20230503ICL_NWEC 1-13 to AVU.pdf

Marie Callaway Kellner (ISB No. 8470)
710 N 6 th Street
Boise, ID 83701
[phone]
[e-mail]
Attorney for the Idaho Conservation League
F. Diego Rivas (MT State Bar No. 68806741, pro hac vice admission)
1101 8 th Ave
Helena, MT 59601
[phone]
[e-mail]
Attorney for the NW Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF AVISTA
CORPORATION TO INCREASE
ITS RATES AND CHARGES FOR
ELECTRIC AND NATURAL GAS
CUSTOMER IN THE STATE OF
IDAHO
)
)
)
)
)
)
)
CASE NO. AVU-E-23-01;
AVU-G-23-01
FIRST PRODUCTION REQUEST
OF IDAHO CONSERVATION
LEAGUE AND NW ENERGY
COALITION TO COMPANY
COMES NOW the Idaho Conservation League (“ICL”) and NW Energy Coalition
(“NWEC”), jointly, with the following production requests for applicant Avista Corporation
(“Avista” or “Company”). Along with the answer to each question, please provide any
supporting documents, workpapers, calculations, communications, or information sources the
Company relies upon to support its answer. As required by IDAPA 31.01.01.228.02, please
indicate the witness who can answer questions regarding the response and who will sponsor the
response at any hearing. If any responses include Excel spreadsheets or other electronic files,
please provide them with all formulas intact and activated. As allowed by IDAPA
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01
First Production Request of ICL/NWEC Page 1
RECEIVED
2023 May 3, 3:37PM
IDAHO PUBLIC
UTILITIES COMMISSION
31.01.01.228.01, if the volume of any response indicates it would be more feasible to do so, ICL
and NWEC agree to the Company depositing the response in an electronic depository.
This production request is ongoing. Accordingly, we respectfully ask Avista to provide
additional documents and information that may supplement any initial responses. We ask the
Company to provide responses at earliest convenience if available before the 21-day response
period required by IDAPA 31.01.01.225.
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01
First Production Request of ICL/NWEC Page 2
Request For Production No. 01
Please provide all responses to production requests filed prior to intervention order No.
35719, dated March 22, 2023.
Request For Production No. 02
Please identify and provide the number of residential household subscribers to electric
service Schedule 1 who are low-income, defined by individual or family taxable income not
exceeding 150% of the federal poverty threshold.
. Request For Production No. 03
Please provide the following:
a) For each line transformer, the number of residential customers connected and amount of
energy that flows through each.
b) Number of line transformers that serve multiple customers.
c) Number of line transformers that serve single customers.
Request For Production No. 04
Please provide the test year budget for Company operations related to connecting
additional customers to Residential Service Schedule 1. Please provide also the number of
customer accounts connection to Schedule 1
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01
First Production Request of ICL/NWEC Page 3
Request For Production No. 05
Please provide the most recently completed conservation potential assessment and end
use study completed for Avista, including any updates, supporting documentation, studies,
memos, or other supplemental information used to develop each.
Request For Production No. 06
Please provide each of the following for the previous five years:
a) Energy efficiency targets as identified by the most recent conservation potential
assessment
b) Actual energy efficiency acquisition
c) Energy efficiency budget
d) Energy efficiency actual spend totals
e) Energy efficiency actual spend, broken down by category, including incentive payments,
marketing, administration and any other relevant category.
Request for Production No. 07
Miller Direct at 7, line 15 states: “If the Commission were to order a lower revenue
requirement than filed for, the Company proposes to allocate the same increase as the Company’s
initial filing to Residential Service Schedule 1, Large General Service Schedules 21/22, and
Pumping 18 Service Schedules 31/32.”
Please provide any work papers or communications related to allocating rate spread or
relative ROR amongst the identified schedules at decreasing revenue requirements.
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01
First Production Request of ICL/NWEC Page 4
Please include calculations for distributing relative ROR among these schedules at
incremental decreases in revenue requirement below that requested by the Company.
Request for Production No. 08
Please provide the customer charge for residential customer schedules comparable to
Idaho Schedule 1 in Avista’s Washington service territory.
Request For Production No. 09
Please provide the authorized revenue requirement and actual revenues for the last five
calendar years (2018-2022).
Request For Production No. 10
Please provide the number of energy efficiency program participants, by measure, for the
previous five years as well as anticipated participants for future years.
Request For Production No. 11
Please provide the number of hours, and percentage of hours, Avista purchased power in
the short-term market (i.e. day ahead, hour ahead). Please also provide the percentage of those
hours that occurred at system peak.
Request For Production No. 12
Please provide a brief narrative description of Avista’s Comfort Level Billing program.
Please also provide the number of customers participating in the Comfort Level Billing program
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01
First Production Request of ICL/NWEC Page 5
over the past five years starting in 2018. Please also provide the number of customers
participating in the program, but disqualified for bill default or other failure to pay.
Request For Production No. 13
Please provide all marketing materials related to the Comfort Level Billing Program
delivered in the past two years. Please provide also, a narrative or numerical description of the
reach of those marketing materials.
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01
First Production Request of ICL/NWEC Page 6
CERTIFICATE OF SERVICE
I hereby certify that on this 3rd day of May, 2023, I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST to the following persons via the method of
service noted:
/s/ F. Diego Rivas
F. Diego Rivas
(MT State Bar No. 68806741)
Attorney NW Energy Coalition
1101 8 th Ave
Helena, MT 59601
[e-mail]
Electronic Mail Only (See Order No.
35058):
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
[e-mail]
Commission Staff
Chris Burdin
Deputy Attorneys General
Idaho Public Utilities Commission
[e-mail]
Avista Corporation
David J. Meyer
Patrick D. Eherbar
P.O. Box 3727
1411 W. Mission Ave
Spokane WA, 99220
[e-mail]
[e-mail]
[e-mail]
Clearwater Paper
Peter Richardson
Richardson Adams PLLP
515 N. 27 th St.
Boise ID, 83702
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Dr. Don Reading
280 Silverwood Way
Eagle ID, 83616
[e-mail]
Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 W. Liberty St., Suite 750
Reno NV, 89502
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01
First Production Request of ICL/NWEC Page 7
Steve W. Chriss
Walmart Inc.
2608 SE J St.
Bentonville AR, 72716
[e-mail]
Idaho Forest Group
Andrew P. Moratzka
Stoel Rives LLP
33 S. Sixth St, Suite 4200
Minneapolis, MN 55402
andrew.moratzka @stoel.com
Larry A. Crowley
The Energy Strategies Institute
3738 S. Harris Ranch Ave.
Boise, ID 83716
[e-mail]
Bradley Mullins
MW Analytics
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01
First Production Request of ICL/NWEC Page 8