20181213Staff 1-10 to Avista.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
R[CEIV ['D
:i0 0[t] i3 Pi'i 2: 3l
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITTES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2OI4-201 7 NATURAL
GAS ENERGY EFFICIENCY EXPENSAS AS
PRUDENTLY INCURRED.
CASE NO. AVU-G-18-08
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,
Sean Costello, Deputy Attorney General, request that Avista Corporation (Company) provide the
following documents and information as soon as possible, or by THURSDAY,
JANUARY 3, 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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I DECEMBER 13,2018
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. 1: Please provide a list in Excel format showing all expenses charged
to the gas DSM Rider from20l4 to 2017. Please include the following information for each
expense: the date, vendor, amount, program, and the account to which the charges were accrued.
Please include and identify any adjustments made from20l4 to 2017 to previously booked
expenses. Please separate all expenses by program. If any amounts are allocated to multiple
programs and/or jurisdictions, please describe the allocation method. Please identify if each
expense is an incentive payment, purchase, service, labor/admin, materials, or any other
classification of expense.
REQUEST NO. 2: Please provide copies of all internal audit reports for all audits
completed on the Company's gas DSM expenses and processes from 2014 through 2018.
REQUEST NO. 3: Please provide invoices for all third party evaluators for 2016 and
2017. Please illustrate how those costs were allocated among jurisdictions.
REQUEST NO. 4: Please provide the gas tariff rider revenue by month and by class for
2016 and20l7.
REQUEST NO. 5: Please provide the calculation of any carrying charge on the gas
Rider balance from2074 to 2017.
REQUEST NO. 6: Please provide all work papers to support the cost-effectiveness of
each measure offered and incented.
REQUEST NO. 7: Please describe how common costs are allocated among the services
and jurisdictions.
FIRST PRODUCTION REQUEST
TO AVISTA 2 DECEMBER 13,2018
REQUEST NO. 8: Please provide all bids, contracts, and engagement letters for
evaluation services for the 2016-2017 biennium.
REQUEST NO. 9: Please provide the amount of labor expense charged to the gas DSM
tariff rider for the years 2013 to 2018. For each of those years, please include the number of Full
Time Equivalent positions funded by the rider. Please also provide the general wage adjustment
percentage for non-union personnel approved by the Compensation Committee of the Board of
Directors for each year.
REQUEST NO. 10: Please provide the data used to produce Table 3-19 in both the
2016 and 2017 Annual Reports in Excel format with all functions intact.
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Dated at Boise, Idaho, this P day of December 2018.
Sean Costello
Deputy Attomey General
i:umisc:prodreq/avug I 8.8scbl prod reql
FIRST PRODUCTION REQUEST
TO AVISTA aJ DECEMBER 13,2018
CERTIF'ICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF DECEMBER 2018,
SERVED THE FOREGOING FIRST 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 BOX3727
SPOKANE W A 99220-3727
E-MAIL : I i nda. ger:vais@)avistacorp.com
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DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: david.me,ver(Oavistacor?.com
CERTIFICATE OF SERVICE