20210331Staff 41-44 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2018.2019 NATURAL
GAS ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED
' -3 :l /" f t1.l i::i\
li:i =i:t 3 | f}t 3: t+0
Street Address for Express Mail:
I133I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, TD 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 2OT 8-2019 ELECTRIC
ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED
CASE NO. AVU-E-20-13
)
)
)
)
)
)
)
)
)
)
)
)
CASE NO. AVU.G.2O.O8
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,
Dayn Hardie, Deputy Attomey General, request that Avista Corporation (Company) provide the
following documents and information as soon as possible, or by WEDNESDAY, APRIL 14,
2021.r
I Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
THIRD PRODUCTION REQUEST
TO AVISTA MARCH 31,20211
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.01.228.
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. 41: On page 8 of its 2019Impact Evaluation, Cadmus describes its
non-residential program sampling methodology. For each of the programs listed in Table 7
(page 9), please provide the workpapers used to determine sample size in electronic format with
formulae and links intact. For each program, please include the population variance (or standard
deviation) assumed in the calculation as well as the source for that variance (or standard
deviation). If any methodology other than simple random sampling was used (e.g. stratified
sampling or cluster sampling), please describe the methodology and explain the rationale for its
use.
REQUEST NO. 42: On page 20 of its 2019Impact Evaluation, Cadmus states that the
Multifamily Direct Install "MFDI Idaho participant group showed a reliable relative precision
estimate of +l- l7%o atthe 90Yo confidence level for the 34 facilities included in the analysis and
savings of 5.8%o." Please provide all workpapers (in electronic format with all formula and links
intact) and data showing how these estimates were determined.
REQUEST NO. 43: On page 18 of its 2019Impact Evaluation, Cadmus states that it
conducted a billing analysis on Avista's HVAC, Shell, Fuel Efficiency, and MFDI programs;
however, the results of these analyses are not included in Table 18, "Residential Programs
THIRD PRODUCTION REQUEST
TO AVISTA MARCH 3I,2O2I2
Billing Analysis Results." Please provide the results of these billing analyses, as well as all
workpapers in electronic format, with formulae and links intact.
REQUEST NO. 44: On page l8 of its 2019Impact Evaluation, Cadmus states that it
conducted a billing analysis on Avista's HVAC, Shell, Fuel Efficiency, and MFDI programs;
however, the results of these analyses are not included in Table 18, "Residential Programs
Billing Analysis Results." For each of these programs, please provide the workpapers used to
determine the size of the sample used in the billing analysis in electronic format with formulae
and links intact. For each program, please include the population variance (or standard
deviation) assumed in the calculations, as well as the source for that variance (or standard
deviation). If any methodology other than simple random sampling was used (e.g. stratified
sampling or cluster sampling), please describe the methodology and explain the rationale for its
use.
DATED at Boise, Idaho, tfri, 3lf day of Mar ch202l
Deputy Attorney General
i:umisc:prodreq/avue2O. I 3_avug20.08dhmm prod req3
THIRD PRODUCTION REQUEST
TO AVISTA J MARCH 3I,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3IST DAY OF MARCH 2021,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-20-13/AVU-G-20-08, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
SHAWN J BONFIELD
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
avistadockets@ avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W499220-3727
E-mail: [e-mail]
.)r"dhr"-
SECRETARY
CERTIFICATE OF SERVICE