20171025Sierra Club 5_1 5_5 to Avista.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION J .;J
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 TDAHO )
Travis Ritchie
Sierra Club Law Program
2l0l Webster Street, Suite 1300
Oakland, CA94612
travis.ritchie@sierraclub. org
CASE NO. AVU-E-I7.OI
AVU-G-17-01
FIFTH SET OF DATA REQUESTS OF SIERRA CLUB TO
AVISTA CORPORATION
Sierra Club hereby serves its fifth 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 November 3.2017.
INSTRUCTIONS
Please provide copies of responses to the following contactsI
Alexa Zimbalist
Sierra Club Law Program
2l0l Webster Street, Suite 1300
Oakland, CA94612
alexa.zimb al i s t@ s i errac lub. org
2.
3
4.
5
6.
Whenever possible, Sierra Club prefers to receive electronic copies of data responses
either by email or on CD.
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.
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.
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.
For each response, identiff 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.
Please reproduce the data request being responded to before the response.7
8
9
If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or fit format.
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 ifnecessary to the understanding ofthe data, provide a record layout ofthe
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.
I l. 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-I 7-OllAVU-G-l 7-01
Sierra Club's Fifth Set of Data Requests to Avista Corporation
October 2017
DATA REQUESTS
SC 5-I
SC 5-2
SC 5-3
SC 5-4
SC 5-5
Please provide a revised version of Andrews Exhibit No. 12, Schedule I , reflecting the
terms of the proposed settlement.
Please provide, or identify in the company's testimony, exhibits, and workpapers, the
calculation of the proposed adjustrnent to depreciation/amortization expense shown in
Andrews Exhibit 12, Scl-redule l, line 9 on pages I (for 2018) and 2 (for 2019). Please
provide such calculations both for the company's initial filing and under the terms of the
proposed settlement.
Please provide the specific calculations behind Table No. 1, Iines b, f, and h, in the
proposed settlement. Specifically, please explain the specific proposed adjustments to
rate base and the calculation of the changes to revenue requirements. Please provide any
underlying workpapers in their native, machine readable fomr with formulas intact.
Please provide Avista's proposed and/or approved depreciation schedules for the
SmartBurn investments at Colstrip Unit 3 (Project ID 10023705, as identified in
confidential attachment G to Avista's response to Sierra Club Production Request l-3)
and Colstrip Unit 4 (Project ID 100221 I l, as identified in confidential attachment E to
Avista's response to Sierra Club Production Request 3-1.)
For each of the Smartburn Capital Projects at Colstrip identified in SC 5-4, please
provide the estimated annual revenue requirement associated with the project, including
but not limited to operating costs, depreciation expense, and return on equity, that Avista
is currently recovering and/or proposes to recover. If this amount has changed between
Avista's as-filed case and the settlement, please identiff the magnitude and nature of the
change.
CERTIFICATE OF SERVICE
I hereby certify that on this 25th day of October 2017 ,I delivered true and correct copies
of the tbregoing FIFTH 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
l4l I East Mission Avenue
Spokane, WA99220-3727
david.meyer@avistacorp. com
Peter J. Richardson
Gregory M. Adams
Richardson Adams PLLC
515 N. 27th Street
P0 Box 7218
Boise. lD 83702
peter@richardsonadams. com
gr e g@r ichard s on adams. c o m
carol. hauge n@clearw aterpaper. com
[e-mail]
j ohn j acobs @clearw atenpaper. com
davi d. wm@ c I e arwaterpap er. com
nathan. smith@clearw aterpaper. com
Matthew A. Nykiel
Idaho Conservation League
PO Box 2308
102 S. Euclid#207
Sandpoint, ID 83864
mnykiel@idahoconservation. org
Dean J. Miller
3620 E Warm Springs Ave.
Boise, ID 83716
deanj [e-mail]
Kelly Norwood
Vice President - State & Federal Regulation
Avista Utilities
PO Box3727
1411 East Mission Avenue
Spokane, WA99220-3727
kelly.norwood@avistacorp. com
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
dreading@mindspring. com
Brad M. Purdy
Attorney at Law
2019 N. 17'h Street
Boise, lD 83702
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise,lD 83701
botto@idahoconservation. org
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]. gov
Ronald L. Williams
Williams Bradbury, P.C.
PO Box 338
Boise,ID 83701
ron@williamsbradbury. com
/s/ Alexa Zimbalist
Alexa Zimbalist
Legal Assistant
Sierra Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA94612
Phone: [phone]