20120815Staff 1-17 to Avista.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RECEVED
?U12UG 15 11112: 1 -1
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S APPLICATION TO )
REVISE NATURAL GAS EFFICIENCY )
PROGRAMS AND RIDER ADJUSTMENT, )
SCHEDULES 190 AND 191. )
)
)
)
CASE NO. AVU-G-12-03
AVU-G-12-06
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that Avista Corporation (Company; Avista)
provide the following documents and information as soon as possible, by WEDNESDAY,
AUGUST 29, 2012.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, 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
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 AUGUST 15, 2012
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide all workpapers supporting Avista's request to
decrease Schedule 191, including, but not limited to, monthly forecasted expenses and revenue
by class.
REQUEST NO. 2: Please explain why language relating to market transformation
efforts was struck from the revised Schedule 190.
REQUEST NO. 3: Please provide the Total Resource Cost test, Program Administrator
Cost test, Participant Cost test, and Ratepayer Impact Measure cost-effectiveness ratios for each
of Avista's Idaho natural gas demand-side management programs.
REQUEST NO. 4: Please provide the TRC and PAC calculations with formulas intact
for each of Avista's Idaho natural gas DSM programs. These calculations should include
avoided cost, measure lives, and sources for energy savings.
REQUEST NO. 5: Please provide Avista's existing natural gas avoided costs.
REQUEST NO. 6: Please provide Avista's previously anticipated natural gas avoided
costs as referenced on page 2, line 3 of the AVU-G- 12-03 application.
REQUEST NO. 7: Please provide Avista's new natural gas avoided costs anticipated
for publication in August 2012 natural gas Integrated Resource Plan.
REQUEST NO. 8: At what natural gas wholesale price does Avista anticipate that its
Idaho natural gas DSM portfolio would become cost-effective?
REQUEST NO. 9: On page 2, lines 18-26 of the AVU-G-12-03 application, Avista
describes five major scenarios which it scrutinized "in an attempt to ascertain if any reasonable
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 15, 2012
calculation of its DSM portfolio or modifications to the avoided cost would a yield a portfolio
that is cost-effective under the TRC test." Please provide detailed explanations and workpapers
for each scenario to support Avista's conclusion on page 3, lines 2-3, that "generally the most
optimistic scenario led to benefit-to-cost ratios in the low 0.70 range."
REQUEST NO. 10: On page 2, line 20 of the AVU-G-12-03 application, Avista states
that one of the scenarios scrutinized for cost-effectiveness was the "inclusion of a natural gas
distribution capacity cost value" in the avoided cost. Does Avista normally exclude natural gas
distribution capacity value in its avoided cost? Please explain.
REQUEST NO. 11: Please provide the number of participants for each of Avista's
Idaho gas DSM programs for the last five years.
REQUEST NO. 12: Please provide the number of Idaho homes funded by Avista's gas
low income weatherization program in calendar years 2007-2011.
REQUEST NO. 13: For those homes identified in your response to the previous
question please provide: a) average cost per home with administrative fees included, b) average
cost of home without administrative fees, c) total administrative fees paid to the CAP for
weatherization of homes, and d) total payments paid to the Community Action Partnership for
weatherization of homes.
REQUEST NO. 14: Are homes weatherized under Avista's gas low income
weatherization program required to have gas space and/or water heating? Please explain.
REQUEST NO. 15: Please provide a copy of Avista's current contract for low income
weatherization with the Lewiston CAP agency.
REQUEST NO. 16: Please provide the estimated TRC ratio for Avista's gas low
income weatherization program if each dollar of non-utility investments in health, safety, and
repair measures was counted as a dollar of non-energy benefits.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUGUST 15, 2012
REQUEST NO. 17: In 1997 the Commission approved Avista's request to suspend its
natural gas DSM programs when declining avoided costs caused those programs to be cost-
ineffective. Please describe the process and timeline by which Avista reconstructed its gas DSM
programs when avoided costs rebounded.
DATED at Boise, Idaho, this I day of August 2012.
gl ~ g-:~
Karl T. Klein
Deputy Attorney General
Technical Staff: Stacey Donohue (1- 8, 11, 16 -17)
Beverly Barker (9-10, 15)
Curtis Thaden (12-14)
i:umisc:prodreq/avue12.7kksd prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 AUGUST 15, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF AUGUST 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G-12-
03/AVU-G-12-06, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
LINDA GERVAIS
MANAGER, REGULATORY POLICY
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3726
E-MAIL: linda. gervais(avistacorp.com
Jo iLy&
SECRETAR7
CERTIFICATE OF SERVICE