20210524IFG 1-12 to Avista.pdf

Ronald L.Williams,ISB No.3034
P.O.Box 388
802 W.Bannock Street,Suite LP 100
Boise,ID 83701
Telephone:[phone]
Email:[e-mail]
Attorneys for Idaho Forest Group LLC
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION OF )Case No.AVU-E-21-01
AVISTA CORPORATION DBA AVISTA )UTILTIES FOR THE AUTHORITY TO )FIRST PRODUCTION REQUEST
INCREASE ITS RATES AND CHARGES FOR )AND INTERROGATORIES OF
ELECTRIC SERVICE TO ELECTRIC )IDAHO FOREST GROUP LLC TO
CUSTOMERS IN THE STATE OF IDAHO )AVISTA CORPORATION
Idaho Forest Group LLC ("IFG"),by and through its attorney of record Ronald L.
Williams and pursuant to the Rules of Procedure of the Idaho Public Utilities Commission
("Commission"),hereby requests that Avista Corporation ("Avista"or the "Company")provide
the followingdocuments and information and answer the below interrogatories,if possible,no
later than 5:00 PM on May 28.2021.
These Production Requests and Interrogatories are 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,and supporting work papers 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
IFG's FIRST PRODUCTIONREQUESTS AND INTERROGATORIESTO AVISTA UTILITIES
Case No.AVU-E-21-01 Page 1
IFG’s FIRST PRODUCTION REQUESTS AND INTERROGATORIES TO AVISTA UTILITIES
Case No. AVU-E-21-01 Page 2
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. 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 or memory stick with formulas activated.

REQUEST NO. 1. Reference Andrews workpaper for adjustment “1.00 Results of
operations”: Please provide Avista’s results of operations files for calendar year 2020. Please
provide both the AMA and EOP files e.g. “12A-2020.12-Avista Electric Pull” and “12E-
2020.12-Avista Electric Pull.”

REQUEST NO. 2. Please provide Avista’s normalized electric results of operations for
calendar year 2020, including support for all restating and other adjustments to the unadjusted
results.

REQUEST NO. 3. Please identify Avista’s actual electric rate base for calendar year 2020
on an AMA basis, including gross plant, depreciation reserves and ADFIT. Please detail both
the total system and Idaho allocated amounts. Please also provide detail for each functional
category of rate base, e.g. distribution, production, transmission, general and intangible plant.

REQUEST NO. 4. Please identify Avista’s actual electric rate base as of December 31,
2020 on an EOP basis, including gross plant, depreciation reserves and ADFIT. Please detail
both the total system and Idaho allocated amounts. Please also provide detail for each
functional category of rate base, e.g. distribution, production, transmission, general and
intangible plant.

REQUEST NO. 5. Please identify Avista’s actual electric rate base on a monthly basis over
the 13-month period April 2020 through April 2021, including gross plant, depreciation reserves
and ADFIT. Please detail both the total system and Idaho allocated amounts. Please also
IFG’s FIRST PRODUCTION REQUESTS AND INTERROGATORIES TO AVISTA UTILITIES
Case No. AVU-E-21-01 Page 3
provide detail for each functional category of rate base, e.g. distribution, production,
transmission, general and intangible plant.

REQUEST NO. 6. Please identify Avista’s depreciation and amortization expenses by
FERC account over the 12-month period May 2020 through April 2021. Please detail both the
total system and Idaho allocated amounts.

REQUEST NO. 7. Please provide an updated insurance expense calculation supporting
Andrews adjustment 3.06 for electric services updated consistent with Avista’s response to
Washington Staff Data Request 44 in Docket UE-200900 before the Washington Utilities and
Transportation Commission.

REQUEST NO. 8. Please provide Avista’s current electric load forecast on a monthly basis
for calendar years 2021, 2022, 2023 and 2024. Please provide the forecast on a total-system and
Idaho-allocated basis. Please also identify when the load forecast was prepared and provide
workpapers supporting the forecast.

REQUEST NO. 9. Please provide actual Idaho base rate revenues by rate schedule for
calendar year 2020. Please provide the revenues on a normalized and non-normalized basis.
Please also include all billing determinant consistent with Avista’s rate design workpapers
sponsored by witness Miller.

REQUEST NO. 10. Please provide detail of actual IT&S expenses consistent with
Andrews electric adjustment 3.04. Please provide the data by vendor and for calendar years
2018, 2019, and 2020.

REQUEST NO. 11. Please provide actual non-executive labor expenses for calendar
year 2020 consistent with the workpapers supporting Andrews electric adjustment 3.01. Please
detail the expenses by FERC account and provide separate detail for union and non-union
employees. Please also detail the total-system and Idaho-allocated amounts.

IFG’s FIRST PRODUCTION REQUESTS AND INTERROGATORIES TO AVISTA UTILITIES
Case No. AVU-E-21-01 Page 4
REQUEST NO. 12. Please provide actual executive labor expenses for calendar year
2020, consistent with the workpapers supporting Andrews electric adjustment 3.02. Please detail
the expenses by FERC account and provide the total-system and Idaho-allocated amounts.

DATED at Boise, Idaho, this 24th day of May, 2021.
Respectfully submitted,

/s/ Ronald L. Williams
____________________________________
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Idaho Forrest Group LLC

IFG CERTIFICATE OF SERVICE, Case No. AVU-E-21-01 Page 1
CERTIFICATE OF MAILING

I HEREBY CERTIFY that on this 24th day of May 2021, I caused to be served in
IPUC Case No. AVU-E-21-01 a true and correct copy of Idaho Forest Group’s First
Production Requests and Interrogatories upon the following individuals by electronic mail:

Jan Norkyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720, Boise ID 83720-0074
11331 W. Chinden Blvd, Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

John Hammond, Jr.
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720
Email: [e-mail]

David J. Meyer
Avista Corporation
P.O. Box 3727
1411 East Mission Avenue
Spokane, WA 99220-3727
[e-mail]

Patrick Ehrbar
Avista Corporation P.O. Box 3727
1411 East Mission Avenue Spokane, WA99220-
3727 [e-mail]
[e-mail]

Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702
peter@richardsonadam s.com

Dr. Don Reading
6070 Hill Road
Boise, ID 83703
[e-mail]
Benjamin Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
[phone] x 12
[phone]
[e-mail]

Dainee Gibson-Webb
Idaho Conservation League
710 N. 6th St
Boise, ID 83702
[e-mail]

Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
[e-mail]

Larry A. Crowley, Director
The Energy Strategies Institute, Inc.
3738 S Harris Ranch Ave
Boise, ID 83716
[e-mail]

IFG CERTIFICATE OF SERVICE, Case No. AVU-E-21-01 Page 2

Norman M. Semanko
Parsons Behle & Latimer
800 W. Main St., Suite 1300
Boise, ID 83702
[e-mail]

Vicki M. Baldwin
Parsons Behle & Latimer
201 S. Main St., Suite 1800
Salt Lake City, UT 84111
[e-mail]

Steven W. Chriss
Director, Energy Strategies, Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
[e-mail]

Clearwater Paper electronic service:
[e-mail]
[e-mail]
[e-mail]

/s/ Ronald L. Williams
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Idaho Forest Group, LLC