20180815Staff to Avista 1.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
IMPLEMENT FIXED COST ADJUSTMENT
RATES FOR NATURAL GAS SERVICE FROM
NOVEMBER 1,2018, THROUGH OCTOBER 31,
2019
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CASE NO. AVU.G.18.O3
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83]02-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Sean Costello, Deputy Attorney General, request that Avista Corporation (Company) provide the
following documents and information as soon as possible, or by WEDNESDAY, AUGUST 29,
2019.1
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 Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA AUGUST I5,2018
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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. l: On page 8 of its Application, the Company estimates that the
Company's DSM programs reduced residential usage by approximately 282,000 therms/yr and
non-residential usage by approximately 70,000 therms/yr in2017. Please answer the following
a. What was the base year used to determine the 2017 reduction in consumption?
b. Please provide the Company's estimate of the total weather-normalized change in
consumption over the same time period for the same customer groups.
Dated at Boise, Idaho, this /t'day of August 2018.
Sean
Deputy Attomey General
i:umisc:prodreq/avue1 8.3scck prod req I
FIRST PRODUCTION REQUEST
TO AVISTA 2 AUGUST I5,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF AUGUST 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G-I8-03,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIRECTOR OF RATES
AVISTA CORPORATION
PO BOX3727
SPoKANE W A 99220-3727
E-MAIL: [e-mail]
avistadockets@ avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE