20190926Staff 41 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
REC EIVED
i0i9 SIP 25 PH 12: 05
Street Address for Express Mail:
1133I W. CHINDEN BLVD, BLDG 8 SUITE 2OI-A
BOISE, IDAHO 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES 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.I2
FOURTH 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 THURSDAY, OCTOBER
10,2019.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
person preparing the document, and the name, location and phone number of the record holder
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FOURTH PRODUCTION
REQUEST TO AVISTA SEPTEMBER26,2OI9
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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 in response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 4l: Please answer the following questions related to Table 1 reflecting
data from the Company's Conservation Report shown below:
a. Please explain why 2017 electric savings in Table I were 377% of the IRP target.
If some programs were more popular than anticipated by the Company-such as
the LED lighting program, please explain why the Company did not forecast this
level of uptake during the planning process; and
b. Please explain why the UCT for electric savings almost doubled between 2016
and20l7 (2.80 to 4.33). Staff previously understood that the Company manages
its DSM portfolio toward a 1.0 UCT to maximize the amount of cost-effective
savings, but this appears to be moving in the opposite direction. Please explain
this change.
Table l. Electric
Dated at Boise, Idaho, this Tboa day of September 2019.
((
Deputy
i:umisc.prodreq/avuel 8. I 2ejck prod req4
FOURTH PRODUCTION
REQUEST TO AVISTA 2
Metric 2016 2017
Energy Savings 38,149 MWh 42,223 MWh
IRP Tarset t1,273 MWh 11,186 MWh
Expenditures $11,743,724 $10,975,480
Utility Cost Test 2.80 4.33
Total Resource Cost Test 2.t7 2.69
General
SEPTEMBER26,2OI9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF SEPTEMBER 2019,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OFF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-18-12,
BY MAILTNG A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-MAIL: [e-mail]
avistadoc kets@avi stacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: david.me),[e-mail]
SECRET Y
CERTIFICATE OF SERVICE