20190814Staff 149-154 to Avista.pdf

EDWARD JEWELL
JOHN R HAMMOND JR
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03r4t (208) 334-03s7
IDAHO BAR NO. T04461 5470
RECEIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCRE,ASE
ITS RATES AND CHARGES FOR ELECTRIC
SERVICE IN IDAHO.
CASE NO. AVU.E.19-04
FIFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
John R. Hammond Jr., Deputy Attorney General, request that Avista Corporation (Company)
provide the following documents and information as soon as possible, or by WEDNESDAY,
SEPTEMBER 4, 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
FIFTH PRODUCTION REQUEST
TO AVISTA AUGUST I4,2OI9
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and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.0r.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. 149: Schedule 3 of Mr. Kalich's Exhibit No. 7 shows "Douglas PUD-
Wells Purchase" costs of $2,898,000 for the 2020 Pro Forma. Through communication with
Avista, it should cost $2,997,000 for the2020 Pro Forma. Please explain the cause of the
difference and provide workpapers that calculates the correct cost.
REQUEST NO. 150: Schedule 3 of Mr. Kalich's Exhibit No. 7 shows "Palouse
Feather" costs of $221,000 for the 2020 Pro Forma. Please confirm whether or not the $221,000
for "Palouse Feather" is intended to capture the payment Avista makes to Palouse Wind for the
curtailed hours beyond the 50 hours in each rolling 2-year period allowed in the contract. Please
include workpapers calculating the $221,000 amount.
REQUEST NO. 151: Regarding the Customer Facing Technology Project Production
Request No. 94 Response, for Customer Experience Platform (CRM), myAvista Web
Enhancements, and CC&B/MDM enhancements, please provide all analysis including: cost
benefit analysis, request for proposal, and break out ofall expenses.
REQUEST NO. 152: Regarding the Data Center Compute and Storage Systems Project
Production Request No. 109 Response, please provide purchase orders and supporting cost
benefit analysis documents for Linux OS Red Hat 6 Refresh.
REQUEST NO. 153: During an on-site Staff audit visit survey metrics regarding the
Customer Facing Technology Mobile Application were referred to and not presented. Please
provide all customer survey metrics and documentation in relation to customer satisfaction,
requested technologies, and payment satisfaction utilized in the Customer Facing Technology
Mobile Application case.
FIFTH PRODUCTION REQUEST
TO AVISTA 2 AUGUST 14,2OI9
REQUEST NO. 154: From the New Generation Resource Integration Study (Kinney,
Schedule 4C at 181), please explain how the Othello/Lind Interconnection for the Rattlesnake
Flats project, which required substantial investments for transmission system upgrades and
construction, was selected over other resource locations such as the Thornton Station (4C at 185)
Interconnection point, which didn't require substantial investment.
Dated at Boise, Idaho, this l4t-day of August 2019.
John R.
Deputy General
Jr
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FIFTH PRODUCTION REQUEST
TO AVISTA 1J AUGUST 14,2079
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF AUGUST 2019,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-I9-04,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: patrick.ehrbar(davistacorp.com
avi stadockets (0)avistacorp. corn
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL : ronr€)wil liamsbradbur),.corn
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE TD 83702
E-MAIL : peterr, g)ricliardsonadarns.com
NORMAN M SEMANKO
PARSONS BEHLE & LATIMER
8OO W MAIN ST STE I3OO
BOISE ID 83702
E-MAIL: nsemankoli)parsonsbehle.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL : botto(l=r)iclahoconscrvation.ors
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: david.nre)'[e-mail]
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 83716
E-MAIL: cleanjmiller(Ocableone.net
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : dreadine(l,rni ndslxing. conr
VICKI M BALDWIN
PARSONS BEHLE & LATIMER
2OI S MAIN ST STE I8OO
SALT LAKE CITY UT 8411I
E-MAIL: vbaldrvin(Z)parsonsbehle.corn
BRAD M PURDY
ATTORNEY AT LAW
20I9 N ITTH ST
BOISE ID 83702
E-MAIL : brnpr-rrclir1.ii;thotrnai l . conr
CERTIFICATE OF SERVICE
ELECTRONIC ONLY
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CERTIFICATE OF SERVICE