First Pro Request.pdf

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
()..(/IO
HECEIVED IT)FfLED
ZUni OCT 3 J PH 2= , 3
,,- , , j'j
U r JUriES COt'-iI-fisSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION BY
AVISTA 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 A WAIVER OF )
WINTER MORATORIUM RULE 306, IDAPA 31.21.01.306.
CASE NO. GNR-02-
FIRST 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
Intennountain Gas Company provide the following documents and infonnation on or before
TUESDAY, NOVEMBER 12, 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 Idaho Power 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 produced.
FIRST PRODUCTION REQUEST
TO A VISTA, P ACIFICORP AND
INTERMOUNTAIN GAS COMPANY
OCTOBER 31 2002
Please provide answers to each question; supporting workpapers that provide detail or are
the source of infonnation 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.
appropriate, please provide a joint response on behalf of all Applicants to Requests No.
through 7 and Request No. 18.
Request No.1: Given the following scenario, does each of the four described outcomes
provide an accurate illustration of how a customer would be affected by both the current
moratorium and the proposed Winter Protection Program? Ifnot, please explain the basis for
distinction and provide an illustrative example of how a customer would be affected.
Scenario. On December 1 , the customer declares inability to pay and has children under
18 in the household. The customer has a past due balance of $100. The customer is billed $75 in
December, $100 in January, and $125 in February for energy usage. For simplicity, interest
charges, which would nonnally apply, are not included in these examples.
Outcomes Under Existing Moratorium Rule 306
Customer eligible for LIHEAP The customer makes no payment from personal funds for
the months of December through February. The utility receives an Energy Assistance benefit
amount of$250 in January, which is applied to the customer s past due balance of$275 ($100
balance carried forward plus $75 bill for December and $100 bill for January.) The utility
prohibited from disconnecting the customer s service from December through February. On
March 1 , the customer has a past due balance of $150 ($25 remaining from January bill plus
$125 February bill) and is disconnected. To restore service, the customer must pay the past due
balance (or make other acceptable payment arrangements) plus a reconnection fee and a deposit.
Customer not eligible for LIHEAP The customer makes no payment for the months of
December through February. The utility is prohibited from disconnecting the customer s service
from December through February. On March 1 , the customer has a past due balance of $400 and
is disconnected. To restore service, the customer must pay the past due balance (or make other
acceptable payment arrangements) plus a reconnection fee and a deposit.
FIRST PRODUCTION REQUEST
TO A VISTA, P ACIFICORP AND
INTERMOUNTAIN GAS COMPANY
OCTOBER 31 , 2002
Outcomes under proposed Winter Protection Program (WPP)
Customer elizible for LIHEAP The customer s regular level pay amount (based on
estimated annual usage plus the past due balance of$100 divided into 12 monthly installments)
is $90. The customer s monthly payment amount under the Winter Protection Program for
December, January and February is $45, one-half the regular level payment amount. The
customer pays $45 in December as agreed. The utility receives an Energy Assistance benefit
amount of$250 in January, which is applied to the customer s actual balance of$230 ($100
balance carried forward plus $75 bill for December and $100 bill for January minus the $45
payment made in December.)* The $20 credit balance is carried forward on the customer
February bill, so the customer pays $25 ($45 WPP amount minus credit of $20). After March 1
the customer must renegotiate payment arrangements. Options available include calculating a
new regular level payment amount, making special payment arrangements to payoff the balance
owing over a prescribed length oftime, or paying the balance of$100 ($125 February bill minus
$25 payment) and paying future bills as they become due.
* At the customer s request, the utility may recalculate the monthly payment amount
following receipt of a LIHEAP or other "bulk" financial assistance payment.
Customer eligible for LIHEAP but fails to make pavment The customer s regular level
pay amount (based on estimated annual usage plus the past due balance of $1 00 divided into 12
monthly installments) is $90. The customer s monthly payment amount under the Winter
Protection Program for December, January and February is $45 , one-half the regular level
payment amount. The customer fails to make the initial $45 payment in December as agreed and
the utility has not yet received Energy Assistance benefit payment on behalf of the customer.
The customer fails to respond to 7 day and 24 hour notices from the utility and is disconnected.
The customer pays the $45 owing under the WPP agreement and service is restored. The utility
includes the reconnection fee on the January bill and waives collection of a deposit. The utility
receives an Energy Assistance benefit amount of$250 in January, which is applied to the
customer s actual balance of $250 ($100 balance carried forward plus $75 bill for December, the
$100 bill for January, and a $20 reconnection fee minus the $45 payment made in December.
) *
The customer pays $45 in February. After March 1 , the customer must renegotiate payment
arrangements. Options available include calculating a new regular level payment amount
FIRST PRODUCTION REQUEST
TO A VISTA, P ACIFICORP AND
INTERMOUNTAIN GAS COMPANY
OCTOBER 31 , 2002
making special payment arrangements to payoff the balance owing over a prescribed length of
time, or paying the balance of$80 ($125 February bill minus $45 payment) and paying future
bills as they become due.
* At the customer s request, the utility may recalculate the monthly payment amount
following receipt of a LIHEAP or other "bulk" financial assistance payment.
Customer not eligible for LIHEAP.The customer does not qualify for the WPP and must
pay bills as they become due. Other payment arrangement options are available. The customer
regular level pay amount (based on estimated annual usage plus the past due balance of $1
divided into 12 monthly installments) is $90. Alternatively, the customer may negotiate a special
payment arrangement tailored to his or her particular circumstances. The utility may disconnect
service if the customer fails to pay bills as they become due or to keep a payment arrangement.
If disconnection occurs, the customer must pay the past due balance plus a reconnection fee and
a deposit.
Request No.2: In the Application at page 2, eligibility for the proposed Winter
Protection Program is defined as "any residential customer who declares that he or she is unable
to pay for utility service during the specified months of December, January and February and
whose household qualifies for energy assistance from a local Community Action Agency . Is
the reference to "energy assistance from a local Community Action Agency" meant to generally
apply to any financial assistance provided through a local Community Action Agency for the
purpose of paying energy bills, including Project Share? Alternatively, should this phrase be
more narrowly construed as eligibility to participate in the Low Income Home Energy Assistance
Program (LIHEAP)?
Request No.3: Is it the intention of the Applicants that eligibility for participation in the
proposed Winter Protection Program be based on State of Idaho income criteria established for
LIHEAP, which may vary from year to year?
Request No.4: In the Application at page 5 , the statement is made that "Tennination of
service may occur if customers do not participate in the Winter Protection Program through
FIRST PRODUCTION REQUEST
TO A VISTA, P ACIFICORP AND
INTERMOUNTAIN GAS COMPANY
OCTOBER 31 , 2002
establishing monthly payments with the exception of special dispensation customers under
medical emergency' designation . Is the reference to a medical "exception" based on the
requirements of Rule 308 of the Utility Customer Relations Rules? Ifnot, please provide further
explanation of how the utilities intend to provide special dispensation in cases of medical
emergencIes.
Request No.5: Rule 308 of the Utility Customer Relations Rules provides for a 30-day
extension for payment. At the utility s option, another 30-day extension may be granted. What
criteria will be used to detennine whether to grant this second medical extension? Will the
criteria differ during the winter heating season as opposed to any other time of year? If a
customer receives a full 60-day medical extension but the same medical conditions exist at the
end of the 60 days, will further extensions be granted? Ifnot, why not? If so, what criteria will
be used to detennine whether further extensions should be granted?
Request No.6: Applicants have requested temporary exemption from Rule 306.01-06.
Would Applicants be opposed to maintaining the part of the current moratorium that prohibits
disconnection of customers who are infinn? If so, why?
Request No.7: The proposed Winter Protection Program will exclude customers who do
not meet LIHEAP income eligibility criteria. What payment options will be available for the
working poor, defined as those customers who fall between 133% and 200% of the Federal
Poverty Guidelines? Will any special consideration be provided to these customers? If so
please describe.
Request No.8: For each Applicant, please provide the number of residential customers
served at the end of the calendar year for 1999 2000 and 2001. For Avista, please provide a
further breakdown of customers by the following categories: electric only, gas only, gas and
electric combined.
FIRST PRODUCTION REQUEST
TO A VISTA, P ACIFICORP AND
INTERMOUNTAIN GAS COMPANY
OCTOBER 31 , 2002
Request No.9: For each Applicant, please provide the number of residential customers
served at the end of the calendar year for 1999, 2000 and 2001 who were on a Level Payment
Plan. For Avista, please provide a further breakdown of customers by the following categories:
electric only, gas only, gas and electric combined.
Request No. 10: For each Applicant, please provide the total number of residential
customers who declared eligibility for protection from disconnection during the moratorium for
the 1999-2000 2000-01 and 2001-02 heating seasons. For Avista, please provide a further
breakdown of customers by the following categories: electric only, gas only, gas and electric
combined.
Request No. 11: For each Applicant, please provide the number of residential customers
served at the end of the calendar year for 1999, 2000 and 2001 who declared eligibility for
protection from disconnection during the moratorium and were on a Level Payment Plan or a
Winter Payment Plan. (Please list each type of plan separately.) For Avista, please provide a
further breakdown of customers by the following categories: electric only, gas only, gas and
electric combined.
Request No. 12: Of those customers identified in the response to Request No. 11 above
how many received a LIHEAP benefit? How many received financial assistance from Project
Share?
Request No. 13: For each Applicant, please provide the total number of customers who
declared eligibility for protection from disconnection during the moratorium for the 1999-2000
2000-01 and 2001-02 heating seasons and made no payments during the months of December
January and February. For Avista, please provide a further breakdown of customers by the
following categories: electric only, gas only, gas and electric combined.
Request No. 14: For each Applicant, please provide the total number of customers who
declared eligibility for protection from disconnection during the moratorium for the 1999-2000
FIRST PRODUCTION REQUEST
TO A VISTA, P ACIFICORP AND
INTERMOUNTAIN GAS COMPANY
OCTOBER 31 , 2002
2000-01 and 2001-02 heating seasons and were disconnected for non-payment the following
March, April or May. (Please list each month separately.) For Avista, please provide a further
breakdown of customers by the following categories: electric only, gas only, gas and electric
combined. Please also provide the total amount owing at the time of disconnection for each
month.
Request No. 15: Of those customers identified in the response to Request No. 13, how
many were subsequently reconnected within 10 days of disconnection? For A vista, please
provide a further breakdown of customers by the following categories: electric only, gas only,
gas and electric combined.
Request No. 16: Of those customers identified in the response to Request No. 13 , how
many did not reestablish service and had made no payment 90 days after disconnection? For
Avista, please provide a further breakdown of customers by the following categories: electric
only, gas only, gas and electric combined. Please also provide the total amount owing 90 days
after disconnection for each month. What percentage of total residential write offs does this
represent for the same time period?
Request No. 17: For each Applicant, please identify the total amount that the Company
received in LIHEAP benefits for Idaho customers during the 1999-2000 2000-01 and 2001-
heating seasons. For each Applicant, please identify the total amount received in Project Share
payments during the 1999-2000 2000-01 and 2001-02 heating seasons. For Avista, please
provide a further breakdown of customers by the following categories: electric only, gas only,
gas and electric combined.
Request No. 18: At the conclusion of the Winter Protection Program pilot, what criteria
should be used to judge whether it was successful? What data should be collected by each utility
and reported to the Commission to aid in its evaluation of the pilot?
FIRST PRODUCTION REQUEST
TO A VISTA, P ACIFICORP AND
INTERMOUNTAIN GAS COMPANY
OCTOBER 31 , 2002
-?4 ~'f
Dated at Boise, Idaho, this .::v.. day of October 2002.
-For Lisa Nordstrom
Deputy Attorney General
Technical Staff: Beverly Barker
i :umisc/prodreq/gnruO2.1Inbab
FIRST PRODUCTION REQUEST
TO A VISTA, P ACIFICORP AND
INTERMOUNTAIN GAS COMPANY
OCTOBER 31 , 2002
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31sT DAY OF OCTOBER 2002
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO, 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
~~~-
SECRET Y
CERTIFICATE OF SERVICE