20040617Responses of Avista to CAPAI.pdf

Avista Corp.
1411 EastMission PO Box 3727
Spokane, Washington 99220-3727
Telephone [phone]
Toll Free 8O(H27-9170
RECEIVED
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June 16 2004
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Brad Purdy
Attorney at Law
2019 N. 17th 8t.
Boise, ill 83702
Re:First Production Request of CAP AI.
in Case Nos. A VU-04-01 and A VU-04-
Mr. Purdy,
I have attached one copy of Avista s response to CAPAI's Data Request No(s). 9 , 10, 11
, 14, 17 , and 21.
If you have any questions, please call me at [phone] or Don Falkner at (509) 495-
4326.
\:erelY,
Mike FInk
Rate Analyst
A vista Utilities
Enclosures
Cc:M. Karp
S. Woodbury
D. Peseau
A. Yankel
Cox
(A W.I.S.
(IPUC)
(Utility Resources, Inc.
(Yankel & Assoc, Inc.
(Coeur)
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-04-01 / A VU-04-
CAP AI
Data Request
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
06/15/2004
Don Kopczynski
Tara Knox
Rates
[phone]
REQUEST:
Please state the total number of A VISTA customers receiving service within the state of Idaho
and how many of those are residential customers.
RESPONSE:
During the 2002 test year, there were an average of91 076 residential electric customers out of
106 515 total Idaho average electric customers, and an average of 51 753 residential natural gas
customers out of 58 761 total Idaho average natural gas customers.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUES TER:
TYPE:
REQUEST NO.
Idaho
A VU - E-04-0 1 1 A VU -04-0 1
CAP AI
Data Request
DATE PREPARED:
WITNES S
RESPOND ER:
DEPARTMENT:
TELEPHONE:
6/15/2004
Don Kopczynski
Mary Broemeling
Utility Finance
[phone]
REQUEST:
Please provide a break-out of the Company s Idaho residential customers based on whether they
rely upon electric space heat, or natural gas heating. Please further break-out the number of low
income customers by whether they rely upon electric space heating or natural gas heating.
RESPONSE:
The Company does not have a study which breaks out our Idaho residential customers based on
whether they rely upon electric space heat, or natural gas heating. Additionally, it has been
A vista s long-standing practice to not collect data regarding our individual Customer s personal
income levels, so we cannot distinguish between low-income and non-low-income customers.
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
REQUEST:
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
Idaho
A VU-04-01 / A VU-04-
CAP AI
Data Request
DATE PREPARED:
WITNESS:
RESPOND ER:
D EP AR TMENT :
TELEPHONE:
06/15/2004
Malyn Malquist
Tara Knox
Rates
[phone]
Please provide the amount of gross operating revenues (Idaho Jurisdiction) for the most recent
year that information is available for A VISTA.
RESPONSE:
Idaho Gross Operating Revenues for Twelve Months Ended December 2003 were as follows:
Electric Operating Revenues
Gas Operating Revenues
Total Idaho Operating Revenues
$177 232 917
$52.328.420
$229 561 337
Source: FERC Form 1 and FERC Form 2 State Supplements, Page 300.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU - E-04-0 1 / A VU -O4-0 1
CAP AI
Data Request
DATE PREPARED:
WITNESS:
RESPOND ER:
D EP AR TMENT:
TELEPHONE:
6/15/2004
Don Kopczynski
Mary Broemeling
Utility Finance
[phone]
REQUEST:
Please provide a single copy of any study within the possession or control of the Company,
performed using Company customers, that distinguishes between residential customers generally
and low-income residential customers in particular. Factors that might distinguish the two
classes might include, but not be limited to: (a) usage levels and patterns; (b) history of payment
troubles; (c) consumption of energy efficiency services; (d) credit and collection history; (
consumption of Company resources such as staff time; and the like.
RESPONSE:
The Company does not have a study which would allow us to distinguish between residential
non-low income customers and residential low-income customers.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU - E-04-0 1 / A VU -O4-0 1
CAP AI
Data Request
DATE PREPARED:
WITNESS:
RESPOND ER:
D EP AR TMENT:
TELEPHONE:
6/15/2004
Don Kopczynski
Mary Broemeling
Utility Finance
[phone]
REQUEST:
Please provide a copy of any study within the possession or control of the Company that
considers or calculates the average yearly number of kWh for a typical low-income residential
customer. Separately provide natural gas and electric studies if available.
RESPONSE:
The Company does not have a study which considers or calculates the average yearly number of
kWh for a typical low-income residential customer.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
CAP AI
Data Request
DATE PREPARED:
WITNES S
RESPONDER:
DEP ARTMENT:
TELEPHONE:
6/15/2004
Don Kopczynski
DJ Spooner
Customer Service
[phone]
REQUEST:
Regarding the preceding Request, please state the percentage of annual arrearages, disconnects
and bad debts are attributable to low-income customers.
RESPONSE:
It has been A vista s long-standing practice to not collect data regarding our individual Customer
personal income levels. Accordingly, A vista does not track low-income customers and can
therefore not identify the annual arrearages, disconnects and bad debts that are attributable to
low-income customers.
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU - E-O4-0 1 1 A VU -O4-0 1
CAP AI
Data Request
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
6/15/2004
Don Kopczynski
DJ Spooner
Customer Service
[phone]
DATE PREPARED:
WITNESS:
RESPOND ER:
DEPARTMENT:
TELEPHONE:
REQUEST:
Please state the total collection costs for the test year, utilized by the Company in its filing in this
case, associated with handling low income customer accounts, including administrative and
overhead expenses, associated with service termination activity including pre-termination notice
by mail, pre-termination personal contact, actual termination of service, post termination and
restoration costs, negotiating payment arrangement requests, budget counseling, handling formal
and informal complaints, securing and maintaining deposits, tracking delinquent accounts
collection agency expenses, litigation expenses, dunning expenses, and winter survey expenses.
RESPONSE:
It has been A vista s long-standing practice to not collect data regarding our individual Customer
personal income levels. Accordingly, Avista does not track low-income customers and can
therefore not identify the total collection costs for the test year associated with handling low-
income customer accounts
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
REQUEST:
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
Idaho
A VU - E-O4-0 1 / A VU -O4-0 1
CAP AI
Data Request
DATE PREPARED:
WITNESS:
RESPOND ER:
DEP ARTMENT:
TELEPHONE:
6/15/2004
Don Kopczynski
DJ Spooner
Customer Service
[phone]
Of the total collection costs identified in response to Request No. 20 , state the total costs
associated with low-income customers.
RESPONSE:
Please see Avista s response to CAP AI's request number 20.