20190513Staff 23-40 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 l4
IDAHO BAR NO. 10446
RECEIVED
ct9 HAY I 3 ?fi \r 22
ir-' f ii'j FUELIC,:i' il i:U COI,{MISSION
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIBS COMMISSION
IN THE MATTER OF'THE APPLICATION OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2016.2017 ELECTRIC
ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. AVU-E.18.12
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Avista Corporation (Company) provide
the following documents and information as soon as possible, or by MONDAY, JUNE 3,2019.
This Production Request is continuing, and the Company is requested to provide, by way
of supplementary responses, additional documents that it orany 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.01.01.228.
THIRD PRODUCTION
REQUEST TO AVISTA
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I MAY 13,2019
In addition to the written copies provided in response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 23: Please provide workpapers showing how the Target
Confidence/Precision (C/P) totals were calculated in Table 3-1: Planned Sampling and
Evaluation Rigor for WA/ID Electric Residential Programs (p.29) and Table 3-2: Planned
Sampling and Evaluation Rigor for WA/ID Electric Nonresidential Programs (p.29) of the 2016-
2017 Electric Impact Evaluation.
REQUEST NO.24: The values in Table 3-3: Achieved Sampling and Evaluation Rigor
for WA/ID Electric Residential Programs (p.30) of the 2016-2017 Electric Impact Evaluation are
not consistent with the values in the corresponding workpapers provided by the Company (Final
Evaluation Tables All Sectors_ID_0608 I 8-FINAL-forlD.xlsx, Worksheet I 6 17
ID_E_lmpact_Tables). Please explain the discrepancy and provide updated workpapers.
REQUEST NO. 25: Please provide workpapers showing how the Achieved Precision
values were calculated in Table 3-4: Achieved Sampling and Evaluation Rigor for WA/ID
Electric Nonresidential Programs (p.30) of the 2016-2017 Electric Impact Evaluation.
REQUEST NO. 26: Please provide workpapers showing how the Achieved
Confidence/Precision (C/P) values, including the total, were calculated in Table 3-3: Achieved
Sampling and Evaluation Rigor for WA/ID Electric Residential Programs (p.30), Table 3-4:
Achieved Sampling and Evaluation Rigor for WA/ID Electric Nonresidential Programs (p.30),
and Table 5-2: Residential Program Achieved Evaluation Sample (p.67) of the 2016-2017
Electric Impact Evaluation.
REQUEST NO. 27: Page 78 of the 2016-2017 Electric Impact Evaluation, reads "while
the program reported savings per participant were estimated at9,865 kWh on average, the
evaluation team ultimately estimated average impacts per customer at 6,527 kWh." This
suggests that the realization rate should be 6,527kWW9,865 kWh : 66.16%. According to Table
5-14: Fuel Efficiency Program Gross Verified Savings (p.78), the realization rate used in the
THIRD PRODUCTION
REQUEST TO AVISTA 2 MAY 13,2019
evaluation was 620 . In the workpapers provided by the Company, arealization rate of 45o/o is
used (Final Evaluation Tables All Sectors_ID_060818-FINAL-forlD.xlsx, E Realization Rates,
Table at A28:E215). Please explain the discrepancies and provide workpapers showing how the
realization rate reported in Table 5-14 was determined.
REQUEST NO.28: Table 5-2: Residential Program Achieved Evaluation Sample
(p.67) of the 2016-2017 Electric Impact Evaluation indicates that Nexant performed a document
audit of 83 Shell program participants. According to Secti on 5 .7 .3 , the evaluation team
conducted 68 document audits. Please explain the discrepancy.
REQUEST NO. 29: Please provide workpapers showing how the values were
calculated in Table ES-3: 2017 ID Electric Utility Cost Test (UCT) (Gross) (p.3) and Table ES-
4:2017 ID Natural Gas Utility Cost Test (UCT) (Gross) (p.3) of the ID 2011 DSM Annual
Conservation Report and Cost Effectiveness Analysis.
REQUEST NO. 30: Please provide workpapers showing how the values were
calculated in the 2017 DSM Annual Conservation Report and Cost Effectiveness Analysis for
the following:
a. Table 2-2:2011 ID Electric Utility Cost Test (UCT) (Gross) (p.1 1)
b. Table 2-3:2017 ID Electric Total Resource Cost (TRC) (Gross) (p.11)
c. Table 2-4:2017 ID Electric Participant Cost (PCT) (Gross) (p.12)
d. Table 2-5:2017 ID Electric Rate Impact Measure (RIM) (Gross) (p.12)
e. Table 2-6:2017 ID Natural Gas Utility Cost Test (UCT) (Gross) (p.13)
f. Table 2-7:2017 ID Natural Gas Total Resource Cost (TRC) (Gross) (p.13)
g. Table 2-8:2017 ID Natural Gas Participant Cost (PCT) (Gross) (p.14)
h. Table 2-9:2017 ID Natural Gas Rate Impact Measure (RIM) (Gross) (p.14)
i. Table 2-10:2017 ID Combined Fuel Utility Cost Test (UCT) (Gross) (p.15)
j. Table 2-ll:2017 ID Combined Fuel Total Resource Cost (TRC) (Gross) (p.15)
k. Table 2-12:2017 ID Combined Fuel Participant Cost (PCT) (Gross) (p.16)
l. Table 2-13:2017 ID Combined Fuel Rate Impact Measure (Rim) (Gross) (p.16).
THIRD PRODUCTION
REQUEST TO AVISTA MAY 13,2019aJ
REQUEST NO. 31: Please provide workpapers showing how the values were
calculated in the 2017 DSM Annual Report and Cost Effectiveness Analysis for the following:
a. Table 10-1: 20l7ID Electric Utility Cost Test (UCT) (Net) (p.63)
b. Table 10-2:2017 ID Electric Total Resource Cost (TRC) (Net) (p.63)
c. Table l0-1 (sic): 2017 lD Electric Participant Cost (PCT) Qllet) (p.6a)
d. Table 10-2 (sic): 2017ID Electric Rate Impact Measure (RIM) (Net) (p.6a)
e. Table l0-5:2017 ID Natural Gas Utility Cost Test (UCT) Qrlet) (p.65)
f. Table 10-6:2017 ID Natural Gas Total Resource Cost (TRC) (liet) (p.65)
g. Table 10-3 (sic): 2017ID Natural Gas Participant Cost (PCT) (Net) (p.66)
h. Table l0-4 (sic): 20ll ID Natural Gas Rate Impact Measure (RIM) Qllet) (p.66)
i. Table l0-9:2017 ID Combined Fuel Utility Cost Test (UCT) Qllet) (p.67)
j. Table 10-10: 2017 ID Combined Fuel Total Resource Cost (TRC) (Net) (p.67)
k. Table l0-5 (sic): 2017 ID Combined Fuel Participant Cost (PCT) Qllet) (p.68)
l. Table 10-6 (sic): 2017 ID Combined Fuel Rate Impact Measure (RIM) Qtlet)
(p.68).
REQUEST NO. 32: For this production request, please refer to the MASTER tab of the
Avista Commercial Tracking Sheet 050318-ID Electric-for ID.xlsx and cross reference the
projects with the application numbers (App No.) in the table below:
THIRD PRODUCTION
REQUEST TO AVISTA 4
App No.Account Measure Type
71917 Parkwood Business Properties PSC Lighting Interior
48495 Couer d'Alene School District 271 SS Lighting Exterior
68909 Clearwater Paper Co- Lewiston Complex SS Lighting Interior
69099 Parker Toyota SS Lighting Interior
69727 Clearwater Paper Co- Lewiston Complex SS Industrial Processes
72298 Community l't Bank SS Shell
72743 Silver Opportunity Partners SS Compressed Air
MAY 13,2019
The Company's process for reviewing potential site-specific projects is summarized on
pages 11 and 12 of the 2016-2017 Electric Impact Evaluation Report. For each project in the
table above, please provide a detailed description of this review process including:
a. Forms or reports submitted by individuals or organizations for consideration as a
site-specific project.
b. Procedures and calculations used by the Company in order to estimate the savings
of site-specific projects, including samples of the energy analyses/savings
estimates generated by Avista's engineers.
a. Does the Company typically conduct site visits and take measurements in the
course of its investigation? If so, please describe how information is gathered and
documented during the site-specific visit.
b. The criteria used by the Company to determine whether a proposed site-specific
project is viable.
c. The Technical Review Top Sheet used to ensure that project documentation is
complete.
d. A sample Energy Efficiency Evaluation Report with supporting calculations.
e. The Payment Top Sheet followed by Staff prior to incentive payment.
f. The checklist used by the Company to assure that the project has been
appropriately documented, tracked, and finalized.
REQUEST NO. 33: For each project in the table shown in Request No. 32, please
provide workpapers showing how the Simple Payback (Col H), KWH (Col I), Incentive Electric
(Col K), and Measure Cost (Col N) were calculated.
REQUEST NO. 34: Please refer to the MASTER tab of the Avista Commercial
Tracking Sheet 050318-lD Electric-for ID.xlsx and cross reference the projects with the
application numbers (App No.) in the table below.
a. Please explain the discrepancy between the KWH (Col I) computed by the
Company and the KWH (BH) computed by Nexant.
b. Please explain the steps that the Company has taken to improve its energy savings
and cost savings estimates.
THIRD PRODUCTION
REQUEST TO AVISTA 5 MAY I3,2OI9
App No.Account Measure
7t9t7 Parkwood Business Properties PSC Lighting Interior
48495 Coeur d'Alene School District 271 SS Lighting Exterior
72298 Communitv l't Bank SS Shell
REQUEST NO. 35: When reviewing potential site-specific projects, does the Company
typically conduct site visits and take measurements in the course of its review to determine if a
project is eligible? If so, please describe how the information is gathered and documented during
the site-specific visit.
REQUEST NO.36: The Company's method for reviewing potential site-specif,rc
projects is summarized on pages l1 and 12 of the Electric Impact Evaluation Report. Please
explain how the results of third party evaluations, such as those conducted by Nexant, are used
by the Company to improve this process.
REQUEST NO. 37: Regarding the Company's Prescriptive Lighting Program, the
Electric Impact Evaluation Report explains that a major reason for the 80Yo realization rate
calculated for this program was an inaccurate reported savings for many of the incented TLED
measures.
a. How did the Company discover these inaccuracies?
b. What steps is the Company taking to assure that accurate information is used in
the future?
REQUEST NO.38: Table 2-1: Prescriptive Lighting Program Measures (p.14) of the
Electric Impact Evaluation Report lists the incentives offered as part of its Prescriptive Lighting
Program for 2016 and20l7. Please explain how these incentive values were determined.
Provide sample workpapers showing how at least one of these incentive values was determined.
THIRD PRODUCTION
REQUEST TO AVISTA 6 MAY 13,2019
REQUEST NO. 39: Please provide workpapers showing how incentives for the
following programs were determined, and determined to be cost-effective based on tables from
the 2016-2017 Electric Impact Evaluation Report. Please include assumptions made for each
program.
a. Table 2-2: Food Service Equipment Program (p.15)
b. Table 2-3: Green Motors Rewinds Program (p.17)
c. Table 2-4: Motor Controls HVAC Program (p.17)
d. Table 2-5: Commercial Insulation Measures (p.1 8)
REQUEST NO. 40: On page 59 of the 2016-2017 Electric Impact Evaluation Report,
Nexant indicates that the Company's realization rate for site-specific interior lighting projects
was 88%. What steps is the Company taking to improve its estimate of the energy savings of its
site-specific interior lighting programs?
Dated at Boise, Idaho, this lg^ day of May 2019.
*>-'U-*L(
Edward
Deputy
i:umisc:prodreq/avue I 8. I 2ejck prod req3
THIRD PRODUCTION
REQUEST TO AVISTA
Jfi;fl
Anohe)General
7 MAY 13,2019
CERTIFICATB OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l3th DAY OF MAY 2019, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OFF THE COMMISSION
STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-18-12, By MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BO)( 3727
SPOKANE WA99220-3727
E-MAIL: linda. servaisri?avistacorp.corn
avi stadockets (ir)av i stac orp. corn
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BO)( 3727
SPoKANE W A 99220-3727
E-MAIL : darvi d.nre,ver(4)avi stacorp. com
SECRE Y
CERTIFICATE OF SERVICE