20160812Staff to AVU 113-141.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
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
A VISTA CORPORATION DBA AVISTA )
UTILITIES FOR AUTHORITY TO INCREASE )
ITS RA TES AND CHARGES FOR ELECTRIC )
SERVICE IN IDAHO. )
)
) ___________________ )
CASE NO. AVU-E-16-03
SIXTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation provide
the following documents and information as soon as possible, and no later than FRIDAY,
SEPTEMBER 2, 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.
SIXTH PRODUCTION
REQUEST TO AVISTA 1 AUGUST 12, 2016
REQUEST NO. 113: Please describe and quantify the impact of using 2016 weather­
normalized loads in place of 2015 weather-normalized loads used in this filing. Please include
impacts to retail rates, the overall revenue requirement, and net power costs. Please provide all
AURORA files and workpapers reflecting the calculations (with formulas intact) using the 2016
loads. Please include non-labor administrative and general, operating and maintenance expenses,
and all other relevant expenses in 2016 in the calculation. Note: These expenses were not included
in Avista's Response to Production Request No. 62.
REQUEST NO. 114: Please provide electronic schedules showing the Annual Capital
Expenditures Budgets for the last 10 years, as of December 31, 20XX. Please include at least the
budgeted amount, the actual spend amount, and the amount booked to plant in service by year by
functional category (i.e., environmental, gas, generation, growth, enterprise technology, other, and
transmission & distribution).
REQUEST NO. 115: Please update the following Company adjustments, both Commission
Basis and Pro Forma adjustments as of December 31, 2016.
• Adjustment 1.02 -Deferred Debits, Credits, and Regulatory Amortizations
• Adjustment 2.05 -FIT/DFIT/ITC/PTC Expense
• Adjustment 3.02 -Pro Forma Transmission Rev/Exp
• Adjustment 3.05 -Pro Forma Property Tax
REQUEST NO. 116: Please explain all obligations that Idaho jurisdictional ratepayers
have in supporting the contractual commitment to the Palouse Wind project.
REQUEST NO. 117: Please explain given the 20% bonus Apprenticeship Credit provided
by Washington State for Palouse Wind RECs, and why this has not been recognized in past sales of
these RECs. Please identify any limitations to the use of the Apprenticeship Credit.
SIXTH PRODUCTION
REQUEST TO AVISTA 2 AUGUST 12, 2016
REQUEST NO. 118: Please explain the methodology in utilizing the RECs associated with
Palouse Wind as it relates to: 1) meeting Washington State RPS requirements; 2) taking advantage
of the 20% bonus Washington State Apprenticeship Credits for Palouse Wind; 3) the sale of Palouse
Wind RECs to third parties; and 4) the use of Palouse Wind RECs in meeting the Washington State
RPS in lieu of other sourced RECs.
REQUEST NO. 119: How will the credit of Palouse Wind RECs be allocated to Idaho
when the Company receives the premium for the Washington State Apprenticeship Credit?
REQUEST NO. 120: Please provide a copy of the Funding Summary Table (Appendix U)
for the Clark Fork Settlement Agreement, Project 2058, as filed with FERC in 1999. Please also
provide copies of all the Avista Clark Fork Settlement Agreement (CFSA), Annual Budget Reports
(i.e., years 1 through 17), and Implementation Plan Budgets.
REQUEST NO. 121: Please provide a table that lists each project associated with each
expense and type (i.e., capital investments, labor, maintenance, etc.) of the funded appendixes of the
CFSA for the following general rate cases: AVU E-11-01, AVU E-12-08, AVU E-15-05, and AVU
E-16-03. Within this table please provide the test year and proforma amounts allowed in to rates,
and the actual expenditures for each test year and proforma.
REQUEST NO. 122: Please provide a detailed description of the controls that are in place
to ensure the projects being implemented under the CFSA are least cost. Please describe the steps
taken to develop each project budget and during project implementation to document the prudency
of expenditures. Please explain if different budget development and implementation processes are
applied if the projects implementation is conducted by: (1) the Company; (2) a contract managed by
the Company; (3) government agency or stakeholder staff; or (4) a contract management by a
government agency or stakeholder.
REQUEST NO. 123: Please provide copies of all mitigation agreements and a list of all
associated pre-determined spending commitments for the Spokane River Hydroelectric and Post
Falls FERC Dam Safety requirements.
SIXTH PRODUCTION
REQUEST TO AVISTA 3 AUGUST 12, 2016
REQUEST NO. 124: Please provide a table that lists each project associated with each
expense and type (i.e., capital investments, labor, maintenance, etc.) of the funded projects of the
Spokane River Hydroelectric License for the following general rate cases: AVU E-11-01, AVU E-
12-08, AVU E-15-05, and AVU E-16-03. Within this table please provide the test year and
proforma amounts allowed in to rates, and the actual expenditures for each test year and proforma.
REQUEST NO. 125: Please provide a table that lists each project associated with each
expense and type (i.e., capital investments, labor, maintenance, etc.) of the funded projects of the
Post Falls FERC Dam Safety requirements for the following general rate cases: AVU E-11-01;
AVU E-12-08; AVU E-15-05; and AVU E-16-03. Within this table please provide the test year and
proforma amounts allowed in to rates, and the actual expenditures for each test year and proforma.
REQUEST NO. 126: Please provide a table that lists each project, associated with each
expense and type (i.e., capital investments, labor, maintenance, etc.), for all distribution and
transmission expenditures for the following general rate cases: A VU E-11 -01; A VU E-12-08;
A VU E-15-05; and A VU E-16-03 . Within this table please provide the test year and proforma
amounts allowed in to rates, and the actual expenditures for each test year and proforma.
REQUEST NO. 127: Please provide an update to Staff Production Request No. 22 through
July 2016. Please provide this workbook with the expenditure requests in the same format as the
May 2016 file included in response to Production Request No. 22. Please include the following
information in columns 'K' and 'L' of the expenditure requests reports tab for the following:
• Expected in-service dates for each project.
• Length of construction time for each project.
REQUEST NO. 128: With respect to Production Request No. 127, please carry through the
July 2016 Year-to-Date actual expenditures to Karen Schuh's Exhibit No. 10, Schedule 3. Please
provide the same with expected year-end expenditures.
SIXTH PRODUCTION
REQUEST TO AVISTA 4 AUGUST 12, 2016
REQUEST NO. 129: In AVU-E-15-05, the Company estimated costs of $2 million to
redesign AvistaUtilities.com. AVU-E-15-03 now shows 2016 costs of $5.5 million. Please explain
why the Company's estimates have increased by $3.5 million. Please describe the updates that have
been made to the website and whether or not the redesign is done internally, or by a third party.
Please further describe the criteria for determining if the website incorporates "best practices for
customer usability and security", as stated on page 13 of the Direct Testimony of Mr. Kensok.
REQUEST NO. 130: In AVU-E-15-05 , the Company did not estimate any costs for the
Cabinet Gorge Unit 1 Refurbishment or the Post Falls South Channel Replacement in 2016 or 2017.
Both projects now have 2016 transfer to plant amounts over $14 million. Please provide a detailed
explanation of these costs.
REQUEST NO. 131: In AVU-E-15-05 , the Company estimated Central Office Facility
Restructuring -Phase 1 expenditures of $4 million for 2016. This project now has 2016
expenditures listed at $9.6 million. Please provide a detailed explanation of these costs, particularly
the difference between the Phase 1 estimate and the current estimate.
REQUEST NO. 132: In AVU-E-15-05, the Company did not estimate any costs for the
Next Generation Radio Refresh project for 2016 or 2017. This project now has 2016 expenditures
listed at $6 million. Please provide a detailed explanation of these costs, including why costs for
this project were not anticipated in the prior rate case.
REQUEST NO. 133: In A VU-E-15-05, the Company estimated Regulating Hydro
expenditures of $3 .5 million for 2016. This project now has 20 I 6 expenditures listed at $5 million.
Please provide a detailed explanation of these costs, particularly the difference between last year's
estimate and the current estimate.
REQUEST NO. 134: In A VU-E-15-05 , the Company estimated Noxon Switchyard
Rebuild expenditures of $0.5 million for 2016. This project now has 2016 expenditures listed at
$11.5 million. Please provide a detailed explanation of these costs, particularly the difference
between last year's estimate and the current estimate.
SIXTH PRODUCTION
REQUEST TO AVISTA 5 AUGUST 12, 2016
REQUEST NO. 135: Please refer to Heather Rosentrater Exhibit No. 7, Schedule 4, Page
86 of 88, the Business Case for Segment Reconductor & FDR Tie Program. The Business Case is
illustrating an IRR of 0.00% with no business risk reduction. Additionally, the Business Case states
that there is low certainty around cost, schedule and resources. Given the parameters shown in the
Business Case, please explain why A vista chose to proceed with this investment. Please include in
your response all customer benefits associated with this investment, alternative approaches to this
investment, and justification for this investment to be included in rate base.
REQUEST NO. 136: Please provide a copy of the 2015 Shared Value Report.
REQUEST NO. 137: In response to Production Request No. 47, historical transfers to
plant for the Meter Minor Blanket show a five-year average (2011-2015) of 8.99% assigned to the
Idaho jurisdiction. Please provide justification for the 43 .92% of the 2016 proforma amount being
assigned to Idaho .
REQUEST NO. 138: For each of the environmental cleanup costs listed on the Company's
response to Staff Production Request No. 9, please provide a brief explanation of the event and how
those costs were allocated to A vista's jurisdictions.
REQUEST NO. 139: For the two swales constructed on the Avista corporate campus,
please provide a listing of all expenses associated with the construction, and the accounts to which
they were booked. Please also describe the necessity and benefit of the swales.
REQUEST NO. 140: Please provide actual transfers to plant for each month of 2016 with
estimates for the remaining pro forma months throughout the year.
SIXTH PRODUCTION
REQUEST TO AVISTA 6 AUGUST 12, 2016
REQUEST N0.141
CONTAINS CONFIDENTIAL
INFORMATION SUBJECT
TO PROTECTIVE
AGREEMENT.
SIXTH PRODUCTION
REQUEST TO A VISTA 7 AUGUST 12, 2016
DA TED at Boise, Idaho, this ( z. ~ day of August 2016.
Technical Staff: Yao Yin (113)
Kathy Stockton ( 114-115)
Rick Keller (116-119)
Johanna Bell (120-126)
Mark Rogers (127-134)
Donn English (135-141)
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SIXTH PRODUCTION
REQUEST TO AVISTA
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8 AUGUST 12, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 121h DAY OF AUGUST 2016,
SERVED THE FOREGOING SIXTH 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]
[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 83702
E-mail: [e-mail]
CERTIFICATE OF SERVICE