20210812Staff 1-4 to Avista.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5214
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Street Address for Express Mail:
1 I331 W CHINDEN BLVD, BLDG 8, SUTTE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S RESIDENTIAL AND
SMALL FARM ANNUAL RATE
ADJUSTMENT FILING
CASE NO. AVU.E.21-10
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Erick Shaner, Deputy Attomey General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than THURSDAY,
AUGUST 26,2021.1
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-14.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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I AUGUST 12,2021
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide supporting documentation for the actual balance of
$487,730.25 as of 5/3112021, as stated on the Attachment A workpaper entitled "Idaho
Residential Exchange Account Actual and Projected".
REQUEST NO. 2: Please provide supporting documentation for the BPA monthly
credits as stated on the workpaper titled "Idaho Residential Exchange Account - Actual and
Projected."
REQUEST NO.3: For the work paper entitled "Projected Kilowatt-hours and
Residential Exchange Amortization", please provide an explanation, with supporting
documentation, on how the projected kilowatt-hours for each group are calculated.
REQUEST NO. 4: Please provide an explanation, with supporting documentation, on
how the work paper entitled "BPA Residential Exchange Load Calculation" was created.
DATED at Boise, Idaho, this l2eauy of August 2021.
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Erick Shaner
Deputy Affomey General
i:umisc:prodreq/avue2 l. I Oesjk prod req I
FTRST PRODUCTTON REQUEST
TO AVISTA CORPORATION 2 AUGUST I2,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l2th DAY OF AUGUST 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TI{E
C0MMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-21-10,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
POBOX3727
SPOKANE WA99220-3727
E-MAIL : [e-mail]
[e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE