20170815Staff 84-98 to AVU.pdf

11,/l DBRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
li li5 PIl l:29
Street Address for Express Mail:
472 W. 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 AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES FOR ELECTRIC
AND NATURAL GAS SERVICE IN IDAHO SIXTH 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, by
TUESDAY, SEPTEMBER 5, 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, 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.
SIXTH PRODUCTION REQUEST
TO AVISTA
)
)
)
)
)
)
)
)
CASE NO. AVU.E-17.01
AVU-G-I7-01
AUGUST 15,2OI71
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. 84: In the Response to Audit Request No. 21, Attachment B, there are
two misstatements that were not corrected at period end that were passed on. Please provide the
details and workpapers supporting the external auditors' recommendations for Adjustments D
and E.
REQUEST NO. 85: Please provide a schedule showing all flights of the Company plane
in2016. Please provide the flight logs including locations and passenger lists. Please include
the costs specific to each flight (fuel, landing fees, etc.). For each flight, please include the
reason for the travel.
REQUEST NO. 86: Please provide a copy of all current union contracts.
REQUEST NO. 87: Please provide the line item entries supporting the Total Electric
Download and Gas North Download as shown in witness Andrew's Workpapers titled "(ID)
FLB Forecast Labor Non-Executive". P1ease include a summary of those entries by service
factor, and further subdivided by time, incentive pay, on-call pay, etc.
REQUEST NO. 88: Please provide a narrative of the commuter reduction programs
used by the Company to limit the parking pressure. Also, please include the costs and results of
those programs, and if the Company plans on continuing those programs after the new parking
structure is built.
REQUEST NO. 89: Please provide the supporting documentation for the level of capital
expense and O&M expense in2017, and2018-2019 forecasted for the PM&E's associated with
the Clark Fork settlement and the Spokane fuver Relicensing implementation.
SIXTH PRODUCTION REQUEST
TO AVISTA 2 AUGUST I5,2OI7
REQUEST NO. 90: Please provide William G. Johnson workpapers reflecting
AURORA runs that exclude Palouse Wind generation ("Workpaper Index" excel file and
"Johnson WP" pdf file).
REQUEST NO. 91: Please provide anltemization for all Idaho expenditures for the
Conservation Education Grant in20l4, and 2015 in Excel format. Please include an itemization
of all purchases attributable to each individual expense category: i.e. Salaries & Wages, Benefits,
Travel, Space Costs, Supplies, Admin, etc.
REQUEST NO. 92: On page I l, lines 25-27, of his testimony, Company witness
Christie states that in 2016, the Company hosted one energy fair and held 28 events in Idaho via
the Mobile Outreach Van. Please provide the location of each of the mobile outreach events in
Idaho. Please explain how the Company determined the number of participants at each event.
Did the person responsible for Conservation Education at CAP participate in these events? If so,
in what capacity did he/she serve?
REQUEST NO. 93: In Company witness Rosentrater's testimony,page 55, lines 29-31,
she states that the Company is required by Commission rules and tariffs to annually test a portion
of customer meters for accuracy. Please cite the particular rule(s) and tariff provision(s) to
which Ms. Rosentrater is referring. Please provide any reports prepared regarding the annual
meter tests conducted for the years 2014,2015, and20l6.
REQUEST NO. 94: What standards and./or specifications does the Company have for
determining proper meter placement? How does the Company determine whether an existing
meter should be relocated? What standards and/or specifications does the Company have for
determining whether additional measures are necessary to protect meters from snow/ice
accumulation and falling snow/ice? Please provide copies of employee procedure manuals,
publications, pamphlets, brochures, website information, or other materials the Company utilizes
to inform its employees, customers, the building and construction industry, and the general
public about proper meter placement and adequate meter protection.
SIXTH PRODUCTION REQUEST
TO AVISTA J AUGUST 75,2077
RBQUEST NO. 95: As a part of the Stipulation and Settlement approved by the
Commission in Case No. AVU-E-I5-05, the Company provided to interested parties comparative
usage data for low income and non-low income customers. The data provided covered the
period from March 2015 through February 2016. Please provide a similar analysis for March
2016 through February 2017.
REQUEST NO. 96: Company witness Morris addresses the Company's Service Quality
Performance, Customer Guarantees, and 2016 Service Quality Measure Report Card. It appears
that the Company has adopted these performance standards, service guarantees and reporting
mechanism only in Washington. Has the Company developed standards and guarantees to track
and report its performance in Idaho? If not, is Avista willing to implement a similar program in
Idaho?
REQUEST NO. 97: Please provide Idaho data corresponding to the benchmarks and
performance measurements shown in Company witness Morris' Exhibit No. l, Schedule 2, pg
40?
REQUEST NO. 98: Please explain why installation of AMI meters in Idaho has been
postponed until2020?
Dated at Boise, Idaho, this (2 day of August 2017.
Technical Staff: Joe Terry/84-88
Donn English/89
Yao Yin/90
Johnathan Farley/9 I -95
Daniel KleirV96-98
i:umisc:prodreq/avue I 7. l_avugl 7. I bkjtdelyjfdk prod req6
SIXTH PRODUCTION REQUEST
TO AVISTA 4 AUGUST I5,2OI7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF AUGUST 2017,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-I7-01/AVU-G-17-01, BY E-MAILING ANDMAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
avistadockets@avistacorp. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
gre q@richardsonadam s. com
ELECTRONIC ONLY
CLEARWATER PAPER CORP.
carol. hau gen@clearwaterpaper. com
[e-mail]
j ohn j acobs@clearwaterpaper. com
david. wren@clearwaterpaper. com
nathan. smith@clearwaterpaoer. com
RONALD L WILLIAMS
WILLIAMS BRADBURY
PO BOX 388
BOISE ID 83701
E-MAIL: [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES INSTITUTE
5549 S CLIFFSEDGE AVENUE
BOISE ID 83716
E-MAIL: [e-mail]
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]
BRAD M PURDY
ATTORNEY AT LAW
20I9 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy@,hotmail.com
ELECTRONIC ONLY
DEAN J MILLER
3620 E WARM SPRINGS
BOISE ID 837I6
E-MAIL: [e-mail]
EMILY MATTHEWS
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
KELLY O NORWOOD
VP STATE & FED REG
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: [e-mail]
MATTHEW A. NYKIEL
ID CONSERVATION LEAGUE
PO BOX 2308
I02 S EUCLID #207
SANDPOINT ID 83864
E-MAIL: mn),[e-mail]
TRAVIS RITCHIE
SIERRA CLUB
2101 WEBSTER ST., SUITE I3OO
OAKLAND, CA 94612
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE