HomeMy WebLinkAbout20111007Purdy Affidavit and Exhibit.pdfBrad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th S1.
Boise, ID. 83702
(208) 384-1299 (Land)
(208) 384-8511 (Fax)
bmpurdyWlhotmail.com
Attorney . for Intervenor
Communty Action Parership
Association of Idaho
RECE
inn OC1-1 PM 4: \1
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHAGES FOR ELECTRC SERVICE
TO ITS CUSTOMERS IN THE STATE OF
)
) CASE NO. IPC-E-ll-08
)
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)
)
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AFFIDAVIT OF BRA M. PURY
STATE OF IDAHO )
) ss.County of Ada )
Bra M. Pudy, being fi duly sworn upon oath, depses and says as follows:
1. I am the attorney of record for the Communty Action Parership Association of
Idaho (CAPAI) in ths proceeding and, as such, have sufcient knowledge to attest to the
statements made herein.
AFFIDAVIT OF BRAD M. PURY 1
2. On September 13, 2011 I caused to be served on the Idaho Power Company
CAPAI's First Discovery Requests directed to Idaho Power in this proceeding and served
on the Company via emaiL.
3. On October 4,2011, I received Idao Power's Response to CAPAI's First
Discovery Requests via electrnic transmission, a tre and correct copy of which is
attched hereto as Exhbit "A."
FURTHER your affant sayeth not.
T ~
DATED ths 1 day of October 7, 201 1.
_/~~,=J--Bra M. Pudy ~
SUBSCRIBED AN SWORN TO before me ths 7th day of October, 2011.
o Ii forI
Residig at Boise
Ada County
My Commssion expires cc 12-, '3
AFFIDAVIT OF BRA M. PURY 2
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on the 7th day of September, 2011 I served
a copy of the foregoing document on the followig by electronic maiL.
Lisa D. Nordstrom
Donovan E. Walker
Jason B. Wiliams
Idaho Power Company
1221 W. Idaho St.
Boise,ID 83702
Inordstrom(ßidahopower .com
dwalker(ßidahopower.com
jwiliams(ßidahopower .com
Gregory W. Said
Idaho Power Company
1221 W. Idao St.
Boise, ID 83702
gsaid(ßidahopower .com
Donald L. Howell
Idaho Public Utilities Commission
472 W. Washington St.
Boise,ID 83702
Don.howell(ßpuc.idaho. gov
Karl.klein(ßpuclidaho. gov
Eric L. Olsen
201 E. Center
Pocatello,ID 83204-1391
elo(ßracinlaw.net
Anthony Yanel
29814 Bay Vilage, OH 44140
tony(ßyanel.net
Peter J. Richardson
Gregory M. Adams
515 N. 27th St.
Boise,ID 83702
peterrgchardsonandolear.com
greg(ßrichardsonandolear .com
Don Reading
AFFIDAVIT OF BRA M. PURY 3
6070 Hil Rd.
Boise, ID 83703
dreading(ßmindspring.com
Arur Perr Bruder
United States Deparent of Energy
1000 Independence Ave., SW
Washington D.C. 20585
Arhur. bruder(ßhq.doe. gov
KurtJ. Boehm
36 E. Seventh St., Suite 1510
Cincinnti, OH 45202
kboehm(ßbkllawfrm.com
Thorvald A. Nelson
Holland & Har
6380 S. Fiddlers Green Circle
Suite 500
Greenwood Vilage, CO 80111
tnelson(ßhollandhar.com
Benjamin J. Otto
Idaho Conservation League
710 N. Sixt St.
Boise,ID 83702
botto(ßidahoconservation.org
Ken Miler
Snake River Allance
P.O. Box 1731
Boise,ID 83701
kmiler(ßsnakeriverallance.org
Nancy Hirsch
NW Energy Coalition
811 1st Ave., Suite 305
Seattle, W A 98104
nancy(ßnwenergy.org
Dean J. Miler
420 E. Banock
Boise,ID 83702
j oe(ßmcdevitt -miler .com
Scott Paul, CEO
AFFIDAVIT OF BRA M. PURDY 4
Hoku Materials, Inc.
OneHoku Way
Pocatello, ID 83204
spaul(ßhokucorp.com
/~~QB~M'Pudy~ /~
AFFIDAVIT OF BRA M. PURDY 5
l'!\
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS (ISB No. 8718)
Idaho .Power Company
1221 West Idaho Stret (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5825
Facsimile: (208) 388-6936
Inordstrom(gidahooower.com
dwalkerCãidahopower.com
jwilliamsCWidahopower.com
Attorneys for Idaho Power Company
EXIBIT ~ (PI) I
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2û1l OCT - 7 Pl'l 4: 18
BEFORE THE IDAHo PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC " )SERVICE IN IDAHO. )
)
)
)
)
)
CASE NO.IPC-E-11-08
IDAHO POWER COMPANY'S
RESPONSE TO COMMUNITY"
ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S-FiRST
DISCOVERY REQUÈSTS TO IDAHO
POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "CompanY'), and in
response to the Community Action Partnership Association of Idaho's First Discovery
" Requests to Idaho Power dated September 13, 2011, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 1
REQUEST NO.1: Please provide a history of WAQC, or its predecessor
program(s) from the time of original inception to the present. In responding to this
Request, pleas~ provide the following details:
a. The year when the proram was first implemented;
b. The rationale for implementation of the program;
c. The objectives of the proram including targets for energy savings
and assistance to the Company's low-income customers,
d. Annual funding levels for each year since inception, and;
e. All program desin changes implemented.
RESPONSE TO REQUEST NO.1:
a. A low income weatherization program, the predecessor to Weatherization
Assistance for Qualifed Customers ("WAQC"), was approved in 1989 under the Idaho
Public Utilties Commission ("Commission") Order No. IPC-E-89-6.
b. Please see the copy of the IPC-E-89-6 Application included in Idaho
Powets 1989 Conservation Plan filed .with the Commission in April 1989 provided on
the enclosed non-confidential CD. In this Application, Idaho Power requested approval
to participate in the State of Idaho Low Income Weatherization Assistance Program for
a period of five years.
c. Please see the Company's response to the Community Action Partnership
of Idaho's ("CAPAI") Request No. 1.b above.
d. Since 2004, in compliance with Commission Order No. 29505, Idaho
Power has funded the WAQC program at $1.2 milion dollars per year. Also, in
compliance with this Commission Order, if a specific Community Action Partnership
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 2
("CAP") agency does not spend its allotted annual funding, it can carr those funds over
into the following year. In addition to the $1.2 milion dollars per year, Idaho Power
funds administrative overheads. The Excel file provided on the non-confidential CD
includes all of Idaho Power's Low Income Weatherization Assistance and
Weatherization Assistance for Qualifed Customers program expenses from 1989 to
2010. Idaho Power could only query its currnt accounting system to 2000. Expenses
earlier than 2000 were obtained from. the Company's Conservation Plans. These
system-wide expenses were funded from Idaho base rates, Oregon base rates, and
Bonnevile Power Administration funds. No energy effciency rider funds are included.
e. Program design changes are included in Idaho Power's annual
Conservation Plans from 1989 to 2003, Idaho Power's Demand-Side Management
Annual Reports from 2004 to 2010, and the Company's WAQC reports from 2004 to
2010. Provided on the non-confidential CD are the relevant pages for each of the Low
Income Weatherization Assistance Program Conservation Plans for 1989-2003, copies
ofthe WAQC Annual Reports from 2004 to 2010, and copies of Idaho Power's Demand-
Side Management Annual Reports from 2004 through 2010.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis leader, Idaho Power Company, in consultation with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 3
REQUEST NO.2: Please state the percentage by which energy rates have
increased for the Company's Residential class since the year when the WAQC proram
was first implemented.
RESPONSE TO REQUEST NO.2: The average Residential class base rate
effective in 1989 was 4.07016 centslkilowatt.;hour ("kWh"). Using an average monthly
usage of 1,050 kWh per month, the average Residential class base rate currently is
7.3555centslkWh. The increase in Residential class base rates for Schedule 1 from
1989 to 2011 is 81 percnt.
The response to this Request was prepared by Darlene Nemnich, Senior
Regulatory Affairs Analyst, Idaho Power Company, in consultation with Jason B.
Willams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 4
REQUEST NO.3: Please state the amount of currnt WAQC funding, for the
test year, as a percentage of the following:
a. Total Residential class gross revenues;
b. Total Company gross revenues;
c. Total funding for all DSM programs.
RESPONSE TO REQUEST NO.3:
a. WAQC program expenditures included in the test year are the same as
actuals for 2010, $1,321,132. Total system Residential class retail revenues for the test
year are $394,327,399, which results in WAQC funding being 0.34 percent of system
Residential class retail revenues.
b. WAQC program expenditures included in the test year are the same as
actuals for 2010, $1,321,132. Total system Company retail revenues for the test year
are $850,501,733, which results in WAQC funding being 0.16 percent of system
Company retail revenues.
c. WAQC program expenditures included in the test year are the same as
actuals from 2010, $1,321,132. Total expenses from all funding sources for demand-
side management ("DSM") activities in 2010 were $45,832,851, which results in WAQC
being 2.88 percent of overall DSM expenses.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis leader, Idaho Power Company, and Darlene Nemnich, Senior
Pricing Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 5
REQUEST NO.4: Please restate the same information sought by subsections
"a" and lOb" in the preceding Request if currnt WAQC funding were increased by $1.5
milion to a total of $2.7 milion.
RESPONSE TO REQUEST NO.4: The inputs required to penorm the reuested
calculation are provided in the Company's response to CAPAI's Request No.3 above.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason. B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 6
REQUEST NO.5: Based on the number of Residential customers used for the
test year and the Company's current funding level of its WAQC program, please state
the WAQC per capita funding level for Idaho Power.
RESPONSE TO REQUEST NO.5: The total average system Residential class
customer count from the test year is 410,981. Using the 2010 actual WAQC program
expenditures included in the 2011 Test Year of $1,321,132, the average per capita
expenditure for WAQC is $3.21.
The response to this Request wap prepared by Darlene Nemnich, Senior Pricing
Analyst, Idaho Power Company, in consultation with Jason B. Willams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 7
REQUEST NO.6: Has the Company made any determination as to whether the
backlog of customers eligible for WAQC who are on the waiting list has increased or
been reduced since 2003 and, if such a determination has been made, please describe
what it is.
RESPONSE TO REQUEST NO.6: Idaho Power has not made any
determination as to whether the backlog of customers eligible for WAQC who are on the
waiting list has increased or been reduced since 2003. There are many factors in
determining the actual waiting list for weatherization. A clarification of speific heat
source and energy supplier, specific geographic area, and specific dates would be
necessary to determine any change in the number of applicants and/or which are
actually Idaho Power customers.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 8
REQUEST NO.7: Please explain the Company's rationale for not increasing
WAQC funding since 2003.
RESPONSE TO REQUEST NO.7: Idaho Power is currently providing funding to
the WAQC program in compliance with Commission Order Nos. 22178, 29505, and
30350. The Company has not received any orders from the Commission since June 25,
2007, to alter its funding for WAQC. In Order No. 30350, the Commission approved
continuation of the $1.2 milion funding for theWAQC program.
While the level of funding that Idaho Power's customers provide to the WAQC
program is not solely under the Company's control, Idaho Power has enhance its
programs and services to special nees customers. TheWAQC program specialist
works directly with weatherization managers on WAQC guidelines. While the mandated
amount of direct payments to CAP agencies may not have increased in recent years,
program guidelines have changed in order to allow managers to spend .current funding
more effciently. For example, each year, the Idaho Power program speialist works
with the CAP agency weatherization managers to develop an annual average cost per
home adjustment. The Company not only provides $1,212,534 to CAP agencies to fund
the weatherization assistance program, but actually spends additional base rates funds
for the salary of a program specialist, marketing of the program, and support of local
CAP agency actvities.
Idaho Power also takes into consideration the level of funds carried over from
_year to year. At the end of 2004, 2005, 2006, and 2007, the program carred forward
over $300,000, $215,000, $83,000, $96,000, respectively, of unused funds to the
following year.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 9
An additional enhancement of the Company's services to special needs
customers began in 2008 when the Company developed the Weatherization Solutions
for Eligible Customers program, which was piloted in 2008 and has since expanded into
an energy efficiency proram serving customers in the southern, eastern, and western
regions of the Company's servce area. Through September 2011 ,Idaho Power has
spent $428,000 on the Weatherization Solutions for Eligible Customers program and the
Company estimates that it will spend another $300,000 weatherizing homes by the end
of 2011. This program is designed to serve those customers whose income puts them
just above the povert level and was developed to provide weatherization servces to
customers who are financially unable to participate in other residential energy effciency
prorams and are not eligible for the WAQC program. Also, customers participating in
Weatherization Solutions for Eligible Customers can be financially qualifed for WAQC
but are not prioritized for services on the State of Idaho weatherization waiting list.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 10
REQUEST NO.8: Regarding WAQC, please provide the following:
a. All cost-effectiveness studies or analyses of WAQC since inception;
b. The Company's current methodology for evaluating the cost-
effectiveness of WAQC;
c. When the Company intends to file its next cost-effectiveness study
of WAQC with the Commission, and;
d. Describe in detail the methodology by which the Company intends
to evaluate the cost-effectiveness ofWAQC.
RESPONSE TO NO.8:
a. In addition to the attachments provided in the Company's response to
CAPAI's Request No. 1 above, provided on the non-confidential CO in reponse to this
Request are the Demand-Side Management 2009 Annual Report Supplement 1: Cost~
Effectiveness (revised) and the Demand-Side Management 2010 Annual Report
Supplement 1: Cost-Effctiveness. All of Idaho Power's cost-effeciveness studies and
analyses of WAQC are described in the Company's Demand Side Management Annual
Reports and the Demand-Side Management Annual Repor Supplement 1: Cost-
Effectiveness filed with the Commission for 2009 and 2010.
b. The Company's currnt methodology for evaluating the cost-effectiveness
of WAQC is included in the Demand-Side Management 2010 Annual Report on pages
15, 60, and 135, and in the Demand Side Management 2010 Annual Repo
Supplement 1: Cost-Effectiveness on pages 1 through 4 and 45. Both of these
documents were filed with the Commission on March 15, 2011, and are included in the
Company's response to CAPAI's Request Nos. 1 and 8.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 11
c. The Company intends to file the Demand-Side Management 2011 Annual
Report on March 15, 2012. Included in this report and it supplements wil be the
description and results of all of Idaho Powets cost-effeciveness analysis for all of. its
DSM programs.
d. In addition to the information included in the Company's response to
CAPAI's Request No. 8.c above, Idaho Power plans to conduct an impact evaluation of
the WAQC program in 2012. This evaluation plan is included on page 3 of the
Company's Demand-Side Management 2010 Annual Repor Supplement 2: Evaluation.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER ~ 12
REQUEST NO.9: Please admit or deny that all of Idaho Powets expenditures
in WAQC to date have been prudent.
RESPONSE TO REQUEST NO.9: Since the inception of the WAQC program
through 201 0, the Commission has detennined that Idaho Powets expenditures
associated with WAQC were prudently incurr.
The response to this Request was prepared by Pete Pengily, Customer
Researc and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER -13
REQUEST NO. 10: If your response to the preceing Request is anything other
than an affirmative response, please explain why and to what extent expenditures in
WAQC have not been prudent.
RESPONSE TO REQUEST NO. 10: Please see the Company's response to
CAPAI's Request NO.9 above.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel. Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER -14
REQUEST NO. 11: Please admit or deny that all of Idaho Powets expenditures
in WAQC to date have been cost-effective.
RESPONSE TO REQUEST NO. 11: The Company has determined that the
WAQC program has been cost-effective since its inception according to the
methodology currntly utilzed for determining cost-effectiveness of WAQC.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason. B.
Wiliams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER -15
REQUEST NO. 12: If your response to the preceing Request is anything but
affnnative, please explain why and to what extent expenditures in WAQC have not
been cost-effective and whether those expenditures were included in the Company's
rates as well as the total dollar amount of said expenditures.
RESPONSE TO REQUEST NO. 12: Please see the Company's response to
CAPAI's Request No. 11 above.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTlON PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER -16
REQUEST NO. 13: Is it the Company's contention that its WAQC program is no
longer pruent or cost-effective at the present time?
RESPONSE TO REQUEST NO. 13: No. Please see the Company's response
to CAPAI's Request Nos. 9 and 11 above.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 17
REQUEST NO. 14: If your response to the preceding Request is in the
affrmative, please provide a detailed explanation, with all relevant supporting
documentation, demonstrating why the program is no longer prudent and/or cost-
effective, at what point in time it was no longer prudent and/or cost-effective, and
precisely what event(s) occurred to make this true.
RESPONSE TO REQUEST NO. 14: Please see the Company's response to
CAPAI's Request No. 13 above.
The response to this Request was prepare by Pete Pengily, Customer
Research and Analysis leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER -18
REQUEST NO. 15: Please indicate whether the Company currntly, or in the
past, calculates the value of "non-energy benefits" produced by WAQC.
RESPONSE TO REQUEST NO. 15: Idaho Power has not currntly, nor in the
past, attempted to determine if there are "non-energy benefits" produce by WAQC or
attempted to calculate the value of any "non-energy benefits" produced by WAQC.
The response to this Request was prepared by Pete Pengily, Customer
Researc and Analysis leader, Idaho Power Company, in consultation with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER -19
REQUEST NO. 18: Please admit or deny that th Copany's 2010 DSM Annual
Report file wi the Comission purp th the WAQC proram is a cost-effective
DSM reurc.
RESPONSE TO REQUEST NO. 18: As shwn on page 45 of th Demand-Side
Managment 2010 Annual Repo Supplemnt 1: Cost-Effness, whch is provided
in the Company's response to CAPAl's Request NO.8 above, the WAOC proram has a
benefit cost ratio greter than one under the Utilit Cost Test, th Total Resourc Cost
Test, and Ratepayer Impac Mesure Tes. As stated on page 3 of the Demand-Side
Management 2010 Annual Repo Supplment 1: Co-Effctveness. the Participant
Cost Test is not calculated for the WAQC proram since there are no partcipant costs.
The footne on page 45 stes: "Energ Saving for each home is detrmined by an
audit using th Energy Audit 4 (EA4) form approve by the U.S. Departent of
Energy (DOE). Cost-effecveness is analyzed on a per projec basis. Each project
must have a savings-to-investmnt ratio (SIR) equal to or greater than 1."
The rens to this Request was prpare by Pete Pengilly, Customer
Resarc and Analyis leader, Idaho Power Company, in consulttion wih Jason B.
Wiliams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 20
REQUEST NO. 17: If your response to the preceding Request is anything other
than in the affirmative, please explain what the 2010 DSM Annual Report reveals
regarding the cost-effectiveness of WAQC.
RESPONSE TO REQUEST NO. 17: Please see the Company's response to
CAPAI's Request No. 16 above.
The response to this Request was prepare by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consulttion with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION .OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 21
REQUEST NO. 18: Please provide all analyses conducted by the Company or
on its behalf that calculate all system-wide benefits to the Company's customers
resulting from the operation ofWAQC including, but not limited to:
a. Reduced arrearages;
b. Reduced bad debt write-ffs;
c. Reduced collection costs;
d. Improved cash flow, and;
e. All other benefits to all customers resulting from implementation of
WAQC.
RESPONSE TO REQUEST NO. 18:
a-d. Idaho Power has not conducted, nor has it had conducted on its behalf,
any analyses that calculate all system-wide benefits of WAQC.
e. Idaho Power and its customers realize a system energy benefit from all of
its energy effciency prorams. These benefits are determined in the Integrated
Resource Plan process and are reflected in the DSM alternative costs which are used to
calculate the energy benefits in the cost-effectiveness calculations for each program.
These benefits are described in detail on page 2 of the Demand-Side Management
2010 Annual Report, Supplement 1: Cost-Effctiveness, provided in the Company's
response to CAPAI's Request No.8 above.
The response to this Request was prepare by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 22
REQUEST NO. 19: Has the Company factored system-wide benefits to its
customers as enumerated in the preceding Request into any cost-effectiveness
analyses conducted of WAQC? If so, please explain in detail what the relative value of
those benefits are and how they are factore into the evaluation.
RESPONSE TO REQUEST NO. 19: Please see the Company's response to
CAPAI's Request No. 18 above.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 23
REQUEST NO. 20: Please state the annual average Residential class accounts
in arrars (past due), as set forth below, for each of the past five (5) years (starting with
the test year) and the dollar amounts associated with said arrars:
a. Thirty (30) to sixt (60) days;
b. Sixt (60) to ninety (90) days;
c. More than ninety (90) days.
RESPONSE TO REQUEST NO. 20: Please se table belo.
30 Dolars 6090 Dolars 90 Dollars
Oc 2009 - De
2009 A 142,709 $4.745,791 23,875 $1,477,06 8,06 $743,208
Jan 2010 - De
2010 Averae 65,569 $5,361.350 25,143 $1,827,766 9,780 $1,269,143
Jan 2011- Aug 2011
Averaae 68,322 $5,983,899 29,04 $2,278,362 12,34 $1,642,759
Inf idenng arrrs by custmer clss is not availabl prr to October
200.
Th infrmaton in the reponse to this Request was prepare by Maggie Brilz,
Customer Serce Manager, Idaho Power Copany, in cosultn wi Jason B.
Wiliams, Corprate Counsel, Idaho Pow Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 24
REQUEST NO. 21: Please describe the steps taken by the Company to obtain
payment from Residential customer accunts that are past due.
RESPONSE TO REQUEST NO. 21: When a bil is prepared and a past due
balance exists, a bil message titled "Importnt Information" appears on the customets
billing statement prompting them to pay the full account balance. The full account
balance is due 15 days from the day the bil is prepared. If the bil is not paid by the due
date, the past due balance includes two months' charges for service, and if the balance
owing is over $1001, a Reminder Notice is systematically generated and mailed to the
customer. If payment is not received within three business days from the day the
Reminder Notice is mailed, a Final Termination Notice is systematically generated and
mailed. to the customer. On the same day the Final Termination Notice is mailed, a
courtesy call is made to the customer. The Reminder Notice, Final Termination Notice,
and the courtesy call all contain the customets full account balance, the past due
amount, and the date the service is scheduled to be disconnected for non-payment. If
payment is not received prior to the Idaho Power representative being dispatched to the
customer's premises to disconnect service, the representative attempts to make on-site
contact with the customer to accpt payment.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Jason B. Willams, Corporate
Counsel, Idaho Power Company.
1 The Utilty Customer Relations Rule 310.01 sets the minimum amount for terminaton of service
due to unpaid bils at $50. Idaho Power at times increases this amount to efciently manage th volume
of work. Currently, the minimum past due amount set to trigger collection activity is $100 rather than the
$50 allowe by the Utilty Customer Relations Rule.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 25
REQUEST NO. 22: Please state the following:
a. the annual number and dollar value of Residential accunt bad debt
write-offs2for the past five (5) years;
b. the annual number of disconnections and reconnections of
Residential accunts for the past five (5) years;
c. the Company's annual collections costs for past due Residential
accunts for the past five (5) years;3
d. the percntage of the foregoing that are attbutable to low-income
customers.
RESPONSE TO REQUEST NO. 22:
a. Information regarding the annual actual number of Residential class wrie-
offs is not available. The dollar value for Residential class account write-offs is as
follows:
Year ~ount2010 $4,549,2992009 $4,280,6702008 $3,143,2262007 $1,830,578
2006 $2,377,301
b. The annual number of disconnections for Residential class service is
available for November 2009 forward. For November and December of 2009, 2,190
Residential class disconnections for non-payment were penormed. In 2010, 18,796
Residential class disconnections for non-payment were penormed. Idaho Power does
2 These are accounts that have been removed from the Company's books pursuant to generally
accepted accounting principles ¡nthe good faith belief that they wil never be recovered. If the Company
has sold such debts to an independent third party, please so indicate and to what extent.
3 By .collecon costs" CAPAI is refering to all cots incurr in attempting to obtain payment on
delinquent accunts not yet writn of as bad debt.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 26
not track the annual number of reconnections; however, Idaho Power does track the
number of reconnections the same day and the number of reconnections within five
busines days. This information was prvided in the Company's response to
Commission Stas Prouctn Reques No. 164.
c. Collecion costs for pa-due Residential dass accunts are not available.
d. Idaho Power does not trck accnt informtin for low-income
customers. However, wre-off infrmn for Residenial clss customers reivng
Low Income Home Energy Assistance Proram ('lllHEAP") assstnce has been
tracked sinæ November 2009. For November and Dember 2009. Idaho Power wrte
off $78,712.91 assciated wi lIHEAP customrs. For 2010, Idaho Power wrte off
$915,419.17 associated with lIHEAP Customers, or 20 percnt of total Residential
write-offs. The percentage of non-payment disconnections for UHEAP customers was
18 percent of total residential accounts for November and December of 2009, and 13
percent of total residential accunts for 2010. Idaho Power is unable to determine the
annual collection costs associated with customers receiving L1HEAP assistance.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 27
REQUEST NO. 23: Please provide the cost, on a per customer basis, of each of
the following residential activities:
a. Disconnection of service for nonpayment;
b. The negotiation of a deferrd payment arrngement (Le., any
negotiated arrngement to pay past due bils over time);
c. Issuance of a written disconnect notice;
d. The reconnection of service;
e. A field collection visit;
f. A field visit to deliver a personal or written disconnect notice, and;
g. A telephone reminder of nonpayment;
RESPONSE TO REQUEST NO. 23:
a. The cost to disconnect service for non-payment is not tracked by
individual customer class. Therefore, the cost on a per customer basis to disconnec
Residential class servce is not available. The average cost to disconnect service for
non-payment across all customer classes combined is $22.33 per disconnect. This
average cost is based on actual costs for 2009, 2010, and January through August
2011.
b. The costs associated with the numerous transactions performed on behalf
of customers are not tracked on a transactional basis. Therefore, the cost to negotiate
a deferr payment arrangement is not available.
c. The cost to send a written discnnect notice to a residential customer is
48 cents. This cost includes postage and the per item cost for the paper and envelope.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 28
d. The cost to reconnect service is not tracked by individual customer class.
Therefore, the cost on a per customer basis to reconnect residential service is not
available. The average cost to reconnect service across all customer classes combined
is $19.80 per disconnect. This average cost is based on actual costs for 2009,2010,
and January through August 2011.
e. The cost for a field collection visit is not tracked by individual customer
class. Therefore, the cost on a per residential customer basis is not available. The
average cost for a field collection visit across all customer classes combined is $22.33.
This average cost is based on actual costs for 2009, 2010, and January through August
2011.
f. The cost for a field visit to deliver a disconnection notice is not tracked by
individual customer class. Therefore, the cost on a per residential customer basis is not
available. The average cost for a field visit to deliver a personal or wnen discnnect
notice across all customer classes combined is $19.80. This average cost is based on
actual costs for 2009,2010, and January through August 2011.
g. The cost for a telephone reminder is not tracked by individual customer
class. Therefore, the cost on a per residential customer basis is not available.
The information in the response to this Request was prèpare by Maggie Brilz,
Customer Service Manager, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER. 29
REQUEST NO. 24: Please provide a detailed description of each diferent type
of deferrd payment plan offere by the company to residential customers. Separately
indicate to whom (or under what circumstances) each type of deferred payment plan is
offered.
RESPONSE TO REQUEST NO. 24: The Company offers three diferent types of
deferrd payment plans to residential customers. Customers are first offered the
"Promise to Pay" option, which allows the customer to pay the full past due balance
within the next 10 days. If the customer is unable to commit to this payment
arrngement, the "Time Pay" option is offered, which allows the customer to pay half of
the total account balance or the 60-90 day past due amount (whichever is greater)
within the next 10 days and the remaining account balance within 30 days. If the
customer is unable to commit to this payment arrngement, "Levelized Pay" is offered to
the customer. The levelized Pay option allows the customer to pay one-twlfth of the
current account balance plus an average of the annual monthly biling amount in 12
monthly installments with the first installment due immediately.
Deferred payment plans are offered to all residential customers who have not
broken arrangements on the same balance.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Jason B. Willams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 30
REQUEST NO. 25: Please provide for each year for the past three years:
a. The total number of customers on each type of payment plan.
b. The total number of customers who have failed to maintain one or
more payment plans for each type of payment plan, and;
c. The total dollar amount of payment plan accounts that have not
been maintained.
RESPONSE TO REQUEST NO. 25:
a. Information regarding the total number of customers on each tye of
payment plan is not available.
b. Information regarding the total number of customers who have failed to
maintain one or more payment plans for each tye of payment plan is not available.
c. Information regarding the total dollar amount of payment plan accunts
that have not been maintained is not available.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER. 31
REQUEST NO. 26: Please provide the information sought in the preceding
Request base only on low-income Residential customers.
RESPQNSE TO REQUEST NO. 26: Information regarding payment plans for
low-income customers is not available.
The response to this Request was prepared by Maggie Brilz, Customer Servce
Manager, Idaho Power Company, in consultation with Jason B. Willams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 32
REQUEST NO. 27: Please provide any study, report, memo or other written
document of any nature in the possession or control of the Company that considers,
evaluates or discusses the relationship between residential payment-troubles and low-
income status. Separately provide any such study, memo, report or other written
document that examines these relationships for Company customers.
RESPONSE TO REQUEST NO. 27: Idaho Power does not track income as part
of its customer information. Beginning in November 2009, Idaho Power began
preparing a monthly report that details certain information for Residential class
customers who have received energy assistance wihin the previous 12 months. A copy
of each monthly report from November 2009 through August 2011 is provided on the
confidential CD. Because the reports contain confidential material and non-public
information, Idaho Power is providing this information only to parties that have executed
the Protective Agreement in this case.
The response to this Request was prepared by Maggie Brilz, Customer Servce
Manager, Idaho Power Company, in consultation with Jason B. Williams, Corprate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 33
REQUEST NO. 28: Please provide a detailed descnption of how the Company
calculates its uncollectible allowance (i.e., the amount of bad debt the Company
considers it will not likely recover).
RESPONSE TO REQUEST NO. 28: The Company used its 2010 actual
uncollectible accounts or "bad debt" expense (Federal Energy Regulatory Accunt
("FERC") Account 904) as its forecast of that same expense category for the 2011 Test
Year. The 2010 FERC Accunt 904 balance was used as the basis for the forecast of
2011 because the Company believed that the 2011 FERC Account 904 amount would
not difer matenally from the 2010 level.
The response to this Request was prepared by Timothy E. Tatum, Senior
Manager of Cost of Service, Idaho Power Company, in consulttion with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 34
REQUEST NO. 29: For the most recent three (3) years (starting with the test
year), please provide the following data for all residential customers:
a. The total number of customers receiving L1HEAP assistance;
b. The total dollar amount per customer of L1HEAP assistance;
c. The total number of customer accunts receiving L1HEAP
assistance that are in arrears, and;
d. The total number and dollar amount of L1HEAP accunts wrtten off
as bad debt.
RESPONSE TO REQUEST NO. 29:
a. Please see the Company's response to Commission Staffs Production
Request No. 35.
b. The total dollar amount of lIHEAP assistance received per customer is
not available.
c. Information regarding customer accunts receiving L1HEAP assistance
that are in arrears is available from November 2009 forward. PÎease see the
Company's response to Commission Staffs Production Request No. 1.57.
d. The Company does not track the total number of L1HEAP accounts written
off. Information regarding the dollar amount of lIHEAP accounts written off is available
from November 2009 forward. Please see the Company's response Commission Staffs
Production Request No. 167.
The response to this Request was prepared by Maggie Brilz, Customer Servce
Manager, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 35
REQUEST NO. 30: Does the Company offer any conservation programs that
target customers whose income levels are slightly above the eligibilty threshold for
WAQC (e.g., 200-250% of Federal Povert Level)?
RESPONSE TO REQUEST NO. 30: Yes. Idaho Powets Weatherization
Solutions for Eligible Customers program offers weatherization measures to customers
whose income is between 175 percent and 250 percent of the federal povert level.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consulttion with Jason B.
Willams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 36
REQUEST NO. 31: If your response to the preceding Request is in the
affrmative, please provide the following:
a. A detailed description of the program including the tyes ,of
conservation measures included and who installs those measures;
b. The annual funded amount of the program;
c. What customer class( es) are eligible for the program;
d. How many customers participate in the program;
e. WHat the criteria for participation in the proram are;
f. Who verifies eligibilty for participation in the program and how;
g. Ifand how the program is relevant to a customer's income level;
h. When the program was implemented. and;
1. How the program is funded and recovere from ratepayers.
RESPONSE TO REQUEST NO. 31:
a. A complete description of the Weatherization Solutions for Eligible
Customers program ("Program") can be found on pages 62-65 of Idaho Powets
Demand-Side Management 2010 Annual Report, provided in the Company's response
to CAPAI's Request NO.1 above.
b. The annual expenses for the Program can be found on page 134 of Idaho
Powets Demand-Side Management 2010 Annual Report, provided in the Company's
response to CAPAl's Request NO.1 above.
C. Residential customers who meet the Program qualifications are eligible.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 37
d. The annual number of participants in the Proram can be found on page
134 of Idaho Powets Demand-Side Management 2010 Annual Report. provided in the
Company's response to CAPAl's Request NO.1 above.
e. The cnteria for the Proram can be found on pages 62-65 of Idaho
Powets Demand-Side Management 2010 Annual Repor, provided in the Company's
response to CAPAl's Request No. 1 above.
f. Potential participants are applicants for the WAQC program who are
denied weatherization servces by the CAP agencies due to being ineligible based on
income or. are eligible but have no priority on the weathenzation list. When these
customers are denied weatherization assistance, they are considered for services from
the Program. The Program contractors then verify that the applicant's meet the
Program requirements, including income guidelines.
g. Applicants for the Program must satisfy the income level requirements as
well as all other Program requirements as describe on pages 62-65 of Idaho Powets
Demand-Side Management 2010 Annual Repor, provided in the Company's response
to CAPAI's Request NO.1 above.
h. Th Proram was firs implemented as a pilot in 2008.
i. The Proram is fued throug the Idaho Energ Eff. Rider, Idaho
Rate Schedule 91, as shown on page 128 of Idaho Powts Demand-Sid Management
2010 Annual Repo, provied in the Company's repons to CAPAl's Request NO.1
above.
Th reponse to this Reques wa prepare by Pete Pengilly, Customer
Reserch and Analyis leaer, Idaho Power Company, in consulttion wi Jason B.
Wiliams, Corprae Counsel, Idaho Power Company.
IOAH POER COMPANS RESPNSE TO COUNITY ACTIO PARNERSHIP
ASSIATION OF IDAHO'S FIRST DISCOVEY REQUESTS TO IDAHO POWER - 38
REQUEST NO. 32: Please provide a copy of any wrtten document in the
possession or contrl of the Company, whether or not prepared for the Company,
assessing, estimating or otherwise discussing the number of low-income customers
served by the Company. To the extent that such document has been prepared by or for
the Company, include all source documents underlying the estimate of the number of
low-income customers.
RESPONSE TO REQUEST NO. 32: Idaho Power does not collect or retain
customers' income information and has not conducted, nor has any part conducted on
its behalf, any analysis assessing, estimating, or otherwse discussing the number of
low-income customers served by the Company.
The response to this Request wcs prepared by Pete Pengily, Customer
Research and Analysis leader, Idaho Power Company, in consulttion with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 39
REQUEST NO. 33: Please provide a detailed wrtten description of all residential
energy effciency programs offered exclusively to low-income customers of the
Company.
RESPONSE TO REQUEST NO. 33: Idaho Power offers two programs to
income qualified customers, the WAQC and the Weatherization Solutions for Eligible
Customers programs. Complete descriptions of these programs can be found on pages
59 and 62 of Idaho Power's Demand-Side Management 2010 Annual Report, provided
in the Company's response to CAPAI's Request NO.1 above.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consulttion with Jason B.
Willams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 40
REQUEST NO. 34: Please prQvide a single copy of any study within the
possession or control of the Company, that distinguishes between residential customers
generally and low-income residential customers in particular. Factors that might
distinguish the tw classes might include, but are not limited to: (a) usage levels and
patterns; (b) history of payment troubles; (c) consumption of energy effciency services;
(d) credit and collection history, and; (e) consumption of Company resources such as
staf time.
RESPONSE TO REEST NO. 34: Idaho Power doe not collect or rein
customers' incme informatin and has no conducted, nor has any part conducted on
it behalf. any analyis that distnguishes been residential customers generally and
low-income reidential custmers in particlar. This indudes Reques No. 34(a). (b),
(d), and (e) above. In reponse to Requet No. 34c), the Company do rerd and
report on partpation in the WAQC and the Weatherizatin Solutns for Eligible
Customers prorams. Participation metrics for thes prorams can be found on pages
134 and 135 of Idaho Powets Demand-Side Management 2010 Annual Report,
provided in the Company's response to CAPAI's Request No. 1 above.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 41
REQUEST NO. 35: Plese prvie the following data for Idaho Powets
Residentl rate class for eac of the past fi (5) yers:
A. Averae revenue per kilowatt hour sold;
B. Average kilowatt hour sales per customer;
C. Average monthly custmer bil;
D. Averae number of customers.
RESPONSE TO REQUEST NO. 35: Please see the followti table representing
Idaho Power sysem wide dat. This data is frm the repeve annul FERC Form 1
Report.
2006 2007 2008 20 2010
Average revenue per $~0591 $.0590 $.0667 $.On3 $.0806
kWh so
Average kWh sales 13,071 13.157 13,160 13,083 12,188
per customer
Average montly $64.39 $64.65 $73.14 $8.23 $81.91
customer bil
Average number of 387,707 397,286 402,520 405,144 407,551
customers
The reponse to this Reque wa prpare by Dartne Nemnic, Senior
Regulatory Affairs Analys; ldaho Power Company, in consulttion wi Jason B.
Williams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 42
REQUEST NO. 36: Regarding the preceding Production Request, does the
Company track and maintain the requested data for its low-income Residential class
customers?
RESPONSE TO REQUEST NO. 36: Idaho Power does not collect or retain
customers' income information.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Companyi in consultation with Jason B.
Willams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 43
REQUEST NO. 37: If your response to the preceding Prouction Request is in
the affrmative, please provide said low-income data.
RESPONSE TO REQUEST NO.. 37: Please see the Company's response to
CAPAI's Request No. 36 above.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 44
REQUEST NO. 38: Has Idaho Power made any calculations or conducted any
analyses of the amount and nature of low-income residential usage as opposed to non-
low-income residential usage, whether low-income usage difers, and the reasons why it
differs?
RESPONSE TO REQUEST NO. 38: Please see the Company's response to
CAPAI's Request No. 36 above.
The response to this Request was prepare by Pete Pengily, Customer
Research and Analysis leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 45
REQUEST NO. 39: In addition to low-income weatherization, please identif all
programs Idaho Power offers that it perceives to be of assistance to its low-income
customers in paying their electric bil and provide an explanation and itemization of the
nature and degree of assistance provided by any such program.
RESPONSE TO REQUEST NO. 39: Project Share is a year-round energy
assistance program started by Idaho Power in 1982 and is administered by The
Salvation Army. The program provides energy aid to qualifying households who heat
with electricity, gas, wood, propane, oil, or coal. Project Share's program year is from
October 1 through September 30 of each year. During the 2009/2010 program year,
2,020 grants were given assisting 6,423 individuals. In program year 2009/2010, Idaho
Power's customers donated $218,225 to Project Share and Idaho Power shreholders
donated $21,823 for The Salvation Army to administer the program and $100,000 for
additional assistance to low-income individuaL. Through August of program year
2010/2011, Idaho Power's customers donated $197,727 to Projec Share and Idaho
Power shareholders donated $19,773 for The Salvation Army to administer the program
and $20,000 for additional assistance to the low-income individuals. In addition to these
donations to Project Share, tw of Idaho Power's energy effciency programs, See Va
later Refrigerator and Home Appliance Program, offer the option for proram
participants to assign their incentives to Project Share. This generated an additional
$3,310 in donated incentives in the 2010/2011 program year.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 46
REQUEST NO. 40: Please provide the name and title of every Idaho Power
agent or employee who is involved with and/nr wo'rks on the Company's WAQC
program.
.,
RESPONSE TO REQUEST NO. 40: The Company employs multiple employees
in multiple positions that are involved with or work on the WAQC program. These
employees include, but are not limited to, a Special Needs Program Specialist, Energy
Effciency Analysts, Information Technology Analysts and System Administrator,
Financial Analyst, Regulatory Analysts, Communication Specialist, Residential Program
Leader, Customer Research and Analysis Leader, lawyers, Customer Servce Center
Representatives, and the Manager of Customer Relations and Energy Effciency. Idaho
Power has not provided the names of its employees as the employee names are not
relevant. Instead, the Company has provided in this response titles of employees who
work on the WAQC program.
The Company also contracts with individual CAP agencies, with Momentum,
LLC, and with The Energy Auditor for consulting.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis leader, Idaho Power Company, in consultation with Jason B.
Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER ~ 47
REQUEST NO. 41: For each employee or agent identifed in response to the
preceding Request, please specifc precisely what tasks and functions said agent or
employee performs with respect to WAQC and provide a hierarchy chart outlining levels
of authority and who reports to whom.
RESPONSE TO REQUEST NO. 41: The Special Needs Program Specialist
works with the CAP agencies, CAPAI, other contactors, and internal employees to
administer the WAQC program. The Energy Effciency Analysts perfrm cost-
effectiveness analysis and reporting. The Information Technology ("IT") Analysts and
Administrators support the data base and the CAP agency portal design and
maintenance. The Financial Analysts perform accounting and financial analyses. The
Communicaion Spealist assist in internVexternal comunicatins and marketing.
The Regulatory Analy cordinae reulatory reportng, filings, and reulatory affairs.
The Residental Proram Leaer supervse the Speial Nees Proram Specialist.
The Customer Research and Analyis Leader provides analyticl and reportng support.
The law provide leal suppo. Customer Servce Center Represtatives field calls
concrnng the WAQC proram and make referrls. The Manager of Customer
Relatns and Energy Efflciency supervse th leaers in the Custmer Relations and
Energ Effciecy department.
The indivual CAP agncs administer the proram and conduct the
weatherition pro. In addition, Momem, LLC, and The Enery Auditor provide
qualit assrance on the homes wetheried by the CAP agency weatherition
depart. Provi on the non-nfl CD is the most re orgniztin chart
for the Custmer Relatons and Energ Effciency departmen. This chart includes
IDAHO POER COANY'S RESPE TO COMMUNIT ACTION PARERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 48
everyone from the Customer Relations and Energy Effciency departments listed above.
Resources from other departments such as IT, Legal, Regulatory Affairs, Customer
Service, and Corporate Communications are not included in this chart as they have no
direct reporting relationship to the Customer Relations and Energy Effciency
department.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Wiliams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 49
REQUEST NO. 42: For each agent or employee identied in response to the
preceding Requests, please specif how much of their daily work is exclusively related
to WAQC as oppose to any other function.
RESPONSE T9 REQUEST NO. 42: The Special Needs Program Specialist
specifically charges his/her time to the WAQC work order and spends about 40 percent
of his/her time working on WAQC. The other Idaho Power employees who work on the
WAQC program do so as ongoing and general business support that Idaho Power has
provided for the WAQCI Low Income Weatherition Assistance programs for over
twenty years. The amount of time each employee dedicates to WAQC varies
dramatically based on program support needed but typically none of the employees
specified in the proceeding requests, except the Special Needs Program Specialist,
dedicates more than about 5 percnt of their time exclusively related to WAQC.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Jason B.
Willams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 50
REQUEST NO. 43: Please state whether there are any positions wholly or
partially dedicated to WAQC wihin the Company that are currently unfilled, how many
positions, and what their respective responsibilties and purposes are.
RESPONSE TO REQUEST NO. 43: There are currently no unfilled positions at
Idaho Power dedicaed to the WAQC program.
The response to this Request was prepared by Pete Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consulttion with Jason B.
Wiliams, Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 51
REQUEST NO. 44: Has the Company conducted any analyses or is it aware of
any documentation demonstrating a connection between the ratings given it by credit
rating agencies such as Standard & Poots and the implementation of the Company's
Power Cost Adjustment Mechanism (PCAM) at any point since the PCAM was first
approved? By this Request, CAPAI seeks information regarding the effect, if any, that a
power cost adjustment mechanism has had on earnings stabilty and the resultng
reduction of nsk and resulting reactions of financial institutions affecting the Company's
credit rating.
RESPONSE TO REQUEST NO. 44: No. However, Standard & Poots has
referenced the credit supportive ness of the Power Cost Adjustment mechanism (notably
the mechnism in place since 2009) by the follong statement:
IPC's rese annual power cost adjunt (PCA)
mechanism in Idaho. implemented in 200, supports crit
quality and reuce the undercllecion of por costs. The
most signifcant crit-support component. of the
annually filed PCA mecanism incude a sharing provision
that reuces th copany's power cost exposure to 5% of
undercllected co. and a forecast cost methology that
reuces deferrls an collecon lag. In exceptinally low
water yers. defrrls can materilly weken cash flws and
crit metrcs, but Standard & Poots generally viws such
collecn delays as temporary beuse we exp that 95%
of cost above base rates will be coUe wi a carring
charge over 12 monts. The prvious PCA mecanism,
which was less robust. had a long history of support and no
record of signifcant disaUownc.
Standard & Poor's Resrc May 20. 2011.
The reponse to this Reques was prpare by lawrnce F. Spencer, Investor
Relations Direr, Idaho Powr Company, in cosulttion wi Jason B. Wiliams,
Corprae Counsl, Idaho Por Company.
IDAHO POER COMPANS RESPOE TO COMMUNIl ACTI PARTERSHIP
ASSIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 52
REQUEST NO. 45: If your response to the preceding Request is in the
affirmative, please provide such analyses, the conclusions contained therein, and any
supporting documentation.
RESPONSE TO REQUEST NO. 45: Pleas see the Company's response to
, CAPAI's Request No. 44.
The response to this Request was prepared by Lawrence F. Spencer, Investor
Relations Director, Idaho Power Company, in consultatiön wih Jason B. Wiliams,
Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 53
REQUEST NO. 46: Please provide the same information set forth in the
preceding tw Requests with respect to the Company's Fixed Cost Adjustment (FCA)
mechanism.
RESPONSE TO REQUEST NO. 46: No. However, Standard & Poots has
referenced the risk mitigation aspects of the FCA by the following statement:
We do not consider load loss stemming from the company's
significant energy efficiency spending a significant risk, due
to a fixed-cost adjustment (FCA) mechanism in Idaho that
decouples certain costs from energy usage by residential
and commercial customers. However, the recent Idaho
commission decision to continue to allow IPC to utilze the
FCA but not on a permanent basis highlights the
uncertainties in determining the credit impact of energy
effciency spending.
Standard & Poor's Research May 20, 2011.
The response to this Request was prepared by Lawrence F. Spencer, Investor
Relations Director, Idaho Power Company, in consultation with Jason B. Wiliams,
Corprate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 54
REQUEST NO. 47: Please admit or deny that the existence of Idaho Powets
PCAM reduces "shareholder risk" as that term is generally used by credit raing
agencies.
RESPONSE TO REQUEST NO. 47: As discussed in Standard & Poots
Research report dated May 20, 2011, "Idaho reulators have authorized a robust cost
recovery mechanism to assist in collecting these costs (referring to the Power Cost
Adjustment Mechanism) and limiting financial exposure in Idaho, the company's chief
service area and primary driver of credit quality."
In the March 9, 2011, Moody's Investor Service credit opinion on Idaho Power,
Moody's stated, "The most significant change in process of the 2009 rate orders was
the power cost adjustment (PCA) rate decision. . .. Moreover, the IPUC revised the
sharing formula under the PCA mechanism to 95 percentl5 percnt
(customer/shareholders) from 90 percentl10 percnt previously, thereby somewhat
reducing risk to investors."
The response to this Request was prepared by lawrence F. Spencer, Investor
Relations Director, Idaho Power Company, in consulttion with Jason B. Willams,
Corporate Counsel, Idaho Power Cómpany.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 55
REQUEST NO. 48: Please admit or deny that the existence of its FCA reducs
"shareholder risk. "
RESPONSE TO REQUEST NO. 48: As discussed in Standard & Poor's
Reserch report dated May 20, 2011:
We (S&P) do not consider load loss stemming from the
company's significant energy effciency spending a
significant risk, due to a fixed-cost adjustment (FCA)
mechanism in Idaho that decouples certain costs from
energy usage by residential and commercial customers.
However, the recent Idaho commission decision to continue
to allow IPC to utilize the FCA but not on a permanent basis
highlights the uncertainties in determining the credit impact
of energy effciency spending.
In the March 9, 2011, Moody's Investor Service credit opinion on Idaho Power,
Moody's states:
The FCA is intended to aid in the predictbilty and
assurance of future cost recovery, as it attempts to assure a
fixed cost reimbursment from customers, independent of
the volume of energy used and variable costs. Any forward
looking approvals or trackers are viewed to be beneficial to a
company's credit profile, from Moody'S persective, since
they should lead to greater predictabilit of revenue levels
and cash flow recovery.
The response to this Request was prepare by Lawrnce F. Spencer, Investor
Relations Director, Idaho Power Company, in consultation with Jason B. Willams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 56
REQUEST NO. 49: Has the Company made any determ.ination rearding the
fruèncy and magnitude of planne general rate case filings in th next five (5) yers?
If sO, piease state what that determination is.
RESPONSE TO REQUEST NO. 49: No.
The response to this Request was prepared by Mike Youngblood, Managèr of
Rate Design, Idaho Power Company, in consultation wih Jason B. Wiliams. CorpOrate
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 41h day of Qdobér2Ö11.
. ~-£Q :: ~
J B. WILLIAMS
A omey fo Idaho POW Company
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION Oi: IDAHO'S FIRST DiSCOVERY REOUESTS TO IDAHO POWER - 57
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 4th day of October 2011 I served a true and
corrct copy of the within and foreoing IDAHO POWER COMPANY'S RESPONSE TO
COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO'S FIRST
DISCOVERY REQUESTS TO IDAHO POWER upon the following named parties by the
method indicated below. and addressed to the following:
Commission Staff
Donald L. Howell, II
Karl T. Klein
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email Don.Howelicæpuc-idaho.gov
Karl.Klein(gpuc. idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Grery M. Adams
RICHARDON & O'lEAY. PLLC
515 Nort2¡l Stret (83702)
P.O. Box 7218
Boise. Idaho 83707
Hand Delivered
U.S. Mail
_Overight Mail
FAX
-2 Email peer(nchardsonandolerv.com
gregnchardsonandolearv.com
Dr. Don Reaing
Ben Johnson Asciates. Inc.
6070 Hill Road
Boise, Idaho 83703
Hand Delivered
U.S. Mail
_ Overight Mail_FAX
-2 Email drtjohnsoassciates.com
Idaho Irrgaon Pumpers Asiaon, Inc.
Enc L. Olsen
RACINE. OLSON. NYE. BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocello,-Idaho 832041391
Hand Oeive
U.S. Mail
_ Ovrnight Mail_FAX
-2 Email elo(âracinelaw.net
Anhony Yankel
29814 Lake Roa
Bay Villag. Ohio 44140
Hand Delivered
_U.S. Mail
_ Ovrnight Mail_FAX
-2 Email tonvcmvankel.net
IDAHO POER CÒMPAN'S RESPOE TO COUNITY ACTION PARERSHIP
ASSOIATION OF IDAHO'S FIRST DISCVERY REQUESTS TO IDAHO POWER - 58
The Kroger Co.
Kurt J. Boehm
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Kevin Higgins
Energy Strategies, LLC
215 South State Street, Suite 200
Salt lake City, Utah 84111
Micron Technology, Inc.
Mary V. York
HOLLAND & HART, LLP
101 South Capital Boulevard, Suite 1400
Boise, Idaho 83702
Richard E. Malmgren
Senior Assistant General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, Idaho 83716
The United States Departent of Energy
Arthur Perry Bruder, Attorney-Advisor
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
Dwight D. Etheridge
Exeter Associates, Inc.
10480 Little Patuxent Parkway, Suite 300
Columbia, Maryland 21044
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email kboehm(ãBKLlawfrm.com
jrhcabattisher. com
Hand Delivered
U.S. Mail
_ Overnight Mail_FAX
-2 Email khigginscmenergystrat.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email myorkcmhollandhart.com
tnelsoncaholland hart. com
madavidsoncmhollandhart.com
fschmidtCâhollandhart.com
Inbuchanancmhollandhart.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email remalmgrencmmicron.com
Hand Delivere
U.S. Mail
_ Overnight Mail
FAX
-- Email Artur.brudercahg.doe.gov
Steven.portercmhg.doe.gov
_Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
X Email detherigecmexeterassociates.com
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POWER - 59
C.ommunily Aeton Partrshlø
Asociation of Idaho
Brad M, Purdy
Attorny at Law
2019 Nort 17th Stret
BOise. Idaho 83702
_Hand Delivere
_U.S. Mail
_Overnight Mail_FAX
-l. Email bmpurdYOhotmail.com
Idaho COnsrvat()nLeague
Benjamin J. Oto
Idaho COnservatiOn Leaue
110 NOrth SixtStrt (83702)
P.O. Box 844
Boise, Idaho 83101
_Hand Deivere
U.S. Mail
_.QvernigtMaii
FAX
-l Email botto(gidahoconservafion.()m
S.nake River Alliance
Ken Miler
Snake. River Allance
P.O. Box 1731
Boise, Idaho 83701
_Hand Delivere
_U.S. Mail
_ Overnight Mail_FAX
-l Email kmilercmsnakerieraUiClnce,om
_Hand Delivere_U.S. Mail
_ Overnight Mail
FAX
-l Email nançynwnemy.org
_Hand Delivere
_U.S. Mail
_ OvemightMail_FAX
-l EmailioeømcdeVi-miler.oomheathrtmcdevitt-miller.êOm
NW Energy Coalition
Nancy Hirs, POlicy Direcor
NW Energy COaliton
811 Firs Avenue, Suit 305
Sea, WashingQn 98104
Hoku Matrials, Inc.
Dean J. Miller
McDEVITT & MILLER LLP
420 East Bannock (83702)
P.O. Box 2564
Boise, Idaho 83701
Scott Pavl,CEO
Hoku Møterials, Inc.
One Hokv Way
Poctello, Idaho 83204
Hand Deliv
U.S. Mail
_Ovrnight Mail
FAX
X Email spaul~hokucorp.com- "
~ ,~~S2 _~illams ~
IDAHO POER COMPANS RESPONSE TO COMMUNIT' ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST DISCOVERY REQUESTS TO IDAHO POER - 60