20051027Avista comments.pdf

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Avista Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
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October 25 , 2005
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
Statehouse Mail
W. 472 Washington Street
Boise, Idaho 83720
RE: Case No. RUL-O4-
Dear Ms. Jewell:
Avista Utilities appreciates the opportunity to comment on the IPUC Staffs Decision
Memo dated August 12, 2005 regarding the proposed revisions to the Commission
Utility Customer Relations Rules (IDAP A 31.21.01) in the above-cited case.
Rule 306 - Termination of Residential Gas and Electric Service - Winter Payment Plan
(The Winter Moratorium)
Expanding the Moratorium Time Frame-Two of the four goals set by the
Commission for the winter moratorium policy include 1) encouragement of good
payment habits by customers and 2) providing relief from impossible financial
obligations. A vista believes that extending the moratorium to include the months
of November and March conflicts with the goals set forth by the Commission.
Customers who are not required to make payments for 5 months could find
themselves in financial situations that could become difficult, if not impossible to
catch up. A vista does not support the proposal to extend the moratorium.
Expanding the Moratorium Eligibility Criteria to include customers who
receive LIHEAP In northern Idaho, LIHEAP appointments start on December
1 st and fill up quickly. Many customers have to wait 1-2 months for an
appointment and by the time their grant is received, the Moratorium is almost
over, In 2004, only 46% of the customers receiving LIHEAP , received their
grants during the months of Dec., Jan., and Feb. Customers unable to get
LIHEAP appointment early on in the heating season would be unfairly treated
under this new rule as opposed to those customers that receive the first
appointments. A vista does not support the proposal to expand the eligibility
criteria for moratorium.
Modifications to Winter Payment Plan Avista supports the proposal to
eliminate the restriction on participation of the Winter Payment Plan and allow
customers who make regular monthly payments during the moratorium period to
participate in the Winter Payment Plan in succeeding years.
Customers and applicants who move - During the "Best Practices" discussions
A vista supported the proposal to continue to provide service to a customer who
moves to another location during the moratorium period. The definition of
customer was recently revised in March 2004. Currently, a customer must have
had service within the past 10 days to be considered a customer. Prior to the
March 2004 revision, a customer must have had service in the past 60 days to be
considered a customer. Under the proposed new rule, the utilities would be
required to provide service to applicants who have had service within the past 30
days, this rule changes the definition of a customer. Avista does not support the
proposal to require that utilities provide service to applicants who move.
Rule 304 - Requirements for Notice to Customers Before Termination of Service
Double the number of Days of a Disconnect Notice- Avista objects to ICAN'
proposal and supports Staff s recommendation.
Require documented attempts to contact Customer - Avista objects to ICAN'
proposal and supports Staffs recommendation.
Rule 305 - Contents of Notice of Intent to Terminate Service
Require Disconnect Notices contain specific information during the months
November through February- During the "Best Practices" discussions, Avista
supported the proposal to include information about the winter moratorium
winter payment plan, and the availability of payment plans, In November 2004
A vista began providing this information in all disconnect notices.
Require Disconnect Notices provide exact date and time of disconnect - Avista
agrees with Staff that it would be impractical to provide this information
notices.
Require Disconnect Notices be printed in foreign languages - Avista agrees
with Staff and does not support ICAN's proposal. Avista is sensitive to customers
whose primary language is other than English and will continue to monitor
changes in demographics that warrant changes in communications.
Rule 308 - Serious Illness or Medical Emergency
Extend Medical Certificate protection - Avista agrees with Staff and does not
support ICAN's proposal.
Rule 311 - Restrictions on Termination of Service - Opportunity to Avoid Termination
of Service
Prohibit Disconnections on Fridays or any day preceding a legal holiday
Avista objects to ICAN's proposal and supports Staffs recommendation to
reinstate the noon deadline on Fridays.
Rule 701 - Summary of Rules
Provide the annual Summary of Rules in foreign languages - A vista objects to
ICAN's proposal and supports Staffs recommendation to develop and make
available model summaries of the rules. A vista is sensitive to customers whose
primary language is other than English and will continue to monitor changes in
demographics that warrant changes in communications.
Rule 702 - Multilingual Notices
Multilingual Notices- Avista agrees with Staff and does not support ICAN'
proposal. A vista is sensitive to customers whose primary language is other than
English and will continue to monitor changes in demographics that warrant
changes in communications.
If you have any questions on these matters, please contact Renee Webb at (509) 495-
7987 or myself at [phone].
Sincerely,
Bruce Folsom
Manager, Regulatory Compliance
A vista Corporation
bruce. fo IsomCIDavistacorp. com