20131223Staff 20-67 to AVU.pdf

KARL T.KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX $3720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.5156
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-59 18
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
FINDING THAT IT PRUDENTLY INCURRED
ITS 2010-2012 ELECTRIC AND NATURAL
GAS ENERGY EFFICIENCY
EXPENDITURES.
)
CASE NO.AVU-E-13-09
AVU-G-13-02
)SECOND 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
JANUARY 13,2014.
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.
SECOND PRODUCTION REQUEST
TO AVISTA
)
)
)
1 DECEMBER 23,2013
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.20:Page $of the 2012 Idaho Electric Impact Evaluation Report says
the low-income program had a 102%realization rate,but only achieved 24%of the Integrated
Resource Plan (IRP)goal.If realization rate was over 100%,please explain how the program
missed the IRP target so significantly.
REQUEST NO.21:Please explain the purpose of the General Population Survey and
how it differs from the Residential Building Stock Assessment (RBSA)conducted for the region
by Northwest Energy Efficiency Alliance (NEEA).
REQUEST NO.22:Please provide an electronic and three hard copies of the General
Population Survey report.
REQUEST NO.23:Please explain why Avista hired Cadmus to develop savings
estimates for the upstream compact fluorescent light bulb (CFL)program when the Regional
Technical Forum (RTF)already provided savings for those measures.If Avista believes that the
program mechanism or delivery method is substantially different from what the RTF evaluated,
please explain the differences in detail.
REQUEST NO.24:Please explain why Avista hired Cadmus to determine energy
savings for refrigerator recycling when those estimates are available from the RIF.If Avista
believes that the program mechanism or delivery method is substantially different from what the
RTF evaluated,please explain the differences in detail.
REQUEST NO.25:Please explain why the electric Energy Smart grocer program does
not use energy savings estimates from the RTF.If Avista believes that the program mechanism
or delivery method is substantially different from what the RTF evaluated,please explain the
differences in detail.
SECOND PRODUCTION REQUEST
TO AVISTA 2 DECEMBER23,2013
REQUEST NO.26:Please explain why Avista was incenting Energy Star dishwashers
when that measure stopped passing most northwest utilities’cost-effectiveness tests several years
ago.
REQUEST NO.27:Please explain why it was reasonable to use 245 washing cycles per
year for dishwasher energy savings estimates when the RTF (based on Residential Building
Stock Assessment data)uses 170 washing cycles and the U.S.Department of Energy uses 215
washing cycles per year.
REQUEST NO.2$:Cadmus justifies using 245 dishwasher annual washing cycles
based on “recent evaluation surveys conducted in the region.”Footnotes 17 and 18 identify
these evaluations as a Pacific Power evaluation and a Rocky Mountain Power evaluation,but
does not identify the authors of either evaluation.Please identify the authors of these
evaluations.
REQUEST NO.29:Please explain why it was reasonable to estimate dishwasher
savings based on methods currently used in the ENERGY STAR calculator,but it was not
reasonable to use the U.S.DOE estimation of annual washing cycles.
REQUEST NO.30:Please explain why it was reasonable to use an amalgamation of
sources (the ENERGY STAR calculator methodology,RTF data inputs,Cadmus-adjusted
baseline,and washing cycles based on northwest data)to construct dishwasher energy savings
rather than use the energy savings estimates provided by the RTF.If Avista believes that the
program mechanism or delivery method is substantially different from what the RTF evaluated,
please explain the differences in detail.
REQUEST NO.31:Please explain why Cadmus modified the RTF baseline for
refrigerators and freezers to assume that 0%of baseline units would be Energy Star.
REQUEST NO.32:Page 39 of the Cadmus evaluation says that “Cadmus calculated
the average base case and the efficient case Energy Factor (EF)[for clothes washers]with both
SECOND PRODUCTION REQUEST
TO AVISTA 3 DECEMBER 23,2013
based on data by the RTF.The baseline EF equaled the average market efficiency of units not
qtialifying for the program,and the efficient EF equaled the market average efficiency of units
qualifying for the program at the time of their rebate.”Please explain why the Company used a
baseline unit market efficiency that assumed no units would qualify for the program.
REQUEST NO.33:Page 19 of the Cadmus evaluation titles a section “Uniform
Methods Project (UMP)and RTF Protocols,”but no reference to the RTF appears in the
following paragraphs.Please explain the discrepancy and supply any missing language.
REQUEST NO.34:Please explain why Avista and Cadmus chose to conform to UMP
rather than some other regionally or nationally accepted standard.
REQUEST NO.35:Please provide RTF clothes washer Unit Energy Savings (UES)for
2010,2011,and 2012 and the Cadmus 2009 UES.If Avista believes that the program
mechanism or delivery method is substantially different from what the RTF evaluated,please
explain the differences in detail.
REQUEST NO.36:Page 34 of the Avista 2012 Idaho Electric impact evaluation reads
“Cadmus updated the analysis for this [clothes washer]evaluation to improve the accuracy of the
savings estimated.”Please fully explain what updates were made,how the updates improved the
accuracy of the savings estimates,and provide the post-update UES.
REQUEST NO.37:Please explain the source and calculations for $36,356 of non
energy benefits produced by the 2012 Electric Energy Star Appliance program.
REQUEST NO.38:Please provide source and calculations for the non-energy benefits
produced by the Nonres-Food Service Equipment electric program for 2010,2011,and 2012.
REQUEST NO.39:Please provide the source and calculations for non-energy benefits
associated with the Nonres-Site Specific Electric program in 2010,2011,and 2012.
SECOND PRODUCTION REQUEST
TO AVISTA 4 DECEMBER 23,2013
REQUEST NO.40:Are Avista’s programs designed to be cost effective under the Total
Resource Cost Test (TRC)or Utility Cost Test (UCT)at the state and program level on an annual
basis?Please explain.
REQUEST NO.41:Since the program does not appear to have been discontinued,
please explain why most of the 2012 data was listed as “nla”for the Non-residential Electric
Premium Efficiency Motors program on page 56 of Exhibit 2,Schedule 1.
REQUEST NO.42:Please provide Avista’s demand-side management (DSM)
organizational charts for 2010,2011,and 2012.
REQUEST NO.43:Please provide all internal communications that led to the
Company’s decision to dissolve the independence of the internal evaluation and the
implementation teams.
REQUEST NO.44:Please explain why Avista never discussed the change in the
independent status of the internal evaluation team with Avista’s Energy Efficiency Advisory
group.
REQUEST NO.45:Please explain how Avista’s internal evaluation team can
effectively evaluate the work of Avista’s implementation team if it is no longer independent from
the implementation team.
REQUEST NO.46:Please provide all drafts of the 2012 Process Evaluation
Memorandum.
REQUEST NO.47:Please provide the “Best Practice Comparative Review”memo
delivered in February 2013.
SECOND PRODUCTION REQUEST
TO AVISTA 5 DECEMBER 23,2013
REQUEST NO.48:Please explain why Avista sent only one-third of projects with
incentives over $50,000 to the Planning,Policy,and Analysis (PPA)team for review in 2012,
even though Avista did not suspend the review process until January 1,2013.
REQUEST NO.49:The planned process improvements include a Technical Review
and Administrative Review (formalized as “Top Sheets”),both of which are conducted by the
implementation team.Please explain how having the implementation team check its own work
is a sufficient replacement for the previously independent review of the PPA group.
REQUEST NO.50:Please explain how having the evaluation team “spot check”the
implementation team’s work after the project has entered into a contract or after the incentive has
been paid protects ratepayers against funding imprudent incentive expenses.
REQUEST NO.51:While the PPA independent review of large projects was in place
(August 2011-January 2013),please provide the percentage of reviewed projects that were
found to:1)rely too heavily on customer data,2)use incorrect interactive effects,3)have
missing documentation (such as invoices),or 4)contain engineering errors that resulted in
incorrect claimed savings and incorrect incentive amounts.
REQUEST NO.52:Please provide a trend chart of all non-incentive utility program
costs as a percentage of total DSM program costs from 2002 to 2012.
REQUEST NO.53:Please provide the number of employees or fTEs by which the
natural gas DSM team was reduced after the suspension of Idaho natural gas DSM.If there was
no reduction in staff,please explain why not.
REQUEST NO.54:for each renewable measure that was incented under Schedules 90
and 190,please provide:the type of measure,the year installed,the sector,the incentive paid,the
total cost of the installation for the participant,measure life,ex ante and ex post savings and the
methods used to obtain savings estimates,and the cost-effective calculations with clearly defined
SECOND PRODUCTION REQUEST
TO AVISTA 6 DECEMBER 23,2013
assumptions.Please include the cost-effectiveness calculations in an executable excel file with
formulas intact.
REQUEST NO.55:Please provide a detailed list of measures that were not compliant
with DSM tariff rules.For each measure,please provide the simple payback period,the incented
amount and whether or not the measure exceeded the 50%cap.Please provide the specific cost-
effectiveness calculations that demonstrate the measure was still cost-effective.
REQUEST NO.56:Please provide a complete list of measures that the Company
believes are subject to the tariff rules under “market transformation”as included in Schedule 90C
and 190C.
REQUEST NO.57:Please provide the amount of measures (“legacy measures”)and
incentives that were paid after each DSM tariff revision from 2010 through 2012.Please provide
the date the rebate was calculated and subsequently processed.
REQUEST NO.58:Please provide the amount of incented measures that had measure
lives less than 10 years.Please delineate by sector,program,and if it is site-specific or
prescriptive.
REQUEST NO.59:What was the total expenditure for site specific projects with
incentive costs that exceeded the 50%incentive cap?
REQUEST NO.60:Please explain how Idaho ratepayers benefit from paying for a
Conservation Potential Assessment every two years.
REQUEST NO.61:Please explain Avista’s “new approach”for reviewing site-specific
projects (Cadmus memo,August 2,2013).
SECOND PRODUCTION REQUEST
TO AVISTA 7 DECEMBER 23,2013
REQUEST NO.62:Please explain how the 2012 claimed energy savings for the non
residential Standby Generator Block Heater program increased by 54%from 2011,but only
increased by 1 rebate (from 4 rebates in 2011 to 5 rebates in 2012).
REQUEST NO.63:How many educational training sessions did the Company host for
Residential New Construction vendors?Please provide the information by year and location.
REQUEST NO.64:Why did the Residential Energy Star Homes program decline by
over 50%from 2010?What outreach was done by the Company to solicit participants?Please
delineate by year.
REQUEST NO.65:Please provide all labor costs charged to the DSM rider for the
years 2002-20 12,both in dollar amount and as a percentage of total DSM expense.
REQUEST NO.66:Please provide the number of FTE’s funded by the DSM rider for
the years 2008-20 12.
REQUEST NO.67:Please indicate if there is an incentive threshold at which incentives
require approval from the internal evaluation team or PPA team.
Dated at Boise,Idaho,this day of December 2013.
Karl T.Klein
Deputy Attorney General
Technical Staff:Stacey Donohue/20-53
Nikki Karpavichl54-64
Donn EnglishI6S-67
i:umisc:prodreq/avue 13 .9_avugl 3.2kkdesdnk prod req2
SECOND PRODUCTION REQUEST
TO AVISTA $DECEMBER 23,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY Of DECEMBER 2013,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NOS.AVU-E-13-09/
AVU-G-13-02,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
DAVID J MEYER LINDA GERVAIS
VP &CHIEF COUNSEL MGR REGULATORY POLICY
AVISTA CORPORATION AVISTA CORPORATION
P0 BOX 3727 P0 BOX 3727
SPOKANE WA 99220-3 727 SPOKANE WA 99220-3 727
E-MAIL:david.rneyeravistacorp.corn E-MAIL:[e-mail]
SECRETAJ’
CERTIFICATE OF SERVICE