20170825Staff 99-111 to AVU.pdf

.- i I-"*)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 CHARGES FOR ELECTRIC
AND NATURAL GAS SERVICE IN IDAHO
. ,)r- nll ?. nQI r-J ltt (.. Lr./
Street Address for Express Mail:
4]2 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU.E-17.0I
AVU-G-I7-01
SEVENTH 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 FRIDAY,
SEPTEMBER 15, 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
31.0t.01.228.
SEVENTH PRODUCTION REQUEST
TO AVISTA I AUGUST 25,2017
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. 99: Please provide the actual average yearly and monthly electricity
market sale prices and the actual average yearly and monthly dispatch prices in2016 for each
Company generation resource. Please provide information in Excel format with all formula
intact.
REQUEST NO. 100: Please provide the average yearly and monthly electricity market
sale prices and the average yearly and monthly dispatch prices in pro forma 2018 for each
Company generation resource. Please provide information in Excel format with all formula
intact.
REQUEST NO. 101: Please provide the most recent asset management plans and
studies for the following business cases: (1) Little Falls Plant Upgrade; and (2) Nine Mile
Rehabilitation.
REQUEST NO. 102: For the Little Falls Plant Upgrade, please provide the most recent
project schedule, scope, and budget. Please also document changes from original documents.
REQUEST NO. 103: For the Nine Mile Rehabilitation, please provide the complete
evaluation of the project alternative's review, the analysis process, and risks associated with the
project analysis that was mentioned in Kinney Exhibit 4, Schedule 3 onpage 47.
REQUEST NO. 104: For the Nine Mile Rehabilitation, please provide the most recent
project schedule, scope, and budget. Please also document changes from original documents.
REQUEST NO. 105: Please provide the three most recent annual business plans for the
Colstrip 3 and 4 Capital Projects business case mentioned in Kinney Exhibit 4, Schedule 3 on
page 91.
SEVENTH PRODUCTION REQUEST
TO AVISTA AUGUST 25,20172
REQUEST NO. 106: For the South Region Voltage Control Project, please provide the
most recent project schedule, scope, and budget. Please also document changes from original
documents.
REQUEST NO. 107: Please explain the difference in the requested spend amount of
$11,850,000 for the Transmission Construction - Compliance business case (Exhibit 8, Schedule
5, pg. 136) compared to $15,390,000 in the 2017 Capital Additions Detail Table (Exhibit 11,
Schedule 1, pg. 1). In addition, please provide the most recent schedule, scope, and budget for
all the projects included in this business case. Please also document changes from original
documents.
REQUEST NO. 108: Please provide the most recent monthly project status update
including the status of the scope, schedule, and budget for the Kettle Falls Water Treatment
System business case. Please also provide all future monthly project status updates as they
become available through the end of this case.
REQUEST NO. 109: In reference to Attachment A included in response to the
Production Request No. 43, please provide the budgeted January through May total system
transfers to plant for 2017 on a monthly basis, by expenditure request. Please also provide future
monthly transfers to plant as they become available through the end of this case.
REQUEST NO. 110: Please provide copies of all executive Outlook calendars and
Daily Planners for 2016 showing day-to-day details supporting the allocation of executive time
for regulated operations. Please also provide any other documentation supporting these
allocations.
REQUEST NO. 111: For all of the environmental costs listed in the Company's
response to Staff Audit Request No. 6, please provide a brief narrative of the incident causing the
cleanup expense and the jurisdictional allocation of the expenses.
SEVENTH PRODUCTION REQUEST
TO AVISTA AUGUST 25,2077aJ
Dated at Boise, Idaho, this Xq+Yaavof August 2017.
Attorney General
Technical Staff: Yao Yin/99-100
Michael Eldred/l 0 1 - I 09
Molly Tripp/l l0
Donn English/l1I
i:umisc:prodreq/avue I 7. l_avugl 7. I bkyymemtde prod reqT
SEVENTH PRODUCTION REQUEST
TO AVISTA 4 AUGUST 25,2017
CERTIFICATE OF SBRVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF AUGUST 2017,
SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-17-OI/AVU.G.I7-OI, BY E-MAILING AND MAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWNG:
KELLY O NORWOOD
VP STATE & FED REG
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-MAIL : [e-mail]
avi stadocket s @avi stacorp. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
gre g@richardsonadam s. com
ELECTRONIC ONLY
CLEARWATER PAPER CORP.
carol. [e-mail]
[e-mail]
j ohn j [e-mail]
david.wren@,clearwaterpaper. com
nathan. smith@clearwaterpaper. com
RONALD L WILLIAMS
WILLIAMS BRADBURY
PO BOX 388
BOISE ID 8370I
E-MAIL : ron@williamsbradbur),.com
LARRY A CROWLEY
THE ENERGY STRATEGIES INSTITUTE
5549 S CLIFFSEDGE AVENUE
BOISE ID 837I6
E-MAIL: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N ITTH 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]
CERTIFICATE OF SERVICE
MATTHEW A. NYKIEL
ID CONSERVATION LEAGUE
PO BOX 2308
102 S EUCLID #207
SANDPOINT ID 83864
E-MAIL: [e-mail]
TRAVIS RITCHIE
SIERRA CLUB
2101 WEBSTER ST., SUITE 13OO
OAKLAND, CA 94612
E-MAIL: travis.ritchie@.sierraclub.org
J" /"A-,ru
SECRETAY/
CERTIFICATE OF SERVICE