20171005Sierra Club 4-1 to Avista.pdf

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 AND NATURAL GAS
SERVICE IN IDAHO
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CASE NO. AVU-E-17-01
AVU-G-17-01

FOURTH SET OF DATA REQUESTS OF SIERRA CLUB TO
AVISTA CORPORATION

Sierra Club hereby serves its fourth set of data requests regarding the above-mentioned docket.
Sierra Club requests that Avista Corporation provide responses as expeditiously as possible, but
not later than the deadline of 21 days, which is October 26, 2017.

INSTRUCTIONS
1. Please provide copies of responses to the following contacts:
Travis Ritchie
Sierra Club Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]

Alexa Zimbalist
Sierra Club Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]

2. Whenever possible, Sierra Club prefers to receive electronic copies of data responses
either by email or on CD.
3. Responses to any and all of Sierra Club’s data requests should be supplied to Sierra Club
as soon as they become available to Avista Corporation.
4. The requests herein shall be deemed to be continuing in nature and Avista Corporation is
requested to supplement its responses as necessary and as additional information
becomes available.
5. In responding to each data request, please consult every document source which is in
your possession, custody, or control, including all documents in the possession of experts
or consultants.
6. For each response, identify the person who prepared the answer to the data request as
well as his or her position with Avista Corporation or any Avista Corporation affiliate or
parent.
7. Please reproduce the data request being responded to before the response.
8. If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
9. If the responses include spreadsheet files, please provide those spreadsheet files in
useable electronic Excel readable format.
10. In responses providing computer files, list the file names with cross-reference to the data
request, and if necessary to the understanding of the data, provide a record layout of the
computer files. Computer files provided with a response must be in or compatible with
the current version, or the immediately prior version, of Microsoft Office.
11. For each dollar amount provided in response to a discovery request please state if the
amount is in nominal or constant dollars and what years dollars.

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
Case Nos. AVU-E-17-01/AVU-G-17-01
Sierra Club’s Fourth Set of Data Requests to Avista Corporation
October 5, 2017

DATA REQUESTS

SC 4-1. With reference to Avista's confidential response to Sierra Club Production Request 2-4:
a. Please explain the meaning of "Incremental Cost" as used in the table provided,
and explain the components of this incremental cost and how it is calculated.

b. Please describe the components the O&M cost included in the "Fuel and O&M
Cost" column, and whether this includes fixed, variable, or both O&M costs.

c. Please provide more specific references than those provided in the text of the
response, including page numbers in the Company's FERC Form 1 and the 2017
IRP, for the data provided, and identify what data in the table came from which
source.

CERTIFICATE OF SERVICE

I hereby certify that on this 5th day of October 2017, I delivered true and correct copies
of the foregoing FOURTH SET OF DATA REQUESTS OF SIERRA CLUB TO AVISTA
CORPORATION to the following persons via electronic mail:

David J. Meyer
Vice President & Chief Counsel, Reg. & Gov't
Affairs
Avista Corporation
PO Box 3727
1411 East Mission Avenue
Spokane, WA 99220-3727
[e-mail]

Kelly Norwood
Vice President - State & Federal Regulation
Avista Utilities
PO Box 3727
1411 East Mission Avenue
Spokane, WA 99220-3727
[e-mail]

Peter J. Richardson
Gregory M. Adams
Richardson Adams PLLC
515 N. 27th Street
P0 Box 7218
Boise. ID 83702
[e-mail]
[e-mail]

Dr. Don Reading
6070 Hill Road
Boise, ID 83703
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
[e-mail]
Matthew A. Nykiel
Idaho Conservation League
PO Box 2308
102 S. Euclid #207
Sandpoint, ID 83864
[e-mail]

Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83701
[e-mail]
Dean J. Miller
3620 E Warm Springs Ave.
Boise, ID 83716
[e-mail]
Larry A. Crowley, Director
The Energy Strategies Institute, Inc.
5549 S. Cliffsedge Ave.
Boise, ID 83716
[e-mail]

Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
[e-mail]
Ronald L. Williams
Williams Bradbury, P.C.
PO Box 338
Boise, ID 83701
[e-mail]

/s/ Alexa Zimbalist
Alexa Zimbalist
Legal Assistant
Sierra Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA 94612
Phone: [phone]