20190820Staff 1-7 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
IMPLEMENT FIXED COST ADJUSTMENT
RATES FOR NATURAL GAS SERVICE
FROM NOVEMBER L, 2019, THROUGH
ocToBER 31, 2019.
&€,cFtyso
f#jgdU8 ?B pff trr t I
, :,, {i:i'',., C,. ;'#,,i[a*,On
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
)
CASE NO. AVU-G-19.04
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,
Dayn Hardie, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than TUESDAY,
SEPTEMBER 3, 2019.1
This Production Request is to be considered as continuing, and Avista Corporation 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
t Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 AUGUST 2O,2OI9
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided in response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide the number of new natural gas customers by month
for January 2019 through June 2019.
REQUEST NO. 2: On page 7, lines 12-15 of the Application, Avista lists the effects of
three drivers (weather, energy efficiency and other) on use-per-customer and FCA Revenue for
the residential and non-residential group. Please provide supporting documentation for these
calculations including Excel workbooks with formulas intact and enabled.
REQUEST NO. 3: On page 7 of its Application, the Company estimates that the
Company's DSM programs reduced residential usage by approximately 400,000 therms in 2018
and non-residential usage by approximately 100,000 therms in 2018.
a.) Please reconcile these results to the Company's 2076,2017, and2018 DSM
reports and any other reports that apply. Please provide supporting
documentation for these calculations including Excel workbooks with formulas
intact and enabled.
b.) Please provide the Company's estimate of the total weather-normalized change in
consumption in 2018 for the same customer groups.
REQUEST NO. 4: Please provide all internal audit reports and SOX reports detailing
the FCA revenue determination since 2017. This includes any safeguards or internal controls
used to ensure that the revenue report is accurate.
REQUEST NO. 5: Please provide an explanation of the process used for the creation of
revenue reports provided in the workpapers.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 2O,2OI9
REQUEST NO. 7: Please provide all internal audit reports and SOX reports regarding
the new customer process since 2017.
DATED at Boise, Idaho, this2Ol?^rof August 2019.
REQUEST NO. 6: Please describe the process, safeguards, and internal controls used
for the validation of new customers for the FCA calculations
Dayn Hardie
Deputy Attorney General
i:umisc:prodreq/avugl9.4dhbejk prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUGUST 2O,2OI9
CERTIFICATB OF SBRVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF AUGUST 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G-19-04,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIR
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: patrick.ehrbar(4)avistacorp.conr
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL : ciavid.me)'erf0avistacotp. com
CERTIFICATE OF SERVICE