20150911Staff 155-156 to AVU.pdf

KARL T. KLEIN
BRANDON KARPEN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-0320 1334-03 s7
IDAHO BAR NOS. 515617956
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES FOR ELECTRIC
AND NATURAL GAS SERVICE IN IDAHO.
1i
CASE NO. AVU-8,I5-05
AVU-G-15-01
SIXTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
i il
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, and no later
than FRIDAY, SEPTEMBER 25,2015.1
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
SIXTH PRODUCTION REQUEST
TO AVISTA SEPTEMBER 11,2015
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 155: Please explain why the Company applied a uniform percentage
increase to the energy charges of its other commercial schedules, but not for Schedule Nos. 1 1
and 12. Furthermore, page 16 of Pat Ehrbar's testimony says, leaving the second block
unchanged will provide o'more meaningful separation between blocks." Since increasing the rate
of the first block while holding the charge for second block usage constant would decrease
(rather than increase) separation between blocks, please explain how the Company's proposal
provides more meaningful separation between blocks.
REQUEST NO. 156: For Schedule Nos. I I and 12, please provide a bill impact analysis
comparing current rates to the Company's proposal and to a proposal that applies a uniform
percentage increase to both energy blocks.
Dated at Boise, Idaho, this t I +L day of September 2015.
xu 1L
Karl T. Klein
Deputy Attorney General
Technical Staff: Stacey Donohue/l 55-1 56
i:umisc:prodreq/avuel5.5_avugl 5. lkkbksd prod req6
SIXTH PRODUCTION REQUEST
TO AVISTA SEPTEMBER 11,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I ITH DAY OF SEPTEMBER 2075,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-I5-05/AVU-G-I5-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
KELLY NORWOOD
VP _ STATE & FED REG
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83702
E-mail : j [e-mail]
CLEARWATER PAPER CORP
C/O PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-mail : [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N ITTH STREET
BOISE ID 83702
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE ID 83702
E-mail : [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES
INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 837I6
E-mail : [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 8370I
E-mail: [e-mail]
kmil I er@ snakeriveralliance. or g
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*
SECRETARY '
I.
CERTIFICATE OF SERVICE