20170106Motion.pdf

CAMILLE CHRISTEN, ISB NO. 10177
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 W. WASHINGTON STREET (83702-5918)
P.O. BOX 83720
BOISE, ID 83720-0074
Telephone: [phone]
E-mail: [e-mail]
Attorney for the Commission Staff
RECE IVED
2011 JA '-6 P.M 11 : 38
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF AVISTA CORPORATION FORA ) CASE NO. AVU-E-16-06
FINDING OF PRUDENCE FOR 2014-2015 )
EXPENDITURES ASSOCIATED WITH ) MOTION FOR
PROVIDING ELECTRIC ENERGY ) PROCEDURAL RELIEF
EFFICIENCY SERVICE IN THE STATE )
_O_F_ID_A_H_O ___________ )
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Camille Christen, Deputy Attorney General, and respectively moves under
Rule 256.03 of the Commission's Rules of Procedure (IDAPA 31.01.01.256.03), for an Order
suspend the comment deadlines in this case, as set in Order No. 33644.
On September 14, 2016, A vista Corporation dba A vista Utilities filed an Application
requesting the Commission to issue an Order finding that the Company prudently incurred
$9,999,742 in electric energy efficiency expenses in Idaho from January 1, 2014 through
December 31, 2015. The Application describes the Company's energy efficiency activities and
their cost-effectiveness. The Application includes an evaluation of the Company's electric
energy efficiency program, performed by a third-party contractor, Nexant, and supporting
testimony.
The Commission issued a Notice of the Application which set a deadline for
interventions. Order No. 33617. The Commission received and granted Petitions to Intervene
from the Community Action Partnership Association of Idaho (CAP AI) and the Idaho
Conservation League. Order No. 33636.
MOTION FOR
PROCEDURAL RELIEF 1
The parties conferred and agreed upon a comment schedule which Staff proposed to
the Commission. The Commission issued a Notice of Modified Procedure adopting the agreed­
upon deadline for comments of January 31, 2017, and deadline for reply comments of February
21, 2017. Order No. 33644. Staff now respectfully moves to suspend these deadlines.
Good cause exists to suspend the deadlines because:
1. In the course of its review of the Application, Commission Staff
discovered potential discrepancies in the data used in the analysis
supporting the Application (specifically, in the data used by the Company
and that used by its contractor, Nexant). Staff raised its questions about
the data with the Company and Nexant. They indicated that additional
time is needed to resolve Staffs questions.
2. All parties to the case have advised Staff that they concur with suspending
the deadlines and that once the questions are resolved, they will discuss a
new comment schedule to propose to the Commission.
3. Staff proposes to provide an update to the Commission regarding the
timeline for resolution of the questions no later than January 31, 2017.
Accordingly, Staff respectfully requests that the Commission grant the Motion and
suspend the January 31, 2017 comment and February 21, 2017 reply comment deadlines.
Respectfully submitted this 61h day of January 2017.
N:AVU-E-16-06_cc_Motion to Suspend
MOTION FOR
PROCEDURAL RELIEF
Camille Christen
Deputy Attorney General
2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF JANUARY 2017,
SERVED THE FOREGOING MOTION FOR PROCEDURAL RELIEF, IN CASE
NO. AVU-E-16-06, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LINDA GERVAIS
SENIOR MGR REGULA TORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83 702
E-MAIL: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE