20210325Staff 96-115 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
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR ELECTRIC AND NATURAL
GAS SERYICE FOR ELECTRIC AND
NATURAL GAS CUSTOMERS IN THE STATE
OF IDAHO.
CASE NO. AVU.E.21.O1
AVU-G-21-01
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
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Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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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 THURSDAY, APRIL 15,2021.
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 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.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
I MARCH 25,202I
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. 96: Please generally describe the Company's methodology for
developing, managing, executing, and completing Capital Projects in a least cost manner. Please
provide a copy of all Company policies and procedures documenting the process.
REQUEST NO. 97: Specific to Colstrip, please describe the methods used to ensure
capital investment projects were completed in a least cost manner. Please include any guidelines
and procedures documenting these methods.
REQUEST NO. 98: Please provide all documentation for plant investments made in
Colstrip since the start of 2018 between the Company and Colstrip operating partner, Talen
Energy, showing how the Company was actively engaged with the operating partner to minimize
plant investment costs. Please include any documentation justifuing the need for an upgrade and
any analysis comparing the cost and benefits of other altematives considered.
REQUEST NO. 99: Please provide the following documentation for each Colstrip plant
capital project with a budget amount of $500,000 or more that was completed from 2018 through
the current date (where requested information has not been provided, please explain why it was
not provided and how the Company assured the construction of the project was completed at least
cost):
a. Analysis ofNeed - a justification of need for each project along with a cost/benefit
analysis comparison of alternatives.
b. Project Plani. Initial project scope.ii. Proposed budget.iii. Proposed schedule.
c. Requests for proposals (RFP)i. Project requirements.ii. Specifications.iii. Short list bidder scorecard.
iv. RFP from winning bid.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH 25,20212
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s).
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus 5
percent during a particular year please list and explain the reason(s) for the
budget amount difference.
REQUEST NO. 100: Please list every Colstrip capital project with a budget of $250,000
or above completed since 2018, which was completed using intemal resources (intemal defined as
any ownership partner) instead of an outside contractor. For each of these projects, please explain
why internal resources were used instead of an outside contractor.
REQUEST NO. 101: Please provide the following documentation for each electric
generation capital project (except for Colstrip) with a budget amount of $1,000,000 or more that
was completed from 2018 through the current date (where requested information has not been
provided, please explain why it was not provided and how the Company assured the construction
of the project was completed at least cost):
a. Analysis of Need - a justification of need for each project along with a cost/benefit
analysis comparison of alternatives.
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (RFP)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH 25,2021aJ
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s).
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus 5 percent
during a particular year please list and explain the reason(s) for the budget
amount difference.
REQUEST NO. 102: Please provide all Company documentation that supports that the
Coyote Springs 2 Single Phase Transformer project was the least cost solution. Please include the
Company's analysis, consultant studies, reports, meeting notes, and communication used to
support the selection.
REQUEST NO. 103: Please provide the following documentation for each transmission
and distribution capital project with a budget amount of $1,000,000 or more that was completed
from 2018 through the current date (where requested information has not been provided, please
explain why it was not provided and how the Company assured the construction of the project was
completed at least cost):
a. Analysis of Need - a justification of need for each project along with a cost/benefit
analysis comparison of alternatives.
b. Project Plani. Initial project scope.ii. Proposed budget.iii. Proposed schedule.
c. Requests for proposals (RFP)i. Project requirements.ii. Specifications.iii. Short list bidder scorecard.
iv. RFP from winning bid.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH 25,20214
d. Project construction documentation including:
i. Construction contract.
ii. Orgarizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s).
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons leamed.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus 5 percent
during a particular year please list and explain the reason(s) for the budget
amount difference.
REQUEST NO. 104: Please provide the following documentation for each natural sas
capital project with a budget amount of $1,000,000 or more that was completed from 2018
through the current date (where requested information has not been provided, please explain why
it was not provided and how the Company assured the construction of the project was completed
at least cost):
a. Analysis of Need - a justification of need for each project along with a cost/benefit
analysis comparison of altematives.
b. Project Plani. Initial project scope.ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (RFP)
i. Project requirements.ii. Specifications.iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:i. Construction contract.ii. Organizational chart.iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s).
viii. Contractors change order request(s).
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH 25,202I5
Company proj ect completion analysis
i. Lessons leamed.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus 5 percent
during a particular year please list and explain the reason(s) for the budget
amount difference.
REQUEST NO. 105: Please provide a list of all transactions booked since 2018 to FERC
Regulatory Asset Account No. 182.314 - Other Reg Asset - Fiserv allocated or directly assigned
to the Company's Idaho Natural Gas jurisdiction.
REQUEST NO. 106: Please provide a list of all transactions booked since 2018 to FERC
Regulatory Asset Account No. 182.344 - Reg Asset - Wildfire Resilience allocated or directly
assigned to the Company's Idaho Electric jurisdiction.
REQUEST NO. 107: Please provide a list of all Operation and Maintenance expenses
incurred for the Wildfire Resiliency Plan for 2019 and2020. In your response, please provide
vendor name, amount, date, FERC account number, and a brief description of the expense.
REQUEST NO. 108: Please provide a detailed listing of the proforma Wildfire
Resiliency Plan O&M Expenses for 2021 ard2022.
RJQUEST NO. 109: Regarding NERC CIP security regulatory obligations in Jeff
Schlect Direct Testimony, pages 3-5, please provide business case documentation or project
selection analysis documents for all projects that were utilized and the requirements they satisfr.
REQUEST NO. 110: Regarding NERC CIP security regulatory obligations in Jeff
Schlect Direct Testimony, pages 3-5, please describe how the projects and investments included in
the NERC CIP transmission expenses are different from other IS/IT business cases, to include
NERC CIP Compliance enterprise security.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
e
6 MARCH 25,2021
REQUEST NO. 111: Regarding Elizabeth M. Andrews Workpapers - l) PF 3.04ID ISIT
Adj 2020, please describe the categorization of IS/IT costs and why they differentiate from
enterprise technology identification. Please include a detailed list of costs associated with each
system type.
REQUEST NO. 112: Regarding the Wildfire Resiliency Plan in Heather L. Rosentrater
Direct Testimony, pages 19-20, please provide all business case documentation or project
selection analysis documents for all projects that are in the Wildfire Resiliency Plan. Please
describe how wildfire resiliency project costs are differentiated from other project costs.
REQUEST NO. 113: Regarding Enterprise Technology Capital Additions in James M.
Kensok Direct Testimony, listed on page 12, please provide business case documentation or
project selection analysis documents and completion dates or expected in-service dates for all
technology projects listed below:
o High Voltage Protection (HVP) Refresh
o Technology Refresh to Sustain Business Process
o Basic Workplace Technology Delivery
o Enterprise Data Science
o ET Modernization & Operational Efficiency - Technology
o Facilities Driven Technology Improvements
o Fiber Network Lease Service Replacement
o Land Mobile Radio & Real Time Communication Systems
o Financial & Accounting Technology
o Energy Resources Modernization & Operational Efficiency
o Human Resources Technology
o Legal & Compliance Technology
o CIP v5 Transition - Cyber Asset Electronic Access
o Payment Card Industry Compliance (PCf
o NERC CIP Compliance
o Facilities and Storage Location Security
o Telecommunication & Network Distribution location Security
o Enterprise Business Continuity
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH 25,20217
REQUEST NO. 114: Please provide workpapers that derive the following2019 actuals
and the pro forma net power costs from Mr. Kalich's Exhibit 9.
Item 2019 Actuals
(Thousand Dollars)
Pro Forma
(Thousand Dollars)
Chelan PUD 15,277 14,680
Douglas PUD 2,629 3,615
Grant PUD 9,438 tL,273
Lancaster PPA 28,141 28,467
Lancaster Combined
Cycle Combustion
Turbine
27,247 29,254
BPA Point-to-Point for
Colstrip, Coyote Springs 2
& Lancaster
12,322 14,350
WNP-3 under Account
555
7,911
WA WNP3 - reconciling
items (not in ERM/PCA)
88
WNP-3 under Account
56s
472
REQUEST NO. 115: Please provide a copy of each of the following contracts:
a. The Chelan PUD contract
b. The Douglas PUD contract
c. The Grant PUD contract
d. The Lancaster PPA
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
8 MARCH 25,2021
Dated at Boise, Idaho, this 25rH day of March2O2l
John Jr
General
umisc/prod req/avue2l. l_awg2l. ljh prod req4
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION
9 MARCH 25,2027
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF MARCH 2021,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
coMMrssloN STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-21-01/AVU-G-21-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
PATzuCK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail : [e-mail]
avistadockets@avistacorp. com
BENJAMIN J OTTO
DAINEE GIBSON-WEBB
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-mail : botto@,idahoconservation.org
[e-mail]
VICKI M BALDWIN
PARSON BEHLE & LATIMER
2OI SOUTH MAIN STREET SUITE 18OO
SALT LAKE CITY UT 84111
E-mail: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-mail: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail : [e-mail]
Electronic Service Only:
carol.haugen@c I earwaterpaper. com
terry.borden @,clearwaterpaper. com
malisa.mavnard@clearwaterpaper. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO WEST MAIN STREET SUITE 13OO
BOISE ID 83702
E-mail: [e-mail]
Electronic Service Only :
STEVE W CHRISS
DIRECTOR ENERGY SERVICES
WALMART INC
E-mail: [e-mail]
LARRY A CROWLEY DIRECTOR
THE ENERGY STRATEGIES INSTITUTE
3738 S HARRIS RANCH AVE.
BOISE ID 83716
E-mail: crowley l.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
CERTIFICATE OF SERVICE
BRAD M PURDY
ATTORNEY AT LAW
2019 N ITTH STREET
BOISE IDAHO 83702
E-mail: [e-mail]
J.,4A*',
SECRETARY' /-
/
CERTIFICATE OF SERVICE