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HomeMy WebLinkAbout20190814Staff 149-154 to Avista.pdfEDWARD 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 l0lg AUG lh Pl{ l:5h ,,,,]..1ii { &'iF'}l8t'o* 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 ) ) ) ) ) ) ) ) 1 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 i :umisc:prodreq/avue I 9.4ejyyjhrf prod req5 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)'er@avistacolp.corn 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 crowle),la@)aol.corn cerrol. ha u gen @clearwaterrraper. com tetry.borden(4)clcarwaterpapcr. com mal i sa.rna-v-nard (@c I earwaterpaper. co rn S tephen. chri ss(g) wa lnraft . com Y CERTIFICATE OF SERVICE