20200818Staff 1-5 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
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Street Address for ExPress Mail:
1 I33 I W CHINDEN BLVD, BLDG 8, SUITE 20 I -A
BOISE, ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE POWER COST
ADJUSTMENT (PCA) ANNUAL RATE
ADJUSTMBNT FILING OF AVISTA
CORPORATION
CASE NO. AVU-E..20.07
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,
Dayn Hardie, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than TUESDAYT SEPTEMBER I'
2020.1
This production Request is to be considered as continuing, and Avista Corporation is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behall may later obtain that will augment the documents or information
produced.
I Stuffi, requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA
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I AUGUST I8,2O2O
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identift the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide all electronic workpapers with formulas intact and
documents supporting the Application, testimonies, and exhibits.
REQUEST NO. 2: Please provide the following in Excel format with all formula intact:
a. Actual monthly mega-watt hours (MWhs) and costs for Avista's generation resources
and purchases from July 2019 through June2020.
b. Authorized monthly MWhs and costs for Avista's generation resources and purchases
from July 2019 through June 2020.
c. Actual monthly MWhs and revenues for Avista's sale transactions from July 2019
through June 2020.
d. Authorized monthly MWhs and revenues for Avista's sale transactions from July
2019 through June 2020.
REQUEST NO. 3: Please provide the amount of monthly sales and purchases between
the Company and Clearwater in dollars and MWhs from July 2019 through June 2020.
REQUEST NO. 4: Please provide a list including the date and duration of all forced
outages for all generation facilities from July 2019 through June 2020 for the following facilities:
Colstrip, Coyote Springs II, Rathdrum, Noxon Rapids, Cabinet Gorge, and Lancaster. For all
forced outages longer than 24 hours in duration, please provide an explanation for each forced
outage. In the explanation, please estimate incremental power supply expense to Idaho
customers as a result of the outage.
FIRST PRODUCTION REQUEST
TO AVISTA 2 AUGUST I8,2O2O
REQUEST NO. 5: Please provide an update on the Comprehensive Report the
Company mentioned in Reply Comments in the 2019 PCA Annual Rate Adjustment Filing
(AVU-E-I9-09). Reply Comments at2,line 5. Also please provide an update on the
Company's future operating plans for Coyote Springs II.
DATED at Boise, Idaho, this \6t y of August 2020.
Deputy Auorney General
i:umisc:prodreq/avue20.7dhme prod rcq I
FIRST PRODUCTION REQUEST
TO AVISTA 3 AUGUST I8,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISTH DAY OF AUGUST 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU.E-20-07,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
POBOX3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
avistadockets @ avistacorp.conr
DAVID J MEYER
VP & CHIEF COI.JNSEL
AVISTA CORPORATION
PO BOX 3727
SPoKANE WA99220-3727
E-MAIL: david. nre_ver@ avistacom.conr
s
CERTIFICATE OF SERVICE