20220411Staff 1-7 to Avista.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMTSSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
!.,:-!1
r a ,\l-'-'l l: tiU
, rll
' I r .,1,1"-l-r. :,,: -..5t4\iI
.,-, ..1 -,|'JlI
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ELECTRIC LINE
EXTENSION SCHEDULE 51 ANNUAL RATE
ADJUSTMENT FILING OF AVISTA
CORPORATION
CASE NO. AVU-8.22.05
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,
Chris Burdin, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than MONDAY, MAY 212022.
This Production Request is to be considered as continuing, and Avista Corporation 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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
)
)
)
)
)
)
)
)
)
APRIL II,2O22
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 the US Bureau of Labor Statistics, Producer Price
Index, for thermoplastic resins from 2015 through to the current period, monthly if available.
REQUEST NO.2: Please provide workpapers in electronic format with links intact and
formulae enabled that support the table of values shown on page 4 of the Application.
REQUEST NO.3: Please provide documentation supporting the claim that higher resin
costs are attributed to: (l) higher demand than manufacturers can supply; and (2) that
manufacturers located along the Texas gulf coast were taken offline one or more months due to
hurricanes and storms affecting the supply of resin in the market. Application at 415.
REQUEST NO. 4: Please provide Company invoices showing the Company's purchase
of 2-inch and 3-inch conduit for the past five yea.rs. These invoices should reflect vendor name,
item description (including specified standard), size, quantity, and price.
REQUEST NO. 5: Please explain the Company's purpose and need for using the term
"Exceptional" in Schedule 51 - Line Extension, Conversion and Relocation Schedule.
REQUEST NO. 6: Please explain why the term "Exceptional" in Schedule 51 - Line
Extension, Conversion and Relocation Schedule would be preferred over the term'Non-
Standard".
REQUEST NO. 7: Please provide several real-life examples explaining why new and/or
existing customers have had difficulty in understanding the provisions outlined in the Company's
tariff Schedule 5l regarding Basic Cost. Application at 5.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 APRIL II,2O22
DATED at Boise, Idaho, this il& Uyof April ZM2.
Chris Burdin
Deputy Attorney Gene,ral
hmriso:prodrc{wuo22.5obrt prcd req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 APRIL II,2A22
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 1ITH DAY OF APRIL 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
coMMrssloN sTAFx' To AyISTA CORPORATION, IN CASE NO. AW-E-22-05,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
PATRICK EHRBAR
DIRECTOR REGULATORY AFFAIRS
AVISTA CORPORATION
POBO){3727
SPOKANE WA99220-3727
E-mail : [e-mail]
dockets@avi stacom.com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE