20210402Staff 116-135 to Avista.pdf

JOHN R.HAMMOND,JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 '
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.5470
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )AVISTA CORPORATION FOR AUTHORITY )CASE NO.AVU-E-21-01
TO INCREASE ITS RATES AND CHARGES )AVU-G-21-01
FOR ELECTRIC AND NATURAL GAS )SERVICE FOR ELECTRIC AND NATURAL )FIFTH PRODUCTIONGASCUSTOMERSINTHESTATEOFIDAHO.)REQUESTOF 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 AttorneyGeneral,requests that Avista Corporation dba Avista
Utilities ("Avista"or the "Company")provide the followingdocuments and information as soon
as possible,or by FRIDAY,APRIL 23,2021.
This Production Request is continuing,and Avista is requested to provide,by way of
supplementaryresponses,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.
FIFTH PRODUCTION REQUEST l APRIL 2,2021
TO AVISTA CORPORATION
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.116:Company witness Kalich's Exhibit No.9 is based on the pro forma
period from September 1,2021 through August 31,2022.Please confirm that Exhibit No.9 will
be used for both Rate Year 1 (September 1,2021 through August 31,2022)and Rate Year 2
(September 1,2022 through August 31,2023).
REQUESTNO.117:Item "BPA Point-to-Point for Colstrip,Coyote Springs 2 &
Lancaster"in Schedule 2 of Mr.Kalich's Exhibit No.9 contains transmission expenses based on
BPA's Point-to-Point transmission capacity for Colstrip,Coyote Springs 2,and Lancaster,which
includes additional 50 MW contract for Coyote Springs 2.However,BPA did not award Avista
the 50MW contract.Please provide the pro forma net power cost adjustments with updates to
confidential and non-confidential schedules and workpapers supporting Mr.Kalich's Exhibit No.
9 and any corresponding changes to the revenue requirement.
REQUESTNO.118:For the natural gas capital projects listed in Table No.4 (Natural
Gas Capital Projects (System))on page 32 of Company witness Rosentrater's direct testimony,
please provide the table in Excel with formulas enabled to include:
a)Current system values for each business case by year.
b)Current values for each jurisdiction by each business case and by year.Include a
supporting worksheet(s)that shows how each jurisdictionalvalue is calculated.
c)An explanation of allocation factors applied or exceptions to allocation factors applied
to each business case and jurisdiction.
REQUESTNO.119:Please provide a version of Ms.Rosentrater's Appendix A Exhibit
No.11 that shows costs by jurisdiction by year for the 2018 Baseline Model and 2018
20-Year Replacement columns in the current appendix.
FIFTH PRODUCTION REQUEST 2 APRIL 2,2021
TO AVISTA CORPORATION
REQUESTNO.120:Regarding the Company's response to Production Request No.12,
please provide further explanation of the events that caused the injuries and damages claims for
the followingamounts:
$29,431.01:Invoice #:L -909340 D
$9,192.6:Invoice#:L-934297 D
$3,27.32:Invoice #:L-924021 D
REQUESTNO.121:Please provide the flight logs for all flights by Company-owned
aircraft for the years 2019 through 2021 as available.
REQUESTNO.122:Please provide a copy of Avista's Policies on Travel for employees
and executives.
REQUESTNO.123:Regarding the Company's response to Production Request No.4(d),
please provide copies of invoices,contracts,engagement letters,etc.for the $115,000 paid to
Moody's.
REQUESTNO.124:Regarding the Company's response to Production Request No.6,
for the year 2019,please provide copies of invoices,settlement agreements,vendor payments for
the followingproject numbers:
77705250 =$320,362.67
09800510=$127,743.61
09803014 =$28,986.64
REQUESTNO.125:For each of the past four calendar years,please provide the monthly
and annual total number of residential gas and/or electric customer accounts.
REQUESTNO.126:For each of the past four calendar years,please provide the monthly
and annual total number of residential gas and/or electric customer accounts disconnected from
service for non-payment.
FIFTH PRODUCTION REQUEST 3 APRIL 2,2021
TO AVISTA CORPORATION
REQUESTNO.127:For each of the past four calendar years,please provide:(a)the
monthlyand annual total number of residential gas and/or electric customer accounts with
payment arrangement agreements;and (b)the monthlyand annual total number of new payment
arrangement agreements made on residential gas and/or electric customer accounts.
REQUESTNO.128:For those customer accounts identified in the response to Request
No.128,how many and what percentage of customer accounts defaulted on payment
arrangements each month and annually?
REQUESTNO.129:For each of the past four calendar years,please provide the monthly
and annual total number of customer accounts that participated in Comfort Level Billing.How
many and what percentage of those customer accounts discontinued Comfort Level Billing each
month?
REQUESTNO.130:For each of the past four calendar years,please provide the monthly
and annual total number of customer accounts that had a Levelized Pay Plan.How many and what
percentage of those customer accounts defaulted on a Levelized Pay Plan each month?Of those
customer accounts that defaulted on a Levelized Pay Plan,how many were subsequently
disconnected for non-payment within 60 days of default?
REQUESTNO.131:For each of the last four years,please provide by month how many
residential gas and/or electric customer accounts that were signed up for the winter Payment Plan
to protect from disconnection in November,December,January,February and March.
REQUESTNO.132:For each of the last four years,please provide by month the number
and percentage of the customer accounts under the Winter Payment Plan that defaulted to the
Winter Moratorium for December,January,and February.
REQUESTNO.133:Please provide the number and percentage of customer accounts
that defaulted on the Winter Payment Plan for each month during the last four calendar years.
FIFTH PRODUCTION REQUEST 4 APRIL 2,2021
TO AVISTA CORPORATION
REQUESTNO.134:Please provide the number of residential customers that had past
due accounts as of year-end for each of the last four calendar years.Please provide an aging
report includingthe number of customers,and the amount they owed,collectively,ex.the total
number of residential customers who are behind in payments,and how many are 30 days late,60
days late,and 90 days late,and the total amount owed for each billing category for each month.
REQUESTNO.135:For each FERC account listed below,please provide a list of all
transactions booked in 2019.Please include vendor name,date,invoice number,and a brief
description of the expense.Please also include total system amounts,and how each amount was
allocated or assigned to each jurisdiction:
a.403.027 Colstrip Plant Adj Depr
b.588 Distribution Oper-Misc
c.880 Dist Exp Oper-Other Expenses
d.904 Uncollect Accts
e.905 Misc Cust Ac Ex
f.910 Cust Svc &Info Exp-Misc
g.923 Outside Services Employed
h.932.2 Misc General Expense
Dated at Boise,Idaho,this day of April 2021.
Jh R.Hammond
uty AttorneyGeneral
i:umisc/prod req/avue21.l_avug21.ljh prod req5
FIFTH PRODUCTION REQUEST 5 APRIL 2,2021
TO AVISTA CORPORATION
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF APRIL 2021,SERVED THE FOREGOING FIFTH PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NOS.AVU-E-21-01/AVU-G-21-01,BY E-MAILING A COPY THEREOF TO THEFOLLOWING:
PATRICK EHRBAR DAVID J MEYERDIROFREGULATORYAFFAIRSVP&CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATIONPOBOX3727POBOX3727SPOKANEWA99220-3727 SPOKANE WA 99220-3727E-mail:[e-mail] E-mail:[e-mail]
[e-mail]
BENJAMIN J OTTO NORMAN M.SEMANKODAINEEGIBSON-WEBB PARSONS BEHLE &LATIMERIDCONSERVATIONLEAGUE800WESTMAINSTREETSUITE 1300710N6THSTBOISEID83702BOISEID83702E-mail:[e-mail]-mail:[e-mail]
[e-mail]
VICKI M BALDWIN Electronic Service Only:PARSON BEHLE &LATIMER STEVE W CHRISS201SOUTHMAINSTREETSUITE1800DIRECTORENERGY SERVICESSALTLAKECITYUT84111WALMARTINCE-mail:[e-mail] E-mail:[e-mail]
RONALD L WILLIAMS LARRY A CROWLEY DIRECTORWILLIAMSBRADBURYPCTHEENERGYSTRATEGIESINSTITUTEPOBOX3883738SHARRISRANCHAVE.BOISE ID 83701 BOISE ID 83716E-mail:[e-mail] E-mail:[e-mail]
PETER J RICHARDSON DR DON READINGRICHARDSONADAMSPLLC6070HILLROAD
515 N 27TH STREET BOISE ID 83703BOISEID83702E-mail:dreading mindspring.comE-mail:[e-mail]
Electronic Service Only:
[e-mail]
[e-mail]
[e-mail]
CERTIFICATE OF SERVICE
BRAD M PURDY
ATTORNEYAT LAW
2019 N 17TH STREET
BOISE IDAHO 83702
E-mail:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE