20160204Staff 1-20 to AVU.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
RECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA CORPORATTON )
DBA AVISTA UTILITIES' APPLICATION FOR ) CASE NO. AVU-E-16-01
AN ACCOUNTING ORDER RELATED TO ) AVU-G-16-01
COSTS INCURRED TO OFFER CUSTOMERS A )
FEE.FREE PAYMENT PROGRAM. ) FIRST PRODUCTION
) REQUEST OF THE) coMMrssroN STAFF To
) AVISTA CORPORATTON
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, and no later than
THURSDAY, FEBRUARY 25, 2016.
This Production Request is continuing, and the Company 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.
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
3t.0t.01.228.
FIRST PRODUCTION REQUEST
TO AVISTA FEBRUARY 4,2016
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. 1: Page 3 of the Company's Application states that in 20l4,the
Company's residential customers made a total of 249,852 payments by credit or debit card and
27,335 one-time unauthenticated payments. Please state whether these numbers reflect payments
from customers Company-wide, or just from the Company's Idaho residential customers.
REQUEST NO.2: Through discussions with other companies offering fee-free payments,
has the Company discovered or does it anticipate that the number of electronic (paperless) bills will
increase? Please explain.
REQUEST NO. 3: How does the Company propose to allocate the processing fees to its
separate j urisdictions?
REQUEST NO. 4: Has the Company filed for fee-free payment approval in Oregon and
Washington? If so, please provide the docket numbers for those cases.
REQUEST NO. 5: Assuming the Company's Application is approved, when does the
Company plan to have its billing systems updated to support the fee-free payments, and when does
the Company expect to have the program in place?
REQUEST NO. 6: Please provide the annual number of calls, inquiries, complaints, and
suggestions the Company received regarding convenience fees in the last three years.
REQUEST NO. 7: Page 10 of the Company's application states that, "The more
convenient the Company can make it for customers to pay bills, the more it can benefit all
customers." Please quantify the benefits all customers will receive from eliminating convenience
fees. Please describe why the Company proposes to recover costs for this request from all
ratepayers when benefits are limited to residential customers that pay with credit or debit cards.
FIRST PRODUCTION REQUEST
TO AVISTA FEBRUARY 4,2016
REQUEST NO. 8: Please provide the number of commercial and industrial customers that
paid with debit or credit cards in the last three years
REQUEST NO. 9: Please provide the percentage of customers within the commercial and
industrial classes that paid with debit or credit cards in the last three years.
REQUEST NO. 10: Please explain whether the Company has had discussions with its
current third-party vendor to reduce or eliminate the $3.50 credit or debit convenience fee. If
discussions have taken place, please provide a summary of the discussions, and the implications of
the convenience fee cost reduction or elimination. If the discussions have not taken place, please
explain why not.
REQUEST NO. 1l: Please provide a summary of discussions that have taken place with
major card providers offering a Utility Pay Program. If discussion have taken place, include a
summary of processing transaction costs by provider. If discussions have not taken place, please
explain why not.
REQUEST NO. 12: Please provide a detailed explanation of criteria used to select a digital
payment processing partner. If applicable, please include copies of completed RFPs and RFQs.
REQUEST NO. 13: Page 3 of the Company's application references discussions with other
utilities and processing vendors. Please provide a summary of these discussions. Additionally,
describe how per transaction costs of $ I .50 contained in Table No. I of the application were
determined.
REQUEST NO. 14: How many credit and debit card payments over $3,000 were made by
residential customers for Calendar Year 2014 and2015? What was the average charge per
transaction and the total cost for all transactions?
REQUEST NO. 15: Would the current transaction limit remain the same for credit/debit
payments? If not, what limit would be established?
FIRST PRODUCTION REQUEST
TO AVISTA FEBRUARY 4,2076
REQUEST NO. 16: How would eliminating fees for payment provide additional options
for residential customers to pay their bills?
REQUEST NO. 17: Does the Company anticipate that by offering a fee-free payment
program, the amount of residential customers who do not pay on time will decrease? If yes, please
explain why.
REQUEST NO. 18: If Idaho approves the proposed fee-free payment program and Oregon
and Washington do not, can the Company implement the program in Idaho only? If the Company
cannot implement an Idaho-only program, please explain why.
REQUEST NO. 19: Under the proposed program, will residential customers be able to set
up automatic bill payment using a credit or debit card? Please explain.
REQUEST NO.20: Under the proposed program, will residential customers still be
charged for paying by phone or online using a checking or saving account? Would there continue
to be a distinction between customers depending on whether they have a "My Avista Account"?
Please explain.
DATED at Boise, Idaho, this ,1 f ! day of February 2016.
L/ '/72<
Karl T. Klein
Deputy Attorney General
Technical Staff: Donn English/l-5
Kevin Keyll6-13
Curtis Thadenll4-2}
i:umisc:prodreq/avue I 6. I _avug I 6. I kkdekskct prod req I
FIRST PRODUCTION REQUEST
TO AVISTA FEBRUARY 4,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY oF FEBRUARY 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSTON STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-16-01/
AVU.G-16-OI, BY E.MAILING ANDMAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
SHAWN BONFIELD
SR REGULATORY POLICY ANALYST
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE