20221103Staff 23-31 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.9917
IiECTIVED
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Street Address for Express Mail:
1T331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATIONS OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2020.2021 ELECTRIC
AI\D GAS ENERGY EFFICIENCY EXPENSES
AS PRUDENTLY INCURRED FOURTH 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, NOVEMBER
25,2022.
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.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
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CASE NO. AVU.E.22.I3
AVU-G-22-05
1 NOVEMBER3,2022
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.23: The2020 in-house cost-effectiveness workpapers reports benefit
values of $127,591,92,535,203, and $168,525, respectively, for the low-income, residential, and
non-residential natural gas programs. The third-party cost-effectiveness workpapers show
benefit values of $68,285, $3,502,394, and $181,083 for those same programs despite claiming
the same number of therm savings as the in-house cost-effectiveness workpapers. Please
reconcile the difference in benefit values from the Company's in-house workpapers and the
third-party cost-effectiveness workpapers for the residential, low-income, and non-residential
programs. Please provide in Excel format with all formulas intact. (See Attachments A through
G in Response to Production Request No I for workpapers referenced above).
REQUEST NO.24: The2020 in-house cost-effectiveness workpapers show benefits
and costs of $3 I I ,999 and $63 7,629, respectively, for the low-income electric program. The
third-party cost-effectiveness workpapers show benefits and costs of $272,178 and 5546,723,
respectively, despite claiming the same number of saved kWh for the same program. Please
reconcile the differences between costs and benefits between the workpapers. Please provide in
Excel format with all formulas intact.
REQUEST NO. 25: The 2020 in-house cost-effectiveness workpapers and the 2020
Annual Report show 5,282,547 kwh in energy savings for the residential electric program. The
third-party cost-effectiveness workpapers show energy savings of 4,523,393 kwh. Please
reconcile the difference in kWh savings between the work-papers. Please provide in Excel
format with all formulas intact.
REQUEST NO. 26: Please provide the workpapers for the benefits and costs reported in
the 2020 Annual Report at 72 for the residential electric program.
REQUEST NO.27: The Company's2l2} Annual Report at 72 shows the residential
electric program had benefits and costs of $5,573,921 and $2,113,107, respectively. The third-
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 2 NOVEMBER3,2022
party cost-effectiveness workpapers show the residential electrical program had benefits and
costs at $5,072,229 and $l ,687,155, respectively. The 2020 in-house workpapers for residential
electric programs show benefits and cost at $4,852,201 and $1,870,086, respectively. Please
reconcile the differences in benefits and costs between the in-house workpapers, third-party
workpapers, and the2020 Annual Report. Please provide in Excel format with all formulas
intact.
REQUEST NO.28: The2020 in-house cost-effectiveness workpapers show costs of
$166,393 for the non-residential gas program. The third-party cost-effectiveness workpapers
show costs of $196,443 for the non-residential gas program despite claiming the same number of
saved therms. Please reconcile the cost differences between the two sets of workpapers. Please
provide in Excel format with all formulas intact.
REQUEST NO.29: The2020 in-house cost-effectiveness workpapers show costs of
52,711,045 for the non-residential electrical program. The third-party cost-effectiveness
workpapers show costs of $3,207 ,038 despite claiming the same number of saved kWh for the
same program. Please reconcile the cost differences between the two sets of workpapers. Please
provide in Excel format with all formulas intact.
REQUEST NO. 30: Please provide the workpapers for the therm savings reported in the
2020 Annual Report at99.
REQUEST NO. 31: The2020 in-house cost-effectiveness workpapers and third-party
workpapers show savings of 4,748 therms for the low-income natural gas program . The 2020
Annual Report at 99 shows therm savings of 5,495 for the low-income natural gas program.
Please reconcile the difference between the savings value reported in the Annual Report and the
two sets of workpapers. Please provide in Excel format with all formulas intact.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION J NOVEMBER3,2022
DATED at Boise, Idaho, X, 3d day ofNovember 2W2.
Dayn Hardie
Deputy Attomey Ge,neralk
i:umiso:prodreqlavue22. l3_41'ug22.5dhjit prod req 4
FOURTH PRODUCTION REQI.JEST
TO AVISTA CORPORATION 4 NOVEMBER3,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF NOVEMBER 2022,
SERVED THE FOREGOING FOI]RTH PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO.
AVU-E-22-I3/AVU-G-22-05, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COLTNSEL
AVISTA CORPORATION
POBO){3727
SPoKANE WA99220-3727
E-mail : [e-mail]
[e-mail]
SHAWN J. BONFIELD SENIOR MANAGER
REGULATORY POLICY & STRATEGY
AVISTA CORPORATION
P.O.BOX3727
I4I I E. MISSION AVENUE, MSC 27
SPOKANE,WA99220
E-mail : shawn.bonfi [e-mail]
,b /4,r,<
SECRETARY /
CERTIFICATE OF SERVICE