20100624Staff 147-159 to AVU.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
RECE n
i~\1 JUR 24 PM 3: 49
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 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
,//
IN THE MATTER OF THE APPLICATION )
OF A VISTA CORPORATION DBA A VISTA )
UTILITIES FOR THE AUTHORITY TO )
INCREASE ITS RATES AND CHARGES FOR )
ELECTRIC AND NATURAL GAS SERVICE )
IN IDAHO. )
)
)
)
CASE NO. AVU-E-I0-l
AVU-G-I0-l
SEVENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilties Commission, by and through 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 THURSDAY,
JULY 15,2010.
SEVENTH PRODUCTION REQUEST
TO AVISTA 1 JUE 24, 2010
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil 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 preparing 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
IDAPA 31.01.01.228.
In addition to the wrtten copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 147: Please provide a Cost of Service model run of the Company Case
incorporating the appropriate corrections identified in Washington Data Request No. Staff - 056,
revised from the current Washington general rate case.
REQUEST NO. 148: In response to Production Request No. 57, Avista reports that in
Januar of 2009 the service level was 48.70%. What is the reason(s) for the exceptionally low
service level?
REQUEST NO. 149: In response to Production Request No. 67, Avista reports that in
June of2009 it received 6,800 emails in the customer service center. This is far more than other
months in the year. Please provide the reason(s) for the large number of emails in June.
REQUEST NO. 150: In response to Production Request No. 69, A vista indicates it wil
allow landlords to provide sign-up information to Avista on behalf of tenants. Landlords may
provide information about tenants. by several methods, including callng Avista or submitting a
written Application for Service. For 2009, please provide the percentage of applications
received from landlords on behalf of tenants for each method. Does A vista contact the tenant to
verify that the information provided by the landlord is correct? If not, why not?
SEVENTH PRODUCTION REQUEST
TO AVISTA 2 JUNE 24, 2010
REQUEST NO. 151: Once sign-up information is taken from the written Application
for Service forms and entered into the computer system for biling puroses, are those forms
retained by Avista? And if so, for how long are they retained?
REQUEST NO. 152: When a new landlord/owner calls Avista and asks that service at
his rental be transferred back into the landlord/owner's name between tenants (Open Between
Tenants option), is the landlord/owner required to sign an application, contract or some other
type of written agreement?
REQUEST NO. 153: In Idaho, how many landlords have requested the Open Between
Tenants option? How many have requested the Shut Off Between Tenant option? How many
total landlords in Idaho participate in this landlord/tenant program?
REQUEST NO. 154: In response to Production Request No. 69, Avista cited
IDAPA 31.21.01 Rule 307 as the justification for allowing third paries to provide sign-up-for-
service!biling information on behalf of the person(s) who wil ultimately be financially
responsible for the utilty bils at an address. Rule 307 does not apply to applications for service,
so please explain your answer to Production Request No. 69.
REQUEST NO. 155: Please describe the dispute resolution process used by Avista to
resolve customer disputes regarding bil payment responsibilty in situations where someone
other than the customer of record signed up for service.
REQUEST NO. 156: In response to Production Request No. 64, Avista answered the
question by providing the total number ofCSRs by month for 2009. Please also provide for the
same months, the number of FTEs.
REQUEST NO. 157: In his testimony, Company witness Kopczynski refers to a study
of heating assistance programs in Spokane County which was prepared for A vista by the Institute
for Public Policy and Economic Analysis at Eastern Washington University. Mr. Kopczyski
SEVENTH PRODUCTION REQUEST
TO AVISTA 3 JUE 24, 2010
states that the "results may have application to other pars of our service area." Please provide a
detailed explanation of how this study has relevance to Avista's customers in Idaho.
REQUEST NO. 158: On page 19 of his testimony, Company witness Kopczynski
mentions Avista's parnership with KRM in producing television programs. Which
communities in Avista's Idaho service territory receive KRM's broadcast signal? Are these
programs carried by or available to other television stations that serve Idaho communities?
REQUEST NO. 159: Once Avista's system is interconnected to BPA's system at the
Lancaster generating facilty, thereby moving Lancaster to Avista's control area, what reserve
requirement wil A vista have to meet for the Lancaster plant? What is the estimated cost for
A vista to meet this reserve requirement? Wil A vista meet this reserve requirement with its own
facilties.
Dated at Boise, Idaho, this 2 tllJy of June 2010.
Donald L. well, II
Deputy Attorney Gener 1
Technical Staff: Keith Hessing/#147
Marilyn Parker/#148 - 156
Beverly Barker/#157 - 158
Rick Sterling/# 159
i:umisc:prodreq/avueJ\Io.ikskh prod req7.doc
SEVENTH PRODUCTION REQUEST
TO AVISTA 4 JUE 24, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF JUE 2010,
SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST I OF THE
COMMISSION STAFF TO AVISTA, IN CASE NOS. AVU-E-1O-0~_AVU-G-1O-01,
BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE PR¡PAID, TO THEFOLLOWING: I
i
KELLYONORWOOD I
VP STATE & FED REG
A VISTA CORPORA TIOi
PO BOX 3727
SPOKANE WA 99220-3717
E-MAIL: kelly.norwood~avistacorp.com
HOWARD RAY I
CLEARWATER PAPER fORP
803 MILL ROAD
PO BOX 1126 !
LEWISTON ID 83501-11r6
E-MAL: howard.raYiCirarateipper.com
LARRY CROWLEY I
ENERGY STRATEGIES ÌNSTITUTE
5549 S CLIFFS EDGE AVE
BOISE ID 83716 I
E-MAIL: crowleyla(ßaol.pom
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: david.meyer(ßavistacorp.com
PETER J RICHARDSON
GREG M ADAMS
RICHARDSON & O'LEARY
515 N 27TH ST
BOISE ID 83702
E-MAIL: peter(ßrichardsonandolear.com
greg(ßrichardsonandoleary.com
DEAN J MILLER
MCDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(ßmcdevitt-miler.com
ROWENA PINEDA
ID COMMUNITY ACTION
NETWORK
3450 HILL ROAD
BOISE ID 83703
E-MAIL: Rowena(ßidahocan.org
BRADMPURDY
ATTORNEY AT LAW
2019N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(ßhotmail.com
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmiler(ßsnakeriveralliance.org
LEEANNHALL
3518 S EDMUNDS ST
SEATTLE WA 98118
BENJAMIN J OTTO
ID CONSERVATION LEkGUE
POBOX 844 I
BOISE ID 83701 I
E-MAIL: botto idahoco' servation.or
ROB PLUID PRESIDEN
NORTH IDAHO ENERG LOGS
PO BOX 571 .
MOYIE SPRIGS ID 83845
E-MAIL: robpluid(ßgmaà.com
I
CLARK FAIRCHILD
VICE PRESIDENT
NORTH IDAHO ENERGY LOGS
PO BOX 571
MOYIE SPRINGS ID 83845
E-MAIL: energylogs(ßgmail.com
TOM OXFORD
SECRETARY TREASURER
NORTH IDAHO ENERGY LOGS
E-MAIL: oxford(ßmeadowcrk.com
(ELECTRONIC SERVICE ONLY)
&~.ì(~
SECRETARY