20170808Sierra Club 1-1, 1-5 to AVU.pdf

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BEFORE THE IDAHO PUBLTC UTTLTTIES 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
Travis Ritchie
Sierra Club Law Program
2l0l Webster Street, Suite 1300
Oakland, CA946l2
travi [e-mail]
CASE NO. AVU-E-I7-01
AVU-G-17-01
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FIRST SET OF DATA REQUESTS OF SIERRA CLUB TO AVISTA CORPORATION
Sierra Club hereby serves its first set of data requests regarding the above-mentioned docket.
Sierra Club requests that Avista Corporation provide responses as expeditiously as possible, but
not later than the deadline of 21 days, which is Aueust 28.2017.
INSTRUCTIONS
Please provide copies of responses to the following contacts:
Alexa Zimbalist
Sierra Club Law Program
2l0l Webster Street, Suite 1300
Oakland, CA946l2
alexa.zimbalist@sierraclub. org
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Whenever possible, Sierra Club prefers to receive electronic copies of data responses
either by email or on CD.
Responses to any and all of Sierra Club's data requests should be supplied to Sierra Club
as soon as they become available to Avista Corporation.
The requests herein shall be deemed to be continuing in nature and Avista Corporation is
requested to supplement its responses as necessary and as additional information
becomes available.
In responding to each data request, please consult every document source which is in
your possession, custody, or control, including all documents in the possession of experts
or consultants.
For each response, identif,, the person who prepared the answer to the data request as
well as his or her position with Avista Corporation or any Avista Corporation affiliate or
parent.
Please reproduce the data request being responded to before the response.
8 If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
9 If the responses include spreadsheet files, please provide those spreadsheet files in
useable electronic Excel readable format.
10. In responses providing computer files, list the file names with cross-reference to the data
request, and if necessary to the understanding of the data, provide a record layout of the
computer files. Computer files provided with a response must be in or compatible with
the current version, or the immediately prior version, of Microsoft Office.
I l. For each dollar amount provided in response to a discovery request please state if the
amount is in nominal or constant dollars and what years dollars.
sc 1-1.
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 Nos. AVU-E-I 7-01IAVU-G -17 -01
Sierra Club's First Set of Data Requests to Avista Corporation
August 7,2017
DATA REQUESTS
Provide electronic copies ofall data requests and responses received from or sent to other
parties in this proceeding. If electronic copies are not available, please contact counsel for
Sierra Club to coordinate response. This is an ongoing request.
SC l-2. Provide all confidential testimony and exhibits included in Avista's application.
sc 1-3.Reference Exhibit No. 4 (Kinney), Schedule 3 pages 90-91. Section I . I states: "The
current operator provides the annual business plan and capital budgets to the owner group
every September."
a. Provide the annual business plan and capital budgets for the past three years (2015,
2016,2017).
b. Provide the 2018 business plan and capital budget when it is available next month.
c. Provide all "individual project summaries" related to the Colstrip 3&4 Capital
Projects.
sc l-4.Reference Exhibit No. 4 (Kinney), Schedule 3 pages 90-91. Section l.l states: "Avista
reviews these individual projects."
a. Provide all documents, emails, communications, memos, or other internal company
documents related to Avista's review of the Colstrip 3&4 Capital Projects.
b. Describe in detail the review process, including the individuals who are responsible
for review and approval ofthe individual projects.
SC I-5 Reference Exhibit No. 4 (Kinney), Schedule 3 pages 90-91. Section l.l states:
"Ultimately, the business plan is approved in accordance with the Ownership and
Operation Agreement for units 3&4 that six companies are party to."
a. Provide the currently applicable Ownership and Operation Agreement.
b. If different than (a), provide the Ownership and Operation Agreement in effect at the
time the Colstrip 3&4 Capital Projects at issue in Avista's application were approved
by the owners.
c. Describe Avista's understanding of how the decision to include a capital project in
the business plan works in practice.
d. Did Avista raise any concerns or vote "no" on the Colstrip 3&4 Capital Projects at
issue in this application? If so, please provide any record of those objections or
concerns.
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 Nos. AVU-E-I 7-0llAVU-G-l 7-01
Sierra Club's First Set of Data Requests to Avista Corporation
August 7,2017
e. Did any other Colstrip owner raise any concerns of vote "no" on the Colstrip 3&4
Capital Projects at issue in this application? If so, please provide any record of those
objections or concerns.
f. Has Avista ever voted "no" or otherwise not approved an individual capital project?
If so, please describe when such a vote occurred and whether the capital project was
ultimately included in the business plan.
CERTIFICATE OF SERVICE
I hereby certify that on this 7th day of Augu st 2017 , I delivered true and correct copies of
the fbregoing FIRST SET OF DATA REQUESTS OF SIERRA CLUB TO AVISTA
CORPORATION to the following persons via electronic mail:
David J. Meyer
Vice President & Chief Counsel, Reg. & Gov't
Affairs
Avista Corporation
PO Box 3727
l4l I East Mission Avenue
Spokane, WA99220-3727
david. meyer@avistacorp. com
Kelly Norwood
Vice President - State & Federal Regulation
Avista Utilities
POBox3727
l4l I East Mission Avenue
Spokane, WA99220-3727
kelly.norwood@avi stacorp. com
Peter J. Richardson
Gregory M. Adams
Richardson Adams PLLC
515 N. 27th Street
P0 Box 7218
Boise. ID 83702
peter@richardsonadams. com
gr e g@r ichards on adam s. c om
carol. hauge n@clearw aterpaper. com
[e-mail]
j ohn j ac ob s @clearw aterpaper. com
davi d. wrn@ c I earwaterpap er. com
nathan. smith@clearw aterpaper. com
Matthew A. Nykiel
Idaho Conservation League
PO Box 2308
102 S. Euclid #207
Sandpoint, ID 83864
mnykiel@idahoconservation. org
Dean J. Miller
36208 Warm Springs Ave.
Boise, ID 83716
deanj [e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
dreading@mindspring. com
Brad M. Purdy
Attornev at Law
2019 N. lTth Street
Boise, lD 83702
[e-mail]
Ronald L. Williams
Williams Bradbury, P.C.
PO Box 338
Boise, ID 83701
ron@williamsbradbury. com
Larry A. Crowley, Director
The Energy Strategies Institute, Inc.
5549 S. Cliffsedge Ave.
Boise, ID 83716
[e-mail]
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
diane.holt@puc. idaho, gov
/s/ Alexa Zimbalist
Alexa Zimbalist
Legal Assistant
Sierra Club Environmental Law Program
2l0l Webster St., Suite 1300
Oakland, CA94612
Phone: [phone]