20170803Staff 46_73 to AVU.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGBS FOR ELECTRIC
AND NATURAL GAS SERVICE IN IDAHO
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-59I8
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU.E.U-oI
AVU-G-I7-01
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, by
THURSDAY, AUGUST 24, 2017.
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
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
3l.01.01.228.
FOURTH PRODUCTION REQUEST
TO AVISTA 1
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AUGUST 3,2017
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. 46: Please provide current electronic copies of technology lifecycle
roadmaps for the Technology Refresh Business project. Kensok Direct at20.
REQUEST NO. 47: Please explain how the Technology Refresh to Sustain Business
Process project expenses of $21,191,000 in 2017, $16,957,000 in 2018 and $14,140,000 in2019
benefits Idaho customers. Kensok Direct at 14. Please include all supporting workpapers and
analysis.
REQUEST NO. 48: Please explain how the Technology Expansion to Enable Business
Process project expenses of $13,941,000 in 2077, $14,350,000 in 2018 and $12,315,000 in20l9
benefits Idaho customers. Kensok Direct at 19. Please include all supporting workpapers and
analysis.
REQUEST NO.49: Please describe and include examples of the o'mandatory
investment drivers" referenced in Mr. Kensok's testimony. Direct at27.
REQUEST NO. 50: Mr. Kensok states that"25o/o of [the Company's] in-service
[technology] assets are beyond [the] manufacturer lifecycle." Please explain the risks associated
with deferring technology upgrades in order to fund the Technology Refresh project at20l6
levels when a quarter of these assets are already beyond the manufacturer lifecycle. Kensok
Exhibit 10, Schedule 1, at 12. Please include all supporting workpapers and analysis.
REQUEST NO. 51: Please describe how the High Voltage Protection Refresh project
aligns with and supports current and expected reliability and critical infrastructure regulations,
requirements and initiatives. Kensok Exhibit 10, Schedule l, at 24. Please include all
supporting workpapers and analysis.
FOURTH PRODUCTION REQUEST
TO AVISTA 2 AUGUST 3,2017
REQUEST NO. 52: Please describe the storage software referenced in testimony.
Morehouse Direct at7.
a.) Did the Company purchase the software or develop it internally?
b.) How will the software be used?
REQUEST NO. 53: Please provide the supporting analysis and workpapers used to
determine the approximately $20 million yearly Gas Facilities Replacement Program values
listed in Morris Exhibit No. l, Schedule 2, at 28 Table 1 I .
REQUEST NO. 54: Please explain how the Company recovers dig-in expenses. Morris
Exhibit No. 1, Schedule 2, at 37 . Please include all supporting workpapers and analysis.
REQUEST NO. 55: Please describe how the Gas Telemetry Program costs are allocated
to individual customers and customer classes. Rosentrater Direct at 56. If costs are not
allocated, please explain why not.
REQUEST NO. 56: Please explain how the Company determined that a 45-percent
reduction in the Overbuild Pipe Replacement Program achieves an acceptable level of risk.
Rosentrater Direct at 58. Additionally, please provide the Company's definition of acceptable
risk.
REQUEST NO. 57: Please quantify the annual and per unit reduction of O&M costs
due to reducing farm taps referred to in Rosentrater Exhibit 8. Please include all supporting
workpapers and analysis.
REQUEST NO. 58: Please provide the business case for the Meter Data Management
System. Rosentrater Direct at 64. Please include all supporting workpapers and documentation.
a.) Please explain why the Meter Data Management System business case was
changed from the Enterprise Technology functional group in20l6 to the General
Plant functional group in2017.
FOURTH PRODUCTION REQUEST
TO AVISTA J AUGUST 3,2017
b.) Please include all benefit-cost analysis conducted showing the value of the Meter
Data Management System before and after AMI is implemented in both Washington
and Idaho. Please include all supporting workpapers and documentation, including
jurisdictional allocations and costs.
REQUEST NO. 59: Please provide all workpapers and documentation for Idaho AMI
business case.
REQUEST NO. 60: Please describe how Avista calculates the cost effectiveness of
replacing overhead feeders with underground lines. Rosentrater Direct at 9.
REQUEST NO.61: Regarding Distribution Wood Pole Management, please provide
the location and number of affected poles in Idaho and Washington. Rosentrater Direct at20.
REQUEST NO. 62: Please provide all studies conducted that compare the overhead and
underground options for the URD replacement projects in Idaho. Rosentrater Direct at2l.
REQUEST NO. 63: Please provide the locations and workpapers associated with Idaho
URD replacement projects. Please include accelerated replacement schedules and calculations
for avoided outage estimations. Rosentrater Direct at22.
REQUEST NO. 64: Regarding the LED Change Out Program, please provide the
locations and associated expense for all Idaho projects. Rosentrater Direct at28.
R-EQUEST NO. 65: Please provide information about all penalties, monetary and
otherwise, that have occurred because of non-compliance with NERC standards. Rosentrater
Direct at32.
REQUEST NO. 66: Please list and provide the associated expense for all proposed
Idaho distribution substation projects, including rebuild projects and new distribution
substations.
FOURTH PRODUCTION REQUEST
TO AVISTA 4 AUGUST 3,2017
REQUEST NO. 67: Please describe how the Hallett and White substation
interconnection investment for an existing large retail customer is a prudent expense for Idaho
customers. Rosentrater Direct at 41.
REQUEST NO. 68: Regarding OATT, please cite the federal rules which require the
Company to construct transmission facilities at the request of transmission customers. Please list
proposed projects and associated expense related to customer requests for new transmission
facilities. Rosentrater Direct at 43.
REQUEST NO. 69: Please include the details and map of the proposed Saddle
Mountain 230l115kV station integration project and demonstrate how this transmission
investment will benefit Idaho rate payers. Rosentrater Direct at 43.
REQUEST NO. 70: For Electric Rate Schedule2ll22 - Extra Large General Service -
Idaho, with approximately 1,125 Idaho customers, please provide - by customer - monthly
energy (kwh) and monthly demand (maximum 15 minute demand in a month, kW) for each
month of the test year. Please provide in Excel format, with one record (customer) per row.
REQUEST NO. 71: For each month of the test year - for each electric Extra Large
General Service (Schedule 25) customer and for Clearwater Paper (Schedule 25-A) - on a
confi dential basis, please provide:
a. kWh:
b. kW (actual):
c. kW (billed) - if different from actual kW due to contract minimums, ratchets,
etc.: and
d. billed revenue
FOURTH PRODUCTION REQUEST
TO AVISTA AUGUST 3,20175
REQUEST NO. 72: For Gas Rate Schedule I I llll2 - Large General Service - Idaho,
with approximately 1,408 Idaho customers, please provide - by customer - monthly gas usage
(therms) for each month of the test year. Please provide in Excel format, with one record
(customer) per row.
REQUEST NO. 73: Page26,line22 of Mr. Ehrbar's testimony shows that currently
there are no Intemrptible gas customers (Schedules l3lll32). Has the Company ever provided
service to a customer under this gas rate schedule? Please provide the name(s) of any
customer(s) and when service was provided.
Dated at Boise,Idaho, this h/Z day of August 2017
Deputy General
Technical Staff: Kevin Keytl46-59
Rachelle Famsworth/60-69
Bentley Erdwurm/70-73
i:umisc:prodreq/avue I 7. 1_avug I 7. I bkkskrfbe prod req4
FOURTH PRODUCTION REQUEST
TO AVISTA 6 AUGUST 3,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY oF AUGUST 2017,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU.E,-I7-
OI/AVU-G-17-OI, BY E-MAILING ANDMAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
KELLY O NORWOOD
VP STATE & FED REG
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3721
E-MAIL: [e-mail]
avi stadockets @avi stacorp. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE TD 83702
E-MAIL : [e-mail]
gre e@,richard sonadam s. com
ELECTRONIC ONLY
CLEARWATER PAPER CORP.
caro l. hau gen@clearwaterpaper. com
marv(@malewallen.com
i ohn j [e-mail]
david.wren@clearwaterpaper. com
nathan. sm ith@clearwaterpaper. com
RONALD L WILLIAMS
WILLIAMS BRADBURY
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES INSTITUTE
5549 S CLIFFSEDGE AVENUE
BOISE ID 83716
DAVID J MEYER
VP & CHIEF COLINSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
20I9 N 17TH ST
BOISE ID 83702
E-MAIL: [e-mail]
ELECTRONIC ONLY
DEAN J MILLER
3620 E WARM SPRINGS
BOISE ID 83716
E-MAIL: [e-mail]
EMILY MATTHEWS
E-MAIL : [e-mail]
E-MAIL: crowley com
CERTIFICATE OF SERVICE
MATTHEW A. NYKIEL
ID CONSERVATION LEAGUE
PO BOX 2308
102 S EUCLTD #207
SANDPOINT ID 83864
E-MAIL: [e-mail]
TRAVIS RITCHIE
SIERRA CLUB
2IO1 WEBSTER ST., SUITE 13OO
OAKLAND, CA 94612
E-MAIL : [e-mail]
J fl"O^r_-_tr.*tei.&-
CERTIFICATE OF SERVICE