20121113Staff 48-57 to Avista.pdf

KARL T. KLEIN
WELDON B. STUTZMAN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0318
IDAHO BAR NOS. 5 156/3283
RECEIVED
21112 NOV 13 PM 2:57
iotiiO 0 pi UTILITIES (>JMMtS
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
ELECTRIC AND NATURAL GAS SERVICE
IN IDAHO.
CASE NO. AVU-E-12-08
AVU-G-12-07
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities requests that Avista Corporation (Company;
Avista) provide the following documents and information as soon as possible, by TUESDAY,
DECEMBER 4, 2012.
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 produced.
Please provide answers to each question, including supporting workpapers that provide
detail or are the source of information used in calculations. The Company is reminded that
responses pursuant to Commission Rules of Procedure must include the name and phone number
of the person preparing the document, and the name, location and phone number of the record
THIRD PRODUCTION REQUEST
TO AVISTA 1 NOVEMBER 13, 2012
holder and if different the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 48: Please explain why "Intangible Plant Costs" (Tara Knox Di, line 1,
Schedule 1, p. 3) are included in the $585,254 Production and Transmission Cost used in the
calculation of the LCAR. Please provide a detailed description of each cost within the
"Intangible Plant Cost" category that was included and a justification for each.
REQUEST NO. 49: Please describe the Production/Transmission-Franchise/Misc.
Intangible Costs (LCAR-10 in Tara Knox LCAR Workpapers) included in the Accumulated
Depreciation and Amortization used to calculate the LCAR.
REQUEST NO. 50: Please identify the cause(s) of Kettle Falls' forced outages in 2007-
2011. For each year, please identify the number of hours associated with each cause. Please also
state whether Avista expects each cause to be a recurring cause or a one-time only occurance.
REQUEST NO. 51: Please explain whether Avista used the correct formula to calculate
the forced outage % for Kettle Falls (cells C29:026 in the "Forced Outage" worksheet in "Kettle
Falls FO Rate Final.xls). If Avista believes it used the correct formula, please explain why the
formula is correct.
REQUEST NO. 52: Please explain why Avista used a six-year average for maintenance
for the Coistrip units ("Coistrip Maintenance Final.xls) while using a five-year average for all
other units.
REQUEST NO. 53: Please provide work papers supporting the calculation of the forced
outage rate for Boulder Park. If using historical figures, please identify the cause(s) of Boulder
Park's forced outages during the pertinent time period. For each year, please identify the number
THIRD PRODUCTION REQUEST
TO AVISTA 2 NOVEMBER 13, 2012
of hours associated with each cause. Please also state whether Avista expects each cause to be a
recurring cause or a one-time only occurrence.
REQUEST NO. 54: Please explain the forced outage rate used for: Coyote Springs 2,
Kettle Falls CT, Northeast A & B, Lancaster, Rathdrum 1 and 2.
REQUEST NO. 55: Please identify the cause(s) of Colstrip 3 and Coistrip 4's forced
outages in 2007-2011. For each year, please identify the number of hours associated with each
cause. Please also state whether Avista expects each cause to be a recurring cause or a one-time
only occurrence.
REQUEST NO. 56: In calculating the capacity factor for wind projects in the Excel
workbook "Wind.xls," it appears that Avista is using a nameplate capacity of 108 MW for the
Kittitas Valley Wind project. Please verify that this is true. Please provide the source for this
capacity number and explain why it differs from the nameplate capacity listed for this project in
the following BPA publication:
http://transmission.bpa.gov/Business/Operations/WindJWIND_InstalledCapacity_CHART.pdf
REQUEST NO. 57: Please provide all supporting analyses used to develop the
Company's pipeline replacement program described on pages 7-10 of Kopczynski's testimony.
Dated at Boise, Idaho, this / day of November 2012.
J/ f
Karl T. Klein
Deputy Attorney General
Technical Staff: Mike Louis/48-49
Cathleen McHughl50-56
Matt Elam/57
i:umisc:prodreq/avue 12.8 avugi 2.7kkmlcmme prod req3
THIRD PRODUCTION REQUEST
TO AVISTA 3 NOVEMBER 13, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF NOVEMBER 2012,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-12-08
& AVU-G-12-07, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
P0 BOX 2564
BOISE ID 83702
E-MAIL: [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
515 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
greg(richardsonando1eary.com
KELLY 0 NOR WOOD
VP STATE & FED REG
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
LARRY A CR0 WLEY
THE ENERGY STRATEGIES
INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 83716
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(mindspring.com
ELECTRONIC SERVICE ONLY:
Howard Ray
Clearwater Paper Corporation
[e-mail]
SECRET'RY
CERTIFICATE OF SERVICE