20160711Staff 69-91 to AVU.pdf

BRANDON KARPEN IiI:CEIVED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION :iii."i-]IL I , PI{ 2: IOPO BOX 83720
BOISE, IDAHO 93720-0074 i , ;,i.i,l(208)334-0357 ' i'ri"'ti'i1r:519P
IDAHO BAR NO. 7956
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVISTA CORPORATION DBA AVTSTA ) CASE NO. AVU-E-16-03
UTILITIES FOR AUTHORITY TO INCREASE )
ITS RATES AND CHARGES FOR ELECTRIC ) TOURTH PRODUCTION
SERVICE IN IDAHO.) REQUEST OF THE) coMMrssroN STAFF To
) AVISTA CORPORATTON
)
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
MONDAY, AUGUST 1,2016.
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.
FOURTH PRODUCTION
REQUEST TO AVISTA JULY 1I,2016
REQUEST NO. 69: Please provide a copy of the Palouse Purchase Power Agreement
(PPA).
REQUEST NO. 70: Please provide actual monthly Palouse Wind kilowatt-hour (kWh)
generation for On-Peak and Off-Peak periods (that coincide with Mid-Columbia On-Peak and Off-
Peak market rates periods) for the period 2015 to date. Please provide work papers in Excel format
with formulae intact.
REQUEST NO. 71: Please provide expected Palouse Wind kWh generation for On-Peak
and Off-Peak periods (that coincide with Mid-Columbia (Mid-C) On-Peak and Off-Peak market
rates periods) for the 201 7 pro forma forecast year. Please provide work papers in Excel format
with formulae intact.
REQUEST NO. 72: Please provide actual monthly average On-Peak and Off-Peak Mid-C
market sale prices of electricity ($/kwh) for the period 201 5 to date. Please provide work papers in
Excel format with formulae intact.
REQUEST NO. 73: Please provide the expected monthly average On-Peak and Off-Peak
Mid-C market sale prices of electricity ($lkwh) for the 2017 pro forma forecast year. Please
provide work papers in Excel format with formulae intact.
REQUEST NO. 74: Please provide the actual number of Renewable Energy Credits (REC)
generated from Palouse Wind on a monthly basis for the period 2015 to date broken down by state
jurisdiction and fuither broken down by disposition (retired to meet RPS, sold, transferred, or
carried over). Also, please provide the number of REC's held or banked at the beginning and at the
end of each year for each jurisdiction for the period 2015 to date. For each REC sold, please
provide the date of sale, the price received, and the state jurisdiction that received the proceeds from
the sale. Please provide work papers in Excel format with formulae intact.
FOURTH PRODUCTION
REQUEST TO AVISTA JULY TI,2016
REQUEST NO. 75: Please provide average monthly REC market prices for the period
2015 to date indicating the source of the information. Please provide work papers in Excel format
with formulae intact.
REQUEST NO. 76: Please provide the monthly number of REC's generated by Palouse
Wind included in Net Power Cost for the pro forma 2017 forecast year. Please include the REC
prices used and the allocation of monthly values for each state jurisdiction. Please provide work
papers in Excel format with formulae intact.
REQUEST NO. 77: Based on Johnson's Direct Testimony (at 8), please provide the
justification and basis used for the calculation of the $1.18 million of Idaho REC sales for Idaho
customers in this rate case. Please provide work papers in Excel format with formulae intact.
REQUEST NO. 78: Based on Johnson's Direct Testimony (at 8-9), please quantify the
amount attributable to Palouse Wind from the $17.58 million in REC sales for Idaho customers.
REQUEST NO. 79: Please explain the2lYo increase in the 349,554 MWh of forecasted
Pro Forma Palouse Wind to actual 288,227 MWh of 2014 generation illustrated in the 2015 Idaho
PCA. See Case No. AVE'E-I5-07, Exhibit 1 to Ehrbar Direct Testimony at 2.
REQUEST NO. 80: Based on Exhibit 6 of Johnson's Direct Testimony, please explain the
discrepancy between the 2017 Pro Forma value of $3,504,000 (shown as 3,504) Non-WA EIA REC
Sales on line 65 of Schedule 1, Page 2, and the $3,423,000 shown on Schedule 4, page 1.
REQUEST NO. 8l: Please provide a breakdown of the number and type of dwellings
weatherized using Avista funds for Program Years 2012-2015. (Ex. Single Family, Mobile,
Multifamily)
REQUEST NO. 82:
energy savings for individual
program.
FOURTH PRODUCTION
REQUEST TO AVISTA
Please provide any reference material that Avista uses to estimate the
measures installed in a participant's home under the weatherization
JULY II,2016
REQUEST NO. 83: What documentation does Avista receive from Community Action
Partnership in order to determine which specific measures are paid for with utility funds under the
weatherization program? Please explain.
REQUEST NO. 84: Please provide or make available the EA5 audit reports, Job Order
Sheets and invoice for each Idaho unit completed during the 2013, 2014 and 2015 program years.
REQUEST NO. 85: Please provide any quality assurance or inspection documentation
Avista collects or receives regarding the installation of weatherization measures for each Idaho
home completed during the2014 or 2015 program year.
REQUEST NO. 86: Please describe the steps Avista takes to ensure all measures installed
at homes under the weatherization program are installed properly and performing as designed?
REQUEST NO. 87: How many workshops/events were held in Idaho by CAP using the
Conservation Education Grant funding in Program Years 2013,2014 and2015? How was
attendance determined? Please provide a brief description of each workshop/event.
REQUEST NO. 88: Please describe the steps Avista takes to ensure participants are
receiving accurate and meaningful information as part of the Conservation Education portion of the
weatherization program?
REQUEST NO. 89: Please describe and quantify the Non-Incentive Utility Costs with
respect to the Low Income Weatherization Program?
REQUEST NO. 90: Please describe how the Company incurs non-incentive utility costs on
a per measure basis for the Low Income Weatherization Program?
FOURTH PRODUCTION
REQUEST TO AVISTA JULY II,2016
REQUEST NO. 9l
CONTAINS CONFIDE,NTIAL
INFORMATION SUBJECT
TO PROTECTIVE
AGREE,MENT.
FOURTH PRODUCTION
REQUEST TO AVISTA JULY II,2016
DATED at Boise, Idaho, this f%dayof July 2016.
Technical Staff: Rick Keller (69-80)
Johnathan Farley (8 1 -90)
Yao Yin (91)
i:umisc:prodreq/avue I 6.3bkdkmlmmrkyybejbmrdekls prod req4
FOURTH PRODUCTION
REQUEST TO AVISTA 6 JULY tt,2016
CERTIFICATE OF SERVTCE
I HEREBY CERTIFY THAT I HAVE THIS I lth DAY OF JULY 2016, SERVED
THE FOREGOING FOURTH 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 BO){ 3727
SPoKANE WA99220-3727
E-mail: [e-mail]
avi stadockets@avistacorp. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE TD 83702
E-mail: [e-mail]
DEAN J MILLER
3620 E, WARM SPRINGS
BOISE ID 837I6
E-mail : dearli [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
223 N 6TH ST STE 317
BOISE ID 83702
E-mail: [e-mail]
MARV LEWALLEN
CLEARWATER PAPER CORP
E-MAIL ONLY:
marv. lewallen@clearwaterpaper. com
carol.hau gen@clearwaterpaper. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
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]
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-mail: [e-mail]
CERTIFICATE OF SERVICE