20130925Staff 1-3 to Avista.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA CORPORATION'S )
APPLICATION TO FUND SELECTED RESEARCH) CASE NO. AVU-E-13-08
AND DEVELOPMENT EFFICIENCY PROJECTS. )) rrRsr PRoDUCTIoN
) REQUEST OF THE
) coMMrssloN STAFF TO
) AVTSTA CORPORATTON
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that Avista Corporation (Company; Avista)
provide the following documents and information as soon as possible, by WEDNESDAY,
ocToBER 9, 2013.
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
the person preparing the documents. Please identi$ the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION SEPTEMBER 25, 2013
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the amounts for Research and Development that
Avista pays annually in its other jurisdictions. Please include the entity to which those payments
are made, and the scope of the work done by those entities.
REQUEST NO. 2: Please explain why Idaho customers should pay for Research and
Development projects that will benefit customers in other jurisdictions.
REQUEST NO.3: The Company's Application reads, "Research and development is
defined, for the purpose of this proposal, to be applied R&D that could yield benefits to
customers in the next one to four years." (Application, page 3). But the list of project types that
may be considered for funding includes a description of the University of Idaho's Integrated
Design Lab's (IDL) work that reads "Involvement on these projects spans both basic and applied
research..." (Application, page 6). Please confirm that the reference to "basic" research
references IDL's past or ongoing work outside of this funding proposal, not projects that would
be funded through Schedule 91.
DATED atBoise,Idaho, this Z# dayof September 2013.
Technical Staff: Donn English/l & 2
Stacey Donohue/3
i:umisc:prodreq/avuel3.8kkdesd prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
44-
Karl T. Klein
Deputy Attorney General
SEPTEMBER 25, 2OI3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF SEPTEMBER 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
coMMrssloN sTAf,'F TO AVISTA, N CASE NO. AVU-E-13-08, BY E-MAILING
AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BO){ 3727
SPoKANE WA99220-3727
E-MAIL: linda. [e-mail]
CERTIFICATE OF SERVICE