20190823Staff 1-3 to Avista.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
RECEIVED
?019 AUS 23 Plt 2r 36
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Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702.5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE POWER COST
ADJUSTMENT (PCA) ANNUAL RATE
ADJUSTMENT FILING OF AVISTA
CORPORATION
CASE NO. AVU.E.19.O9
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,
John R. Hammond, Jr., Deputy Attorney General, requests that Avista Corporation dba Avista
Utilities ("Avista" or the o'Company") provide the following documents and information as soon
as possible, or by FRIDAY, SEPTEMBER 6, 2019.r
This Production Request is continuing, and Avista 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. Avista is reminded that responses pursuant to
Commission Rules of Procedure must include the name and phone number
I Staffis requesting an expedited response. If this is problematic, please contact Staff s attorney at [phone] or
i oh n. harn mond (i)puc. ida ho. gov.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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AUGUST 23,2019I
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 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. 1: Please provide the following in Excel format with all formula intact:
a. Actual monthly mega-watt hours (MWhs) and costs for each of Avista's generation
resources and purchases from July 2018 through June 2019.
b. Authorized monthly MWhs and costs for each of Avista's generation resources and
purchases from July 2018 through June 2019.
c. Actual monthly MWhs and revenues for Avista's sale transactions from July 2018
through June 2019.
d. Authorized monthly MWhs and revenues for Avista's sale transactions from July 2018
through June 2019.
REQUEST NO. 2: For the period prior to the revision of the Clearwater Paper
Corporation ("Clearwater") contract (i.e., before April 2019), please provide the monthly amount
of actual excess energy (in MWhs and dollars) Clearwater generated above its own load
requirements that was used to offset intra-year loads for billing purposes.
REQUEST NO. 3: For the period after the new contract was in force through June 2019,
please provide the amount of monthly sales and purchases between the Company and Clearwater
in dollars and MWhs.
Dated at Boise, Idaho, thiJ) day of August 2019.
Hammond
Attorney General
i:umisc/prod req/avue19.09jhbe prod reql
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
J
2 AUGUST 23,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF AUGUST 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-I9-09,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIRECTOR REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
CERTIFICATE OF SERVICE
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