20220714Staff 1-11 to Avista.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03r8
IDAHO BAR NO. II2O2
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
: -'L--lfr!-i:.. ; _- \- ii..,l {
IN THE MATTER OF THE PETITION OF
AVISTA CORPORATION FOR AN
EXEMPTION FROM GAS SERVICE RULES 15I
AND 152, UTILITY CUSTOMER RELATTONS
RULE 203(3), AND ASSOCIATED TARIFFS
)
)
)
)
)
)
)
)
)
CASE NO. AVU.G.22.O3
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,
Riley Newton, Deputy Attomey General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than THURSDAY, AUGUST 4o
2022.
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
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION I JULY 14,2022
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 as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: 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 repairing,
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?
REQUEST NO. 2: 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 in20l9?
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?
REQUEST NO.3: 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 badging 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.
REQUEST NO. 4: On page 6 of the Petition, the Company stated the lead time for
Encoder Receiver Transmitter ("ERT") modules is approximately 24 weeks:
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 JULY 14,2022
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 them.
b. Please provide current inventory levels of ERTs, and anticipated consumption rates.
REQUEST NO. 5: Please provide supporting workpapers for the values shown on page
l0 of the Petition:
a. How many fast/slow 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 and
2021?
REQUEST NO. 6: Please provide a copy of all standards cited in the petition including
ANSVASQ Zr.4 and Zt.9 2003 (R201 8).
REQUEST NO. 7: Please describe altemative meter testing methods and protocols the
Company has explored.
REQUEST NO. 8: The Company is requesting a waiver from the provisions of Section
24-25 of its natural gas tariff, I.P.U.C No.27, Schedule 170. Part D of Section 25 is Meter Tests
Requested by Customers. 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.
REQUEST NO. 9: 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 in
2020 and202l?
b. How many internal requests for meter reads and replacements were requested by the
billing department?
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION J ruLY 14,2022
c. How many intemal requests for meter reads and replacements were requested by the
Company?
REQUEST NO. 10: 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 l0 of the Application. Does this imply that the
Company is certain all meters are currently working within spec at this time?
REQUEST NO. 11: Please describe the Company's procedure to determine rebilling
amounts when a meter malfunctions (high and low).
DATED at Boise, Idaho, this l{{t^ day of iuly 2022
Riley Newton
Deputy Attorney General
i:umisc:prodreq/avue22.3mksk prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 ruLY t4,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF ruLY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G-22-03,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
POBOy'3727
SPOKANE WA99220-3727
E-MAIL : [e-mail]
dockets@avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
POBOX3727
SPOKANE WA99220-3727
E-MAIL : david.meyer@avistacom. com
J./)Z-=\
SECRETAF./ -
CERTIFICATE OF SERVICE