20120924Staff 1-5 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
RE CE 1 V ED
7,012 SEP 24 AM 9: 24
WbLika
I jM
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING OF AVISTA)
CORPORATION DBA AVISTA UTILITIES' 2012)
NATURAL GAS INTEGRATED RESOURCE )
PLAN (IRP). )
)
)
)
CASE NO. AVU-G-12-8
FIRST 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 MONDAY,
OCTOBER 15, 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.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUESTS OF
THE COMMISSION STAFF TO AVISTA 1 SEPTEMBER 24, 2012
Request No. 1: Regarding Appendix 3.3 WA/ID Base Coefficient Calculation (page 40
of the Appendices), please provide the following tables:
a.Average Actual Demand by Class
b.Average Actual Customer Count by Class
c.Base Coefficients.
Please provide in electronic format with all formulas intact.
Request No. 2: Please send the data used to derive the WA/ID regression statistics found
in Appendix 3.3 (page 41 of Appendices). Please provide in electronic format.
Request No. 3: Please clarify why Figure 6.8 shows Existing Resources vs. Average
Day Demand (Net of Demand-side Management (DSM)) and Figure 6.12 shows WA/ID
Existing Resources vs. Peak Day Demand (Net of DSM) in light of the filings to suspend DSM
programs in Washington and Idaho. Please provide updated figures that are not net of DSM.
Request No. 4: Please provide the formulas used to forecast the number of customers
and a detailed description of the data used. Does your forecast implicitly assume that the
penetration of gas appliances remains constant in all types of new construction across time? If
so, please provide your support for this assumption.
Request No. 5: Please provide a copy of the Risk Management Policy referenced on
page 5.15.
DATED at Boise, Idaho, this 2 q 4 day of September 2012.
Karl T. Klein
Deputy Attorney General
Technical Staff: Cathleen McHugh
i :umisc:prodreq/kkcmavugl 2.8.doc
FIRST PRODUCTION REQUESTS OF
THE COMMISSION STAFF TO AVISTA 2 SEPTEMBER 24, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24"'DAY OF SEPTEMBER 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA, IN CASE NO. AVU-G-12-08, BY MAILING A
COPY THEREOF, POSTAGE PREPAID AND VIA E-MAIL, TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
SEC TARY
CERTIFICATE OF SERVICE