20200720Staff 1-7 to Avista.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
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Street Address for Express Mail:
I133I W CHINDEN BLVD, BLDG 8, SUITE 2OT-A
BOISE,ID 83714
Attorneys forthe Commission Staff
BEF'ORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S AIINUAL FIXED COST
ADJUSTMENT MECIIAI\ISM FILING
CASE NO. AVU-E.20.06
FIRST PRODUCTION
REQUEST OF TIIE
COMMISSION STAFF TO
AYISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Jr., Deputy Attorney General, requests that Avista Corporation dba Avista
Utilities ("Avista" or the "Company") provide the following documents and information as soon
as possible, orby MONDAY, AUGUST 10,2020.
This Production Request is continuing, and Avista 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. Avista 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 31.01.01.228.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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1 ruLY 20,2020
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 1: On page 8, lines 3-6, 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. 2: On page 7, lines ll-17, of the Application, the Company estimates
that in 2019 its DSM programs reduced residential usage by approximately 30 million kWh and
non-residential usage by approximately 82 million kWh.
a) Please reconcile these results to the Company's 2016,2017,2018 and 2019 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 2019 for the same customer groups.
REQUEST NO. 3: Please provide supporting documentation for the actual monthly
revenue for the 2019 deferral period.
REQUEST NO.4: Please provide all documents used as guidelines in the process for
setting up a new customer in the Customer Care and Billing System.
REQUEST NO. 5: Please provide supporting detail for the actual number of kWhs as
reported in the filing for each month in the deferral period.
REQUEST NO. 6: Please provide all internal audit reports and SOX reports detailing the
FCA revenue determination during the 2019 deferral period, including any safeguards or intemal
controls used to ensure that the revenue report is accurate.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION ruLY 20,20202
REQTIEST NO. 7: Please provide all internal audit reports and SOX reports detailing the
new customerprocess during the 2019 deferral p€riod.
Dated at Boise,Idaho, thrs 2dh day of July 2020.
Hammond Jr.
Attorney General
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FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 JULY 20,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20ft DAY OF ruLY 2020, SERVED
THE FOREGOING FIRST PRODUCTTON REQUEST OF TIrE COMnflSSION STAFF
TO AVISTA CORPORATION, IN CASE NO. AVU-E-20-06, BY E-MAILING A COPY
THEREOF, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
POBO){3727
SPoKANE W499220-3727
E-MAIL: [e-mail]
avistadockets @ avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
POBOX3727
SP0KANE WA99220-3727
E-MAIL: [e-mail]
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SECRETARY
CERTIFICATE OF SERVICE