20190712Staff 63-109 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 E IVE D
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Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-59T8
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES FOR ELECTRIC
SERVICE IN IDAHO.
CASE NO. AVU.E-19.04
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 Attomey General, request that Avista Corporation (Company) provide
the following documents and information as soon as possible, or by FRIDAY,
AUGUST 2,2019.
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
31.0t.0r.228.
THIRD PRODUCTION REQUEST
TO AVISTA
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1 JULY I2,2OI9
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. 63: Please have available for Staff to review onsite during the week of
July 22-26 all supporting documentation for each of the Pro Forma 2020 amounts listed on
Andrews workpaper 3.05-3.
REQUEST NO. 64: Please provide the Capital Expenditures Budget and supporting
information as of December 3 l, 2019. Please include the budgeted amount, the actual spent
amount to date, and the amount booked to plant in service by year, by functional category
(environmental, gas, generation, growth, enterprise technology, other, transmission, and
distribution) for the last 5 years.
REQUEST NO. 65: Please explain how the Capital Recovery Factor of l2.003Yowas
determined. Provide supporting documents with the explanation.
REQUEST NO. 66: In her testimony, on page 14, lines 1,2 and 3, Ms. Schuh stated that
a review of maintenance records was conducted. Please provide documentary evidence
pertaining to the reviewed maintenance records with calculations that resulted in Adjustment
3.10 of $59,000.
REQUEST NO. 67: Please provide updates to each Pro-Forma adjustment included in
the Company's case with actuals through June 30, 2019.
REQUEST NO. 68: In Witness Schuh's *2019 Adds Detail" Work Paper there are a
number of projects with no amounts in any of the months but have Residual CWP. It appears
that the residual CWIP is included in Adjustment 3.09. Please provide a narrative on how these
projects are moved out of CWIP and into Plant in Service.
THIRD PRODUCTION REQUEST
TO AVISTA 2 JULY I2,2OI9
REQUEST NO. 69: For the Rattlesnake Flats Wind PPA, please provide all workpapers
and spreadsheets (with calculations and links enabled) used to develop any cost-benefit analysis
to Idaho customers, rate comparison analysis, and all other analyses performed.
REQUEST NO. 70: For the Adams Neilson Solar PPA, please provide all workpapers
and spreadsheets (with calculations and links enabled) used to develop any cost-benefit analysis
to Idaho customers, rate comparison analysis, and all analyses used for approval with the
Washington Utilities and Transportation Commission.
REQUEST NO. 71: For the Adams Neilson Solar PPA, are Idaho customers allowed to
participate? If so, please provide how many are participating.
REQUEST NO. 72: Please provide the following information regarding incoming calls
handled by the customer service call center by month for 2017 , 201 8, and YTD 2019: (a) number
of incoming calls (call volume); (b) number of abandoned calls; (c) percentage of incoming calls
that are abandoned; (d) average speed of answer; and (e) service level. "Abandoned calls" are
calls that reach the Company's incoming telephone system, but the calling party terminates the
call before speaking with a customer service representative or choosing to use a self-service
option. "Average speed of answer" is the interval (typically measured in seconds) between when
a call reaches the Company's incoming telephone system and when the call is picked up by a
customer service representative. "Service level" is the percentage of calls answered within a
certain number of seconds , e.9., 80%o of calls answered within 20 seconds. Please provide this
information in an Excel spreadsheet format.
REQUEST NO. 73: For 2011,2018, and YTD 2019, please provide the following
information regarding customers' inquiries, requests, comments and complaints submitted on the
Company's website or through myAvista accounts (messages): (a) number of messages; and (b)
average response time to messages. "Average response time" is the average amount of time
between receiving a message and sending a substantive response; acknowledgments of receipt
are not considered to be a substantive response.
THIRD PRODUCTION REQUEST
TO AVISTA 1J JULY I2,2OT9
REQUEST NO. 74: Please describe the self-help options that are available to customers
using the Company's Interactive Voice Response system. For 2017,2078, and YTD 2019,
please provide the utilization rate for each available option.
REQUEST NO. 75: Please describe the self-help options that are available to customers
using the Company's website. For 2017,2018 and YTD 2019, please provide the utilization rate
for each available option. What percentage of Idaho customers have established a myAvista
account?
REQUEST NO. 76: In his testimony on p. 19, lines 1-19, Company Witness Kensok
addresses the Company's Customer Facing Technology Program and, beginning on line 12,
identifies several key projects taking place in 2019. Please describe in more detail what each of
these projects entail and whether the project is designed to solve an existing problem or prevent a
future problem.
REQUEST NO. 77: Company Witness Kensok's Exhibit No. 9, p. 2, refers to several
metrics used by the Customer Facing Technology Program. Please provide the specific customer
satisfaction scores, web satisfaction scores, channel growth statistics, and transaction success
rates used by the Company in determining what projects to undertake in20l9.
REQUEST NO. 78: Please provide a copy of the current Payment Card Industry (PC!
Standards as referenced in Company Witness Kensok's testimony on p. 19. Please describe in
more detail the two projects identified for 2079, PCI Web Site Payment Compliance and PCI
Phone Payment Compliance.
REQUEST NO. 79: With respect to the Company's Voice of the Customer Survey, how
often does the Company conduct the survey? How are survey participants selected? How many
customers are surveyed? What percentage of survey participants are Idaho customers? For
2017,2018, and YTD 2019, please provide copies of the survey instrument(s) used, survey
results, and any analysis performed by Avista of those results.
THIRD PRODUCTION REQUEST
TO AVISTA 4 JULY 12,2019
REQUEST NO. 80: Please provide a copy of the benchmark study of collection
agencies and a more detailed description of the Customer Service scorecard process referenced
in Company witness Vermillion's testimony on p. ll-12.
REQUEST NO. 81: Please explain and quantify how Idaho customers will benefit from
implementation of the Digital Grid Expansion business case and the Idaho AMI project.
REQUEST NO. 82: In Exhibit 9 on page 133, the Company shows "Expand private
network infrastructure (recommended) starting in2019 with completion December of 2023."
Please provide the project completion percentage, cost to date, remaining costs to incur, and the
expected total cost of the program.
REQUEST NO. 83: In response to Production Request No. 6, the Company lists total
(2011 &.2018) costs of $413,654.07 for Project Number 77705250, Project Description KFGS
Diesel Fuel Spill (O&M). Please describe in detail the cause, location, and remediation of the
fuel spill.
REQUEST NO. 84: Please describe how the Company uses the FEMA ICS system
referenced in Kensok's testimony. Kensok Direct at 4, lines l-5.
REQUEST NO. 85: Please explain what actions are being undertaken to negotiate a
new coal contract or to extend the coal supply beyond the end of 2019 for Colstrip Units 3 & 4.
REQUEST NO. 86: Please provide a summary of Colstrip meetings that have taken
place with Talen during the 2019 calendar year. Please provide updates regarding capital
investments, environmental compliance, regulatory discussions, coal supply, and other pertinent
discussions.
REQUEST NO. 87: Please provide a detailed description of software, upgrades, and
equipment needed for participation in the Energy Imbalance Market. Please describe the Capital
THIRD PRODUCTION REQUEST
TO AVISTA 5 JULY I2,2OI9
Investment Project/s where all EIM related software/systems, upgrades, and equipment are
included.
REQUEST NO. 88: Please provide a detailed list of projects, cost estimates or cost
breakdown, and descriptions included in the Technology Refresh to Sustain Business Process
IS/IT Capital Project.
REQUEST NO. 89: Please provide a detailed list of projects, cost estimates or cost
breakdown, and descriptions included in the Enterprise Security IS/IT Capital Project. Kensok
Schedule I at 10.
REQUEST NO. 90: Please provide a detailed list of projects, cost estimates or cost
breakdown, and descriptions included in the Security Systems IS/IT Capital Project.
REQUEST NO. 9l: Please provide a detailed list of projects, cost estimates or cost
breakdown, and descriptions included in the Generation, Substation, and Gas Location Security
IS/IT Capital Project. Kensok Schedule 1 at 91.
REQUEST NO. 92: Please provide a detailed list of projects, cost estimates or cost
breakdown, and descriptions included in the Enterprise Communication Systems Capital
Investment Business Case. Kensok Schedule I at 47.
REQUEST NO. 93: Please provide a detailed list of projects, cost estimates or cost
breakdown, and descriptions included in the Technology Capital Investment Business Case.
Kensok Schedule I at ll3.
REQUEST NO. 94: Please provide a detailed list of projects, cost estimates or cost
breakdown, and descriptions included in the Customer Facing Technology Capital Investment
Business Case. Kensok Schedule I17.
THIRD PRODUCTION REQUEST
TO AVISTA 6 JULY I2,2OI9
REQUEST NO. 95: Please provide a detailed list of projects, cost estimates or cost
breakdown, and descriptions included in the Critical Infrastructure Protection v5 Transition IS/IT
Capital Project. Kensok Schedule I at 124.
REQUEST NO. 96: Does the System Center Configuration Manager tool manage assets
identified as critical (CIPX Please describe how the Company complies with CIP-0 I 0- 1 .
Kensok DI at 8.
REQUEST NO. 97: Regarding the statement on page 9 of Kensok Direct Testimony,
line 38-40, how many and what types of projects occurred in 2018 relating to improvement
projects, quality issues, annual exercises, or actual events? Of those projects how many had a
Business Impact Assessment (BIA)? Please provide all of these Business Impact Assessments
for projects in 2018.
REQUEST NO. 98: Regarding enterprise security regulatory obligations in Kensok
Direct Testimony, page 10-l l, have all the regulatory requirements, including CIP v.5, been
adhered to and when were they met?
REQUEST NO. 99: Please provide the completion percentage, the cost to date,
remaining costs to be incurred, and the yearly expected percentage of completion of Enterprise
Security.
REQUEST NO. 100: Regarding Kensok Direct Testimony, page 8-9, please provide a
list of differentiation between the Technology Refresh to Sustain Business Process project and
the projects listed below:
a. Endpoint Compute and Productivity Systems
b. Enterprise & Control Network Infrastructure
c. Enterprise Communication Systems
d. Environmental Control & Monitoring Systems
e. Infrastructure Technology Failed Assets
THIRD PRODUCTION REQUEST
TO AVISTA 7 JULY 12,2019
REQUEST NO. 101: Regarding Energy Delivery Modemization in Kensok Direct
Testimony, page ll-12, please provide all of the costs and the expected implementation dates
for;ArcGIS, EAM-Maximo, Mobile Dispatch, FCS, FN, and Global Mapper. What is the
allocation percentage for Idaho gas and electric for these programs implemented in 2019?
REQUEST NO. 102: Regarding Energy Delivery Operational Efficiency & Shared
Services in Kensok Direct Testimony, page 12, please provide the reasoning on how this case is
differentiated from the Energy Delivery Modernization case and the individual cost for each
technology piece implemented prior to or during 2019.
REQUEST NO. 103: Regarding Energy Resources Modernization & Operational
Efficiency in Kensok Direct Testimony , pdge 12, please provide all of the costs and the expected
implementation dates for; Nucleus Enhancements, ADSS Enhancements, Nostradamus Upgrade,
GPSS Mobile Substation Inspections, and Unitization Project Phase III. What is the allocation
percentage for Idaho gas and electric for the projects implemented in2019?
REQUEST NO. 104: Regarding ET Modernization & Operational Efficiency-
Technology in Kensok Direct Testimony, page 14, please provide all of the Idaho Electric 2019
costs and the expected implementation dates for; IT Incident & Asset Management, Non-
production Environment & Data Management, ET Portfolio Management, Application Lifecycle
Management Tools, and Shared Systems and Tooling.
REQUEST NO. 105: Regarding Financial & Accounting Technology in Kensok Direct
Testimony, page 15, please provide all of the Idaho Electric 2019 costs and the expected
implementation dates for; Budget System Replacement, Power Plan Tax Upgrade, EBS
Additional Modules, Cash/Treasury Upgrades, and EBS Enhancements.
REQUEST NO. 106: Regarding Human Resources Technology in Kensok Direct
Testimony , page I 5, please provide all of the Idaho Electric 20 I 9 costs and the expected
implementation dates for; Analytics/Compliance, Employee Engagement, HR Information
Systems, HR Management, Learning, and Ongoing Training.
THIRD PRODUCTION REQUEST
TO AVISTA 8 JULY I2,2OI9
REQUEST NO. 107: Regarding Infrastructure Technology Failed Assets in Kensok
Direct Testimony, page 17, please provide additional descriptions of the meaning of failed assets
and cost offailed assets in 2018.
REQUEST NO. 108: Regarding Generation, Substation & Gas Location Security and
CIP 14v1 - High Impact Assets in Kensok Exhibit No.9, what additional security controls are
going to be satisfied in High Impact project that are not going to be completed in the Location
Security project?
REQUEST NO. 109: Regarding Data Center Compute and Storage Systems in Kensok
Direct Testimony, page 20, please provide description and cost of the cloud services and on
premise servers.
Dated at Boise, Idaho, this lzt*day of July 2019
*-'("-(
Edward i"*#\-
Deputy Attolbybeneral
i:umisc:prodreq/avuel9.4ejde prod req3
THIRD PRODUCTION REQUEST
TO AVISTA 9 JULY I2,2OI9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF JULY 2019,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-8.19-04,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL
avi staclockets/.2=4avistacorp. corn
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-MAIL : ron,@lvi I liam sbradbur),.corn
ELECTRONIC ONLY
LARRY A CROWLEY
crorv le.r' I a, ilaol.ctrrn
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE TD 83702
E-MAIL : peter(#)richard sonadarns.corn
ELECTRONIC ONLY
carol.hauecn (i,cleanvatel'paDel'-cotn
tcrrr-. bordcnt?;c I eanvatcrpapg.c0!!
rnal isa. lna-\'nard?cL'ar\\atetpat)cr.coln
NORMAN M SEMANKO
PARSONS BEHLE & LATIMER
8OO W MAIN ST STE 13OO
BOISE ID 83702
E-MAIL : nsenlanko(0pi1r'sonsbehle.corn
ELECTRONIC ONLY
Stephen.clrriss@ q-qnt
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SP0KANE W A 99220-3727
E-MAIL: clavid.meyer(a)avistacol p.co!!
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 83716
E-MAIL: clcanjmil lcrr?cableonc.net
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : dreadinsI, g)mindsprirlu.com
VICKI M BALDWIN
PARSONS BEHLE & LATIMER
201 S MATN ST STE ISOO
SALT LAKE CITY UT 841I I
E-MAIL: vbaldrvi n(J)parson sbeh le.com
CERTIFICATE OF SERVICE
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7lo N 6rH sr
BOISE ID 83702
E-MAIL: bottor, g)idahoconservation.ors
CERTIFICATE OF SERVICE
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