20230418Staff 142-166 to AVU.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION Ü Û
PO BOX 83720
BOISE,IDAHO 83720-0074 16
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.AVU-E-23-01
AVISTA CORPORATION FOR THE )AVU-G-23-01
AUTHORITY TO INCREASE ITS RATES AND )CHARGES FOR ELECTRIC AND NATURAL )SIXTH PRODUCTION
GAS SERVICE TO ELECTRIC AND NATURAL )REQUESTOF THE
GAS CUSTOMERS IN THE STATE OF IDAHO.)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 dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and information as soon as
possible,but no later than TUESDAY,MAY 2,2023.1
This Production Request is to be considered as continuing,and Avista 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 telephonenumber of
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION l APRIL 18,2023
the person preparing the documents.Please also identify 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 with formulas intact and enabled.
REQUESTNO.142:Please describe changes made to the Company's allocation
methodology since the last general rate case.
a.If changes were made due to legislation,regulatory mandates,or commission
orders please explain how allocation factors were modified for each change and
eachjurisdiction;and
b.Quantifythe impact,if any,to Idaho in dollars,as a result of the change.
REQUESTNO.143:Please describe and include specifics of how the Coeur d'Alene,
ID gate station upgrade described in the Company's latest natural gas IRP was considered in this
case.
REQUESTNO.144:Please provide an Excel version of Table No.4 on page 24 of
Company witness DiLuciano's Direct Testimony that details the natural gas capital projects costs
by system and jurisdiction (Idaho,Oregon,and Washington)by project,and by year,for the
years 2022 through 2025.
REQUESTNO.145:Please provide the costs that will be allocated to Idaho natural gas
for the System Operations Office ("SOO")and Backup Control Center ("BuCC")project by year
for 2022 through 2025.
REQUESTNO.146:Company witness DiLuciano's Direct Testimony maintains that
federal and state regulatory requirements are a driver of 39%of the Company's investment for
2022 through 2025.Please provide a workpaper that details the costs by regulatory requirement
and year for Idaho for the years 2022 through 2025.
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION 2 APRIL 18,2023
REQUESTNO.147:Please describe how Idaho Commission Order No.35585 in Case
No.AVU-G-22-03 was incorporated into the cost calculations for the Planned Meter Changeout
program as referenced in Company witness DiLuciano's Direct Testimony on page 27.
REQUESTNO.148:In Company witness DiLuciano's Direct Testimony on page 28,
the witness describes the Gas Transient Voltage Mitigation Program.Please explain if,and
what,the Company's electric business is doing to mitigate issues on the electric transmission
system.
REQUESTNO.149:Please describe in detail the services the Customer Assistance
Referral and Evaluation Services ("CARES")team provides.
REQUESTNO.150:Please provide the number of customers the CARES team has
assisted in each of the past three years (2020,2021 and 2022)in total and by jurisdiction.
REQUESTNO.151:Regarding the Company's response to Production Request No.
04(i),Staff Attachment 4A,please provide copies of invoices,contracts,workpapers,supporting
documentation and a brief explanation on the cost differences between 2021 and 2022 insurance
coverage.
REQUESTNO.152:Regarding the Company's response to Production Request No.3,
Staff_PR-003C-Confidential Attachment 153A,please provide copies of invoices from Staffs
confidential attachment.
REQUESTNO.153:Regarding the Company's response to Production Request No.3,
Staff_PR-003C-Confidential Attachment 154A,please explain what happened and provide
additional details about each item listed in Staff's confidential attachment.
REQUESTNO.154:Regarding the Company's response to Production Request No.37,
please provide all documents and supporting information for Wildfire Operation and
Maintenance expense samples selected in Attachment 155A,tab labeled O&M.
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION 3 APRIL 18,2023
REQUESTNO.155:Regarding the Company's supplemental response to Production
Request No.16,please provide all documents and supporting information for ER 2075 -
Wildfire Resiliency samples selected in Attachment 156A,tab labeled Capital.
REQUESTNO.156:Please provide the actual cost of wildfire insurance attained by the
Company for 2017 through 2023.Please provide supporting documents (i.e.,invoices).
REQUESTNO.157:Please provide any supporting documentation for the increase in
insurance related to the Wildfire Resiliency Plan ("WRP")for 2022.Please provide any
supporting documentation for the estimated increase in insurance costs for 2023 and 2024 (i.e.,
emails,letters,invoices).
REQUESTNO.158:Please describe any occurrences where the Company
undergroundedany distribution lines both inside and outside of the scope of the WRP.
a.If any,please provide a supporting workpaper that details a brief description,
location,cost,and FERC account.
REQUESTNO.159:Please explain why the wildfire category cost of "Wildfire
Planning"in 2022 was nearly $217,000 more than the projected cost for 2023.Please provide
any supporting workpapers.
REQUESTNO.160:In the table "2023 Wildfire Resiliency Program Elements"on
pages 11 and 12 in the WRP,there are 4 projects that have costs labeled as "Embedded cost".
a.Please define "embedded costs".
REQUESTNO.161:Please explain why the Company changed its "Risk Tree"
program to inspect 100%of distribution lines every year from 20%.
a.Please explain the benefits of doing the annual inspection of 100%of the electric
distribution system each year compared to the 20%;and
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION 4 APRIL 18,2023
b.Please provide supporting documents of the increased need for the full-scale
program and supporting workpapers that show the increased year-over-year costs
through2025.
REQUESTNO.162:Please provide a worksheet that describes any participation in
wildfire-related groups.Please include the name of the group,description of the group,cost of
participation,and the benefits gained from each group.
REQUESTNO.163:Please explain how jurisdictional allocations are considered and
displayed within the WRP.If jurisdictional allocations are not considered and displayed within
the WRP,please explain why not.
REQUESTNO.164:Please explain how jurisdictional allocations are reconciled
between the WRP and actual costs.
REQUESTNO.165:As a supplement to response to Production Request No.48,please
explain what the criteria to determine a pilot a "success"is.Please explain how least-cost,least-
risk is used to evaluate projects.
REQUESTNO.166:As stated in Company response to Production Request No.49,the
Company did not begin tracking steel poles installations directly relatedto wildfire resiliency
until 2022.Please explain how the Company attributed steel pole installations expenses to the
WRP in 2021.
DATED at Boise,Idaho,this Ëday of April 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/avue23.l_avug23.lcbde prod req 6
SIXTH PRODUCTION REQUEST
TO AVISTA CORPORATION 5 APRIL 18,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18th DAY OF APRIL 2023,
SERVED THE FOREGOING SIXTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NOS.AVU-E-23-01/
AVU-G-23-01,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:[e-mail]
[e-mail]
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27TH STREET EAGLE,ID 83616
BOISE ID 83702 E-mail:[e-mail]
E-mail:[e-mail]
Electronic Service Only:
carol.haugen clearwaterpaper.com
[e-mail]
[e-mail]
ANDREW P MORATZKA LARRY A CROWLEY
STOEL RIVES LLP THE ENERGY STRATEGIES INSTITUTE
33 SOUTH SIXTH STREET,SUITE 4200 3738 S HARRIS RANCH AVE.
MINNEAPOLIS,MN 55402 BOISE ID 83716
E-MAIL:andrew.moratzka stoel.com E-mail:[e-mail]
JUSTINA A.CAVIGLIA STEVE W CHRISS
PARSONS BEHLE &LATIMER DIRECTOR,ENERGY SERVICES
50 W.LIBERTY STREET,SUITE 750 WALMART INC
RENO,NV 89502 2608 SOUTHEAST J ST
E-MAIL:[e-mail] BENTONVILLE AR 72716
E-MAIL:[e-mail]
CERTIFICATE OF SERVICE
MARIE CALLAWAY KELLNER BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH ST 710 N 6TH ST
BOISE ID 83702 BOISE ID 83702
E-MAIL:mkellner idahoconservation.ora E-MAIL:
bheusinkveld idahoconservation.org
F DIEGO RIVAS
NW ENERGY COALITION
1101 8TH AVE
HELENA MT 59601
E-MAIL:diego nwenerev.org
SECRE
CERTIFICATE OF SERVICE