20230412Staff 125-141 to AVU.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 3:5POBOX83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-ABOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.AVU-E-23-01AVISTACORPORATIONFORTHE)AVU-G-23-01AUTHORITYTOINCREASEITSRATESAND)CHARGES FOR ELECTRIC AND NATURAL )FIFTH PRODUCTIONGASSERVICETOELECTRICANDNATURAL)REQUESTOF THEGASCUSTOMERSINTHESTATEOFIDAHO.)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Avista Corporation dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and information as soon as
possible,but no later than WEDNESDAY,MAY 3,2023.
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 or informationproduced.
Please provide answers to each question;supporting workpapers that provide detail or are
the source of information used in calculations;and the name,job title,and telephone number of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIFTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 1 APRIL 12,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.125:Please identify how many Customer Service Representatives
("CSRs")in total are employed by the Contact Center.
REQUESTNO.126:Please list how many CSRs work in each of the Contact Centers
located in Spokane WA,Coeur d'Alene ID,and Lewiston,ID respectively.
REQUESTNO.127:Please list the operating hours of the Contact Center in each
location.
REQUESTNO.128:Please explain the efforts put forth by the Company to promote
Project Share.
REQUESTNO.129:Please describe the types of advertising (radio,tv,bill insert,
welcome kit,etc.)that is conducted in Idaho to inform and educate customers about the
following:
a.Energy assistance and bill payment options;
b.Energy conservation;and
c.Winter Moratorium and the Winter Payment Plan.
In addition,please provide copies of any written brochures or documents sent or
otherwise provided to customers for each defined category listed in this question.
REQUESTNO.130:Please describe in detail the type of standard payment
plans/arrangements the Company offers its customers.
REQUESTNO.131:Please describe in detail the temporary alternative/modified
payment/plan arrangements the Company offered its customers in 2020 and 2021 due to
COVID-19.
FIFTH PRODUCTION REQUEST
TO AVISTA CORPORATION 2 APRIL 12,2023
REQUESTNO.132:Did the Company make any of the temporary alternative/modified
payment plan/arrangementa permanent offering?If no,please explain why not.
REQUESTNO.133:For each of the past three winters (2020-2021,2021-2022 and
2022-2023),how many participants were under Winter Moratoriumeach year?Of that amount,
how many participants agreed to be placed on the winter payment plan and how many were
unable to meet their monthlypayment?
REQUESTNO.134:Does the Company follow up after each customer interaction to
gauge customer satisfaction?If yes,please provide the method the Company uses,such as
surveys or satisfaction scores and provide the results for the past three years (2020,2021 and
2022).
REQUESTNO.135:Please explain the steps the Company made to address or follow-
up on any concerns identified through the above methods,such as surveys or satisfaction scores,
to ensure customer satisfaction with their Contact Center and/or CSR.
REQUESTNO.136:Please provide test year monthlyexpenses for account E-908
referenced in Schultz Exhibit 1.00 Result of Operations.
a.Please provide a breakdown of monthly expenses by category (i.e.,incentives,
admin,labor,etc.).
REQUESTNO.137:Please provide test year monthlyexpenses for account G-908
referenced in Schultz Exhibit 1.00 Result of Operations.
a.Please provide a breakdown of monthly expenses by category (i.e.,incentives,
admin,labor,etc.).
FIFTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 3 APRIL 12,2023
REQUESTNO.138:Regarding the Company's response to Production Request No.4,
Staff Attachment 4A,please provide copies of invoices,contracts,workpapers,supporting
documentation and a brief explanation on the cost differences between 2021 and 2022 for the
following:
a.4a-Internal auditing expenses:2021 employee expenses $2,981 and 2022
employee expenses $17,982;
b.4e-software/information system items:2021 other $2,877,313 and 2022 other
$3,357,750;
c.4e-software/information system items:2021 training $52,262 and 2022 training
$98,307;
d.4h-travel &training for executives:2021 $14,695 and 2022 $35,031;
e.4j-overhead items:2021 other $77,883 and 2022 other $5,678;and
f.4j-overhead items:2021 professional services $290,741 and 2022 professional
services $790,546.
REQUESTNO.139:Regarding the Company's response to Production Request No.
4(d),Staff Attachment 4A,please provide copies of the Moody reports received for years 2021
and 2022.
REQUESTNO.140:Regarding the Company's response to Production Request No.
4(f),Staff Attachment 4C,please provide documents/contracts/agreements to support the 2022
amounts paid to K Blake and S Morris.
REQUESTNO.141:Regarding the Company's response to Production Request No.
4(f),Staff Attachment 4C,tab MR_BOD-2,please provide copies of invoices and/or supporting
documentation,and a brief explanation of expenses and the need for the followingBoard of
Directors expenses:
a.020 Professional Services:Dean Davis Photography $2,753.96;and
b.020 Professional Services:Davis Polk &Wardwell $16,684.00.
FIFTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 4 APRIL 12,2023
DATED at Boise,Idaho,this ((day of April 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/avue23.l_avug23.lcbde prod req 5
FIFTH PRODUCTION REQUEST
TO AVISTA CORPORATION 5 APRIL 12,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12"DAY OF APRIL 2023,SERVED THE FOREGOING FIFTH PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NOS.AVU-E-23-01/AVU-G-23-01,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYERDIROFREGULATORYAFFAIRSVP&CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATIONPOBOX3727POBOX3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727E-mail:[e-mail] E-mail:[e-mail]@avistacorp.com
PETER J RICHARDSON DR DON READINGRICHARDSONADAMSPLLC280SILVERWOOD WAY515N277"STREET EAGLE,ID 83616BOISEID83702E-mail:[e-mail]-mail:[e-mail]
Electronic Service Only:
[e-mail]
[e-mail]
[e-mail]
ANDREW P MORATZKA LARRY A CROWLEY
STOEL RIVES LLP THE ENERGY STRATEGIES INSTITUTE
33 SOUTH SIXTH STREET,SUITE 4200 3738 S HARRIS RANCH AVE.MINNEAPOLIS,MN 55402 BOISE ID 83716E-MAIL:[e-mail] E-mail:crowleyla aol.com
JUSTINA A.CAVIGLIA STEVE W CHRISSPARSONSBEHLE&LATIMER DIRECTOR,ENERGY SERVICES
50 W.LIBERTY STREET,SUITE 750 WALMART INC
RENO,NV 89502 2608 SOUTHEAST J STE-MAIL:[e-mail] BENTONVILLE AR 72716
E-MAIL:[e-mail]
CERTIFICATE OF SERVICE
MARIE CALLAWAY KELLNER BRAD HEUSINKVELDIDCONSERVATIONLEAGUEIDCONSERVATIONLEAGUE710N6THST710N6THSTBOISEID83702BOISEID83702E-MAIL:[e-mail] E-MAIL:
bheusinkveld idahoconservation.org
F DIEGO RIVAS
NW ENERGY COALITION
1101 8TH AVE
HELENA MT 59601
E-MAIL:[e-mail]
S CRE
CERTIFICATEOF SERVICE