20230627Staff 38-80 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF IDAHO POWER COMPANY FOR )CASE NO.IPC-E-23-11
AUTHORITY TO INCREASE ITS RATES )AND CHARGES FOR ELECTRIC SERVICE )SECOND PRODUCTION
IN THE STATE OF IDAHO AND FOR )REQUESTOF THE
ASSOCIATED REGULATORY )COMMISSION STAFF
ACCOUNTING TREATMENT )TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and informationas soon as possible,but no
later than TUESDAY,JULY 18,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER l JUNE 27,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.38:Please identify how many Customer Service Representatives
("CSRs")are employed by the Company.
REQUESTNO.39:Please list how many CSRs work in the Customer Service Center
and how many work remote.
REQUESTNO.40:Please list the operating hours of the Customer Service Center.
REQUESTNO.41:Please describe the top menu self-help options that are available to
customers using the Company's Interactive Voice Response system.Please provide the
utilization rate for each available option for the past three years (2020,2021,and 2022).
REQUESTNO.42:Please provide the Company's performance objectives for handling
incoming calls.
REQUESTNO.43:What steps does the Company take if it fails to meet its
performance objectives?
REQUESTNO.44:Please provide the service levell for the Customer Service Center
by month for each of the past three years (2020,2021,and 2022).
REQUESTNO.45:Please provide the number of incoming calls handled by the
Customer Service Center by month for each of the past three years (2020,2021,and 2022).
'"Service level"is the percentage of calls answered within a certain number of seconds,e.g.,80%of calls answeredwithin20seconds.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 27,2023
REQUESTNO.46:Please provide the number of abandoned callS2 to the Customer
Service Center by month for each of the past three years (2020,2021 and 2022).
REQUESTNO.47:Please provide the average speed of answer3 for the Customer
Service Center by month for each of the past three years (2020,2021,and 2022).
REQUESTNO.48:Please provide the average handling time4 for the Customer Service
Center by month for each of the past three years (2020,2021,and 2022).
REQUESTNO.49:Please provide the first call resolution rates for the Customer
Service Center by month for each of the past three years (2020,2021,and 2022).
REQUESTNO.50:Please provide the average response time6 fOT C-maiÏ ÍTanSRCÍiORS
for the Customer Service Center by month for each of the past three years (2020,2021,and
2022).
REQUESTNO.51:Please explain the efforts put forth by the Company to promote
Project Share.
REQUESTNO.52:Please describe the types of advertising (radio,tv,bill insert,
welcome kit,etc.)conducted in Idaho to inform and educate customers about the following:
a.Energy assistance and bill payment options;and
b.Winter Moratorium and the Winter Payment Plan.
2 "Abandoned calls"are calls that reach the Company's incoming telephone system,but the calling party terminates
the call before speaking with a CSR.
3 "Averagespeed of answer"is the interval(typically measured in seconds)between when a call reaches theCompany's incoming telephone system and when the call is picked up by a customer service representative.
4 "Averagehandling time"is the average amount of time (usually expressed in minutes)it takes for a CSR to talkwithacustomerplusanyadditional"off-line"time it takes to complete the transaction or fully resolve the
customer's issue(s).
6 "First call resolution rate"is the percentage of calls where the transaction,inquiry,or complaint is resolved uponinitialcontactwiththeCompany.
6 "AVeTage TOSponse time"is the average number of hours from receipt of an e-mail by the Company to sending a
substantive response;auto-response acknowledgements do not count as a substantive response.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 3 JUNE 27,2023
In addition,please provide copies of any written brochures or documents sent or otherwise
provided to customers for each defined category listed in this question.
REQUESTNO.53:Please describe in detail the type of standard payment
plans/arrangements the Company offers its customers.
REQUESTNO.54:Please describe in detail the temporary alternative/modified
payment/plan arrangements the Company offered its customers in 2020 and 2021 due to
COVID-19.
REQUESTNO.55:Did the Company make any of the temporary alternative/modified
payment plan/arrangements a permanent offering?Explain.If no,please also explain.
REQUESTNO.56:For each of the past three winters (2020-2021,2021-2022,and
2022-2023),how many participants were under Winter Moratorium each year?Of that amount,
how many participants agreed to be placed on the winter payment plan and how many were
unable to meet their monthlypayment?
REQUESTNO.57:When a request is made for both new service and disconnection of
service,does the Company issue the requester a confirmation number?If no,please explain.
REQUESTNO.58:When a request is made to either add or remove a name to an
existing account,does the Company issue the requester a confirmation number?If no,please
explain.
REQUESTNO.59:In situations when a payment arrangement is setup and the required
payment is paid late or underpaid,why does the Company terminate the payment arrangement
and proceed with disconnection of service rather than keeping the arrangement in place if the
customer continues to make payments to pay off the arrearage?
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 JUNE 27,2023
REQUESTNO.60:Please provide the Company's actual insurance expenses for
Wildfire for each year for 2020-2023.Please provide supporting documentation of actual
expenses,includingworkpapers,and any documentation of expected increased expenses (i.e.,
emails,invoices,memos)for 2019 through 2024.
REQUESTNO.61:Please clarify that the adjustment to the wildfire deferral balance of
$14,022,056 is the vegetation management expenses that are excluded in the Company's request
for amortization.Also,please clarify that the balance of the wildfire deferral of $13,056,171 is
what is being sought in amortization over seven years.
REQUESTNO.62:In the Case No.IPC-E-21-02,the Company was authorized to defer
incremental Operational and Maintenance ("O&M")expenses for wildfire mitigation above 2019
actual costs escalated annuallyfor inflation (1.81%in 2019).Please provide the current baseline
from which the Company begins deferring incremental O&M expenses.
REQUESTNO.63:Please provide an Excel worksheet that details the actual costs for
2020 to date,by year,separated into the various components of the Wildfire Mitigation Plan
("WMP")as listed in Table 6 of the WMP.WMP at 35.Please quantifythe incremental
amounts that have been deferred by component.
REQUESTNO.64:Please provide a worksheet that details a list of all O&M expenses
incurred for the WMP for 2020 to date.In your response,please provide vendor name,amount,
date,FERC account number,and a brief description of the expense.
REQUESTNO.65:In Final Order No.35717,the Company was ordered to develop
project criteria,a selection process,and cost-benefit analysis for completed and future
undergrounding distribution line projects related to the wildfire mitigation prior to the
Company's next general rate case.Please provide the followinginformation:
a.An update to the status of the development of project criteria,selection process,
and cost benefit analysis;
SECOND PRODUCTIONREQUEST
TO IDAHO POWER 5 JUNE 27,2023
b.If these are developed,please provide supporting documentation of each of them;
and
c.If these haven't been developed,please explain why.
REQUESTNO.66:Please describe any occurrences where the Company
undergroundedany distribution lines both inside and outside of the scope of the WMP.If any,
please provide a supporting worksheet detailing the cost,date in service,and location (within or
outside a Red Risk Zone).
REQUESTNO.67:Please provide all fundingalternativesand sources that the
Company has pursued and/or received for its WMP.Please provide supporting workpapers.If
any,please explain how that is displayed within the WMP and incorporated in the Company's
filing.
REQUESTNO.68:The initial results of the satellite pilotproject in the WMP "...did
not demonstrate sufficient accuracy needed to make risk informed decisions for vegetation
encroachment."Colburn Direct at 53.Additionally stated,"[t]he Company plans to reassess the
technology in 3 to 5 years as improvements in machine learning and AI are made."Colburn
Direct at 53.Please answer the following:
a.Please explain if the Company will discontinue the pilotproject based on these
results;and
b.If so,please explain the impact this will have on expected expenses for the test
year ending December 31,2023.
REQUESTNO.69:Please explain why the Company used additional personnel to
"evaluate the annual use of thermography inspections in Red Risk Zones..."Colburn at 44.
Also,please explain any benefits the expanded use of thermography inspections gained
compared to the historical approach of periodic use across its system.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 6 JUNE 27,2023
REQUESTNO.70:Please provide a worksheet that describes any participation in
wildfire-relatedgroups.Please include the name of the group,description of the group,cost of
participation,and quantifythe tangible and intangible benefits gained from participation in each
group.
REQUESTNO.71:Please answer the followingabout the Enterprise Omnichannel
Notification System ("EONS")tool:
a.Please provide the in-service date of the EONS tool;
b.Please explain if the Company has utilized the tool since the in-service date;
c.Please provide any documentation of customer alerts sent/proposed to be sent
through the tool;
d.Please provide a worksheet that breaks down the tool costs by year since
implementation to date;and
e.Please provide a worksheet that breaks down expected cost for the tool by year for
2023 through 2026.
REQUESTNO.72:Please explain the expected increase in the incremental costs for
Weather Forecasting Personnel from Version 4 of the WMP to Version 5 for the years 2023
through 2025.
REQUESTNO.73:Please explain how much the Company spent to have additional
audits done for all pruningwork performed in wildfire risk zones.See Colburn at 46.Please
also explain if these expenses were included in the original cost estimates for vegetation
management.Please provide supporting workpapers.
REQUESTNO.74:As part of the Fuel Reduction program,please describe if there was
any cost sharing between partners.If any,please provide a worksheet detailing how costs were
allocated between partners.
REQUESTNO.75:Please provide all workpapers used to develop Larkin's Load
Research and Forecasting Workpaper in electronic format with all formulas intact and enabled.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 7 JUNE 27,2023
REQUESTNO.76:Please provide all workpapers used to develop the Company's
Weather Normalization discussed on page 6 of Larkin's Load Research and Forecasting
Workpaper in electronic format with all formulas intact and enabled.Please include all data used
as inputs and identify the source of the data.
REQUESTNO.77:Please provide all workpapers used to develop the Company's
Residential Forecast Model discussed on pages 7-8 in Larkin's Load Research and Forecasting
Workpaper in electronic format with all formulas intact and enabled.Please include all source
data used as inputs and identify the source of the data.
REQUESTNO.78:Please explain the regression modeling method and provide the
regression models used to develop the Company's Residential Forecast Model discussed on
pages 7-8 in Larkin's Load Research and Forecasting Workpaper in electronic format with all
formulas intact and enabled.Please include all models that were compared and provide the
rationale for selecting the final model and regression coefficients.
REQUESTNO.79:Please provide all workpapers used to developthe Company's
Commercial and Industrial Forecast Models discussed on pages 8-9 in Larkin's Load Research
and Forecasting Workpaper in electronic format with all formulas intact and enabled.Please
include all source data used as inputs and identify the source of the data.
REQUESTNO.80:Please explain the regression modeling method and provide all
regression models used to develop the Company's Commercial and Industrial Forecast Models
discussed on pages 8-9 in Larkin's Load Research and Forecasting Workpaper in electronic
format with all formulas intact and enabled.Please include all models that were compared and
provide the rationale for selecting the final model and regression coefficients.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 8 JUNE 27,2023
DATED at Boise,Idaho,this day of June 2023.
D ardi
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.1ldhtnc prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 9 JUNE 27,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF JUNE 2023,SERVED
THE FOREGOING SECOND PRODUCTION REQUESTOF THE COMMISSION
STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-11,BY E-MAILING
A COPY THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:E-MAIL:[e-mail]
[e-mail] caschenbrenner idahopower.com
[e-mail] mlarkin idahopower.com
[e-mail]
dockets idaho ower.com
KELSEY JAE MICHAEL HECKLER
LAW FOR CONSCIOUS LEADERSHIP COURTNEY WHITE
920 N CLOVER DR CLEAN ENERGY OPPORTUNITIESBOISEID837033778PLANTATIONRIVERDR
E-MAIL:[e-mail] STE 102
BOISE ID 83703
E-MAIL:
[e-mail]
[e-mail]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:[e-mail]
E-MAIL:elo echohawk.com
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27TH ST EAGLE ID 83616
BOISE ID 83702 E-MAIL:[e-mail]
E-MAIL:[e-mail]
CERTIFICATE OF SERVICE
SECRETARY
CERTIFICATE OF SERVICE