20190227Staff 1-9 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA'S PETITION
FOR AN EXTENSION TO FILE ITS 2019
ELECTRIC INTEGRATED RESOURCE PLAN
CASE NO. AVU-E-19-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Avista Corporation (Company) provide
the following docurnents and information as soon as possible, or by WEDNESDAY,
MARCH 20,2019.
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
3t.01.0t.228.
FIRST PRODUCTION REQUEST
TO AVISTA
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I FEBRUARY 27 ,2019
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 describe any potential decisions the Company will not be able
to make or identify due to a 6 month extension of the IRP filing date.
REQUEST NO. 2: What types of subsequent filings that rely on the IRP will be
impacted by the extension (e.g. PURPA deficit date and avoided cost filings) and what would the
impacts be?
REQUEST NO.3: What risks has the Company identified that are created by an
extension of the IRP filing date?
REQUEST NO. 4: What options could the Company undertake to mitigate any risks by
extending the IRP filing date? (e.g. file an update to the 2017 IRP)
REQUEST NO. 5: What kind of changes will the Company need to make to their
modeling methodology and analysis if the different types of legislation passes? Please explain
why these changes are important.
REQUEST NO. 6: If the extension is approved, will the Company plan to use the
alternative futures and scenarios discussed at the second TAC meeting on November 21,2019?
REQUEST NO. 7: Could the Company incorporate the legislation into the normal IRP
process as separate what-ifcases or scenarios?
REQUEST NO. 8: Please provide the dates by which the Company will know if the
legislation is enacted for all the proposals mentioned in the petition for extension.
FIRST PRODUCTION REQUEST
TO AVISTA 2 FEBRUARY 27 ,2019
REQUEST NO. 9: What is the projected likelihood that the legislation in Washington
passes? Please explain by providing an assessment of the interests and the strength of those
interests for and against the legislation.
Dated at Boise, Idaho, this }],bauyof February 2019
Edward
Deputy General
i:umisc:prodreq/avue19. lejme prod reql
FIRST PRODUCTION REQUEST
TO AVISTA )FEBRUARY 27,2019
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF FEBRUARY 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU.E-19-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL : I inda. servai s(d,avi stacom. corn
avistadockets@avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: david.nreyer(0avistacom.com
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SECRETARY
CERTIFICATE OF SERVICE