20210521ICL 1-6 to Avista.pdf

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Benjamin J. Otto (ISB No. 8292)
710 N 6tr Street
Boise,ID 83701
Ph: (208) 34s-6933 xrl2
Fax: [phone]
botto@idahoconservation. org
IN THE MATTER OF TIIE
APPLICATION OF AVISTA
CORPORATION FOR THE
AUTHORITY TO INCREASE ITS
RATES AND CHARGES FOR
ELECTRIC AI\D NATURAL GAS
CUSTOMERS IN THE STATE OF
IDAHO
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Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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cAsE NO. Avrr-E-21-01
CASE NO: AVII-G-21-01
IDAHO CONSERVATION LEAGU
FIRST PRODUCTION REQUST
ICL submits the following production request to Avista, pursuant to IDAPA 31.0
-240. As agreed to during the May 19,2021Settlement Conference, please provide resl
as soon as possible.
This production request is ongoing and ICL requests the Company provide, by w
supplementary responses, additional documents that it or any person acting on its behalf
later obtain that will augment any initial response.
Please provide answers to each question along with all supporting workpapers us,
formulating Avista's answers. Commission's Rules of Procedure require Avista to incluc
rurme and phone number of the person preparing the document, and the name, location, a
phone number of the record holder and, if different, the witness who can sponsor the ans
hearing. IDAPA 31.01.01.228.
Pursuant to Order 3478L and the Notice of Parties in this case, please provide all
responses electronically, via email to [e-mail] and dgibson-
[e-mail], to the electronic depository for confidential information
established by Avista for this docket.
AVU-E-2 I -0 I /AVU-G -21 -01
ICL FIRST PRODCUTION REQUEST I May 21,202
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1.01.216
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REQUEST ICL-I: Mr. Thackston states on page 21 of his Direct Testimony that the Colstrip
owners did not approve a capital budget during 2020. [n response to Staff Production Request
98, Avista states the Colstrip owners approved a2021capital budget on March 24,2021. Please
update the timeline and budgets for each of the Colstrip related capital projects included in this
docket to reflect the Colstrip ownership group approved capital budgets for 2020 and202l.
REQUEST ICL-2: Please provide the most recent budget to actual reports Avista has received
from Talen for each of the Colstrip related capital additions included in Mr. Tackston's Direct
Testimony and Exhibit 7, Schedule 5. For any project that is completed and the budget included
a contingency amount, please indicate whether that contingency amount was spent or not.
REQUEST ICL-3: Please provide documentation that the Montana Department of
Environmental Quality has completed review of the Remedial DesignlRemedial Action Report
for Units 3 and 4 as described in Mr. Thackston's Direct Testimony pages 55, lines 6- 8 and lines
22-23.
REQUEST ICL-4: Please provide all updated project timelines and budgets that result the
Montana DEQ review of the Remedial Design/Remedial Action Report for Units 3 and 4.
REQUEST ICL-5: Please provide documentation that the Unit 3 overhaul scheduled for May
2021 is underway and provide any update on the expected in service date for all capital additions
included in that overhaul.
REQUEST ICL-6: Please provide a status report on the arbitration proceeding currently
underway between the Colstrip ownership group.
Respectfully submitted this 2l't day of May 2021
/s/ Benjamin Otto
Idaho Conservation League
AVU-E-2 I -0 1 /AVU-G -2t -01
ICL FIRST PRODCUTION REQUEST 2 May 21,2021
CERTIFICATE OF SERVICE
I certify that on the 2l st day of May , 2021 ,I served the foregoing FIRST
REQUEST to the following:
/s/ Beniamin Otto
Electronic Mail only:
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
secretary@puc. idaho. gov
j an.noriyuki@puc. idaho. gov
John Hammond
Deputy Attorney General
j ohn. hammond@puc. idaho. gov
Avista Utilities
David J. Meyer, Esq.
Patrick D. Erhbar
David. meyer@avistacorp. com
Pat. Ehrbar@avistacorp. com
AvistaDockets@avistacorp. com
V[/'almart
Vicki M Bladwin
Norman M. Semanko
Parsons Behle & Latimer
vbaldwin@parsonsbehle. com
nsemanko @parsonsbehle. com
Steve W. Chriss
Walmart,Inc
Stephen. Chriss@walmart. com
Idaho Forest Group
Ronald L. Williams
Williams Bradbury PC
ron@williamsbradbury. com
Larry A. Crowley
Energy Strategies Institute
[e-mail]
Clearwater Paper
Peter J Richardson
Richardonson Adams Pllc
peter@richardonadams. com
Dr. Don Reading
dreading@mindspring. com
caro l. hauge n@clearw aterp aper. com
terry. borde n@clearw aterpaper. com
malisa.maynard@clearwaterpaper
CAPAI
Brad Purdy, Attorney at Law
[e-mail]
CERTIFICATE OF SERVICE May 21,1