20141031Staff 1-17 to PAC.pdf

KARL KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA CORPORATTON, )
IDAHO POWER COMPANY, AND ) CASE NO. GNR-U-14-01
PACIFICORP DBA ROCKY MOUNTAIN )
POWER'S PETITION FOR AN EXEMPTTON TO) FIRST PRODUCTION
UTILITY CUSTOMER RE,LATIONS RULES ) REQUEST OF THE
31r(4) AND (s). ) COMMTSSTON STAFF TO
) ROCKY MOUNTATN POWER
)
)
The Staff of the ldaho Public Utilities Commission, by and through its attomey of record,
Karl Klein, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company) provide the following documents and information as soon as possible, but no later
than FRIDAY, NOVEMBER 14,2014.1
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
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 MOL]NTAIN POWER 1 OCTOBER 3I,2OI4
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.
Please note that all questions pertain to the Company's policies and practices with respect
to customers located in its Idaho service territory.
REQUEST NO. 1: For calendar year 2013, please provide the number of field
disconnection visits made to the premises of customers. How many of these visits were made to
non-residential customers?
REQUEST NO. 2: For calendar year 2013, please provide the number of customers
who had field disconnection visits made to their premises two or more times. How many of
these customers were non-residential customers?
REQUEST NO. 3: For calendar year 2013, please provide the number of (a) residential
customers and (b) non-residential customers who paid at the door at the time of the
disconnection visit.
REQUEST NO. 4: For calendar year 2013, please provide the number of scheduled
disconnections that were cancelled by an on-site employee who had concerns about the impact of
disconnection on the customer's health and/or safety.
REQUEST NO. 5: Please provide the number of call attempts routinely made by the
Company to each affected customer prior to disconnection of service.
REQUEST NO. 6: What steps has the Company taken to validate the telephone
numbers it has on file for customers?
REQUEST NO. 7: Does the Company electronically notify customers of pending
disconnection of service? If so, please explain: (1) how the notification occurs (timing, whether
FIRST PRODUCTION REQUEST
TO ROCKY MOT]NTAIN POWER 2 OCTOBER 3I,2OI4
by e-mail or text message, etc.); and (2) whether electronic notification is in addition to or in lieu
of sending written notices via US Mail.
REQUEST NO. 8: Please provide the current cost of a visit to a customer premise in
Idaho for the purpose ofdisconnecting and reconnecting service? Is there a difference in cost
between a disconnection visit and a reconnection visit?
REQUEST NO. 9: If the requested rule exemption is approved, under what
circumstances will the Company's employees accept payment from a customer during the
employee's visit to the customer's premises?
REQUEST NO. 10: The Petitioners have expressed concem about employee safety and
the risk posed by knocking at the door before disconnecting service and accepting payment in
lieu of disconnection. Assuming that the degree of risk varies from customer to customer, what
factors (e.g., customer behavior, payment history, service location, etc.) increase risk? Please
also provide: (1) a copy of any risk analysis or formal study that has been performed by or on
behalf of the Company; and (2) any other evidence on which the Company bases its concerns
about employee safety and risk.
REQUEST NO. 11: For calendar year 2013, how many documented, customer-related
safety incidents have occurred when a Company employee has visited a customer's home for the
purpose of disconnecting the customer? Please provide a breakdown of the types of incidents.
REQUEST NO. 12: If the requested rule exemption is granted, will the Company
implement a uniform "no-knock, no payment at the door" policy for all customer classes
(residential, small commercial, large commercial, industrial, and agricultural)? Are there
particular circumstances under which the policy will apply, e.g., premise visits for the primary
purpose of disconnecting service for non-payment, or will the policy apply regardless of the
reason for the premise visit? Does the policy apply to a particular subset of customers, e.9.,
customers who have been disconnected2 or more times in a 12 month period? Please explain to
whom the policy will apply.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER OCTOBER 3T,2014
REQUEST NO. 13: Does the Company contend that customer field visits, for the
primary purpose of disconnecting service for non-payment, pose the greatest safety risk to
employees? Do customer field visits for other reasons also pose a safety risk? Has the Company
determined that leaving a door hanger at the site 48 hours prior to disconnection does not pose a
safety risk to employees?
REQUEST NO. 14: If the requested rule exemption is granted, Idaho Power plans to
make field visits during the winter moratorium to knock on the customer's door before
disconnecting the customer for nonpayment, regardless of meter type. Has Rocky Mountain
considered taking that step as well in its service territory? Does the Company prefer to establish
a consistent no-knock policy throughout the year?
REQUEST NO. 15: In her testimony, Company witness Coughlin states that "In 2013,
1050 payments were collected by field metering specialists in Idaho." See page 7,line 21, how
much money was collected? How much of that total amount collected was for payment of the
$20 field service collection charge?
REQUEST NO. 16: In states where a policy change was approved and the Company
subsequently implemented a no knock, no payment at the door" policy, did the number of
customers disconnected for non-payment increase, decrease, or stay about the same?
REQUEST NO. 17: In preparing to change its field collection practices in other states,
the Company only informed customers with past due balances of the change. Please explain why
notification was limited to these customers. Does the Company propose to use the same process
in Idaho? If not, please explain.
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER ocroBER 31,2014
DATED at Boise, Idatro, tr, 3 Pt *rof October 2A14.
lL< ,l (u
Karl Klein
Deputy Attorney General
Technical Staff: Beverly Barker
i:umiso:pmdrcq/gnrul4.lkkbab prod rcq I to Roclcy Mountain Power
FIRST PRODUCTION REQUEST
TO ROCKY MOI.JNTAIN POWER ocToBER 31,2474
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31ST DAY OF OCTOBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE NO.
GNR-U-14.01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
DAVID J MEYER
AVISTA CORPORATION
PO BO){ 3727
SPOKANE W A 99220
E-MAIL: [e-mail]
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
DANIEL E SOLANDER
TED WESTON
ROCKY MOUNTAIN POWER CO
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I I I
E-MAIL: [e-mail]
ted. wqston@pacifi corp. com
datareq uest@f acifi corp. com
LINDA GERVAIS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA9922O
E-MAIL: linda. [e-mail]
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
BARBARA COUGHLIN
PACIFICORP
825 NE MULTNOMAH STE 8OO
PORTLAND OR 97232
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE