20160801Staff 92-112 to AVU.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 7956
Street Address for Express Mail :
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
RECE IVE D
20 I & t'ilJG -I PM 2: 2 9
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVISTA CORPORATION DBA AVISTA )
UTILITIES FOR AUTHORITY TO INCREASE )
ITS RATES AND CHARGES FOR ELECTRIC )
SERVICE IN IDAHO. )
)
) ___________________ )
CASE NO. AVU-E-16-03
FIFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that A vista Corporation
(Company) provide the following documents and information as soon as possible, and no later than
MONDAY, AUGUST 23, 2016.
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 must
include the name and phone number of the 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. 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.
FIFTH PRODUCTION
REQUEST TO AVISTA 1 AUGUST 1, 2016
REQUEST NO. 92: Please explain the method and justification used to jurisdictionally
allocate the $2,525,000 cost of improvement assets related to the Westside (Substation) Rebuild
Phase I project discussed in Bryan Cox's Direct Testimony (pp. 28 -29).
REQUEST NO. 93: Please provide a Washington and Idaho jurisdictional breakdown of
Table No. 1: Distribution-Related Capital Projects (System $), shown on page 13 of
Ms. Rosentrater's Direct Testimony.
REQUEST NO. 94: Please provide an update to Adjustment 2.12, Colstrip and CS2
Maintenance Amortization Workpapers, showing actual amounts through June 2016 that were
provided as part of Ms. Andrews's workpapers in the Application.
REQUEST NO. 95: Please explain the Company's methodology for developing,
managing, executing, and completing Capital Projects considering a least cost approach. Please
provide a copy of any Company policies and procedures documenting the process.
REQUEST NO. 96: Please describe how the Company achieved the least cost solution for
the Little Falls Powerhouse Redevelopment project. Discuss alternatives the Company evaluated
and provide documentation used to achieve least-cost, such as request for proposals, list of potential
bidders, submitted proposals, bid evaluations, and bidder pricing. Also, please provide a copy of
the final EPC contract, construction organization charts, construction schedules (baseline vs.
actual), project status reports, action item lists, and change orders.
REQUEST NO. 97: Please provide copies of the most recent monthly construction reports for
the following projects:
• Powerhouse Rehabilitation Program, Units 1 and 2 Replacement Project for the Nine Mile
Hydroelectric Development of the Spokane River Project, FERC Project No. 2545;
• Post Falls Hydroelectric Development South Channel Dam Spillway Gates Replacement
Project, FERC Project No. 2545; and
• All other FERC mandated monthly construction reports.
Please provide continuous updates of these reports as they become available.
FIFTH PRODUCTION
REQUEST TO AVISTA 2 AUGUST 1, 2016
REQUEST NO. 98: Please provide a copy of the Company's Distribution Services
Business Plan.
REQUEST NO. 99: Please provide individual distribution circuit work plans and
associated time lines for past and future completion and in-service dates for those circuits which
serve Idaho load. Please provide detailed locational maps of each of the circuits serving Idaho.
REQUEST NO. 100: Please provide a copy of the Company's Grid Modernization
Business Plan. Please provide copies of the work plans developed for grid modernization
investments including completion dates and in-service dates for those circuits which (a) serve the
Company's entire service area; and (b) serve load in Idaho.
REQUEST NO. 101: Please provide a copy of the Company's Transmission Business
Plan.
REQUEST NO. 102: Please provide a single map of the locations for each of the
transmission investments described in Mr. Cox's Direct Testimony, including substation rebuilds
(e.g., West Side Phase 1, etc.).
REQUEST NO. 103: Please list the circuits and the associated load locations for each of
the transmission investments and substation rebuilds. For looped flow configurations, please list the
associated circuits and associated maximum monthly peak loads for the past three years.
REQUEST NO. 104: Please provide work plans and in-service dates for the each of the
transmission investments summarized in Mr. Cox's Direct Testimony.
REQUEST NO. 105: Please provide the Idaho customer load served by each of the
individual transmission investments summarized in Mr. Cox's Direct Testimony.
FIFTH PRODUCTION
REQUEST TO A VISTA 3 AUGUST 1, 2016
REQUEST NO. 106: Please provide the most recent ColumbiaGrid regional transmission
plan and the Company's most recent Local Transmission Plan. Describe how each of the
transmission capital plant investments summarized in Mr. Cox's Direct Testimony were
incorporated into one or both of the regional transmission and local transmission plans.
REQUEST NO. 107: Please provide a large scale, multi-ownership, map of each of the
transmission capital plant investments described in Mr. Cox's Direct Testimony that includes all
transmission, sub-transmission, and distribution assets by owner.
REQUEST NO. 108: Please describe all joint-ownership and joint-operation agreements
between the adjacent asset owners that impact the load served by the Company. Please provide
copies of any proposed or existing agreements.
REQUEST NO. 109: Please explain cost savings achieved by the Company via the
implementation of joint ownership and operation agreements. Please explain whether any of joint
operation/ownership agreements assist the Company in meeting existing reliability contingency
requirements. Please provide a list of potential joint operation/ownership agreements the Company
could pursue that could either increase reliability or increase transmission system operation
efficiencies.
REQUEST NO. 110: Please provide the annual total expenses associated with the Colstrip
transmission system for each of the previous 10 years.
REQUEST NO. 111: Please provide the calculation method, equation(s), values used, and
results of the Company's current OATT rates, including the source and time period used to create
each of the equation(s)' values and the date(s) when the current rates came into effect. Please
explain whether the Company plans to update the current OATT rates and whether the Company
plans to propose any changes to the current calculation method.
FIFTH PRODUCTION
REQUEST TO AVISTA 4 AUGUST 1, 2016
REQUEST NO. 112: Please provide a copy of all mitigation agreements and a list of all
associated pre-determined spending commitments for the Clark Fork relicensing. Please also
provide a summary of the associated annual costs. Information, where applicable, should be listed
by O&M expense, contract and other expense, construction and other account groups (listed by
functional categories). Please include wages and salaries for each employee category (officer,
exempt, non-exempt, and union), paid time-off, overtime, bonuses, incentive pay, and overheads for
pension, benefits, and payroll taxes. Please also include average and year-end number of employees
by employee category. Please include part-time and temporary employees as full-time equivalents.
Please provide a detailed description and examples of how the Company took steps to control costs
determined by the agreements and the Collaborative.
DATED at Boise, Idaho, this
Technical Staff: Rick Keller (92-96)
Mark Rogers (97)
Johanna Bell (98-112)
i:umisc:prodreq/avue I 6.3bkdkmlmmrkyybejbmrdekls prod req5
FIFTH PRODUCTION
REQUEST TO AVISTA 5
4} l ,,,,.-day of August 2016.
AUGUST 1, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I51 DAY OF AUGUST 2016,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-16-03,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
KELLY NORWOOD
VP -STATE & FED REG
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail : [e-mail]
[e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail: [e-mail]
DEAN J MILLER
3620 E WARM SPRINGS
BOISE ID 83716
E-mail: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
223 N 6TH ST STE 317
BOISE ID 83702
E-mail: [e-mail]
MARV LEW ALLEN
CLEARWATER PAPER CORP
E-MAIL ONLY:
[e-mail]
earn l [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES INSTITUTE
5549 S CLIFFSEDGE A VENUE
BOISE ID 83716
E-mail: [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83 702
E-mail: [e-mail]
~~~© SECRE ARY
CERTIFICATE OF SERVICE