20171031Staff 1-4 to Avista.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-OO]4
[phone]
IDAHO BAR NO. 8370
IN THE MATTER OF AVISTA
CORPORATION'S COMPLIANCE FILING TO
UPDATE LOAD AND GAS FORECASTS IN THE
INTEGRATED RESOURCE PLAN AVOIDED
COST MODEL AND TO ESTABLISH ITS
CAPACITY DEFICIENCY PERIOD FOR USE IN
AVOIDED COST CALCULATIONS.
CASE NO. AVU-F"-I7.IO
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
RECEIVED
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!.}T ILITiE$ COMMISSION
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILITIBS COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Avista Corporation (Company) provide
the following documents and information as soon as possible, or by TUESDAY,
NOVEMBER 21, 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
31.01.01.228.
FIRST PRODUCTION REQUEST
TO AVISTA I ocroBER 31,2017
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. 1: Is Figure 1 in the Company's filing the same load and resource
balance used in Avista's published 2017 IRP adjusted by the additions or cancellations of long-
term contracts since the publication of the 2017 IRP? If not, please describe and quantify the
difference. Does the difference change the first deficit year or the amount of deficiency in the
first deficit year? Please explain.
REQUEST NO. 2: Please provide in Excel format the load and resource balance data
used in Avista's 2017IRP adjusted by the additions or cancelations of long-term contracts since
the publication of the 2017 IRP.
REQUEST NO.3: Please provide in Excel format the load and resource balance data
used to calculate the first capacity deficiency date in Case No. AVU-E-13-10.
REQUEST NO. 4: Please provide and explain the major drivers that cause the first
capacity deficit year to move from2020 in Case No. AVU-E-13-10 to 2026 in this case.
Dated at Boise, Idaho, this 3 t4o*of october 2017.
Daphne
Deputy Attomey General
Technical Staff: Yao Yin (l-4)
i:umisc:prodreq/avuel 7. l0djhyy prod reql
FIRST PRODUCTION REQUEST
TO AVISTA 2 ocroBER 37,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31't DAY OF OCTOBER 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-I7-10,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail : [e-mail]
ARY
CERTIFICATE OF SERVICE