20201217Staff 1-29 to Avista.pdf

DAYN HARDIE
'
DEPUTY ATTORNEY GENERAL ,AN 4:99
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )AVISTA CORPORATION FOR A )CASE NO.AVU-E-20-13
DETERMINATION OF 2018-2019 ELECTRIC )
ENERGY EFFICIENCY EXPENSES AS )PRUDENTLYINCURRED )
IN THE MATTER OF THE APPLICATION OF )CASE NO.AVU-G-20-08
AVISTA CORPORATION FOR A )DETERMINATION OF 2018-2019 NATURAL )FIRST PRODUCTION
GAS ENERGY EFFICIENCY EXPENSES AS )REQUESTOF THE
PRUDENTLY INCURRED )COMMISSION STAFF TO
)AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy AttorneyGeneral,request that Avista Corporation (Company)provide the
followingdocuments and information as soon as possible,or by THURSDAY,
JANUARY 7,2021.
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
FIRST PRODUCTION REQUEST
TO AVISTA 1 DECEMBER 17,2020
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
31.01.01.228.
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.1:Please provide a list in Excel format showing all expenses charged
to the electric and gas DSM riders in 2018 and 2019.Please include the followinginformation
for each expense:the date,vendor,amount,program,task number,and account to which the
charges were assigned.Please include and identify any adjustments made in 2018 or 2019 to
previously incurred expenses.Please separate all expenses by program.If any amounts were
allocated to multipleprograms 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.
REQUESTNO.2:Please provide copies of all internal audit reports for audits
completed on the Company's electric and gas DSM processes and expenses from 2018 through
2020.Please list the scope of any internal audits in progress on the Company's electric and gas
DSM processes and expenses.
REQUESTNO.3:Please provide invoices for all third-partyevaluators for 2018 and
2019.Please describe how those costs were allocated among jurisdictions and fuel sources.
REQUESTNO.4:Please provide the electric and gas tariff rider revenue by month and
by class for 2018 and 2019.
REQUESTNO.5:Please provide the calculation of any carrying charge or interest on
the electric and gas rider balances during 2018 and 2019.
REQUESTNO.6:Please provide the amount of labor expense charged to the Idaho
electric and gas DSM tariff riders for the years 2017 through 2019.For each year,please include
FIRST PRODUCTIONREQUEST
TO AVISTA 2 DECEMBER 17,2020
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.
REQUESTNO.7:Please provide a current organizational chart by title and name
showing all Avista employees who charge time to the electric and gas DSM riders.Please
include complete job descriptions,required qualifications,salary ranges,bonus opportunities,
and total compensation ranges,including benefits,for all employees identified in this request.
REQUESTNO.8:Please provide the cost-effectiveness workpapers and calculations
for all DSM programs and measures by year (2018 and 2019)in Excel format with formulas
intact and all assumptions clearly defined.
REQUESTNO.9:Please provide a list of the benefits the Company and its customers
have received from the Research and Development ("R&D")projects since 2013.
REQUESTNO.10:Did the Company make any changes to its input and verification of
site-specific projects based on Cadmus'recommendation on page 30 of the 2018 Annual
Conservation Report?
REQUESTNO.11:Please provide all workpapers in a digital format,illustratinghow
the cost-effectiveness of the Company's participation in the Northwest Energy Efficiency
Alliance ("NEEA")was calculated for the years 2018 and 2019.
REQUESTNO.12:Please provide the amount of savings obtained through the
Company's participation in NEEA for 2018 and 2019.Please identify any savings that were
allocated to Avista's Idaho jurisdiction,and the methods used to allocate those savings.
REQUESTNO.13:Please provide the source of the avoided cost used to calculate the
cost-effectiveness of NEEA for Avista's Idaho jurisdiction.
FIRST PRODUCTION REQUEST
TO AVISTA 3 DECEMBER 17,2020
REQUESTNO.14:Please provide electronic workpapers showing the derivation of
values shown in Tables 2,3,8-12,14-17,19,21-25,28,30,32-35,37-47,and 50-55 of the
Company's 2018 Annual Conservation Report.
REQUESTNO.15:Please provide electronic workpapers showing the derivation of
values shown in Figures 4,5,9,10,15,36,38,39,and 41 of the Company's 2018 Annual
Conservation Report.
REQUESTNO.16:Please provide electronic workpapers showing the derivation of
values shown in Tables 2,3,6-9,11,13,17-26,30,and 31 of the 2018 Electric Impact
Evaluation prepared by Cadmus.
REQUESTNO.17:Please provide electronic workpapers showing the derivation of
values shown in Tables 2,3,6-9,11-18,20-23,and 25-28 of the 2018 Gas Impact Evaluation
prepared by Cadmus.
REQUESTNO.18:Please provide electronic workpapers showing the derivation of
values shown in Tables 2,3,16-19,21-24,28,31,33,35-37,39-46,52,56,57,and 63-66 of the
Company's 2019 Annual ConservationReport.
REQUESTNO.19:Please provide electronic workpapers showing the derivation of
values shown in Figures 4,5,9,10,16,17,30,and 31 of the Company's 2019 Annual
Conservation Report.
REQUESTNO.20:Please provide electronic workpapers showing the derivation of
values shown in Tables 2,3,6-9,11,13,16-28,and 30 of the 2019 Electric Impact Evaluation
prepared by Cadmus.
REQUESTNO.21:Please provide electronic workpapers showing the derivation of
values shown in Tables 2,3,6-9,11,12,14-18,20,and 22-25 of the 2019 Gas Impact
Evaluation prepared by Cadmus.
FIRST PRODUCTION REQUEST
TO AVISTA 4 DECEMBER 17,2020
REQUESTNO.22:In the 2018 and 2019 Electric Impact Evaluations,Cadmus
presents "Savings Goals"and "Percentage of Goal"in several tables (e.g.,Table 3 in both
reports).Please provide the following:
a.An explanation of the purpose of these goals;
b.An explanation of how these goals are set;and
c.An explanation of how these goals are used.
REQUESTNO.23:On pages 7 and 8 of its 2018 Electric Impact Evaluation,Cadmus
describes the sample design used to evaluate the Company's non-residential site-specific
programs.Please provide the followinginformation:
a.The entire population of site-specific projects from which the sample was drawn.For
each project,include the application number,account,a description,location,
estimated savings,and any additional criteria that were used to eliminate programs
from the random selection process.
b.Identify which site-specific projects were used in the sample.
c.Please explain the criteria used to select the 12 sites selected for certainty review.
d.Please provide all workpapers used to determine the realization rates shown in
Table 11.
REQUESTNO.24:Please provide the versions of the TRM (Technical Reference
Manual)used by the Company to prepare its 2018 and 2019 Annual ConservationReports.
REQUESTNO.25:On page 3 of its application in Case No.AVU-E-13-08,the
Company defines R&D for the purposes of its proposal "to be applied R&D that could yield
benefits to customers in the next one to four years."Please provide the followinginformation:
a.Examples of R&D projects that have yielded benefits to customers since the
Commission authorized funding of R&D projects in Order No.32918.For each
project cited,please include fundingcosts and the estimated benefits to customers.
b.Any reports or cost/benefit analyses conducted by Avista regardingR&D projects
since the Commission issued Order No.32918 in 2013.
FIRST PRODUCTION REQUEST
TO AVISTA 5 DECEMBER 17,2020
REQUESTNO.26:For the Aerogel Phase II project described in Avista's 2019 Idaho
Research and Development Report,please answer the followingquestions:
a.How does Avista plan to use the results of this project?
b.What is Avista's timeline for using the results of this project?
c.The two-page report in Appendix A states that one of the deliverables is a cost
analysis.Please provide this cost analysis.
d.Please provide any reports or cost/benefit analyses conducted by Avista in
conjunction with this project.
REQUESTNO.27:For the All Iron Battery project described in Avista's 2019 Idaho
Research and Development Report,please answer the followingquestions:
a.How does Avista plan to use the results of this project?
b.What is Avista's timeline for using the results of this project?
c.The two-page report in Appendix A states that one of the deliverables is a report on
"path to market."Please provide this report.
d.Would Avista or its customers receive any tangible benefit if this project were to
result in a marketable product?
e.Please provide any reports or cost/benefit analyses conducted by Avista in
conjunction with this project.
REQUESTNO.28:For the Energy Trading System project described in Avista's 2019
Idaho Research and Development Report,please answer the followingquestions:
a.How does Avista plan to use the results of this project?
b.What is Avista's timeline for using the results of this project?
c.Is Avista considering an energy trading system like that conducted in this project?
d.Please provide any reports or cost/benefit analyses conducted by Avista in
conjunction with this project.
FIRST PRODUCTION REQUEST
TO AVISTA 6 DECEMBER 17,2020
REQUESTNO.29:For the IR Camera Phase I project described in Avista's 2019 Idaho
Research and Development Report,please answer the followingquestions:
a.How does Avista plan to use the results of this project?
b.What is Avista's timeline for using the results of this project?
c.Please provide any reports or cost/benefit analyses conducted by Avista in
conjunction with this project.
DATED at Boise,Idaho,this day of December 2020.
Deputy AttorneyGeneral
i:urnisc:prodreq/avue20.13_avug20.08ejde prod reql
FIRST PRODUCTION REQUEST
TO AVISTA 7 DECEMBER 17,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF DECEMBER 2020,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NOS.AVU-E-20-13/AVU-G-20-08,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
SHAWN J BONFIELD DAVID J MEYERAVISTACORPORATIONVP&CHIEF COUNSELPOBOX3727AVISTACORPORATIONSPOKANEWA99220-3727 PO BOX 3727
E-mail:shawn.bonfield@avislacoracom SPOKANE WA 99220-3727
SECRETAR
CERTIFICATE OF SERVICE