20180801Staff 1-3 to Avista.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
IMPLEMENT FIXED COST ADJUSTMENT
RATES FOR ELECTRIC SERVICE FROM
ocToBER 1,2018 THROUGH
SEPTEMBER 30, 2019.
RECEIVED
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83]02-5918
Attorney for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU.E-18.06
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,
Sean Costello, Deputy Attorney General, request that Avista Corporation (Company) provide the
following documents and information as soon as possible, or by WEDNESDAY,
AUGUST 22,2018.
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
31.0t.0t.228.
FIRST PRODUCTION REQUEST
TO AVISTA 1 AUGUST 1,20I8
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 the number of new customers per month for January
2018 through May 2018.
REQUEST NO. 2: On page 8, lines 13-16 of the Application, Avista lists the impacts of
three drivers (weather, energy efficiency and other) on use-per-customer and FCA Revenue for
the residential and non-residential group. Please provide supporting documentation for these
calculations including Excel workbooks with formulas intact.
REQUEST NO.3: On page 8 of its Application, the Company estimates that the
Company's DSM programs reduced residential usage by 28 million kWh/year over the years
2015,2016, and20l7, and non-residential usage by approximately 45 million kWh over the
same time period.
a. Please reconcile these results to the Company's 2015,2016, and2017 DSM
reports and any other reports that apply. Please provide supporting
documentation for these calculations including Excel workbooks with formulas
intact.
b. Please provide the Company's estimate of the total weather-normalized change in
consumption over the same time period for the same customer groups.
Dated at Boise, Idaho, this /i day of August 2018
Deputy Attorney General
Technical Staff: Bentley Erdwurm (l-3a)
Mike Morrison (3b)
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FIRST PRODUCTION REQUEST
TO AVISTA 2 AUGUST I,2OI8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I't DAY OFAUGUST2Ol8,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAF'F TO AVISTA CORPORATION, IN CASE NO. AVU-E-I8-06,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIRECTOR REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BO){ 3727
SPOKANE W A 99220-3727
E-mail: david.meyer@,avistacorp.com
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CERTIFICATE OF SERVICE