200404206th Request of Staff to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
CCEiVED (?J
, ,.
iOGt: f\PR 20 Mi 10: 52
! "~' "
:r";2;
"'! II' ; :L-:J l.ur-,i '0,) i'I
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF A VISTA 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-
SIXTH 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 TUESDAY MAY 4, 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.
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.
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA APRIL 20, 2004
For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.
CDs and all underlying formulas intact in Excel 2000 compatible language.
STAFF PRODUCTION REQUEST NOS. 183 AND 187 PERTAIN TO ACCOUNTING
ISSUES
Request No. 183: Please provide a month-to-month analysis reconciling the assets of the
Retirement Plan for Employees of A vista Corporation on a cash basis for the months of January -
December 2003.
Request No. 184: Please provide the actuarial report and calculations used to determine the
2004 FAS 87 Pension Expense of$14 million referred to on page 24 ofMr. Falkner s direct
testimony.
Request No. 185: It appears that Avista is not a member of the Western Electricity
Coordinating Council (WECC). As indicated on WECC's web site homepage "Membership in
WECC is voluntary and open to any organization having an interest in the reliability of
interconnected system operation or coordinated planning." Staff notes that Idaho s two other major
electric utilities, PacifiCorp and Idaho Power, are members. Please indicate Avista s reasons for
not being a member and explain how the Company, its customers and the western region are
affected by A vista s decision to not participate.
Request No. 186: What are the annual WECC membership fees?
Request No. 187: Referring to the Washington Utilities and Transportation Commission
Sixth Supplemental Order Rejecting the Benchmark Mechanism Tariff issued on February 13, 2004
regarding the affiliated interest arrangement between A vista Energy and A vista Utilities, please
answer the following questions:
(a) Please provide all documentation reviewed or prepared by Avista Utilities or Avista
Energy showing the continued reasonableness of the affiliate transactions associated
with the benchmark mechanism.
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA APRIL 20, 2004
(b) What accounting or tracking mechanism does A vista have in place to reflect cost
differences in the past and going forward between using A vista Energy or in-house
Avista Utilities' personnel to enter these energy transactions?
( c) If no mechanism is currently set up, please determine and explain a proposed
method to track differences in costs going forward.
STAFF PRODUCTION REQUEST NOS. 188 TO 206 PERTAIN TO CONSUMER ISSUES
Request No. 188: In 2003 , how many customer-requested disconnects were performed on
the regular billing cycle meter reading dates?
Request No. 189: Please provide the total number of out of cycle bills prepared for Idaho
customers in 2003.
Request No. 190: Regarding bills prepared outside of regular billing cycles in 2003, please
provide how many of the readings entered on the bills were determined by: a) a computer estimate;
b) a manual estimate; c) an actual reading by a Company employee; or, d) a customer-provided
reading.
Request No. 191: Please explain how a Customer Service Representative (CSR) decides
how to implement a customer s request to discontinue service. Describe how a CSR determines a
beginning bill's meter reading by estimating. Please provide copies of online help screens, printed
employee procedure manuals, or other written material explaining this process.
Request No. 192: When Avista estimates a meter reading either manually or by computer
for the purpose of preparing a closing or initial bill, does the customer s bill show "estimated" or
actual" to the right of the reading?
Request No. 193: How much money did Avista provide for weatherization programs in
Idaho for each of the past 4 years? Please identify the recipient and dollar amount provided.
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA APRIL 20, 2004
Request No. 194: How many Idaho Avista customers received the benefit of
weatherization in each of the past 4 years? How many of these were residential customers? What
is the average amount spent per home receiving weatherization benefits?
Request No. 195: Please explain why the Company was not able to meet its established
service level goal in the years 2001 and 2003.
Request No. 196: Please explain why the Company established its target service level to
answer 70% of calls within 60 seconds.
Request No. 197: Please provide the number ofIdaho Avista customers who applied for
Project Share assistance in each of the past 4 years but were denied assistance.
Request No. 198: Please provide the reason(s) why customers were denied Project Share
assistance?
Request No. 199: Please explain why Avista increased its donations to Project Share from
$50 000 in 2001 to $200 000 in 2002 and 2003.
Request No. 200: In response to Production Request No. 63, Avista states that if an
answering machine is reached or a live person is reached that a recorded phone message is left.
Please explain what efforts are made to obtain viable telephone numbers for customers at the time
of application for service. What efforts are made to update telephone numbers so that messages are
not being left at incorrect telephone numbers? Please explain why, if a live person is reached, a
recorded message is played rather than transferring the call to a CSR.
Request No. 201: In both gas and electric tariffs under Schedule 66 (Electric 14.3 and Gas
15.3), it states that a charge for reconnect will be increased by $4.00 for each additional service
reconnected at the same time. Please provide the cost justification for charging an additional $4.
to read 2 meters simultaneously. In each of the past 4 years, how many customers were billed this
fee? What was the total revenue collected in each of those years?
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA APRIL 20, 2004
Request No. 202: The response to Production Request No. 70 indicates service is
disconnected when there is no responsible person to bill and usage exceeds 500 kWh or 40 therms.
Does this mean that the Company takes a meter reading but leaves the service on until such time as
the 500 kWh or 40 therm thresholds are reached? Who pays for the energy usage between 0 and
500 kilowatt hours and between 0 and 40 therms when service is subsequently disconnected
because no one signs up for service before the limits are met?
Request No. 203: The response to Production Request No. 77 was unresponsive. Please
provide how often the Company failed to read meters on the regularly scheduled meter reading date
in 2003. If the Company does not read on the scheduled date, does the date shown on the bill
correspond to the actual reading date as opposed to the date the meter was scheduled to be read?
Request No. 204: In response to Production Request No. 62, the Company states it offers
Language Line assistance to customers who speak languages other than English. How are
customers made aware that this service is available?
Request No. 205: In Company Witness Hirschkorn s Exhibit No., Schedule 43-, under
SPECIAL TERMS AND CONDITIONS, the first paragraph has a change in the first line. The
word "Company" is being changed to the word "Customer . Please explain why the Company
proposes to shift responsibility from the Company to the customer.
Request No. 206: For each of the past 7 years (1997-2003), please provide the following
Idaho-specific system reliability data:
(a) System Average Interruption Duration Index (SAID I);
(b) System Average Interruption Frequency Index (SAIFI);
(c) Momentary Average Interruption Frequency Index (MAIFI);
(d) Number of trouble calls received from customers; and
( e) Five worst performing circuits.
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA APRIL 20, 2004
If A vista uses reliability indices other than those specified above, please provide those reliability
indices for the years specified. If A vista does not collect data specific to Idaho, please provide
systemwide data.
Dated at Boise, Idaho, this C)J"day of April 2004.
Technical Staff: Terri Carlock
Don English
Patricia Harms
Kathy Stockton
Marilyn Parker
i:umisc:prodreq/avueO4.avugO4.1sw6
SIXTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA APRIL 20, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF APRIL 2004
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-04-
1/AVU-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(q),avistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220-3727
E-mail Kelly.norwood(q),avistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-mail cew(q),givenspursley.com
DENNIS E PESEAU, PH. D.
UTILITY RESOURCES INC
1500 LIBERTY ST SE, SUITE 250
SALEM OR 97302
E-mail dpeseau(q),excite.com
CHARLES L A COX
EVANS KEANE
111 MAIN STREET
PO BOX 659
KELLOGG ID 83837
E-mail ccox(q),usamedia. tv
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-mail bmpurdyCfYhotmail.com
MICHAEL KARP
147 APPALOOSA LANE
BELLINGHAM W A 98229
E-mail michaelCfYawish.net
E-mail don.falkner(q),avistacorp.com
k~.k'~
SECRETARY
CERTIFICATE OF SERVICE