20131211Staff 1-19 to AVU.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, TDAHO 83702-5918
Attorneys for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CoRPORATION'S APPLICATION FOR A ) CASE NO. AVU-E-13-09
FINDTNG THAT rr PRUDENTLY TNCURRED ) AVU-G-13-02
rrs 2010-2012 ELECTRTC AND NATURAL )
GAS ENERGY EFFICIENCY ) FIRST PRODUCTIONEXPENDITURES. ) REQUEST OF THE
) COMMISSION STAFF TO
) AVTSTA 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 2,2014.
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.
FIRST PRODUCTION REQUEST
TO AVISTA DECEMBER I1, 2013
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. 1: Please list all expenses charged to the Idaho DSM Rider ("Rider")
for the years 2010-2012. Please include date, vendor, amount, and a brief description of the
expense. Please separate expenses by year and by program. If any expenses were allocated to
Idaho, please provide the total system expense and the method of allocating Idaho's share.
REQUEST NO. 2: Please provide the Rider revenue by year and by class for the years
2010-20t2.
REQUEST NO.3: Please provide the calculation of any carrying charge on the Rider
balance for the years 2010-2012.
REQUEST NO. 4: Please provide a list of all external consulting and evaluation fees
paid from the rider during 2010-2012. Please indicate how any of those expenses were allocated
between j urisdictions.
REQUEST NO. 5: Please provide a justification of funding for the Northwest Energy
Efficiency Alliance ("NEEA"). Please include all savings attributed to Avista's Idaho
jurisdiction from NEEA for each year (2010-2012), along with amounts paid to NEEA as a part
of the current cycle funding agreement. Please report the savings for each year: 1) based on
funding allocation, and2) based on sales data for Avista's Idaho service territory.
REQUEST NO. 6: Please provide an electronic copy and three hard copies of Avista's
Technical Reference Manual.
REQUEST NO. 7: Please provide the Requests for Proposals ("RFPs") for all
evaluation services between 2010 and 2012 and all responses to those RFPs. Also, please
provide the number, location, and duration of all RFP advertisements.
FIRST PRODUCTION REQUEST
TO AVISTA DECEMBER 11, 2OI3
REQUEST NO. 8: Page l0 of Ms. Hermanson's testimony says Cadmus was retained
for another two years in part to provide a "deeper evaluation for the 2012 and 2013 program
years." Please explain in detail the deep evaluation services Cadmus provided in the contract
extension that could not have been provided by another evaluator.
REQUEST NO. 9: Page l0 of Ms. Hermanson's testimony says Cadmus was retained
for another two years in part to conduct "some market analysis for the 2012 and 2013 electric
and gas DSM portfolio." Please explain market analysis, how it is differs from a Conservation
Potential Assessment, and why it is necessary for gas DSM in Idaho which was suspended in
20t2.
REQUEST NO. 10: Besides health and safety measures, what other non-energy benefits
("NEBs") were included in the low income cost-effectiveness calculation?
REQUEST NO. 11: Page 9 of the Avista 2012ldaho Electric Impact evaluation
recommends that Avista o'consider analyzing easy to quantiff NEBs, which could be added to the
programs for cost-effectiveness reporting." Please explain which NEBs are being referenced and
how they might be analyzed.
REQUEST NO. 12: Pages 13 and 20 of the Avista 2}l2[daho Electric Impact
evaluation read "Error! Reference Source Not Found." Please provide the correct reference
source for each of those omissions.
REQUEST NO. 13: Page l9 of the Avista 2012ldaho Electric Impact evaluation
includes a paragraph that ends with an incomplete sentence: The diversity of the." Please
provide the complete sentence and any missing supplemental sentences.
REQUEST NO. 14: Page 16 of the 2012Process Evaluation Memorandum contains a
line that reads "(see Error! Not a valid bookmark self-reference.)." Please provide the correct
reference source for the omission.
FIRST PRODUCTION REQUEST
TO AVISTA DECEMBER 11, 2013
REQUEST NO. 15: Please explain why Avista used 2009 Cadmus evaluation data for
clothes washer energy savings estimates rather than then-current Regional Technical Forum
("RTF") data.
REQUEST NO. 16: Please list the projects, incentive payments, and locations for all
Office of Energy Resources ("OER") projects that Avista incented in20l0,20ll, and20l2.
REQUEST NO. 17: Please provide the percentage of residential, commercial, and
industrial customers who participated in Avista's DSM programs in 2010, 2011, and20l2.
REQUEST NO. 18: Please explain why Avista does not track the Residential New
Construction program separately from the Residential Home Improvement program.
REQUEST NO. 19: Please provide Avista's cost-effectiveness calculations, including
all input and assumptions in executable Excel format, for the TRCruCT Simple Steps Smart
Savings program in 2012 (17 .04) and 20 1 I ( I .95).
Dated at Boise, Idaho, this \W auy of Decemb er2013.
W |L.
Karl T. Klein
Deputy Attorney General
Technical Staff: Donn English/l-5
Stacey Donohue/6-19
i : umisc:prodreq/avue I 3.9_avug I 3.2kkdesd prod req I
FIRST PRODUCTION REQUEST
TO AVISTA DECEMBER 11, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I ITH DAY oF DECEMBER 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATTON, IN CASE NOS. AVU-E-13-09/
AVU-G-I3-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPoKANE W A 99220-3727
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-MAIL: [e-mail] E-MAIL: [e-mail]
CERTIFICATE OF SERVICE