20161025Staff 6-29 to AVU.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10177
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
RE CEIVED
2016 OCT 25 PM 2: 12
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVISTA CORPORATION FOR A FINDING OF )
PRUDENCE FOR 2014-2015 EXPENDITURES )
ASSOCIATED WITH PROVIDING ELECTRIC )
ENERGY EFFICIENCY SERVICE IN THE )
ST ATE OF IDAHO. )
) ___________________ )
CASE NO. AVU-E-16-06
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that A vista Corporation
(Company) provide the following documents and information as soon as possible, and no later than
TUESDAY, NOVEMBER 15, 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 IDAP A
31.01.01.228.
SECOND PRODUCTION
REQUEST TO AVISTA OCTOBER 25, 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.
REQUEST NO. 6: Please provide the tariff rider revenue by year and by class for 2014-
2015.
REQUEST NO. 7: Please provide the calculation of any carrying charge on the Rider
balance during 2014 and 2015.
REQUEST NO. 8: Please provide all work papers to support the cost-effectiveness of each
measure offered and incented.
REQUEST NO. 9: Referring to the Site Specific program, Page 5 of the Nexant Impact
Evaluation states that "Within the last two years, A vista has increased their level of quality
assurance and review on projects through the program" resulting in a realization rate of 99%.
Please describe in detail the improvements the Company has made to their level of QA and review.
REQUEST NO. 10: Please provide a listing of all site specific projects completed in 2014
and 2015. Please include in your response the reported savings, the verified savings, the realization
rate, the amount of the incentive paid, and a brief description of the project.
REQUEST NO. 11: Please describe how Common Costs are allocated among the services
and jurisdictions.
REQUEST NO. 12: Page 5 of the Nexant Impact Evaluation ofldaho Programs for 2014-
2015 states that, in reference to Nonresidential Programs, "cases of ineligible VFD projects
receiving incentives were the cause of the low realization rate for these programs." Please describe
how the ineligible VFD projects received incentive payments. Please provide a list of all ineligible
VFD projects that received an incentive payment.
SECOND PRODUCTION
REQUEST TO AVISTA 2 OCTOBER 25, 2016
REQUEST NO. 13: Please provide all bids, contracts, and engagement letters for
evaluation services for the 2012-13 biennium and the 2014-2015 biennium.
REQUEST NO. 14: Please provide a copy of the Company's 2015 contract with
Community Action Partnership (CAP) regarding the Low Income Weatherization Program.
REQUEST NO. 15: Does the Company disburse funds to CAP for the Low Income
Weatherization Program as an annual lump sum, advance payment, or reimbursement upon receipt
of invoices?
REQUEST NO. 16: At what frequency does CAP report measures installed and associated
expenses to the Company? What documentation of expenses does CAP provide to the Company?
Please provide all CAP documents received by the Company pertaining to expenses incurred in
2014 and 2015.
REQUEST NO. 17: Does the Company review project expenses on a per project basis? If
not, please explain how the Company reviews CAP project expenses.
REQUEST NO. 18: How does the Company monitor CAP Health and Safety expenditures
to ensure they do not exceed 15% of the overall program allocation? Please explain why 26% of
the program funds were allocated to Health and Safety in 2014.
REQUEST NO. 19: What criteria does the Company use to determine whether measures
installed under the Low Income Weatherization Program are for Health and Safety? Are measures
approved by A vista prior to installation? Are measures reviewed for appropriateness after
installation?
REQUEST NO. 20: How many homes did the Company visit to confirm installation of
measures installed as part of the Low Income Weatherization Program in 2014 and 2015?
SECOND PRODUCTION
REQUEST TO AVISTA 3 OCTOBER 25, 2016
REQUEST NO. 21: Please provide a detailed explanation of how the Company determines
whether expenses for the Low Income Weatherization Program are prudent?
REQUEST NO. 22: What steps has the Company taken to ensure that the most cost
effective measures are installed in a participant home under the Low Income Weatherization
Program?
REQUEST NO. 23: Please provide invoices for all projects completed as part of the Low
Income Weatherization Program in 2014 and 2015 .
REQUEST NO. 24: Does the Company track low income weatherization expenses on a per
project basis? If not, why?
REQUEST NO. 25: Please provide an itemization and explanation of all Idaho
expenditures for the Conservation Education Outreach Grant in 2014 and 2015.
REQUEST NO. 26: In 2014, 253 participants took part in the low income program
weatherization program, 177 participants received energy usage letters and the remaining 76 did
not. Please explain why all participants did not receive energy usage letters? Please provide a
sample copy of an energy usage letter.
REQUEST NO. 27: In 2014, only 4 participants received one-on-one education from the
Community Action Partnership as part of the ConEd Grant. How were these participants chosen?
Why were so few participants involved in one-on-one education? Please provide a detailed
explanation of the process and materials used in educating participants.
REQUEST NO. 28: What changes have been made to Avista low income programs to
better serve participants in rented housing units?
REQUEST NO. 29: Please provide the most recent billing analysis performed by the
Company or its contractor/evaluator for customers participating in Low Income Programs.
SECOND PRODUCTION
REQUEST TO AVISTA 4 OCTOBER 25, 2016
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DA TED at Boise, Idaho, this 2 S day of October 2016.
Technical Staff: Donn English (6-13)
Johnathan Farley (14-29)
i:umisc:prodreq/avue I 6.6ccdesdkkj f prod req2
SECOND PRODUCTION
REQUEST TO AVISTA
Camille Christen
Deputy Attorney General
5 OCTOBER 25, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF OCTOBER 2016,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-16-06,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERVAIS
SENIOR MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail: [e-mail]
CERTIFICATE OF SERVICE