20210510Staff 178-181 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 AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC AND NATURAL GAS
SERVICE FOR ELECTRIC AND NATURAL
GAS CUSTOMERS IN THE STATE OF IDAHO.
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Street Address for Express Mail:
I1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU-E-2l-OI
AVU-G-21-01
SEVENTH PRODUCTION
REQUEST OF 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 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 MONDAY, MAY 17,2021.r
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
I Staffis requesting an expedited response. lf responding by this date will be problematic, please call Stafls attorney
at (208) 334-03s7.
SEVENTH PRODUCTION REQUEST
TO AVISTA CORPORATION
MAY 10,2021
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.
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. 178: Please provide copies of the following Internal Audit Reports, and
include all internal charges incurred during the audit and how those charges were allocated to the
Company' s j urisdictions :
l. AEL&P Incentive Plan audit
2. Certificate Lifecycle Management Follow-Up review
3. Debt Issuance and Reacquisition Costs Review - Regulatory Requirement
4. Employee and Board of Directors Expense Audit
5. First Care Clinic Physical Security Review
6. Parking Garage Contract Review
7. Security Program review
8. Steam Plant Kitchen and Brewery Follow-Up Review
9. Steam Plant Kitchen and Brewery Intemal Controls Review
R-EQUEST NO. 179: Regarding the Company's response to Production Request No. 4,
please provide the invoices and supporting documentation for the $283,370 spent on producing the
Company's Annual Report.
REQUEST NO. 180: Regarding the Company's response to Production Request No. 3,
please provide copies of invoices from the following law firms and how those expenses were
allocated to the Company's jurisdictions:
l. Gibson Dunn & Crutcher LLP
2. Owens McCrea & Linscott Trust Account
3. Ogletree, Deakins, Nash, Smoak & Steward, PC
4. Regulatory Law Chambers
5. Bracewell LLP
6. Randall Danskin Attorneys -7. KSB Litigation
8. Mclane Law PLLC
9. Stoel Rives -
SEVENTH PRODUCTION REQUEST
TO AVISTA CORPORATION
2 MAY t0,2021
REQIIEST NO. 181: Regarding the Company's response to Production Request No. 6,
please pmvide invoices forproject number 09800510 and the amount allocated to the Idalro
Electic and Idaho Gas jurisdictions.
Dated at Boise, Idaho, this f*rof May 2fr21.
Jr.
Attorney General
i:umiso@rod ndavue2l.l_avupl. ljh prod reqT
SEVENTH PRODUCTION REQUEST
TO AVISTA CORPORATION
J MAY 1.A,z$zt
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IOTH DAY OF MAY 2021,
SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU.E-2I-01/AVU-G-21-OT, BY E-MAILTNG A COPY THEREOF TO THE
FOLLOWNG:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: patrick.avistacom.com
avi stadockets@av i stacorp. com
BENJAMIN J OTTO
DAINEE GIBSON-WEBB
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-mail: [e-mail]
[e-mail]
VICKI M BALDWIN
PARSON BEHLE & LATIMER
2OI SOUTH MAIN STREET SUITE ISOO
SALT LAKE CITY UT 84I I I
E-mail : vbaldwin@.parsonsbehle.com
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOTSE ID 8370I
E-mail: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
Electronic Semice Only:
carol.haugen@c learwaterpaper.com
terfi,. borden@clearwaterpaper. com
mal isa. [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail : david.meyer@.avi stacorp.com
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: Stephen.Chriss@.walmart.com
LARRY A CROWLEY DIRECTOR
THE ENERGY STRATEGIES INSTITUTE
3738 S HARRIS RANCH AVE.
BOISE ID 83716
E-mail: crow'[e-mail]
DR DON READINU
6070 HILL ROAD
BOISE ID 83703
E-mail : [e-mail]
CERTIFTCATE OF SERVICE
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE IDAHO 83702
E-mail: [e-mail]
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SECRETAPr . ,-
CERTIFICATE OF SERVICE