20150909AVU to Staff 133.docx

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATIONJURISDICTION:IDAHODATE PREPARED:09/02/2015CASE NO.:AVU-E-15-05/AVU-G-15-01WITNESS:Joseph Miller/Patrick EhrbarREQUESTER:IPUCRESPONDER:Joe MillerTYPE:Production RequestDEPARTMENT:State & Federal RegulationREQUEST NO.:Staff-133TELEPHONE:[phone]REQUEST:
In the Company’s Washington rate case, Docket No. UG-150205, Joseph D. Miller’s testimony at pages 12 and 14 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; Ehrbar (direct testimony) Tables 6, 7, 8, and 10.RESPONSE:
Please see the attachment labeled “Staff_PR_133 Attachment A” for the results of the cost of service study using the Washington rate case distribution main allocation methodology as requested above.
The Washington distribution main allocation methodology would result in a significant shift in costs to the five Idaho Schedule 146 customers. The Company chose not to propose this main allocation methodology at this time. The Company did not believe that it was appropriate to shift a significant amount of costs to such a small rate schedule.
For purposes of replicating the Ehrbar Tables 6, 7, 8, and 10, the Company applied a rate spread consistent with its direct filed case, which results in the rates of return for the various service schedules moving one-third closer to the overall rate of return (unity). Page 34, beginning on line 14, of the Ehrbar testimony incorrectly stated that “The spread of the proposed increase generally results in the rates of return for the various service schedules moving approximately one-quarter closer to the overall rate of return (unity). The word one-quarter should have stated one-third.
Please see the attachments labeled “Staff_PR_133 Attachment B” and Staff_PR_133 Attachment C” for the Ehrbar Tables 6, 7, 8, and 10.