20161222Staff 1-6 to AVU.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
HE CE IVE.D
"31Si.T( 22 A1 II: 29
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING OF AVISTA )
CORPORATION DBA A VISTA UTILITIES' 2016)
NATURAL GAS INTEGRATED RESOURCE )
PLAN )
)
)
) ___________________ )
CASE NO. AVU-G-16-03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that A vista Corporation (Company; A vista)
provide the following documents and information as soon as possible, but no later than
THURSDAY, JANUARY 12, 2017.
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
and if different, the witness who can sponsor the answer at hearing if need be. IDAP A
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.
FIRST PRODUCTION REQUEST
TO AVISTA 1 DECEMBER 22, 2016
REQUEST NO. 1: Page 1 of the Avista 2016 Natural Gas IRP Appendix lists
organizations and representatives that participated in the 2016 Natural Gas IRP TAC meetings.
Please provide the telephonic and in-person attendance records for each of the TAC meetings,
including attendee names and corresponding organizations. Additionally, please provide copies
of any notifications, flyers, or publications sent to the public regarding the 2016 Natural Gas
IRP.
REQUEST NO. 2: On page 133 of the Avista 2016 Natural Gas IRP, the Company
states: "Over the longer-term, targeted conservation programs may provide a cumulative benefit
that could offset potential constraint areas and may be an effective strategy." Please describe any
targeted conservation programs that have been considered in Idaho. As part of the response,
please explain how the Company evaluates and measures the cost-effectiveness of these
programs. If the Company has not considered targeted conservation programs in Idaho, please
explain why not and describe plans for future consideration.
REQUEST NO. 3: On page 46 of the Avista 2016 Natural Gas IRP, the Company
states: "Since the benefits of deferred capacity are a one-time cost, the benefits would be spread
over the life of a typical distribution upgrade (35 years) as an avoided payment. This component
of avoided costs was not included in this IRP and will be discussed with A vista's DSM Advisory
Group as well as the TAC to determine the correct approach for the 2018 IRP." Please explain
why this component of the avoided cost was not included in this IRP. Furthermore, please
provide schedules for discussions and meetings with the DSM Advisory Group and TAC where
the topic of distribution avoided costs will be addressed. If schedules have not been established,
provide best estimates for when discussions and meetings will occur.
REQUEST NO. 4: On page 111 of the Avista 2016 Natural Gas IRP, the Company
states that no supply resource deficiencies exist under the Average Case or Expected Case
scenarios within the 20-year planning horizon. However, the Company shows that several
distribution resource projects will be required within the planning horizon. Please explain how
the Company considered DSM as a least-cost way to defer or avoid the distribution projects
FIRST PRODUCTION REQUEST
TO AVISTA 2 DECEMBER 22, 2016
listed in Table 7.1 of the Avista 2016 Natural Gas IRP, particularly when it did not include the
value of deferred distribution capacity in the avoided cost calculation.
REQUEST NO. 5: Please provide a detailed description of the Coeur d'Alene High
Pressure Reinforcement project listed in Table 7.1 to include why the project is needed, how
much capacity will be added, what alternatives the Company explored, and why this is the least­
cost solution.
REQUEST NO. 6: Please explain differences in A vista's projections of customer
growth, consumption, and demand. For example on page 39, the Company projects customer
growth of 1.1 %, but only predicts that demand will grow at a rate of 0.36%. Please provide any
relevant workpapers with formulae intake.
~
DATED at Boise, Idaho, this J/J; .. ::day of December 2016.
Technical Staff: Kevin Keyt (1-5)
Mike Morrison ( 6)
i:umisc:prodreq/avugl6.3dhkskmm prod reql avista
FIRST PRODUCTION REQUEST
TO AVISTA
Dap Huang
Deputy Attorney General
3 DECEMBER 22, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22nd DAY OF DECEMBER 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G-16-03,
BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE