20141014Staff 1-9 to AVU.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITTES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
BAR NO. 6618
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702.5983
Attorneys for the Commission Staff
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
REQUEST TO USE AVAILABLE FUNDS
FROM SCHEDULE 95 TO PROMOTE
ROOFTOP SOLAR INSTALLATIONS ON
COMMERCIAL BUILDINGS.
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)) CASE NO. AVU-E-14-10
)) FIRST PRODUCTION
) REQUEST OF THE) coMMrssroN STAFF
) TO AVTSTA CORPORATTON
)
)
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Kristine A. Sasser, Deputy Attorney General, requests that Avista Corporation (Company;
Avista) provide the following documents and information on or before TUESDAY,
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. 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
FIRST PRODUCTION REQUEST
TO AVISTA ocToBER 14,2014
and, if different, the witness who can sponsor the answer at hearing. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please explain the reasons for the differences in the estimated
equipment costs of Washington State and Out-of-State equipment listed in Table No. I of the
Application.
REQUEST NO.2: Please provide an explanation of the grant selection process. Include
project eligibility criteria and requirements. How will the program administration be funded?
REQUEST NO. 3: Please explain how projects will be funded. For example, will
applicants be required to secure a portion of total funding from matching sources? Please
explain.
REQUEST NO. 4: What, if any, alternative uses for excess funds were considered? In
particular, did Avista consider increasing the size of blocks that customers purchase under the
existing Buck-A-Block program?
REQUEST NO. 5: Please provide any cost/benefit analysis performed justiffing the use
of surplus Schedule 95 funds on rooftop solar projects. Did Avista perform any analysis
comparing its rooftop solar proposal to other types of renewal energy resources? Is so, please
provide that analysis.
REQUEST NO. 6: How will the details of this change be communicated to existing
Buck-A-Block customers?
REQUEST NO. 7: Does Avista track Schedule 95 contributions by jurisdiction? If so,
how much of the $200,000 surplus is attributable to Idaho jurisdiction customers?
FIRST PRODUCTION REQUEST
TO AVISTA ocToBER t4,2014
REQUEST NO.8: Please provide forecasted estimates of the surplus balance through
2016 if Avista were not to use additional funds on its rooftop solar proposal.
REQUEST NO. 9: Because Avista's fixed costs are recovered primarily through the
commodity rate and not through a demand charge or the monthly service charge, has Avista
performed any studies or analysis illustrating how much of a subsidy will be paid by other
customers to cover the fixed costs associated with the rooftop solar projects?
Dated at Boise,Idaho, tnis lfiaay of Octob er2014.
Technical Staff: Mike Monison (1-4, 6)
Donn English (5,7-9)
i:umisc:prodreq/avuel4.l0ksdemmsd prod reql.doc
FIRST PRODUCTION REQUEST
TO AVISTA
Deputy Attorney General
ocToBER 14,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l4th DAY OF OCTOBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-14-10,
BY E.MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPoKANE W A 99220-3727
E-MAIL: [e-mail]
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL : linda. [e-mail]
CERTIFICATE OF SERVICE