20181220Staff 11-21 to Avista.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
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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 THE APPLICATION OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2014.2017 NATURAL
GAS ENERGY EFFICIENCY EXPENSAS AS
PRUDENTLY INCURRED.
CASE NO. AVU.G.I8.O8
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
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 THURSDAY,
JANUARY 10,2018.
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. Reference IDAPA
3t.01.01.228.
FIRST PRODUCTION REQUEST
TO AVISTA
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1 DECEMBER 20, 2018
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. 11: Please provide electronic work papers showing the derivation of all
figures presented in Exhibit 2,Table ES-4.
REQUEST NO. 12: On page 25 of Exhibit 2, Nexant explains that it created bins for
residential and non-residential programs in Washington/Idaho, and Natural gas programs in
Washington. Please answer the following questions:
a. Why was no natural gas bin created for Idaho?
b. Were Idaho customers included in Nexant's audit of the Company's Natural Gas
programs? If so, how many residential and non-residential customers were
included in Nexant's analysis?
c. Were Idaho customers included in Nexant's Billing Analysis of the Company's
Natural Gas programs? If so, how many residential and non-residential customers
were included in Nexant's analysis?
d. Were Idaho customers included in the surveys sent by Nexant to evaluate its
natural gas programs? If so, how many residential and non-residential customers
were included in Nexant's analysis?
REQUBST NO. 13: On pages 25 and26 of Exhibit 2, Nexant explains how it
determined sample sizes for its Electrical residential and non-residential programs; however, it
does not explain how it determined sample sizes for its natural gas programs. Please explain
how sample sizes were calculated for the Company's natural gas programs.
REQUEST NO. 14: Exhibit 1, Equation 3-2 includes the variables "event" and the
interaction term, "treat X event." Neither of these is described in Table 3-5. Please provide a
description for these variables. Also, please explain why the variable "treat" is not included in
the model.
FIRST PRODUCTION REQUEST
TO AVISTA 2 DECEMBER 20, 2018
REQUEST NO. 15: Exhibit 1, Section 4.8 indicates that the Company's nonresidential
realization rates range from 42oh (Energy Smart Grocer) to 142o/o (Commercial Insulation).
What steps is the Company taking to improve the accuracy of the methodologies used to estimate
nonresidential program savings?
REQUEST NO. 16: Exhibit 1, Section 5.8 indicates that the Company's residential
realization rates range from2SYo (Low Income Conservation) to 212% (Energy Star Homes).
What steps is the Company taking to improve the accuracy of the methodologies used to estimate
residential program savings?
REQUEST NO. 17: Exhibit l, Section 4.7.3.4 discusses the "Program-stipulated
electric energy (Therms) saved per unit installed." Is this wording correct? If so, please explain
how electric energy savings are considered in the Company's natural gas efficiency program.
REQUEST NO. 18: Exhibit l, Section 4.7.4 (Findings and Recommendations) states,
"The gross verified electric energy savings for the sample of reviewed projects for the Small
Business program resulted inarealization rate of 1060/o (Table 4-30)." Given that this refers to
savings of a gas DSM program, is this wording regarding electric energy savings correct? If so,
please explain how electric energy savings are considered in the Company's natural gas
efficiency program.
REQUEST NO. 19: Please confirm that the total savings of -118,905 Therms reported
in Exhibit 1, Table 5-13 represents an increase in natural gas consumption.
REQUEST NO. 20: Are the fuel efficiency savings reported in Exhibit l, Table 5-13,
corrected for the effects of weather? If so, please explain how this was done.
REQUEST NO. 21: Please provide the technical manual(s) used to estimate DSM
energy efficiency savings for 2016 and2017.
FIRST PRODUCTION REQUEST
TO AVISTA J DECEMBER 20, 2018
Dated at Boise, Idaho, this l''l* aurof December 2018.
(
Sean
Deputy Attorney General
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FIRST PRODUCTION REQUEST
TO AVISTA 4 DECEMBER 20, 2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF DECEMBER 2018,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G.18-08,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-MAIL: linda. qer:vaisG),avistacorp.corn
avi stac{ockets ljl)avi stac clrp. corn
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W499220-3727
E-MAIL: david.mer"erQ)avistacorp.com
CERTIFICATE OF SERVICE