20210524CAPAI 1-11 to Avista.pdf

Brad M. Purdy
Attomey atLaw
Bar No. 3472
2019 N. 17tr St.
Boise,lD. 83702
(208) 384-129e (Lnd)
[phone] (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AI-J"IHORIry TO
INCREASE ITS RATES AND CHARGES FOR
ELECTRIC SERVICE AND NATURAL GAS
CUSTOMERS IN THE STATE OF IDAHO
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU-E.21.0I
AVU-G-21-01
COMMUNITY ACTION
PARTNERSHIP
OF IDAHO'S FIRST
PRODUCTION REQUES
AVISTA.
The Community Action Partnership Association of Idaho (CAPAD, by and
attorney of record, Brad M. Purdy, and, pursuant to the Idaho Public Utilities
of Procedure requests that AVISTA CORPORATION (Avista) provide the following
in the above-captioned case.
The Company is rerninded that responses pursuant to Commission Rules of
must include the name and phone number of the person preparing the document, and the
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 AVIST
respectfully requested to provide supplementary responses and any additional
or any person acting on its behalf may later obtain that will augment the information
For each item, please indicate the name of the person(s) preparing the answers, along
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)
CAPAI'S FIRST PRODUCTION REQUESTS TO AVISTA
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REQUEST NO. 1: Does Avista track the identities and number of its customers who
assistance under the Company's Low Income Weatherization Assistance program
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
(10) years? In responding to this request, please break-out the percentage ofsuch
utilize gas versus electricity as their primary heating source.
REQUEST NO. 3: Of its customers who receive LIWA funding, whether they heat
or electric, what has been the average number of Avista residential customers who have
such funding over the past ten (10) years?
REQUEST NO. 4: Is there a limitation that Avista imposes on those customers
LIWA funding such that they must consume a minimum of a specific number of
electricity and/or therms of gas annually? If so, what are those limitations and why are
imposed?
REQUESTS NO. 5: If your response to the preceding discovery request is in the
what are those minimum consumption levels for both gas and/or electricity and how
what percentage of Avista low-income customers have been denied LIWA assistance in
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
that its LIWA program has on low-income customers in terms of reducing their
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
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REQUEST NO. 7: What are the number of disconnections between residential
receive LIWA assistance and those who do not?
REQUEST NO. 8: How many of Avista's low-income customers have been
to non-payment, or inability to pay, their electric or gas bills in the past ten (10) years
percentage do any such customers are residential customers?
REQUEST NO.9: Has Avista analyzed and concluded the relative effect of
low-income customers with LIWA funding on those same customers' tendency to timel
their bills and reduce uncollectible/collection costs for the Company? If so, please
results of such analysis for the past ten (10 years.
REQUEST NO. 10: Does Avista track and compare the number of customer
and related costs thereof between those customers who receive LIWA funding and
residential customers who do not?
REQUEST NO. 11: Does Avista believe that its current LIWA program has the effect
reducing disconnection, bad debt expense and other costs related to the loss of low
customers due to their inability to pay? If so, please explain such a belief.
DATED, this 24tr day of May,202l.
CAPAI'S FIRST PRODUCTION REQUESTS TO AVISTA
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Brad M. Purdy
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CERTIFICATE OF SERVICE
I certiff that on the24thday of May,202l,I served the foregoing FIRST PRODUCTI
REQUEST of COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO
following via electronic mail:
Idaho Public Utilities Commission
Jan Noriyuki Commission Secretary
i an.noriyuki@puc. idaho. eov
John Hammond
[e-mail]. sov
Avista:
David J. Meyer
David.mever@avistacorp. com
PatEhrbar@.avistacom.com
Avista dockets@avi stacorp. com
Idaho Conservation Leazue
Benjamin Otto
botto@idahocoservationleazue. ore
Walmart
Norman Semanko
nsemanko@f arsonsbehle. com
Steven Chriss
Walmart
Stephen. chri ss@walmart. com
Vicki M Baldwin
vbaldwin@parsonsbehle. com
Idaho Forest Group
Ron Williams
ron@wi I liamsbradbury. com
Lary Crowley
CAPAI'S FIRST PRODUCTION REQUESTS TO AVISTA
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[e-mail]
elearwatcrPapr
Peter J. Richatdmn
pet@richardsonadams. com
DonReading
dreadine(Amindsprine.com
cApAI',S FIRST PRODUCTION REQLJESTS TO AVTSTA
Brad M. Purdy
5