20230817Staff 1-7 to Avista.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
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
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE POWER COST )ADJUSTMENT (PCA)ANNUAL RATE )CASE NO.AVU-E-23-08
ADJUSTMENT FILING OF AVISTA )COPRORATION )
)FIRST PRODUCTION
)REQUESTOF THE
)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 AVISTA CORPORATION ("Company")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY SEPTEMBER 7,2023.
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 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
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 AUGUST 17,2023
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:Regarding the Company's confidential response to Audit Request
No.3,please provide invoices,journal transaction,or supporting documentation for each sample
selected in the confidential spreadsheet attached to these discovery requests.
REQUESTNO.2:Please provide the followingin Excel format with all formulas
mtact:
a.Actual monthlymega-watt hours ("MWhs")and costs for Avista's generation
resources and purchases from July 1,2022,through June 30,2023;
b.Authorized monthlyMWhs and costs for Avista's generationresources and
purchases from July 1,2022,through June 30,2023;
c.Actual monthlyMWhs and revenues for Avista's sale transactions from July 1,
2022,through June 30,2023;and
d.Authorized monthlyMWhs and revenues for Avista's sale transactions from July
1,2022,through June 30,2023.
REQUESTNO.3:Does the Company include kilowatt-hours ("kWh")generated and
consumed for all on-site customer-generators in the PCA?If so,please provide the impact to the
2022-2023 PCA,if removed.
REQUESTNO.4:Please quantifythe monthlysales and purchases between the
Company and Clearwater Paper Corporation in dollars and MWhs from July 1,2022,through
June 30,2023.
REQUESTNO.5:Please explain the Company's acceleration toward dispatching
natural gas fueled generationin late 2022 (i.e.,Sept.,Oct.,Nov.,and Dec.)compared to the
amount of coal-fired generation considering the higher dispatch cost of natural gas generation
relative to coal generation during this period.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 17,2023
REQUESTNO.6:Please explain why the Company had a ($5,464,169)expense for
"CT Fuel"in January 2023.See Schultz Workpapers 2.xlsx,tab "Act-Auth-Proposed".Please
provide a detailed description of the circumstances that led to the expense.
REQUESTNO.7:Please explain the $120,073 expense for the EIM in March 2023.See
Schultz Workpapers 2.xlsx,tab "Act-Auth-Proposed".Please provide a detailed description of
the circumstances that led to the expense and supporting documentation.
DATED at Boise,Idaho,this day of August 2023.
Deputy AttorneyGeneral
i:umisc:prodreq/avue23.8 prod req 1
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUGUST 17,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF AUGUST 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION
STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-E-23-08,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:patrick.ehrbar avistacorp.com E-mail:[e-mail]
avistadockets avistaco .com
SECRE ARY
CERTIFICATE OF SERVICE