20240411Staff 1-3 to AVU.pdf

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Thursday,April 11,2024 4.17.40 PM
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DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ELECTRIC LINE )
EXTENSION SCHEDULE 51 ANNUAL RATE ) CASE NO.AVU-E-24-05
ADJUSTMENT FILING OF AVISTA )
CORPORATION )
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA UTILITIES
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General,requests that Avista Utilities ("Company")provide the
following documents and information as soon as possible, but no later than THURSDAY,
APRIL 18, 2024.'
This Production Request is to be considered as continuing, and the Company 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
I Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0312.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 APRIL 11, 2024

the person preparing the documents. Please also identify 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 with formulas intact and enabled.
PRODUCTION REQUEST 1: In reference to the OH Transformer and UG
Transformer work order cost estimates provided on pages 23 and 30 of the Application, please
respond to the following:
a. Please explain why the Electric Admin and Acct, Electric Labor Overhead, Electric
Material Overhead, and Electric Overhead line items do not add up to the Overhead
Amt total like the other work order cost estimates;
b. Please explain why the Electric Admin and Acct, Electric Labor Overhead, Electric
Material Overhead, and Electric Overhead line item costs are not included as part of
the weighted allocation calculation that determines the fixed cost for these
transformers; and
c. For UG Transformers, please explain the drivers that caused the unit price reductions
for 25 kVA, 37.5 kVA, and 100 kVA transformers, while the 15 kVA, 50 kVA, and
75 kVA transformer unit prices increased compared to last year.
PRODUCTION REQUEST 2: Please explain the major drivers that caused the 24%
increase in the Overhead Service Circuit cost from last year.
PRODUCTION REQUEST 3: Please provide a copy of the workpapers showing the
calculations of the overhead rates used in the work order cost estimates and a copy of the
Overhead Policy document that was followed in the application of overheads. Please provide
workpapers in electronic format with all formula enabled and inputs identified by their source.
DATED at Boise, Idaho, this 1 Ith day of April 2024.
Dayn Hardk
Deputy Attorney General
1:\Utility\UNDSC\PRDREQ\AVU.E-24-05 PR#Ldocx
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 APRIL 11, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IITH DAY OF APRIL 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA UTILITIES, IN CASE NO. AVU-E-24-05, BY E-MAILING A
COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: patrick.elirbar(c�avistacom.com E-mail: david.meyer(i�avistacorp.com
I M v kC/ y
KERI HAWYER
CERTIFICATE OF SERVICE