20230427Staff 1-7 to AVU.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION -C |
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-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.AVU-E-23-02
OF AVISTA CORPORATION,D/BIA AVISTA )AVU-G-23-02UTILITIES,REQUESTINGAUTHORITY TO )REVISE ITS ELECTRIC AND NATURAL )FIRST PRODUCTION
GAS BOOK DEPRECIATION RATES AND )REQUESTOF THE
AUTHORIZE DEFERRED ACCOUNT )COMMISSION STAFFTREATMENTFORDIFFERENCEIN)TO AVISTA CORPORATION
DEPRECIATION EXPENSE )
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 THURSDAY,MAY 18,2023.
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
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION l APRIL 27,2023
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.1:Please explain the circumstances that caused a significant increase in
the cost of asset removal between the years 2013 and 2016,for accounts 356,and 361 through
370.
REQUESTNO.2:Please provide all audit and/or data request questions issued by
parties in other states along with the Company's response for any Company filed depreciation
case relating to the 2021 Gannett Fleming Depreciation Study.This should include confidential
questions and responses.Please consider this an ongoing request.
REQUESTNO.3:In the 2021 Depreciation Study,PART I,page 2,please provide all
documentationused by the consultant in reference to:(1)the Company's practice and outlook
relating to plant operation and retirement,and (2)the current practice in the electric and gas
industry,including knowledge of service lives and net salvage estimates used for other electric
and gas companies.
REQUESTNO.4:Please provide all correspondence between Gannett Fleming and
Avista as it pertains to the 2021 Depreciation Study.This includes all informational requests
from Gannett Fleming to Avista and the responses from Avista to Gannett Fleming.
REQUESTNO.5:For each FERC account studied in the 2021 Depreciation Study,
please identify and explain all adjustments Gannett Fleming made to Avista's accounting data
prior to conducting the service life and net salvage analyses presented in Parts VII,VIII,and IX
of the depreciation study.
REQUESTNO.6:For each FERC account studied in the 2021 Depreciation Study,
please provide the results of any additional useful life analyses conducted.These analyses would
be those conducted on original life tables that have experience and placement bands that differ
from those presented in the depreciation study.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 APRIL 27,2023
REQUESTNO.7:Please provide copies of all GannettFleming field notes compiled
for field trips referenced in PART III,pages 2 and 3 of the 2021 GannettFleming Depreciation
Study.
DATED at Boise,Idaho,this day of April 2023.
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/avue23.2_avug23.2cbtj prod req l
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 APRIL 27,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27'"DAY OF APRIL 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NOS.AVU-E-23-02/AVU-G-23-02,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYERDIROFREGULATORYAFFAIRSVP&CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727E-mail:[e-mail] E-mail:[e-mail]
[e-mail]
SECRE ARY
CERTIFICATEOF SERVICE