20210205Staff 35-40 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILMIES COMMISSION
PO BOX 83120
BOISE, IDAHO 83120-007 4
(208) 334-O3r2
IDAHO BAR NO. 9917
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Street Address for Express Mail:
II33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S COMPLIANCE FILING TO
UPDATE AND ESTABLISH ITS CAPACITY
DEFICIENCY PERIOD TO BE USED FOR
AVOIDED COST CALCULATIONS
CASE NO. AVU.E,-2O.II
THIRD 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 FRIDAY, FEBRUARY 12,
2021.r
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 behalf, may later obtain that will augment the documents or information
produced.
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney
at [phone].
THIRD PRODUCTION REQUEST
TO AVISTA
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1 FEBRUARY 5,2021
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 identify 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.35: Please update the Load and Resource Balance provided in
Response to Staff's Production Request No. 1 with the Company's August 2O20load data.
REQUEST NO.36: Please update the Load and Resource Balance provided in
Response to Staff s Production Request No. 1 with the Company's August 2020load data and:
(I) a2025 shutdown date of Colstrip 3 and 4 as approved by Washington using WA's
jurisdictional allocation of Colstript and (2) the end-of-useful-life dates of 2034 for Unit 3 and
2036 for Unit 4 using Idaho's jurisdictional allocation of Colstrip.
REQUEST NO.37: Please update the Load and Resource Balance provided in
Response to Staff's Production Request No. 1 with the Company's August 2O2Oload data and
(I) a2025 shutdown date of Colstrip 3 and 4 as approved by Washington using WA's
jurisdictional allocation of Colstrip; and (2) the depreciation life of 2021 for Idaho's
jurisdictional allocation of Colstrip.
REQUEST NO.38: Please update the Load and Resource Balance provided in
Response to Staff's Production Request No. 1 with the Company's August 2020load data and
end-of-useful-life dates of 2034 for Colstrip Unit 3 and 2036 for Colstrip Unit 4 for the system.
REQUEST NO.39: Please update the Load and Resource Balance provided in
Response to Staff's Production Request No. I with the Company's August 2020load data and
depreciation life of 2027 for both Units 3 and 4 of Colstrip for the system.
THIRD PRODUCTION REQUEST
TO AVISTA FEBRUARY 5,20212
RBQUEST NO. 40: If the first deficit occurs in2026 but in a month different than
January as the Company proposed and for a different amount of deficiency, is it going to affect
avoided cost of capacity calculation under Avista's IRP Method? If so, please explain how
different timing and deficiency amounts will affect avoided cost of capacity.
DATED at Boise, Idaho, this 5rH day of February 2021.
Dayn
Deputy Attomey General
i:umisc:prodreq/avue20.1 ldhyy prod req 3
THIRD PRODUCTION REQUEST
TO AVISTA 3 FEBRUARY 5,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF FEBRUARY 2021,
SERVED THE FOREGOING THIRD PRODUCTION REQUBST OF THE
COMI\{ISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-}o-II,
BY E-MAILING A COPY THEREOF TO TTM FOLLOWING:
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
POBOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
avistadockets @ avistacorp.com
SHAWN BONFIELD
SR MGR/REGULATORY POLICY
AVISTA CORPORATION
POBOX3727
SPoKANE W499220-3727
E-MAIL: shawn.bonfield @ avistacorp.com
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SECRETAY
CERTIFICATE OF SERVICE