20200715Staff 1-7 to Avista.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAI,
IDAHO PUBLIC UTILII]ES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR AN
ACCOUNTING ORDER AUTHORIZING
ACCOUNTING AND RATEMAKING
TREATMENT OF COSTS ASSOCIATED WITH
THE COMPANY'S WILDFIRE RESILIENCY
PLAN
cAsE NO. AVU-E-20-05
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
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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 "Company") provide the following documents and information as soon
as possible, or by WEDNESDAY, AUGUST 5,2020.
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 Iater
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 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 3 LOl .01 .228.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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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 all workpapers used to calculate Attachment C -
Wildfire Resiliency Cost Forecast in Excel format with all formulas intact. Also provide, if any, a
list of other applications used to calculate the expected costs. (Please provide these as soon as
possible before the other responses.)
REQUEST NO. 2: Please clariff if the Wildfire Resiliency Plan is an additional program
on top of the Vegetation Management PIan. If so, will there be cost savings within the Vegetation
Management PIan? If not, will there be a cost increase to Vegetation Management Plan?
REQUEST NO.3: Please provide estimated rate impact to Idaho ratepayers, both on a
percentage basis by rate class and as a change in the average monthly bill for a typical residential
customer.
REQUEST NO. 4: Please provide depreciation rates for new poles for the entire Wildfire
Resiliency Plan. Please provide amounts as of the current date. Also, please provide the
following:
early retirement to Plant in Service, retirement costs, and depreciation expense
early additions to Plant in Service and yearly depreciation expense.
REQUEST NO.5: In reference to the page T,lines l9 and 20 of the Application, are
Avista's liability insurance levels adequate to protect against a single large wildfire? If not, what
is the cost to increase the liability insurance to cover a single large event?
REQUEST NO. 6: In reference to page 7, lines 14 and I5 of the Application, please
provide a copy of the contract with Core Logic Consulting Group. Please provide copies of any
invoices paid to date.
REQUEST NO. 7: How many additional labor hours will the Wildfire Resiliency Plan
add to annual labor costs, direct overhead costs, and indirect overhead costs?
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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2 JULY I5,2O2O
DatedatBoise,Idaho, this ffiyof July 2020.
Hammond
Attomey Creneral
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FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I5TH DAY OF JIJLY 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AYISTA CORPORATION, IN CASE NO. AVU-E-20.05,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF RECULATORY AFFAIRS
AVISTA CORPORATION
PO BOX 3727
SPoKANE WA99220-3727
E-MAIL: patrick.ehrbar(0iavistacorp.conr
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DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPoKANE WA99220-3727
E-MAIL: david.me.ver(4liavistacorp.com
SECRETAR
CERTIFICATE OF SERVICE