20110711Staff 16-50 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
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2011 JUL I I PH 2: 15
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
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-l1-12
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,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information on or before
MONDAY, AUGUST 1,2011.
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
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 11,2011
and, if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO. 16: For calendar year 2010, please provide by rate schedule for
Schedules 1 and 36: (a) the anual total number of accounts with payment arangements, and (b)
the anual total number of payment arrangements made on accounts.
REQUEST NO. 17: For those accounts identified in your response to Request No. 16
(previous question) please provide: (a) the total number and percentage of accounts that
defaulted on payment arangements annually, and (b) the total number and percentage of
payment arangements that were not kept anually.
REQUEST NO. 18: For calendar year 2010, please provide by rate schedule for
Schedules 1 and 36: (a) the total number of accounts with payment arangements that received
LIHEAP assistance, and (b) the total number of payment arangements made on accounts that
received LIHEAP assistance.
REQUEST NO. 19: For those accounts identified in your response to Request No. 18
(previous question) please provide: (a) the total number and percentage of accounts that
defaulted on payment arangements, and (b) the total number and percentage of payment
arangements that were not kept.
REQUEST NO. 20: For calendar year 2010, please provide by rate schedule for
Schedules 1 and 36, the 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 Payment Program for each time period? Of
those accounts that defaulted on the Time Payment Program, how many were subsequently
disconnected for non-payment?
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 11,2011
REQUEST NO. 21: For those accounts identified in your response to Request No. 20
(previous question), please provide the 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 for each time period? Of those accounts that
defaulted on the Time Payment Plan, how many were subsequently disconnected for non-
payment?
REQUEST NO. 22: Please explain in detail any new initiatives and/or communication
that have been undertaken by the Company in 2010 and YTD 2011 to provide assistance to
customers who are having trouble paying their bils. If none, please explain.
REQUEST NO. 23: By month, for the past heating season (2010/2011), how many
Idaho accounts were signed up for Moratorium protection from disconnection?
REQUEST NO. 24: For those accounts identified in your response to Request No. 23
(previous question) by month, how many and what percentage of those accounts were placed on
the Winter Payment Plan.
REQUEST NO. 25: For those accounts identified in your response to Request No. 24
(previous question) by month how many and what percentage of those accounts defaulted on the
Winter Payment Plan.
REQUEST NO. 26: For Program Year 2010/2011, please provide the total dollar
amount contributed to Lend-A-Hand for Idaho 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. 27: In each of the past three program years (2007/2008, 2008/2009,
2010/2011, RMP shareholders have donated $40,000 in grants for the Lend-A-Hand Program.
SECOND PRODUCTION REQUESTTO ROCKY MOUNTAIN POWER 3 JULY 11,2011
Given the growing number of customers in need of financial assistance has the Company
considered increasing the shareholder fuding amount? If no, please explain.
REQUEST NO. 28: For calendar year 2010 please provide the following: (a) the total
number of Idaho homes weatherized using RMP funds, and (b) the total dollar amount paid by
RMP to both Southeastern Idaho Community Action Agency (SEICAA) and Eastern Idaho
Community Action Parnership (EICAP) for weatherization and administrative costs.
REQUEST NO. 29: Please explain any new efforts put forth by the Company to
promote the Lend-A-Hand program?
REQUEST NO. 30: Please explain in detail the types of advertising (radio, tv, bil
insert, welcome kit, etc.) conducted in Idaho in 2010 and YTD 2011 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. 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. 31: Please provide the actual monthly service levels reached by your
Customer Service Call Centers for the calendar year 2010.
REQUEST NO. 32: Please provide the total number of incoming telephone calls
handled by month by the Customer Service Center for the calendar year 2010. For each month
provide a breakdown by the following categories: a) IVR handled calls; b) Customer Service
Representative (CSR) handled calls; and c) abandoned calls.
REQUEST NO. 33: Please provide by month the average call handle times per CSR in
the Rocky Mountain Power (RMP) call centers for the calendar year 2010.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 11,2011
REQUEST NO. 34: Please provide by month the average length of time in minutes and
seconds that customers placing calls to your call center were placed on hold during calendar year
. 2010.
REQUEST NO. 35: Please provide the number of customers by month for calendar year
2010, who accessed RMP's Interactive Voice Recognition (IVR) telephone system and
subsequently elected to speak with a CSR.
REQUEST NO. 36: Please provide the number of Idaho RMP customers signed up to
receive their bils online at the end of December 2010.
REQUEST NO. 37: Please provide the total number of CSR Full Time Employees
(FTEs) at the end of December 2010. Identify how many of those positions were vacant at the
end of the year. Provide the same information for par time employees.
REQUEST NO. 38: With respect to meters that are not disconnected concurently with
a customer-requested account closure, how many times in 2010 was the 1,000 kilowatt-hour
threshold reached in Idaho? (RMP refers to the unbiled-for kilowatt hours in these situations as
"usings".) Please provide the "usings" information by rate schedule.
REQUEST NO. 39: With respect to meters that are not disconnected concurently with
a customer-requested account closure, how many times in 2010 was the 1,000 threshold not
reached. Please provide a breakdown of these "usings" by the following categories: a) under
500 kilowatt hours; and, b) 500-999 kilowatt hours.
REQUEST NO. 40: For "usings" identified in Production Request No. 38, how many
kilowatt-hours went unbiled in 201 O? Please provide this information by rate schedule.
REQUEST NO. 41: For "usings" identified in Production Request No. 39, how many
kilowatt hours went unbiled in 201 O? Please provide this information by rate schedule.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 11,2011
REQUEST NO. 42: For the instances identified in Production Request No. 38, how
long did it take from the date of the account closure for the meter to reach the 1,000 kilowatt
hour threshold? Please provide this information by rate schedule in the following time blocks:
a) 30 days or less; b) 31-60 days; c) 61-90 days; or, d) more than 90 days.
REQUEST NO. 43: Once the 1,000 threshold was reached, in 2010, how long did it
take to disconnect the meter? Please provide this information by rate schedule in the following
time blocks: a) 30 days or less; b) 31-60 days; c) 61-90 days; or, d) more than 90 days.
REQUEST NO. 44: Please provide the number of Idaho customer-requested account
closures in 2010. Please provide this information by rate schedule.
REQUEST NO. 45: For those customer-requested account closures in 2010 identified in
response to Production Request No. 44, how many new customers signed up for service
following closure of the account by the prior customer: a) within 3 calendar days; b) within 4-5
calendar days; or c) more than 5 calendar days? Please provide this information by rate
schedule.
REQUEST NO. 46: On page 3, line 23 of Company Witness Coughlin's testimony, she
states that under the Company's curent method of leaving meters on between tenants until 1,000
kilowatt hours is surassed, that the Company operation cost was $222,628 in 2010. Please
provide the assumptions and calculations used to arrive at that amount.
REQUEST NO. 47: On page 4, line 1 of Ms. Coughlin's testimony, she states the cost
to physically disconnect meters when a customer moves out and then subsequently reconnecting
those meters would result in a cost of $408,553. Please provide the assumptions and calculations
used to arive at that amount.
REQUEST NO. 48: On page 4, line 8 of Ms. Coughlin's testimony, she states that the
Company saves money through its policy of leaving meters on between tenants by avoiding
property damage such as frozen pipes. Does the Company assume financial responsibilty for
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 JULY 11, 2011
frozen pipes if a home or business is disconnected for any reason, including nonpayment, and the
pipes freeze in the winter? And if so, what was the cost to RMP in 2010 as a result of this
policy?
REQUEST NO. 49: The IPUC's Utilty Customer Relations Rules (UCRR) allow a
utilty to rebil a customer for no more than six months in instances where usage has been
estimated. Please explain what action is taken by RMP when a meter reading canot be
obtained? Please provide copies of letters, notices or bil statements that are sent to the customer
in such instances. How many consecutive months of estimated meter readings are allowed
before the Company contacts the customer?
REQUEST NO. 50: When RMP bils a customer using an estimated reading, is the fact
that the usage is estimated highlighted or indicated anywhere on the front page of the customer's
bil? Please explain.
DATED at Boise, Idaho, this \, t\ day of July 2011.
,
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¡
Neil Price
Deputy Attorney General
Technical Staff: Curis Thaden/16-30
Marilyn Parker/31-50
i:umisc:prodreq/pacel 1.2npctmp prod req2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JULY 11,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11 TH DAY OF JULY 2011, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-II-12, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MGR
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.westonCÐpacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solanderCÐpacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datareguestCÐpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbCÐracinelaw.net
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: bcollnsCÐconsultbai.com
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithCÐmonsanto.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: eloCÐracinelaw.net
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tonYCÐyankel.net
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdYCÐhotmail.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: bottoCÐidahoconservation.org
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
10 15 W HAYS STREET
BOISE ID 83702
E-MAIL: ronCÐwiliamsbradbury.com
DON SCHOENBECK
RCS INC
900 WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: dwsCÐr-c-s-inc.com
CERTIFICATE OF SERVICE
E-MAIL: ONLY
TIM BULLER
P ACIFICORP IDAHO INDUSTRIAL
CUSTOMERS
AGRIUM US INC/NU- WEST INDUSTRIES
E-MAIL: tbullerCÐagrium.com
,b~SECRETA. ==
CERTIFICATE OF SERVICE