20160622Staff 36-42 to AVU.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES F'OR ELECTRIC
SERVICE IN IDAHO.
ftECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. AVU.E-16.03
SECOND 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, JULY 13, 2016.
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 and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
SECOND PRODUCTION
REQUEST TO AVISTA JUNE 22,2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUBST NO. 36: Pages 4 and 5 of Ms. Knox's direct testimony describe the 10 year
regression analysis used normalize consumption for weather effects. Please provide the predictor
(CDD and HDD) and consumption data used in the Company's regression analysis.
REQUEST NO.37: Please provide the Company's rationale for including autoregressive
terms in its weather normalization models?
REQUEST NO. 38: The Company's weather normalization models assume there to be
linear relationships between Cooling Degree Days, Heating Degree Days, and Consumption. Did
the Company consider incorporating higher order curvature terms in its model? If so, why were
they not included?
REQUEST NO.39: The Company used data from 2005 through2}l4 to create its weather
normalization model. Please explain why data from the year 2015 was not included in the
Company's regression analysis.
REQUEST NO. 40: The Company's weather normalization adjustments were obtained by
applying coefficients obtained from the Company's 2005 -2014 regression analysis to 2015
Heating and Cooling Degree Days. Did the Company consider using the consumption estimate
obtained directly from its model? If so, why was this estimate not used?
REQUEST NO. 41: In its 2015 rate case (AVU-E-15-05), the Company based its Cost of
Service allocators on a Load Research Study performed by DNV-GL (dated January 22,2015). For
the present case (AVU-E-16-03), were the Cost of Service allocators based on the same study? If
not, please provide the information used as a basis for the allocators used in the present case.
SECOND PRODUCTION
REQUEST TO AVISTA JI.INE 22,2016
REQUEST NO. 42: On page 14 of Ms. Knox's testimony, the Company proposes changing
the method it uses to classify and allocate production costs from its traditional replacement-cost-
based peak credit methodology to a load factor methodology. The Company made a similar
proposal in its 2015 rate case (AVU-E-l5-05). Are there any differences between the Company's
present proposal and its 2015 proposal? If so, please explain.
DATED at Boise,Idaho, tnis lL*day of June 2016.
Technical Staff: Mike Morrison (36-42)
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SECOND PRODUCTION
REQUEST TO AVISTA JUNE 22,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22Nd DAY OF JUNE 2016,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-16-03,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
KELLY NORWOOD
VP _ STATE & FED REG
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail : [e-mail]
PETER J zuCHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE TD 83702
E-mail: [e-mail]
DEAN J MILLER
3620E WARM SPRINGS
BOISE ID 837I6
E-mail : deanj [e-mail]
DAVID J MEYER
VP & CHIEF COLINSEL
AVISTA CORPORATION
PO BOX3727
SP0KANE W499220-3727
E-mail : [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES INSTITUTE
5549 S CLIFFSEDGE AVENUE
BOISE ID 83716
E-mail: [e-mail]
CERTIFICATE OF SERVICE