20210416Staff 1-2 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, \D 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ELECTRIC LII\E
EXTENSION SCHEDULE 5I ANNUAL RATE
ADJUSTMENT FILING OF AVISTA
CORPORATION
CASE NO. AVU-E-2T-03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attorney General, request that Avista Corporation (Company) provide
the following documents and information as soon as possible, or by FRIDAY, MAY 7,2021.
This Production Request is continuing, and the Company 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. The Company 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
31.0t.01.228.
FIRST PRODUCTION REQUEST
TO AVISTA
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APRIL 16,202I
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. 1: On page 4 of the Application, the Company states that the primary
driver of the increase in overhead line extension rates is due to a decrease in vehicle usage during
2020. Please respond to the following regarding decreased vehicle usage and the increase in
overhead line extension rates:
a. Please provide the reasons for decreased vehicle usage in overhead electrical
work during2020.
b. Does the Company expect the decreased vehicle usage in overhead electrical
work to continue in future years? Please explain.
c. Please provide the vehicle usage by year for all vehicles used in overhead
electrical work from 2018-2020.
d. Did vehicle usage in underground electrical work decrease during 2020? Please
explain.
e. Please explain other drivers, besides decreased vehicle use, that caused an
increase in overhead line extension rates.
REQUEST NO.2: On page 5 of the Application, the Company states that the primary
driver ofthe decrease in underground line extension rates is due to a business process
improvement in the way vehicle rates are applied in the Company's workorder system. Did this
business process improvement affect any of the other average costs discussed in the Application?
If so, please explain how those costs were affected. If not, please explain why not.
DATED at Boise,Idaho, this l6rH day of April2}2l
r(
Edward
Deputy Attorney General
i:umisc:prodreq/avue2 I .3ejme prod req I
FIRST PRODUCTION REQUEST
TO AVISTA
P
2 APRIL 16,202I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF APRIL 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OT' THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-21-03,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-mail : [e-mail]
avi stadockets@avistacorp. com
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
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SECRETARY
CERTIFICATE OF SERVICE