20141031Staff 1-25 to IPC.pdf

KARL KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
IN THE MATTER OF AVISTA CORPORATION, )
IDAHO POWER COMPANY, AND )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER'S PETITION FOR AN EXEMPTION TO)
UTILITY CUSTOMER RELATIONS RULES )
311(4) AND (s).
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CASE NO. GNR.U.14.O1
FIRST PRODUCTION
REQUEST OF TT{E
COMMISSION STAFF TO
IDAHO POWER COMPANY
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl Klein, Deputy Attomey General, requests that Idaho Power Company (Company) provide
the following documents and information as soon as possible, but no later than FRIDAY,
NOVEMBER 14, 2014.r
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
' 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 IDAHO POWER ocToBER 31,2014
the person preparing the documents. Please identifu 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. l: 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?
RBQUEST 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 IDAHO POWER ocToBER 31,2014
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 of disconnecting 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 concems
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: Year to date, how many of the Company's 14,500 meters with
remote disconnecVreconnect capability have been installed at customer premises? How many of
the meters are installed at locations where the customer received LIHEAP benefits during the 12
months before installation?
REQUEST NO. 13: If all of the 14,500 meters have not been installed, what is the
Company's planned timeline for installing the remaining meters?
FIRST PRODUCTION REQUEST
TO IDAHO POWER ocroBER 3t,20t4
REQUEST NO. 14: Please provide a breakdown of actual meter installations to date by
customer class (residential and non-residential).
REQUEST NO. 15: Are affected customers notified that a remote connect/disconnect
meter has been or will be installed at their location? If so, please explain: (1) how the
notification occurs; and (2) whether the customers are told why a remote connect/disconnect
meter has been or will be installed at therr
REQUEST NO. 16: Company witness White testifies that the criterion used to
determine meter placement was "any location that was field visited two or more times during an
approximately 18-month period ending August 2013." See Direct Testimony of Tami White, p.
4,1120-24. Please explain why the Company used this particular screening process.
REQUEST NO. 17: Company witness White testifies that "The reasons for the field
visits were primarily due to collection activity, payments collected at the door, and
disconnections for non-payment. These visits also included customer requested connections and
disconnections." See id., p. 5, ll 1-4. Please: (1) define what is meant by the term "collection
activity;" and (2) explain why the Company included field visits for customer-requested
connections and disconnections in its screening process.
REQUEST NO. 18: For those remote/disconnect meters that the Company has installed
to date, please provide a breakdown by customer class and reason for selection, using the
following categories: 2 or more disconnections for non-payment;2 or more involuntary
disconnections for reasons other than non-payment;2 or more payments at the door/no
disconnect; 2 or more customer-requested connections/disconnections; 2 or more premise visits
for multiple reasons.
REQUEST NO. 19: If the Company visits a premise to disconnect service and then
retums to reconnect service, does the Company count this sequence as two visits? If so, how
many meters with remote disconnect/reconnect meter were installed at premises where a
customer was disconnected only once and subsequently reconnected?
FIRST PRODUCTION REQUEST
TO IDAHO POWER OCTOBER 3T,2074
REQUEST NO.20: Has the Company installed meters with remote
disconnectiorVreconnection capability at any locations served under a master-metering
arrangement?
REQUEST NO. 21: When a customer closes an account at a location where the
Company has installed a meter with remote disconnect/reconnect capability, will the Company
allow the meter to remain in place? If the targeted customer moves to a new location within the
Company's service territory, will the Company install a meter with remote disconnect/reconnect
capability at the customer's new location? Does the Company intend to move a meter with
remote disconnect/reconnect capability to a different location if a customer no longer meets, or a
subsequent customer atthat location does not meet, the original selection criteria for this type of
meter? Does the Company intend to keep the meter in place and not use the remote capability?
REQUEST NO. 22: Since the Company has identified employee safety as a concern,
please explain why the Company feels it is necessary for an on-site employee to knock on the
door before disconnecting service at locations where remote connect/disconnect capable meters
have not been installed.
REQUEST NO.23: Please explain why, during the winter moratorium, the Company
plans to continue to make field visits and knock on the door of customers with remote
connect/disconnect meters before a disconnection for nonpayment.
REQUEST NO.24: Please provide the Company's unit cost for a meter with remote
disconnect/reconnect capability.
REQUEST NO. 25: Please provide the Company's unit cost for a meter without remote
disconnect/reconnect capability.
FIRST PRODUCTION REQUEST
TO IDAHO POWER ocToBER 31,2014
DATED at Boise,Idaho, this 3 lt *rof October 2014.
lLl 7L-
Karl Klein
Deputy Attorney General
Technical Staff: Beverly Barker
i:umisc:prodreq/gnrul4.lk*bab prod rcq I to IPCo
FIRST PRODUCTION REQUEST
TO IDAHO POWER ocToBER 31,20t4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3IST DAY oF oCTOBER 2014,
SERVED THE FOREGOING F'IRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
GNR-U-14-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
AVISTA CORPORATION
PO BOX3727
SPOKANE WA9922O
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 MOI.]NTAIN POWER CO
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 84I I I
E-MAIL: [e-mail]
ted.weston@pacifi corp. com
datarequest@pacifi corp. com
LINDA GERVAIS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA9922O
E-MAIL: linda. [e-mail]
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
BARBARA COUGHLTN
PACIFICORP
825 NE MULTNOMAH STE 8OO
PORTLAND OR 97232
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE