20170911Sierra Club 3-1-3, 3-13 to Avista - Redacted.pdf

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SIERRA
CLUB
Via FedEx
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
diane.holt@puc. idaho. gov
September 8,2017
Re: Case No. AVU-E-17-01/AW-G-17-01: Third Set of Data Requests of Sierra Club to
Avista Corporation [CONFIDENTIAL]
Dear Ms. Hanian,
Please find enclosed the original and seven (7) copies of the Third Set of Data Requests of Sierra
Club to Avista Corporation ICONFIDENTIAL] in Case No. AVU-E-17-01/AVU-G-17-01.
Please do not hesitate to contact me if you have any questions or need other materials. Thank
you.
Sincerely,
/s/ Alexa Zimbalist
Alexa Zimbalist
Legal Assistant
Sierra Club Environmental Law Program
2l0l Webster Street, Suite 1300
Oakland, CA94612
Phone: [phone]
alexa.zimbal [e-mail]
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
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CASE NO. AVU-E-17-01
AVU-G-17-01

REDACTED THIRD SET OF DATA REQUESTS OF SIERRA CLUB TO AVISTA
CORPORATION

Sierra Club hereby serves its REDACTED third 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 September 29,
2017.

INSTRUCTIONS
1. Please provide copies of responses to the following contacts:
Travis Ritchie
Sierra Club Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]

Alexa Zimbalist
Sierra Club Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]

2. Whenever possible, Sierra Club prefers to receive electronic copies of data responses
either by email or on CD.
3. 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.
4. 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.
5. 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.
6. For each response, identify 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.
7. 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.
11. 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 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-17-01/AVU-G-17-01
Sierra Club’s Third Set of Data Requests to Avista Corporation
September 8, 2017

DATA REQUESTS

SC 3-1. Please identify and itemize the "Pollution Control Taxes" referenced in the document
"SC_PR_1-3C Confidential Attachment C - 2017 Business Plan.pdf", provided in
response to Sierra Club Data Request 1-3.

SC 3-2. Please describe Avista corporation's current expectations regarding future greenhouse gas
regulations, emissions restrictions, and/or pricing for resource planning purposes. Please
provide any available supporting documentation such as board presentations, board
minutes, financial statements, or white papers describing these expectations.

SC 3-3. What is the status of Avista's "cost/benefit analysis associated with joining the CAISO
EIM" described on Page 6-6 of its 2017 IRP? Please provide this analysis and supporting
workpapers if and when available.

SC 3-4. In Appendix G of Avista's 2017 IRP, the company estimates integration costs for
Montana wind as $4.40/kW-yr.
a. Please confirm that these are the intended units for this assumption. If not, please
identify the correct units.
b. Please provide underlying workpapers, analysis, or references supporting this
assumption.

SC 3-5. Please provide any analyses of the price, availability, technical feasibility, and integration
costs associated with using Montana wind resources to serve Avista's electricity
customers prepared by or for Avista, or relied upon by the company in developing its
resource plans.

SC 3-6. Reference Avista’s response to SC 1-3, Confidential Attachment E, page 33 of 38.

a. What is the construction and operation status of
(“Project ID 10022111”)? If it has not been completed, when (month and year) does
Avista anticipate it will be completed?
b. Please provide the dollar amount, if any, from Project ID 10022111 that Avista
included in its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10022111 was or will be “used and
useful”?
d. The project description states:

What is the status of the “
” referenced in this project authorization?
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-17-01/AVU-G-17-01
Sierra Club’s Third Set of Data Requests to Avista Corporation
September 8, 2017

e. On what date did the “” referenced by this document
come into effect? If that date has not yet occurred, what date does Avista anticipate
they will come into effect?
f. Please provide all memos, reports, emails, or other documents prepared by, reviewed
by, or made available to Avista that support the conclusion that “

g. Please provide all memos, reports, emails, or other documents prepared by, reviewed
by, or made available to Avista between 2015 and today that discuss any changes to the
referenced
and/or the referenced
h. Please provide a narrative description of what Avista understands its regulatory
obligations are today that necessitate the installation of Project ID 10022111, including
but not limited to compliance deadlines and applicable emissions limits.

SC 3-7. Reference Avista’s response to SC 1-3, Confidential Attachment G, page 50 of 74.

a. What is the construction and operation status of the
(“Project ID 10023705”)? If it has not been completed, when (month and year) does
Avista anticipate it will be completed?
b. Please provide the dollar amount, if any, from Project ID 10023705 that Avista
included in its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10023705 was or will be “used and
useful”?
d. Please provide a narrative description of what Avista understands its regulatory
obligations are today that necessitate the installation of Project ID 10023705, including
but not limited to compliance deadlines and applicable emissions limits.
e. Please provide all memos, reports, emails, or other documents prepared by, reviewed
by, or made available to Avista that support the conclusion that any regulation, statute,
or other requirement requires the installation of Project ID 10023705.

SC 3-8. Reference Avista’s response to SC 1-3, Confidential Attachment G, page 48 of 74.

a. What is the construction and operation status of the
(“Project ID 10023703”)? If it has not been completed, when (month and year) does
Avista anticipate it will be completed?
b. Please provide the dollar amount, if any, from Project ID 10023703 that Avista
included in its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10023703 was or will be “used and
useful”?
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-17-01/AVU-G-17-01
Sierra Club’s Third Set of Data Requests to Avista Corporation
September 8, 2017

d. Does Avista anticipate that Project ID 10023703 has or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not?
e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?

SC 3-9. Reference Avista’s response to SC 1-3, Confidential Attachment G, page 43 of 74.

a. What is the construction and operation status of the
(“Project ID 10022113”)? If it has not been completed, when (month and year) does
Avista anticipate it will be completed?
b. Please provide the dollar amount, if any, from Project ID 10022113 that Avista
included in its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10022113 was or will be “used and
useful”?
d. Does Avista anticipate that Project ID 10022113 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not?
e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?

SC 3-10. Reference Avista’s response to SC 1-3, Confidential Attachment G, page 2 of 74.

a. What is the construction and operation status of the
(“Project ID 10019068”)? If it has not been completed, when (month and year) does
Avista anticipate it will be completed?
b. Please provide the dollar amount, if any, from Project ID 10019068 that Avista
included in its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10019068 was or will be “used and
useful”?
d. Does Avista anticipate that Project ID 10019068 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not?
e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?

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-17-01/AVU-G-17-01
Sierra Club’s Third Set of Data Requests to Avista Corporation
September 8, 2017

SC 3-11. Reference Avista’s response to SC 1-3, Confidential Attachment G, page 3 of 74.

a. What is the construction and operation status of the
(“Project ID 10019069”)? If it has not been completed, when (month and year) does
Avista anticipate it will be completed?
b. Please provide the dollar amount, if any, from Project ID 10019069 that Avista
included in its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10019069 was or will be “used and
useful”?
d. Does Avista anticipate that Project ID 10019069 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not?
e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?

SC 3-12. Reference Avista’s response to SC 1-3, Confidential Attachment G, page 6 of 74.

a. What is the construction and operation status of the
(“Project ID 10022077”)? If it has not been completed, when (month and year) does
Avista anticipate it will be completed?
b. Please provide the dollar amount, if any, from Project ID 10022077 that Avista
included in its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10022077 was or will be “used and
useful”?
d. Does Avista anticipate that Project ID 10022077 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not?
e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?

SC 3-13. Reference Avista’s response to SC 1-3, Confidential Attachment G, page 7 of 74.

a. What is the construction and operation status of the
(“Project ID 10022078”)? If it has not been completed, when (month and year) does
Avista anticipate it will be completed?
b. Please provide the dollar amount, if any, from Project ID 10022078 that Avista
included in its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10022078 was or will be “used and
useful”?
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-17-01/AVU-G-17-01
Sierra Club’s Third Set of Data Requests to Avista Corporation
September 8, 2017

d. Does Avista anticipate that Project ID 10022078 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not?
e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?

CERTIFICATE OF SERVICE

I hereby certify that on this 8th day of September 2017, I delivered true and correct
copies of the foregoing THIRD SET OF DATA REQUESTS OF SIERRA CLUB TO AVISTA
CORPORATION to the following persons via electronic mail. A true and correct copy of the
confidential version has been served via FedEx or U.S. Mail to those persons who have signed the
protective agreement.

David J. Meyer (C)
Vice President & Chief Counsel, Reg. & Gov't
Affairs
Avista Corporation
PO Box 3727
1411 East Mission Avenue
Spokane, WA 99220-3727
[e-mail]

Kelly Norwood (C)
Vice President - State & Federal Regulation
Avista Utilities
PO Box 3727
1411 East Mission Avenue
Spokane, WA 99220-3727
[e-mail]

Peter J. Richardson
Gregory M. Adams
Richardson Adams PLLC
515 N. 27th Street
P0 Box 7218
Boise. ID 83702
[e-mail]
[e-mail]

Dr. Don Reading
6070 Hill Road
Boise, ID 83703
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
[e-mail]
Matthew A. Nykiel
Idaho Conservation League
PO Box 2308
102 S. Euclid #207
Sandpoint, ID 83864
[e-mail]

Ronald L. Williams
Williams Bradbury, P.C.
PO Box 338
Boise, ID 83701
[e-mail]
Dean J. Miller
3620 E Warm Springs Ave.
Boise, ID 83716
[e-mail]
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
[e-mail]

/s/ Alexa Zimbalist
Alexa Zimbalist
Legal Assistant
Sierra Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA 94612
Phone: [phone]