20230828Staff 1-5 to AVU.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL c -
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
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 )CASE NO.AVU-E-23-10
APPROVAL TO DECREASE ITS ENERGY )
EFFICIENCY TARIFF RIDER ADJUSTMENT )SCHEDULE 91 )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that AVISTA CORPORATION ("Company")
provide the followingdocuments and information as soon as possible,but no later than
TUESDAY SEPTEMBER 5,2023'.
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 telephone number of
I Staff is 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 1 AUGUST 28,2023
the person preparing the documents.Please also identify 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 with formulas intact and enabled.
REQUESTNO.1:Please explain the difference between the revenue conversion factor
from the June Monthly Report for the Commissioners in the "ID-Sch91 Forecasted-Act Rev"tab,
of .99565,and the revenue conversion factor in the DSM Workpapers provided with the
Application in the "Rev Conv Factor"tab,of .996223.
REQUESTNO.2:Please explain how the Company developedits expense forecasts for
this filing.
a.If the Company used the expense forecast provided in the previous rider
adjustment,Case No.AVU-E-22-09,as a basis please describe the factors that the
Company adjusted when updating the forecast;and
b.Please note which factors are driving the reduced expenditures in each August and
March of the forecast period.
REQUESTNO.3:Please explain what measures the Company has taken to mitigate
project delays associated with COVID-19 impacts.
REQUESTNO.4:Please explain when the Company forecasts the COVID-19 related
issues to abate.
REQUESTNO.5:Please explain if the Company has conducted any analysis on the
quantity,magnitude,and cause of project delays since DSM projects resumed operations.
a.If yes,please provide said analysis;and
b.If not,why not.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 28,2023
DATED at Boise,Idaho,this day of August 2023.
Claire Sharp
Deputy AttorneyGeneral
i:umise:prodreq/avue23.10cslejjtet prod req l
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUGUST 28,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28*DAY OF AUGUST 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-E-23-10,
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:[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE