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Home My WebLink About20081205Staff 13-38 to PAC.pdfSCOTT WOODI3URY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BARNO. 1895 RECEIVED 20080EC -5 PM 2: 02 IDAHO PLii:¡iJ UTILITiES COr/;ivl 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 ROCKY MOUNTAIN ) POWER FOR APPROVAL OF CHANGES TO ) ITS ELECTRIC SERVICE SCHEDULES ) ) ) ) ) CASE NO. PAC-E-08-7 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER The Staff of the Idaho Public Utilties Commission, by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power (Company; Rocky Mountain) provide the following documents and information as soon as possible, but no later than FRIDAY, DECEMBER 26, 2008. This Production Request is to be considered as continuing, and Rocky Mountain Power 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. 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. SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 1 DECEMBER 5, 2008 REQUEST NO. 13: Please provide by rate schedule for Schedules 1,23 and 23A, the monthly and anual total number of customers for each of the past three calendar years (2005- 2007). REQUEST NO. 14: Please provide by rate schedule for Schedules 1,23 and 23A, the monthly and anual total number of customers disconnected from service in each of the past three calendar years (2005-2007). Of those customers who were disconnected, how many were disconnected due to non-payment? REQUEST NO. 15: Please describe any new initiatives that have been underten by the Company to provide assistance to customers who are having trouble paying their bils? REQUEST NO. 16: Please provide by rate schedule for Schedules 1,23 and 23A, the monthly and annual total number of customers who entered into a payment arangement agreement for each of the past three calendar years (2005-2007). If payment arangement agreements are not tracked by customer then please provide the number of accounts with established payment arangement agreements for each of the past three calendar years (2005- 2007). REQUEST NO. 17: Please provide by rate schedule for Schedules 1,23 and 23A, the monthly and anual total number of customers who defaulted on a payment arangement in each of the past three years (2005-2007). If payment arangement defaults are not tracked by customers then please provide the number of accounts with payment arangement defaults for each of the past three calendar years (2005-2007). REQUEST NO. 18: Since each customer and or account can have more than one payment arangement agreement associated with it, please provide by rate schedule for Schedules 1,23 and 23A, the monthly and anual total count of payment arrangement agreements made in each of the past three calendar years (2005-2007). SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 2 DECEMBER 5, 2008 REQUEST NO. 19: Please provide by rate schedule for Schedules 1,23 and 23A, the monthly and anual total number of defaulted payment arrangements for each of the past three calendar years (2004-2007). REQUEST NO. 20: Please provide by rate schedule for Schedules 1,23 and 23A, the monthly and anual total number of customers and or accounts that paricipated in the Equal Pay Program in each of the past three calendar years (2005-2007). REQUEST NO. 21: Please provide by rate schedule for Schedules 1, the monthly and anual total number customers and or accounts that dropped out of the Equal Pay Program in each of the past three calendar years (2005-2007). Of those customers and or accounts that dropped out of the Equal Pay Program, how many were due to the anual cost adjustment to their monthly payment? REQUEST NO. 22: Please provide by rate schedule for Schedules 1,23 and 23A, the monthly and anual number of customers and or accounts that paricipated in the Levelized Pay Program in each of the past three calendar years (2005-2007). Iflevelized payment arangements are not tracked separately, then how many payment arangements exceeded 10 months or more? REQUEST NO. 23: Please provide by rate schedule for Schedules 1,23 and 23A, a monthly and anual total number of customers and or accounts that were unable to keep their levelized payment arangement or payment arrangements that exceeded 10 months or more and were subsequently disconnected from service in each of the past three past three calendar years (2005-2007). REQUEST NO. 24: Other than Lend A Hand, does Rocky Mountain Power have any in-house programs that assist low-income customers or customers needing more personalized attention? If yes, please describe the programs and the dollar amount, if any, that have been collected for bil payment assistance in each of the past three calendar years (2005-2007). SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 3 DECEMBER 5, 2008 REQUEST NO. 25: What programs, if any, are offered by Rocky Mountain Power that wil assist customers who will have higher bils under the proposed rate increase? REQUEST NO. 26: What programs wil be implemented to offer targeted assistance for customers with electric space heat? REQUEST NO. 27: How many Idaho customers were signed up for Moratoriuminter protection from disconnection in each of the last 3 winter seasons (2005/2006-2006/2007- 2007/2008)? REQUEST NO. 28: How many of those customers who declared the need for Moratorium/Winter protection were placed on the Winter Payment Plan? REQUEST NO. 29: How many customers on the Winter Payment Plan were not able to meet the monthly payment, in each of the last 3 winter seasons (2005/2006-2006/2007- 2007/2008)? REQUEST NO. 30: How does Rocky Mountain Power educate and inform customers of the availabilty of protection from disconnection during winter months and availabilty of the Winter Payment Plan? Please provide copies of any written brochures or documents sent or otherwise provided to customers. REQUEST NO. 31: Please provide a list of all DSM programs the Company had in place for 2007 and 2008 with the following information: a. What classification the DSM program has (i.e. 1,2,3 or 4) b. Jurisdiction c. Funding mechanism (i.e. DSM rider, rate base, power supply) d. Cost associated with DSM program (2007 and 2008) e. Allocation of costs among jurisdictions f. Class allocation within jurisdiction SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 4 DECEMBER 5, 2008 REQUEST NO. 32: Please provide a power supply analysis comparing, for all jurisdictions, the effect oftreating the Idaho Irrigation Load Control Program (Program) as a) Special Contract without Ancilar Service Contract Attributes, as defined in Appendix D of the Revised Protocol; b) no offering of the Program at all; and c) the current treatment of the Program. Include all workpapers and GRID rus. REQUEST NO. 33: Please provide a schedule of all Idaho Irrgation Load Control interrptions for 2008. Include the number of service points contacted and associated MW, number of service points that opted out and the associated MW, and total MW realized for each event. REQUEST NO. 34: Please provide the temperature normalization workpapers for residential and small commercial customers in executable format, with formulas intact. If there are links to other workpapers, provide those as well. REQUEST NO. 35: Please provide a list of the rate designs for residential schedules for each jurisdiction. If the general design has changed in the past 3 years, please sumarize in what ways. REQUEST NO. 36: Please provide a 2007 bil frequency analysis for Schedules 1 and 36 customers. To the extent possible, please convert to actual usage months. Provide any workpapers, in executable format with formulas intact. Please use the following increments: 0-300 kWh 300-600 kWh 100 kWh increments to 1200 kWh 1200-1500 kWh 1500-2000 kWh 500 kWh increments to 4000 kWh 4000-5000 kWh Above 5000 kWh REQUEST NO. 37: Which schedules have the metering equipment capable to support time of use rates? SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 5 DECEMBER 5, 2008 REQUEST NO. 38: Please provide the differentials in marginal cost by season between on peak and off peak. Provide any workpapers, in executable format, used to support this response. DATED at Boise, Idaho, this '5 y¡ day of December 2008. d. Scott Woodbur Deputy Attorney General Technical Staff: Curtis Thaden 13 - 30 Bryan Lanspery 31 - 38 i:umisc:prodreq/pace08.7swct prod req 2 SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 6 DECEMBER 5, 2008 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF DECEMBER 2008, SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-08-07, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: TED WESTON MGR, ID REGULATORY AFFAIRS ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2300 SALT LAKE CITY UT 84111 E-MAIL: ted.weston(fpacificorp.com DATA REQUEST RESPONSE CENTER PACIFICORP 825 NE MUL TNOMAH STE 2000 PORTLAND OR 97232 E-MAIL: dataequest(fpacificorp.com KATIE IVERSON BRUBAKER & ASSOCIATES 17244 W CORDOVA COURT SURPRISE AZ 85387 E-MAIL: kiverson(fconsultbai.com ERIC L OLSEN RACINE OLSON NYE BUDGE & BAILEY 201 ECENTER PO BOX 1391 POCATELLO ID 83204 E-MAIL: elowacinelaw.net BRAD MPURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ID 83702 E-MAIL: bmpurdy(fhotmail.com DANIEL SOLANDER SENIOR COUNSEL ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2300 SALT LAKE CITY UT 84111 E-MAIL: daniel.solander(fpacificorp.com RANDALL C BUDGE RACINE OLSON NYE BUDGE & BAILEY 201 ECENTER PO BOX 1391 POCATELLO ID 83204 E-MAIL: rcb(fracinelaw.net JAMES R SMITH MONSANTO COMPANY E-MAIL: jim.r.smith(ßmonsanto.com ELECTRONIC COPIES ONLY ANTHONY Y ANKEL 29814 LAK ROAD BAY VILLAGE OH 44140 E-MAIL: tony(ßyanel.net CONLEY E WARD MICHAEL C CREAMER GIVENS PURSLEY LLP 601 W BANNOCK ST PO BOX 2720 BOISE ID 83701-2720 E-MAIL: cew(ßgivenspursley.com CERTIFICATE OF SERVICE DENNIS E PESEAU PhD UTILITY RESOURCES INC 1500 LIBERTY ST SE SUITE 250 SALEM OR 97302 E-MAIL: dpeseau(ßexcite.com ~~- SECRETARY CERTIFICATE OF SERVICE