20181219Staff 11-22 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t4
IDAHO BAR NO. 10446
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Dln l9 PI{ l: htr
Street Address for Express Mail
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSIOI{
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION F'OR A
DETERMINATION OF 2016.2017 ELECTRIC
ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. AVU-E-18-12
SECOND 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,
JANUARY 9,2019.
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
3t.01.0t.228.
SECOND PRODUCTION REQUEST
TO AVISTA
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1 DECEMBER 19,2018
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. 11: Please provide electronic work papers showing the derivation of all
figures presented in Exhibit 2,Table ES-3.
REQUEST NO. 12: Exhibit l, Section 5.5 indicates that the Company's fuel efficiency
program realization rate was 62%o. What steps are the Company taking to improve the accuracy
of the methodology used to estimate this program's savings?
REQUEST NO. 13: What is the increase in the number of Therms of natural gas
consumed by customers who participated in the Company's fuel efficiency program (Converted
their HVAC and other appliances to Natural Gas)? What is the average net savings, in dollars, of
customers who participated in this program?
REQUEST NO. 14: Exhibit 1, Section 5.7 indicates that the Company's Shell program
realization rate was 27Yo. What steps are the Company taking to improve the accuracy of the
methodology used to estimate this program's savings?
REQUEST NO. 15: Exhibit 1, Equation 3-2 includes the variables "event" and the
interaction term, "treat X event." Neither of these is described in Table 3-5. Please provide a
description for these variables. Also, please explain why the variable "treat" is not included in
the model.
REQUEST NO. 16: Regarding Exhibit 1, Equation 5-2: What steps were taken to
guard against multicollin earity?
REQUEST NO. 17: Regarding Exhibit 1, Equation 5-2: What was the reason for
incorporating the double sum, f,|], E!1=, I r,,, pr, in the model?
SECOND PRODUCTION REQUEST
TO AVISTA 2 DECEMBER 19,2018
REQUEST NO. 18: Regarding Exhibit 1, Equation 5-2: Please define the index
variables t, y, and n.
REQUEST NO. 19: Regarding Exhibit 1, Equation 5-2: How are the effects of weather
incorporated into the model for kWhity?
REQUEST NO.20: Exhibit 1, Table 5-21 explains that Fo is a coefficient on the billing
month t, post-period year indicator variable that is left-out due to collinearity. Please explain
how this differs from the intercept that would normally be included in a lagged dependent
variable (LDV) model.
REQUEST NO. 21: Regarding the analysis of the Company's Home Energy Reports
Program (Section 5.8). Did either the Company or Nexant perform a simple, two-sample
comparison of kWh consumed by each group? If so, please provide the results of the analysis
with workpapers.
REQUEST NO. 22: Please provide the technical manual(s) used to estimate DSM
energy efficiency savings for 2016 and2017.
l4t-Dated at Boise, Idaho, this day of December 2018
Edward J
Deputy Attorney General
i:umisc:prodreq/avuel 8. l2ejmm prod req2
SECOND PRODUCTION REQUEST
TO AVISTA
(
aJ DECEMBER 19,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF DECEMBER 2018,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OFF THE
COMMISSION STAFF TO AVISTA CORPORATION, TN CASE NO, AVU-E-18-12,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPoKANE W A 99220-3727
E-MAIL: lir:rda. servaisG)avistacorp.corn
avi st acl o c ket s ri, avi st ac olp. co rn
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL : david.nreyer(#,tavi stacor:p.con,
CERTIFICATE OF SERVICE