20111007CAPAI to PAC 1-35.docx

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN) CASE NO. PAC-E-11-12
POWER FOR APPROVAL OF CHANGES TO)
ITS ELECTRIC SERVICE SCHEDULES) COMMUNITY ACTION) PARTNERSHIP ASSOCIA-) TION’S FIRST DISCOVERY) REQUESTS TO ROCKY) MOUNTAIN POWER
____________________________________________)The Community Action Partnership Association of Idaho (CAPAI), by and through its attorney of record, Brad M. Purdy and, pursuant to Rule 225 of the Commission’s Rules of Procedure, IDAPA 31.01.01, requests that Rocky Mountain Power Company (Rocky Mountain; Company) provide the following documents and information as soon as possible, BUT NO LATER THANOCTOBER 28, 2011. Pursuant to Rule 225(01) of the Commission’s procedural rules, each discovery request below is to be sequentially numbered. This Discovery Request is to be considered as continuing, and Rocky Mountain 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 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 telephone number of the person preparing the documents. Please identify the name, job title, location and telephone number of the record holder.In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
You are further instructed that whenever the terms "you," "your," or "Company" appear herein, they are all construed to refer to the Company. In addition, to the extent the term “LIWA” (an abbreviation for “Low Income Weatherization Assistance”) appears in this discovery as it pertains to Rocky Mountain, it is to be considered one and the same as whatever the Company’s current name or acronym or that program might be. Unless otherwise stated or obvious, all Requests set forth herein pertain to the test year and are directed to the Company’s Idaho jurisdiction results only.
REQUEST NO. 1:Please provide a history of LIWA, or its predecessor program(s) from the time of original inception to the present. In responding to this Request, please provide the following details:a.The year when the program was first implemented;b.The rationale for implementation of the program;c.The objectives of the program including targets for energy savings and assistance to the Company’s low-income customers, d.Annual funding levels for each year since inception, and; e.All program design changes implemented.REQUEST NO. 2:Please state the percentage by which energy rates have increased for the Company’s Residential class for the following time periods:a.Since the year when the LIWA program was first implemented;b.From the year 2000 to the present.REQUEST NO. 3:Please state the current amount of LIWA funding, for the test year, as a percentage of the following:a.Total Residential class gross revenues;b.Total Company gross revenues;c.Total funding for all DSM programs.REQUEST NO. 4:Based on the number of Residential customers used for the test year and the Company’s current funding level of its LIWA program, please state the LIWA per capita funding level for Rocky Mountain.REQUEST NO. 5:Has the Company made any determination as to whether the backlog of customers eligible for LIWAwho are on the waiting list has increased or been reduced since 2000 and, if such a determination has been made, please describewhat it is.REQUEST NO. 6:Please admit or deny that all of Rocky Mountain’s expenditures in LIWA to date have been prudent.REQUEST NO. 7:If your response to the preceding Request is anything other than an affirmative response, please explain why and to what extent expenditures in LIWA have not been prudent.REQUEST NO. 8:Please admit or deny that all of Rocky Mountain’s expenditures in LIWA to date have been cost-effective.REQUEST NO. 9:If your response to the preceding Request is anything but affirmative, please explain why and to what extent expenditures in LIWA have not been cost-effective and whether those expenditures were included in the Company’s rates as well as the total dollar amount of said expenditures.REQUEST NO. 10:Is it the Company’s contention that its LIWA program is no longer prudent or cost-effective at the present time?REQUEST NO. 11:If your response to the preceding Request is in the affirmative, please provide a detailed explanation, with all relevant supporting documentation, demonstrating why the program is no longer prudent and/or cost-effective, at what point in time it was no longer prudent and/or cost-effective, and precisely what event(s) occurred to make this true.REQUEST NO. 12:Please refer to the Company’s pending application in Case No. PAC-E-11-13. Assuming that the Commission were to grant Rocky Mountain’s request that the Commission “acknowledge the [LIWA] program as an acceptable part of Rocky Mountain Power’s program portfolio, and that it should continue,” as requested in the application, please explain if and how this would affect future increases to LIWA funding or program design changes and on what basis any future increases in funding would be assessed as to reasonableness.REQUEST NO. 13:Please provide all analyses conducted by the Company or on its behalf that calculate all system-wide benefits to the Company’s customers resulting from the operation of WAQC including, but not limited to:a.Reduced arrearages;b.Reduced bad debt write-offs;c.Reduced collection costs;d.Improved cash flow, and;e.All other benefits to all customers resulting from implementation of WAQC.REQUEST NO. 14:Please state the annual average Residential class accounts in arrears (past due), as set forth below, for each of the past five (5) years (starting with the test year) and the dollar amounts associated with said arrears:a.Thirty (30) to sixty (60) days;b.Sixty (60 to ninety (90) days;c.More than ninety (90) days.REQUEST NO. 15:Please describe the steps taken by the Company to obtain payment from Residential customer accounts that are past due.REQUEST NO. 16:Please state the following:a.the annual number and dollar value of Residential account bad debt write-offs for the past five (5) years;b.the annual number of disconnections and reconnections of Residential accounts for the past five (5) years;c.the Company’s annual collections costs for past due Residential accounts for the past five (5) years;d.the percentage of the foregoing that are attributable to low-income customers.REQUEST NO.17:Please provide the cost, on a per customer basis, of each of the following residential activities: a.Disconnection of service for nonpayment; b.The negotiation of a deferred payment arrangement (i.e., any negotiated arrangement to pay past due bills over time); c.Issuance of a written disconnect notice; d.The reconnection of service; e.A field collection visit; f.A field visit to deliver a personal or written disconnect notice, and; g.A telephone reminder of nonpayment.REQUEST NO. 18:Please provide a detailed description of each different type of deferred payment plan offered by the company to residential customers. Separately indicate to whom (or under what circumstances) each type of deferred payment plan is offered.REQUEST NO. 19:Please provide for each year for the past three years: a.The total number of customers on each type of payment plan. b.The total number of customers who have failed to maintainone or more payment plans for each type of payment plan, and; c.The total dollar amount of payment plan accounts that have not been maintained.REQUEST NO. 20:Please provide the information sought in the preceding Request based only on low-income Residential customers.REQUEST NO. 21:Please provide any study, report, memo or other written document of any nature in the possession or control of the Companythat considers, evaluates or discusses the relationship between residential payment-troubles and low-income status. Separately provide any such study, memo, report or other written document that examines these relationships for Company customers.REQUEST NO. 22:Please provide a detailed description of how the Company calculates its uncollectible allowance (i.e., the amount of bad debt the Company considers it will not likely recover).
REQUEST NO. 23:For the most recent three (3) years (starting with the test year), please provide the following data for all residential customers:a.The total number of customers receiving LIHEAP assistance;b.The total dollar amount per customer of LIHEAP assistance;c.The total number of customer accounts receiving LIHEAP assistancethat are in arrears, and;d.The total number and dollar amount of LIHEAP accounts written off as bad debt.
REQUEST NO. 24:Please provide a copy of any written document in the possession or control of the Company, whether or not prepared for the Company, assessing, estimating or otherwise discussing the number of low-income customers served by the Company. To the extent that such document has been prepared by or for the Company, include all source documents underlying the estimate of the number of low-income customers.REQUEST NO. 25:Please provide a detailed written description of all residential energy efficiency programs offered exclusively to low-income customers of the Company.REQUEST NO. 26:Please provide a single copy of any study within the possession or control of the Company, that distinguishes between residential customers generally and low-income residential customers in particular. Factors that might distinguish the two classes might include, but are not limited to: (a) usage levels and patterns; (b) history of payment troubles; (c) consumption of energy efficiency services; (d) credit and collection history, and; (e) consumption of Company resources such as staff time.
REQUEST NO. 27:Please provide the following data for Rocky Mountain’s Residential rate class for each of the past five (5) years:A.Average revenue per kilowatt hour sold;B.Average kilowatt hour sales per customer;C.Average monthly customer bill;D.Average number of customers.REQUEST NO. 28:Regarding the preceding Production Request, does the Company track and maintain the requested data for its low-income Residential class customers?REQUEST NO. 29:If your response to the preceding Production Request is in the affirmative, please provide said low-income data.
REQUEST NO. 30:Has Rocky Mountain made any calculations or conducted any analyses of the amount and nature of low-income residential usage as opposed to non-low-income residential usage, whether low-income usage differs, and the reasons why it differs? REQUEST NO. 31:In addition to low-income weatherization, please identify all programs Rocky Mountain offers that it perceives to be of assistance to its low-income customers in paying their electric bill and provide an explanation and itemization of the nature and degree of assistance provided by any such program.REQUEST NO. 32:Please provide the name and title of every Rocky Mountain agent or employee who is involved with and/or works on the Company’s LIWA program.REQUEST NO. 33:For each employee or agent identified in response to the preceding Request, please specific precisely what tasks and functions said agent or employee performs with respect to LIWA and provide a hierarchy chart outlining levels of authority and who reports to whom. REQUEST NO. 34:For each agent or employee identified in response to the preceding Requests, please specify how much of their daily work is exclusively related to LIWA as opposed to any other function.REQUEST NO. 35:Please state whether there are any positions wholly or partially dedicated to LIWA within the Company that are currently unfilled, how many positions, and what their respective responsibilities and purposes are.
DATED, this 7th day ofSeptember, 2011._________________________________Brad M. Purdy
CERTIFICATE OF SERVICEI, the undersigned, hereby certify that on the 7th day of September, 2011 I served a copy of the foregoing document on the following by electronic mail.
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
[e-mail]
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 W, Washington (83702)
P0 Box 83720
Boise, ID 83720-0074
[e-mail]
Randall C. Budge
Racine, Olson, Nyc, Budge & Bailey
201 E. Center
P0 Box 1391
Pocatello, ID 83204-1391
E-Mail: [e-mail]
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, ID 83276
[e-mail]
Eric L. Olsen
ASSOCIATION, INC: Racine, Olson, Nye, Budge & Bailey
(Exhibit Nos. 30 1-400) 201 E. Center
P0 Box 1391
Pocatello, ID 83204-1391
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
tony@,yankel.net
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
[e-mail]
Ronald Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83702
[e-mail]
Don Schoenbeck
RCS, Inc.
900 Washington St., Suite 780
Vancouver, WA 98660
[e-mail]
Tim Buller
Agrium, Inc.
3010 Conda Rd.
Soda Springs, ID 83276
[e-mail]
DATED, this 7th day of September, 2011.
_________________________________Brad M. Purdy