20190513Staff 22-32 to Avista.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
REC EIVED
l0l9 HAY l3 PH tr: 23
iDi\l'1.) PiJELIC
i.I ILiT] [S CCI,{MISSION
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 2OI4-201 7 NATURAL
GAS ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. AVU.G-18-08
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Matt Hunter, Deputy Attorney General, request that Avista Corporation (Company) provide the
following documents and information as soon as possible, or by MONDAY, JUNE 3,2019,
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
31.0t.0r.228.
THIRD PRODUCTION
REQUEST TO AVISTA
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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. 22: Please provide workpapers showing how the Target
Confidence/Precision (C/P) totals were calculated in Table 3-l: Planned Sampling and
Evaluation Rigor for Gas Residential Programs (:p.26) and Table 3-2: Planned Sampling and
Evaluation Rigor for Gas Nonresidential Programs (p.26) of the 2016-2017 Natural Gas Impact
Evaluation.
REQUEST NO. 23: Please provide workpapers showing how the Achieved Precision
values were calculated in Table 3-3: Achieved Sampling and Confidence/Precision for Gas
Residential Programs (p.27) and Table 3-4: Achieved Sampling and Evaluation Rigor for Gas
Nonresidential Programs (p.27) of the 2016-2017 Natural Gas Impact Evaluation were
calculated.
REQUEST NO. 24: Please provide workpapers showing how the Achieved Confidence/
Precision (C/P) values, including the Total, were calculated in Tables 3-3: Achieved Sampling
and Confidence/Precision for Gas Residential Programs (p.27), Table 3-4: Achieved Sampling
and Evaluation Rigor for Gas Nonresidential Programs (p.27), and 5-2: Residential Program
Achieved Evaluation Sample (p.60) of the 2016-2017 Natural Gas Impact Evaluation.
REQUEST NO. 25: For this production request, please refer to the MASTER tab of the
Avista Commercial Tracking Sheet 051618-lD Gas-for ID.xlsx and cross reference the projects
with the application numbers (App no.) in the table below:
THIRD PRODUCTION
REQUEST TO AVISTA MAY 1,3,20192
App No.Account Measure
73183 Hayden Car Wash SS Appliances
72811 Saint Dominic's Girls School SS Shell
72298 Community I't Bank SS Shell
68077 Rosauers Supermarkets, Inc.ESG SS Cases
The Company's process for reviewing potential site-specific projects is summarized on
pages 1l and 12 of the Impact Evaluation Report. For each project in the table, please provide a
detailed description of the review process including:
a. Samples of forms or reports submitted by individuals or organizations for
consideration as a site-specific project.
b. Procedures and calculations used by the Company in order to estimate the savings
of site-specific projects, including samples of the energy analyses/savings
estimates generated by Avista's engineers.
c. Does the Company typically conduct site visits and take measurements in the
course of its investigation? If so, please describe how information is gathered and
documented during the site-specific visit.
d. The criteria used by the Company to determine whether a proposed site-specific
project is viable.
e. The Technical Review Top Sheet used to ensure that project documentation is
complete.
f. A sample Energy Efficiency Evaluation Report with supporting calculations.
g. The Payment Top Sheet followed by Staff prior to incentive payment.
h. The checklist used to assure that the project has been appropriately documented,
tracked, and finalized.
REQUEST NO. 26: For each project in the table shown in Request No. 25, please
provide workpapers showing how the Simple Payback (Col H), KWH (Col I), THERM (Col J),
Incentive Electric (Col K), Incentive Gas (Col L), and Measure Cost (Col N) were calculated.
REQUEST NO. 27: Please refer to the MASTER tab of the Avista Commercial
Tracking Sheet 050318-ID Gas-for ID.xlsx and cross reference the projects with the application
numbers (App no.) in the table below. For each project listed:
a. Please explain the discrepancy between the (Col I) computed by the Company and
the KWH (BH) computed by Nexant.
b. Please explain the steps that the Company has taken to improve its energy savings
and cost savings estimates.
THIRD PRODUCTION
REQUEST TO AVISTA J MAY 13,2019
App No.Account Measure
68077 Rosauers Supermarkets, Inc.ESG SS Cases
REQUEST NO. 28: The Company's method for reviewing potential site-specific
projects is summarized on pages I I and 12 of the Impact Evaluation Report. Please explain how
the results of third-party evaluations, such as those conducted by Nexant, are used to improve
this process.
REQUEST NO. 29: When reviewing potential site-specific projects, does the Company
typically conduct site visits and take measurements in the course of its review to determine if a
project is eligible? If so, please describe how the information is gathered and documented during
the site-specifi c visit.
REQUEST NO. 30: Table 4-4:Energy Smart Grocer Reported Energy Savings by
Measure (p.38) states that four Energy Smart Grocer projects were completed in Idaho in2017;
however, Table 4-5: Energy Smart Grocer Achieved Sample (p.39) indicates that 12 audits and
six on-site inspections were conducted. A footnote under Table 4-6: Energy Smart Grocer
Impact Energy Realization Rate Results (p.41) indicates that the audit includes projects in
Washington and Idaho jurisdictions.
a. Please confirm that the audit described in Table 4-5 (p. 39) was conducted using
both Idaho and Washington projects. If not, please explain.
b. What was the total population size from which the sample of 12 projects in Table
4-5 was drawn?
c. Did the sample population only include projects from2017 or were 2016 projects
also included?
REQUEST NO. 31: Please provide project documentation for each sampled project
listed on page 39 for the Energy Smart Grocer program in Idaho, including invoices, savings
calculations, work order forms, equipment specification sheets, and copies of any other project
records that may exist.
THIRD PRODUCTION
REQUEST TO AVISTA 4 MAY t3,2019
REQUEST NO.32: Please provide workpapers showing how the Energy Realization
Rate and 80olo precision listed in Table 4-6: Energy Smart Grocer Impact Energy Realization
Rate Results of the Natural Gas Impact Evaluation Report were calculated.
Dated at Boise, Idaho, this t xt't-day of May 2019
rt
Matt
Deputy General
i :umisc:prodreq/avug I 8. Smhck prod req3
THIRD PRODUCTION
REQUEST TO AVISTA 5 MAY t3,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l3th DAY OF MAY 2019, SERVED
THE FOREGOING THIRD 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 CORPORATTON
PO BOX3727
SPoKANE W A 99220-3727
E-MAIL : I i rrda. qervai s/,iDavi stacorp.corn
avi staclockcts (g)av i staco rp. co rn
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: david.meyer(rtrvistacorp.som
CERTIFICATE OF SERVICE