20090303Staff 1-21 to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
Q'i:":Cr:1 '''i ~ ._ 1-1 ')
2009 MAR -3 AM 9: 37
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO.
)
) CASE NO. A VU-E-09-1) AVU-G-09-1
)
) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO A VISTA CORPORATION
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that A vista Corporation (Company;
Avista) provide the following documents and information on or before TUESDAY,
MARCH 24, 2009.
FIRST PRODUCTION REQUEST
TO AVISTA MARCH 3, 2009
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: On page 4, lines 7-8, of Bruce Folsom's pre-filed testimony is the
statement that "...Virtually all customers have had the opportunity to paricipate and a great
many have directly benefited from the (energy efficiency) program offerings." Please provide an
estimate for the number of different customers by customer class who participated in one or
more of Avista's energy efficiency programs in 2008.
REQUEST NO.2: Please provide a copy of all the customer communications materials
used by A vista in 2008 to promote customer participation in its energy effciency programs.
REQUEST NO.3: A) Please provide a copy of Avista's marketing plan for its energy
effciency programs. B) Please provide a description and schedule for TV, newspaper, radio
advertising, bil inserts, direct mailers, etc. used to promote these programs. C) Does A vista
target high energy users with direct offers of energy audits? If so, please explain. If not, why
not?
REQUEST NO.4: For Avista's Idaho-funded DSM portfolio, please provide a
breakdown of total costs in 2008, including incentive payments to paricipants, direct program
FIRST PRODUCTION REQUEST
TO AVISTA 2 MARCH 3, 2009
administrative costs, direct program evaluation costs, and allocated indirect administrative and
evaluation costs with a description of how such allocations were made.
REQUEST NO.5: For each Idaho-funded DSM program please provide the pre-
implementation estimated post-implementation evaluation budget and the amount actually spent
on post-implementation evaluations from 2004 through 2009 to date. Where Idaho costs are an
allocation of larger costs, explain the allocation method.
REQUEST NO.6: Please list and briefly describe all post-implementation evaluations
of Idaho-funded DSM programs or general DSM management completed by or for Avista from
2004 through 2009 to date. Include in the descriptions the evaluation costs and the names and
affiiations of the primar evaluators and the process(es) by which any 3rd pary evaluators were
chosen. Include both internal and external evaluations of direct energy and peak demand
impacts, program processes, portfolio management, and educational and/or market
transformation effects. Provide copies of, or readily accessible references to, each report listed.
REQUEST NO.7: Please describe how post-implementation evaluations or informal
questions regarding assumptions have been used by A vista to improve its DSM programs and/or
to improve its overall resource planing. Include supporting discussion notes, letters and
memorandums, all whether on paper or electronically distributed. (An example of an informally
questioned assumption is the life of vending misers.)
REQUEST NO.8: Please provide post-implementation benefit/cost (B/C) ratios
estimated by or for Avista's energy effciency programs in Idaho with electronically executable
cost-effectiveness formulae. Include B/C ratios from all perspectives considered, e.g. TRC,
Utilty, Paricipant and Non-Participant. Include complete descriptions of, and bases for, all
assumptions (e.g. net-to-gross savings ratios, measure life, discount rate,), values (e.g. demand,
energy and non-energy savings, tax credits) and calculations used in estimating the B/C ratios.
Describe all sensitivity analyses of any variables and assumptions used in estimating B/C ratios.
FIRST PRODUCTION REQUEST
TO AVISTA 3 MARCH 3, 2009
REQUEST NO.9: To the extent that assumptions and variable values of post-
implementation B/C ratios differ from those used in pre-implementation DSM "potential"
studies, please describe and explain those differences.
REQUEST NO. 10: Please describe any post-implementation DSM program
evaluations that are not yet completed, but are currently in progress.
REQUEST NO. 11: Please describe any post-implementation DSM program
evaluations that are currently in a planing stage.
REQUEST NO. 12: Beginning on page 16, line 24, of Bruce Folsom's pre-fied
testimony is a summary of cost-effectiveness of Avista's combined energy effciency efforts in
Washington and Idaho. There seems to be an implication that if program benefits exceed costs,
then the program is de facto prudent. Is a B/Cratio greater than 1.0 A vista's sole criterion for
determining the success of its programs? Or does the Company also evaluate program success
based on possible alternative demand-side costs, e.g. whether all expenses and direct and indirect
administration and overhead are reasonable and necessary and whether a program's customer
incentives are set to maximize net utilty benefit? If so, please provide documented examples of
the use of such additional criteria.
REQUEST NO. 13: On page 9, lines 19-22, of Bruce Folsom's pre-fied testimony is an
estimate of NEE A savings of2.0 aMW (17,520 MWH) in 2007 in Avista's service area
(Washington and Idaho) at a cost of 0.07 cents/kWh. Assuming Mr. Folsom's 0.07 cents per
kWh has a misplaced decimal point, please provide the assumptions and calculations the
Company and/or NEEA used to estimate those savings numbers and any analyses by Avista to
assess the veracity of those electricity savings, the value of such savings, and an estimate for the
share of those savings that benefit Idaho customers. If available, please provide similar
assumptions, calculations and analyses for 2008.
FIRST PRODUCTION REQUEST
TO AVISTA 4 MARCH 3, 2009
REQUEST NO. 14: Please provide copies of customer and vendor complaints to Avista
or its contractors from 2006 through 2008 regarding any of its energy effciency programs. Also
provide the ultimate resolutions of such complaints.
REQUEST NO. 15: Please separately identify and quantify any Idaho Tariff Schedule
91 or 191 funds used for personnel, administration and/or marketing expenses related to
promotion of renewable energy resources or expenses related to bil payment assistance.
REQUEST NO. 16: Please provide copies of all demand side management (DSM), e.g.
energy efficiency, conservation or demand response, business plans prepared by or for Avista
Utilties from 2004 through 2008 in which its Idaho service area is included.
REQUEST NO. 17: Please provide an organization char of Avista's Demand Side
p
Management unit, including its placement within the larger A vista organization.
REQUEST NO. 18: Please provide names and job titles with descriptions of duties for
all A vista employee positions in the Demand Side Management unit.
REQUEST NO. 19: Please provide the salar range, bonus range, and total
compensation range, including benefits, for each employee in the Demand Side Management
unit.
REQUEST NO. 20: Please provide resumes of all employees in the Demand Side
Management unit. (Personal information not pertinent to A vista duties may be redacted).
REQUEST NO. 21: A) Please provide the total number of Avista employees outside the
Demand Side Management unit for which the tariff riders paid some portion of their
compensation or other expenses. B) Please provide the total amount of such employee
compensation or other expenses funded by the taiff riders.
FIRST PRODUCTION REQUEST
TO AVISTA 5 MARCH 3, 2009
Dated at Boise, Idaho, this ~ day of March.
~~a~
KriS A&iSšer
Deputy Attorney General
Technical Staff: Lynn Andersonll-21
i:umisc:prodreq/avue~09. lksla prod reql.doc
FIRST PRODUCTION REQUEST
TO AVISTA 6 MARCH 3, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF MARCH 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA, IN CASE NOS. AVU-E-09-01 & AVU-G-09-01, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220
E-MAIL: david.meyer(ßavistacorp.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(ßmcdevitt-miler.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(ßgivenspursley.com
mcc(ßgivenspursley.com
KELL Y NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwood(ßavistacorp.com
SCOTT ATKINSON
PRESIDENT
IDAHO FOREST GROUP LLC
171 HIGHWAY 95 N
GRANGEVILLE ID 83530
E-MAIL: scotta(ßidahoforestgroup.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
SUITE 250
1500 LIBERTY STREET SE
SALEM OR 97302
E-MAIL: dpeseau(ßexcite.com
.YaL
SECRETARY
CERTIFICATE OF SERVICE