20170215Staff 35-40 to AVU.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. IOI77
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR A FINDING OF
PRUDENCE FOR 2OI 4-2015 EXPENDITURES
ASSOCIATED WITH PROVIDING ELECTRIC
ENERGY EFFICIENCY SERVICE IN THE
STATE OF'IDAHO.
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. A\rt -E-16-06
FOURTH 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, MARCH 8, 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 IDAPA
31.01.01.228.
FOURTH PRODUCTION
REQUEST TO AVISTA FEBRUARY I5,2OI7
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.35: On January 25,2017 the Company filed an amended 2014Idaho
Annual Demand Side Management Report correcting Table 3-12. The Company did not identify
what was changed or explain why the original report was incorrect. It appears only the data in the
incentives column has changed and none of the data in the rest of the table has changed. Please
explain all of the changes made to Table 3-12 as well as why other data within the table remained
unchanged.
REQUEST NO. 36: Please provide the data used to produce Table 3-12 in Excel format
with all functions intact.
REQUEST NO.37: Please provide the name and job description of the Conservation
Education Specialist funded by the Conservation Education Outreach Grant provided to the
Community Action Partnership. Does this person only provide services to Avista customers in
Idaho? Please explain.
REQUEST NO.38: Does Avista provide a similar Conservation Education Outreach Grant
to fund salaries and/or expenditures for Washington customers? If so, please provide an itemization
and explanation of all Washington expenditures for 2014 and20l5.
REQUEST NO. 39: In years 2014 and20l5, a total of $30,046 was spent on "Supplies" as
part of the Conservation Education Outreach Grant; $13,656 in20l4 and 16,390 in 2015. Please
provide an itemized list of all expenditures directly assigned as "Supplies" for both2014 ar:rd2015.
REQUEST NO. 40: Please provide examples of all printed materials purchased as part of
the Conservation Education Outreach Grant in20l4 and 2015.
FOURTH PRODUCTION
REQUEST TO AVISTA 2 FEBRUARY I5,2OI7
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DATED at Boise, Idaho, this 15 day of Febrtrlry 2017.
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Camille Christen
Deputy Attorney General
Technical Staff: Johnathan Farley (35-40)
i:umisc:prodreq/avue I 6.6ccdesdkkjf prod req4
FOURTH PRODUCTION
REQUEST TO AVISTA 3 FEBRUARY I5,2OI7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15th DAY OF FEBRUARY 2017,
SERVED THE FOREGOING FOURTH 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 BOX3727
SPOKANE W A 99220-3727
E-MAIL: linda. [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: [e-mail]
DAVID J MEYER
VP & CHIEF COIINSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE