20141104Staff 1-10 to AVU.pdf

NEIL PRICE F''t'ic'E1''li: i:
DEPUTY ATTORNEY GENERAL
IDAHo puBLIC uTILITIES coMMISSIoN ?01', l{0v -r'{ [H l0: 2h
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ISB NO. 6864
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PI]BLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )oF AVISTA CORPORATION SEEKING A ) CASE NO. AVU-E-14-07
DETERMINATION BY THE COMMISSION) AVU.G.14.O2
THAT THE COMPANY'S ELECTRIC AND )
NATURAL GAS ENERGY EFFICIENCY ) TTRsT PR6DUCTI9N REQUEST
EXPENDITURES WERE PRUDENTLY ) OT THE COMMISSION STAFF TOINCURRED. ) AVTSIA CORpORATION
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Avista Corporation (Company; Avista)
provide the following documents and information as soon as possible, but no later than
TUESDAY, NOVEMBER 18, 2ot4.r
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 IDAPA 31.01.01.228.
I Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA 1 NOVEMBER 4,2014
This Production Request is to be considered as continuing, and Avista 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, and the name, job title and telephone number of
the person preparing the documents. Please identifu the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a list in Excel format showing all expenses charged
to the DSM Rider in 2013. Please include a brief description of the expense, the date, vendor,
amount, and the account to which the charges were booked. Please include and identify any
adjustments made in2013 to previously booked expenses. Please separate all expenses by
program. If any amounts are allocated to multiple programs or jurisdictions, please describe the
allocation method. Please identify if each expense is an incentive payment, purchased service,
labor/admin., materials, or any other classification of expense.
REQUEST NO.2: Please provide copies of the Con-Ed CAP reports provided through
Avista during 2013.
REQUEST NO. 3: Please explain why there were no refrigerators replaced for Idaho's
Low Income program during 2013.
REQUEST NO. 4: Please explain why replacement of operating, but perhaps very
inefficient, refrigerators through Avista's Low Income program requires advance approval from
the Company.
REQUEST NO. 5: Please provide examples of the Top Sheets used in the revised
process for non-residential site-specif,rc proj ects,
FIRST PRODUCTION REQUEST
TO AVISTA NOVEMBER 4,201,4
REQUEST NO. 6: Please explain why the Standard Operating Procedures for the non-
residential site specific process do not include the "internal review of a subset of completed site-
specific" projects, particularly when this type of review is intended to inform the Company's
"continuous process improvement activities." Chris Drake Testimony, p. 17 .
REQUEST NO. 7: Please provide copies of the "2009 Avista Internal Audit Department
Review of DSM Processes," the "July 2013 Avista Internal Audit Department Memo," the
"April 2014 Internal Audit Memo," and any other internal audits relating to DSM activities.
REQUEST NO. 8: Please provide all reports, conclusions, recommendations, and 'next
steps' that resulted from the Roles and Responsibilities process conducted by Milepost
Consulting. If any recommendations or'next steps' were not implemented, please explain why.
REQUEST NO. 9: Please provide an electronic copy of Avista's Technical Reference
Manual (TRM). If an electronic copy cannot be provided, please provide the information
necessary to access the TRM.
REQUEST NO. 10: For any prescriptive programs not using Regional Technical Forum
(RTF) deemed energy savings, please explain how Avista's program delivery, customer base,
service territory, or other factors are different from the data sources or methods used in the
RTF's analysis. As part of the response, please explain how these differences justiff the
Company using savings other than those deemed by the RTF.
DATED at Boise, Idaho, thist)F96urof Novemb er2Ol4.
Technical Staff: Stacey Donohue
i:umisc:prodreq/avue I 4.7_avugl 4.2npsd prod req I
FIRST PRODUCTION REQUEST
TO AVISTA
r-,r!,ai/Neil Price
Deputy Attorney General
NOVEMBER 4, 2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF NOVEMBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
coMMrssroN STAFF To AVISTA CORPORATION, IN CASE NOS. AYU-E-14-071
AVU-G-14.02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail : linda. [e-mail]
CERTIFICATE OF SERVICE