20160318Staff 1 - 9 to PAC.pdf

NEIL PRICE RECEIVED
DEPUTY ATTORNEY GENERAL
IDAHo puBLIC uTILITIES coMMISSIoN 2016 fiilR lB Ai{ l0: 26
PO BOX 83720
BorsE, rDAHo 83720-0074 ,- ''1,'l,.,tiratii'5i8s,o*
[phone]
ISB NO. 6864
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN ) CASE NO. PAC-E-16-06
POWER FOR AUTHORTTY TO MODTFY )
REGULATION NO. 9 DEPOSITS AND ) FIRST PRODUCTION REQUEST
ADVANCE PAYMENTS. ) OF THE COMMISSION STAFF TO
) ROCKY MOUNTATN POWER
)
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Neil Price, 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, APRIL 1,2016.r
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.
This Production 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 produced.
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MARCH 18,2016
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 identifu the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: For CY 2012-2015, please provide the total accounts receivable as
of December 3 l't for irrigation customer served under Schedule 10.
REQUEST NO.2: For CY 2012-2015, please provide the total net write-offs for
Schedule 10 irrigation customers.
REQUEST NO.3: For CY 2012-2015, please provide the number of Schedule 10
customers who:
a. owed more than $25,000 as of December 3l't;
b. had service disconnected for non-payment;
c. requested Schedule l0 service for the first time (new customer);
d. received 2 or more past due notices during the previous 12 months or irrigation
season; and
e. filed for bankruptcy, been discharged from bankruptcy, or had receivership
proceedings terminated or bankruptcy proceedings dismissed.
REQUEST NO. 4: Please provide the criteria the Company is going to use to determine
whether a new Schedule 10 customer must pay an advance. If the customer does not have any
history of service with the Company, how will the estimated monthly bill for an irrigation season
be calculated? Please explain.
REQUEST NO. 5: Please explain how the estimated monthly bill for an irrigation
season will be calculated for an existing customer.
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER 2 MARCH 18,2016
REQUEST NO.6: Do new customer records identify the total amount of connected
horsepower for each Schedule 10 customer? If not, please describe the criteria the Company
uses to determine estimated monthly bills.
REQUEST NO. 7: Please explain how the Company determined $25K was a suitable
threshold for customers required to pay an advance.
REQUEST NO. 8: In the Company's Application, a guarantor is defined as an active
RMP customer on Schedule 10 and have no more than one late payment in the previous 12
months of service. The guarantor is also described as "larger or comparable in size" (See at p. 4,
fl 10). What criteria does the Company use to determine the "size" of customers?
REQUEST NO. 9: Is a Schedule 10 customer required to pay a deposit for any amount
in arrears from $0.01 to $25k? Please explain.
DATED at Boise, Idaho, ,n r1gh*of March 2016.
Technical Staff: Johnathan Farley
i:umisc:prodreq/pacel6.6npjf prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
Deputy Attorney General
MARCH 18,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISTH DAY OF MARCH 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE NO.
PAC-E-16-06, BY MATLING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOLTNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi corp. com
WONNE HOGLE
ASSISTANT GENERAL COUNSEL
ROCKY MOLTNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
SECRETARY,
CERTIFICATE OF SERVICE