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Home My WebLink About20170829Avista to Sierra Club 1-1, 1-5.pdfAvista Corp. 14'l 1 East Mission P.O. Box 3727 Spokane. Washington 99220-0500 Telephone 509-489-0500 TollFree 800-727-9170 lHtnsrfi Corp, August 28,2017 Travis Ritchie Sierra Club Law Program 2l0l Webster Street, Suite 1300 Oakland, CA94612 Re: Production Request of Sierra Club in Case No. AVU-E-I7-01/AVU-G-17-01 Dear Mr. Ritchie, Enclosed are an original copy of Avista's responses to Sierra Club's production requests in the above referenced docket. Included in the mailing are Avista's responses to production requests l-1 - 1-5 & 2-l -2-5. The electronic versions of the responses were emailed on 08128117 Also included on a separate CD are Avista's CONFIDENTIAL responses to PR 1-1C - 1-5Cr2-lC & 2-4C. This response contain TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and is separately filed under IDAPA 31.01.01, Rule 067 and233, and Section 9-340D,Idaho Code. It is being provided under a sealed separate envelope, marked CONFIDENTIAL. If there are any questions regarding the enclosed information, please contact me at (509) 495- 4584 or via e-mail at paul.kimabll@avistacorp.com Sincerely, Paul Kimball Regulatory Analyst Enclosures CC (Email)Sierras CIub (Ntchie, Zimbalist) IPUC (Hanian) Clearwater (Nchardson, Reading, Lewallen, Haugen, Jacobs, Wren, Smith) Idaho Conservation League (Nykiel) Idaho Forest Group (Miller, Williams, Crowley) CAP Assoc. (Purdy) ;29 AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 08/21/2017 CASE NO.: AVU-E-17-01 / AVU-G-17-01 WITNESS: Elizabeth Andrews REQUESTER: Sierra Club RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: State & Federal Regulation REQUEST NO.: Sierra Club-1-1 TELEPHONE: (509) 495-4584 REQUEST: Provide electronic copies of all data requests and responses received from or sent to other parties in this proceeding. If electronic copies are not available, please contact counsel for Sierra Club to coordinate response. This is an ongoing request. RESPONSE: Please see Avista's response 1-1C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. Enclosed is a CD with all data requests and NON-CONFIDENTIAL responses associated with the current general rate case before the Idaho Public Utilities Commission. Avista will continue to provide copies of data requests, along with corresponding data responses, from all parties to this proceeding as they are received. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 08/21/2017 CASE NO.: AVU-E-17-01 / AVU-G-17-01 WITNESS: Elizabeth Andrews REQUESTER: Sierra Club RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: State & Federal Regulation REQUEST NO.: Sierra Club-1-2 TELEPHONE: (509) 495-4584 REQUEST: Provide all confidential testimony and exhibits included in Avista’s application. RESPONSE: Please see Avista's response 1-2C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. Please see the CD provided with the confidential testimony and exhibits for case no. AVU-E-17-01 and AVU-G-17-01. Page 1 of 1 AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 08/23/2017 CASE NO.: AVU-E-17-01 / AVU-G-17-01 WITNESS: Scott Kinney REQUESTER: Sierra Club RESPONDER: Tom Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: SC-1-4 TELEPHONE: (509) 495-4960 REQUEST: Reference Exhibit No. 4 (Kinney), Schedule 3 pages 90-91. Section 1.1 states: “Avista reviews these individual projects.” a. Provide all documents, emails, communications, memos, or other internal company documents related to Avista’s review of the Colstrip 3&4 Capital Projects. b. Describe in detail the review process, including the individuals who are responsible for review and approval of the individual projects. RESPONSE: Please see Avista's response 1-4C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. Page 1 of 2 AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 08/23/2017 CASE NO.: AVU-E-17-01 / AVU-G-17-01 WITNESS: Scott Kinney REQUESTER: Sierra Club RESPONDER: Tom Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club-1-5 TELEPHONE: (509) 495-4960 REQUEST: Reference Exhibit No. 4 (Kinney), Schedule 3 pages 90-91. Section 1.1 states: “Ultimately, the business plan is approved in accordance with the Ownership and Operation Agreement for units 3&4 that six companies are party to.” a. Provide the currently applicable Ownership and Operation Agreement. b. If different than (a), provide the Ownership and Operation Agreement in effect at the time the Colstrip 3&4 Capital Projects at issue in Avista’s application were approved by the owners. c. Describe Avista’s understanding of how the decision to include a capital project in the business plan works in practice. d. Did Avista raise any concerns or vote “no” on the Colstrip 3&4 Capital Projects at issue in this application? If so, please provide any record of those objections or concerns. e. Did any other Colstrip owner raise any concerns of vote “no” on the Colstrip 3&4 Capital Projects at issue in this application? If so, please provide any record of those objections or concerns. f. Has Avista ever voted “no” or otherwise not approved an individual capital project? If so, please describe when such a vote occurred and whether the capital project was ultimately included in the business plan. RESPONSE: Please see Avista's response 1-5C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. a. See SC_PR_1-5C Confidential Attachment A for the current Colstrip Ownership and Operation Agreement. b. The current Colstrip Ownership and Operation Agreement provided in question SC 1-5a was in effect at the time the projects included in Avista’s application were approved. c. Engineering, equipment condition assessment, and all other daily operational activities and capital planning are provided by Talen as operator of Colstrip 3&4. The following is a general description of Talen’s process: After the first of a given year, Talen updates the existing capital plan to include projects carried forward from a prior year. It also adds in all newly proposed capital projects Page 2 of 2 that were not part of the prior year’s 2 year projection. Talen’s management team vets all of the projects to ensure that the projects that are included as proposed capital projects are justified and prioritized and included based on a financial analysis or are required for environmental, regulatory, or safety reasons. d. Avista didn’t vote “no” on any of the Colstrip 3&4 projects included in the rate case application. With respect to projects occurring in 2018 and beyond, no such approval process has started yet- with the exception of those projects that are multiyear projects starting in 2017 or prior that continue on into 2018 and beyond. e. As a matter of general practice, Avista does not maintain records of other companies’ voting positions. f. Objection: Avista objects to this data request on the ground that it does not include any defined timeframe and, therefore, the request is overly broad and unduly burdensome. Without waiving its objections, Avista provides the following response. Avista doesn’t maintain any formal documentation regarding previous individual project approval discussions. If a project that Talen proposed was rejected by the committee it would be eliminated from the budget. With respect to an instance where Avista objected to a project that was ultimately included in the budget, we do not recall an instance at this time. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 08/23/2017 CASE NO.: AVU-E-17-01 / AVU-G-17-01 WITNESS: Scott Kinney REQUESTER: Sierra Club RESPONDER: Tom Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club-1-3 TELEPHONE: (509) 495-4960 REQUEST: Reference Exhibit No. 4 (Kinney), Schedule 3 pages 90-91. Section 1.1 states: “The current operator provides the annual business plan and capital budgets to the owner group every September.” a. Provide the annual business plan and capital budgets for the past three years (2015, 2016, 2017). b. Provide the 2018 business plan and capital budget when it is available next month. c. Provide all “individual project summaries” related to the Colstrip 3&4 Capital Projects. RESPONSE: Please see Avista's response 1-3C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. a. Avista is providing the Colstrip 3&4 business plans and capital budgets for 2015, 2016, and 2017. See SC_PR_1-3C Confidential Attachments A-C. Please note, each business plan received annually provides a 5-year plan i.e. 2015 business plan provides 2015-2019. Therefore, outer years within the 5-year plan are updated annually with each subsequent year. b. The Colstrip units 3&4 2018 Business Plan and capital budget for 2018 will not be approved and finalized until after November 1st. c. Avista is providing project summaries for 2015, 2016 and 2017 Colstrip 3&4 capital projects as requested. See SC_PR_1-3C Confidential Attachments D-J.