated coeffcients, and statistical results of the
regression analyses described in detail in the "Model Description" document. Because
these attachments are confidential, they wil be provided to those parties that have
executed the Protective Agreement. A key describing the explanatory variable
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
abbreviations in the confidential attachments is also attached. The tabs in the
confidential attachments contain the following information:
Tab Name Description
Data Historical/forecast data by variable
Corr Correlation between variables
Coef Coefficients and associated descriptive statistics for each variable
MStat Descriptive statistics for entire model
Elas Elasticity statistics of each explanatory variable
e. Economic variables at the national, state, metropolitan statistical area
("MSA"), and county level were downloaded from Moody's Analytics July 2010
economic forecast. County economic variables were used to develop Idaho Power
service area economic drivers, which are provided in the confidential Excel file, SA
Macro Variables in Excel - Moody's July 2010 Forecast.x/s. This data is considered
confidential and wil be provided to those parties that have executed the Protective
Agreement in this docket. As described in the Company's response to Staff's
Production Request No. 9.c, all third-party economic and demographic data used in the
forecasting process is voluminous and cumbersome without the proper database engine
and application softare. For the complete working model and all data inputs, please
make arrangements to view to this material at the Company's corporate headquarters.
Please contact Doug Jones at [phone] or Camila Victoria at [phone] to
arrange a time to review the requested materiaL.
The response to this Request was prepared at the direction of Matthew T. Larkin,
Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST NO. 10: On pages 4-5 of Exhibit No. 27, the Company describes
how it adjusts its system forecast based on jurisdictional 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.
RESPONSE TO REQUEST NO. 10: The system customer forecast was
separated between jurisdictions in the manner described on pages 4 through 5 of
Exhibit No. 27 to best reflect the Company's expected jurisdictional customer counts for
the forecast period. With respect to several of the Company's smaller rate schedules,
forecasting based on actual historical data and known customer behavior is more
accurate than allocating a portion of the system customer forecast.
As stated on page 4 of Exhibit No. 27, "the forecasts of all (residential) schedules
except Schedule 1 were set to the most recent month's actual customer count,
December 2010." In addition to Schedule 1, residential rates include Schedules 3, 4,
and 5, all in the Company's Idaho jurisdiction. Schedule 3 is a grandfathered rate under
which new service is no longer allowed, and Schedules 4 and 5 experienced no growth
throughout the 2010 historical year. Because these classes demonstrated no growth
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
and are limited to the Idaho jurisdiction, including them in the jurisdictional allocation of
residential customer growth would be counter to presently known information regarding
the jurisdictional breakdown of the residential rate class.
In a similar fashion, commercial rate schedules 9-Transmission ("9T"), 40, 41,
and 42 were set to the most current month of actual data, in this case December 2010.
Schedule 9T consists of three total customers, two in Idaho and one in Oregon.
Historically, these numbers have remained stagnant, and applying any growth to the 9T
rate schedule would not align with historical customer behavior or the Company's test
period expectations. Schedules 40, 41, and 42 displayed little to no growth in the
Company's Oregon jurisdiction, and only moderate growth in its Idaho jurisdiction. It is
the Company's view that the most current month of actual data is the most appropriate
estimate of future customer counts for these rate schedules.
The industrial forecast consists of Schedule 19 (Primary, Secondary, and
Transmission Service) customers.Schedules 19-5econdary ("19S") and 19-
Transmission ("19T") were set to the most current month's actual customer count, in this
case December 2010. Currently, there is only one Schedule 19S customer and only
four Schedule 19T customers, and the Company has no basis for forecasting another
Schedule 19S or 19T customer to come on-line in the foreseeable future. Setting the
customer count to one for Schedule 19S in the Idaho jurisdiction prior to allocating the
remaining customers allows for the count to remain at one customer. If jurisdictional
splits were estimated by dividing the one Schedule 19S customer by the total industrial
customer count, the result would be a fraction that would be applied to the class total,
which would require rounding. When considering a class of one customer, rounding to
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10
the nearest whole number can improperly skew test year values, especially when
historical data does not justify forecasted growth. The same logic also applies to the
Schedule 19T customer counts. Since March 2009, these counts have not changed
and are not expected to change in the foreseeable future.
Based on the historical characteristics of certain rate classes, the Company
believes the adjustments described on pages 4 and 5 of Exhibit No. 27 improve the
accuracy of the jurisdictional allocation of the system customer forecast. By directly
assigning smaller rate schedules to jurisdictions when possible, the Company is able to
take into account all currently known information and derive a forecast that best reflects
expected customer counts on a jurisdictional basis for the test period.
a. The customer forecast by class is developed using proprietary softare
called EXPRESS. The allocation of the class level customer forecasts to rate schedule
and jurisdiction is also developed within the EXPRESS softare, and the associated
jurisdictional split factors are contained within the EXPRESS database. Consequently,
the Company is unable to provide an executable electronic model used to develop the
jurisdictional split factors. However, the EXPRESS database and working electronic
model are readily available for on-site review at the Company's corporate headquarters.
Please contact Doug Jones at [phone] or Camila Victoria at [phone] to
arrange a time to review the requested materiaL.
b. The Company has not performed this analysis and to do so would be
burdensome. As stated in the Company's response to Staffs Production Request No.
10.a, the customer forecast is developed utilzing the EXPRESS softare package.
This softare is not currently calibrated to perform the requested analysis, and to do so
would require the development of a new softare modeL. Additionally, the customer
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
forecast serves as one of the initial inputs in the Company's overall general rate case
preparation. Updating Exhibit Nos. 38 and 45 would require the Company to recreate a
number of models, including the test year retail revenue forecast, the jurisdictional
separation study, the class cost-of-service study, and several rate design exhibits.
c. Please see the Company's response to Staffs Production Request 10.b.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST NO. 11: Please explain how the Company adjusted the test period
loads, incentive payments, and administrative costs to account for changes to the
Irrigation Peak Rewards Program (Order No. 32200).
RESPONSE TO REQUEST NO. 11: Test period loads were not adjusted to
account for changes to the Irrigation Peak Rewards Program resulting from Order No.
32200. As described on page 23 of the Direct Testimony of Company witness Matthew
T. Larkin, lines 13 through 16, ". . . the Company's proposed method derives system
coincident demand factors as if no (demand response) programs had been in effect
during the historical data period." Under the Company's proposed methodology, load
reductions from demand response programs are removed from the derivation of test
year demand values, thus eliminating the need to adjust test period loads to account for
program changes. For a detailed description of the derivation of test year demand
values, please see the document titled Peak Responsibilty Methods for the 2011
General Rate Case, provided on page 50 of Mr. Larkin's workpapers.
The incentive payments for the Irrigation Peak Rewards Program included in the
test period are based on the incentive payments made in 2010. Because of the
uncertainty in participation as a result of Order No. 32200, the Company did not forecast
a new 2011 incentive leveL. Seventy-five percent of the Idaho Irrigation Peak Rewards
Program incentive payments from 2010 were included in the test period. This is the
fixed portion of the incentives as a result of Order No. 32200. Administrative costs for
the Irrigation Peak Rewards Program are collected through the Energy Efficiency Rider
and are therefore excluded from the test period.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, and Pete Pengily, Customer Research & Analysis
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
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 (IVRU).
RESPONSE TO REQUEST NO. 12: Please see the tables below.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -15
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.
RESPONSE TO REQUEST NO. 13: Please see the tables below.
Sene Lenl (ACD .D1 -)
87.66X
7729X
53.4~~. '
83.23X
69.54X
64.20x.. ..
81.53X
75.42X
63.91x
82.22X 83.76X 76.69X 81.51x 79.23X 68.87x
83.55X 79.19X 81.61X 74.57x ,6.0,86~ . .8.6:0.9~
62.t~:/J 57.90x j. 49,05X .. 29.13XL.22,92,x 16.95x
77,09X ,
72.14X
t~~~34.46x
4.58x
2.87x
6.74x
. ..1()0~00X : 100.00x : 100.00x 100 100.00x , . lQQ,()()~ +100.00X:JfJO.00X .
......1Q(),Q()~ lìl.0000....00.00...~. J.L 100.0ox,lQoi¡:i(l~(l(lXr 100.00X , 100.00X j 100.00X
...IQ();()O~.., ~. 100.00x .L.l00J)0~.i(l(l:QQ:/I!(l~(l.(lxTj(l(l.(l(lXT1(i(i:O(iX
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER CO'MPANY - 16
REQUEST NO. 14: Please provide by month from July 2007 through December
2010 the total number of abandoned calls for the CSC.
RESPONSE TO REQUEST NO. 14: Please see the table below.
I ,".n.I
2007 1305 1850 2516 1363 1835 2344 20: '2 1930 I
2008 1349 1261 1466 1598 211 1656 21(1977
2009 1599 1810 2101 1576 I 1898 1970 36' '9 1431 I 0
2010 5188 2398 3330 3600 5611 9744 14517 14660 I
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17
REQUEST NO. 15: Please provide by month from July 2007 through December
2010, the percentage of calls abandoned by the CSC.
RESPONSE TO REQUEST NO. 15: Please see the table below.
2007
2008
2009
2010
Percent er A1lnÑ Cal
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -18
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.
RESPONSE TO REQUEST NO. 16: Please see the table below.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
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.
RESPONSE TO REQUEST NO. 17: The Customer Service Center receives e-
mails from customers in a variety of ways (please see table below). E-mails from
customers who click the "contact us" button on Idaho Powets website are included in
the "Iwebstet' column. E-mails from customers who fil out an order form on Idaho
Powets website are included in the "Web Orders" column. Occasionally, an Idaho
Power representative needs to contact a customer directly via e-mail to obtain additional
or clarifying information. Responses to these e-mails are included in the "Direct Email"
column.
Aug-08 214 435 n/a
Sep-08 245 357 n/a
Oct-08 273 315 n/a
Nov-08 188 315 n/a
Dec-08 262 273 n/a
2008 YTD 1,182 1,695
Jan-09 321 431 n/a
Feb-09 401 352 n/a
Mar-09 363 520 n/a
Apr-09 344 483 n/a
May-09 275 553 n/a
Jun-09 293 659 n/a
Jul-09 295 638 n/a
Aug-09 270 637 47
Sep-09 266 551 n/a
Oct-09 331 662 n/a
Nov-09 279 1193 n/a
Dec-09 301 756 56
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
2009 YTD 3,739 7,435 103
Jan-10 395 876 n/a
Feb-10 332 886 94
Mar-10 355 1142 152
Apr-10 315 875 136
May-10 336 1017 119
Jun-10 264 1056 171
Jul-10 269 1091 135
Aug-10 327 1230 220
Sep-10 365 965 240
Oct-10 328 896 237
Nov-10 284 1136 153
Dec-10 296 930 187
2010 YTD 3,866 12,100 1,844
Idaho Power does not currently have the abilty to track the response time to
customer-generated e-mails. However, based on the expertise of the Webmail group, it
is estimated that at least 93 percent of the e-mails received from customers are
responded to with 24 business hours.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21
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.
RESPONSE TO REQUEST NO. 18: Please see the tables below.
2007
2008
2009
2010
2007
2008
2009 .~.
2010
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22
REQUEST NO. 19: Please provide by month from July 2007 through December
2010 the total number of calls abandoned by the Outage Management Department.
RESPONSE TO REQUEST NO. 19: Please see the table below.
2007
2008
2009
2010
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23
REQUEST NO. 20: For those same months referenced in Production Request
No. 20, please provide the percent of calls that are abandoned.
RESPONSE TO REQUEST NO. 20: Please see the table below.
2007
2008 1.02:-
2009 4.44:-
2010 4.49:-
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24
REQUEST NO. 21: In Case No. IPC-E-08-10, Idaho Power responded to Staff
Production Request No. 36 that it had selected Western Union's Speed pay, Inc. to
begin processing electronic payments as of January of 2009. 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.
RESPONSE TO REQUEST NO. 21: At the time Idaho Power responded to
Staff's Production Request No. 36 in Case No. IPC-E-08-10, Idaho Power had selected
Western Union Speed pay, Inc., to provide electronic payment processing and
anticipated transaction processing to begin in January 2009. However, Idaho Power
and Western Union Speedpay, Inc., were not able to reach agreement on certain terms.
As a result, Idaho Power did not proceed with the implementation of electronic
transaction processing with Western Union Speed pay, Inc. Idaho Power, however, has
continued to provide electronic check, credit card, and debit card payment options
through NCO Financial for a fee of $2.85 per transaction. In 2010, Idaho Power
negotiated with NCO Financial to increase the maximum transaction amount from $300
per transaction to $5,000 per transaction for credit and debit cards and $250,000 per
electronic check.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25
REQUEST NO. 22: How many customers in 2008, 2009, and 2010 used Idaho
Powets on-demand electronic payment options? Please provide the information by
type of payment option, i.e. credit card, debit card, check by phone. This information
can be provided in yearly totals.
RESPONSE TO REQUEST NO. 22: Please see the table below.
Debit Card
Credit Card
Check by Phone
2008
31,989
157,607
54,418
2009
31,776
198,929
58,201
2010
36,271
193,573
48,118
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 26
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 Utilty Customer Relations Rules (UCRR) IDAPA 31.21.01.403.
RESPONSE TO REQUEST NO. 23: The written record of complaints and
requests is voluminous and contains confidential customer information. It is available
upon request at Idaho Power's corporate headquarters to those parties that have signed
the Protective Agreement in this case. Please contact Doug Jones at [phone] or
Camila Victoria at [phone] to arrange a time to review the requested materiaL.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 27
The following questions pertain to the testimony of Company Witness
Warren 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.
RESPONSE TO REQUEST NO. 24: The implementation of AMI has provided
several process advantages beyond the obvious effciency and cost reduction
enhancements. Please see the list below for further explanation.
1. The AMI system provides very accurate meter reading, which has
virtually eliminated biling errors and bil corrections. This frees up customer service
field personnel to address other customer needs, such as managing their energy
consumption and assisting customers with past due balances.
2. The new AMI meters have digital displays making them easier for
customers to read. In addition, hourly energy usage information is available to
customers on-line through Account Manager on Idaho Power's website. These features
allow the Company to more effectively address customer biling questions, help
customers determine how energy is being used, and help customers manage their
energy consumption.
3. The AMI system is used to complete the majority of the customer
movement orders. Customer movement peaks on the 1 st and 15th of the month.
Historically, this was an enormous impact on workloads when the process required a
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 28
site visit to obtain a meter reading. With the AMI system, these meter reads are
retrieved through automation, which allows the Company to respond to customer on-site
needs in a timelier manner.
4. The Mobile Workforce Management system provides skil-based
assignment of orders to qualified workers by area. This enables Idaho Power to more
efficiently dispatch its field personnel and improves its abilty to resolve customers' on-
site needs during the initial visit.
5. The Mobile Workforce Management system balances workload
between resources, allowing the Company to continually and consistently adjust
assignments to more effectively complete its field service work.
6. The Mobile Workorce Management system provides tracking of
field service work. This tracking enables Idaho Power to continually review and adjust
work assignments on an ongoing basis to provide more efficient and effective
completion of field orders.
7. The Mobile Workforce Management system automatically routes
the work for each of the Company's field personneL. The electronic map that is
produced identifies job locations and the most efficient route, enabling quicker response
to customers' needs.
8. The Mobile Workforce Management system is integrated with the
Customer Information System ("CIS") and provides a complete transfer of order
information to the mobile terminal, enabling field resources to more effectively respond
to customer questions while on site.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 29
9. In most instances, field work completed via the Mobile Workforce
Management system is automatically updated in CiS in near real-time. This automation
has significantly reduced order completion time, lost orders, and data entry errors. In
addition, it improves the quality of information communicated with customers.
The response to this Request was prepared by Duane Van Patten, Manager
Regional Operations Support, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 30
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.
RESPONSE TO REQUEST NO. 25:When a power outage is detected or
reported, Idaho Power personnel can confirm the outage by attempting to contact the
affected service points through the AMI system. The AMI system communicates
through the electrical distribution network. The result of the communication request
provides individual service point status. This information is beneficial in several
scenarios, including the following:
1 . When a single customer reports an outage, frequently the problem
is with his/her own equipment, not Idaho Power service. When this can be confirmed
through AMI, the Company can avoid dispatching a resource for a customer equipment
problem and instead assist the customer in resolving his/her issue in a timelier manner.
2. When an outage is reported, Idaho Power personnel wil be able to
initiate communications with selected meters and narrow the outage to specific
customers. This wil confirm the scope of the outage and indicate the location for
dispatching field personnel to begin repairs. The additional information and the speed
that it can be obtained wil improve outage response.
3. Occasionally, when there is an outage involving a large number of
customers or a large area, there are embedded outages. Embedded outages are
smaller groups of customers or sections of line within the large outage area that have
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 31
additional issues. When the cause of the major outage is repaired and power is
restored, the imbedded outage stil exists. Historically, these imbedded outages were
not immediately known to Idaho Power and crews were often sent to other areas
needing their help or they were sent home. Eventually the imbedded outage was
reported and an additional response was initiated. With the integration of OMS and
AMI, Idaho Power personnel wil be capable of confirming power restoration by
contacting the meters that were involved in the outage and confirming power is
restored. If there is an imbedded outage, this process wil bring it to the attention of the
personnel confirming restoration and they can take appropriate action to resolve the
issue before leaving the area.
4. The AMI system can also provide instantaneous voltage readings
through the interface between OMS and AMI. Often to restore power in a timely
manner the electrical system is reconfigured through alternate paths, or temporary
repairs are made. When this happens, Idaho Power must often send personnel to
multiple, sometimes remote, locations to check the condition of the system by
measuring voltage. When OMS and AMI are integrated, personnel at the dispatch
centers can select locations on OMS and obtain a voltage reading through the AMI
interface, saving resources and time.
The response to this Request was prepared by Duane Van Patten, Manager
Regional Operations Support, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 32
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 wil facilitate more flexible pricing options. Please describe in detail the
pricing options referenced.
RESPONSE TO REQUEST NO. 26: As stated in the Direct Testimony of Mr.
Youngblood on pages 9-11, the Company has future plans to expand the time variant
pricing ("TVP") alternatives that are now only available to some customers. Since the
Company first offered a TVP option to its customers in the EmmeWLetha area on a pilot
basis, it has anticipated that the knowledge gained from the initial pilot may one day be
expanded and offered to more customers system-wide. However, there are two major
projects which must be completed before TVP options can be offered across the
Company's system. First, the Company's AMI smart meters must be installed. Idaho
Powets three-year AMI implementation project is on track to finish the meter
installations by the end of 2011. Second, all of the back offce infrastructure must be
updated and implemented, including a new CiS and an enterprise data warehouse. It is
anticipated that this work wil be completed by early 2013. As stated in Mr.
Youngblood's testimony, Idaho Power anticipates offering the TVP options currently
available to EmmeWLetha customers to a greater number of participants as an
expanded pilot in 2012.
The response to this Request was prepared by Mike Youngblood, Manager Rate
Design, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 33
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.
RESPONSE TO REQUEST NO. 27: As stated in Mr. Kline's testimony, the
Company is implementing a new Customer Service Call Management system. This
system provides several new features to customers, including a "virtual hold" option
through the Interactive Voice Response unit and a "call me" option through Idaho
Powets website.
Additionally, in response to customer feedback, the Company is developing a no-
fee bil payment option to be available to customers who utilze its Account Manager
functionality on Idaho Powets website. This option is scheduled to be available in
2011. This payment option wil allow customers to schedule no-fee electronic payments
from their checking or savings account, which will provide more flexibility and
convenience to customers.
In addition, one of the projects that the Company is working on is an Energy Use
Advising TooL. This tool will improve the detailed AMI usage analysis capabilty of Idaho
Power's current Energy Tools, as well as add new features for customers. Customers
wil be able to see their "bil to date," providing useful information on the costs and
pattern of energy consumption since their last bil was prepared.
The response to this Request was prepared by Warren Kline, Vice President
Customer Operations, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 34
REQUEST NO. 28: On page 25 Witness Kline discusses the 3rd party Language
Line utilized by IPCO. In 2008, 2009, and 2010 how many times was this service
utilized by customers? Please provide the totals by language. What was the cost of
this service per call in each of those years?
RESPONSE TO REQUEST NO. 28: Please see the table below.
2008 2009 2010
Albanian 0 3 0
Arabic 3 31 63
Bantu 0 0 0
Bosnian 5 21 16
BUIQarian 0 1 0
Burmese 3 4 2
Cambodian 0 0 1
Cantonese 1 1 6
Chinese 1 3 2
Croatian 1 0 1
Czech 1 0 1
Dari 0 1 4
Dinka 0 1 0
Dutch 0 0 1
Farsi 2 7 17
French 3 5 2
Greek 0 1 0
Italian 0 0 1
Japanese 1 0 3
Karen 1 3 0
Kirundi 2 10 6
Korean 2 5 3
Lao 1 2 0
Mandarin 2 5 12
Navajo 0 1 0
Nepalese 0 10 17
Dromo 1 0 0
Pashto 0 0 1
Persian 1 2 1
Portuguese 0 3 4
Punjabi 2 0 0
Romanian 1 0 1
Russian 20 50 37
Somali 18 8 10
Spanish 4840 3223 3463
Swahili 6 28 12
Tagalog 0 0 1
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 35
Thai 0 1 1
Tiariana 0 0 2
Tonaan 0 1 1
Turkish 2 3 0
Ukrainian 1 1 2
Urdu 0 0 1
Uzbek 0 1 1
Vietnamese 4 7 16
TOTAL 4925 3443 3712
Average
Cost per Call $7.23 $6.62 $7.64
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 36
REQUEST NO. 29: On page 28 Witness Kline refers to "virtual hold" and "call
me". Please describe in more detail these two features.
RESPONSE TO REQUEST NO. 29: These above new features are part of the
new Customer Service Call Management System that is scheduled for implementation
at the end of August 2011.
Virtual Hold. This queue management solution allows customers to receive a
callback rather than wait on hold for the next available representative. Customers who
select this option will have their requests placed in the callback queue in the order
requests are received. This option provides customers the convenience of not
remaining on the line while waiting for a representative.
Call Me. In addition to transacting and sending correspondence e-mails, Web
Account Managers can request a representative call them by simply clicking on an icon
and providing their phone number. A customer service representative wil call
customers within 24 business hours of the "call me" request.
The response to this Request was prepared by Maggie Britz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 37
REQUEST NO. 30: On page 28 Witness Kline says that a no fee online bank
debiting payment option wil be available in August of 2011. Please describe the steps
a customer would take to use this option.
RESPONSE TO REQUEST NO. 30: Idaho Powets new no-fee on-line bank
account payment method wil be available to customers who log on to Idaho Power's
website as an Account Manager. Once logged in, customers select the "Pay My Bil"
button. Depending on how many accounts the customer has, he/she wil either see a
single account or a listing of all accounts. The customer can then choose which
accounts to pay during this transaction. The customer enters how much wil be paid for
each account, selects the payment date, and then enters the applicable banking
information. Customers have the choice of having this banking information saved or
not, although if they choose to save the information, the payments are not recurring;
saving banking information simply allows for ease of use the next time this payment
option is used. Once payment is made, the customer wil receive a payment
confirmation e-mail within minutes and an automated customer contact with payment
confirmation information wil be placed on the customer's account. In most cases, the
payment posts to his/her Idaho Power account within one to three days.
This payment option wil also provide special consideration for customers with
collection activity. Customers who log onto Account Manager wil continue to be alerted
when the account is past due or has a pending service disconnection. Customers who
have a pending service disconnection scheduled for the current day wil be informed of
the necessity to contact Idaho Powets Customer Service Center when a payment is
made to confirm payment and to have the disconnection cancelled. Customers who
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 38
have a service disconnection scheduled for a future date wil receive e-mail confirmation
of their payment and also a separate e-mail verifying the disconnection of service has
been cancelled. This payment option is a great addition to the variety of convenient bil
pay options Idaho Power offers customers.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 10th day of August 2011. \.
"'
AS N B. WILLIAMS
orney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 39
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of August 2011 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Don.Howell(Cpuc.idaho.gov
Karl T. Klein
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Karl.Klein(Cpuc.idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email peter(Crichardsonandolearv.com
greg(Crichardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email dreading(Cmindspring.com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email elo(Cracinelaw.net
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 40
Anthony Yankel
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email tony(Cyankel.net
Kroger Co.
Kurt J. Boehm
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email kboehm(CBKLlawfirm.com
jrh(Cbattfisher.com
Kevin Higgins
Energy Strategies, LLC
215 South State Street, Suite 200
Salt Lake City, Utah 84111
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email khiggins(Cenergystrat.com
Micron Technology, Inc.
MaryV. York
HOLLAND & HART LLP
101 South Capital Boulevard, Suite 1400
Boise, Idaho 83702
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email myork(Chollandhart.com
tnelson(Chollandhart.com
madavidson(Chollandhart.com
fschmidt(Chollandhart.com
Richard E. Malmgren
Senior Assistant General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, Idaho 83716
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email remalmgren(Cmicron.com
Department of Energy
Arthur Perry Bruder, Attorney-Advisor
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
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U.S. Mail
_ Overnight Mail
FAX
-l Email Arthur.bruder(Chq.doe.gov
Steven .porter(Chq.doe.gov
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 41
Dwight D. Etheridge
Exeter Associates, Inc.
5565 Sterrett Place, Suite 310
Columbia, Maryland 21044
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email detheridge(Cexeterassociates.com
Community Action Partnership
Association of Idaho
Brad M. Purdy
Attorney at Law
2019 North 17th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email bmpurdy(Chotmail.com
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email botto(Cidahoconservation.org
Snake River Allance
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email kmiller(Csnakeriverallance.org
NW Energy Coalition
Nancy Hirsh, Policy Director
NW Energy Coalition
811 First Avenue, Suite 305
Seattle, Washington 98104
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email nancy~wenergy.org
~
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 42