20130103Staff 160-181 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
pc r' C 'r: n
PM 1:39
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
TENTH 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 24, 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 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.
TENTH PRODUCTION REQUEST
TO AVISTA JANUARY 3, 2013 1
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. 160: Please provide the workpapers used to create "Illustration No. 1" on
page 33 of Ehrbar's testimony.
REQUEST NO. 161: Is the Energy Efficiency Load Adjustment (EELA) calculated using
net or gross energy savings?
REQUEST NO. 162: Please provide the net and gross energy savings for each of Avista's
Idaho DSM programs included in the EELA for 2011 and YTD for 2012. Please provide sources
for all unit energy savings and net-to-gross estimates.
REQUEST NO. 163: Please provide the projected net and projected gross energy savings
for each of Avista's Idaho DSM programs included in the EELA for 2013. Please provide sources
for all unit energy savings and net-to-gross estimates.
REQUEST NO. 164: Please provide the annual and daily load shapes for each program in
Avista's Idaho DSM portfolio in 2011 and 2012, and projections for 2013.
REQUEST NO. 165: Are energy savings generated by NEEA for Avista in Idaho included
in the EELA? If so, please provide the actual savings for 2011, YTD savings for 2012, and
projected savings for 2013 generated by NEEA in Avista's Idaho service territory. Please provide
sources for all unit energy savings.
REQUEST NO. 166: Are energy savings produced by codes and standards included in the
EELA? If so, please provide the actual savings for 2011, YTD savings for 2012, and projected
savings for 2013 produced by codes and standards in Avista's Idaho service territory. Please
provide sources for unit energy savings.
REQUEST NO. 167: Are energy savings produced by distribution efficiency included in
the EELA? If so, please provide the actual savings for 2011, YTD savings for 2012, and projected
TENTH PRODUCTION REQUEST
TO AVISTA 2 JANUARY 3, 2013
savings for 2013 produced by distribution efficiency in Avista's Idaho service territory. Please
provide sources for all unit energy savings.
REQUEST NO. 168: Are energy savings produced by fuel-switching measures included in
the EELA? If so, please provide the actual savings for 2011, YTD savings for 2012, and projected
savings for 2013 produced by fuel-switching measures in Avista's Idaho service territory. Please
provide sources for all unit energy savings.
REQUEST NO. 169: If fuel-switching measures are included in the EELA, what
corresponding adjustments did the Company make to natural gas billing determinants?
REQUEST NO. 170: Please explain how the EELA incorporates the effects of a likely
reduction in the electric avoided cost for 2013, which could result in a reduction of cost-effective
energy savings.
REQUEST NO. 171: Since part of the pro forma EELA is based on energy savings
projections for 2013, how does the Company intend to reconcile the discrepancy if actual savings
turn out to be lower than the projected estimates?
REQUEST NO. 172: Please provide aMW and peak MW reductions associated with each
of Avista's Idaho DSM programs included in the EELA for 2011, 2012 and 2013.
REQUEST NO. 173: Please provide the results of an AURORA net power cost run using
loads adjusted to reflect the energy and demand savings included in the EELA. Please provide a
copy of all files used to make the AURORA run.
REQUEST NO. 174: Please provide actual and weather normalized electric loads and
average customer counts by class for 2007 through 2011.
REQUEST NO. 175: Did Avista consider whether lesser truck loader models, such as the
D8 or D9, were adequate for expected projects before purchasing the Caterpillar Dl 0? If so, please
explain how the decision was made to purchase the Caterpillar D10?
TENTH PRODUCTION REQUEST
TO AVISTA 3 JANUARY 3, 2013
REQUEST NO. 176: Please provide the evaluation mentioned on page 24 of Lafferty's
testimony supporting the installation of the hydrogen gas generator at CS2.
REQUEST NO. 177: Has the Washington Department of Ecology ruled on the water rights
acquired in 2011 by Avista? If so, what was the finding?
REQUEST NO. 178: Please provide the terms (amount, cost, seller, length, etc.) associated
with the $ 1.075 million water rights procurement.
REQUEST NO. 179: Please provide a list of all PM&E measures, including cost and
completion dates, for the Clark Fork River included in the Company's filing. Please indicate
whether measures are one-time or ongoing.
REQUEST NO. 180: Please provide a list of all PM&E measures, including cost and
completion dates, for the Spokane River included in the Company's filing. Please indicate whether
measures are one-time or ongoing.
REQUEST NO. 181: Please list the pro forma generation additions/upgrades included in
the AURORA power cost model. Please specify the capacity (or capacity upgrade) and availability
of each asset as modeled.
Dated at Boise, Idaho, this 3 ("i day of January 2013.
Weldon B. 46tzman
Deputy Attorney General
Technical Staff: Stacey Donohue/ 160-171
Bryan Lanspery/1 72-181
i:umisc:prodreq/avuel2.8_avugl2.7wsblsd prod reql 0
TENTH PRODUCTION REQUEST
TO AVISTA 4 JANUARY 3, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF JANUARY 2013,
SERVED THE FOREGOING TENTH 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]
KELLY 0 NOR WOOD
VP STATE & FED REG
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
ELECTRONIC SERVICE ONLY: DEAN J MILLER
PAUL KIMBALL McDEVITT & MILLER LLP
AVISTA CORPORATION P0 BOX 2564
E-MAIL: [e-mail] BOISE ID 83702
E-MAIL: j [e-mail]
LARRY A CR0 WLEY
THE ENERGY STRATEGIES
INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 83716
E-MAIL: [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
515 N 27TH STREET
BOISE ID 83702
E-MAIL: Deter(r1chardsonando1earv.com
greg(richardsonando1eary.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(mindspring.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N. 6TH ST
BOISE ID 83702
E-MAIL: botto(idahoconservation.org
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
ELECTRONIC SERVICE ONLY:
HOWARD RAY
CLEAR WATER PAPER CORPORATION
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019N 17TH ST.
BOISE ID 83702
E-MAIL: [e-mail]
SECRET
CERTIFICATE OF SERVICE