20170802Staff 1-7 to AVU.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-00]4
[phone]
IDAHO BAR NO. 8370
IN THE MATTER OF THE FIXED COST
ADJUSTMENT MECHANISM (FCA) ANNUAL
RATE ADJUSTMENT FILING OF AVISTA
COROPORATION FOR ELECTRIC SERVICE
FROM OCTOBER 1,2017 THROUGH
SEPTEMBER 30,2018.
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU.B,-I7.04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Avista Corporation (Company) provide
the following documents and information as soon as possible, or by WEDNESDAY, AUGUST
16,2017.r
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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at (208) 334-03 I 8.
FIRST PRODUCTION REQUEST
TO AVISTA I AUGUST 2,2017
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.
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. 1: Please provide supporting documentation for the average number of
customers used in the FCA calculations, including workpapers in Excel with formulas intact.
Please explain the calculation methodology.
REQUEST NO. 2: Please provide supporting documentation for the kWh sold used in
the FCA calculations, including workpapers in Excel with formulas intact.
REQUEST NO.3: Please provide the number of new customers by month for 2016 and
for January through May 2017.
REQUEST NO. 4: On page 7, lines 13-15 of the Application, Avista states that the
"FCA revenue shortfall associated with weather was approximately $2.4 million residential and
$0.3 million non-residential." Please provide support for these calculations including Excel
workbooks with formulas intact.
REQUEST NO. 5: On page 8, lines 4-6 of the Application, Avista states that the
"estimated FCA revenue shortfall associated with energy efficiency programmatic savings is
$1.5 million residential and $1.3 million non-residential." Please provide support for these
calculations including Excel workbooks with formulas intact. Please provide the kWh
reductions upon which the above dollar savings are based. Also, please reconcile these results to
the Company's pending20l6 DSM report and any previous DSM reports that apply.
REQUEST NO. 6: Please provide the Company's annual 2016 DSM energy efficiency
savings (in kwh) for the Residential rate group and the Non-Residential Rate schedules
(Commercial Schedules I 1, 12, 21, 22, 3 l, and 32).
FIRST PRODUCTION REQUEST
TO AVISTA 2 AUGUST 2,2017
REQUEST NO. 7: Please provide the actual monthly energy usage from January l,
2016 through May 31,2016 for the Residential rate group and the Non-Residential rate
schedules (Commercial Schedules 1 1, 12, 21, 22, 31, and 32).
Dated at Boise, Idaho, thi, Ld day of August 2017.
uang
Deputy Attomey
Technical Staff: Bentley Erdwurm (l-7)
i:umisc:prodreq/avuel 7.4djhbe prod reql
FIRST PRODUCTION REQUEST
TO AVISTA 3 AUGUST 2,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF AUGUST 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU.E-I]-j4,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
SR MGR RATES & TARIFFS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3721
E-mail: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
ARY
CERTIFICATE OF SERVICE