20110824ICL 1-6 to Avista.pdf

RECEIVED
Benjamin J. Otto (ISB No 8292)
710 N 6th Street
PO Box 844
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
bottotPidaoconservtion.org
2011 AUG 24 AM 10: 13
IOM'IO
UTILITIES
Attorney for the Idao Conservtion Leag
BEFORE TI IDAHO PUBliC UTUTES COMMISSION
IN THE MAITR OF A VISTA
CORPORATION REQUESTIG
APPROVAL TO DECREASE ITS
ENERGY EFFCIENCY PUBliC
PURPOSE RIDER SCHEDULE 91
AND 191
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CASE NO. AVU-E-1l-02
AVU-G-II-03
IDAHO CONSERVATION LEGUE'S
FIRST PRODUCTION REQUEST
COMES NOW the Idao Conservtion Leage ("ICL") with the followig
prouction requess. Along with the answer to each quesion, pleas provide any
supporting documents, workpapers, calculations, or information sources Avia relies upon
to support its answer. As requied by IDAPA 31.01.01.228.02, plea indicate the witnes
who ca answer question redig the response and who wi spnsor the reponse at any
potential heang. If any renses include Excel spreadsheets or other electronic fùes,
pleae provide them with all formulas intact and activated. As allowed by IDAPA
31.01.01.228.01, if the volume of any response indicates it would be more feaible to do so
ICL agrees to the Company depsiting the response in an electronic depository.
Ths production request is ongoing. Accordigly, ICL resctfuly asks Avia to
provide additional documents and information that may supplement any initial rense
ICLs First Production
Request to A vista 1 Augut 24,2011
REQUEST No 1. On page 2 of the Application Avita mentions energ efficiency
tarets established throug the Integrted Resource Plans (IRPs). Pleas provide a copy of
the IRPs usd to establish the effciency tarets for both electric and ga If Avita us
additional analysis, or relied upon additional resources to establish thes tarets, pleas
provide these also.
REQUEST No 2. Pleae provide the most recent study or other document that quatifies
the DSM potential for both ga and electric applicable to Avista's Idao servce terrtory.
REQUEST No 3. The Application states, on page 2, Avista achievd 105% of the IRP go
for electricity, but only 85% of the IRP goal for natur ga Pleas explain why thi recrd
of achievment supports a larer reduction in the ga rider tarf than the electric rider
tarff.
REQUEST No 4. The Application states on page 3:
"Avista has long encourged the diect-us of natur ga by its electric
cusomers. As an electric efficiency progr, the Compay is continuig
this effort with residential rebates for the conversion of electric and natur
ga space and water heat loads as well as a broad progr for any non-
residential electric to natur ga conversions meeting spcific criteria for
relative British Thermal Unit (BTU) effciency. The cos-effectiv potential
for thes measures has been incorprated into Avista's Integted Resource
Planning effort and are contaied withi the identified acquisition goal."
For electric to natur ga conversions pleas explai:
a. Whch IRP, electric or ga, the compay uss to establish the cost effective
potential and acquisition tarets for thes programs.
b. Whch tarff rider, electric or ga, provides the funds for these progrs.
ICLs First Production
Request to A vista 2 Augut 24,2011
REQUEST No 5. The Application states on page 6: "For 2010, the Company's portfolios
were cost-effective with TRC and PAC ratios of 2.33 and 5.02, repectively for its electric
portfolio and 1.62 and 3.60, respectively for its natur ga portfolio." Please provide:
a. The documentation supporting these calculations.
b. The results of any cost effectiveness tests at the progr level for both ga and
electric.
REQUEST No 6. Pleas explai why Avista proposes to reduce fundig for DSM when
the Company's portfolios are cost effective.
DATED this 24th day of Augt 2011.
~~
Benjamin J. Otto
Idao Conservtion Leage
ICLs First Production
Request to A vista 3 Augut 24, 2011
CERTIFICATE OF SERVICE
I hereby certif that on thi 24th day of Augut, 2011, I delivered true and corrct
copies of the foregoing IDAHO CONSERVA nON LEAGUE'S FIRST PRODUCTION
REQUEST to the followig persons via the method of servce noted:
Hand delivery
Jean Jewell
Commission Secretar (Original and three copies provided)
Idao Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
Emai only:
David J. Meyer, Esq.
Michael G. Andrea
Bruce Folsom
A vista Corpration
P.O. Box 3717
1411 E. Mission Ave.
Spokane, WA 99220-3727
David.meyertavistacorp.com
MichaeL.andreatPavistacorp.com
Bruce. folsomtPavitacorp. com
& &0\~
Benjamin J. Otto
--
ICLs First Production
Request to A vista 4 Augut 24, 2011