990205.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO  83720-0074
[phone]
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO  83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF THE WASHINGTON WATER POWER COMPANY (NOW AVISTA CORPORATION DBA AVISTA UTILITIES — WASHINGTON WATER POWER DIVISION) FOR AN ORDER APPROVING INCREASED RATES AND CHARGES FOR ELECTRIC SERVICE IN THE STATE OF IDAHO.
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CASE NO. WWP-E-98-11
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA UTILITIES — WASHINGTON WATER POWER DIVISION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests that Avista Corporation dba Avista Utilities - Washington Water Power Division (Avista; Company) provide the following documents and information on or before FRIDAY, FEBRUARY 26, 1999.
This Production Request is to be considered as continuing, and Avista 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 name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
Request No. 1:What have Avista’s actual experienced monthly reserve margins been for capacity and energy for the years 1992 through 1998.  For the purpose of this request only Company owned resources and firm supply contracts should be measured against the Company’s firm loads and obligations.  Please provide workpapers showing the individual monthly calculations.
Request No. 2:Using the same criteria established in Request No. 1, please provide minimum planning reserve margins for capacity and energy.
Request No. 3:Please provide distribution rate base per customer for Sandpoint service area customers included in this case.  Also provide distribution rate base per customer
for the Company’s other customers included in this case.
Request No. 4:Please provide a copy of input to and output from the Northwest Power Pool (NWPP) hydro regulation model run discussed on page 8 of Company witness Norwood’s direct testimony.  Also provide the name and telephone number of a person at the NWPP who can answer questions concerning the model and the specific run used by Avista.
Request No. 5:Please provide a copy of input to and output from the NWPP Headwater Benefits Study run discussed on page 10 of Company witness Norwood’s direct testimony.  Also provide the name and telephone number of a person at the NWPP who can answer questions concerning the model and the specific run used by Avista.
Request No. 6:What is Avista’s position on possible elimination of all speculative trading of energy from the regulated Company.  Please provide an explanation.
Request No. 7:It is my understanding that, in it’s filing, Avista included known and measurable changes in power supply costs through June of the year 2000.  (a)  What would the power supply adjustments be if known and measurable changes were made through December of 1999?
(b)  What would the power supply adjustments be if known and measurable changes were made through June of 1999?
Request No. 8:Please provide Avista’s tree trimming schedule for the past five years.  At a minimum, the information provided should identify locations, type of line, and time frame for each job completed.
Request No. 9:Please describe Avista’s process to notify affected customers of a planned outage.  Describe Avista’s process to provide customers information during  “unplanned” outages.
Request No. 10:Has Avista historically provided notice to its customers of rate changes, including adjustments to rates due to a surcharge or rebate?  Please indicate what type of notice is provided to customers for changes in rates.
Request No. 11:Please describe how partial payments are applied to customers’ bills.  Although regulated and unregulated charges are separately stated on bills, are unpaid balances kept separate?  Or do unpaid balances blend into a single unpaid balance?  What happens when a billing dispute arises?
Request No. 12:Does Avista allow a customer to direct a partial payment toward a specific regulated service?  That is, can a customer direct a partial payment toward electric service to prevent interruption of it although the partial payment is not sufficient to also protect gas service?
Request No. 13:Describe Avista’s landlord/tenant policies and practices.  Does Avista have a landlord agreement in place?  Does power revert to landlord’s name when a tenant requests a disconnect?  Are landlords allowed to put power in a tenant’s name at the time a new person becomes a tenant?
Request No. 14:Avista is asking for a revenue adder due to its efficiency and good customer service.  Please describe special or innovative programs which the Company considers above and beyond that expected of all regulated utilities?
Request No. 15:Please indicate all regulatory and/or judicial fines, judgements or settlements levied, assessed or entered against Avista (or Washington Water Power Company) since the Company’s last general rate case.  Please describe the circumstances and nature of same, including all case captions and docket numbers.
Request No. 16:Provide the number and type of  consumer complaints the utility received during the years 1996, 1997, and 1998.  Are there specific areas of concern revealed by root cause analysis that the Company plans to address in 1999 or some later date?
Request No. 17:What information does Avista provide low income home energy assistance consumers and how does it provide the information?  Describe any programs to assist special needs customers, including those of  low income, trying to meet their utility financial obligations.  Does Avista conduct home energy audits, or have some other program to assist customers determine the possible cause of high energy use?  Describe Avista’s CARES program, providing the average number of individuals who participated in this service the last three years.
Request No. 18:Certain Avista local offices recently closed or will be closed to the public.  Please describe the changes being made and how Idaho customers will be assisted in making the transition.  Do all calls to the Company’s published contact numbers go to Call Center in Spokane?  Is the Company’s 800 number listed in each community’s telephone book?
Request No. 19:Are there different metering requirements for mobile home parks and RV parks?  If Avista discovers through a complaint received from an RV park tenant that the RV park owner has rented a space to the complainant for longer than 30 days and charged rates higher than Avista’s residential rates, what steps would Avista take to resolve the problem?
Request No. 20:  If the Company were to sell its ownership share of Centralia effective June 30, 1999, what effect would this have on the Company’s case?  Please provide the details of including this adjustment in the Company’s case.
Request No. 21:Provide a summary list of all line extensions made in Idaho during 1997 and 1998 to serve all new customers, except individual residential customers, in which no advance or customer contribution was received by the Company.  Include the following information in the summary:
a.Date of start of construction.
b.Description of location (e.g., T51N, R05W, S18 & S19 along W Hayden Ave).
c.Description of the number and type of customers served (e.g., 25 lot residential subdivision).
d.Brief general description of the work involved (e.g., 1500 ft. of three phase 34.5 kV line).
e.Total cost of the line extension.
f.Amount of any allowances made to customers.
g.Total contribution/advance received from customers.
Do not include replacement or maintenance of existing facilities in the summary.
Request No. 22:For Avista’s Idaho jurisdiction, what is the total cost of line extensions (other than replacement or upgrades) in each of the years 1994-1998?  What is the total amount of line extension related costs added to rate base in each of these years?  What is the corresponding total amount of customer advances or customer contributions for line extensions during each of these years?  What is the total amount of vested interest refunds made to customers in each of these years?
Request No. 23:Does Avista anticipate requesting any changes to its line extension rules in the foreseeable future?
Request No. 24:What is the status of the Clark Fork Settlement Agreement?  Has it been signed by all parties?  Does the Company still plan to begin settlement provision implementation by March of 1999?
Request No. 25:Please provide a year by year break down of the $13.443 million booked to FERC account 302 for relicensing.
Request No. 26:Please show how annual license implementation costs were calculated.  Please include all assumptions made with respect to the timing and nature of expenditures over the life of the license.
Request No. 27:On page 29 of his direct testimony, Company witness Faulkner states that $2.042 million of the annual $4.8 million has been determined to be capital expenditures and $2.75 million has been determined to be operation and maintenance.  Please show how this division was made and how these numbers were derived.
Request No. 28:By general account, please itemize all Clark Fork Hydro Relicensing expenses included in the test year.
Request No. 29:Centralia is dispatched in the power supply model at $13.1/MWh but the actual fuel charge used to determine annual expense is $18.24/MWh.  The difference between these two charges does not appear to be due to fixed coal costs because the costs vary with generation.  Please explain this difference.
Request No. 30:Why are Colstrip and Kettle Falls dispatched at one rate ($8.6/MWh and $12/MWh, respectively) in the power supply model and charged a different rate ($6.8/MWh and $$9.86/MWh, respectively) to determine annual fuel expense?
DATED at Boise, Idaho, this              day of February 1999.
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Scott Woodbury
Deputy Attorney General
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