Staff's Second Prod. Req..doc

LISA NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 5733

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION BY AVISTA UTILITIES, INTERMOUNTAIN GAS AND PACIFICORP TO IMPLEMENT A TWO-YEAR PILOT WINTER PROTECTION PROGRAM THAT ESTABLISHES MINIMUM MONTHLY PAYMENTS DURING THE WINTER MORATORIUM, AND A WAIVER OF WINTER MORATORIUM RULE 306, IDAPA 31.21.01.306. )
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CASE NO. GNR-U-02-1

SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO
AVISTA UTILITIES, PACIFICORP 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 Avista Utilities, PacifiCorp and Intermountain Gas Company are 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 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. 10 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, 2000-01, 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 of Idaho 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 of Idaho residential customers who had a past due amount owing as of October 1, 2001, December 1, 2001, March 1, 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 of the 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 1, 2001, December 1, 2001, March 1, 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 of Idaho residential disconnections for nonpayment for each month between November 1, 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 of Idaho 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 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.

____________________________________
Lisa Nordstrom
Deputy Attorney General

Technical Staff: Beverly Barker

i:umisc/prodreq/gnru02.1lnbab 2nd

SECOND PRODUCTION REQUEST 1 NOVEMBER 6, 2002
TO AVISTA, PACIFICORP AND
INTERMOUNTAIN GAS COMPANY