20220823Staff 1-12 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 APPLICATIONS OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2020.2021 ELECTRIC
AND GAS ENERGY EFFICIENCY EXPENSES
AS PRUDENTLY INCURRED
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Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUTTE 2OI-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU.E.22.I3
AVU-G-22-05
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 TUESDAY, SEPTEMBER
13,2022.
This Production Request is to be considered as 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 or information produced.
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.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 AUGUST 23,2022
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 the in-house and third-party cost-effectiveness
workpapers and calculations for all Demand Side Management ("DSM") programs and measures
by year (2020 and202l) in Excel format with formulas intact and all assumptions clearly
defined.
REQUEST NO. 2: Please describe the Company's efforts to evaluate Research and
Development ("R&D") opportunities. Additionally, please describe the metrics used to evaluate
R&D opportunities.
REQUEST NO. 3: Please provide all workpapers in Excel format illustrating how the
cost-effectiveness of the Company's participation in the Northwest Energy Efficiency Alliance
("NEEA") was calculated for the years 2020 and202l.
REQUEST NO. 4: Please provide the amount of savings obtained through the
Company's participation in NEEA for 2020 and202l. Please identiff any savings that were
allocated to Avista's Idaho jurisdiction, and the methods used to allocate those savings.
Additionally, please provide the report from NEEA for the finalized savings for 2020 and202l
in Excel format, with all formulas intact.
REQUEST NO. 5: Please provide the avoided cost used to calculate the cost-
effectiveness of low-income, residential, commercial/industrial programs, and NEEA programs
for Avista's Idaho jurisdiction in Excel format with formulas intact.
REQUEST NO. 6: Please provide a list in Excel format showing all expenses charged to
the electric and gas DSM riders in2020 and202l. Please include the following information for
each expense: the date, vendor, amount, program, task number, and account to which the charges
were assigned. Please include and identiff any adjustments made in2020 and 2021 to
previously incurred expenses. Please also separate all expenses by program. If any amounts
were allocated to multiple programs and/or jurisdictions, please describe the allocation method.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 23,2022
Please identiff whether each expense is an incentive payment, purchase, service, labor/admin,
materials, or any other classification of expense.
REQUEST NO. 7: Please provide copies of all internal audit reports for audits
completed on the Company's electric and gas DSM processes and expenses from 2020 to 2022.
Please list the scope of any internal audits in progress on the Company's electric and gas DSM
processes and expenses.
REQUEST NO. 8: Please provide invoices for all third-party evaluators for 2020 and
2021. Please describe how those costs were allocated among jurisdictions and fuel sources.
REQUEST NO. 9: Please provide the electric and gas tariff rider revenue by month and
by class for2020 and202l.
REQUEST NO. l0: Please provide the calculation of any carrying charge or interest on
the electric and gas rider balances during 2020 and202l.
REQUEST NO. 11: Please provide the amount of labor expenses charged to the Idaho
electric and gas DSM tariff riders for the years 2019 through 2021. For each year, please include
the number of Full Time Equivalent positions funded by the rider. Please also provide the
general wage adjustment percentage for non-union personnel approved by the Compensation
Committee of the Board of Directors for each year.
REQUEST NO. 12: Please provide a current organizational chart by title and name
showing all Avista employees who charge time to the electric and gas DSM riders. Please
include complete job descriptions, required qualifications, salary ranges, bonus opportunities,
and total compensation ranges, including benefits, for all employees identified in this request.
Z4DATED at Boise,Idaho, this day ofAugust2022
i:umisc:prodreq/avue22, I3_avug22 Sdh.iitlc prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION J
Deputy Attorney General
AUGUST 23,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF AUGUST 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
C0MMISSION STAX'F TO AVISTA CORPORATION, IN CASE NO.
AYU-E-22-I3/AVU-G-22-05, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-mail : david.meyer@avi stacorp.com
[e-mail]
SHAWN J. BONFIELD SENIOR MANAGER
REGULATORY POLICY & STRATEGY
AVISTA CORPORATION
P.O.BOX3727
I411 E. MISSION AVENUE, MSC 27
SPOKANE,WA99220
E-mail: [e-mail]
$,4.fu
CERTIFICATE OF SERVICE