20210301Staff 30-40 to Avista.pdf

DAYNHARDIE
DEPUTY ATTORNEY GENERAL
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
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVISTA CORPORATION FOR A )
DETERMINATION OF 2018-2019 ELECTRIC )
ENERGY EFFICIENCY EXPENSES AS )
PRUDENTLY INCURRED ) __________________ )
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2018-2019 NATURAL
GAS ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED
)
)
)
)
) __________________ )
CASE NO. AVU-E-20-13
CASE NO. AVU-G-20-08
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, request that Avista Corporation (Company) provide the
following documents and information as soon as possible, or by MONDAY, MARCH 22, 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
person preparing the document, and the name, location and phone number of the record holder
SECOND PRODUCTION REQUEST
TO AVISTA 1 MARCH 1, 2021
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
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.
REQUEST NO. 30: In the 2019 Idaho Annual Conservation Report, Table 39 reports a
UCT cost of $3,294,904 for residential electric programs and Table 40 reports a UCT cost of
$671 ,310 for residential gas programs. In Appendix F, the table displays total Utility Costs of
$2,698,269 for residential electric and $675,070 for residential gas. Please provide a
reconciliation of the Utility Cost for Table 39 and Table 40 and the residential utility cost for gas
and electric in 2019 as displayed in Appendix F. Please provide this information in Excel format
with formulas enabled.
REQUEST NO. 31: In Order No. 34067, the Commission increased Low-Income
funding by $125,000 annually to weatherize more homes and decrease the Community Action
Partnership Association of Idaho waiting list, which was at 303 customers as of October 2017.
Please provide the number of customers' homes served and the number of homes on the waiting
list in Avista Idaho's service territory by year for the years 2018 through 2020.
REQUEST NO. 32: On page 28 of the 2019 Electric Impact Evaluation, Table 24
shows the Company achieved 43% of its participation goals, with 13 participants for Low­
Income Fuel Efficiency. Please explain why the Company did not reach its participation goals of
30 participants. Additionally, please explain what led to the Company achieving 3 7% of its
101,640 kWh energy savings goal for Low-Income Fuel Efficiency.
REQUEST NO. 33: On page 19 of the 2019 Gas Impact Evaluation, Table 19 shows
that the Company achieved 2% of its participation goals. Please explain why the Company did
not reach its participation goals for the 2019 Low Income Gas Program. Additionally, please
explain what led to the Company achieving 15% of its 25 ,262 therms energy savings goal for the
Low-Income Programs.
SECOND PRODUCTION REQUEST
TO AVISTA 2 MARCH 1, 2021
REQUEST NO. 34: In the 2019 Idaho Annual Conservation Report, Appendix E shows
a total of $91 ,399 for Health and Safety for the Low-Income programs. Appendix F shows the
Low-Income programs total Utility Cost of $320,352 for gas and electric Health and Safety
programs. Please provide in Excel format with formulas enabled a reconciliation of the Health
and Safety costs in Appendix E and F for Low-Income Programs for both gas and electric.
REQUEST NO. 35: In the 2019 Idaho Annual Conservation Report, Appendix E shows
Health and Safety gas utility costs of $145,985, which is 42% of the Company's Low-Income
Utility Cost. Please explain how the Company monitors Lewiston Community Action
Partnership Health and Safety expenditures to ensure they do not exceed 15% of the overall
program allocation. Please provide any documentation for the Company's procedures. Please
explain why 42% of program funds were allocated to Health and Safety in 2019.
REQUEST NO. 36: On page 70 of the 2019 Annual Conservation Report, the Company
states that for natural gas Energy Star manufactured homes, the rebate was reduced from $600 to
$200 in the beginning of 2019, then mid-year it was increased to $400.
a. Please explain the reasoning for adjusting the rebate.
b. How often are the rebates for measures adjusted?
c. Please provide documents for the Company's formal process for setting and adjusting
rebates/incentives.
d. If no documents are available, please explain the Company's process for setting and
adjusting rebates/incentives.
REQUEST NO. 37: In response to Production Request No. 2, what steps has the
Company taken to implement recommendations related to the Customer Care & Billing system,
customer approval of rebates, and incentive calculations and Top Sheets?
REQUEST NO. 38: Please answer the following questions regarding the Residential
Static Var Compensator ("RSVC") research listed in the table provided by the Company in
Production Response No. 9:
SECOND PRODUCTION REQUEST
TO AVISTA 3 MARCH 1, 2021
a. Is the 1 % savings listed on this table an actual savings value, or does it represent a
potential savings derived from modeling? Please explain.
b. Has the Company installed any of the RSVC devices developed through this
research? If so, please provide any reports on the field effectiveness of these devices.
c. Has the Company or its customers benefited from the patent that was issued for this
project? If so, please describe the benefits.
REQUEST NO. 39: Please answer the following questions regarding the Simulation
Based Commissioning of Energy Management Control System ("EMCS") listed in the table
provided by the Company Production Response No. 9 and further described in Production
Response No. 25.
a. Please explain the asterisk(*) next to the 14MWh savings listed for this project?
b. Was EMCS used to control the HV AC system at U of I's COBE building, or was the
study confined to simulations? Please explain in detail.
REQUEST NO. 40: In the 2018 and 2019 Idaho Annual Conservation Reports,
Appendix E reports total Northwest Energy Efficiency Alliance ("NEEA") expenditures as
$471 ,953 in 2018 and $824,591 in 2019 for a combined total of $1 ,296,544. In the Company 's
Production Response No. 11 , the Company states that Idaho customers incurred $1,255,424 for
NEEA in 2018 and 2019. Please provide a reconciliation of the difference in NEEA
expenditures reported in Appendix E and the Company 's Production Response No. 11. Please
provide in Excel format with all formulas intact.
DATED at Boise, Idaho, this 1,1!"
i:umisc:prodreq/avue20.13_avug20.08ejbl prod req2
SECOND PRODUCTION REQUEST
TO AVISTA
day of March 2021.
Deputy Attorney General
4 MARCH 1, 2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1sr DAY OF MARCH 2021 ,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-20-13/AVU-G-20-08, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
SHAWN J BONFIELD
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail: [e-mail]
[e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail: [e-mail]
SECREJ?~
CERTIFICATE OF SERVICE