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Home My WebLink About20100727Staff 142-166 to PAC.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 ISB NO. 1895 2010 JUt 27 . AM 9: I 3 NEIL PRICE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 ISB NO. 6864 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5918 Attorneys 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-I0-07 FOURTH 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 on or before TUESDAY, AUGUST 17,2010. FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 1 JULY 27, 2010 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 wil 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 Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder and, if different, the witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228. In addition to the written copies provided as response to the questions, please provide all Excel and electronic files on CD with formulas activated. REQUEST NO. 142: For each of the past three calendar years (2007-2009) and YTD 2010 for Schedule 23A, please provide the anual total number of accounts that received LIHEAP assistance. REQUEST NO. 143: For each of the past three calendar years (2007-2009), please provide by rate schedule for Schedules 1 and 36: (a) the anual total number of accounts with payment arangements, and (b) the annual total number of payment arangements made on accounts. REQUEST NO. 144: For those accounts identified in your response to Request No. 143 (previous question) please provide: (a) the total number and percentage of accounts that defaulted on payment arrangements anually, and (b) the total number and percentage of payment arangements that were not kept anually. REQUEST NO. 145: For each of the past three calendar years (2007-2009), please provide by rate schedule for Schedules 1 and 36: (a) the anual total number of accounts with payment arangements that received LIHEAP assistance, and (b) the anual total number of payment arrangements made on accounts that received LIHEAP assistance. FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 2 JULY 27, 2010 REQUEST NO. 146: For those accounts identified in your response to Request No. 145 (previous question) please provide: (a) the total number and percentage of accounts that defaulted on payment arangements anually, and (b) the total number and percentage of payment arangements that were not kept anually. REQUEST NO. 147: For each of the past three calendar years (2007-2009), please provide by rate schedule for Schedules 1 and 36, the annual total number of accounts that paricipated in the Equal Payment Plan. How many and what percentage of those accounts discontinued the Equal Payment Plan annually? REQUEST NO. 148: For each of the past three calendar years (2007-2009), please provide by rate schedule for Schedules 1 and 36, the annual total number of accounts that were placed on the Equal Time Payment Program for each of the following time periods: (a) less than 6 months, and (b) 6-12 months. How many and what percentage of those accounts defaulted on the Equal Time Payment Program each anually? Of those accounts that defaulted on the Equal Time Payment Program, how many were subsequently disconnected for non-payment annually? REQUEST NO. 149: For those accounts identified in your response to Request No. 148 (previous question) please provide the anual total number of residential accounts that received LIHEAP assistance that were placed on the Equal Time Payment Program for each of the following time periods: (a) less than 6 months, and (b) 6-12 months. How many and what percentage of those accounts defaulted on the Equal Time Payment Plan each annually? Of those accounts that defaulted on the Time Payment Plan, how many were subsequently disconnected for non-payment annually? REQUEST NO. 150: For each ofthe past three calendar years (2007-2009), please provide by rate schedule for Schedules 1 and 36, the anual total number of accounts placed on the Time Payment Program for each of the following time periods: (a) less than 6 months, and (b) 6-12 months. How many and what percentage of those accounts defaulted on the Time FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 3 JULY 27,2010 Payment Program each annually? Of those accounts that defaulted on the Time Payment Program, how many were subsequently disconnected for non-payment anually? REQUEST NO. 151: For those accounts identified in your response to Request No. 150 (previous question), please provide the anual total number of residential accounts that received LIHEAP assistance that were placed on the Time Payment Program for each of the following time periods: (a) less than 6 months, and (b) 6-12 months. How many and what percentage of those accounts defaulted on the Time Payment Plan each anually? Of those accounts that defaulted on the Time Payment Plan, how many were subsequently disconnected for non- payment annually? REQUEST NO. 152: Please provide a detailed description of any new payment plan options that have been offered to residential customers over the past two calendar years (2008- 2009) and YTD 2010. Has the Company considered implementing any new payment plans with greater flexibilty for those customers with high arrearages coming out of the winter heating season? If not, please explain. REQUEST NO. 153: Have any existing payment plan options been terminated or modified over the past two calendar years (2008-2009) and YTD 201 O? If yes, please explain. REQUEST NO. 154: Please provide any new initiatives that have been underten by the Company to provide assistance to customers who are having trouble paying their bils. If none, please explain. REQUEST NO. 155: For each of the past three calendar years (2007-2009), please provide by rate schedule for Schedules 1 and 36: (a) the anual total number of accounts with deposits; (b) the average annual percentage of accounts with deposits; and (c) the deposit dollar amount on accounts. FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 4 JULY 27, 2010 REQUEST NO. 156: For each of the past three calendar years (2007-2009) for those accounts that received LIHEAP assistance, please provide by rate schedule for Schedules 1 and 36: (a) the annual total number of accounts with deposits; (b) the average annual percentage of accounts with deposits; and (c) the deposit dollar amount on accounts. REQUEST NO. 157: By month, for each of the past three winter heating seasons (2007/2008,2008/2009,2009/2010), how many Idaho accounts were signed up for Moratorium protection from disconnection? REQUEST NO. 158: For those accounts identified in your response to Request No. 16 (previous question) by month, how many and what percentage of those accounts were placed on the Winter Payment Plan. REQUEST NO. 159: For those accounts identified in your response to Request No. 17 (previous question) by month how many and what percentage of those accounts defaulted on the Winter Payment Plan. REQUEST NO. 160: For Program Year 2009/2010, please provide the total dollar amount contributed to Lend-A Hand forldaho by: a) RMP shareholders; b) Idaho customers; and c) other sources. In addition, please provide: a) the total number of grants provided to Idaho customers; b) maximum benefit amount of each grant; c) eligibilty requirements; and d) the total dollar amount distributed to Idaho customers. REQUEST NO. 161: Please explain the efforts put forth by the Company to promote the Lend-A-Hand program? REQUEST NO. 162: Order No. 30783 directed that an annual grant of $50,000 be provided to Southeastern Idaho Community Action Parnership and Eastern Idaho Community Partnership "to be used to support conservation education as a component of Rocky Mountain Power's Low Income Weatherization Program, Schedule 21". Please provide: (a) a copy of the FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 5 JULY 27, 2010 signed contract between RMP ard the CAP agencies in compliance with this Order; (b) the date the program was implemented in Idaho; (c) the number of RMP customers that have received energy conservation education; and (d) how the money has been spent, e.g., percentage breakdown for personnel, administration, equipment, publications, kits, etc. REQUEST NO. 163: Does the Company provide programs in Idaho specifically designed to assist senior citizens? If yes, please provide a detailed description. If the Company does not offer such a program, please explain why. REQUEST NO. 164: What types of advertising (radio, tv, bil insert, welcome kit, etc.) is conducted in Idaho to inform and educate customers about: 1) energy assistance and bil payment options; 2) energy conservation; and 3) Winter Moratorium and the Winter Payment Plan. 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. REQUEST NO. 165: What does the Company view as the biggest challenge facing its low income customers? REQUEST NO. 166: Does the Company feel it adequately addresses the needs of its low income, special needs and elderly customers? Please explain. ¡JDATED at Boise, Idaho, this).7 day of July 2010. Scott Woodbury Deputy Attorney General Technical Staff: Curis Thaden/142-166 ì:umìsc:prodreq/pace i o. 7swct prod req4 FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 6 JULY 27,2010 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 27TH OF JULY 2010, SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-IO-07, BY MAILING A COPY THEREOF , POSTAGE PREPAID, TO THE FOLLOWING: TED WESTON ID REGULATORY AFFAIRS MANAGER ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2300 SALT LAKE CITY UT 84111 E-MAIL: ted.westonCfacificorp.com E-MAIL: ONLY MARKC MOENCH DANIEL E SOLANDER ROCKY MOUNTAIN POWER E-MAIL: mark.moenchaYpacificorp.com daniel.solander(qpacificorp.com RANDALL C BUDGE RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 E-MAIL: rcbaYracinelaw.net E-MAIL: ONLY JAMES R SMITH MONSANTO COMPANY j im.r. smithaYmonsanto.com ANTHONY Y ANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 E-MAIL: tonyaYyankel.net PAUL J HICKEY HICKEY & EVANS LLP 1800 CAREY AVE., SUITE 700 PO BOX 467 CHEYENNE WY 82003 E-MAIL: phickeyaYhickeyevans.com E-MAIL: ONLY DATA REQUEST RESPONSE CENTER PACIFICORP E-MAIL: datarequestaYpacificorp.com KATIE IVERSON BRUBAKER & ASSOCIATES 17244 W CORDOVA CT SURPRISE AZ 85387 E-MAIL: kiversonaYconsultbai.com ERIC L OLSEN RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 E-MAIL: eloaYracinelaw.net MICHAEL C CREAMER KELSEY J NUNEZ GIVENS PURSLEY LLP PO BOX 2720 BOISE ID 83701-2720 E-MAIL: mccaYgivenspursley.com kelseynunezaYgi venspursley .com CERTIFICATE OF SERVICE TIM BULLER JASON HARRS AGRIUMINC 3010 CONDA RD SODA SPRINGS ID 83276 E-MAIL: tbulleraYagrium.com jaharisaYagrium.com BENJAMIN J OTTO IDAHO CONSERVATION LEAGUE 710 N 6TH STREET POBOX 844 BOISE ID 83702 E-MAIL: bottoaYidahoconservation.org MELINDA J DAVISON DAVISON VAN CLEVE, P.C. 333 SW TAYLOR, SUITE 400 PORTLAND, OR 97204 E-MAIL: mjdaYdvclaw.com RONALD L WILLIAMS WILLIAMS ßRADBURY, P.C. 10 15 W HAYS STREET BOISE ID 83702 E-MAIL: ronaYwiliamsbradbury.com BRAD M PURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ID 83702 E-MAIL: bmpurdyaYhotmaiL.com ~b~ SECRETARÝ CERTIFICATE OF SERVICE