20090313Staff 47-62 to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 8~702-5983
Attorneys for the Commission Staff
RECE'tJ n\ - ,,' 'C¡' ",:.,.,.'
2009 MAR I 3 PH 2= 00
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF A VISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO.
)
) CASE NO. AVU-E-09-1
) A VU-G-09- 1
)
) THIRD PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO A VISTA CORPORATION
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, requests that Avista Corporation (Company; Avista)
provide the following documents and information on or before FRIDAY, APRIL 3, 2009.
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
THIRD PRODUCTION REQUEST
TO AVISTA 1 MARCH 13, 2009
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil 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 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
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 47: Please provide actual load weather normalized by month and
schedule from January 2004 to present for the total Company and the Idaho jurisdiction.
REQUEST NO. 48: Please provide a calculation of the average production and
transmission cost (TLK-R-2 workpaper) showing the production and transmission components
separately.
REQUEST NO. 49: Please provide an analysis of the effects on revenue of the
production property adjustment by month from the time rates including the adjustment were put
in place on October 1, 2008, to the present time. Include the power supply effects, the
production property effects and the retail revenue adjustment effects. Also include any other
related revenue impacts, effects or explanation that would help one understand the results of the
Company's analysis.
REQUEST NO. 50: Please provide the amount of the Production Tax Credit included in
Base Rates staring with the implementation of rates in Case No. AVU-E-04-1 to the present
time. Show the actual amount of the credit for each month over the same time period.
THIRD PRODUCTION REQUEST
TO AVISTA 2 MARCH 13,2009
REQUEST NO. 51: Please provide a PCA backcast of calendar year 2008 showing
what the deferral balance differences would have been if that year had included the PCA changes
the Company is proposing in this case. The changes should include; 1) Sharing at 95/5, 2) Third
Pary Transmission Revenue and Expense, 3) New Retail Revenue Credit Calculation, and 4) the
Production Tax Credit.
REQUEST NO. 52: Please show the proposed PCA calculation template that includes
the four changes identified in question No. 51 and the changes required to incorporate Lancaster
into the PCA as proposed by the Company. Show the amounts of the Lancaster fixed monthly
costs.
REQUEST NO. 53: Please provide, by rate schedule and test year month, actual and
weather normalized energy usage. Please indicate the customer classes that were not weather
normalized.
REQUEST NO. 54: Please provide normal heating degree days (HDD) and ~ooling
degree days (CDD), by month, using a twenty-five year moving average.
REQUEST NO. 55: Please provide the analysis discussed on pages 15 through 16 of
Mr. Hirschkorn's testimony pertaining to consumption comparisons between all-electric
customers receiving LIHEAP assistance and those that do not.
REQUEST NO. 56: Please provide a comparison of total energy (gas and electric) and
overall bil amount, by test year month, for Idaho residential all-electric and dual customers.
Please provide this for both the overall average customer and the average customer receiving
LIHEAP assistance.
REQUEST NO. 57: It appears as though Avista has lost two Schedule 25 customers
since the last rate case. Is this correct, or have they moved to other schedules? What is the
energy and demand impact of loss or shift of these customers?
THIRD PRODUCTION REQUEST
TO AVISTA 3 MARCH 13,2009
REQUEST NO. 58: What is the basis for the load forecast for the pro forma period?
How does it relate to the test year loads? Has the Company updated its load forecast, and if so,
please provide it; and if not, does the Company intend to as par of this proceeding?
REQUEST NO. 59: If a customer receives both electric and gas service, do they receive
two separate bils, or one combined bil? Has the Company identified any economic efficiencies
in meter reading and bil preparation, or other cost savings, resulting from a dual customer? If
so, please identify.
REQUEST NO. 60: Please provide the number of customers, by month for the test year,
in Schedules 11, 21, and 25 whose usage fell exclusively in the first rate block, and the
corresponding average usage. How many of those customers, by schedule, never entered the
second rate block over the entire test year?
REQUEST NO. 61: Please provide Transmission and Distribution Loss Studies or any
relevant studies the Company uses to determine the energy losses in the system.
REQUEST NO. 62: If the Company does not have relevant studies, what methodology
and assumptions does the Company use to gross up sales to the generation level? Please provide
any workpapers in response.
Dated at Boise, Idaho, this /3 ffay of March.
~~.úæid2~~ 0 Clbury
Deputy Attorney General
Technical Staff: Keith Hessing/47-52
Bryan Lanspery/53-60
TJ Go10/61 - 62
i:umisc:prodreq/avue-.09. lswkhbltjg prod req3.doc
THIRD PRODUCTION REQUEST
TO AVISTA 4 MARCH 13,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF MARCH 2009,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA, IN CASE NOS. AVU-E-09-01 & AVU-G-09-01, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220
E-MAIL: david.meyer(iavistacorp.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(imcdevitt-miler.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(igivenspursley.com
mcc(igi venspursley.com
BETSY BRIDGE
ID CONSERVATION LEAGUE
710 N SIXTH STREET
PO BOX 844
BOISE ID 83701
E-MAIL: bbridge(iwildidaho.org
KELL Y NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwood(iavistacorp.com
SCOTT ATKINSON
PRESIDENT
IDAHO FOREST GROUP LLC
171 HIGHWAY 95 N
GRANGEVILLE ID 83530
E-MAIL: scotta(iidahoforestgroup.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
SUITE 250
1500 LIBERTY STREET SE
SALEM OR 97302
E-MAIL: dpeseau(iexcite.com
.kod
SECRETARY
CERTIFICATE OF SERVICE