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Home My WebLink About20160701Staff 43-68 to AVU.pdfBRANDON KARPEN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-03s7 IDAHO BAR NO. 7956 Street Address for Express Mail: 472 W, WASHINGTON BOISE, IDAHO 83702-5918 Attorney for the Commission Staff IN THE MATTER OF THE APPLICATION OF AVISTA CORPORATION DBA AVISTA UTILITIES FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC SERVICE IN IDAHO. [:iICEIVED ::15 ":iJL - I Pij 2: 3l BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. AVU-E-I6.03 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 FRIDAY, JULY 22,2016. 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 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. 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. THIRD PRODUCTION REQUEST TO AVISTA JULY I,2016 REQUEST NO. 43: Please provide the incremental costs associated with the 2015 wind storm by FERC account number. REQUEST NO. 44: Please provide records of any insurance settlements received associated with the 2015 wind storm. If no insurance settlements were received, please explain why not. REQUEST NO. 45: Has the Company applied for any grants or other funding/relief for the 201 5 wind storm? If no such funding was requested, please explain why not. REQUEST NO. 46: Has the Company filed an application to have Greensferry Road site (for a potential natural gas-fired combustion turbine) rezoned to industrial designation? If so, please provide an update on the rezoning status. If not, please explain why. REQUEST NO.47: Table No. 1 in Heather Rosentrater's testimony lists several distribution-related capital projects with system-wide costs. Please explain how these costs are allocated to the Idaho jurisdiction by account. Please also provide a five year history (201 1-2015) by account of these system costs illustrating how each was allocated to the Idaho and Washington jurisdictions. REQUEST NO. 48: Please provide a complete copy of the Avista 2014 Vehicle Replacement Summary from Utilmarc. If a more recent summary is available, please also provide the more recent summary. REQUEST NO. 49: Please provide a list of all vehicles scheduled to be replaced in 2016. Please include year, make, model, mileage or hours of operation, and any other pertinent information. For all vehicles that have already been disposed of in 2016, please provide the same information along with proceeds from sale or auction. REQUEST NO. 50: Please provide Equipment (see Table No. 5, Schuh, Di page THIRD PRODUCTION REQUEST TO AVISTA the historical amounts spent for Capital Tools & Stores 19) for the years 2010-2015. JULY I,2016 REQUEST NO. 5l: Please provide the number of incoming calls handled by the customer service call center by month from August 2015 to YTD 2016. REQUEST NO. 52: Please provide the Company's performance objectives for handling incoming calls. What steps does the Company take if it fails to meet its performance objectives for such calls? REQUEST NO. 53: Please provide the number of abandoned calls to the customer service call center by month from August 2015 to YTD 2016. "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. 54: Please provide the average speed of answer for the customer service call center by month from August 2015 to YTD 2016. "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. 55: Please provide the service level for the customer service call center by month from August 2015 to YTD 2016. "Seryice level" is the percentage of calls answered within a certain number of seconds, e.9., 80%o of calls answered within 20 seconds. REQUEST NO. 56: Please provide the average number of busy signals reached by parties calling the customer service call center by month from August 2015 to YTD 2016. REQUEST NO. 57: Please provide the average response time for e-mail transactions by month from August 2015 to YTD 2016. "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. THIRD PRODUCTION REQUEST TO AVISTA JULY I,2016 REQUEST NO. 58: Please provide the average handling time by month from August 2015 to YTD 2016. "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.59: Please provide the first call resolution rate by month from August 2015 to YTD 2016. "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.60: According to Mr. Johnson's Exhibit No.6 Schedule 3, "Coyote Springs Fuel Cost $/MWh" is $17.74, and "Lancaster Fuel Cost $/MWh" is $18.35. Please explain the reasons for the price difference. Also provide a definition of "fuel cost" and the components of cost that is included. REQUEST NO. 61: On Page 1l of Mr. Kalich's Direct Testimony that "for this filing weather normalized 2015 load is 1,051.5 average megawatts compared to actual loads of 1,046.6". Please provide a comparison of 2015 monthly weather-normalized loads as shown in "Table No. 2 - Pro Forma Loads" on Page l2 of Mr. Kalich's Direct Testimony to2017 monthly weather- normalized forecast loads. REQUEST NO. 62: Please describe and quantify the impact of using 20L7 weather- normalized forecasted loads in place of 2015 weather-normalized loads used in this filing. Please include impacts to retail rates, the overall revenue requirement, and net power costs. Please provide all AURORA files and workpapers reflecting the calculations (with formula intact) using forecasted loads. REQUEST NO. 63: Please provide Mid-C electricity forward prices for January 2017 to December 2017 contract months on settlement dates from January 7,2016, YTD 2016. THIRD PRODUCTION REQUEST TO AVISTA JULY I,2016 REQUEST NO. 64: Please provide natural gas forward prices of all hubs used in AURORA for January 2017 to December 2017 contract months on settlement dates from January l, 2016, YTD 2016. REQUEST NO. 65: Please list and describe any natural gas purchase contracts that have already been executed for delivery of natural gas to Coyote Springs 2 orLancaster during any months of the pro forma period. List of the date of the purchase, the quantity of natural gas, the scheduled delivery dates, and the prices for the purchase in $/IvIMBtu. REQUEST NO. 66: According to "Johnson Exh 6_Schedule I 3 4 - Proforma 2017" fiIe Tab Sch -1, Avista received $19,174,000 revenue from the PGE contract in 2015. ($13,861,000 PGE Capacity Sale + $5,313 Spokane Energy Capacity Payment AdjustmenF $19,174,000 revenue). How much did it cost Avista to meet the PGE contract obligations in 2015? What was the resulting net revenue of the contract and how much was Idaho's share? REQUEST NO. 67: Please describe changes made in the AURORA model run used in this filing compared to the AURORA model run used to develop rates in the AVU-E-15-05 rate case? THIRD PRODUCTION REQUEST TO AVISTA JULY I,2016 REQUEST NO.68 CONTAINS CONFIDENTIAL INFORMATION SUBJECT TO PROTECTIVE AGREEMENT. THIRD PRODUCTION REQUEST TO AVISTA JULY 1,2016 1L awofJuly 2016.DATED at Boise,ldaho, this Technical Staff: Donn English (43-50) Daniel Klein (51-59) Yao Yin (60-68) i:umisc:prodreq/avue I 6.3bkdkmlmmrkyybejbmrdckls prod req3 THIRD PRODUCTION REQUEST TO AVISTA JULY I,2016 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT T HAVE THIS I't DAY OF JULY 2016, SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF' TO AVISTA CORPORATION, IN CASE NO. AVU.E-I6-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: KELLY NORWOOD VP - STATE & FED REG AVISTA CORPORATION PO BOX 3727 SPOKANE W A99220-3727 E-mail : kelly.norwood@avistacorp.com PETER J RICHARDSON RICHARDSON ADAMS PLLC PO BOX 7218 BOISE ID 83702 E-mail: peter@richardsonadams.com DEAN J MILLER 3620 E WARM SPRINGS BOISE ID 837I6 E-mail : deanjmiller@cableone.net KEN MILLER SNAKE RIVER ALLIANCE 223 N 6TH ST STE 3I7 BOISE ID 83702 E-mail : kmiller@snakeriveralliance.org MARV LEWALLEN CLEARWATER PAPER CORP E.MAIL ONLY: marv. lewal len@ clearwaterpaper. com caro l. hau gen@cl earwaterpaper. com DAVID J MEYER VP & CHIEF COUNSEL AVISTA CORPORATION PO BOX 3727 SPoKANE WA99220-3727 E-mail: david.meyer@avistacorp.com DR DON READING 6070 HILL ROAD BOISE ID 83703 E-mail: dreading@,mindspring,com LARRY A CROWLEY THE ENERGY STRATEGIES INSTITUTE 5549 S CLIFFSEDGE AVENUE BOISE ID 837I6 E-mail: crowleyla@aol.com BRAD M PURDY ATTORNEY AT LAW 2019N 17TH ST BOISE TD 83702 E-mail : bmpurdy@hotmail.com CERTIFICATE OF SERVICE