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Home My WebLink About20100629CAPAI 1-22 to AVU.pdf.. Brad M. Purdy Attorney at Law BarNo. 3472 2019 N. 17th St. Boise,ID. 83702 (208) 384-1299 (Land) (208) 384-8511 (Fax) bmpurd y0lhotmail. com Attorney for Petitioner Community Action Parnership Association of Idaho RECEIVED iam JUN 29 PH 3: 12 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF AVISTA CORPORATION DBA AVISTA UTILITIES FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC AND NATURAL GAS SERVICE IN IDAHO. ) ) CASE NO. AVU-E-lO-Ol ) CASE NO. AVU-G-IO-Ol ) ) COMMUNITY ACTION ) PARTNERSHIP ASSOCIA- ) TION'S FIRST PRODUCTION ) REQUESTS TO A VISTA ) The Community Action Partnership Association of Idaho (CAP AI), by and through its attorney of record, Brad M. Purdy, requests that AVISTA provide the following documents and information pursuant to the Commission's scheduling order previously issued in this case. Pursuant to IDAPA 31.01.01.228, please include the name(s) of the person(s) who wil be able to answer questions about or sponsor the Company's responses to these Requests at hearing. As a courtesy, A VISTA is requested to further provide the job title of said person(s). This Production Request is to be considered as continuing, and A VISTA is hereby 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. CAP AI FIRST PRODUCTION REQUEST TO A VISTA 1 REQUEST NO.1: Please provide the Company's two most recent FERC Form 1 reports. If the report can be readily obtained (and printed) through the internet, or some other equally accessible means, then please simply provide instructions on how to access it. REQUEST NO.2: Please provide the Company's two latest anual reports to shareholders. As with the FERC Form l, directions to a readily obtainable, alternative source wil suffice. REQUEST NO.3: Please provide the Company's two latest anual reports to the Securities and Exchange Commission or directions on how to obtain said reports through equally Please provide the following data, for AVISTA's Residential rate~..='-c:zwco accessible means. REQUEST NO.4: class for each of the past five (5) years: 1.Average number of customers; 2.Average monthly kilowatt hour sales per customer; 3.Average monthly customer bil; ::-m(jm -0:: N.'.f Ql0" ,,,,,,..,0,,"""i 4. Average monthly bil for LIHEAP-recipient customers (without factoring in the LIHEAP benefit received). REQUEST NO.5: Has the Company conducted, contracted for, or relied upon any price elasticity studies or models in analyzing the consumption levels of its two-tiered block rate structure for residential customers? By this question, CAP AI seeks to know whether A VISTA has attempted to calculate a minimum level of consumption for residential customers, regardless of the price. REQUEST NO.6: If your answer to the preceding Request is in the affirmative, please provide a copy of said study(ies) or model(s). CAP AI FIRST PRODUCTION REQUEST TO A VISTA 2 REQUEST NO.7: On pages 15-16 of his direct testimony, AVISTA witness Patrick Ehrbar testifies, regarding monthly residential consumption levels, that "based on regression results from the Company's weather normalization model, the average residential base load usage is 651 kwh's." Please explain how Mr. Ehrbar derived this purported average usage from the Company's weather normalization modeL. REQUEST NO.8: On page 15 of his direct testimony, Mr. Ehrbar, relying upon a document produced by the U.S. Department of Housing and Urban Development, quantifies the average residential monthly usage at an average of 571 Kwh's. Does this quantification include electricity consumed for the purpose of electric space heating? REQUEST NO.9: In any of his calculations of average monthly residential consumption, and the assumptions he made in calculating said consumption, did Mr. Ehrbar take into account the degree of weather efficiency of low-income housing and the potential impact that variable might have on monthly consumption? If so, please provide elaboration of Mr. Ehrbar's analysis in this regard. REQUEST NO. 10: On page 13 of his direct testimony, Mr. Ehrbar makes a monthly comparison of electricity consumed annually by non-LIHEAP residential customers, to a sample group of LIHEAP-recipient, residential customers. Based upon this sampling, what is the average total monthly consumption for all residential customers compared to the average monthly consumption of the sample group of LIHEAP-recipient, residential customers? REQUEST NO. 11: On page 13 of his direct testimony, Mr. Ehrbar, in discussing the possibility of modifying A VISTA's existing two-tier residential rate block, states: "( fJurther rate inversion could result in additional fixed costs recovered through an even higher tail block 3 CAPAI FIRST PRODUCTION REQUEST TO A VISTA rate.. .." Please explain what "additional fixed costs" Mr. Ehrbar is referring to and how further rate inversion would cause recovery of said costs to increase. REQUEST NO. 12: Does A VISTA track and maintain any data specific to residential class customers who are deemed "low-income" by the Company using any criteria including, but not limited to, the criteria used in determining LIHEAP eligibility? REQUEST NO. 13: If the answer to the preceding Request is in the affrmative, please state the criteria used to determine whether a customer is "low-income," identify the nature of the data tracked and produce said data. REQUEST NO. 14: For each of the most recent three years for which data is available, please provide the total number of residential accounts in arrears for the following time periods: 1. Thirty (30) to sixty (60) days; 2. Sixty (60) to ninety (90) days; 3. Ninety (90) and over days. REQUEST NO. 15: Regarding the Company's residential rate class, please provide, for each ofthe past five calendar years, (1) AVISTA's total allowance for bad debt and (2) total bad debts written-offs. REQUEST NO. 16: Does AVISTA track its administrative costs (e.g., personnel costs etc.) attributable to monitoring and recovering delinquent accounts? REQUEST NO. 17: If your answer to the preceding Request is in the affirmative, please quantify said costs and explain how they are calculated. REQUEST NO. 18: What is the Company's policy regarding how many days a residential account becomes past due before it is written-off as bad, or uncollectible, debt? 4 CAP AI FIRST PRODUCTION REQUEST TO A VISTA REQUEST NO. 19: For the test year period, please state the total revenue collected from the residential class and the average monthly dollar amount of revenue collected from each residential customer. REQUEST NO. 20: For the most recent three (3) years for which data is available, please provide the following data for all residential accounts receiving LIHEAP assistance: 1) The total number of customers receiving LIHEAP assistance; 2) The total dollar amount per customer of LIHEAP assistance; 3) The total number of customer accounts in arrears. REQUEST NO. 21: For all residential customers receiving LIHEAP assistance, please provide the total number of said accounts for the most recent three (3) years for which data is available and the total dollar amount of said accounts, written off as uncollectible. REQUEST NO. 22: For the most recent three (3) years for which data is available, please provide the number of residential customers on level pay plans for each month, the number of said level pay plan accounts in arrears, and the total dollar amount of said accounts. DATED, this 29th day of June, 2010, ,L~~ Brad M. Purdy C .~. 5 CAPAI FIRST PRODUCTION REQUEST TO AVISTA CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on the 29th day of June, 2010, I served a copy of the foregoing document on the following by email and U.S. mail, first class postage. Kelly Norwood A vista Corporation PO Box 3727 Spokane, WA 99220-3727 David Meyer A vista Corporation PO Box 3727 Spokane, WA 99229-3727 Donald L. Howell, II Kristine A. Sasser Idaho Public Utilities Commission 472 W. Washington St. Boise, ID 83702 Peter J. Richardson Greg M. Adams 515 N. 2ih St. PO Box 7218 Boise, ID 83702 Howard Ray PO Box 1126 Lewiston, ID 83501 Dean J. Miler 420 W. Banock St. Boise, ID 83702 Larry A. Crowley 5549 S. Cliffsedge Ave. Boise, ID 83716 Rowena Pineda 3450 Hil Rd. Boise, ID 83703-4715 LeeAnn Hall 3518 S. Edmunds St. Seattle, W A 98118 6 CAP AI FIRST PRODUCTION REQUEST TO A VISTA ~ Benjamin J. Otto 710 N. Sixth St. Boise, ID 83702 Ken Miler PO Box 1731 Boise, ID 83701 Rob Pluid PO Box 571 Moyie Springs, ID 83845 Clark Fairchild PO Box 571 Moyie Springs, ID 83845 Hand-Delivery Jean Jewell Commission Secretary Idaho Public Utilities Commission DATED, this 29th day of June, 2010 ß¡:::4r\~Brad M. Purdy '~ 7 CAP AI FIRST PRODUCTION REQUEST TO A VISTA