20210428Staff 136-177 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
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC AND NATURAL GAS
SERVICE FOR ELECTRIC AND NATURAL
GAS CUSTOMERS IN THE STATE OF IDAHO.
Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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cAsE NO. AVU-E-21-01
AVU-G-21-01
SIXTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA 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, or by WEDNESDAY, MAY 12,2021.r
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
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staffls attorney
at [phone].
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION
1 APRIL 28,2021
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.
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. 136: Please provide the first call resolution rate by month for each of the
past three years (2018,2019,2020). "First call resolution rate" is the percentage of customer
contacts where the transaction, inquiry or complaint is resolved upon initial contact with the
Company.
REQUEST NO. 137: Company witness Magalsky's testimony states that customer
contacts have steadily increased over the last twelve years. What factors does the Company
attribute to the increase in customer contacts?
REQUEST NO. 138: Please describe the self-help options that are available to customers
using the Company's Interactive Voice Response system. For 2018,2019, and2020, please
provide the utilization rate for each available option.
REQUEST NO. 139: Please describe the self-help options that are available to customers
using the Company's website. For 2018,2019, and2020, please provide the utilization rate for
each available option. What percentage of Idaho customers have established a myAvista account?
REQUEST NO. 140: 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 2018,
2019, and2020, please provide copies of the survey instrument(s) used, survey results, and any
analysis performed by Avista of those results.
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION
2 APRTL 28,2021
REQUEST NO. 141: Please provide all customer survey metrics and documentation in
relation to customer satisfaction, requested technologies, and payment satisfaction utilized in the
Customer Facing Technology Program.
REQUEST NO. 142: Please provide a detailed list of projects and descriptions, in the
same Excel format as those provided in response to Staff Production Request 81, for the following
business cases:
a. Technology Refresh to Sustain Business Process
b. Facilities Driven Technology Improvements
c. Human Resources Technology
d. Legal and Compliance Technology
e. Enterprise Business Continuity
REQUEST NO. 143: Please provide all business cases that contain costs for the
Company's Rattlesnake Flat Wind integration project. Please include a detailed breakdown of
costs.
REQUEST NO. 144: Please separate investment costs related to the Company's
Rattlesnake Flat Wind integration project for existing transmission line rebuild, the additional
switching station and transmission line leading to it, and existing substation upgrades. Please
describe what costs and which parts of the project the Company is required to make per NERC
standards, and which are not. Rosentrater Schedule 3 at9.
REQUEST NO. 145: Please provide a detailed schematic of the Company's Rattlesnake
Flat Wind integration project which includes existing transmission intended for rebuild, the
existing substation, the additional switching station and transmission line leading to it, and the
Rattlesnake Flat Wind facility.
REQUEST NO. 146: It is Staff s understanding that software refresh and upgrade type
projects can occur at a global administrative level. Please explain if cost recovery for the
following projects is replicated in multiple business cases: firewall refresh and upgrades, endpoint
protection, Microsoft products updates, Pi enhancements.
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION
J APRIL 28,2021
REQUEST NO. 147: Please describe Enterprise Data Science program packages and
provide the forecast of planned projects and associated costs. Kensok, Schedule I at 88.
REQUEST NO. 148: Regarding the Company's response to Production Request Nos. 42
and 43, please provide all projects, including ER numbers and business case numbers, that were
delayed or pushed back beyond the original December 31, 2020 completion date.
REQUEST NO. 149: Please provide the same information requested in Production
Request No. 149 for any projects delayed or pushed back beyond the original August 31,2021
completion date.
REQUEST NO. 150: For the Customer Facing Technology Program Business Case,
please provide a list of projects that have been started and when those projects will be
implemented. Are any projects expected to be delayed or transferred to plant beyond the original
August 31,2021End of Period date? For the Customer Transactional Systems Business Case,
please provide a list of projects that have been started and when those projects will be
implemented. Are any projects expected to be delayed or transferred to plant beyond the original
August 31,2021End of Period date?
REQUEST NO. 151: Regarding the Customer Transactional Systems, please provide the
CC&B software name. If acquired after Case No. AVU-E-19-04, please provide a copy of the
bids/proposals and the selection criteria used to select the software.
REQUEST NO. 152: Regarding the Customer Experience Platform ("CXP") Business
Case, please provide when CXP was created, why it was transferred to a new business case, and if
any projects have been started.
REQUEST NO. 153: Please provide an update to the Idaho Advanced Metering
Infrastructure ("AMI") Expansion project for Electric and Gas. Please include in Excel format a
list of the relative business case numbers, the amount assigned specifically for Idaho AMI
Expansion, the expected start date, and the expected completion date.
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION
4 APRIL 28,2021
REQUEST NO. 154: Please provide a list, in Excel format, of all Business Cases that
have AMI related capital expenses.
REQUEST NO. 155: Please provide the cost breakdown, in Excel format, for the
51,925,172 Gas Distribution Non-Revenue in Business Case 2023 that was transferred to plant in
2020.
REQUEST NO. 156: Of the projects mentioned in Witness Kinney's testimony related to
EIM, please provide a list of projects that have uses other than integrating with EIM.
REQUEST NO. 157: In Order No. 34606, Case No. AVU-E-20-01 the Commission
granted the Company a deferral of incremental O&M Costs related to the implementation of EIM.
Please provide the current amount booked to the regulatory asset account. Please provide monthly
updates as additional amounts are deferred.
REQUEST NO. 158: Please provide a list of all currently "loaned employees" who are
performing work for other Company's, i.e., McKinstry Engineering and Consulting, or any non-
regulated subsidiary. Please also include the total remuneration for those employees in 2019 and
the accounts to which they were charged.
REQUEST NO. 159: Regarding Customer at the Center Initiative in Kelly E. Magalsky
Direct Testimony, please provide a consolidated list and breakdown of all cost savings, future cost
savings, deferred costs, and cost savings realized in this rate case related to the Customer at the
Center Initiative.
REQUEST NO. 160: Regarding Customer at the Center Initiative in Kelly E. Magalsky
Direct Testimony, please provide the data, costs, and calculations used to develop the average cost
per call.
REQUEST NO. 161: Regarding Customer at the Center Initiative CXP Cost Savings in
Kelly E. Magalsky Direct Testimony, page 25, please provide the number of calls placed to the
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION
5 APRIL 28,2021
call center, amount of time it takes to resolve a customer case, time spent to onboard
representatives, and labor hours for call center representative for the last five years.
REQUEST NO. 162: For all expenses assigned to FERC Account #909 for Idaho Gas
referenced in Adjustment No. 2.08, please provide a copy of the invoices and an explanation for
why these expenses were assigned to "AN.CD."
REQUEST NO. 163: Please provide all updated supporting documentation for the
estimated O&M expenses for Colstrip/CS2 shown in Adjustments No. 2.12 and22.06.
REQUEST NO. 164: Please fully describe the $25,000 increase in transmission revenues
in Pro Forma Transmission Revenues and Expenses Adjustment 3.00T that was not included in
Exhibit No. 5, Schedule l.
REQUEST NO. 165: Please provide supporting documentation for the pro forma
adjustments shown in Adjustment No. 3.00T PF for the following parties:
a. NorthernGrid
b. NERC CIP
c. RC West
d. OASIS
e. PacifiCorp (Dry Gulch)
REQUEST NO. 166: Please describe the methods of communication the Company
provides to customers for reporting outages and the methods of communication the Company uses
to accurately provide timely updates of outages to its customers.
REQUEST NO. 167: What improvements, if any, is the Company making to its outage
management notifi cation?
REQUEST NO. 168: Please provide the number of incoming calls handled by the
customer service call center by month for each of the past three years (2018,2019 and YTD
2020).
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION
6 APzuL 28,2021
REQUEST NO. 169: Please provide the number of abandoned calls to the customer
service call center by month for each of the past three years (2018,2019 and YTD 2020).
"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.
REQUEST NO. 170: Please provide the average speed of answer for the customer
service call center by month for each of the past three years (2018,2019 and YTD 2020).
"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.
REQUEST NO. 171: Please provide the service level for the customer service call center
by month for each of the past three years (2018,2019 and YTD 2020). "Service level" is the
percentage of calls answered within a certain number of seconds, e.9., 80o/o of calls answered
within 20 seconds.
REQUEST NO. 172: Please provide the average number of busy signals reached by
parties calling the customer service call center by month for each of the past three years (2018,
2019 and YTD 2020).
REQUEST NO. 173: Please provide the average response time for e-mail transactions by
month for each of the past three years (2018,2019 and YTD 2020). "Average response time" is
the average number of hours from receipt of an e-mail by the Company to sending a substantive
response; auto-response acknowledgements do not count as a substantive response.
REQUEST NO. 174: Please provide the average handling time by month for each of the
past three years (2018,2019 and YTD 2020). o'Average handling time" is the average amount of
time (usually expressed in minutes) it takes for a customer service representative to talk with a
customer plus any additional "off-line" time it takes to complete the transaction or fully resolve
the customer's issue(s).
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION
7 APRIL 28,2021
REQUEST NO. 175: Is the integration rate of $1.067/kW-month supplied in response to
Staff Production Request No. 56 a rate that should be applied to the total nameplate capacity of
Rattlesnake Flat? Please explain.
REQUEST NO. 176: What integration rate should be applied to Palouse Wind?
REQUEST NO. 177: Regarding the proforma insurance costs discussed in Andrews
Direct Testimony, pages 42-44,please provide copies of any invoices received in202l for
insurance premiums.
Dated atBoise, Idaho, fln, ftffiyof April 22zl.
Jr
Attorney General
i:umisc/prod req/avue2l.l_avug2l. ljh prod req6
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION
J
8 APzuL 28,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF APRIL 2021,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AYISTA CORPORATION, IN CASE NOS.
AVU-E-21-OI/AVU-G-21-OI, BY E-MAILING A COPY THEREOF TO THE
FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail : [e-mail]
avi [e-mail]
BENJAMIN J OTTO
DAINEE GIBSON-WEBB
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-mail : [e-mail]
[e-mail]
VICKI M BALDWIN
PARSON BEHLE & LATIMER
201 SOUTH MAIN STREET SUITE 18OO
SALT LAKE CITY UT 84I I I
E-mail : [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-mail: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE TD 83702
E-mail:nadams.com
Electronic Service Only:
carol. haugen@c learwaterpaper.com
terry.borden @c I earwaterpaper.com
mal i sa. maynard@clearwaterpaper. com
DAVID J MEYER
VP & CHIEF COLTNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail: [e-mail]
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO WEST MAIN STREET SUITE I3OO
BOISE ID 83702
E-mail: [e-mail]
Electronic Service Only:
STEVE W CHRISS
DIRECTOR ENERGY SERVICES
WALMART INC
E-mail: [e-mail]
LARRY A CROWLEY DIRECTOR
THE ENERGY STRATEGIES INSTITUTE
3738 S HARRIS RANCH AVE.
BOISE ID 837I6
E-mail: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail : dreadin [e-mail]
CERTIFICATE OF SERVICE
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N 17TH STREET
BOISE IDAHO 83702
E-mail : [e-mail]
CERTIFICATE OF SERVICE