The URL can be used to link to this page

Home My WebLink About200503293rd Staff Request to PacifiCorp.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 1\' r (' ,,"- n erI i-- . .. 7005 MAR 29 Ai1lf: 21 it) .;U i-JULIC TILl T iE S COr.lf"lISSfON Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF PACIFICORP DBA UTAH POWER & LIGHT COMPANY FOR AUTHORITY TO INCREASE ITS RATES FOR ELECTRIC SERVICE TO ELECTRIC CUSTOMERS IN THE STATE OF IDAHO. CASE NO. PAC-05- THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO ACIFICORP The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that PacifiCorp (PacifiCorp; Company) provide the following documents and information on or before TUESDAY, APRIL 12 2005. This Production Request is to be considered as continuing, and PacifiCorp 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 produced. Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. THIRD PRODUCTION REQUEST TO ACIFICORP MARCH 29, 2005 For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. Reference IDAP A 31.01.01.228. For documents provided please include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder. For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.), CDs with all underlying formulas intact in Excel 2000 compatible language. REQUEST NO. 39: PacifiCorp recently provided a chart showing the number of its Call Center s abandoned calls by month from February 2003 through January 2005. For that same time period, please provide the total number of incoming calls in each of those months. REQUEST NO. 40: In the chart mentioned above in the month of December 2003, it shows that 43 291 calls were abandoned from the Agent queue and 461 were abandoned from the Irrigation Specialist queue. What caused those higher than normal abandoned rates for that month? REQUEST NO. 41: The Company has indicated it mails the Rules Summary to each customer once a year. Does the Company provide the Rules Summary to each new customer at the time service is initiated as required by UCRR 701? If not, why not? REQUEST NO. 42: The Company stated recently that all customers annually receive a copy of the Rules Summary. Is the Rules Summary that was provided to Staff sent to non- residential customers as well? If a different summary is provided to non-residential customers please provide a copy of that summary or summaries. REQUEST NO. 43: The Company has stated there were 693 customers who declared the need for winter disconnection protection by the end of calendar year 2004. How many of those customers were on the Winter Payment Plan? How many customers were on a Winter Payment Plan but did not declare the need for moratorium protection? THIRD PRODUCTION REQUEST TO ACIFICORP MARCH 29, 2005 REQUEST NO. 44: PacifiCorp recently provided to Staff many brochures and pamphlets written in Spanish. How does the Company make customers aware that Spanish- language information is available? REQUEST NO. 45: The Company indicated recently to Staff that it would allow (although not encourage) a customer to be placed on the Equal Time Payment Plan, even if the customer did not have 12 months of service at a location. Since Level Pay is normally based upon prior usage, how does the Company calculate a level payment amount if the customer is in a newly constructed home with no prior usage? Does this same methodology apply to deposit calculations when there is no prior usage? If not, please explain. REQUEST NO. 46: Since the Company has stated that it does not routinely physically disconnect meters between occupants, what meter reading does the Company use to prepare the final bill for the occupant moving out and the initial bill for the occupant moving in? Is an actual meter reading obtained on the date the customer requests service to end? Ifnot, why not? Is an actual meter reading obtained on the date a new customer requests service to begin? Ifnot, why not? REQUEST NO. 47: The Company stated recently that meters are typically left on between occupants unless usage is above a threshold amount at the next billing date. What is that threshold amount? How was the threshold established? REQUEST NO. 48: Does the Company take additional steps, other than the information included in the Consumer Information brochure and the Company Voices publication, to make customers aware of how to receive protection from disconnection during the winter months and how to sign up for the Winter Payment Plan? If other steps are taken to target those customers who might benefit from Winter Disconnection Protection or the Winter Payment Plan, please provide detailed information such as mailing dates and a copy of the brochure or pamphlet that is mailed at specific time frames. THIRD PRODUCTION REQUEST TO ACIFICORP MARCH 29, 2005 REQUEST NO. 49: One of the forms recently provided to Staff by PacifiCorp was identified as the Winter Moratorium Door Hanger. At what point in the collection process is this form hung on the customer s door? Is this form used in any other circumstances, such as being mailed with final disconnect notices? If so, please explain. Dated at Boise, Idaho , this c;t1 7Jt day of March 2005. adt) Scott Woodbury Deputy Attorney General Technical Staff: Marilyn Parker i:umisc:prodreq/paceO5.1 sw pr 3 mp 39- THIRD PRODUCTION REQUEST TO ACIFICORP MARCH 29, 2005 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF MARCH 2005 SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP IN CASE NO. PAC-05-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE FOLLOWING: JOHN STEWART ACIFICORP 201 S MAIN ST., SUITE 2300 SALT LAKE CITY, UT 84140 E- MAIL: i obn. stewart2~pacificorp. com DATA REQUEST RESPONSE CENTER ACIFICORP 825 NE MUL TNOMAH SUITE 800 PORTLAND OR 97232 MAIL: datarequest~pacificorp.com ANTHONY YANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 MAIL: tony~yankel.com JAMES R SMITH MONSANTO COMPANY PO BOX 816 SODA SPRINGS ID 83276 MAIL: iim.smith~monsanto.com DENNIS E PESEAU UTILITY RESOURCES INC 1500 LIBERTY ST SE SUITE 250 SALEM OR 97302 MAIL: dpeseau~excite.com JAMES M. VAN NOSTRAND STOEL RIVES LLP 900 SW FIFTH AVE SUITE 2600 PORTLAND OR 97204 MAIL: jmvannostrand~stoel.com ERIC L OLSEN RACINE OLSON NYE BUDGE & BAILEY, CHARTERED PO BOX 1391 POCATELLO ill 83204-1391 MAIL: elo~racinelaw .net RANDALL C. BUDGE RACINE OLSON NYE BUDGE & BAILEY, CHARTERED PO BOX 1391 POCATELLO ID 83204-1391 MAIL: rcb~racinelaw.net CONLEY E WARD GIVENS PURSLEY LLP 601 WBANNOCKST PO BOX 2720 BOISE ID 83701-2720 MAIL: cew~givenspursley.com BRAD M. PURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ID 83702 MAIL: bmpurdy~hotmail.com CERTIFICATE OF SERVICE R. SCOTT PASLEY ASSISTANT GENERAL COUNSEL J R SIMPLOT COMPANY 999 MAIN ST (83702) PO BOX 27 BOISE ID 83707 MAIL: spasley~simplot.com DAVID HAWK, DIRECTOR ENERGY NATURAL RESOURCES J R SIMPLOT COMPANY 999 MAIN ST (83702) PO BOX 27 BOISE ID 83707 MAIL: dhawk~simplot.com TIM OTHY J SHURTZ 411 SMAIN FIRTH ID 83236 MAIL: tim~idahosupreme.com TARY CERTIFICATE OF SERVICE