20210812Staff 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
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
IMPLEMENT FCA RATES FOR ELECTRIC
SERVICE FROM OCTOBER 1, 2021 THROUGH
SEPTEMBER30,2022
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Street Address for Express Mail:
I 133I 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. AVI'.E.21-08
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 Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than THURSDAY,
AUGUST 26,2021.1
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.
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at (208) 334-12.
FTRST PRODUCTION REQUEST
TO AVISTA CORPORATION I AUGUST I2,2O2I
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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. l: Please provide supporting documentation for the actual monthly
revenue for the deferral period from January 1,2020 through June 30, 2021.
REQUEST NO. 2: Please provide supporting documentation for the actual number of
kilowatt-hours ("kWh") sold as reported in the filing for each month in the January 1,2020
through June 30, 2021 defenal period.
REQUEST NO.3: Please provide all internal audit reports and SOX reports detailing
the revenue process during the January 1,2020 through June 30, 2}2ldeferral period.
REQUEST NO. 4: Please provide all intemal audit reports and SOX reports detailing
the new customer process during the January 1,2020 through June 30, 2021 deferral period.
REQUEST NO. 5: Please provide the number of new customers by class per month for
the January 1,2020 throughJune 30,2021 defenal period.
REQUEST NO. 6: On page 8, lines l-4 of the Application, Avista estimates that for
January 1,2020 through June 30, 2021 deferral period, its DSM programs reduced residential
usage by approximately 23 million kWh and non-residential usage by approximately 5l million
kwh.
a. Please reconcile these results with the Company's 2017 through 2020 DSM
reports and any other reports that may apply.
b. Please provide supporting documentation for these calculations.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST I2,2O2I
REQUEST NO. 7: Please provide the Company's estimate of the total weather-
nonnalired change in consumption for the lanuary 1,202A through June 30, 2021 defenal
period, for the sanre customer groups.
DATED at Boise, Idaho, tfri, lS day of August 2021.
Deprrty Attomey General
Technical Staff: Johm Kalala-Kasanda (1-7)
i:umise:podreq/avue2t.8dhik prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUCUST I2,2A2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I2M DAY OF AUGUST 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-2I-08,
BY E.MAILING A COPY THEREOF, TO THE FOLLOMNG:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL : [e-mail]
dockets@avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
POBOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE