20100223Staff 1-15 to AVU.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
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2010 FEB 23 PM \2: 58
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING BY AVISTA )
CORPORATION DBA AVISTA UTILITIES OF )
ITS 2009 NATURAL GAS INTEGRATED )
RESOURCE PLAN (IRP). )
)
)
)
CASE NO. A VU-G-09-6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA
, The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Donald L. Howell, II, Deputy Attorney General, requests that A vista Corporation dba A vista
Utilties (A vista; Company) provide the following documents and information as soon as
possible, but no later than TUESDAY, MARCH 9, 2010.
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
For each item, please indicate the name ofthe person(s) preparng the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
FIRST PRODUCTION REQUEST
TO AVISTA 1 FEBRUARY 23,2010
REQUEST NO.1: As par of demand forecasting, please explain the "demand
influencing factors" that were reviewed in an attempt to quantify customer growth and usage per
customer. Where applicable, please provide the executable electronic analysis of your review.
REQUEST NO.2: Please explain why peak day demand (Dth/day) is expected to
increase at a faster rate than anual average daily demand (Dth/day) from 2009-2029.
REQUEST NO.3: On page 3.10, when specifying the price elasticity factor used in the
IRP, it's mentioned that the AGA price elasticity study compared favorably to your past
estimates. Please provide an explanation of how the AGA price elasticity study compared to
your past estimates. In your response, please provide executable electronic copies of both
studies.
REQUEST NO.4: On page 1.5, when modeling the "Expected Case" price elasticity,
the IRP states: "We have assumed a low response to prices in our Expected Case, parly based on
a conservative assumption that tight economic conditions and declining real estate values may
deter many customers from investing in long-term capital intensive conservation measures in the
near term." When determining customer willngness to invest in long-term capital intensive
conservation measures, do you quantify the impact of Federal Stimulus measures associated with
energy effciency? If you do, explain how? If not, explain why?
REQUEST NO.5: On page 1.12, one of the 2010-2011 Action Plan items is to
"continue to monitor the discussion around diminishing Canadian natural gas imports and look
for signals that indicate increased risk of disrupted supply." Since a substantial portion of the
Company's supply comes from Canadian sources, please explain the "signals" Avista wil
monitor indicating increased risk of disrupted supply.
REQUEST NO.6: On page 2.2, the IRP states: "Because our transportation only
customers purchase their own natual gas and delivery on our distribution system is non-firm, we
exclude these customers from our long-term resource planing." Do you forecast the number of
FIRST PRODUCTION REQUEST
TO AVISTA 2 FEBRUARY 23, 2010
non-firm transporttion customers and plan for distribution to serve them? If you do, explain
how? If not, explain why?
REQUEST NO.7: Please provide a 2007 IRP comparson for Idaho and Washington in
a format similar to Figures 2.5 and 2.6.
REQUEST NO.8: Please provide an explanation of how long-term Global Insight data
was combined with local knowledge about sub-regional construction activity, age, demographic
trends, and historical data to develop a 20-year customer forecast. Please provide the Global
Insight data, sub-regional data, and forecast analysis in executable electronic format.
REQUEST NO.9: Please provide a scatter plot comparison of daily demand and
temperature for each class in a format similar to Figure 3.2?
REQUEST NO. 10: When modeling use per customer by class, and then checking the
modeling coeffcients for reasonableness, please explain why use of a very low adjusted r-square
statistic for July and August is reasonable. In your response, please include an explanation of
how this might impact the modeled results and how it wil be reconciled in the next IRP.
REQUEST NO. 11: On page 3.5, it's mentioned that in Oregon, multiple weather
stations are used for weather normalization because the weather in locations where natural gas
services are provided don't correlate. However in eastern Washington and northern Idaho, the
only location used for normalization is the Spokane airport. What is the correlation between the
Spokane airport weather station and other weather stations within Washington and northern
Idaho where natural gas services are provided? In your response, please include a comparison of
how the Washington and northern Idaho weather stations correlate compared to how the four
weather stations in Oregon correlate.
REQUEST NO. 12: When preparing the peak day demand forecast, please explain why
Februy 15th is the peak date modeled for the Idaho/Washington service terrtories, but
December 20th is the peak date modeled for the Oregon service terrtories. When reviewing the
FIRST PRODUCTION REQUEST
TO AVISTA 3 FEBRUARY 23, 2010
summar of record setting HDD for Idaho/Washington service territories, the dates are more
aligned with December.
REQUEST NO. 13: Please explain how the 2005 Oregon conservation analysis
completed by RL W Analytics was used to extrapolate the technical potential in Washington and
Idaho. In your response, please provide the RL W Analytics conservation analysis and the
corresponding executable electronic fies associated with extrapolating the Oregon results to
Washington and Idaho.
REQUEST NO. 14: On page 4.8, when describing the North Division's conservation
goals, the IRP states: "As more participation occurs in specific applications and technologies,
program implementers and engineers use results to establish more prescriptive approaches in
order to increase participation without having to add additional infrastructure." Please give
examples of these approaches.
REQUEST NO. 15: On page 7.2, when modeling "Peak Day Demand by Case," the
IRP states: "The price increase in 2015 is a result of significant carbon cost adders for climate
change policy going into effect," please explain how the carbon adder was modeled, how the
2015 estimated cost per ton of carbon was chosen, and how the contingencies associated with
your forecasts were identified.
Respectfully submitted this 23 day of February 2010.
"~
Deputy Attorney General
Technical Staff: Matt Elam
i: :umisciprodreqlavug09 ,6dhme,doc
FIRST PRODUCTION REQUEST
TO AVISTA 4 FEBRUARY 23,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF FEBRUARY 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST TO A VISTA, IN
CASE NO. AVU-G-09-06, BY MAILING A COPY THEREOF, POSTAGE PREPAID
AND VIA E-MAIL, TO THE FOLLOWING:
GREGRAHN
A VIST A CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: greg.rahrfavistacoro.com
CERTIFICATE OF SERVICE