20230412Staff 94-124 to AVU.pdf

CHRIS BURDIN
DEPUTYATTORNEY GENERALIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-ABOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.AVU-E-23-01AVISTACORPORATIONFORTHE)AVU-G-23-01AUTHORITYTOINCREASEITSRATESAND)CHARGES FOR ELECTRIC AND NATURAL )FOURTH PRODUCTIONGASSERVICETOELECTRICANDNATURAL)REQUESTOF THEGASCUSTOMERSINTHESTATEOFIDAHO.)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Avista Corporation dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and information as soon as
possible,but no later than WEDNESDAY,MAY 3,2023.
This Production Request is to be considered as 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 or informationproduced.
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 identify the name,job title,location,and
telephonenumber of the record holder.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 1 APRIL 12,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.94:Please provide an Excel file showing all capital projects completed
within the test year (July 1,2021 through June 30,2022).For each project,please provide the
following:
a.Name or Title;
b.Project identifier(s)(BCJN,ER,and BI);
c.Plant-In-Service date;
d.Business Case classification (i.e.Generation,Transmission,Distribution,
Environmental,Enterprise,Other,etc.);
e.Rationale supporting the need for each capital investment;
f.Whether a cost benefit analysis was completed (Yes/No);
g.Project dates:(i.e.target start date,actual start date,target completion date,and
actual completion date);
h.Project costs:(i.e.estimated cost,budgeted cost,and actual cost).Note:Where
adjustments were made to forecasted costs indicate the date and amount of the
adjustment;
i.Cost analysis considering whether the work should be completed by a contractor
or primarily using company employees (Yes/No);and
j.If a contractor was used,was a request-for-proposal issued for the project
(Yes/No).
REQUESTNO.95:Please provide an Excel file showing all capital projects completed
within the pro forma period (July 1,2022 through August 31,2025).For each project separated
by year,please provide the following:
a.Name or Title;
b.Project identifier(s)(BCJN,ER,and BI);
c.Plant-In-Service date;
d.Business Case classification (i.e.Generation,Transmission,Distribution,
Environmental,Enterprise,Other,etc.);
FOURTHPRODUCTIONREQUEST
TO AVISTA CORPORATION 2 APRIL 12,2023
e.Rationale supporting the need for each capital investment;
f.Whether a cost benefit analysis was completed (Yes/No);
g.Project dates:(i.e.target start date,actual start date,target completion date,and
actual completion date);
h.Project costs:(i.e.estimated cost,budgeted cost,and actual cost).Note:Where
adjustments were made to forecasted costs indicate the date and amount of the
adjustment;
i.Cost analysis considering whether the work should be completed by a contractor
or primarily using company employees (Yes/No);and
j.If a contractor was used,was a request-for-proposal issued for the project
(Yes/No).
REQUESTNO.96:Please explain the Company's procedures for determining the need
to initiate a request-for-proposal in constructing a capital project.Please also provide any
Company policies and/or guidelines relevant to the process.
REQUESTNO.97:Please provide data and any analyses showing how the following
categorized transmission capital investments are directly beneficial to Avista's Bulk Electric
System (see Bulk Electric System (BES)Definition Reference Document (nerc.com)
(https://www.nerc.com/pa/RAPA/BES%20DL/bes_phase2_reference_document 20140325 fina
l clean.pdf).For each of the transmission projects listed below,please provide an explanation
with specific reasoning and examples indicating how these capital investments directly benefit
the Company's Idaho ratepayers:
a.Saddle Mountain 230/ll5kV Station (New)Integration Project Phase 1;
b.Saddle Mountain 230/115kV Station (New)Integration Project Phase 2;
c.Spokane Valley Transmission Reinforcement Project;and
d.Westside 230/115kV Station Brownfield Rebuild Project.
REQUESTNO.98:Please provide the followingdocumentation for the Colstrip
Generation CapitalProjects referenced in Kinney Direct Testimony,page 38.The response
should include all individual projects within this filing where Avista is seeking recovery of the
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 3 APRIL 12,2023
Company's capital investment.If any of the information requested below cannot be provided or
is not available,please explain why,and explain how the Company ensured the construction of
the project was completed at least cost.
a.Analysis of Need --a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winningbid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actualschedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 4 APRIL 12,2023
REQUESTNO.99:Specific to the Colstrip plant,please describe the methods used to
ensure capital investment projects were completed in a least cost manner.Please include any
guidelines and procedures documenting these methods.
REQUESTNO.100:Please provide the followingdocumentation for the Cabinet
Gorge Dam Fishwayproject referenced by BCJN_01 of Kinney'sExhibit No.6,Schedule 4.
If any of the information requested below cannot be provided or is not available,please explain
why,and explain how the Company ensured the construction of the project was completed at
least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
iv.Initial project scope.
v.Proposed budget.
vi.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 5 APRIL 12,2023
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
vii.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.101:Please provide the followingdocumentation for the Base Load
Thermal Program projects referenced by BCJN_05 of Kinney's Exhibit No.6,Schedule 4.If
any of the informationrequested below cannot be provided or is not available,please explain
why,and explain how the Company ensured the construction of these projects was completed at
least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 6 APRIL 12,2023
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.102:Please provide the followingdocumentation for the Cabinet
Gorge Station Service projects referenced by BCJN 11 of Kinney'sExhibit No.6,Schedule
4.If any of the informationrequested below cannot be provided or is not available,please
explain why,and explain how the Company ensured the construction of these projects was
completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 7 APRIL 12,2023
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actualschedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.103:Please provide the followingdocumentation for the CS2 Single
Phase Transformer project referenced in the Company's response to Staff Production Request
17.If any of the information requested below cannot be provided or is not available,please
explain why,and explain how the Company ensured the construction of the project was
completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 8 APRIL 12,2023
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.104:Please provide the followingdocumentation for the HMI Control
Software projects referenced by BCJN_16 of Kinney'sExhibit No.6,Schedule 4.If any of
the information requested below cannot be provided or is not available,please explain why,and
explain how the Company ensured the construction of these projects was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winningbid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 9 APRIL 12,2023
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.105:Please provide the followingdocumentation for the KF _Fuel
Yard EquipmentReplacement projects referenced by BCJN_20 of Kinney's Exhibit No.6,
Schedule 4.If any of the information requested below cannot be provided or is not available,
please explain why,and explain how the Company ensured the construction of these projects
was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winningbid.
d.Project construction documentation including:
i.Construction contract.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 10 APRIL 12,2023
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.106:Please provide the followingdocumentation for the Long Lake
Plant Upgrade projects referenced by BCJN 24 of Kinney'sExhibit No.6,Schedule 4.If any
of the informationrequested below cannot be provided or is not available,please explain why,
and explain how the Company ensured the construction of these projects was completed at least
cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
FOURTHPRODUCTIONREQUEST
TO AVISTA CORPORATION 11 APRIL 12,2023
d.Project construction documentationincluding:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.107:Please provide the followingdocumentationfor the LongLake
StabilityEnhancement projects referenced from CapitalPlanning Group monthly meetings in
response to Staff Production Request 19.If any of the information requested below cannot be
provided or is not available,please explain why,and explain how the Company ensured the
construction of these projects was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
FOURTHPRODUCTIONREQUEST
TO AVISTA CORPORATION 12 APRIL 12,2023
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.108:Please provide the followingdocumentation for the Noxon
Rapids Spillgate Refurbishmentprojects referenced by BCJN 32 of Kinney'sExhibit No.6,
Schedule 4.If any of the informationrequested below cannot be provided or is not available,
please explain why,and explain how the Company ensured the construction of these projects
was completed at least cost.
a.Analysis of Need --a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 13 APRIL 12,2023
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure,
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.109:Please provide the followingdocumentation for the Regulating
Hydroprojects referenced by BCJN_34 of Kinney'sExhibit No.6,Schedule 4.If any of the
information requested below cannot be provided or is not available,please explain why,and
explain how the Company ensured the construction of these projects was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 14 APRIL 12,2023
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.110:Please provide the followingdocumentation for the Energy
Imbalance Market projects referenced by BCJN_36 of Kinney'sExhibit No.6,Schedule 4.
If any of the information requested below cannot be provided or is not available,please explain
why,and explain how the Company ensured the construction of these projects was completed at
least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 15 APRIL 12,2023
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthlyproject status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.111:Please provide the followingdocumentation for the Protection
System Upgrade for PRC-002 projects referenced by BCJN_15 of Diluciano's Exhibit No.9,
Schedule 3.If any of the information requested below cannot be provided or is not available,
please explain why,and explain how the Company ensured the construction of these projects
was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 16 APRIL 12,2023
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.112:Please provide the followingdocumentation for the Saddle
Mountain 230/115kV Station (New)IntegrationProject referenced by BCJN_16 of
Diluciano's Exhibit No.9,Schedule 3.If any of the information requested below cannot be
provided or is not available,please explain why,and explain how the Company ensured the
construction of the project was completed at least cost.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 17 APRIL 12,2023
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.113:Please provide the followingdocumentation for the Spokane
Valley TransmissionReinforcementProject referenced by BCJN_17 of Diluciano's Exhibit
No.9,Schedule 3.If any of the informationrequested below cannot be provided or is not
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 18 APRIL 12,2023
available,please explain why,and explain how the Company ensured the construction of the
project was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
viii.Initial project scope.
ix.Proposed budget.
x.Proposed schedule.
c.Requests for proposals ("RFP")
v.Project requirements.
vi.Specifications.
vii.Short list bidder scorecard.
viii.RFP from winning bid.
d.Project construction documentation including:
ix.Construction contract.
x.Organizational chart.
xi.Scope document.
xii.Work breakdown structure.
xiii.Baseline Schedule.
xiv.Monthly project status report(s).
xv.Action items list(s).
xvi.Contractors change order request(s).
e.Company project completion analysis
v.Lessons learned.
vi.Budget-to-actual comparisons for overall project and by year.
vii.Baseline schedule-to-actual schedule comparison.
viii.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 19 APRIL 12,2023
REQUESTNO.114:Please provide the followingdocumentation for the Transmission
Construction -Compliance projects referenced by BCJN_18 of Diluciano's Exhibit No.9,
Schedule 3.If any of the information requested below cannot be provided or is not available,
please explain why,and explain how the Company ensured the construction of these projects
was completed at least cost.
k.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
l.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
m.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
n.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
o.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 20 APRIL 12,2023
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.115:Please provide the followingdocumentationfor the Transmission
NERC Low-Risk Priority Lines Mitigationprojects referenced by BCJN_19 of Diluciano's
Exhibit No.9,Schedule 3.If any of the informationrequested below cannot be provided or is
not available,please explain why,and explain how the Company can ensure the construction of
these projects was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winningbid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthlyproject status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 21 APRIL 12,2023
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.116:Please provide the followingdocumentation for the Substation -
Station Rebuilds Program projects referenced by BCJN_24 of Diluciano's Exhibit No.9,
Schedule 3.If any of the information requested below cannot be provided or is not available,
please explain why,and explain how the Company ensured the construction of these projects
was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 22 APRIL 12,2023
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.117:Please provide the followingdocumentation for the Transmission
-Minor Rebuild projects referenced by BCJN_25 of Diluciano's Exhibit No.9,Schedule 3.If
any of the information requested below cannot be provided or is not available,please explain
why,and explain how the Company ensured the construction of these projects was completed at
least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 23 APRIL 12,2023
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.118:Please provide the followingdocumentation for the Transmission
Major Rebuild -Asset Condition projects referenced by BCJN 26 of Diluciano's Exhibit No.
9,Schedule 3.If any of the informationrequested below cannot be provided or is not available,
please explain why,and explain how the Company ensured the construction of these projects
was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 24 APRIL 12,2023
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.119:Please provide the followingdocumentation for the Electric
Storm projects referenced by BCJN_04 of Diluciano's Exhibit No.9,Schedule 3.If any of the
informationrequested below cannot be provided or is not available,please explain why,and
explain how the Company ensured the construction of these projects was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 25 APRIL 12,2023
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.120:Please provide the followingdocumentation for the Distribution
Grid Modernization projects referenced by BCJN_06 of Diluciano's Exhibit No.9,Schedule
3.If any of the informationrequested below cannot be provided or is not available,please
explain why,and explain how the Company ensured the construction of these projects was
completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 26 APRIL 12,2023
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.121:Please provide the followingdocumentation for the Distribution
Minor Rebuild projects referenced by BCJN_07 of Diluciano's Exhibit No.9,Schedule 3.If
any of the information requested below cannot be provided or is not available,please explain
why,and explain how the Company ensured the construction of these projects was completed at
least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winningbid.
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 27 APRIL 12,2023
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.122:Please provide the followingdocumentation for the Wood Pole
Managementprojects referenced by BCJN_09 of Diluciano's Exhibit No.9,Schedule 3.If
any of the information requested below cannot be provided or is not available,please explain
why,and explain how the Company ensured the construction of these projects was completed at
least cost.
p.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
q.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
r.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 28 APRIL 12,2023
iii.Short list bidder scorecard.
iv.RFP from winning bid.
s.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
t.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.123:Please provide the followingdocumentation for the Distribution
System Enhancementprojects referenced by BCJN_10 of Diluciano's Exhibit No.9,
Schedule 3.If any of the informationrequested below cannot be provided or is not available,
please explain why,and explain how the Company ensured the construction of these projects
was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
iii.Proposed schedule.
c.Requests for proposals ("RFP")
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 29 APRIL 12,2023
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actual schedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
REQUESTNO.124:Please provide the followingdocumentation for the Substation -
New Distribution Station Capacity Program projects referenced by BCJN_11 of Diluciano's
Exhibit No.9,Schedule 3.If any of the informationrequested below cannot be provided or is
not available,please explain why,and explain how the Company ensured the construction of
these projects was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b.Project Plan
i.Initial project scope.
ii.Proposed budget.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 30 APRIL 12,2023
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements.
ii.Specifications.
iii.Short list bidder scorecard.
iv.RFP from winning bid.
d.Project construction documentation including:
i.Construction contract.
ii.Organizational chart.
iii.Scope document.
iv.Work breakdown structure.
v.Baseline Schedule.
vi.Monthly project status report(s).
vii.Action items list(s).
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned.
ii.Budget-to-actual comparisons for overall project and by year.
iii.Baseline schedule-to-actualschedule comparison.
iv.For any actual costs differing from the budget amount by plus or minus five
percent during a particular year,please list and explain the reason(s)for the
budget amount difference.
DATED at Boise,Idaho,this (Gday of April 2023.
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/avue23.l_avug23.lcbde prod req 4
FOURTH PRODUCTIONREQUEST
TO AVISTA CORPORATION 31 APRIL 12,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12th DAY OF APRIL 2023,SERVED THE FOREGOING FOURTH PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NOS.AVU-E-23-01/AVU-G-23-01,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYERDIROFREGULATORYAFFAIRSVP&CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATIONPOBOX3727POBOX3727SPOKANEWA99220-3727 SPOKANE WA 99220-3727E-mail:[e-mail] E-mail:[e-mail]@avistacorp.com
PETER J RICHARDSON DR DON READINGRICHARDSONADAMSPLLC280SILVERWOODWAY515N27THSTREETEAGLE,ID 83616BOISEID83702E-mail:[e-mail]-mail:[e-mail]
ElectronicService Only:
[e-mail]
[e-mail]
[e-mail]
ANDREW P MORATZKA LARRY A CROWLEYSTOELRIVESLLPTHEENERGYSTRATEGIES INSTITUTE33SOUTHSIXTHSTREET,SUITE 4200 3738 S HARRIS RANCH AVE.MINNEAPOLIS,MN 55402 BOISE ID 83716E-MAIL:[e-mail] E-mail:crowleyla aol.com
JUSTINA A.CAVIGLIA STEVE W CHRISSPARSONSBEHLE&LATIMER DIRECTOR,ENERGYSERVICES50W.LIBERTY STREET,SUITE 750 WALMART INCRENO,NV 89502 2608 SOUTHEAST J STE-MAIL:[e-mail] BENTONVILLE AR 72716
E-MAIL:Stephen.chriss walmart.com
CERTIFICATEOF SERVICE
MARIE CALLAWAY KELLNER BRAD HEUSINKVELDIDCONSERVATIONLEAGUEIDCONSERVATIONLEAGUE710N6THST710N6THSTBOISEID83702BOISEID83702E-MAIL:mkellner idahoconservation.org E-MAIL:
[e-mail]
F DIEGO RIVAS
NW ENERGY COALITION
1101 8TH AVE
HELENA MT 59601
E-MAIL:[e-mail]
SEC Al(Y
CERTIFICATE OF SERVICE