20100706AVU to CAPAI 1, 2, 3, 5, 6, 8-13.pdf

Avlsta Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
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AII'STJI.
Corp.
ZOIU JUt -6 PM 3: 48
July 1,2010
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, il. 83702
Re: Production Request of the Communty Action Parership Association of Idaho (CAPAI
in Case Nos. A VU-E-10-0l and A VU-G-1O-01
Dear Mr. Pudy,
Enclosed are an original of Avista's responses to CAPAI production requests in the above
referenced docket. Included in ths mailng are Avista's responses to production requests 001,
002,003,005,006,008 through 013.
If there are any questions regarding the enclosed information, please contact me at (509) 495-
4584 or via e-mail atpaui.kiabll~avistacorp.comS~k
Paul Kimball
Regulatory Analyst
Enclosures
CC (Email): all pares electronic
.
.
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
AVU-E-1O-01 / AVU-G-10-01
IPUC
Production Request
CAPAI-001
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
07/0112010
Elizabeth Andrews
Paul Kimball
State & Federal Reg.
[phone]
Please provide the Company's two most recent FERC Form 1 report. If the report can be readily
obtaied (and prited) through the interet, or some other equally accessible means, then please
simply provide instrctions on how to access it.
RESPONSE:
Please see CAPAI_PR_001 Attachment A for the 2008 Form 1 and CAPAI_PR_001 Attchment
B for the 2009 Form 1. Due to the voluminous natue of ths data, it is being provided in electronic
format only
.
.
.
JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
AVU-E-10-01 1 AVU-G-10-0l
IPUC
Production Request
CAPAI-002
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
07/0112010
Elizabeth Andrews
Paul Kimball
State & Federal Reg.
[phone]
Please provide the Company's two latest anua report to shareholders. As with the FERC Form
1, directions to a readily obtaiable, alterative source will suffce.
RESPONSE:
Please see CAPAI_PR_002 Attchment A for the 2008 Shareholder report and CAPAI_PR_002
Attchment B for the 2009 Shareholder report. Due to the voluminous natue of ths data, it is
being provided in electronic format only
.
.
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
AVU-E-10-01 1 AVU-G-1O-01
IPUC
Production Request
CAPAI-003
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
07/0112010
Elizabeth Andrews
Paul Kimball
State & Federal Reg.
[phone]
Please provide the Company's two latest anual reports to the Secuties and Exchange
Commission or directions on how to obtai said reports though equaly accessible means.
RESPONSE:
Please see CAPAI_PR_003 Attachment A for the 2008 10K report and CAPAI_PR_003
Attchment B for the 2009 10K report. Due to the voluminous natue of ths data, it is being
provided in electronic format only
.
.
.
JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INORMTION
IDAHO
AVU-E-1O-011 AVU-G-1O-01
IPUC
Production Request
CAPAI-005
DATE PREPARD:WISS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
06/30/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Reg.
[phone]
Has the Company conducted, contracted for, or relied upon any price elasticity studies or models
in analyzing the consumption levels of its two-tiered block rate strctue for residential customers?
By this question, CAP AI seeks to know whether A VISTA has attempted to calculate a minimum
level of consumption for residential customers, regardless of the price.
RESPONSE:
The Company has not conducted or relied upon any price elasticity stuies specificaly related to
its curent electrc two-tiered block rate strctue for residential cutomers. However, the
Company uses its weather normalization model to estiate base load consumption. The two
blocks for Schedule 1 residential electrc customers generally reflect base-load (fist 600 kwhs)
versus non base-load consumption (over 600 kwhs) based on the results of regression analyses
used to determine weather-sensitive consumption. As is discussed in Mr. Ehrbar's testimony at
page 15, that the first block, which is the first 600 kWh's of usage, is stil representative of
base-load, with base-load being the minimum level of consumption for residential customers.
.
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
AVU-E-1O-0l 1 AVU-G-I0-0l
IPUC
Production Request
CAPAI-006
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
06/30/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Reg.
[phone]
If your answer to the preceding Request is in the affrmative, please provide a copy of said
study(ies) or model(s).
RESPONSE:
Please see the Company's response to CAPAI-005.
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.: .
REQUEST:
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
A VU-E-1O-01 1 A VU-G-1O-01
IPUC
Production Request
CAPAI-008
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
06/30/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Reg.
[phone]
On page 15 of his direct testimony, Mr. Ehrbar, relying upon a document produced by the U.S.
Deparent of Housing and Urban Development, quantifies the average residential monthy usage
at an average of 571 Kwh's. Does ths quantification include electrcity consumed for the purse
of electrc space heating?
RESPONSE:
Ths quantification was the average usage for lighting, refrgeration, and cooking and does not
include electrc space heat.
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
AVU-E-I0-0l 1 AVU-G-1O-01
IPUC
Production Request
CAPAI-009
DATE PREPARD:WISS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
06/30/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Reg.
[phone]
In any of his calculations of average monthly residential consumption, and the assumptions he
made in calculating said consumption, did Mr. Ehrbar take into account the degree of weather
effciency of low-income housing and the potential impact that varable might have on monthy
consumption? If so, please provide elaboration of Mr. Ehrbar's analysis in ths regard.
RESPONSE:
The calculations of average monthy residential consumption were derved from the average
anual usage tables included in Mr. Ehrbar's testimony (Tables 11 and 12) and as a result did not
take into account any other factors.
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
AVU-E-1O-01 1 AVU-G-1O-01
IPUC
Production Request
CAPAI-OlO
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
06/30/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Reg.
[phone]
On page 13 of his direct testimony, Mr. Ehrbar makes a monthy comparson of electrcity
consumed anually by non-LIHAP residential customers, to a sample group of
LIHEAP-recipient, residential customers. Based upon this sampling, what is the average total
monthy consumption for all residential customers compared to the average monthly consumption
of the sample group ofLIHEAP-recipient, residential customers?
RESPONSE:
As discussed in the Company's response to Staff-085, limited income electrc only customers use,
on average, 14,807 kilowatt hours per year, versus 12,908 kilowatt hours for regular income
customers. On a monthy basis, that would equate to 1,234 kWhs per month for limited income
customers versus 1,076 kWhs per month for all residential customers.
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO
AVU-E-I0-0l 1 AVU-G-I0-0l
IPUC
Production Request
CAPAI-0l1
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
06/30/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Reg.
[phone]
On page 13 of his direct testimony, Mr. Ehrbar, in discussing the possibilty of modifyng
AVISTA's existing two-tier residential rate block, states: "(t)urer rate inversion could result in
additional fixed costs recovered though an even higher tal block rate...." Please explain what
"additional fixed costs" Mr. Ehrbar is referg to and how fuer rate inversion would cause
recover of said costs to increase.
RESPONSE:
The point Mr. Ehrbar makes in his testimony was that, if the Company created a thrd block for
residential electrc schedule 1, some of the fixed costs that are being recovered in the existing two
block strctue would be shifted to an additional block. The recovery of fixed costs, therefore,
would be more volatile, as usage in the thrd block would var considerably based on weather.
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
AVU-E-I0-01 1 AVU-G-1O-01
IPUC
Production Request
CAPAI-012
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
06/30/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Reg.
[phone]
Does A VISTA track and maitain any data specific to residential class customers who are deemed
"low-income" by the Company using any crteria including, but not limited to, the critera used in
deterinng LIHEAP eligibilty
RESPONSE:
The only income specific data maintaned by the Company is for those customers who have
paricipated in LIHAP and Low-Income DSM programs. In order for customers to quaify for
these programs, their income must be at or below 125% of the Federal Pover Guidelines. The
varous communty action agencies which administer these programs income qualify these
customers. It is only when an agency grants an award that Avista can know that a specific
customer is "low-income".
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JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
AVU-E-1O-01 1 AVU-G-10-01
IPUC
Production Request
CAPAI-013
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
06/30/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Reg.
[phone]
If the answer to the preceding Request is in the affrmative, please state the critera used to
deterine whether a customer is "low-income," identify the natue of the data tracked and produce
said data.
RESPONSE:
Please see the Company's response to CAPAI-012.