20080620Staff to AVU 153-177.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
R.. D.h"" L
ionB JUN 20 Atf 9: 22
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 NO. A VU-E-08-1
) A VU-G-08-1
)
) SIXTH PRODUCTION REQUEST
) OF THE COMMISSION STAFF
) TO AVISTA CORPORATION
)
)
The Staff of the Idaho Public Utilities Commission, by and though its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Avista Corporation (Company;
Avista) provide the following documents and information on or before MONDAY, JULY 7,
2008.
SIXTH PRODUCTION REQUEST
TO A VISTA CORPORATION 1 JUNE 20, 2008
This Production Request is to be considered as contini;ing, and A vista is requested to
provide, by way of supplementa responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparng the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 153: How many regular cycle bils were sent to customers in 20077
REQUEST NO. 154: How many regular cycle bils sent to customers in 2007 were
estimated (not based on an actul meter reading)?
REQUEST NO. 155: How many out of cycle (opening or closing) bils were sent to
customers in 20077
REQUEST NO. 156: Is it the Company's policy to not physically disconnect service
when a customer closes his/her account? If so, please explain the reason(s) for the policy and
provide any cost/enefit analysis performed to justify it.
REQUEST NO. 157: How many therms and kWh went unbiled in 2007 as a result of
the Company's policy to leave meters connected between customers? What is the total dollar
value of those unbiled therms and kWh?
REQUEST NO. 158: Please explain how the Company determines meter readings for
billng puroses when an account is opened or closed at the request of a customer.
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION 2 JUE 20, 2008
REQUEST NO. 159: Regarding opening bils prepared outside of regular biling cycles
in 2007, please provide how many of the readings on which the bils were based were
determined by: (a) an actual meter reading taken by a Company employee or via remote meter
reading; (b) a computer estimate; (c) a manual estimate made by a Company employee; (d) a
customer-provided reading; or (e) other methods.
REQUEST NO. 160: Under what circumstances is an opening bil for a new customer
prepared using the identical meter reading used in preparng the closing bil for the previous
customer?
REQUEST NO. 161: Regarding closing bils prepared outside of regular biling cycles
in 2007, please provide how many of the readings on which the bils were based were
determined by: (a) an actual meter reading taken by a Company employee or via remote meter
reading; (b) a computer estimate; (c) a manual estimate made by a Company employee; (d) a
customer-provided reading; or (e) other methods.
REQUEST NO. 162: If an actual meter reading is taken by a Company employee at the
customer's location when an account is closed, what is the normal interval between the time a
customer requests closure and the time the meter reading is taken? If a meter reading is taken via
remote meter reading when an account is closed, what is the normal interval between the time a
customer requests closure and the time the meter reading is taen?
REQUEST NO. 163: If an actual meter reading is not taen on the same day as the
customer's requested date of closure, what date is identified on the customer's bil for the meter
reading, the requested date of closure or the date the actul reading was taen?
REQUEST NO. 164: If an actual meter reading is taken by a Company employee when
an account is closed, does that employee disconnect service at that time? If a customer has both
SIXTH PRODUCTION REQUEST
TO A VISTA CORPORATION 3 JUE 20, 2008
gas and electric service, does the employee disconnect both services? If not, please explain why
not.
REQUEST NO. 165: Is Avista using AMR to read meters remotely when customers
open or close accounts? If not, why not? If so, please explain the process for taing a remote
meter reading not coincident with the customer's regular meter reading cycle.
REQUEST NO. 166: Please describe in detail procedures implemented by Avista to
monitor gas and electric usage to identify slow and dead meters in a timely maner.
REQUEST NO. 167: What is the normal interval between when a slow or dead meter is
identified and when the customer is rebiled?
REQUEST NO. 168: Please provide the year to year percentage decrease or increase in
the total number of estimated meter readings for 2004-2007.
REQUEST NO. 169: Please provide the year to year percentage decrease or increase in
the total number of misread or incorrect meter readings for 2004-2007.
REQUEST NO. 170: Please provide the reasons for and number of instaces in 2007
where the Company had to rebil customers because a previous bil was based on incorrect
billng determinants, e.g., incorrect identification of foot drive or meter size.
REQUEST NO. 171: Please provide the reasons for and number of instances in 2007
where the Company had to rebil customers due to metering equipment failure, e.g., failure of an
ERT or index or mechanical failure of the meter itself.
REQUEST NO. 172: For each type of automated meter reading (AMR) technology
installed and employed by your company, i.e., Power-Line Carrier or Radio-Based, please
SIXTH PRODUCTION REQUEST
TO A VISTA CORPORATION 4 JUE 20, 2008
describe any problems encountered during or after AMR installation and how the problems were
addressed.
REQUEST NO. 173: What is the expected useful life of the new automated meters? By
meter type, is there any evidence that suggests the meters may not perform for the same length of
time as old-technology meters? If so, please explain.
REQUEST NO. 174: Please provide the number and percentage of installed meters or
metering equipment that failed for the years 2004-2007. Please report separately for gas and
electric meters. Is the failure rate for AMR meters significantly different than that of older-
technology meters?
REQUEST NO. 175: Are all Avista gas and electric meters in Idaho read using one of
the two tyes of AMR technology? If not, please explain.
REQUEST NO. 176: Is a uniform AMR data collection system now in place?
REQUEST NO. 177: Please explain how meter reading data is entered into the biling
system.
-;
Dated at Boise, Idaho, this ~day of June 2008.
~.:b. 11 L'/bQø . dúÁ1AKr tine A. Sasser ~
Deputy Attorney General
Technical Staff: Daniel Klein
i:umisc:prodreq/avue~8.ksdk prod req6
SIXTH PRODUCTION REQUEST
TO A VISTA CORPORATION 5 JUE 20, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF JUE 2008,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-08-01
& AVU-G-08-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220
E-MAIL: david.meyer(ßavistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
POBOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwood(ßavistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
601 W BANNOCK ST (83702)
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(ßgivenspursley.com
DENNIS E. PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY STREET SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(ßexcite.com
BRAD M. PURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE, ID 83702
E-MAIL: bmpurdy(ßhotmail.com
,Jo~SECRETA ~
CERTIFICATE OF SERVICE