20220815Staff 1-6 to Avista.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
,- llr-ri,:
,-\u1i\:t'
Street Address for Express Mail:
I 133 1 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FIXED COST
ADJUSTMENT MECHANISM (FCA) ANNUAL
RATE AJUSTMENT FILING OF AVISTA
CORPORATION
CASE NO. AVU.E-22-I2
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,
Chris Burdin, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than MONDAY,
AUGUST 29,2022.1
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 Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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I AUGUST 15,2022
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 identifu 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. 1: Please provide all internal audit reports and SOX reports detailing
the FCA revenue determination during the deferral period, July I ,2021, through June 30, 2022.
Please include any safeguards or internal controls used to ensure that the revenue report is
accurate.
REQUEST NO. 2: Please provide the number of new and existing customers by class
per month for the July I ,2021, through June 30, 2022, deferral period.
REQUEST NO.3: Please provide supporting documentation for the actual number of
kWhs sold for each month in the July 1, 2021, through June 30, 2022, deferral period.
REQUEST NO. 4: Please provide the Company's quarterly reports showing pertinent
information regarding the status of the current deferral. Please include a spreadsheet showing
the monthly revenue deferral calculation for each month of the deferral period, July 1, 2021,
through June 30, 2022, as well as the current and historical monthly balance in the deferral
account.
REQUEST NO. 5: The Company estimates that for the July 1,2021, through June 30,
2022, deferral period, its Demand Side Management ("DSM") programs reduced residential
usage by approximately 16 million kWhs and non-residential usage by approximately 46 million
kWhs. Applicationat6.
a. Please reconcile these results with the Company's2021DSM report and any other
reports that may apply.
b. Please provide supporting documentation for these calculations.
FIRST PRODUCTION REQUEST
TO AVTSTA CORPORATION 2 AUGUST 15,2022
REQUEST NO.6: The Company lists the impacts of three drivers (weather, energy
efficiency, and other) on use-per-customer and FCA Revenue for the residential and non-
residential groups. Application at6-7. Please provide supporting documentation for these
calculations including Excel workbooks with formulas intact and enabled.
DATED at Boise,Idatro, ttis l{$1day of August2022.
U*f LJI
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/avue22.l2abrm pnod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUGUST 15,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l5th DAY OF AUGUST 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-22-12,
BY E-MAILING A COPY TIIEREOF, TO THE FOLLOMNG:
PATRICK EHRBAR
DIRECTOR REGULATORY AFFAIRS
AVISTA CORPORATION
POBOX3727
SPoKANE W499220-3727
E-mail: [e-mail]
dockets@avistacom. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
POBO)(3727
SPoKANE WA99220-3727
E-mail: [e-mail]
Y
CERTIFICATE OF SERVICE