20151118Staff 1-10 to Avista.pdf

BRAND,N KARPEN n*flt:t\i nn
DEPUTY ATTORNEY GENERAL
IDAH, PUBLIC ,TILITIES coMMISSIoN ?fl15 ilov lB At{ ll: 28
PO BOX 83720 r;1r,,!-,^i lt;L,i_ ..,
BOTSE, rDAHO 83720-0074 uirr_lTiiiC0i,Il.ttsstol',l(208) 334-03s7
IDAHO BAR NOS.7956
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 AVISTA CORPORATION )
FOR THE REQUEST TO RESUME NATURAL ) CASE NO. AVU-G-15-03
GAS EFFICIENCY PROGRAMS SCHEDULE )
I9O AND INCREASE ITS ENERGY ) FIRST PRODUCTION
EFFICIENCY RIDER ADJUSTMENT ) REQUEST OF THE
SCHEDULE r9l. ) COMMISSION STAFF TO
) AVISTA CORPORATION
)
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, by
WEDNESDAY, DECEMER 2, 2015.r
This Production Request is 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 produced.
Please provide answers to each question, 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
t Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffls
attomey at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA NOVEMBER 18,20I5
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0t.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. 1: Please provide a cost-effectiveness forecast for the first year of
Avista's Idaho natural gas programs. This forecast should include the same information
provided in Table l: Washington Natural Gas Programs Cost-Effectiveness (Application at 7).
Please explain how the Company calculates the UCT, TRC, PCT, and RIM for each program and
include all associated workpapers and files with formulas intact.
REQUEST NO.2: Please provide all inputs the Company uses in its Idaho natural gas
cost-effectiveness calculations. This should include cost and savings estimates, the avoided cost,
the real WACC, the demand portion of Schedule 150, and non-energy benefits. Please provide
sources for all inputs.
REQUEST NO.3: Please provide the Company's avoided cost calculation in Excel
format with all formulas intact. Please identify and describe all components (including the
WACOG) and formulas.
REQUEST NO. 4: Please explain in detail why the Company believes the demand
portion of the PGA is a more accurate representation of the total costs to deliver natural gas from
the wellhead to the customer meter than variable transmission costs.
REQUEST NO. 5: Table 7 .2 in the Company's 20L4IRP (Integrated Resource Plan)
shows a $10 million high pressure gas reinforcement upgrade in2016 and2017 and two
additional upgrades expected after 2019. Please describe how energy efficiency programs could
reduce or defer the need for these capacity upgrades (e.g. location-specific targeted marketing).
Please include all financial analysis and an explanation of how the timing of these projects could
change.
FIRST PRODUCTION REQUEST
TO AVISTA NOVEMBER 18, 2015
REQUEST NO. 6: Please describe how the Company uses net-to-gross estimates when
determining whether to implement and how to manage natural gas conservation programs. If the
Company does not consider net-to-gross estimates, please explain why not. Furthermore, please
estimate how applying a net-to-gross to the UCT could impact cost-effectiveness.
REQUEST NO. 7: Please describe in detail how the budget in Table 2: Estimated2016
Idaho Natural Gas Budget (Application at 9) was developed. Please explain the type of expenses
included in each category and how the estimates were determined. Please include all associated
workpapers and files.
REQUEST NO. 8: Please describe in detail how the per therm increases listed in
Schedule 191 were calculated for each rate schedule. Please include all associated workpapers
and files with formulas intact.
REQUEST NO. 9: Please provide a table that identifies the rate schedules from which
the 233,000 first year achievable therm savings will be acquired.
REQUEST NO. 10: Please provide evidence that "levelized incentives of $3.00 per first
year therm savings for any project with a simple payback less than l5 years and capped at 70Yo
of the project cost" (Application at 8) is reasonable and consistent with industry standards.
Dated at Boise, Idaho, tn s lfaay of November 2015.
Technical Staff: Kevin Keyt
Stacey Donohue
Donn English
i:umisc:prodreq/avugl5.3bkksksdde prod reql
FIRST PRODUCTION REQUEST
TO AVISTA
Deputy Adtorney General
NOVEMBER 18, 2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF NOVEMBER 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G-15-03,
BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LINDA GERVAIS
MANAGER, REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPoKANE W A 99220-3727
E-MAIL: linda. [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE