20230721Staff 1-8 to AVU.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL .ogIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10221
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 AVISTA CORPORATION FOR AN )CASE NO.AVU-E-23-06
ACCOUNTING ORDER AUTHORIZING )DEFERRAL OF CERTAIN COSTS )FIRST PRODUCTIONASSOCIATEDWITHTHEMONTANA)REQUESTOF THE
RIVERBEND LEASE AGREEMENT )COMMISSION STAFF
)TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than FRIDAY,AUGUST 4,2023.'
This Production Request is to be considered as continuing,and the Company 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 workpapersthat provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber of
'Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0312.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION l JULY 21,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber 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.1:Please provide the documents,statements and other workpapers,
with all formulas intact and enabled,includingsource documents,used to calculate the total due
of $28,288,773.72 stated on page two of Attachment A of the Application.
REQUESTNO.2:Please provide the documents,statements and other workpapers,
with all formulas intact and enabled,including source documents,that support the escrow
account ending balance of $24,522,420.49 as stated on page one of Attachment A of the
Application.
REQUESTNO.3:Please provide the interest rates required under the escrow
agreement as described on page six of the Application (i.e.,the "rate of return of the united
investment program").
REQUESTNO 4:Please provide the interest rate on the escrow account by year for
each year of its existence.
REQUESTNO.5:Please provide the Company's rationale for the carrying charge
mentioned on page 2 of the Application.
REQUESTNO 6:Please provide the Company's cost-benefit analysis for placing the
lease payments into escrow when the escrow account was established.Please include
workpapers,with all formulas intact and enabled.
REQUESTNO.7:Please provide and describe the calculations used to generate the
CPI index appearingon page seven of the Application for each year listed.Please include
workpapers,with all formulas intact and enabled.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 JULY 21,2023
REQUESTNO.8:Please provide supporting documentation for all the actual annual
lease payments made to the state of Montana.
DATED at Boise,Idaho,this g/g day of July 2023.
Adam Triplett
Deputy AttorneyGeneral
i:umisc:prodreq/avue23.06atlg prod req l
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 JULY 21,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF JULY 2023,SERVED
THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION TO
AVISTA CORPORATION,IN CASE NO.AVU-E-23-06,BY E-MAILING A COPYTHEREOFTOTHEFOLLOWING:
PATRICK EHRBAR DAVID J MEYERDIROFREGULATORYAFFAIRSVP&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]
SECRETARY
CERTIFICATE OF SERVICE