20071024Avista comments.pdf

Avista Corp.
1411 East Mission PO Box3727
Spokane, Washington 99220-3727
Telephone [phone]
Toll Free 800-727-9170
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October 23 2007
Jean Jewell , Commission Secretary
State of Idaho
Idaho Public Utilities Commission
Statehouse
Boise, ill 83720
Re: Comments of Avista Corporation in RUL-07-
Dear Ms. Jewell:
Enclosed for filing are an original and seven (7) copies of Avista s comments regarding
Revision of the Commission s Utility Customer Relations Rules, Docket No. 31-2101-
0701."
If you have any questions regarding this filing, please feel free to contact DJ Spooner at
[phone] or myself at [phone].
Sincerely,-
Linda Gervais
Senior Regulatory Analyst
State and Federal Regulation
A vista Utilities
509-495-4975
linda. gervais(Z~a vistacorp .com
Kelly Norwood
Vice President, State and Federal Regulation
A vista Corporation
1411 East Mission Ave.
Spokane, W A 99202
Phone: [phone]
Fax: [phone]
kell y. norwood(fYavi stacorp. com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.RUL-07-
IN THE MATTER OF THE REVISION
FO THE COMMISSION'S UTILITY
CUSTOMER RELATIONS RULES
IDAPA 31.21.01
COMMENTS OF A VISTA
CORPORATION
A vista Corporation ("A vista" or "Company ) hereby submits comments in response to
the Idaho Public Utilities Commission s ("Commission ) proposed changes to the Utility
Customer Relations Rules, IDAP A 32.21.01.
The Company appreciates the opportunity to comment on the IPUC Staffs Decision
Memo dated August 9, 2007 regarding the proposed amendments to the Utility Customer
Relations Rules. The Company s comments will focus primarily on Rules 203 and 311.
Rule 105
Offers the Customer the option of paying their deposit in two installments Avista
supports the proposed revisions to Rules 105.01 and 105.2 regarding installation of
deposits.
A VISTA CORPORATION COMMENTS IN RUL-O7-Page 1
Rule 203 and
Rule 204
Under and Over billing time frame - A vista supports the proposed revisions to Rule
203.04 and the proposed addition of Rule 203.01b. Regarding Rule 203., Avista
believes that, in circumstances where the customer was under-billed should be consistent
with the circumstance where the customer was over-billed, and retain the 3 year time
frame.
Rule 300 and
Rule 600
llows notices to be sent electronically if the customer has opted for electronic billing
and consents to electronic notification - Avista supports the addition of 300.04 that
allows a "written notice" be provided by electronic mail if the customer is billed
electronically and consents to electronic notification.
Rule 302 and
Rule 310
Prohibits denial or termination of service for bills four or more years old - A vista
supports this revision as it is consistent with the Company s current processes.
Rule 311
Prohibit Disconnections on Fridays or any day preceding a legal holiday - A vista
disagrees with the proposed revisions to Rule 311. The rules currently allow utilities to
terminate service on Friday until noon; this allows Avista to utilize its labor resources
efficiently. Also, the Company believes that customers have access to agency assistance
on Fridays, just as they would on any other day. Customers also have payment options
AVISTA CORPORATION COMMENTS IN RUL-O7-Page 2
available 24 hours a day, 7 days a week, including direct checking, debit and credit card
by phone and internet. A vista has many pay stations available throughout its service
territory. If 311.01a. were to become effective, Avista would support the changes to
311.01b., that provide extending the times when service may be terminated from 4 p.
to 5 p.m. This additional time will allow the Company to balance its workload.
Respectfully submitted this 23rd day of October 2007.
A VISTA CORPORATION
~,..~
KELLY NORWOOD
Vice President, State and Federal Regulation
A VISTA CORPORATION COMMENTS IN RUL-O7-Page 3