20180628Staff 1-19 to Avista.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
RECEIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
CHANGE ITS ELECTRIC AND NATURAL GAS
DEPRECIATION RATES
FIRST 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
THURSDAY, JULY 19, 2018.
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
3L01.01.228.
FIRST PRODUCTION REQUEST
TO AVISTA
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CASE NO. AVU.E.18.O3
AVU-G-I8-02
1 JI-INE 28,2018
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: Please provide all audit and data request questions and responses
that have been asked in current depreciation cases in other states by all parties. This should
include conhdential questions and responses. Please consider this an ongoing request.
REQUEST NO.2: Please provide the three most recent annual business plans and
capital budgets for the Colstrip Power Plant provided by the operator to the owner group every
September.
REQUEST NO.3: Please provide the meeting minutes for the three most recent
Colstrip Power Plant annual September owners' meetings.
REQUEST NO. 4: Please describe in detail the minimum set of conditions needed for
Avista to continue to economically receive generation from the Colstrip plant. Please include a
comprehensive list of conditions, including mandates and policies passed in other states and at
the federal level, including carbon prices, fuel availability and price, and environmental control
requirements, etc.
REQUEST NO. 5: In the 2017 IRP, the Company established Colstrip Units 3 and 4
would operate during the entire 2)-year planning time frame. Please describe all the factors and
assumptions (costs, mandates and policies passed in other states and at the federal level including
carbon prices, fuel availability and price, and environmental control requirements, etc.) that have
changed or were not considered from those assumed in the 2017 IRP that would potentially
change the Company's plan for Colstrip. For each factor or assumption, please provide a relative
likelihood that each could occur and the relative impact of each factor or assumption in
determining the closure date.
FIRST PRODUCTION REQUEST
TO AVISTA 2 JUNE 28,2018
REQUEST NO. 6: What did the Company assume in its 2017 IRP regarding the closure
of Units I and2 that affect the cost (common costs, operation and maintenance costs,
decommissioning costs, etc.) and operational life of Units 3 and 4?
REQUEST NO. 7: Please provide all analyses conducted or commissioned by Avista
studying the economic effects of a carbon tax imposed by the State of Washington on the
continued operation of Colstrip.
REQUEST NO. 8: Please provide the current expected operational life of the Rosebud
Mine. Please include details, assumptions, and sources used to determine the operational life.
REQUEST NO. 9: Is Area F expansion for the Rosebud Mine required to operate the
Colstrip plant until the current depreciation terminal lives of 203 4 and 2036 for Units 3 and 4?
Please explain.
REQUEST NO. 10: Please provide the current coal supply agreement for Colstrip Units
3 and 4 between the plant ownership group and Western Energy Company (WECO).
REQUEST NO. 11: Please describe how the potential Westmoreland bankruptcy could
affect the operation of Colstrip. Please include impacts to cost, fuel availability, etc.
REQUEST NO. 12: Please provide Avista's response to Request for Information PSC-
028, prepared March 28,2078, by Jason Thackston. Please include the Ownership and
Operation Agreement, for Colstrip Units 3 and 4.
R-EQUEST NO. 13: Please provide a table showing ownership percentage and current
terminal depreciation year used by other owners for Colstrip Units 3 and 4.
FIRST PRODUCTION REQUEST
TO AVISTA J JI-INE 28,2018
REQUEST NO. 14: Please provide a copy of the testimony of Christopher S. Hancock
of the Staff of the Washington Utilities and Transportation Commission in Docketu-170970
dated April 10, 2018.
REQUEST NO. 15: In the 2016 Gannett Fleming Depreciation Study the estimation of
the service lives and the net salvage values are made on the basis of various assumptions,
namely: informed judgement, review of company practices and outlook, and consideration of
current industry practices. Please specifically identify all assumptions used for each account,
group or functional group of accounts.
REQUEST NO. 16: Please provide detailed factors used in the determination of the life
of all the Hydraulic Production Plant facility associated with the following account s: 331 , 332,
333,334.
REQUEST NO. 17: Please provide a list showing all plant details included in the
following accounts:
a) Electric: 316 Miscellaneous Power Plant Equipment,
b) 335 Miscellaneous Power Plant Equipment,
c) 392.50 Transportation Equipment - Other,
d) 396.50 Power Operated Equipment - Other
e) Gas: 357.00 Other Equipment,
REQUEST NO. 18: Please provide details for the expenses incurred in complying with
the Electric Utilities Finale Rule of the Environmental Protection Agency's Disposal of Coal
Combustion Residuals.
REQUEST NO. 19: Please provide the detailed support and reasons for the changes in
the salvage values for the following Gas accounts:376. Mains and 381 Meters.
FIRST PRODUCTION REQUEST
TO AVISTA 4 JtrNE 28,2018
Dated at Boise, Idaho, this ffi day of June 2018.
Attomey
Technical Staff: Michael Eldred/l-l I
Bentley Erdwnm/12-14
Johan Kalala-Kasanda/ I 5- I 9
i:umisc:prodreq/avue 18.3_avug I 8.2bkbeme prod req I
FIRST PRODUCTION REQUEST
TO AVISTA 5 JUNE 28,2078
CERTIFICATE OF SERVICB
I HEREBY CERTIFY THAT I HAVE THIS 28th DAY OFJUNE2OI8, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
srAFF TO AVTSTA CORPORATTON, IN CASE NOS. AVU-E-I8-03 /AVU-G-18-02,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
SR MGR RATES & TARIFFS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83701
E-mail: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-mail : [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail : [e-mail]
ELECTRONIC SERVICE ONLY
LARRY CROWLEY, DIR
ENERGY STRATEGIES INST.
E-MAIL : crowleyla@,aol.com
ELECTRONIC SERVICE ONLY
CAROL HAUGEN
E-MAIL:
carol.hau gen@clearwaterpaper. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
TRAVIS RITCHIE
STAFF ATTORNEY
SIERRA CLUB
2101 WEBSTER ST STE I3OO
OAKLAND CA946I2
E-mail: travis
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 83716
E-mail: deanjmiller@,cableone.net
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
ELECTRONIC SERVICE ONLY
MARV LEWALLEN
E-MAIL:
marv. lewal ler"r@c learwaterpaper. com
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SECRETARY
CERTIFICATE OF SERVICE