200403011st Request of Staff to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO.
CASE NOS. AVU-04-
A VU-04-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that Avista Corporation (Avista; Company)
provide the following documents and information on or before WEDNESDAY, MARCH 24, 2004.
The Company is reminded that responses pursuant to Commission Rules of Procedure must
include the name and phone number of the person preparing the document, and the name, location
and phone number of the record holder. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and A vista is requested to provide
by way of supplementary responses, additional documents that it or any person acting on its behalf
may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 , 2004
For each item, please indicate the name of the person(s) preparing the answers, along with the
job title of such person( s) and the witness who can sponsor the answer at hearing. For all responses
to the following requests, please provide all workpapers, diskettes (3.5 in.), CDs and all
underlying formulas in Excel (version 5) language.
STAFF PRODUCTION REQUEST NOS. 1 - 29 PERTAIN TO THE COMPANY'
NATURAL GAS OPERATIONS
Request No.1: Please provide the complete natural gas and electric weather normalization
calculation, including all workpapers, Excel spreadsheets, weather data, and regression calculations.
(Reference TLK-GI) Please include the following natural gas data:
Please provide the average use per residential and small commercial (Schedule
101) customer by month for each year 1989-2003. In addition to the averages for
schedule 101 please provide the average residential and the average commercial
customer data separately. Include all workpapers.
Please provide the average weather normalized use per residential and small
commercial (Schedule 101) customer by month for each year 1989-2003. In
addition to the averages for Schedule 101 , please provide the average residential
and the average commercial customer data separately. Include all workpapers.
Please provide the monthly and annual number of customers and volumetric gas
usage for each year 1989-2003 for each of Tariff Schedules 111 , 121 , 122, 131
132 and 146.
Request No.2: Please provide a weather sensitivity analysis as shown on TLK-G2 for the
following time periods:
7/93-12/98
7/94-12/99
7/95-12/00
7/96-12/01
1/98-12/02
1/99-12/02
7/99-12/02
1/00-12/02
7/00-12/02
1/01-12/02
7/01-12/02
1/02-12/02
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1, 2004
Request No.3: For Idaho usage, please provide an Idaho-specific weather normalization
regression calculation based on weather and customer data separated into two geographical areas, the
Sandpoint/Coeur d' Alene area and the Lewiston/Moscow area.
Request No.4: Please provide the study that determined that the average residential and
small commercial (Schedule 101) usage has decreased from 82 therms/mo to 73 therms/mo. Include
all workpapers.
Request No.5: Please provide the following test year Schedule 101 data: a) number of
monthly bills terminating in the block, b) monthly therms from bills terminating in the block, and c)
cumulative monthly therms used within the block. Provide the data in blocks of 10 therms from 0-
200 therms/mo and blocks of 50 therms from 200-500 therms/mo and all over 500 therms/mo. In
addition to the data for Schedule 101 please provide residential and commercial information
separately.
Request No.6: Please provide the following test year Schedule 111 data: a) number of
monthly bills terminating in the block, b) monthly therms from bills terminating in the block, and c)
cumulative monthly therms used within the block. Provide the data in blocks of 200 therms from 0-
1000 therms/mo and blocks of 400 therms from 1000-5000 therms/mo, and all over 5000
therms/month.
Request No.7: Please provide the following test year Schedule 121 data: a) number of
monthly bills terminating in the block, b) monthly therms from bills terminating in the block, and c)
cumulative monthly therms used within the block. Provide the data in blocks of 500 therms from 0-
000 therms and blocks of 1 000 therms from 10 000-000, and all over 000 therms/mo.
Request No.8: Please explain why the current W ACOG included in rates is the most
appropriate W ACOG to be included in base rates for this rate case. Include all supporting
documentation.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 2004
Request No.9: Please provide the Company s anticipated forward monthly natural gas
prices at each of the northwest trading hubs, Sumas, AECO, and Rockies for the next 10 years.
Include all supporting documentation.
Request No. 10: Please provide the Company s anticipated W ACOG included in natural gas
rates for each of the next 5 years and the anticipated 5-year W ACOG. Include all supporting
documentation.
Request No. 11: Are the forecasted natural gas prices in the power supply model the same as
the forward gas prices used for the estimated W ACOG? If not, please explain the differences.
Request No. 12: Avista s current Tariff Schedules 101 , 111 , 112, 121 , 122, 131 , 132 and 146
are subject to the Purchase Gas Adjustment Schedule 150, Gas Rate Adjustment Schedule 155, Tax
Adjustment Schedule 158, and DSM Rider Adjustment Schedule 191. With the exception of Tax
Adjustment Schedule 158, please explain what would be required for the Company to summarize the
listed Adjustment Schedules on each of the Tariff Schedule Sheets in addition to the current
reference. If summaries cannot be provided on each Tariff Schedule, please explain why.
Request No. 13: Please provide the number of interruptions and volume of interruptions for
each interruptible and transportation gas customer for the last 5 years.
Request No. 14: Under what circumstances are interruptible and/or transportation customers
interrupted? Are the conditions the same for transportation customers as interruptible customers?
not, please describe the differences.
Request No. 15: Can interruptible and transportation customers be interrupted for conditions
other than reliability? If so, what are the other conditions for interruption? Please provide all
supporting documentation, written policies, etc.
Request No. 16: Please provide the anticipated annual benefit (operationally and/or
financially) provided to Idaho Customers by Avista s interruptible gas customers.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MARCH 1 , 2004
Request No. 17: Will the Company realize the same level of interruptible benefit from the
proposed changes in Schedule l46? Please explain why or why not.
Request No. 18: Please explain how the overrun and underrun penalties and levels were
determined for the Company s proposed Schedule 146 changes. Include all supporting
documentation.
Request No. 19: To what extent do the penalties and levels proposed in Schedule 146 reflect
costs that are or could be incurred by the Company?
Request No. 20: Are all Schedule 121, 131 and 146 customers only served by mains larger
than 4-inch? Please explain how this is verified and include all supporting documentation.
Request No. 21: Please provide copies of contracts, in place over the last 5 years, for long-
term (greater than 1 month) release, lease or resale of Avista s natural gas storage facilities.
Request No. 22: What is the total volume of Avista s storage released, leased or resold in
each of the last 5 years? How does the quantity compare to A vista s total storage volume? Include
all workpapers and supporting documentation.
Request No. 23: Over the last 5 years, what was the monthly and annual revenue and/or
other benefit that A vista received from the release, lease or resale of its storage resources? Include
all workpapers and supporting documentation.
Request No. 24: What is the withdrawal capacity of the Jackson Prairie storage facility?
What is A vista s withdrawal capacity? How is withdrawal capacity allocated among the various
owners of the storage facility?
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 , 2004
Request No. 25: Does Avista control sufficient pipeline transportation to enable the use of
all of its storage resources including storage currently leased, released or sold to others? If not
please describe any additional transportation resources necessary and the costs associated with
acquiring these resources.
Request No. 26: What is Avista s average and maximum daily load volatility from the
forecasted monthly average daily usage? Could this volatility be met from Jackson Prairie storage?
Please explain why or why not.
Request No. 27: Avista has recently relied on financial hedging to provide some level of
natural gas price stability. Please provide all data on all hedges executed from 1999 to present.
Please provide the analysis that indicates that maintaining this practice is preferred (operationally
andlor financially) to reacquiring all of Avista s storage resources.
Request No. 28: On February 13, 2004, the Washington UTC issued an Order in
Docket UG-02l584 that indicates the current natural gas Benchmark Mechanism will no longer be
acceptable and has directed the Company to present a plan for transferring back to Avista Utilities the
functions performed by A vista Energy under the Benchmark Mechanism. What operational changes
and additional costs (if any) are anticipated in Idaho as a result ofthe Company s compliance with
this Order?
Request No.29: Please provide all gas and electric load research data/statistical studies and
associated documentation used in this case.
STAFF PRODUCTION REQUEST NOS. 30 - 79 PERTAIN TO CONSUMER ISSUES
Request No. 30: Does the Customer Contact Center handle calls from all states served by
A vista or are specific Customer Service Representatives assigned to handle calls from Idaho
customers?
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 , 2004
Request No. 31: Are the employees who handle outages and emergencies separate from
Customer Service Representatives in the Contact Center. If so , do those representatives have
different titles and skill levels? Please explain.
Request No. 32: Please provide Avista s established service level goal for its Customer
Contact Center.
Request No. 33: Please provide actual service levels by month for the past four years (2000-
2003).
Request No. 34: Please provide the numbers of abandoned calls recorded by month for the
past four years (2000-2003).
Request No. 35: For each of the past four calendar years (2000-2003), please provide the
total dollar amount contributed to Project Share by: a) Avista s shareholders; b) Avista s employees;
c) contributions from Idaho customers; and, d) other sources.
Request No. 36: What was the total dollar amount received by Avista s customers from
Project Share in each of the past four calendar years (2000-2003)? How many customers received
assistance in each of those years?
Request No. 37: Other than Project Share, did the Company or its shareholders contribute to
community-based organizations for the purpose of providing services to or paying bills of low-
income A vista customers in Idaho? If so, please provide a list of the amounts and the recipients of
the funds for the past four years (2000-2003).
Request No. 38: Please provide the Company s written record of complaints and requests for
conferences from the year 2003 , kept pursuant to Rule 403 of the Commission s Utility Customer
Relations Rules (UCRR) IDAPA 31.21.01.403.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 , 2004
Request No. 39: Please provide a sample copy of the Rules Summary required by Rule 701
(UCRR) sent to customers served under Schedules 1 , 11 , 21 , and 31. Please explain how and when
these customers are given the summary?
Request No. 40: Please provide a sample copy of the form used as required by UCRR
Rule 104 entitled Written Explanation for Denial of Service or Requirement of Deposit.
Request No. 41: Under what circumstances does A vista collect deposits for residential
customers?
Request No. 42: Under what circumstances does Avista collect deposits for small
commercial accounts?
Request No. 43: Please provide the formula used to calculate deposits for residential and
small commercial customers.
Request No. 44: How and when are deposits refunded for both residential customers and
small commercial customers?
Request No. 45: Please provide a sample copy ofthe initial receipt for the first deposit
installment as required by Rule 109 (UCRR). Provide a copy of the receipt for the second
installment, if such receipt is different from the first.
Request No. 46: Please provide sample bills that are current and NOT past due for customers
served under Rate Schedules 1 , 11 , 21 , and 31.
Request No. 47: Please provide a sample Schedule 1 bill with a past due balance.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 2004
Request No. 48: In accordance with Rule 206.03 (UCRR), please provide a sample copy of a
Customer Notice that informs the customer ofthe Company s intent to: a) transfer an amount owed
from a former service location; or, 2) transfer an amount owed for another person s bill.
Request No. 49: Please provide a sample copy of the Notice left at the customer s premises
following disconnection of service for non-payment. If customers served under different Rate
Schedules receive a different type of notice, include a sample copy of each notice for each of the
Schedules 1 , 11 , and 31.
Request No. 50: Please provide a sample copy of the Annual Rate Summary provided to
customers as required by Rule 101 , Utility Customer Information Rules (UCIR) IDAPA
31.21.02.101.
Request No. 51: Does the Company make available to customers a pre-printed form for the
medical emergency certificate required by Rule 308 (UCRR)? If so, please provide a sample copy of
the form.
Request No. 52: For master-metered accounts and residents or occupants who are not
customers but who are in jeopardy oflosing service, please provide a sample copy of the Notice
required by Rule 312 (UCRR).
Request No. 53: Please provide a sample copy of the Seven Day Notice required by Rule
304 (UCRR) when the Company intends to terminate service under Rule 302.
Request No. 54: Please provide a sample copy of the written Twenty-Four Hour Notice
required under Rule 304 (UCRR).
Request No. 55: Please provide a sample copy of any brochure or other printed material
regarding the Company s Third-Party Notice program. How and when is this material provided to
customers?
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 , 2004
Request No. 56: Please provide a sample copy of any brochure or other printed material
regarding the Company s Level Pay Plan. How and when is this material provided to customers?
Request No. 57: Please provide a sample copy of any brochure or other printed material
regarding the Company s Winter Payment Plan. How and when is this material provided to
customers?
Request No. 58: How are residential customers made aware of the protection from
disconnection (i.e. the winter disconnection Moratorium) that is available to qualifying customers
during the months of December through February? Please provide brochures or other printed
material explaining to customers how to declare eligibility for protection from disconnection. When
and how is this information distributed?
Request No. 59: Are any of Avista s brochures, notices, forms, and bills available in Spanish
or other languages? If so, please indicate the language(s) and information available.
Request No. 60: If there is written material available in languages other than English, how
are customers made aware of their availability?
Request No. 61: How many customer service representatives in the Customer Contact
Center speak Spanish? Is there always a Spanish-speaking representative available during Call
Center hours of operation?
Request No. 62: What provisions are made for assisting customers who speak languages
other than English or Spanish?
Request No. 63: How many attempts are made to contact customers either in person or by
telephone prior to disconnection as required by Rule 304.02 (UCRR)?
Request No. 64: Under what circumstances would a personal visit be made to satisfy the
requirements of Rule 304.02 (UCRR)?
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 , 2004
Request No. 65: Does the Company use an automated system to make outgoing calls to
satisfy the requirements of Rule 304.02 (UCRR)? If so, during what hours are calls made to
customers?
Request No. 66: In compliance with Rule 304 (UCRR), when calling a customer for the
Twenty-Four Hour Notice, what percentage of call attempts reach a live customer?
Request No. 67: With the Company s automated telephone system, when a customer
answering machine or voice mail picks up the call, does the automated system leave a message?
, please provide the text of that message.
Request No. 68: Please describe how the comfort level billing amount is calculated for a
Schedule 1 customer.
Request No. 69: Under what circumstances would a comfort level billing amount for a
Schedule 1 customer be revised prior to the l2-month anniversary of enrollment in such a plan?
Request No. 70: Does the Company routinely physically disconnect service after a customer
requests closure of an account or disconnection of service? If so, what are the average and maximum
intervals between receipt of the customer s requests and actual disconnection of service?
Request No. 71: What percentage of out-of-cycle meter disconnections are completed within
3 calendar days? 4-5 calendar days? More than 5 calendar days?
Request No. 72: When meters are left on between occupants, is a reading always taken again
when a new tenant moves in? Ifnot, please explain how the Company determines whether to read
the meter.
Request No. 73: In situations where a meter is not physically disconnected between
occupants, does the ending meter reading date given on bills for the departing customer correspond to
the actual date the meter was read? Ifnot, please explain.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 1 , 2004
Request No. 74: In situations where a meter is not physically disconnected between
occupants, does the beginning meter reading date given on the bill for the new customer correspond
to the actual date the meter was read following the customer s request to initiate service? If not
please explain.
Request No. 75: How many out-of-cycle meter readings were taken in 2003 where service
was not physically disconnected between occupants?
Request No. 76: How many out-of-cycle meter readings were taken in 2003 where service
was physically disconnected?
Request No. 77: When Avista establishes a meter reading schedule for its regular billing
cycles , does it always read the meter on the established days? If not, please explain why and how
often in 2003 the Company failed to read meters as scheduled.
Request No. 78: Please provide any cost benefit analysis or study prepared to demonstrate
the cost effectiveness of the Company s Cares Representatives.
Request No. 79: How many actual non-pay disconnects did Avista perform in each the
calendar years 1999 through 2003?
Dated at Boise, Idaho, this 6"/day of March 2004.
,$:-)p-
tt Woodbury
Deputy Attorney General
Technical Staff: Michael Fuss
Marilyn Parker
i:umisc:prodreq/avueO4,- avugO4, Iswmfmp
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MARCH 1 , 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF MARCH 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST TO A VISTA
CORPORATION, IN CASE NO. A VU-04-1IA VU-04-, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J. MEYER
SR VP AND GENERAL COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail dmeyer(illavistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE W A 99220-3727
E-mail Kelly .norwood(illavistacorp .com
~.
JC~
CERTIFICATE OF SERVICE