20210812Staff 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
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
IMPLEMENT FCA RATES FOR NATURAL
GAS SERVICE FROM OCTOBER 1,2021
THROUGH SEPTEMBER 30, 2022
CASE NO. AVU-G-21-06
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 Attomey General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than THURSDAYT
AUGUST 26,2021.1
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
I Stuffit requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at (208) 334-12.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATTON
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I AUGUST 12,2O2I
the person preparing the documents. Please also identiff 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 all intemal audit reports and SOX reports detailing
the FCA revenue determination during the 18-month deferral period, January 1,2020 through
June 30, 2021. These include any safeguards or internal controls used to ensure that the revenue
report is accurate.
REQUEST NO. 2: Please provide the number of new customers by class per month for
the January 1,2020 throughJune 30,2021 defenal period.
REQUEST NO. 3: Please provide a description of the process, safeguards, and the
internal controls that have been implemented for the validation of new customers for the FCA
calculations.
REQUEST NO. 4: Please provide all intemal audit reports and SOX reports regarding
the new customer process for the 1S-month deferral period that ended June 30, 2021.
REQUEST NO. 5: Please provide the number of new natural gas customers by class per
month for the 18-month deferral period that ended June 30, 2021.
REQUEST NO. 6: On page 7,line 20 through page 8, line 4 of the Application, Avista
estimates that during the 18-month deferral period ended June 30, 2021, its DSM programs
reduced residential usage by approximately 1.1 million therms and non-residential usage by
approximately 200,000 therms.
a. Please reconcile these results with the Company's 2017 through 2020 DSM
reports and any other reports that may apply.
b. Please provide supporting documentation for these calculations.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST I2,2O2I
REQIIEST NO. 7: Please provide an estimate of the total weather-normalized change in
oonsumption in the 18-month deferr'al period that ended Jrure 30, 2A21,.
DATED at Boise, Idaho, this l2l4 day of Augu st202l.
Dayn
Deputy Attorney General
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FrRST PRODUCTTON REQUEST
TO AVISTA CORPORATION 3 AUGUST 12,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12th DAY OF AUGUST 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
coMMrssroN STAFF To AVISTA CORPORATION, IN CASE NO. AVU-G-21-06,
BY E-MAILING A COPY THEREOF, TO T}IE FOLLOMNG:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL : [e-mail]
dockets@avi stacorp.com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: david.meyer@avistacorp,com
SECRET
CERTIFICATE OF SERVICE