20210713Staff 1-18 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9917
;! .
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTTLITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO REVISE ELECTRIC
SERVICE SCHEDULE NO.3OO .
REGULATION CHARGES
CASE NO. PAC.E.2I-15
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie, Deputy Attorney General, request that Rocky Mountain Power
("Company") provide the following documents and information as soon as possible, but no later
than TUESDAY, AUGUST 3,2021.
This Production Request is to be considered as continuing, and the Company 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 also identi$, the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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1 JULY 13,2021
In addition to the written copies provided as response to the requests, please provide all
EXCEL spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide workpapers showing the number of AMI service
meters that have been replaced and a schedule for replacing the remaining meters by fall of 2022
REQUEST NO.2: Does the Company expect to achieve 100% AMI deployment? If
not, why?
REQUEST NO.3: If the Company achieves full AMI deployment, when will the non-
remote reconnection fee be removed from tariff schedule 300?
R-EQUEST NO. 4: Please provide supporting documentation for the costs and calls data
shown in the Company's workpapers.
REQUEST NO. 5: Has the Company instituted similar remote reconnection services in
any of its other jurisdictions? If so, please provide any data on the volume of calls the Company
has received from its customers for such services.
REQUEST NO. 6: When did the Company begin installing AMI meters in Idaho?
REQUEST NO. 7: Has the Company charged any Idaho customers for remote
reconnection through AMI? If so, how much were customers charged, and how was that charge
determined?
REQUEST NO. 8: Are the Total O&M Costs listed in the workpapers calculated at the
System level for the Calendar Year 2017? Additionally, please explain why the Company used
2017 data for its workpapers for this Application.
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 JULY I3,2O2I
REQUEST NO. 9: Please provide O&M Costs for calls (Labor and Employee Expense;
Materials, Contracts and Services; Telephony) and Actual Live Agent Calls data for the years
2018, 2079, and2020.
REQUEST NO. 10: Please provide a breakdown for each cost item, the Total O&M
Costs, and actual live agent calls by state and recalculate the cost per call value for each state for
calendar years 2017 through2020.
REQUEST NO. 11: Please define each cost category in the workpapers and provide
specific examples that cause the costs in each category.
REQUEST NO. 12: For customers with AMI meters with remote disconnect/reconnect
capability, will the Company keep its existing options for reconnections outside regular business
hours?
REQUEST NO. 13: Once payment arrangements are made and a payment is received
for involuntary loss of service, how quickly does the Company anticipate being able to reconnect
service?
REQUEST NO. 14: Please explain the automated reconnection process for customers
once payment arrangements are made and a payment is made following involuntary loss of
servlce.
REQUEST NO. 15: How will the Company determine what time of day to remotely
disconnect service for customers for non-payment who have AMI meters with remote
disconnect/reconnect capabi lity?
REQUEST NO. 16: For calendar years 2019,2020 and2021to date, please provide the
number of scheduled disconnections that were delayed by an on-site employee who had concerns
about the impact of disconnection on the customer's health and/or safety.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J JULY I3,2O2I
REQUEST NO. 17: Please explain the notification process for disconnecting service for
non-payment for customers withAMI meters with remote diseonneot/reconnect oapability and
customers who do not have AMI meters.
REQUEST NO. 18: WilI the Company seek to update its tariffto eliminato the Field
Visit Charge of $20.00 once the replacement of existing eleotric metprs with AMI meters is
complete? If no, please explain.
DATED at Boise, Idaho, this l?D day ofJuly 2A21.
Deputy Attorney GenEral
i:urni*c:prodnoq/paoe2l . I Sdhbl prod req I
FIRST PRODUCNON REQUEST
TO ROCKY MOI.INTAIN POWER
\
4 JULY I3,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I3TH DAY OF JULY 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO ROCKY MOITNTAIN POWER, IN CASE NO.
PAC-E-21.I5, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston@pacifi corp.com
idahodockets@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL OITILY:
datareq uest@paci fi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL : emily.wegener@pacificorp. com
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SECRETARY
CERTIFICATE OF SERVICE