2004052413th Request of Staff to Avista.pdf

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
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UT iLlT1ES COf'1t'1ISS10N
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. A VU-04-
A VU -04-
THIRTEENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission (IPUC), by and through its attorney of
record, Scott Woodbury, Deputy Attorney General, requests that A vista Corporation (A vista;
Company) provide the following documents and information on or before MONDAY,
JUNE 7, 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.
THIRTEENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 21 , 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.
ST AFF PRODUCTION REQUEST NO. 290 PERTAINS TO NATURAL GAS ISSUES
Request No. 290: Please provide the total therm usage by customer class for each month in
the test year for all customer classes.
STAFF PRODUCTION REQUEST NOS. 291 AND 292 PERTAIN TO CONSUMER
ISSUES
Request No. 291: How much energy went unbilled in 2003 as a result of the Company
policy to leave meters connected between customer/tenant changes at a single location? Please
provide unbilled energy in both total kWhs on the electric service side and total therms on the
natural gas service side of the Company. What would be the total revenue associated with that
energy?
Request No. 292: What is Avista s estimated cost to perform actual closing and initial bill
meter readings in between scheduled meter readings rather than estimating readings when customer
changes occur at a single location? Please provide the analysis showing derivation of the cost
estimate.
Dated at Boise, Idaho this .df day of May 2004.
Technical Staff:Michael Fuss
MarilYn Parker
i:umisc:prodreq/avueO4.l avugO4.1jhl13
THIRTEENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 21 2004
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF MAY 2004
SERVED THE FOREGOING THIRTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO VISTA CORPORATION, IN CASE NO. A VU-04-
1/AVU-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
DAVID J. MEYER
SR VP AND GENERAL COUNSEL
VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail dmeyerCf!)avistacorp.com
KELLY NORWOOD
VICE PRESIDENT STATE & FED. REG.
AVIS T A UTILITIES
PO BOX 3727
SPOKANE WA 99220-3727
E-mail Kelly .norwoodCf!)avistacorp. com
CONLEY E WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-mail cewCf!)givenspursley.com
DENNIS E PESEAU, PH. D.
UTILITY RESOURCES INC
1500 LIDERTY ST SE, SUITE 250
SALEM OR 97302
E-mail dpeseauCf!)excite.com
CHARLES L A COX
EV ANS KEANE
111 MAIN STREET
PO BOX 659
KELLOGG ID 83837
E-mail ccoxCf!)usamedia. tv
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-mail bmpurdyCf!)hotmai1.com
MICHAEL KARP
147 APPALOOSA LANE
BELLINGHAM W 98229
E- mail michaelCf!)awish.net
E-mail don. falknerCf!)avistacorp. com
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SECRETARY
CERTIFICATE OF SERVICE