20110914CAPAI 1-49 to IPC.PDF

Brad M.Purdy
Attorney at Law
2019N.17th St.
Boise,Idaho 83702
[phone]
Cell:[phone]
Fax:[phone]
HAND DELIVERED
?SEp 13 P:t::29
1
September 13,2011
Jean Jewell
Secretary,Idaho Public Utilities Commission
472 W.Washington St.
Boise,ID 83702
Re:Case No.IPC-E-U8-44 CAPAI’s First Discovery Requests to Idaho Power
Dear Ms.Jewell:
Included herewith is the original and one (1)copy of Community Action Partnership
Association of Idaho’s First Discovery Requests to Idaho Power in the above-referenced
proceeding.Thank you for your acceptance of this filing.
/3
Brad M.Purdy
Brad M.Purdy
Attorney at Law
Bar No.3472
2019N.17th St.
Boise,ID.83702
[phone] (Land)
[phone] (Fax)
Attorney for Petitioner
Community Action Partnership
Association of Idaho
(D V D’i •
—‘I
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
TO ITS CUSTOMERS IN THE STATE OF
IDAHO
)
)CASE NO.IPC-E-1 1-08
)
)
)COMMUNITY ACTION
)PARTNERSHIP ASSOCIA
)TION OF IDAHO’S FIRST
)DISCOVERY REQUESTS
)TO IDAHO POWER
The Community Action Partnership Association of Idaho (CAPAI),by and through its
attorney ofrecord,Brad M.Purdy and,pursuant to Rule 225 of the Commission’s Rules of
Procedure,IDAPA 3 1.01.01,requests that Idaho Power Company (Company;Idaho Power)
provide the following documents and information as soon as possible,BUT NO LATER THAN
OCTOBER 4,2011.Pursuant to Rule 225(01)of the Commission’s procedural rules,each
discovery request below is to be sequentially numbered.
This Discovery Request is to be considered as continuing,and Idaho Power Company is
requested to provide,by way of supplementary responses,additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
Please provide answers to each question,supporting work papers that provide detail or
are the source of information used in calculations,and the name,job title and telephone number
CAPAI FIRST PRODUCTION REQUESTS 1
of the person preparing the documents.Please identify the name,job title,location and
telephone number ofthe record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel and electronic files on CD with formulas activated.
You are further instructed that whenever the terms “you,”“your,”or “Company”appear
herein,they are all construed to refer to the Company.In addition,to the extent the term
“LIWA”(an abbreviation for “Low Income Weatherization Assistance”and the former name of
the Company’s program)appears in this discovery as it pertains to Idaho Power,it is to be
considered one and the same as the Company’s current acronym “WAQC.”Unless otherwise
stated or obvious,all Requests set forth herein pertain to the test year and are directed to the
Company’s Idaho jurisdiction results only.
REQUEST NO.1:Please provide a history of WAQC,or its predecessor program(s)from the
time of original inception to the present.In responding to this Request,please provide the
following details:
a.The year when the program was first implemented;
b.The rationale for implementation of the program;
c.The objectives ofthe program including targets for energy savings and
assistance to the Company’s low-income customers,
d.Annual funding levels for each year since inception,and;
e.All program design changes implemented.
REQUEST NO.2:Please state the percentage by which energy rates have increased for the
Company’s Residential class since the year when the WAQC program was first implemented.
REQUEST NO.3:Please state the amount of current WAQC funding,for the test year,as a
percentage ofthe following:
a.Total Residential class gross revenues;
b.Total Company gross revenues;
c.Total funding for all DSM programs.
REQUEST NO.4:Please restate the same information sought by subsections “a”and “b”in
the preceding Request if current WAQC funding were increased by $1.5 million to a total of $2.7
million.
CAPAI FIRST PRODUCTION REQUESTS 2
REQUEST NO.5:Based on the number of Residential customers used for the test year and
the Company’s current funding level of its WAQC program,please state the WAQC per capita
funding level for Idaho Power.
REQUEST NO.6:Has the Company made any determination as to whether the backlog of
customers eligible for WAQC who are on the waiting list has increased or been reduced since
2003 and,if such a determination has been made,please describe what it is.
REQUEST NO.7:Please explain the Company’s rationale for not increasing WAQC funding
since 2003.
REQUEST NO.8:Regarding WAQC,please provide the following:
a.All cost-effectiveness studies or analyses of WAQC since inception;
b.The Company’s current methodology for evaluating the cost-effectiveness of WAQC;
c.When the Company intends to file its next cost-effectiveness study of WAQC with
the Commission,and;
d.Describe in detail the methodology by which the Company intends to evaluate the
cost-effectiveness of WAQC.
REQUEST NO.9:Please admit or deny that all of Idaho Power’s expenditures in WAQC to
date have been prudent.
REQUEST NO.10:If your response to the preceding Request is anything other than an
affirmative response,please explain why and to .what extent expenditures in WAQC have not
been prudent.
REQUEST NO.11:Please admit or deny that all of Idaho Power’s expenditures in WAQC to
date have been cost-effective.
REQUEST NO.12:If your response to the preceding Request is anything but affirmative,
please explain why and to what extent expenditures in WAQC have not been cost-effective and
whether those expenditures were included in the Company’s rates as well as the total dollar
amount of said expenditures.
REQUEST NO.13:Is it the Company’s contention that its WAQC program is no longer
prudent or cost-effective at the present time?
REQUEST NO.14_:If your response to the preceding Request is in the affirmative,please
provide a detailed explanation,with all relevant supporting documentation,demonstrating why
CAPAI FIRST PRODUCTION REQUESTS 3
the program is no longer prudent and/or cost-effective,at what point in time it was no longer
prudent and/or cost-effective,and precisely what event(s)occurred to make this true.
REQUEST NO.15:Please indicate whether the Company currently,or in the past,calculates
the value of “non-energy benefits”produced by WAQC.
REQuEST NO.16:Please admit or deny that the Company’s 2010 DSM Annual Report filed
with the Commission purports that the WAQC program is a cost-effective DSM resource.
REQUEST NO.17:If your response to the preceding Request is anything other than in the
affirmative,please explain what the 2010 DSM Annual Report reveals regarding the cost-
effectiveness of WAQC.
REQUEST NO.18:Please provide all analyses conducted by the Company or on its behalf that
calculate all system-wide benefits to the Company’s customers resulting from the operation of
WAQC including,but not limited to:
a.Reduced arrearages;
b.Reduced bad debt write-offs;
c.Reduced collection costs;
d.Improved cash flow,and;
e.All other benefits to all customers resulting from implementation of WAQC.
REQUEST NO.19:Has the Company factored system-wide benefits to its customers as
enumerated in the preceding Request into any cost-effectiveness analyses conducted of WAQC?
If so,please explain in detail what the relative value of those benefits are and how they are
factored into the evaluation.
REQUEST NO.20:Please state the annual average Residential class accounts in arrears (past
due),as set forth below,for each ofthe past five (5)years (starting with the test year)and the
dollar amounts associated with said arrears:
a.Thirty (30)to sixty (60)days;
b.Sixty (60 to ninety (90)days;
c.More than ninety (90)days.
REQUEST NO.21:Please describe the steps taken by the Company to obtain payment from
Residential customer accounts that are past due.
REQUEST NO.22:Please state the following:
CAPAI FIRST PRODUCTION REQUESTS 4
a.the annual number and dollar value of Residential account bad debt write-offs1 for the
past five (5)years;
b.the annual number of disconnections and reconnections of Residential accounts for
the past five (5)years;
c.the Company’s annual collections costs for past due Residential accounts for the past
five (5)years2;
d.the percentage ofthe foregoing that are attributable to low-income customers.
REQUEST NO.23:Please provide the cost,on a per customer basis,of each of the following
residential activities:
a.Disconnection of service for nonpayment;
b.The negotiation of a deferred payment arrangement (i.e.,any negotiated
arrangement to pay past due bills over time);
c.Issuance of a written disconnect notice;
d.The reconnection of service;
e.A field collection visit;
f.A field visit to deliver a personal or written disconnect notice,and;
g.A telephone reminder of nonpayment;
REQUEST NO.24:Please provide a detailed description of each different type of deferred
payment plan offered by the company to residential customers.Separately indicate to whom (or
under what circumstances)each type of deferred payment plan is offered.
REQUEST NO.25:Please provide for each year for the past three years:
a.The total number of customers on each type of payment plan.
b.The total number of customers who have failed to maintain one or more payment
plans for each type of payment pian,and;
c.The total dollar amount of payment plan accounts that have not been
maintained.
REQUEST NO.26:Please provide the information sought in the preceding Request based only
on low-income Residential customers.
‘These are accounts that have been removed from the Company’s books pursuant to generally accepted accounting
principles in the good faith beliefthat they will never be recovered.Ifthe Company has sold such debts to an
independent third party,please so indicate and to what extent.
2 By “collection costs”CA1AI is referring to all costs incurred in attempting to obtain payment on delinquent
accounts not yet written off as bad debt.
CAPAT FIRST PRODUCTION REQUESTS 5
REQUEST NO.27:Please provide any study,report,memo or other written document of any
nature in the possession or control ofthe Company that considers,evaluates or discusses the
relationship between residential payment-troubles and low-income status.Separately provide
any such study,memo,report or other written document that examines these relationships for
Company customers.
REQUEST NO.28:Please provide a detailed description of how the Company calculates its
uncollectible allowance (i.e.,the amount of bad debt the Company considers it will not likely
recover).
REQUEST NO.29:For the most recent three (3)years (starting with the test year),please
provide the following data for all residential customers:
a.The total number of customers receiving LII{EAP assistance;
b.The total dollar amount per customer of LIHEAP assistance;
c.The total number of customer accounts receiving LIHEAP assistance that are in
arrears,and;
d.The total number and dollar amount of LII{EAP accounts written off as bad debt.
REQUEST NO.30:Does the Company offer any conservation programs that target customers
whose income levels are slightly above the eligibility threshold for WAQC (e.g.,200-250%of
Federal Poverty Level)?
REQUEST NO.31:If your response to the preceding Request is in the affirmative,please
provide the following:
a.A detailed description of the program including the types of conservation measures
included and who installs those measures;
b.The annual funded amount ofthe program;
c.What customer class(es)are eligible for the program;
d.How many customers participate in the program;
e.What the criteria for participation in the program are;
f.Who verifies eligibility for participation in the program and how;
g.If and how the program is relevant to a customer’s income level;
h.When the program was implemented,and;
i.How the program is funded and recovered from ratepayers.
CAPAI FIRST PRODUCTION REQUESTS 6
REQUEST NO.32:Please provide a copy of any written document in the possession or control
of the Company,whether or not prepared for the Company,assessing,estimating or otherwise
discussing the number of low-income customers served by the Company.To the extent that such
document has been prepared by or for the Company,include all source documents underlying the
estimate ofthe number of low-income customers.
REQUEST NO.33:Please provide a detailed written description of all residential energy
efficiency programs offered exclusively to low-income customers of the Company.
REQUEST NO.34:Please provide a single copy of any study within the possession or control
of the Company,that distinguishes between residential customers generally and low-income
residential customers in particular.Factors that might distinguish the two classes might include,
but are not limited to:(a)usage levels and patterns;(b)history of payment troubles;(c)
consumption of energy efficiency services;(d)credit and collection history,and;(e)
consumption of Company resources such as stafftime.
REQUEST NO.35:Please provide the following data for Idaho Power’s Residential rate class
for each ofthe past five (5)years:
A.Average revenue per kilowatt hour sold;
B.Average kilowatt hour sales per customer;
C.Average monthly customer bill;
D.Average number of customers.
REQUEST NO.36:Regarding the preceding Production Request,does the Company track and
maintain the requested data for its low-income Residential class customers?
REQUEST NO.37:If your response to the preceding Production Request is in the affirmative,
please provide said low-income data.
REQUEST NO.38:Has Idaho Power made any calculations or conducted any analyses of the
amount and nature of low-income residential usage as opposed to non-low-income residential
usage,whether low-income usage differs,and the reasons why it differs?
REQUEST NO.39:In addition to low-income weatherization,please identify all programs
Idaho Power offers that it perceives to be of assistance to its low-income customers in paying
their electric bill and provide an explanation and itemization of the nature and degree of
assistance provided by any such program.
CAPAT FIRST PRODUCTION REQUESTS 7
REQUEST NO.40:Please provide the name and title ofevery Idaho Power agent or employee
who is involved with and/or works on the Company’s WAQC program.
REQUEST NO.41:For each employee or agent identified in response to the preceding
Request,please specific precisely what tasks and functions said agent or employee performs with
respect to WAQC and provide a hierarchy chart outlining levels of authority and who reports to
whom.
REQUEST NO.42:For each agent or employee identified in response to the preceding
Requests,please specify how much oftheir daily work is exclusively related to WAQC as
opposed to any other function.
REQUEST NO.43:Please state whether there are any positions wholly or partially dedicated
to WAQC within the Company that are currently unfilled,how many positions,and what their
respective responsibilities and purposes are.
REQUEST NO.44:Has the Company conducted any analyses or is it aware of any
documentation demonstrating a connection between the ratings given it by credit rating agencies
such as Standard &Poor’s and the implementation of the Company’s Power Cost Adjustment
Mechanism (PCAM)at any point since the PCAM was first approved?By this Request,CAPAI
seeks information regarding the effect,if any,that a power cost adjustment mechanism has had
on earnings stability and the resulting reduction of risk and resulting reactions of financial
institutions affecting the Company’s credit rating.
REQUEST NO.45:If your response to the preceding Request is in the affinnative,please
provide such analyses,the conclusions contained therein,and any supporting documentation.
REQUEST NO.46:Please provide the same information set forth in the preceding two
Requests with respect to the Company’s Fixed Cost Adjustment (FCA).mechanism.
REQUEST NO.47:Please admit or deny that the existence of Idaho Power’s PCAM reduces
“shareholder risk”as that term is generally used by credit rating agencies.
REQUEST NO.48:Please admit or deny that the existence of its FCA reduces “shareholder
risk.”
REQUEST NO.49:Has the Company made any determination regarding the frequency and
magnitude of planned general rate case filings in the next five (5)years?If so,please state what
that determination is.
CAPAI FIRST PRODUCTION REQUESTS 8
DATED,this 13th day of September,2011.
Brad M.Purdy
CAPAI FIRST PRODUCTION REQUESTS 9
CERTIFICATE OF SERVICE
I,the undersigned,hereby certify that on the 13thy of September,20111 served a copy
of the foregoing document on the following by electronic mail.
Lisa D.Nordstrom
Donovan E.Walker
Jason B.Williams
Idaho Power Company
1221 W.Idaho St.
Boise,ID 83702
Gregory W.Said
Idaho Power Company
1221 W.Idaho St.
Boise,ID 83702
Donald L.Howell
Idaho Public Utilities Commission
472 W.Washington St.
Boise,ID 83702
Eric L.Olsen
201 E.Center
Pocatello,ID 83204-1391
Anthony Yankel
29814 Bay Village,OH 44140
Peter J.Richardson
Gregory M.Adams
515 N.27th St.
Boise,ID 83702
Don Reading
6070 Hill Rd.
CAPAI FIRST PRODUCTION REQUESTS 10
Boise,ID 83703
Arthur Perry Bruder
United States Department ofEnergy
1000 Independence Ave.,SW
Washington D.C.20585
Kurt J.Boehm
36 E.Seventh St.,Suite 1510
Cincinnati,OH 45202
Thorvald A.Nelson
Holland &Hart
6380 S.Fiddlers Green Circle
Suite 500
Greenwood Village,CO 80111
Benjamin J.Otto
Idaho Conservation League
710 N.Sixth St.
Boise,ID 83702
Ken Miller
Snake River Alliance
P.O.Box 1731
Boise,ID 83701
Nancy Hirsch
NW Energy Coalition
811 Vt Ave.,Suite 305
Seattle,WA 98104
Dean J.Miller
420 E.Bannock
Boise,ID 83702
Scott Paul,CEO
Hoku Materials,Inc.
CAPAI FIRST PRODUCTION REQUESTS 11
One Hoku Way
Pocatello,ID 83204
DATED,this 13th day of September,2011.
Brad M.Purdy
CAPAI FIRST PRODUCTION REQUESTS 12