20230825Staff 1-7 to AVU.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION "
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10221
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF AVISTA CORPORATION FOR AN )CASE NO.AVU-E-23-07
ACCOUNTING ORDER AUTHORIZING )AVU-G-23-04
ACCOUNTING AND RATEMAKING )
TREATEMENT OF COSTS ASSOCIATED )FIRST PRODUCTION
WITH THE COMPANY'S INVESTMENT IN )REQUESTOF THE
AMI (ADVANCEDMETERING )COMMISSION STAFF
INFASTRUCTURE))TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy AttorneyGeneral,requests that Avista Corporation dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and information as soon as
possible,but no later than FRIDAY SEPTEMBER 15,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 AUGUST 25,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Are any of the automated meter reading ("AMR")or AMI system
components currentlyin service forward compatible or upgradable for use in the proposed
replacement system?If yes,please provide a description of each component to be reused or
upgraded and savings achieved by avoiding the purchase of new components.
REQUESTNO.2:Please provide an Excel file with formulas intact and enabled that
details salvage values by component for all items that will be taken out of service and replaced.
REQUESTNO.3:Please provide an Excel file with formulas intact and enabled that
supports the Incremental Lifecycle Values for each Major Area of Benefit shown in Table 4-2 of
the Company's Idaho Advance Metering Refresh Project.Application -Exh.A (Status Report)
at 26.
REQUESTNO.4:Please provide an Excel file with formulas intact and enabled that
supports the Company's estimated savings of $597,376 for Reduced Customer Calls shown in
Table 4-4 of the Company's Idaho Advance Metering Refresh Project.Application -Exh.A
(Status Report)at 30.
REQUESTNO.5:Please provide an Excel file with formulas intact and enabled that
supports the AMI Enabled Energy Efficiencyvalues for each Area of Benefit (Conservation
Voltage Reduction,Customer Energy Efficiency,Behavioral Energy Efficiency)shown in Table
4-5 of the Company's Idaho Advance Metering Refresh Project.Application -Exh.A (Status
Report)at 32.
REQUESTNO.6:Please describe all federal,including Department of Energy
("DOE"),electric AMI fundingopportunities or grants the Company has pursued or been
awarded.If no fundingor grants have been pursued or been awarded,please explain why not.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 25,2023
REQUESTNO.7:Please quantifyreduction in Full Time Equivalent ("FTE"),in an
Excel file with formulas intact and enabled,that will be achieved through implementation of the
proposed replacement metering system.Please break down the cost savings by business type
(electric and gas)and when they will be recognized.
DATED at Boise,Idaho,this K day of August 2023.
Adam Triplett
Deputy AttorneyGeneral
i:umise:prodreq/avue23.7_avug23.4 prod req l
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUGUST 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF AUGUST 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTTO AVISTA
CORPORATION,IN CASE NOS.AVU-E-23-07 /AVU-G-23-04,BY E-MAILING A
COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:david.meyer avistacorp.com
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE