20110822Staff to Avista 118-138.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEI D
ioi I AUG 22 P~1 2: 04
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 AVISTA CORPORATION DBA AVISTA )
UTILITIES FOR THE AUTHORITY TO )
INCREASE ITS RATES AND CHARGES FOR )
ELECTRIC AND NATURAL GAS SERVICE )
IN IDAHO. )
)
)
)
CASE NO. AVU-E-11-l1
AVU-G-11-1
FIFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that A vista Corporation (Company;
Avista) provide the following documents and information on or before MONDAY,
SEPTEMBER 12,2011.
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 wil augment the documents produced.
Please provide answers to each question, including 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
FIFTH PRODUCTION REQUEST
TO AVISTA 1 AUGUST 22,2011
holder and if different the witness who can sponsor the answer at hearng if need be. Reference
IDAPA 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. 118: For calendar year 2010, please provide the monthly and anual
total number of residential accounts.
REQUEST NO. 119: For calendar year 2010, please provide the monthly and annual
total number of residential accounts disconnected from service for non-payment.
REQUEST NO. 120: For calendar year 2010, please provide: (a) the monthly and
anual total number of residential accounts with payment arangements; and (b) the monthly and
anual total number of payment arangements made on residential accounts.
REQUEST NO. 121: For those accounts identified in your response to Request No. 120
(previous question), please provide: (a) the total number and percentage of accounts that
defaulted on payment arangements; and (b) the total number and percentage of payment
arrangement agreements that were not kept.
REQUEST NO. 122: For calendar year 2010, please provide the anual total number of
residential accounts that had payment arrangements: a) less than 6 months, and b) 6-12 months.
How many and what percentage of those accounts defaulted on payment arangements anually?
Of those accounts that defaulted, how many were subsequently disconnected for non-payment
annually?
REQUEST NO. 123: For calendar year 2010, did the Company terminate or modify any
payment plans or payment arangement options? If yes, please explain.
FIFTH PRODUCTION REQUEST
TO AVISTA 2 AUGUST 22, 2011
REQUEST NO. 124: For calendar year 2010, please provide (a) the monthly and annual
total number of accounts with deposits; (b) the average anual percentage of accounts with
deposits; and (c) the deposit dollar amount on accounts.
REQUEST NO. 125: By month, for the past winter heating season (2010/2011), how
many Idaho accounts were signed up for Moratorium protection from disconnection?
REQUEST NO. 126: For those accounts identified in your response to Request No. 125
(previous question) by month, how many and what percentage of those accounts were placed on
the Winter Payment Plan?
REQUEST NO. 127: For those accounts identified in your response to Request No. 126
(previous question) by month, how many and what percentage of those accounts defaulted on the
Winter Payment Plan?
REQUEST NO. 128: Please provide the number of Idaho accounts that received
LIHEAP assistance and were signed up for Moratorium protection from disconnection by month,
for each of the past three winter heating seasons (2008/2009, 2009/2010, 2010/2011).
REQUEST NO. 129: For those accounts identified in your response to Request No. 128
(previous question), please provide the number and percentage of those accounts that were
placed on the Winter Payment Plan by month.
REQUEST NO. 130: For those accounts identified in your response to Request No. 129
(previous question), please provide the number and percentage of those accounts that defaulted
on the Winter Payment Plan by month.
REQUEST NO. 131: Please identify the Company's types of advertising (radio, TV,
bil insert, social media, welcome kit, etc.) in Idaho to inform and educate customers about:
1) energy assistance and bil payment options, 2) Project Share, 3) energy conservation,
FIFTH PRODUCTION REQUEST
TO AVISTA 3 AUGUST 22, 2011
4) Senior Energy Outreach, and 5) Winter Moratorium and the Winter Payment Plan. In
addition, please provide copies of any written brochures or documents sent or otherwise provided
to Idaho customers for each defined category listed in this question.
REQUEST NO. 132: For calendar year 2010, please provide the following: (a) the total
number of Idaho homes weatherized using A vista fuds, and (b) the total dollar amount paid by
A vista to each of the Community Action Agency for weatherization and administrative costs.
REQUEST NO. 133: For Fiscal Year 2010 and 2011, please provide the total dollar
amount contributed to Project Share for Idaho by: a) Avista shareholders, b) Avista customers,
and c) other sources. In addition, please provide the total number of grants provided to Idaho
customers and the total dollar amount distributed to Idaho customers.
REQUEST NO. 134: For Fiscal Year 2010 and YTD 2011, please explain the
Company's efforts to promote Project Share.
REQUEST NO. 135: For calendar 2010 and YTD 2011, please describe the Company's
oversight activities with respect to the Community Action Agency's (CAP) Low Income Energy
Conservation Education Program. If none, please explain.
REQUEST NO. 136: For calendar 2010, please provide an itemization ofthe
expenditures associated with the Low Income Energy Conservation program. Please identify
whether these costs are directly incured by the Company or reimbursement of costs incured by
CAP.
REQUEST NO. 137: For calendar year 2010 and YTD 2011, please provide the total
number of A vista customers who have received low income energy conservation education.
FIFTH PRODUCTION REQUEST
TO AVISTA 4 AUGUST 22,2011
REQUEST NO. 138: For calendar year 2010 and YTD 2011, please provide, the
monthly and anual total number of residential Idaho customers assisted by the CARES
program.
Dated at Boise, Idaho, this 'U ~ay of August 2011.
£t:.,,a, £.4"A. tine A. Sasser
Deputy Attorney General
Technical Staff: Curtis Thaden/118-138
i:umisc:prodreq/avue~i I.ks prod req 5
FIFTH PRODUCTION REQUEST
TO AVISTA 5 AUGUST 22, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF AUGUST 2011,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO A VISTA, IN CASE NOS. AVU-E-II-0l AVU-G-II-0l, BY
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: david.meyer~avistacorp.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy~hotmail.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading~mindspring.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83702
E-MAIL: botto~idahoconservation.org
LARRY CROWLEY
ENERGY STRATEGIES INSTITUTE INC
5549 S CLIFFS EDGE AVE
BOISE ID 83716
E-MAIL: crowleyla~aoi.com
KELLY 0 NORWOOD
VP STATE & FED REG
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: kelly.norwood~avistacorp.com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter~richardsonandolear.com
greg~richardsonandoleary.com
E-MAIL ONLY:
MARV LEWALLEN
CLEARWATER PAPER CORP
E-MAIL:
marv.l ewallen(aclearwaterpapercorp.com
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK ST
PO BOX 2564 (83701)
BOISE ID 83702
E-MAIL: joe~mcdevitt-miler.com
\ \~~
CERTIFICATE OF SERVICE