20140205Staff 68-70 to AVU.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL ii : ; n ;r _-., o, , r,-:* r *IDAHO PUBLIC UTILITIES COMMISSION ;.!.I I :,.t1i... i;.,
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S APPLICATION FOR A ) CASE NO. AVU-E-13-09
FINDING THAT IT PRUDENTLY INCURRED )
ITS 2010-2012 ELECTRTC AND NATURAL )
AVU-G-13-02
GAS ENERGY EFFICIENCY
EXPENDITURES.
) THIRD PRODUCTION
) REQUEST OF THE) coMMrssroN 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
WEDNESDAY, FEBRUARY 19, 2014.1
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
I Staff seeks an expedited response. If responding by February lg,2014 will be problematic, please contact Staffs
attorney.
THIRD PRODUCTION REQUEST
TO AVISTA 1 FEBRUARY 4,2014
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. 68: Staff Production Request No. 55 asked the Company to list the
measures that did not comply with DSM tariff rules. The Company responded, in summary,that
the "Company followed processes and procedures as set forth in DSM tariff Schedule 90," but
"Schedule 90 previously did not ... mention ... prescriptive ... programs." The Company thus
"proposed and received approval of additional language [to clarify] how these programs are
offered and designed in compliance with tariff rules." See Response to Staff Production Request
No. 55. With regard to the Company's response, does the Company contend that all the
measures in its prescriptive programs complied with DSM tariff rules?
a. If so, please explain why the Company disagrees with the Cadmus 2012 Process
Evaluation conclusion that74% of nonresidential prescriptive projects did not comply with tariff
rules to cap project incentives at 50Yo of the incremental cost of the project. See Cadmus memo,
August 2,2013,p.7.
b. If not, please list each measure in the Company's prescriptive programs that did not
comply with DSM tariff rules and, for each listed measure, please provide: (i) the simple
payback period, (ii) the incented amount, (iii) whether or not the measure exceeded the 50% cap;
and (iv) the specific cost-effectiveness calculations that demonstrate the measure was still cost-
effective.
REQUEST NO. 69: In response to Staff Production Request No. 56, the Company lists
two programs as being subject to the tariff rules under "market transformation." Please explain
the Company's definition of "market transformation" and how "market transformation"
programs contrast with other energy efficiency programs.
THIRD PRODUCTION REQUEST
TO AVISTA FEBRUARY 4,2014
REQUEST NO. 70: In response to Staff Production Response No. 54, the Company
indicates that none of its 11 renewable projects were cost-effective. See Response to Staff
Production Request No. 54 (disclosing that each renewable project had a TRC and UCT of less
than one). Why did the Company incent renewable projects that were not cost-effective? How
many customers who participated in a renewable project participated in additional DSM
progftrms (spillover)?
Dated at Boise, Idaho, this 51t day of February 2014.
Technical Staff: Nikki Karpavich
i:umisc:prodreq/avue 13.9_avugl3.2kknk prod req3
THIRD PRODUCTION REQUEST
TO AVISTA
/('l t'-
Karl T. Klein
Deputy Attomey General
FEBRUARY 4,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5., DAY oF FEBRUARY 2014,
SERVED THE FOREGOING THIRD 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
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: [e-mail]
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: linda. [e-mail]
CERTIFICATE OF SERVICE