20210524CAPAI 1-11 to Avista.pdf

CAPAI’S FIRST PRODUCTION REQUESTS TO AVISTA 1

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
[e-mail]

Attorney for Petitioner
Community Action Partnership
Association of Idaho

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-E-21-01
OF AVISTA CORPORATION DBA AVISTA ) AVU-G-21-01
UTILITIES FOR AUTHORITY TO ) COMMUNITY ACTION
INCREASE ITS RATES AND CHARGES FOR ) PARTNERSHIP ASSOCIATION
ELECTRIC SERVICE AND NATURAL GAS ) OF IDAHO'S FIRST
CUSTOMERS IN THE STATE OF IDAHO ) PRODUCTION REQUESTS TO
) AVISTA.
__________________________________________)

The Community Action Partnership Association of Idaho (CAPAI), by and through its
attorney of record, Brad M. Purdy, and, pursuant to the Idaho Public Utilities Commission Rules
of Procedure requests that AVISTA CORPORATION (Avista) provide the following documents
in the above-captioned case.
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 IDAPA 31.01.01.228.
This Production Request is to be considered as continuing in nature, and AVISTA is
respectfully requested to provide supplementary responses and any additional documents that it
or any person acting on its behalf may later obtain that will augment the information 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.
Please provide a response to the following discovery within twenty-one (21) days:
RECEIVED
2021 May 24, PM 4:12
IDAHO PUBLIC
UTILITIES COMMISSION
CAPAI’S FIRST PRODUCTION REQUESTS TO AVISTA 2

REQUEST NO. 1: Does Avista track the identities and number of its customers who receive
assistance under the Company’s Low Income Weatherization Assistance program (LIWA)
operated by the North Idaho Community Action Partnership (CAP)?
REQUEST NO. 2: If your answer to the preceding request is in the affirmative, what
percentage of Avista’s total residential customers have received LIWA funding over the past ten
(10) years? In responding to this request, please break-out the percentage of such customers who
utilize gas versus electricity as their primary heating source.
REQUEST NO. 3: Of its customers who receive LIWA funding, whether they heat with gas
or electric, what has been the average number of Avista residential customers who have received
such funding over the past ten (10) years?
REQUEST NO. 4: Is there a limitation that Avista imposes on those customers seeking
LIWA funding such that they must consume a minimum of a specific number of kilowatts of
electricity and/or therms of gas annually? If so, what are those limitations and why are they
imposed?
REQUESTS NO. 5: If your response to the preceding discovery request is in the affirmative,
what are those minimum consumption levels for both gas and/or electricity and how many and
what percentage of Avista low-income customers have been denied LIWA assistance in the past
ten years for failure to consume the amount of energy consumption stated above?
REQUEST NO. 6: Has Avista conducted any studies in the past ten (10) years of the effect
that its LIWA program has on low-income customers in terms of reducing their uncollectible
accounts and related collection costs otherwise paid by the Company’s non-low-income
residential ratepayers? If so, please provide the results of such studies.
CAPAI’S FIRST PRODUCTION REQUESTS TO AVISTA 3

REQUEST NO. 7: What are the number of disconnections between residential customers who
receive LIWA assistance and those who do not?
REQUEST NO. 8: How many of Avista’s low-income customers have been disconnected due
to non-payment, or inability to pay, their electric or gas bills in the past ten (10) years and what
percentage do any such customers are residential customers?
REQUEST NO. 9: Has Avista analyzed and concluded the relative effect of providing its
low-income customers with LIWA funding on those same customers’ tendency to timely pay
their bills and reduce uncollectible/collection costs for the Company? If so, please provide the
results of such analysis for the past ten (10 years.
REQUEST NO. 10: Does Avista track and compare the number of customer disconnections
and related costs thereof between those customers who receive LIWA funding and those
residential customers who do not?
REQUEST NO. 11: Does Avista believe that its current LIWA program has the effect of
reducing disconnection, bad debt expense and other costs related to the loss of low-income
customers due to their inability to pay? If so, please explain such a belief.

DATED, this 24th day of May, 2021.

______________________________________
Brad M. Purdy
CAPAI’S FIRST PRODUCTION REQUESTS TO AVISTA 4

CERTIFICATE OF SERVICE

I certify that on the 24th day of May, 2021, I served the foregoing FIRST PRODUCTION
REQUEST of COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO to the
following via electronic mail:

Idaho Public Utilities Commission

Jan Noriyuki Commission Secretary
[e-mail]

John Hammond
[e-mail]

Avista:

David J. Meyer
[e-mail]

Pat [e-mail]
Avista [e-mail]

Idaho Conservation League

Benjamin Otto
[e-mail]

Walmart
Norman Semanko
[e-mail]

Steven Chriss
Walmart
[e-mail]

Vicki M Baldwin
[e-mail]

Idaho Forest Group

Ron Williams
[e-mail]

Larry Crowley
CAPAI’S FIRST PRODUCTION REQUESTS TO AVISTA 5

[e-mail]

Clearwater Paper
Peter J. Richardson
[e-mail]

Don Reading
[e-mail]

____________________________________
Brad M. Purdy