20220802Avista to Staff 1-11.pdf

JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
i:?.',ii,.:,'. ;*
AVISTA CORPORATION
RESPONSE TO REQUEST FORINFORMATION :,,; ii; , - r 11 ?: 39
IDAHO DATE PREPARED: 07 l2gl2o22' , : ' , . -,
,H S1 0 ilAW-G-22-03 WITNESS: N/AIPUC RESPONDER: JeffWebb
Production Request DEPARTMENT: Gas EngineeringStaff-001 TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Describe the Company's capabilities to repair meters that fail their accuracy test:
a. Please describe which meters (by manufacturer) the Company is capable of re,pairing, and the
types of deficiencies that can be repaired.
b. Please describe availability of components required to repair meters.
c. What is the Company's current monthly repair capacity?
d. Has the Company explored expanding its repairs of meters? If not, why not. If yes, what is the
capacity of monthly repairs the Company could achieve?
RESPONSE:
a. The Avista Gas Meter Shop has the haining and tools to fully rebuild all diaphragm meter sizes
(175 to 1000) from both Elster & Sensys manufacturers.
b. Avista's designated manufacturer representative has notified the Company that repair parts are
available in limited quantities, depending on the part required, and that inventory levels are in
constant flux as there is a high level of uncertainty upstream from the manufacturer themselves.
c. Those qualified to repair meters at Avista have minimal capacity to do more work, as they are
already incurring overtime to complete many of their existing responsibilities. Any additional
workload would require mandatory overtime or hiring and training additional ernployees to
complete the repairs.
d. Avista has not completed any analysis regarding the expansion of its repairs of small diaphragm
meters. When reviewed in the past, it was deemed cost prohibitive to do so, as the relatively low
cost of a new meter did not justifr spending much time and/or materials to repair an old one.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-G-22-03
IPUC
Production Request
Staff-002
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: JeffWebb
DEPARTMENT: Gas Engineering
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
On page 5 of the Petition, the Company described exploring a second meter manufacturer in 2019:
a. Has the Company revisited the potential of using the manufacturer explored in2019? If yes,
please provide findings. If not, why not?
b. Has the Company explored any other manufactures or sources? If yes, please describe findings.
If not, why not?
RESPONSE:
a. Yes. While the second vendor Avista researched in 2019 had a longer lead time than the
Company's primary supplier (70+ weeks vs. 52), Avista is placing orders with the second supplier
in order to diversifu its supply chain. Due to the lead time issues noted, however, these additional
orders will of[er no expedition of meter receipt.
b. To Avista's knowledge, there are no other manufacfurers of residential-sized diaphragm gas
meters through which it could procure additional meters.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATTON
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-G-22-03
IPUC
Production Request
Staft-003
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: Jeff Webb
DEPARTMENT: Gas Engineering
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
On pages 5 and 6 of the Petition, the Company describes why use of its current vendor is the
preferred alternative.
a. Please describe what is involved in the badgrng process and what is required for another vendor
to meet the Company's requirements.
b. Please describe what is involved in qualifying a meter vendor's QA and QC processes.
RESPONSE:
a. Each Avista meter is labeled with a unique metallic badge from the Company. This label
contains information about the meter, such as the manufacturer name, meter size, manufacture
year, and serial number. Our Company n.rme, "Avista", is also included on the label. This label
information is common throughout the industry and meter vendors anticipate this requirernent. If
Avista were to change vendors, the labeling would not be an issue. However, if we were to
purchase meters from our peer utilities, the labels would contain the incorrect utility name and
would therefore need replaced. Replacing the badge would require working with the meter
manufacturer to create new badges, with Avista then able to rernove the riveting from the old
badges and replace with the new ones. It is also worth noting supply chain issues, and associated
meter shortages, are an industry-wide issue-with other utilities Avista has corresponded with
noting similar, if not worse lead times-and it is highly unlikely that others would be willing to sell
from their own limited inventories.
b. While Avista's process to qualiff a new vendor's QA/QC process is not formally documented, it
involves visiting the manufacturer and conducting a plant audit (which includes, among other
activities, review of their training program, safety record, and root cause analysis protocol), in
addition to a trial-run of the vendor's product. This means ordering a small quantity of their
meters, placing them into service in a controlled location (and in series with an existing meter so
that reads can be compared), and ensuring the AMR/AMI devices communicate properly.
Assuming the testing goes well, this process would give Avista a high level of confidence in the
accuracy of these meters.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-G-22-03
IPUC
Production Request
Staff-004
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: JeffWebb
DEPARTMENT: Gas Engineering
TELEPHoNE: (s09) 49s-4424EMAIL: [e-mail]
RBQUEST:
On page 6 of the Petition, the Company stated the lead time for Encoder Receiver Transmitter
("ERT') modules is approximately 24 weeks:
a. Has the Company experienced ERT module availability constraints or shortages other than
increased lead time? If so, please describe constraints and how the Company is addressing thern.
b. Please provide current inventory levels of ERTs, and anticipated consumption rates.
RESPONSE:
a. The only ERT module compatible with the fixed network syston in Idaho is the 100G DLT,
production of which was discontinued by its manufacturer, Itron, several years ago. In anticipation
of AMI being scheduled to start in Idaho in2024, the Company worked with Itron to manufacture
a special run of 50,000 l00G DLT modules-made specifically for Avista-so that the Company
would not run the risk ofnot having enough 100G DLT modules to support new meter installations
as well as replacement of ERTs in the event ofbattery failure. With this agreement, Avista expects
to have a sufficient supply of ERTs until the AMI project is under"way. The first shipment of these
ERT modules is expected to be delivered in late 2022 andthe rest in the first and second quarter of
2023.
b. Current inventory levels for the 100G DLT areo Elster with f index: 480o Elster with 2' index: 60o Elster with 5' index: 80o Elsterwith 10'index: 75o Rockwell index: 0
Regarding consumption rates, the average failure rate for ERTs is about 20 per day.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
REQUEST:
Please provide supporting workpapers for the values shown on page l0 of the Petition:
a. How many fasUslow meters by meter type were replaced in Idaho by year in2020 and202l?
b. How many dead meters by meter type were replaced in Idaho by year in2020 and202l?
RESPONSE:
Please see Staff-PR-005 Attachments A-C for the following workpapers:
o Staff-PR-005 Attachment A-2020 Fast Test Natural Gas Meterso Staff-PR-005 Attachment B -2021Fast Test Natural Gas Meterso StaflPR-O05 Attachment C - 2022 Fast Test Natural Gas Meters
a. The tables below show the number of meters by type that were replaced and tested either fast or
slow in 2020 and202l:
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-G-22-03
IPUC
Production Request
Staff-005
2020
Meter Type Quantity that Tested Fast or Slow
5B
AC250
AC630
A11000
A11400
A1175
A12300
AL250
A1425
A15000
ALSOO
R275
RA175
RA275
L7
515
45
45
15
51
3
L
67
2
5
377
7
58
Total L,L48
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
EMAIL:
07t29t2022
N/A
JeffWebb
Gas Engineering
(s09) 49s-4424
j [e-mail]
202,,
Meter Type Quantity that Tested Fast or Slow
5B
AC250
AC630
A11000
A11400
A1175
A12300
A1425
ALSOO
R275
RA175
RA275
sA175
18
4t6
4L
35
9
31
6
27
5
675
4
108
t
Total L,376
b. It is assumed that a "dead meter" is a meter that has a mechanical issue that results in the meter
not registering usage. Avista refers to meters that are not registering usage as a stopped meter.
Some coillmon reasons for a stopped meter can be from a dead ERT battery, a vacant or seasonal
home, a broken wiggler, etc. The tables below show the number of stopped meters that were due to
mechanical issues that prevented the meter from registering flow that were replaced in2020 and
2021:
2020
Meter Type Stopped Meter Quantitv Replaced
AC250
AC630
A11000
A11400
R275
27
2
L
2
5
Total 37
2021
Meter Type Stopped Meter QuantiW Replaced
AC250
AC630
A1175
4L425
R275
18
3
4
1
3
Total 29
AYISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION: IDAHO
CASE NO: AW-G-22-03
REQUESTER: IPUC
TYPE: Production Request
REQUEST NO.: Staff-006
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: JeffWebb
DEPARTMENT: Gas Engineering
TELEPHONE: (509) 49s-4424EMAIL: [e-mail]
REQUEST:
Please provide a copy of all standards cited in the petition including ANSVASQZI.4 and Zl.9 2003
(R2018).
RESPONSE:
Please see Avista's response Staff-PR-006C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exernpt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and233, and Section 9-340D, Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-G-22-03
IPUC
Production Request
Staff-006C
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: JeffWebb
DEPARTMENT: Gas Engineering
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Please provide a copy of all standards cited in the petition including ANSVASQZI.4 andzl.g 2003
(R2018).
RESPONSE:
Please see Avista's response Staff-PR-006C Confidential Attachment A for the ANSI Zl.9
standard referenced in its Petition (ASQZI.4 noted above was not cited in the Company's Petition).
Staff-PR-006C Confidential Attachment A contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and exe,mpt from public view and is separately filed under
IDAPA 31.01.01, Rule 067 and233, and Section 9-340D, Idaho Code. The attachment is being
provided as confidential due to copyrighting.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-G-22-03
IPUC
Production Request
Staff-007
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: JeffWebb
DEPARTMENT: Gas Engineering
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Please describe alternative meter testing methods and protocols the Company has explored.
RESPONSE:
Avista is not aware of any other testing methods that are supported by ANSI or other utilities in the
indusbry that would not place an even greater burden on inventory levels. For example, one
altemative method would be to field test the smaller diaphragm meters (as is the protocol for larger
meters); however, the quantity of meters required to complete such tests would require an
additional fleet of equipment (mobile provers, etc.) and associated staffllabor to support the effort.
ruzuSDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AYISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO
AW-G-22-03
IPUC
Production Request
Staff-008
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: Jeff Webb
DEPARTMENT: Gas Engineering
TELEPHONE: (s09) 49s-4424EMAIL: [e-mail]
REQUEST:
The Company is requesting a waiver from the provisions of Section 24-25 of its natural gas tarifi
LP.U.C No.27, Schedule 170. Part D of Section 25 is Meter Tests Requested by Customsrs. Please
clariff if a waiver is requested for Part D, too, or if Part D will remain in effect. If a waiver is being
requested for Part D, please explain and provide additional documentation for that need.
RESPONSE:
Avista is not requesting a waiver of customer-requested meter testing, as the number of natural gas
meter requests by customers on an annual basis has, historically, been low.
The number of customer-requested meter tests in 2020 and202l were:
2020: ll0
2021: l3l
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO
AVU-G-22-03
IPUC
Production Request
Staffi009
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: JeffWebb
DEPARTMENT: Gas Engineering
TELEPHONE: (s09) 495-4424EMAIL: [e-mail]
REQUEST:
Please provide the audit parameters the Company uses to detect high, slowing or stopped meters.
How often are reports reviewed, and within what time frame are field investigations conducted and
corrective action taken if necessary?
a. How many meter replacement requests originated from customers in Idaho by year in2020 and
2021?
b. How many internal requests for meter reads and replacements were requested by the billing
department?
c. How many internal requests for meter reads and replacements were requested by the Company?
RESPONSE:
Avista's billing department has high-read and low-read parameters assigned to each meter in its
Customer Care & Billing (CC&B) system. If the meter read hits either the high or low read
parameters, the billing team receives notification the next business day after the meter is read and
reviews the account and billing history to see if the read makes sense. If the billing team suspects
that the read is inaccurate, the bill is postponed, and a Field Activity is created for a field visit to
investigate the situation. This review and Field Activity creation (if necessary) is done the next
business day after the meter is read. The target resolution date is 5 business days from when the
Field Activity is created. From 2020 to present, the average number of days from when the Field
Activity was created until completion was 4 days.
a. Quantity of customer:Ti.d,* meter replacements:
2021 - l3l
b. Quantity ofbilling department requested meter reads and replacements:
2021 - 531
c. Quantity of internal request for meter reads and replacements (includes billing deparbnent
requests, PMC pro8ram, il,#* Family meter replacements):
2021 - 1,714
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO: AW-G-22-03
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Staff-0l0
DATE PREPARED: 07 12912022WITNESS: N/A
RESPONDER: Jaime Majure
DEPARTMENT: Regulatory Affairs
TELEPHONE: (509) 49s-7839EMAIL: [e-mail]
REQUEST:
Current rules/tariffs limit rebilling to 36 months (UCRR 203 03(b)). Please explain how the
Company determines an 18-month limit is appropriate for overbilling as shown in the example on
page 10 of the Application. Does this imply that the Company is certain all meters are currently
working within spec at this time?
RESPONSE:
UCCR 203.030) states that "If the time when the billing problem began can be reasonablv
determined and the utility determines the customer was overcharged, the corrected billings will go
back to that time, but not to exceed three (3) years from the time the billing problem occurred as
provided by Section 6l-642,Idaho Code." [Emphasis added]
In its Petition, Avista asked to extend the 6-month timeframe in UCCR 203.03@), which states, in
comparison, that "If the time when the billing error, billing under incorrect rates, or failure to bill
(collectively referred to as "billing problem") began cannot be reasonably determined to have
occurred within a specific period. the corrected billings will not exceed the most recent six (6)
months before the discovery of the billing problem." [Emphasis added] Avista's request, since the
time at which the meter began malfunctioning may not be reasonably determined, is intended to
credit 18 months back to customers. This will accommodate the 12 months that the Company
anticipates not testing meters, in addition to the 6 months we typically refund for a fast meter,
totaling 18 months. To clarify, if the Company is able to reasonably determine the time when the
billing problem began, the 36-month provision per UCCR 203.030) will be applicable in those
instances.
The purpose of the PMC Program is to verify the accuracy of Avista's meters and identifu those
that aren't working within spec, so that the appropriate repair or removal process can be completed
The Company's proposal was not intended to imply that all meters are currently working within
spec at this time, but rather to provide security for a customer whose meter, hlpothetically, would
have failed if tested noul versus being testing after having paused our PMC program 12 months
from now. For example, if a meter tested outside of the prescribed 2% threshold today, we would
provide the customer with up to 6 months of credit; if Avista's waiver is granted and the PMC
Program is paused for 12 months, upon resuming such meter testing the Company would like to
ensure that the customer is compensated for what they would have received (6 months of credit) in
addition to the 12 months that their meter test was delayed. It is for this reason that when testing of
meters resumes, the Company proposed to credit customers for any discovered overbilling for up
to 18 months.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AYU-G-22-03
IPUC
Production Request
Staff-0lI
DATE PREPARED: 07 129/2022WITNESS: N/A
RESPONDER: Jaime Majure
DEPARTMENT: Regulatory Affairs
TELEPHONE: (509) 49s-7839EMAIL: [e-mail]
REQUEST:
Please describe the Company's procedure to determine rebilling amounts when a meter
malfunctions (high and low).
RESPONSE:
If, upon testing a meter, it is determined that the meter is malfunctioning high (i.e., the meter tests
more than 2o/o fast, with more natural gas registering as used than was actually consumed,
therefore the customer has been potentially overbilled), Avista provides a bill credit for amount of
the potential overage for the previous six months' usage. This amount is calculated by multiplying
the percentage of the overage (from what 1O0%-meter accuracy would have been) times the usage
during that time period, based on current rates. In instances where the meter is instead determined
to be malfunctioning low (i.e., testing more than 2o/o slow), the Company uses the same
calculation. However, Avista rarely encounters meters that test slow; rather, the majority of
slow-testing meters actually qualifu as stopped meters (they have stopped registering usage
completely) and rebills are therefore estimated based on historical usage (prior 2 years) at the
premise. If the customer has not been at the prernise for at least 2 years, or the usage patterns are
inconsistent, a new meter read is obtained after 7 days and the usage is estimated based on that
read.