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Home My WebLink About20180523Sierra Club 1-8 to Avista.pdfRECEIVED BEFORE rHE IDAHO PUBLIC UTILITIES COMMISSION ?ill8 H$'{ 23 Pll lz 29 if i.., i._. i,,jBLiCj'i.: i i :r'; (lCi,tl,4lSSl0N IN THE MATTER OF AVISTA CORPORATION'S APPLICATION TO CHANGE ITS ELECTRIC AND NATURAL GAS DEPRECIATION RATES Travis Ritchie Sierra Club Law Program 2101 Webster Street, Suite 1300 Oakland, CA94612 travis. ritchie@sienaclub. org CASE NO. AW-E-I8-03 AVU-G-18-02 ) ) ) ) ) ) ) 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-@!!;!!l& INSTRUCTIONS Please provide copies of responses to the following contacts Ana Boyd Sierra Club Law Program 2l0l Webster Street, Suite 1300 Oakland, CA94612 ana.boyd@sierraclub. org 2 aJ 4. 5 6. 7 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. I 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 ifnecessary to the understanding ofthe data, provide a record layout ofthe 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 dollar SC 1.I In the Matter of Avista Corporation's Application to Change its Electric and Natural Gas Depreciation Rates Case Nos. AVU-E-18-03/AVU-G-1 8-02 Sierra Club's First Set of Data Requests to Avista Corporation May 23, 2018 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 I-3 When does the currently applicable coal supply agreement for Colstrip Units 3 and 4 terminate? Provide a narrative description of the status of any negotiations or discussions regarding the extension of any currently applicable coal supply contract(s) for Colstrip Units 3 and 4. Provide any documents prepared by or for Avista summarizing these negotiations or discussions SC I-4 By what date does Avista and/or the Rosebud mine owner expect that the Rosebud mine's currently permitted coal reserves will be exhausted? SC I.5 Does Avista anticipate that all of the currently permitted coal supply at the Rosebud mine will be economically feasible to extract? If not, when does Avista expect the currently permitted coal reserve to become uneconomic for use at Colstrip Units 3 and 4? Please explain who bears the risk (i.e. Avista or Westmoreland) for any potential increase in coal extraction costs in the event the mine's permitted reserves become more expensive to extract. SC I-6 Provide Avista's understanding of the status of any efforts by the Rosebud mine owner to obtain permits to expand the Rosebud mine. Please provide a narrative description of the impact on available coal supply of any such efforts and the expected timing of any required development. Provide any documents prepared by or for Avista summarizing these permitting and/or expansion efforts. sc 1-7.Please describe how a bankruptcy by Westmoreland Coal Company could impact the coal supply to Colstrip Units 3 and 4. Provide any documents prepared by or for Avista that address any contingency plans in the event of a Westmoreland Coal Company bankruptcy. SC I-8 Has Avista or any of the Colstrip Unit 3 and 4 co-owners explored the potential of Colstrip Units 3 and 4 to receive coal from a supplier other than the Rosebud mine? If yes, please describe the cost and feasibility of such alternative supplies. Provide any documents prepared by or for Avista addressing such potential alternative coal supplies. CERTIFICATE OF SERVICE I hereby certify that on this 23'd day of May 2018, I delivered true and correct copies of the foregoing FIRST SET OF DATA REQUESTS OF SIERRA CLUB TO AVISTA CORPORATION to the following persons via electronic mail: David J. Meyer Patrick Ehrbar Avista Corporation PO Box3727 1411 East Mission Avenue Spokane, WA99220-3727 david. meyer@avistacorp. com P atri ck. ehrb ar @av istacorp. com Avi staDockets@avistacorp. com Diane Hanian Commission Secretary Idaho Public Utilities Commission 427 W. Washington St. Boise, ID 83702-5983 diane.holt@puc.idaho. gov Dean J. Miller 3620 8 Warm Springs Ave. Boise, ID 83716 deanj miller@cableone.net Peter J. Richardson Gregory M. Adams Richardson Adams PLLC 5 l5 N. 27th Street Boise. lD 83702 p eter @r ichardsonadams. com Brandon Karpen Deputy AttorneyGeneral Idaho Public Utilities Commission 472 w . Washington (837 02) PO Box 83720 Boise, ID 83720-0074 brandon.karpen@puc. idaho. gov Benjarnin I. Otto Idaho Conservation League 710 N. 6tr'St. Boise, ldaho 83702 botto@idahoconservation. org 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. crowlevla@aol.com Dr. Don Reading 6070 Hill Road Boise, ID 83703 dreading@mindspring. com carol. hau ge n@cle arw aterpaper. com marv. lewallen@clearwaterpaper. com /s/ Ana Boyd Ana Boyd Legal Assistant Sierra Club Environmental Law Program 2101 Webster St., Suite 1300 Oakland, CA94612 Phone: (415)977-5649 ana.b oy d@si errac lub. org