20200713ICL 1-3 to Staff.pdf

Benjamin J. Otto (ISB No. 8292)
Matthew A. Nykiel (ISB No. 10270)
710 N 66 Steet
Boise,ID 83701
Ph: [phone] x t2
Fax: [phone]
botto@idahoconservation. org
mnykiel @idahoconservation. org
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Afforneys for the Idaho Conservation League
BEFORE THE IDAHO PT]BLIC UTILITIES COMN{ISSION
IN THE MATTER OF THE
AVISTA'S 2O2ONLECTRIC
INTEGRATED RESOURCE PLAN
cAsE NO. AVU-E-19-01
ICL's FIRST PRODUCTION
REQUEST TO IDAIIO PUBLIC
UTILITIES COMMISSION
The Idaho Public Utilities Commission granted the ldaho Conservation League's (ICL)
Petition to Intervene in this docket in Order 34626.ICL submits the following production request
to the Idaho Public Utilities Commission Staff, pursuant to IDAPA 31.01.01.216 -240.
This production request is ongoing and ICL requests the Company 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 along with all supporting workpapers that
provide detail or are the source of information used in formulating ldaho Power's answers.
Commission's Rules of Procedure require ldaho Power to 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. IDAPA
3t.01.0t.228.
Pursuant to Order 34602, please provide all responses electronically, via email to ICL's
council at [e-mail] and [e-mail], including any
supporting materials in Excel format with formulas activated.
Please provide responses on or before August 3,2020.
IPC-E-19-19
ICL I't P. R. tO IdAhO PUC StAff
)
)
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I
July 13,2020
PRODUCTION REQUEST 1:
On July 9,2020 the tdaho Public Utilities Commission Staffhosted a public workshop covering
Avista's 20lg Integrated Resource Plan. During the Staffpresentation ICL leamed of
"additional economic analysis", requested of Avista by the PUC Staff, regarding the
economically optimal date for Avista to exit the Company's share of the Colstrip coal plant.
A. Please provide this analysis and all supporting workpapers or other documentation.
PRODUCTION REQUEST 2:
Please provide PUC StaffProduction Requests to Avista, and any answers received to date,
numbers I through 9 and any further requests beginning with number 39.
PRODUCTION REQI.JEST 3 :
Please provide any additional analysis or supporting materials the PUC Staff have received from
Avista pursuant to either Production Requests, pursuant to IDAPA 31.01.01.225 or Audits,
conducted pursuant to IDAPA 31.01 .01 .227 , regarding Avista's 2019 Integrated Resource Plan.
Respectfully submitted this 13ft day of July 2020.
/s/ Beniamin Otto
Idaho Conservation League
IPC-E-19-19
ICL I't P. R. tO IdAhO PUC StAff
2
July 13,2020
CERTIFICATE OF SERVICE
I hereby certiff that on this l3th day of July 2020,I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST TO IDAHO PUC STAFF to the following
persons via the method of service noted:
/^s/Otto
Idaho Conservation League
Electonic Mail only (See Order 34602):
Idaho Public Utilities Commission
Diane Hanian, Commission Secretary
secretary@puc. idaho. gov
Edward Jewell, Deputy Attorney General
Idatro Public Utilities Commission
Edward j ewell@puc. idaho. gov
Avista
David Meyer, VP and Chief Counsel of
Regualtory & Govemment Affairs
David.meyer@avistacorp. com
Linda Gervais
Linda. Gervais@avistacorp. com
(Please update this contact infonnation.
Thank you)
[PC-E-19-19
ICL I't P. R. to Idaho PUC Staff
3
July 13,2020