20190926Staff 33 to Avista.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
Street Address for Express Mail:
1 1331 W. CHINDEN BLVD, BLDG 8 SUITE 2OI.A
BOISE, IDAHO 83714
Attorney for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2014.2017 NATURAL
GAS ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. AVU-G-I8.08
FOURTH 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 THURSDAY,
ocToBER 10,2019.1
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
I Staffis requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at [phone].
FOURTH PRODUCTION
REQUEST TO AVISTA
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SEPTEMBER26,2OI9
RUC EIVED
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and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0t.0r.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.33: Please answer the following questions related to Table 1 reflecting
data from the Company's Conservation Report shown below:
a. Please explain why 2017 savings in Table 1 were 155% of the Company's natural
gas IRP target. If some programs were more popular than anticipated by the
Company-such as the fuel efficiency program, please explain why the Company
did not forecast this level of uptake during the planning process; and
b. Please explain why the UCT for natural gas savings increased between 2016 and
2017 (1.45 to 2.35). Staff previously understood that the Company manages its
DSM portfolio toward a 1.0 UCT to maximize the amount of cost-effective
savings, but this appears to be moving in the opposite direction. Please explain
this change.
Table 1. Gas
Dated at Boise, Idaho, this >{16 day of September 2019
Hunter
Deputy Attorney General
i:umisc:prodreq/avugl 8.8mhck prod req4
FOURTH PRODUCTION
REQUEST TO AVISTA SEPTEMBER26,2OI92
Metric 2016 2017
Energy Savings 189,297 therms 305,508 therms
IRP Target 114,000 therms 197,640 therms
Expenditures 91,029,227 $ 1,135,471
Utility Cost Test 1.45 2.35
Total Resource Cost Test 0.49 0.62
CERTIFICATB OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF SEPTEMBER 2019,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
coMMrssroN STAFF To AVISTA CORPORATION, IN CASE NO. AVU-G-18-08,
BY MAILTNG A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: [e-mail]
av i stadoc kets@av i stacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-MAIL : dav'id. mel'er(Zr-ravi stacorp.com
CERTIFICATE OF SERVICE