20221003Staff 13-21 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF THE APPLICATIONS OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2020.2021 ELECTRIC
AND GAS ENERGY EFFICIENCY EXPENSES
AS PRUDENTLY INCURRED
tTCEIVED
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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
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CASE NO. AVU.E-22.I3
AVU-G-22-05
SECOND 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 Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than MONDAY, OCTOBER 17,
2022.
This Production Request is to be considered as continuing, and Avista is requested to
provide, by way of supplementary responses, additional documents that it, or any person acting
on its behall 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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 1 OCTOBER 3,2022
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. 13: Please provide electronic workpapers showing the derivation of
values shown in all the Tables and Figures included in the Company's 2020 and 2021 Annual
Conservation Reports.
REQUEST NO. 14: Please provide electronic workpapers showing the derivation of
values shown in the all the Tables included in the 2020 and 2021 Idaho Electric Impact
Evaluation Reports prepared by Cadmus.
REQUEST NO. 15: Please provide electronic workpapers showing the derivation of
values shown in all the Tables included in the 2020 and202l ldaho Natural Gas Impact
Evaluation Reports prepared by Cadmus.
REQUEST NO. 16: Please provide electronic workpapers showing the derivation of
values shown in all the Tables included in the Evaluation, Measurement, and Verifications
("EM&V") of Avista Idaho Electric for PY2020 andPY2021 Residential and Low-Income
Energy Efficiency Programs prepared by ADM Associates.
REQUEST NO. 17: Please provide electronic workpapers showing the derivation of
values shown in all the Tables included in the EM&Vs of Avista Idaho Natural Gas PY2020 and
PY 2021Residential and Low-Income Energy Efficiency Programs prepared by ADM
Associates.
REQUEST NO. 18: In the 2020 and 2021 Annual Conservation Report, the Company
indicates that it is allowed to spend up to ten percent of its conservation budget on programs
whose savings impacts have not yet been measured so long as the portfolio remains cost-
effective. Please explain the basis for this allowance.
SECOND PRODUCTTON REQUEST
TO AVISTA CORPORATION 2 OCTOBER 3,2022
REQUEST NO. 19: Please describe the Company's efforts to address the realization
rates for the2020 and202I Residential Fuel Efficiency and the202l Residential Appliances
measures.
REQTIEST NO. 20: Please describe the Company's efforts to address the cost
effectiveness of the Low-Income Weatheri zation program.
REQUEST NO.21: The Company indicates that the completion of significant
Commercial and Industrial projects are expected to increase the cost-effectiveness of the natural
gas progftlm.202l Annual Conservation Report at 30. Please provide a list of these projects,
including a brief description and expected completion date for each.
,4DATED at Boise, Idaho, this day of October2022.
Deputy Attomey General
i:umisc:prodreq/avue22.l3 _awg22.5dhmejjt prod req 2
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 3 OCTOBER 3,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF OCTOBER 2022,
SERVED THE FOREGOING SECOI\D PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO.
AYU.E-22.I3IAVU.G-22-05, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-mail: [e-mail]
[e-mail]
SHAWN J. BONFIELD SENIOR MANAGER
REGULATORY POLICY & STRATEGY
AVISTA CORPORATION
P.O.BOX3727
14I I E. MISSION AVENUE, MSC 27
SPOKANE,WA99220
E-mail : shawn.bonfi [e-mail]
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SECRETAT
CERTIFICATE OF SERVICE