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Home My WebLink AboutSecond Pro. Request.pdfLISA NORDSTROM DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 BAR NO. 5733 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff ;'),,3'-1 RECEIVED FILED lfiOHtOV -6 fH 3: 0' IDl'j.j~,,-jC UTll1j"IES CDl1t"HSSlON BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION BY VISTA UTILITIES, INTERMOUNTAIN GAS AND P ACIFICORP TO IMPLEMENT A TWO- YEAR PILOT WINTER PROTECTION PROGRAM THAT ESTABLISHES MINIMUM MONTHLY PAYMENTS DURING THE WINTER MORATORIUM, AND WAIVER OF ) WINTER MORATORIUM RULE 306, IDAPA )31.21.01.306. CASE NO. GNR-02- SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO VISTA UTILITIES, ACIFICORP AND INTERMOUNTAIN GAS COMPANY The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Lisa Nordstrom, Deputy Attorney General, requests that Avista Utilities, PacifiCorp and Intermountain Gas Company provide the following documents and information on or before MONDAY, NOVEMBER 18, 2002. The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name location and phone number of the record holder. Reference IDAPA 31.01.01.228. This Production Request is to be considered as continuing, and A vista Utilities PacifiCorp and Intermountain Gas Company are requested to provide, by way of supplementary SECOND PRODUCTION REQUEST TO A VISTA, P ACIFICORP AND INTERMOUNTAIN GAS COMPANY NOVEMBER 6, 2002 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. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. Clarification to Request No. 12: Request No. 12 should reference Request No. 10, not No. 11. The corrected Request No. 12 should read as follows: Of those customers identified in the response to Request No.1 0 above, how many received a LIHEAP benefit? How many received financial assistance from Project Share? General Clarification: All questions refer to information specific to Idaho customers or each Applicant's Idaho service territory. Request No. 19: For each Applicant, how many residential customers received a LIHEAP benefit but did not declare eligibility for protection from disconnection during the moratorium for the 1999-2000 2000-, and 2001-02 heating season? For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 20: For each Applicant, please provide the number ofldaho residential customers served as of October 1 2001 and April 1 , 2002, respectively. For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 21: For each Applicant, please provide the number ofldaho residential customers who had a past due amount owing as of October 1 , 2001 , December 1 , 2001 , March 1 SECOND PRODUCTION REQUEST TO AVISTA, PACIFICORP AND INTERMOUNTAIN GAS COMPANY NOVEMBER 6, 2002 2002 and April 1 , 2002, respectively. For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 22: For each Applicant, how many ofthe Idaho residential customers.who had a past due amount owing as of March 1 , 2002 and April 1 , 2002, received LIHEAP benefits during the previous heating season? For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 23: For each Applicant, please provide the total revenue past due and owed by residential customers as of October 2001 December 2001, March 2002 and April 1 2002, respectively. For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 24: For each Applicant, please provide the number ofldaho residential disconnections for nonpayment for each month between November 2000 and March 31 2001. For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 25: For each Applicant, please provide the number ofldaho residential disconnections for nonpayment for each month between November 1 , 2001 and March 31 , 2002. For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 26: For each Applicant, please provide the aggregate number of residential disconnections for nonpayment between April 1 , 2000 and October 31 , 2000. For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 27: For each Applicant, please provide the aggregate number of residential disconnections for nonpayment between April 1 , 2001 and October 31 , 2001. For Avista, please SECOND PRODUCTION REQUEST TO A VISTA, P ACIFICORP AND INTERMOUNTAIN GAS COMPANY NOVEMBER 6, 2002 provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Request No. 28: For each Applicant, what is the gross residential write-off ratio (total residential revenue divided by total residential write-offs) for calendar years 1999 2000 and 2001? For Avista, please provide a further breakdown of customers by the following categories: electric only, gas only, and gas and electric combined. Dated at Boise, Idaho, this day of November 2002. isa Nordstro Deputy Attorney General Technical Staff: Beverly Barker i:umisc/prodreq/gnruO2.11nbab 2nd SECOND PRODUCTION REQUEST TO AVISTA, PACIFICORP AND INTERMOUNTAIN GAS COMPANY NOVEMBER 6, 2002 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF NOVEMBER 2002 SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA UTILITIES, PACIFICORP AND INTERMOUNTAIN GAS COMPANY, IN CASE NO. GNR-02-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: KELLY 0 NORWOOD A VISTA UTILITIES 1411 EMISSION PO BOX 3727 SPOKANE W A 99220-3727 PAUL POWELL INTERMOUNTAIN GAS COMPANY 555 S COLE RD PO BOX 7608 BOISE ID 83707 CAROLE ROCKNEY P ACIFICORP 1900 SW FOURTH AVE, PLAZA LEVEL PORTLAND OR 97201 ba~ SEC 1\RY CERTIFICATE OF SERVICE