20181023Staff 5-13 to Avista.pdf

ED JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t4
IDAHO BAR NO. 10446
Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE AGREEMENT FOR
PURCHASE AND SALE OF THE CHENEY AND
FOUR LAKES TAP LINES AND THE
TRANSFER OF OWI\ERSHIP AGREEMENT
BETWEEN AVISTA AND BONNEVILLE
POWER ADMINISTRATION.
CASE NO. AVU-E.18-09
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
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The Staff of the Idaho Public Utilities Commission, request that Avista Corporation
provide the following documents and information as soon as possible, by TUESDAY,
NOVEMBER 6,2018.r
This Production Request is continuing. The Company is requested to provide, by way of
supplementary responses, additional documents that it may later obtain that augments the
documents produced.
Please provide answers to each question and 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,
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
SECOND PRODUCTION REQUEST
TO AVISTA I ocToBER 23,2018
and if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01 .01.228.
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. 5: Has the Company completed an inspection report of the assets being
acquired? If so please provide details of the Company's inspection. If not, please explain why
not.
REQUEST NO. 6: Has the Company completed an environmental assessment of the
assets being acquired? If so please provide details of the Company's environmental assessment.
If not, please explain why not.
REQUEST NO. 7: Are there any liens associated with the assets being acquired by the
Company? If so, please provide details.
REQUEST NO. 8: Are there any lawsuits associated with the assets being acquired by
the Company? If so, please provide details.
REQUEST NO. 9: Please provide the proposed journal entries for the assets received
from BPA and the assets transferred to BPA that illustrate all assets being removed from or
added to the Company's rate base. Please provide a spreadsheet showing any impact on
customer rates.
REQUEST NO. 10: What methodology has the Company used in the determination of
the value ofthe assets received and given up under this proposed transfer?
REQUEST NO. l1: Will the proposed transfer result in a loss or a gain for the
Company?
SECOND PRODUCTION REQUEST
TO AVISTA 2 ocToBER 23,2018
REQUEST NO. 12: Does the Company anticipate the need for additional capital
expenditures for the betterment of the received assets?
REQUEST NO. 13: What are the estimated yearly operation and maintenance expenses
associated with the assets received after the proposed exchange is finalized?
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Dated at Boise, Idaho, this 23 day of October 2018.
Deputy General
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SECOND PRODUCTION REQUEST
TO AVISTA
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J ocToBER 23,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF OCTOBER 2018,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-I8-09,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIRECTOR REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
avi stadockets@ avi stacorp. com
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CERTIFICATE OF SERVICE
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