20170808Sierra Club 2-1, 2-5 to AVU.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION , . ,1 . . T
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
2101 Webster Street, Suite 1300
Oakland, CA94612
travis.ritchie@sierraclub. org
CASE NO. AVU-E-17-OI
AVU-G-17-01
SECOND SET OF DATA REQUESTS OF SIERRA CLUB TO AVISTA CORPORATION
Sierra Club hereby serves its second 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 29.2017.
INSTRUCTIONS
Please provide copies of responses to the following contacts:
Alexa Zimbalist
Sierra Club Law Program
2l0l Webster Street, Suite 1300
Oakland, CA946l2
[e-mail]
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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, identifu 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.
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If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
If the responses include spreadsheet files, please provide those spreadsheet files in
useable electronic Excel readable format.
10. [n 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.
In the Maffer 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 Second Set of Data Requests to Avista Corporation
August 8,2017
DATA REQUESTS
sc 2-1.Please provide the AURORA-model projected annual energy production and capacity
factors for Colstrip Units 3 and 4 for each scenario modeled in Avista's 2017,2013,
2015, and2017 Integrated Resource Plans (IRPs). Please provide these projections in a
machine-readable format such as a Microsoft Excel workbook.
sc2-2.Please provide the actual annual capacity factors for Colstrip Units 3 and 4 for the years
201I through20lT (to date). Please provide these projections in a machine-readable
format such as a Microsoft Excel workbook.
SC 2-3 Please provide Avista's annual usage, in MWh, of the output of Colstrip Units 3 and 4
from 201I through 2017 (to date.) Please provide these projections in a machine-readable
format such as a Microsoft Excel workbook.
SC2-4 Please provide Avista's marginal and levelized per-MWh cost for output from Colstrip
Units 3 and 4 by year for the years 2011 - 2017. Please provide Avista's projected
marginal and levelized per-MWh cost for output from Colstrip Units 3 and 4 for 2018
and2019.
SC 2-5 Please provide Avista's most recent (2013) depreciation study, along with documents and
workpapers supporting the depreciable plant balances as of December 31, 201 1, as
referenced in the testimony of Karen Schuh, p.l0 at 16.
CERTIFICATE OF SERVICE
I hereby certify that on this 8th day of August 2017 ,I delivered true and correct copies of
the fbregoing SECOND 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
1411 East Mission Avenue
Spokane, WA99220-3727
david.meyer@avistacorp. com
Peter J. Richardson
Gregory M. Adams
Richardson Adams PLLC
515 N. 27th Street
P0 Box 7218
Boise. ID 83702
peter@richardsonadams. com
greg@richardsonadams. com
carol. hauge n@clearw aterpaper. com
[e-mail]
j ohn j acobs @clearw aterpaper. com
david. wrn@ c I earwaterpaper. 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 miller@cableone. net
Kelly Norwood
Vice President - State & Federal Regulation
Avista Utilities
POBox3727
1411 East Mission Avenue
Spokane, WA99220-3727
kelly.norwood@avistacorp. com
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreading@mindsprin g. com
Brad M. Purdy
Attornev at Law
2019 N. lTth Street
Boise, ID 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, tD 83702-5983
[e-mail]. gov
/s/ Alexa Zimbalist
Alexa Zimbalist
Legal Assistant
Sierra Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA94612
Phone: [phone]