20141031Staff 1-23 to Avista.pdf

KARL KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA CORPORATION, )
IDAHO POWER COMPANY, AND ) CASE NO. GNR-U-14-01
PACIFICORP DBA ROCKY MOUNTAIN )
POWER'S PETITTON FOR AN EXEMPTION TO) FrRST PRODUCTTON
UTILITY CUSTOMER RELATIONS RULES ) REQUEST OF THE
3lr(4) AND (s).) coMMrssloN srAFF To
) AVTSTA CORPORATION
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl Klein, Deputy Attorney General, requests that Avista Corporation (Company) provide the
following documents and information as soon as possible, but no later than FRIDAY,
NOVEMBER 14, 2014.r
This Production Request is to be considered as continuing, and the Company 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 information produced.
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
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA 1 OCTOBER 3I,2OI4
the person preparing the documents. Please identifu the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
Please note that all questions pertain to the Company's policies and practices with respect
to customers located in its Idaho service territory.
REQUEST NO. 1: For calendar year 2013, please provide the number of field
disconnection visits made to the premises of customers. How many of these visits were made to
non-residential customers?
REQUEST NO. 2: For calendar year 2013, please provide the number of customers
who had field disconnection visits made to their premises two or more times. How many of
these customers were non-residential customers?
REQUEST NO.3: For calendar year 2013, please provide the number of (a) residential
customers and (b) non-residential customers who paid at the door at the time of the
disconnection visit.
REQUEST NO. 4: For calendar year 2013, please provide the number of scheduled
disconnections that were cancelled by an on-site employee who had concerns about the impact of
disconnection on the customer's health and/or safety.
REQUEST NO. 5: Please provide the number of call attempts routinely made by the
Company to each affected customer prior to disconnection of service.
REQUEST NO. 6: What steps has the Company taken to validate the telephone
numbers it has on file for customers?
REQUEST NO. 7: Does the Company electronically notify customers of pending
disconnection of service? If so, please explain: (l ) how the notification occurs (timing, whether
FIRST PRODUCTION REQUEST
TO AVISTA ocroBER 31,2014
by e-mail or text message, etc.); and (2) whether electronic notification is in addition to or in lieu
of sending written notices via US Mail.
REQUEST NO. 8: Please provide the current cost of a visit to a customer premise in
Idaho for the purpose ofdisconnecting and reconnecting service? Is there a difference in cost
between a disconnection visit and a reconnection visit?
REQUEST NO. 9: If the requested rule exemption is approved, under what
circumstances will the Company's employees accept payment from a customer during the
employee's visit to the customer's premises?
REQUEST NO. l0: The Petitioners have expressed concern about employee safety and
the risk posed by knocking at the door before disconnecting service and accepting payment in
lieu of disconnection. Assuming that the degree of risk varies from customer to customer, what
factors (e.g., customer behavior, payment history, service location, etc.) increase risk? Please
also provide: (1) a copy of any risk analysis or formal study that has been performed by or on
behalf of the Company; and (2) any other evidence on which the Company bases its concerns
about employee safety and risk.
REQUEST NO. 1l: For calendar year 2013, how many documented, customer-related
safety incidents have occurred when a Company employee has visited a customer's home for the
pu{pose of disconnecting the customer? Please provide a breakdown of the types of incidents.
REQUEST NO. 12: How many meters with remote disconnecVreconnect capability are
installed at customer premises? Please provide a breakdown by customer class (residential and
non-residential) and selection criteria.
REQUEST NO. 13: Of the locations identified in the previous question, how many are
served under a master-metering arrangement? How many of the meters are installed at locations
where the customer received LIHEAP benefits during the past 12 months?
FIRST PRODUCTION REQUEST
TO AVISTA ocToBER 31,2014
REQUEST NO. 14: Using the most current data available, please provide a breakdown
of the type of disconnect device (TWACS; Nighthawk/l way communication; NighthawW2way
communication) installed.
REQUEST NO. 15: Does the Company's intend to continue using the same criteria
specified in Case No. AVU-E-07-09 for identifying locations where a meter with remote
disconnection/reconnection capability will be installed? If not, please explain what criteria the
Company intends to use.
REQUEST NO. 16: For customers with remote disconnect/reconnect meters, does the
Company intend to continue to charge those customers 50olo of its authorized reconnection fees?
If not, please explain.
REQUEST NO. 17: When a customer closes an account at a location where the
Company has installed a meter with remote disconnect/reconnect capability, does the Company
allow the meter to remain in place? If the targeted customer moves to a new location within the
Company's service territory, does the Company install a meter with remote disconnect/reconnect
capability at the customer's new location? Does the Company move a meter with remote
disconnect/reconnect capability to a different location if a customer no longer meets, or a
subsequent customer does not meet, the selection criteria for this type of meter?
REQUEST NO. 18: Since the Company has identified employee safety as a concem,
please explain why the Company feels it is necessary for an on-site employee to knock on the
door before disconnecting service at locations where remote connect/disconnect capable meters
have not been installed.
REQUEST NO. 19: If the requested rule exemption is granted, Idaho Power plans to
make field visits during the winter moratorium to knock on the customer's door before
disconnecting the customer for nonpayment, regardless of meter type. Has Avista considered
taking that step as well in its service territory? Does the Company prefer to establish a consistent
no-knock policy throughout the year?
FIRST PRODUCTION REQUEST
TO AVISTA ocroBER 3t,2014
REQUEST NO.20: Please provide the Company's unit cost for a meter with remote
disconnect/reconnect capability.
REQUEST NO.21: Please provide the Company's unit cost for a meter without remote
di sconnect/reconnect capability.
REQUEST NO. 22: For calendar year 2013, please provide the total number of remote
disconnections by month and reason for disconnection, following the format used in Company
witness Gervais' Exhibit No. l, Schedule 2, Illustration No. 3, page 7 .
REQUEST NO.23: For calendar year2013, please provide the length of time between
remote disconnections and subsequerit reconnections, following the format used in Company
witness Gervais' Exhibit No. l, Schedule 2, Illustration No. 4, page 7 .
DATED at Boise, ldaho, this 3 1 'l duv of October 2014.
1U /t-
Karl Klein
Deputy Attorney General
Technical Staff: Beverly Barker
i:umisc:prodreq/gnrul4.lkkbab prod req I to Avista
FIRST PRODUCTION REQUEST
TO AVISTA ocToBER 31,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3IS, DAY OF OCTOBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
coMMrssroN STAFF To AVISTA CORPORATION, IN CASE NO.
GNR-U.l4-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220
E-MAIL : [e-mail]
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
DANIEL E SOLANDER
TED WESTON
ROCKY MOLTNTAIN POWER CO
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
ted. weston@pacifi corp. com
datarequest@pacifi corp. com
LINDA GERVAIS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220
E-MAIL: linda. [e-mail]
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
BARBARA COUGHLIN
PACIFICORP
825 NE MULTNOMAH STE 8OO
PORTLAND OR 97232
E-MAIL: barbara.coushlin@pacifi corp.com
SECRETARY
CERTIFICATE OF SERVICE