20141121Staff 1-3 to AVU.pdf

KARL T. KLErN Il I c I I \,/ a: r ]
DEPUTY ATTORNEY GENERAL
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PO BOX 83720 tiji,l,BOISE,IDAHO g3720-0074 ,111-';;:;,i1-;'; -,,.. .,.:5,,,,,;;,
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA CORPORATION )
DBA AVTSTA UTTLITIES'2014 NATURAL GAS ) CASE NO. AVU-G-14-03
INTEGRATED RESOURCE PLAN )) nmsr PRoDUCTToN) nreuEST oF THE) COvTMISSION STAFF To
) AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Karl T. Klein, Deputy Attorney General, requests that Avista Corporation (Company) provide
the following documents and information as soon as possible, by FRIDAY, DECEMBER 5,
2014.r
This Production Request is to be considered as continuing, and the Company 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 telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attomey at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION I NOVEMBER 2I,2OI4
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. l: Please provide the incremental added capacity for each project
shown in Table 7 .2. See 2014 Natural Gas IRP at I 3 I .
REQUEST NO.2: Please provide the avoided cost calculations the Company used to
determine that natural gas demand-side management is not cost-effective for Idaho. Please
provide and explain the assumptions used.
REQUEST NO. 3: Did the Company assume any avoided distribution, transportation or
storage related costs in its avoided-cost calculation? Please explain why or why not.
DATED at Boise, Idaho, this 2 l)aduy of Novemb er 2014.
Karl T. Klein
Deputy Attorney General
Technical Staff: Nikki Karpavich
i:umisc:prodreq/avugl4.3kknk prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION NOVEMBER2I,2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2IST DAY oF NoVEMBER 2014,
SERVED THE FOREGOING I'IRST PRODUCTION REQUEST OF THE
C0MMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G-14-03,
BY E.MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: linda. [e-mail]
DAVID J MEYER
VP & CHIEF COI.INSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE W A 99220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE