20190806Staff 1-7 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
RECEIVED
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Street Address for Express Mail:
4]2W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FIXED COST
ADJUSTMENT MECHANISM (FCA) ANNUAL
RATE ADJUSTMENT FILING OF AVISTA
CORPORATION
CASE NO. AVU.E.I9-07
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,
Dayn Hardie, Deputy Attomey General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than TUESDAY, AUGUST 27,
2019.
This Production Request is to be considered as continuing, and Avista Corporation 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION AUGUST 6,2019
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the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided in response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide the number of new customers by class per month for
January 201 9 through May 2019.
REQUEST NO. 2: On page 7, lines 9-13 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 group and non-residential groups. Please provide supporting documentation for
these calculations including Excel workbooks with formulas intact and enabled.
REQUEST NO. 3: On pages 7 of its Application, the Company estimates that the
Company's DSM programs reduced residential usage by 19 million kWh in 2018 and non-
residential usage by approximately 57 million kWh in 2018.
a.) Please reconcile these results to the Company's 2016,2017,and2018 DSM reports
and any other reports that apply. Please provide supporting documentation for these
calculations including Excel workbooks with formulas intact and enabled.
b.) Please provide the Company's estimate of the total weather-normalized change in
consumption in 2018 for the same customer groups.
REQUEST NO. 4: Please describe the process, safeguards, and internal controls for
validating new customers for the FCA calculations.
REQUEST NO. 5: Please provide all internal audit reports and SOX reports detailing
the new customer process since 2017.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 6,2079
REQUEST NO. 6: Please explain the process the Company uses to create the revenue
reports provided in its workpapers, including any safeguards or internal controls used to ensure
the revenue report's accuracy.
REQUEST NO. 7: Please provide any and all internal audit reports and SOX reports
detailing FCA revenue determination since 2017.
DATED at Boise, Idaho, tni, 6L day of August 2019
Dayn Hardie
Deputy Attorney General
i:umisc:prodreq/avuel 9.7dhjk prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION J AUGUST 6,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY oF AUGUST 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-19-07,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: palr:ick.ehrbar(iavistacorp.com
avi staclockcts 6i-),avi s tacorp. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: botto(Oidahoconservation.org
DAVID J MEYER
VP & CHIEF COLINSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: david.meyer(Paivistacorp.com
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SECRETAT.t/-
CERTIFICATE OF SERVICE