20150826Staff 94-136 to AVU.pdf

KARL T. KLEIN
BRANDON KARPEN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-0320 t334-03s7
IDAHO BAR NOS, 515617956
Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVTSTA CORPORATTON DBA AVISTA ) CASE NO. AVU-E-15-05
urrl,rrrEs FoR AUTHORTTY TO TNCREASE ) AVU-G-15-01
ITS RATES AND CHARGES FORELECTRIC )
AND NATURAL GAS SERVICE IN IDAHO. ) FOURTH 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, SEPTEMBER 16o 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
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 26,2015
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3r.01.0r.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. 94: Please provide copies of the original Bonus Plan and any updated
Bonus Plans associated with the Project Compass installation and completion.
REQUEST NO. 95: Please provide the amount of bonuses paid under the Project
Compass Bonus Plan and describe the accounting treatment for the bonuses.
REQUEST NO. 96: Please provide a listing of all external consultants fees paid for the
installation and testing of Project Compass. Please include amounts, dates, vendor, voucher
number, and a brief description of the services rendered.
REQUEST NO. 97: Please provide copies of the engagement letters or contracts for all
extemal consultants used for the Project Compass installation and testing.
REQUEST NO. 98: Please provide the calculation of the Net Prepaid Pension
Asset/Accrued Post-Retirement Liability included in the working capital adjustment.
REQUEST NO. 99: Please provide the most recent updates to the Company's Net
Periodic Pension Expense.
REQUEST NO. 100: Please provide the Company's performance objectives for
handling incoming calls.
REQUEST NO. 101: What steps does the Company take if it fails to meet its
performance obj ectives?
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 26,2015
REQUEST NO. 102: Please provide the number of incoming calls handled by the
customer service call center by month for each of the past three years (2013 ,2014 and YTD
20ts).
REQUEST NO. 103: Please provide the number of abandoned calls to the customer
service call center by month for each of the past three years (201 3,2014 and YTD 201 5).
"Abandoned calls" are calls that reach the Company's incoming telephone system, but the
calling party terminates the call before speaking with a customer service representative.
REQUEST NO. 104: Please provide the average speed of answer for the customer
service call center by month for each of the past three years (2013,2014 and YTD 2015).
"Average speed of answer" is the interval (typically measured in seconds) between when a call
reaches the Company's incoming telephone system and when the call is picked up by a customer
service representative.
REQUEST NO. 105: Please provide the service level for the customer service call
center by month for each of the past three years (201 3,2014 and YTD 2015). "Service level" is
the percentage of calls answered within a certain number of seconds, e.g.,80o/o of calls answered
within 20 seconds.
REQUEST NO. 106: Please provide the average number of busy signals reached by
parties calling the customer service call center by month for each of the past three years (2013,
2014 and YTD 2015).
REQUEST NO. 107: Please provide the average response time for e-mail transactions
by month for 2013, 2014 and YTD 2015. "Average response time" is the average number of
hours from receipt of an e-mail by the Company to sending a substantive response; auto-response
acknowledgements do not count as a substantive response.
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 26,2015
REQUEST NO. 107: Please provide the average handling time by month for each of the
last three years (2013,2014 and YTD 2015). "Average handling time" is the average amount of
time (usually expressed in minutes) it takes for a customer service representative to talk with a
customer plus any additional "off-line" time it takes to complete the transaction or fully resolve
the customer's issue(s).
REQUEST NO. 109: Please provide the first call resolution rate by month for each of
the last three years (2013,2014 and YTD 2015). "First call resolution rate" is the percentage of
calls where the transaction, inquiry or complaint is resolved upon initial contact with the
Company.
REQUEST NO. ll0: The Project Compass mobile web application allows customers
access to the Company website using their smart phones and/or tablet. Does the Company know
how many customers have taken advantage of the mobile web applications? Does the Company
plan to have dedicated phone and tablet applications in the future?
REQUEST NO. 111: In20l4, please provide the number of payment transactions in
each of the following categories:
a. payment by phone via credit/debit cards;
b. payment by phone via checking/savings account withdrawal;
c. payment online via checking/savings account withdrawal (customer enrolled through
"My Account";
d. payment online via credit/debit;
e. automatic withdrawal from the customer's financial institution;
f. payment at authorized pay stations;
g. payment by mail; and
h. other payment methods, if any
REQUEST NO. 112: The Company's vendor, Kubra, charges a significantly higher
transaction fee ($3.50) than other vendors used by other energy utilities serving Idaho customers.
Does the Company have a contractual agreement with Kubra to provide this payment service to
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 26,2015
its customers? If so, what time period does that contract cover? Has the Company considered
negotiating lower transaction fees or using other lower cost vendors? Please explain.
REQUEST NO. 113: Please provide the energy savings generated by the Company's
investments in local demand-side management (DSM) programs and, the Northwest Energy
Efficiency Alliance by rate schedule and customer class for each year between 2010 and20l4.
REQUEST NO. 114: The Fixed Cost Adjustment (FCA) proposal has been justified in
Idaho to remove the utility's financial disincentive for energy efficiency. P1ease provide the
justification for the natural gas FCA proposal given the Company's natural gas DSM programs
have been suspended since 2012.
REQUEST NO. 115: Please explain in detail the problems with Project Compass
implementation that led to the six-month intemrption of Home Energy Reports.
REQUEST NO. 116: Page 57 of Pat Ehrbar's direct testimony states that "customers
can expect to see rebates as well as surcharges over time with the FCA." Please provide the
Company's analysis supporting this statement.
REQUEST NO. 117: Please provide the Company's 20-year annual forecast for electric
and gas use-per-customer. Please exclude the effects of the Company's locally run DSM
programs from this forecast.
REQUEST NO. l18: Please provide the Company's 2O-year annual forecast for electric
and natural gas customer counts.
REQUEST NO. 119: Please provide an analysis showing the annual deferral balance of
the Company's FCA proposal if it had been in effect since 2007.
REQUEST NO. 120: The Company's FCA proposal assumes it incurs and therefore
should recover the full embedded fixed costs for each new customer. Please provide evidence to
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 26,2015
support the position that each new customer causes the Company to incur additional expenses
(e.g. generation and transmission). Furthermore, please explain how additional fixed costs
recovered through the FCA will be verified between rate cases.
REQUEST NO. 121: Table No. 9 on page 49 of Pat Ehrbar's testimony shows the bill
impacts for low, medium, and high usage electric residential customers. Please provide a similar
comparison showing the bill impacts to electric LIHEAP recipients and all other residential
customers. Please provide the comparison given the usage levels shown on Table No. 9, but
with the following:
a. a single energy rate;
b. a first rate block from 0 kWhs to 700;
c. a first rate block from 0 kWhs to 800; and
d. a first rate block from 0 kWhs to 900.
REQUEST NO. 122: Table Nos. 9 and l0 on pages 49-50 of Pat Ehrbar's direct
testimony show the bill impacts for low, medium, and high usage electric and gas residential
customers. Please provide the number of customers in each usage bracket and indicate how
many of the customers in each usage bracket received Low Income Home Energy Assistance
(LIHEAP) grants.
REQUEST NO. 123: Table 13 on page 54 of Pat Ehrbar's direct testimony presents the
results of the Idaho Residential Usage Analysis for 2014, but excluded accounts that were only
open for a partial year. Please provide this analysis without excluding accounts that were only
open for a partial year. In addition, please indicate the number of customers in each group
(electric only- LIHEAP, electric only- all other, dual fuel- LIHEAP, and dual fuel- all other) with
low, medium, and high usage.
REQUEST NO. 124: Please provide an updated version of the original file
Staff_DR_143_Attachment_B from June 8th in Washington Docket No. UE-150204. Please
update this Excel workbook with all actual system transfers to plant, by expenditure request and
month for the period January 2015 through December 2015. Where monthly data are not yet
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 26,2015
available, please provide the projected transfers to plant and indicate the transfers are
projections.
REQUEST NO. 125: Page 4 of Exhibit 15, Schedule 7, provides the inputs and
calculations to determine the Company's Fixed Cost Adjustment Revenue per-Customer, please
provide the Fixed Cost Adjustment Revenue per-Customer if production and transmission were
excluded from the calculation.
REQUEST NO. 126: Exhibit No. 11, Schedule I of Karen Schuh's testimony is a
graphical summary of capital expenditures from 2005 through2019. Please explain each cost
category and provide the data used to develop this graph. Please include the FERC accounts
when providing this information.
REQUEST NO. 127: In general, one concem with FCA mechanisms has been the
layering effect of unverified fixed costs between rate cases. Because FCA mechanisms provide
additional revenue beyond the rate case approved total revenue requirement, did the Company
consider altemative FCA approaches or reporting requirements to resolve this concern (i.e.,
Unbundling Reports)? If not, explain why not.
REQUEST NO. 128: Page 58, lines 9-12 of Pat Ehrbar's testimony states: "May 2,
2015 Avista filed a general rate case in the State of Oregon (Docket No. 10 UG-288), and
requested a similar adjustment mechanism as well." Please describe whether there are
differences between the proposal in Idaho and the proposed mechanism in Oregon.
REQUEST NO. 129: Avista's Project Compass Revised Timeline and Budget forecasts
Idaho's costs for the revised Project Compass implementation plan as $17 .927 million. See
Exhibit No. 10, Schedule 2, pp. ll-12. Please provide a detailed description of actual Idaho
costs associated with the revised Project Compass implementation plan.
REQUEST NO. 130: Please provide the Project Compass bonus plan (Idaho specific)
details, including payout amounts and dates paid.
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 26,2015
REQUEST NO. 131: Please describe why a period of 24 months was selected for
Project Compass Deferral and Amortization. See Workpapers EG-COM-I, G-COM, and E-
COM. Additionally, provide examples of EG-COM-I, G-COM, and E-COM at both 60 and72
month amortizations.
REQUEST NO. 132: The Company plans to spend $10M on Rathdrum Prairie HP
(High Pressure) gas reinforcement upgrades. See Morehouse's exhibit schedule 1, pgs. 134 and
135. Please describe alternatives the Company explored to eliminate or defer the need for
upgrades such as this. If no alternatives have been examined, please explain why not? As part
of the response, explain whether the Company has encouraged intemrptible load or considered
utilizing DSM to defer or avoid capacity upgrades. Please provide the financial impacts of
alternatives the Company considered. Additionally, please describe whether the value of
deferred distribution will be addressed in the Company's Business Plan due later this year.
REQUEST NO. 133: In the Company's Washington rate case, Docket No. UG-l50205,
Joseph D. Miller's testimony at pages 12 and l4 proposes changes to the way distribution main
is allocated. Please explain why the methodology proposed in the Washington case was not
proposed and modeled in the current Idaho rate case. Please complete and provide the results of
an Idaho gas Cost-of-Service study using the distribution main allocation methodology proposed
in the Washington rate case. Please include examples of the following tables and exhibits using
the Washington rate case distribution main allocation methodology: Miller Exhibit 14, Schedule
2; Ehbar (direct testimony) Tables 6,7,8, and 10.
REQUEST NO. 134: The Company's response to Production Request No. 87 included
the following statement: o'One of the ways we seek to deliver value to our customers is through
the prudent deployment of technology." Please describe how the Company defines and measures
whether the deployment of technology is prudent. Please provide supporting analysis.
REQUEST NO. 135: The Company's response to Production Request No. 89 included
the following statement: "While it is difficult to predict how many customers will enroll in the
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 26,2015
Notifi service, other utilities surveyed have indicated ranges of 18% to 30%;o in the first year
alone." Please provide a cost benefit analysis for Notifi. What does it cost to serve a customer
that participates in Notifi? What does it cost to serve a customer that does not participate in
Notifi?
REQUEST NO. 136: The Company's response to Production Request No. 9l included
the following statementr "A benefit of moving a project out in time is that it frees up resources to
complete other projects that may have a greater priority or more rigid implementation
constraints." Please explain what resources and costs would be required to complete the AFM
COTS migration in 2016. Please provide a cost benefit analysis of deferring the project until
2017.
Dated at Boise,Idaho, this L 1rh aaVof August 2015.
Technical Staff: Donn English/94-99
Daniel Kleir/100-112
Stacey Donohue/l 13-123
Mark Rogers/\24
Matt Elam/125-128
Kevin Keytll29-136
i:umisc:prodreq/avuel5.S_avugl 5. lkkbkdedksdmrmeksk prod req4
FOURTH PRODUCTION REQUEST
TO AVISTA
u4b
Karl T. Klein
Deputy Attorney General
AUGUST 26,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF AUGUST 2015,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-I5-05/AVU-G-I5.OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
KELLY NORWOOD DAVID J MEYER
VP _ STATE & FED REG VP & CHIEF COLTNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA99220-3727 SPOKANE WA99220-3727
E-mail: [e-mail] E-mail: [e-mail]
DEAN J MILLER LARRY A CROWLEY
McDEVITT & MILLER LLP THE ENERGY STRATEGIES
PO BOX 2564 INSTITUTE INC
BOISE ID 83702 5549 S CLIFFSEDGE AVE
E-mail: [e-mail] BOISE ID 83716
E-mail : [e-mail]
CLEARWATER PAPER CORP DR DON READING
C/O PETER J RICHARDSON 6070 HILL ROAD
RICHARDSON ADAMS PLLC BOISE ID 83703
515 N 27rH STREET E-mail: [e-mail]
BOISE TD 83702
E-mail : [e-mail]
BRAD M PURDY SNAKE RIVER ALLIANCE
ATTORNEY AT LAW BOX 1731
2OI9 N ITTH STREET BOISE ID 8370I
BOISE ID 83702 E-mail: [e-mail]
E-mail: [e-mail] [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
. ./l rl,//, L-. / ni4 ut_
SECRETARY
CERTIFICATE OF SERVICE