20150729Staff 74-93 to AVU.pdf

KARL T.KLEIN
BRANDON KARPEN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PU BOX $3720
BOISE,IDAHO 83720-0074
[phone]/334-0357
IDAHO BAR NOS.5 156/7956
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-5918
Attorneys for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES FOR ELECTRIC
AND NATURAL GAS SERVICE IN IDAHO.
)
CASE NO.AVU-E-15-05
AVU-G-15-O1
)THIRD PRODUCTION
)REQUEST OF THE
)COMMISSION STAFF TO
)AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company)provide the following documents and information as soon as possible,and no later
than WEDNESDAY,AUGUST 19,2015.
This Production Request is continuing,and the Company 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
THIRD PRODUCTION REQUEST
TO AVISTA
)
)
)
1 JULY 29,2015
and if different the witness who can sponsor the answer at hearing if need be.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.74:Pages 4 and 5 of Ms.Knox’direct testimony describe the 10-year
regression used to normalize weather data.Please provide monthly Idaho electrical usage by rate
schedule for the years 2004 through 2013.
REQUEST NO.75:Pages 5 and 6 of Mr.Miller’s direct testimony describe the 10-year
regression used to normalize weather data.Please provide monthly Idaho natural gas usage by
rate schedule for the years 2004 through 2013.
REQUEST NO.76:Table 11 of the Electric Load Research Study presented in Ms.
Knox’workpapers is a sample design.According to the accompanying text (page 14),this
sampling plan is based on the ratio model.Please answer the following:
a.Were samples (within each strata)selected randomly?If so,why was a Model Based
Statistical Sampling (MBS$)methodology used instead of a design-based
methodology?
b.Were MBSS results compared to results of a design-based analysis?If so,how did
system load factor estimates and class load factor,coincident peak,and non-
coincident peak estimates compare?
REQUEST NO.77:Equation 2 on page 21 of the Electric Load Research Study
presented in Ms.Knox’workpapers is an expression for standard deviation as a power function
of a variable,x.Please answer the following:
a.for each class and strata,what values of GO and y were used?
b.Was this standard deviation estimate used only for planning,or was it also used as part
of the analysis?If used in the analysis,please explain how it was used.
c.Would it have been possible to estimate standard deviation from actual data (e.g.the
previous load study)?If so,why was this estimate of standard deviation not used?
d.Please provide summary statistics (sample size,mean,and sample standard deviation)
for the data used to estimate system load factor and class load factor,coincident peak,
and non-coincident peak for each of classes listed in Table 11 (page 14).
THIRD PRODUCTION REQUEST
TOAVISTA 2 JULY 29,2015
REQUEST NO.78:Please provide a source for Equation 3 on page 21 (error ratio)of
the Electric Load Research Study presented in Ms.Knox’workpapers.
a.Why was this equation used,instead of the following?
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b.What is the justification for a summation on standard deviation,rather than variance?
REQUEST NO.79:Pages 17 through 20 of the Electric Load Research Study presented
in Ms.Knox’workpapers describe a method for editing the data.The editing method included
processes for eliminating suspected outliers and for recreating missing data.Please answer the
following:
a.How were the spike elimination and data recreation methods validated?
b.How sensitive are the estimates of load factors,coincident peaks,and non-coincident
peaks to DNV-GL’s data editing methods?
c.Would use of unedited data in DNV-GL’s model have resulted in a significant (>1%)
difference in estimated load factors,coincident peaks,and non-coincident peaks?
REQUEST NO.80:On pages 12 through 15 of Ms.Knox’testimony,the Company
proposes changing the method it uses to classify and allocate production costs from its traditional
replacement-cost-based peak credit methodology (traditional methodology)to a methodology
based on system-wide load factor (load factor methodology).Under the traditional methodology,
the costs of fuel,load dispatch,and water for power generation are classified as energy related
costs.Under the load factor methodology,these costs would be allocated to both energy and
demand using the Company’s system wide load factor.Please answer the following:
a.Why does the Company believe it to be preferable to classify fuel,load dispatch,and
water costs to both energy and demand under its proposed load factor methodology?
b.Did the Company consider continuing its practice of classifying these as energy
related costs under the load factor methodology?If so,how did this affect the total
cost allocation for each customer class?
REQUEST NO.81:Under the Company’s traditional methodology,the costs of peaking
units are classified entirely as demand related,and the costs of hydro and thermal base
THIRD PRODUCTION REQUEST
TO AVISTA 3 JULY 29,2015
generating units are classified as both energy and demand related.Under the load factor
methodology,all production plant costs would be allocated to energy and demand using the
Company’s system-wide load factor.Please answer the following questions:
a.Why does the Company believe it to be preferable to classify peaking unit costs to
both energy and demand under its proposed load factor methodology?
b.Did the Company consider continuing its practice of classifying peaking unit costs to
demand under the load factor methodology?If so,how would this affect the costs
allocated to each customer class?
REQUEST NO.$2:Page 102 of Schedule 3,Exhibit 11 to Ms.Schuh’s testimony
states:“Please also see Company witness Labolle for further details regarding this program.”
Please provide the Labolle details regarding Aldyl A Replacement referenced in Exhibit No.11.
REQUEST NO.$3:Please describe why there are 12 IND and 1$ROT meters on
Schedule 101.See Idaho Gas COS Excel spreadsheet (tab titled “Meters Average equip type”).
REQUEST NO.84:Please describe how many times service has been curtailed,in the
last two years,for interruptible customers by schedule.If service has not been curtailed,or is
minimal,please describe how the discounted rate for these customers is justified and the methods
used to determine their rates.
REQUEST NO.$5:Please quantify the benefits large customers receive from the
capacity that smaller (less than four inches)main and distribution lines provide.
REQUEST NO.86:Please describe how IT/IS (Systems)costs are managed between
the Company and its unregulated affiliates.
REQUEST NO.87:Page 7 of Mr.Kensok’s testimony states:“Over the past several
years,Avista has focused on reducing customer transaction costs through the prudent
deployment of technology.”Please provide a three-year view of customer transaction cost
changes (reductions,increases)as a result of technology deployment.
THIRD PRODUCTION REQUEST
TO AVISTA 4 JULY 29,2015
REQUEST NO.88:Page 9 of Mr.Kensok’s testimony states:“There will be a net
increase of $663,188 over current operating expenses associated with the deployment of the
Company’s new Customer Service and Work and Asset Management Systems implemented as
part of Project Compass.The total for new operating expenses required to support these new
Systems is $3,020,858;however,there is a corresponding offset in the amount of $2,357,670,
which reflects the annual expense reduction in contract services and mainframe computer costs
associated with the retirement of the Company’s Legacy Customer Service and Work
Management Systems.”Please provide information on additional and future offsets,if any,
including when they will occur and the amount of the offset.
REQUEST NO.89:Page 11 of Mr.Kensok’s testimony states:“With automated
outbound event processing and preference management for customers,Notifi pushes information
to Avista customers,over the channel they want to receive it,including mobile text,email,social
media and voice natively on iPhone and Android smart phone devices.”Please describe what
percentage of the customer base is expected to adopt the Notifi system capability.Of the
expected adoption rate,have all customer profiles been updated to include a Notifi preference?
If not,why not?Also,please describe how the Company will manage customer communications
for customers that do not utilize the Notifi system.
REQUEST NO.90:Page 19 of Mr.Kensok’s testimony states:“Each project has
formal project management and adheres to our Project Management Office (PMO)process.”
Please provide a current copy of PMO process documentation to include manuals,policies,
procedures,and any additional applicable worksheets or instructions.
REQUEST NO.91:Page 21 of Mr.Kensok’s testimony states:“AFM COTS Migration
—2015:$0;2016:$0;2017:$15,608,000.The project replaces the Company’s obsolete,custom
Facilities Management system (Project Atlas)with a commercial,off-the-shelf application.”
Please describe the reasoning,benefits,and risks associated with the AFM COTS Migration
project being deferred until 2017.
THIRD PRODUCTION REQUEST
TO AVISTA 5 JULY 29,2015
REQUEST NO.92:Page 64 of Mr.Kensok’s testimony states:“Through this process,
the efficiency and performance of the new applications is improved,and important technical
knowledge is transferred from the application developers to those who will have responsibility
for the long-term maintenance of the systems.”Please describe the process used to identify and
manage defects,a current list of known or anticipated defects,and the status of any defects.
REQUEST NO.93:Page 65 of Mr.Kensok’s testimony states:“In addition to changes
for employees,customers were required to make changes to their accounts,to become familiar
with a new bill format,and experience some process changes from those with which they were
familiar.”Please specifically describe all the account and process changes customers were
required to make relating to implementation of new systems.
Dated at Boise,Idaho,this Z’day of July 2015.
4f
Karl T.Klein
Deputy Attorney General
Technical Staff:Mike Morrisonl74-81
Kevin Keyt/$2-93
i:umisc:prodreq/avue15 .5_avugi 5.1 kkbkmmksk prod req3
THIRD PRODUCTION REQUEST
TO AVISTA 6 JULY 29,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY
SERVED THE FOREGOING
COMMISSION STAFF TO
AVU-E-1 5-05/AVU-G-15-01,
TO THE FOLLOWING:
KELLY NORWOOD
VP -STATE &FED REG
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3 727
E-mail:[e-mail]
DAVID J MEYER
VP &CHIEF COUNSEL
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3 727
E-mail:david.meyer(iiavistacorp.com
DEAN J MILLER
McDEVITT &MILLER LLP
P0 BOX 2564
BOISE ID $3702
E-mail:I [e-mail]
CLEARWATER PAPER CORP
C/O PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID $3702
LARRY A CR0WLEY
THE ENERGY STRATEGIES
INSTITUTE INC
5549 $CLIFF$EDGE AVE
BOISE ID $3716
E-mail:[e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID $3703
E-mail:dreading(mindspring.com
E-mail:[e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-mail:[e-mail]
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-mail:[e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID $3702
E-mail:[e-mail]
Jo
SECRETARy -
THAT I HAVE THIS 29TH DAY OF JULY 2015,
THIRD PRODUCTION REQUEST OF THE
AVISTA CORPORATION,IN CASE NOS.
BY MAILING A COPY THEREOF,POSTAGE PREPAID,
CERTIFICATE OF SERVICE