20141114IPC to Staff 1-25 redacted.pdf

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LISA D. NORDSTROM
Lead Counsel
November 14,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
!daho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. GNR-U-14-01
Exemption from UCRR 311 - ldaho Power Company's Response to the First
Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies
each of Idaho Power Company's Redacted Response to the First Production Request of
the Commission Staff and ldaho Power Company's Gonfidential Responses to the
Commission Staff's Production Request Nos. 24 and 25.
Sincerely,
An IDACORP ComDanv
X*-O 4^*n*r-
Lisa D. Nordstrom
LDN:evp
Enclosures
1221 W ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LlsA D. NORDSTROM (tSB No. 5733) n:i::11"- '"i
Idaho Power Company
1221 west tdaho street (83702) ?nl! HOV I h PI'"l lt 22
P.O. Box 70 li,jl,l.ii.. ); i,", i.',
Boise, ldaho 83707 Uilltt"lE$ C0Mh'lllililUi't
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ ida hopower. co m
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )coRpoRATtoN, IDAHO POWER ) CASE NO. GNR-U-14-01
COMPANY, AND PACIFICORP DBA )
ROCKY MOUNTATN POWER'S PETITION ) TDAHO POWER COMPANY'S
FOR AN EXEMPTTON TO UTrLrry ) REDACTED RESPONSE TO THE
cusToMER RELATTONS RULES 311(4) ) FIRST PRODUCTTON REQUEST
AND (5).) oF THE COMMTSSTON STAFF
)
)
COMES NOW, ldaho Power Company ('ldaho Powe/' or "Company'), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated October 31,2014, herewith submits the following information:
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
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?
RESPONSE TO REQUEST NO. 1: For the 12-month period ending August 31,
2013, there were 56,504 field disconnect visits of which 7,379 were made to non-
residential customers.
For this response, the Company is providing information for the 12-month time
period ending August 31,2013, due to the September 2013 implementation of the
Company's new customer information and billing system. lt is overly burdensome and
difficult to extract data from both the old and the new system and match the data into a
single cohesive body of information. The Company does not believe the results would
be materially different if calendar year 2013 data was provided.
The response to this Request is sponsored by Mark Heintzelman, Regiona!
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: For calendar yeat 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?
RESPONSE TO REQUEST NO. 2: For the 12-month period ending August 31,
2013, there were 7,417 customers who had two or more visits made to their premise, of
which 1,422 were non-residentia! customers.
For this response, the Company is providing information for the 12-month time
period ending August 31, 2013, due to the September 2013 implementation of the
Company's new customer information and billing system. lt is overly burdensome and
difficult to extract data from both the old and the new system and match the data into a
single cohesive body of information. The Company does not believe the results would
be materially different if calendar year 2013 data was provided.
The response to this Request is sponsored by Mark Heintzelman, Regiona!
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 3: For calendar year 2013, please provide the number of (a)
residential customers and (b) non-residentia! customers who paid at the door at the time
of the disconnection visit.
RESPONSE TO REQUEST NO. 3: For the 12-month period ending August 31,
2013, there were 11,305 customers who paid at the door of which 1,403 were non-
residential customers.
For this response, the Company is providing information for the 12-month time
period ending August 31, 2013, due to the September 2013 implementation of the
Company's new customer information and billing system. It is overly burdensome and
difficult to extract data from both the old and the new system and match the data into a
single cohesive body of information. The Company does not believe the results would
be materially different if calendar year 2013 data was provided.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
REQUEST NO. 4: For calendar yeat 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 custome/s health and/or safety.
RESPONSE TO REQUEST NO. 4: The Company does not possess the data
specifically requested. However, from November 2013 to March 2014, 425
disconnections were cancelled due to qualifying customers declaring protection while an
employee was on-site.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 5: Please provide the number of call attempts routinely made by
the Company to each affected customer prior to disconnection of service.
RESPONSE TO REQUEST NO.5: One telephone call attempt is routinely made
by the Company to each affected customer seven days prior to the date of the
scheduled service d isconnection.
The response to this Request is sponsored by Maggie Brilz, Customer Service
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMM]SSION STAFF - 6
REQUEST NO. 6: What steps has the Company taken to validate the telephone
numbers it has on file for customers?
RESPONSE TO REQUEST NO. 6: Customer phone numbers are verified and
updated if necessary each time a customer interacts with a customer service
representative regardless of whether the interaction is over the phone or online.
Customers who use the online forms to make requests are required to enter their
primary phone number prior to submitting the form. Customers who make online
requests through a means other than the forms receive a reply email asking them to
provide their primary phone number prior to their request being fulfilled by the customer
service representative. Customers are also prompted to provide updated phone
numbers by submitting the new information in the applicable section of the monthly bill
return pay stub.
Records maintained on the Company's call attempts indicate an invalid phone
number is encountered approximately 0.3 percent of the time.
The response to this Request is sponsored by Maggie Brilz, Customer Service
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
REQUEST NO. 7: Does the Company electronically notify customers of pending
disconnection of service? lf so, please explain: (1) how the notification occurs (timing,
whether by e-mai! or text message, etc.); and (2) whether electronic notification is in
addition to or in lieu of sending written notices via US Mail
RESPONSE TO REQUEST NO.7: No.
The response to this Request is sponsored by Maggie Brilz, Customer Service
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
REQUEST NO. 8: Please provide the current cost of a visit to a customer
premise in ldaho for the purpose of disconnecting and reconnecting service? ls there a
difference in cost between a disconnection visit and a reconnection visit?
RESPONSE TO REQUEST NO. 8: The average field visit cost for either
disconnecting and reconnecting for the 12-month period of September 1 , 2012 lo
August 31,2013 was $35.61.
The Company does not record disconnect and reconnect costs in a manner that
facilitates reporting separately the different transactions costs.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
REQUEST NO. 9: lf 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 custome/s premises?
RESPONSE TO REQUEST NO. 9: Field payments will be accepted from
customers by Company employees for any collection field visit to the custome/s
premise.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
REQUEST NO. 10: The Petitioners have expressed concern 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.9., customer behavior, payment history,
service location, etc.) increase risk? Please also provide: (1) a copy of any risk
analysis or forma! 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.
RESPONSE TO REQUEST NO. 10: The Company has not performed any
safety risk analysis or study on degree of risk related to field collection activities.
However, the Company believes the risk to employees may increase by entering the
property and disconnecting service without attempting to notify the customer prior to
doing so.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST NO. 11: For calendar year 2013, how many documented, customer-
related safety incidents have occurred when a Company employee has visited a
custome/s home for the purpose of disconnecting the customeP Please provide a
breakdown of the types of incidents.
RESPONSE TO REQUEST NO. 112 ln 2013 there were nine incidents reported
where customers were aggressive or hostile - none resulted in actual acts of violence.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 12
REQUEST NO. 12: Year to date, how many of the Company's 14,500 meters
with remote disconnecUreconnect capability have been installed at customer premises?
How many of the meters are installed at locations where the customer received LIHEAP
benefits during lhe 12 months before installation?
RESPONSE TO REQUEST NO. 12: As of November 4, 2014, 12,743 meters
with remote connecUdisconnect capability have been installed at customer premises.
lnformation regarding LIHEAP payments for specific meter Iocations for the 12
months prior to the installation of the remote connecUdisconnect meters is not available
due to the conversion to the Company's new customer information system in
September 2013. However, 1,037 (or 8 percent) out of the 12,743 meters cunently
installed are at locations where the current customer of record received at least one
LIHEAP payment between November 1,2013, and October3l, 2014.
The response to this Request is sponsored by Maggie Brilz, Customer Service
Manager, Idaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
REQUEST NO. 13: lf all of the 14,500 meters have not been installed, what is
the Company's planned timeline for installing the remaining meters?
RESPONSE TO REQUEST NO. 13: The Company plans to have all of the
meters installed by the end of 2014.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
REQUEST NO. 14: Please provide a breakdown of actual meter installations to
date by customer class (residential and non-residential).
RESPONSE TO REQUEST NO. 14: As of November 4, 2014, the Company
installed 12,743 automated connecUdisconnect meters. There are 12,234 installed on
residential and 509 on non-residential service points.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
REQUEST NO. 15: Are affected customerc notified that a remote
connecUdisconnect 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 connecUdisconnect meter has been or wi!! be installed at their location.
RESPONSE TO REQUEST NO. 15: At the time of any meter installation, if a
customer is present, the customer is verbally notified that the Company is installing a
new meter. Meter functionality is not typically discussed at the time of a meter
exchange.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, Idaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REOUEST OF THE COMMISSION STAFF - 16
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, ll 20-24. Please explain why the Company used this particular
screening process.
RESPONSE TO REQUEST NO. 16: ln the course of responding to Staffs
production request, it has come to the Company's attention that there is an error in the
testimony of Company witness Tami White. !n the event this case goes to hearing, it
will be formally corrected at that time.
The criterion used to determine meter placement was any location that was field
visited two or more times for collection activify during an approximately 18-month
period ending August 2013. The criterion did not include visits for customer requested
connections and disconnections as stated on page 5 of Tami White's testimony.
The Company used 18 months of historic data to identify locations where it would
be reasonable (based on history) to predict that multiple collection visits might occur in
the future. lt is beneficial, from a cosUbenefit perspective, to install remote
connecUdisconnect capable meters at locations where multiple visits occur.
The response to this Request is sponsored by Tami White, Manager, Rate
Design, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
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.
RESPONSE TO REQUEST NO. 17: Please see the Company's response to
Staffs Production Request No. 16.
1. Collection activity is the combination of payments at the door or
d isconnection for non-payment.
2. The Company did not use field visits for customer-requested connections
and disconnections as a screening criteria.
The response to this Request is sponsored by Tami White, Manager, Rate
Design, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
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.
RESPONSE TO REQUEST NO. 18: Please see the Company's response to
Staff's Production Request No. 16 for a description of the Company's selection criteria.
Of the approximately 14,500 locations identified to receive the remote
connecUdisconnect meters the breakdown during the 18-month time period ending
August 31,2013, is as follows:
Locations with two or more disconnections for non-payment - residential 10,915,
non-residential 316.
Locations with two or more involuntary disconnections for reasons other than
non-payment - none.
Locations with two or more payments at the door resulting in no disconnect -
residential 9,782, non-residential 1,1 79.
Locations with two or more customer-requested connections/disconnections -
none.
Locations with two or more premise visits for multiple reasons - unable to
determine as this is a subset of the above mentioned categories.
There were a total of 20,881 disconnects for non-payment and 20,555 payments
at the door. Many of the locations qualified in both categories for two transactions.
IDAHO POWER COMPANY'S REOACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 19
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF.20
REQUEST NO. 19: lf the Gompany visits a premise to disconnect service and
then returns to reconnect service, does the Company count this sequence as two visits?
lf so, how many meters with remote disconnecUreconnect meter were installed at
premises where a customer was disconnected only once and subsequently
reconnected?
RESPONSE TO REQUEST NO. 19: The sequence of one disconnect and a
subsequent reconnect was counted as one event.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THt
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 21
REQUEST NO. 20: Has the Company installed meters with remote
disconnection/reconnection capability at any locations served under a master-metering
anangement?
RESPONSE TO REQUEST NO.20: No.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 22
REQUEST NO. 21: When a customer closes an account at a location where the
Company has installed a meter with remote disconnecUreconnect capability, will the
Company allow the meter to remain in place? lf the targeted customer moves to a new
location within the Company's service territory, will the Company install a meter with
remote disconnecUreconnect capability at the custome/s new location? Does the
Company intend to move a meter with remote disconnecUreconnect capability to a
different location if a customer no longer meets, or a subsequent customer at that
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?
RESPONSE TO REQUEST NO. 21: When a customer closes an account at a
location with a remote connecUdisconnect capable meter, the meter will remain in place.
The Company did not and does not target customers; it identified locations where
multiple visits occurred. At this time, the Company does not intend to move meters.
The Company intends to keep meters in place and if necessary use their
functionality.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF.23
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
connecUdisconnect capable meters have not been installed.
RESPONSE TO REQUEST NO. 22: As stated in Ms. White's testimony on page
10, lines 13 through 15: "Locations without remote connecUdisconnect meters will still
need to be visited by an Idaho Power representative to connect or disconnect service."
The Company wishes to offer customers a courtesy notification prior to entering their
property to disconnect their service. This also gives the Company representative the
opportunity to assess the situation and decide how to safely proceed.
The response to this Request is sponsored by Tami White, Manager, Rate
Design, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 24
REQUEST NO. 23: PIease explain why, during the winter moratorium, the
Company plans to continue to make field visits and knock on the door of customers with
remote connecUdisconnect meters before a disconnection for non-payment.
RESPONSE TO REQUEST NO. 23: The Company believes it is important to
confirm that customers eligible for winter moratorium protection are given the
opportunity to declare before being disconnected for non-payment.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 25
REQUEST NO. 24: Please provide the Company's unit cost for a meter with
remote d isconnecUreconnect capability.
RESPONSE TO REQUEST NO. 24: AMI automated connecUdisconnect meters
cost the Company $I each, excluding sales tax, toading and installation.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 26
REQUEST NO. 25: Please provide the Company's unit cost for a meter without
remote d isconnecUreconnect capability.
RESPONSE TO REQUEST NO. 25: The standard AMI meter (no switch) that is
comparable to the AMt automated connecUdisconnect meter costs the Company $I
each, excluding sales tax, loading and installation.
The response to this Request is sponsored by Mark Heintzelman, Regional
Operations Support Leader, ldaho Power Company.
DATED at Boise, ldaho, this 14th day of November 2014.
IDAHO POWER COMPANY'S REDAGTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 27
Attomey for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 14h day of November 20141 served a true and
correct copy of IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following
named parties by the method indicated below, and addressed to the following:
Gommission Staff
Karl Klein
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Avista Corporation
David J. Meyer
P.O. Box 3727
1411 E. Mission Avenue, MSC-23
S pokane, Washingto n 99220
Linda Gervais
P.O. Box 3727
1411 E. Mission Avenue, MSC-29
Spokane, Washingto n 99220
Rocky Mountain Power
Daniel E. Solander
Ted Weston
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
PacifiCorp
Barbara Coughlin
825 N.E.Multnomah, Suite 800
Portland, OR97232
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IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 28