20161222Staff 30-35 to AVU.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-0314
IDAHO BAR NO. 10177
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
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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 A TE OF IDAHO. )
) ___________________ )
CASE NO. AVU-E-16-06
THIRD 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
THURSDAY, JANUARY 12, 2017.
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 and 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 ID APA
31.01.01.228.
THIRD PRODUCTION
REQUEST TO A VISTA DECEMBER 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.
REQUEST NO. 30: Please explain why Avista missed its 2015 electric IRP savings target
and the steps taken to ensure that IRP targets will be met in the future.
REQUEST NO. 31: Please provide the electric avoided costs workpapers, including values
and sources for all assumptions.
REQUEST NO. 32: Please provide copies of all interviews conducted as part of the
evaluations, referenced on Page 9 of Lynn Roy's testimony, including but not limited to the 82
contractor interviews, 27 lighting retailer interviews, implementation contractor interviews, and
A vista program staff interviews.
REQUEST NO. 33: Please explain the timeline of events and the circumstances of events
that led to the inadvertent elimination and reinstatement of 0-Power reports.
REQUEST NO. 34: Please provide the amount of labor expense charged to the DSM tariff
rider for the years 2010-2015. For each of those years, please include the number of Full Time
Equivalents funded by the rider. Please also provide the general wage adjustment percentage for
non-union personnel approved by the Compensation Committee of the Board of Directors for each
year.
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DATED at Boise, Idaho, this 21,,, day of December 2016.
Technical Staff: Stacey Donohue (30-33)
Donn English (34)
i:umisc:prodreq/avue l 6.6ccdesdkkjf prod req3
THIRD PRODUCTION
REQUEST TO AVISTA
Camille Christen
Deputy Attorney General
2 DECEMBER 22, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22nct DAY OF DECEMBER 2016,
SERVED THE FOREGOING THIRD 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: linda. [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE