20230505Staff 189-201 to AVU.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.98 10
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor 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 )EIGHTH 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 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 FRIDAY,MAY 12,2023.1
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 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'sattorneyat(208)334-0314.
EIGHTH PRODUCTION REQUEST
TO AVISTA CORPORATION 1 MAY 5,2023
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.189:Mr.Kalich's Direct Testimony states that the EIM revenues above
expenses will pass through the PCA.Please respond to the following:
a.Does Account 447 Sales for Resale capture the EIM revenues above expenses;
b.If not,how do the EIM revenues above expenses pass through the PCA;and
c.Please define the EIM expenses and explain how the EIM expenses are
determined.
REQUESTNO.190:Schedule 2 of Confidential Exhibit No.7 includes a line item
"407 Regulatory Debits:Incremental EIM O&M."Please respond to the following:
a.What does "Incremental EIM O&M"means;
b.How was the $286,000 determined;and
c.Why was the $286,000 item eliminated for the pro forma.
REQUESTNO.191:Please answer the followingregarding WRAP funding included in
Kinney Direct testimony at 56:
a.Please provide actual WRAP funding amounts for 2022 and 2023 (through
March 31,2023);
b.Please define Phase 1,Phase 2,Phase 2b,Phase 3A,and Phase 3B;
c.Please explain the basis and types of costs that make up the actual and estimated
funding included in Table Nos.9 and 10,respectively.Please provide a cost
breakdown of each cost included in the tables and include whether the costs are
one-time or ongoing;and
d.Please explain how the Company determinedan annual recovery amount of
$350,000 given that WRAP has proposed one-time fees and ongoing fees.Please
include electronic workpapers with all formula enabled.
EIGHTH PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MAY 5,2023
REQUESTNO.192:Please reconcile the differences in the requested spend amounts
for CIP v5 Transition described in Table No.1 of Company Witness Kensok's Direct Testimony
at 9 of $416,000 and the $250,000described in the Business Case Justification Narrative in
Kensok's Exhibit No.11 at 254.Please provide a narrative explanation of the difference and any
changes made to the business case.
REQUESTNO.193:Please explain what the Company's existing lifecycle
management program covers.Please provide a supporting workpaper that includes the year over
year budgets,actual spend,and a brief description of differences by item for the years 2020
through 2023.
REQUESTNO.194:In reference to Footnote 6 of Kensok's Direct Testimony at 39,
please provide an update on the IS/IT contracts includingrenewal status,changes to Terms and
Conditions,and consolidation.If contract savings are achieved,please explain the amount of
savings and how the Company will reflect Idaho's share of the savings in this case.
REQUESTNO.195:Please explain if the Distribution IntegrityManagementPlan
("DIMP")expected $200k annual reduction in risk profile beginning in 2023 is reflected in the
Company's revenue requirement.If not,please explain.
REQUESTNO.196:As supplement to Production Request No.66,please provide a
supporting spreadsheet that breaks down each actual cost,description,and year booked within
the Technology Failed Assets from July 2021 to end of the Test Period.Please include details
for the items listed in the Company's response,as well as any additional items incurred between
July 2022 through March 2023.
REQUESTNO.197:As supplement to Production Request No.66,for the Mt.Spokane
Siding project,please explain what the building is used for,why costs are allocated to Idaho,and
reasoning for the project to be included under the Technology Failed Asset business case.
Additionally,please explain why the project is not considered under a building asset account.
EIGHTH PRODUCTION REQUEST
TO AVISTA CORPORATION 3 MAY 5,2023
REQUESTNO.198:As supplement to Production Request No.70,please provide a
supporting worksheet for employee incentives to use their own mobile devices instead of a
Company phone.Please include the amount budgeted and the actual spend by month for the
period July 1,2021 through March 31,2023.
REQUESTNO.199:Please provide a copy of all Avista employee surveys conducted
since January 1,2021,and a summary of the results.
REQUESTNO.200:Please provide a copy of all Customer Surveys conducted by/for
Avista since January 1,2021,and a summary of the results.
REQUESTNO.201:Please provide a list of payments made to Ethisphere from 2021
through March 31,2023,and include the amounts,dates,and accounts charged.
DATED at Boise,Idaho,this 6 day of May 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/avue23.l_avug23.lcbde prod req 8
EIGHTH PRODUCTION REQUEST
TO AVISTA CORPORATION 4 MAY 5,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5th DAY OF MAY 2023,SERVED
THE FOREGOING EIGHTH 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:
[e-mail]
[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:[e-mail] 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:[e-mail] E-MAIL:
bheusinkveld idahoconservation.org
F DIEGO RIVAS
NW ENERGY COALITION
1101 87"AVE
HELENA MT 59601
E-MAIL:[e-mail]
SECRE ARY
CERTIFICATE OF SERVICE