20031114Decison Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
WORKING FILE
FROM:BEVERLY BARKER
DATE:NOVEMBER 7 2003
RE:DATA COLLECTION REQUIRED OF ENERGY UTILITIES PURSUANT
TO ORDER NO. 29165.
BACKGROUND
Last October, the Commission received a Joint Application from Avista Corporation
Intermountain Gas Company and PacifiCorp (Applicants) seeking authorization to implement a
two-year pilot "Winter Protection Program" that established minimum monthly payments during
the winter moratorium period. The Commission opened Case No. GNR-02-1 to consider the
Applicants ' request. Avista withdrew from the case on November 20 2002. Idaho Power was
not a party to this case, but did participate in discussions leading up to filing the Application and
did provide data at the request of the Commission Staff.
On November 29 2002, the Commission issued Order No. 29165 denying the
Application. The Applicants and Idaho Power were directed to gather specific information
listed in an attachment to the Order
, "
to ensure that we have the necessary information to
properly evaluate any future changes to the winter moratorium rules . Order No. 29165 at 10.
The majority of the required information specifically referred to the December 2002 through
May 2003 time period. See attachment.
STAFF ANALYSIS & RECOMMENDATION
The Commission did not receive a request to modify the moratorium this year. Staff has
received most of the information required by the Order and is now in the process of gathering the
remaining information. Staff contemplates doing an analysis of that data and submitting a report
DECISION MEMORANDUM - 1 -NOVEMBER 7, 2003
to the Commission by the end of this year. Avista, Intermountain Gas, PacifiCorp and Idaho
Power have informally inquired as to whether there is a continuing obligation to collect the
information required by the Order. Subsequently, Intermountain Gas indicated that it would
continue to collect the same information during the 2003-2004 moratorium period. The
Company indicated that changes in its procedures and prices, as well as last year s warmer
winter weather, made it questionable as to whether the existing information is representative of
what the Company might expect to happen in the future. The Company is willing to share that
additional information with the Commission. Staff agrees that collection of additional
information for Intermountain Gas would be helpful.
Order No. 29165 states
, "
IT IS FURTHER ORDERED that utilities intending to seek
future modification of the Commission s winter moratorium eligibility rules collect the
information identified in the Attachment to this Order." At the time the Order was issued, it
appeared likely that at least one utility would pursue modification of the rules in 2003. Clearly,
the Commission decided that it was important to have certain information to use in future
deliberations. It is difficult to predict when, if ever, another request to modify the moratorium
will be presented to the Commission.
Staff believes that, with the exception of Intermountain Gas, collection of all the required
information during 2002 and 2003, together with information provided by the utilities in Case
No. GNR-02-1 is sufficient to provide a baseline for future discussions about modification of
the moratorium. Staff commends Intermountain Gas for its willingness to collect information for
another moratorium period. Staff recommends that information collected by Avista, PacifiCorp
and Idaho Power pursuant to Order No. 29165 for the period from December 2002 through May
2003 be considered sufficient to satisfy the requirements of the Order.
After it has an opportunity to review Staff s report on the information already collected
the Commission may want to provide further direction to the affected utilities. Some
information required by the Order, such as utility revenue and collection information, will be
available upon Staff request. However, Staff recognizes that certain customer-specific
information, e., income level at the time of declaring moratorium eligibility, will not be
available unless utilities take steps to collect the information during this and future heating
seasons.
DECISION MEMORANDUM - 2 -NOVEMBER 7, 2003
CO MMISSI ON D ECISI
Does the Commission agree that collection of the information by Avista, PacifiCorp, and
Idaho Power as required by Order No. 29165 for the period from December 2002 through May
2003 satisfies the requirements of the Order?
Does the Commission agree that collection of additional information by Intermountain
Gas for the period from December 2003 through May 2004 would satisfy the requirements of the
Order?
i:udmemos/Data coHee DM
DECISION MEMORANDUM - 3 -NOVEMBER 7 , 2003
MORA TORllJM INFORMATION REQUIRED
FOR FUTURE COMMISSION REVIEW
Establishing a Baseline
How many residential customers were served at the end ofthe calendar year 2002? For PacifiCorp,
how many residential customers were served at the end of the fiscal year (March 2003)?
Inability to Pay
How many residential customers declared moratorium eligibility during the months of December
2002 and January and February 2003? List the number of customers who declare during each month
separately.
For those customers declaring moratorium eligibility, how many:
Had children (18 or under) in the household?
Had elderly (62 or older) in the household?
Met the income eligibility guidelines for LlliEAP?
For those that meet LlliEAP income eligibility guidelines, how many actually
receive LllIEAP benefits?
How many residential customers received LllIEAP benefits but did not declare moratorium
eligibility?
Participation in Level Pay Plans and Winter Payment Plans
How many moratorium eligible customers sign up for a regular Level Pay Plan? How many make all
monthly payments as agreed during the months of December, January and February? Payments may
be from any source, including LllIEAP benefits.
How many moratorium eligible customers sign up for a Winter Payment Plan? How many make all
monthly payments as agreed during the months of December, January and February? Payments may
be from any source, including LIHEAP benefits.
Payment History
For those moratorium eligible customers who receive LllIEAP benefits, how many make no payment
other than the LIHEAP benefit amount during the months of December, January and February?
ATTACHMENT
ORDER NO. 29165
CASE NO. GNR-O2-
F or those moratorium eligible customers who do not meet the eligibility guidelines for LIHEAP, how
many make no payment during the months of December, January and Febru.ary?
For those moratorium eligible customers who qualify for but do not receive LllIEAP benefits, how
manyrnake no payment during the months of December, January and February?
How many moratorium eligible customers had a past due amount owing at the time they declared
moratorium eligibility? For these customers, what is the total revenue past due and owed at the time
of declaration of eligibility? List the months of December through February separately.
How many moratorium eligible customers had a past due amount owing as of March 1, 2003? For
these customers, what is the total revenue past due and owed as of March 1 , 2003? How many of
these customers received LIHEAP benefits?
How many moratorium eligible customers are disconnected for nonpayment during the months of
March through May 2003? For these customers, what is the aggregate amount owing at the time of
disconnection for nonpayment? How many of these customers received LIHEAP benefits? List each
month separately.
During the months of March through May 2003, how many moratorium eligible customers are
disconnected for nonpayment and subsequently reconnected within 10 days of disconnection? For
these customers, what is the aggregate amount paid at the time of reconnection? How many of these
customers received LlliEAP benefits? List each month separately.
How many moratorium eligible customers were disconnected for nonpayment during the months of
March through May 2003 and did not re-establish service and made no payment 90 days after
disconnection? Of these customers, what was the total amount owing 90 days after disconnection?
How many of these customers received LIHEAP benefits? What percentage of total residential write
offs does this represent for the same time period?
ATTACHMENT
ORDER NO. 29165
CASE NO. GNR-O2-