Staff's First 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

FIRST 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 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.
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. If appropriate, please provide a joint response on behalf of all Applicants to Requests No. 1 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? If not, 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 normally 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 is 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.
Outcomes under proposed Winter Protection Program (WPP)
Customer eligible 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’s 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 pay off the balance owing over a prescribed length of time, 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 payment. 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 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, making special payment arrangements to pay off 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’s regular level pay amount (based on estimated annual usage plus the past due balance of $100 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 “Termination of service may occur if customers do not participate in the Winter Protection Program through 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? If not, 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 determine 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? If not, why not? If so, what criteria will be used to determine 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 infirm? 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.

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, 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 Avista, 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 2001-02 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?

Dated at Boise, Idaho, this day of October 2002.

____________________________________
Lisa Nordstrom
Deputy Attorney General

Technical Staff: Beverly Barker

i:umisc/prodreq/gnru02.1lnbab

FIRST PRODUCTION REQUEST 1 OCTOBER 31, 2002
TO AVISTA, PACIFICORP AND
INTERMOUNTAIN GAS COMPANY