20230316Staff to AVU 1-5.pdf

MICHAEL DUVAL E Û
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 6 5 |
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11714
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 AVISTA'S ANNUAL )RATE ADJUSTMENT FILING FOR ELECTRIC )CASE NO.AVU-E-23-03
LINE EXTENSION SCHEDULE 51 )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Avista Corporation provide the
followingdocuments and information as soon as possible,but no later than THURSDAY,
MARCH 30,2023.1
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.
Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 MARCH 16,2023
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.
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.
REQUESTNO.1:Please provide workpapers in electronic format with links intact and
formulae enabled that support the table of values shown on pages 4 and 5 of the Application.
Please explain how the Company applied the principle of average costing for these calculations.
REQUESTNO.2:Please explain the followingaspects of the Work Order Cost
Estimates provided as pages 35 to 50 of the Application:
a.Please confirm whether these are actual work order costs,or hypothetical
estimates;
b.Please explain how the adjusted total for the first table matches the overall total of
the second table for each work order,given that the first table shows labor,
material,and overhead costs,while the second table lists only material costs;
c.Many of the individual Work Order Cost Estimates include additional worksheet
calculations that divide the total cost by seemingly arbitrary number of units to
calculate a unit cost.Please explain and show how the number of units is
properly associated with the cost of each work order;
d.The Work Order Cost Estimates on pages 40 and 47 include the calculation of a
weighted average for transformer costs.Please explain how the weighting was
determined and provide supporting worksheets;and
e.The unit costs for "OH"transformers are markedly different than the unit costs
for "pad"transformers of the same rating.Please explain why there is a
difference.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MARCH 16,2023
REQUESTNO.3:Please provide Company invoices showing the Company's purchases
of 25 KVA transformers for the past two years,whether "OH"or "pad"or some other type.For
each invoice,please include the vendor name,item description (includingspecified standard),
size,quantity,and price or provide separately if not indicated on the invoices.
REQUESTNO.4:Please provide Company invoices showing the Company's purchases
of 50 KVA transformers for the past two years whether "OH"or "pad"or some other type.For
each invoice,please include the vendor name,item description (includingspecified standard),
size,quantity,and price or provide separately if not indicated on the invoices.
REQUESTNO.5:Please provide Company invoices showing the Company's purchases
of 3-inch Sweep PVC products for the past two years.For each invoice,please include the
vendor name,item description (includingspecified standard),size,quantity,and price or provide
separately if not indicated on the invoices.
DATED at Boise,Idaho,this i day of March 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreq/avue23 3mdjjt prod req l
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 MARCH 16,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF MARCH 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-E-23-03,
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:david.meyer avistacorp.com
[e-mail]
SECRETÀI Y
CERTIFICATE OF SERVICE