20121217Staff 137-146 to Avista.pdf

KARL T. KLEIN
WELDON B. STUTZMAN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0318
IDAHO BAR NOS. 5 156/3283
RE CE U
7412 DEC 1 N I_I I 1. •
TLtTi MV1J
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 THE APPLICATION
OF AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
ELECTRIC AND NATURAL GAS SERVICE
IN IDAHO.
CASE NO. AVU-E-12-08
AVU-G-12-07
EIGHTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities requests that Avista Corporation (Company;
Avista) provide the following documents and information as soon as possible, by THURSDAY,
JANUARY 3,2013.'
This Production Request is to be considered as continuing, and Avista 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 produced.
Please provide answers to each question, including 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
Staff is asking for an expedited response. Please contact Staff's attorneys if you believe an expedited response will
be problematic.
EIGHTH PRODUCTION REQUEST
TO AVISTA 1 DECEMBER 17, 2012
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
IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 137: For the following electric rate schedules, please explain why the
Company is proposing the revenue increase be spread on a uniform percentage basis to the
energy billing components, rather than applying the revenue increase uniformly to all billing
components:
a.General Service Schedule 11/12
b.Large General Service Schedule 21/22
c.Extra Large General Service 25
d.Clearwater Paper Schedule 25P
e.Pumping Service Schedule 31/32
REQUEST NO. 138: On page 21 of Pat Ehrbar's Testimony, Table 6 shows the
Company serves one interruptible sales service customer on Schedules 131 or 132. Please
provide the number of times this customer has been curtailed over the last four years. As part of
your response, please compare the revenue from this customer during the test period to what
would have been collected had this customer been on a firm service schedule.
REQUEST NO. 139: Please explain how the Company determines the cost of providing
service to interruptible customers, particularly given the number, magnitude and duration of
interruptions may vary.
REQUEST NO. 140: Please explain how the Company allocates the costs of gas
distribution mains to the various rate schedules when the installation or expansion is necessary to
enhance system reliability or capacity. As part of your response, explain how the costs of
distribution mains used for looping are treated differently than other distribution mains of the
same diameter.
EIGHTH PRODUCTION REQUEST
TO AVISTA 2 DECEMBER 17, 2012
REQUEST NO. 141: Please explain how gas distribution mains less than four inches in
diameter contribute to the overall reliability and capacity of the system. As part of your
response, please explain how Schedule 146 customers might benefit from improved reliability
and additional capacity on the distribution system.
REQUEST NO. 142: The Company's gas Cost-of-Service study classifies distribution
mains into two categories: those less than four inches and those four inches or greater. Please
provide the number of distribution mains four inches or greater serving fewer than five
customers. As part of your response, please provide the change in revenue requirement for each
schedule if the cost of the large distribution mains serving fewer than five customers were
directly assigned to the customers served from these mains.
REQUEST NO. 143: Page 20 of Pat Ehrbar's testimony describes the purpose of having
Schedules 112 and 132. Please provide the number of customers who switched between
Schedule 146 and Schedules 112 or 132 during the test period. As part of your response, please
provide a detailed explanation of how fixed costs were annualized for the test period to account
for customers switching between schedules.
REQUEST NO. 144: If the Special Contract revenues and costs are not shown
separately in Cost-of-Service, please provide the revenues and costs from providing service to
Special Contract customers. If the Special Contract revenues and costs are shown separately,
please explain where they can be found.
REQUEST NO. 145: Please explain how the costs of the Company's pipeline
replacement program are allocated to each jurisdiction. Specifically, describe whether the
Company's cost allocation methodology for the program is commensurate with the replacement
of Aldyl A piping in each jurisdiction.
REQUEST NO. 146: Please provide estimates of Idaho's total construction costs and
rate impacts for Avista' s Aldyl-A replacement program under scenarios of 10 years, 15 years, 20
years, and 25 years. Assume the Company's proposed rate of return holding items other than
EIGHTH PRODUCTION REQUEST
TO AVISTA 3 DECEMBER 17, 2012
program costs constant. Provide the rate impact in dollars per customer, per schedule, per year.
Estimate the expected number of Aldyl-A leaks for each year of the program under each
scenario.
Dated at Boise, Idaho, this I I day of December 2012.
4:2 L) 72.
Karl . Klein
j) Deputy Attorney General
Technical Staff: Matt Elam/137-146
i:umisc:prodreq/avue 1 2.8 avugl 2. 7kkme prod req8
EIGHTH PRODUCTION REQUEST
TO AVISTA 4 DECEMBER 17, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF DECEMBER 2012,
SERVED THE FOREGOING EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-12-08
& AVU-G-12-07, 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]
DEAN J MILLER
McDEVITT & MILLER LLP
P0 BOX 2564
BOISE ID 83702
E-MAIL: joemcdevitt-miller.com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
515 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
greg,richardsonandoleary.com
ELECTRONIC SERVICE ONLY:
Howard Ray
Clearwater Paper Corporation
[e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST.
BOISE ID 83702
E-mail: [e-mail]
KELLY 0 NOR WOOD
VP STATE & FED REG
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
LARRY A CR0 WLEY
THE ENERGY STRATEGIES
INSTITUTE INC
55495 CLIFFSEDGE AVE
BOISE ID 83716
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading2mindspring.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710N. 6TH ST
BOISE ID 83702
E-mail: boUoidahoconservation.org
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-mail: kmil1ersnakerivera1liance.org
Jo %I1T/ SECRETARY
CERTIFICATE OF SERVICE