20181002Staff 50-59 to Avista.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
RECEIVED
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UISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
CHANGE ITS ELECTRIC AND NATURAL
GAS DEPRECIATION RATES
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, by
TUESDAY, OCTOBER 23, 2018.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.0r.0r.228.
THIRD PRODUCTION REQUEST
TO AVISTA
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CASE NO. AVU.E-18.03
AVU-G-18-02
1 OCTOBER 2,2018
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 50: In the Company's 2017 IRP filing, information was provided to
Staff about planned base capital expenses at Colstrip Units 3 and 4. (Avista's Confidential
Response to Stafls Production Request No. 3 in Case No. AVU-E-17-08). Staff observes that
the level of base capital expenses increases significantly in2019,2020,2022, and2023. Other
notable increases occur in2025,2026,2028, and2029. Please explain the increased expenses in
these years.
REQUEST NO. 51: In reference to the Kettle Falls Station plant, the depreciation study
proposes a Net Salvage of -4oh for Account 315.0 (Accessory Electric Equipment) instead of the
currently approved Net Salvag e of 0o/o. The analysis provided on pages VIII- 1 3 and VIII- 1 4 of
the Gannett Fleming study indicates an historical 30-year average Net Salvage of -lo/o, and a
five-year average Net Salvage of -3o/o. Please provide justification for using a Net Salvage
of -4%o.
REQUEST NO. 52: In reference to Colstrip Unit 3, the depreciation study proposes a
Net Salvage of -6Yo for Account 315.0 (Accessory Electric Equipment) instead of the currently
approved Net Salvage of 0o/o. The analysis provided on pages VIII-13 and VIII-14 of the
Gannett Fleming study indicates an historical 30-year average Net Salvage of -lYo, and a five-
year average Net Salvage of -3o/o. Please provide justification for using a Net Salvage of -60/o.
REQUEST NO. 53: In reference to Colstrip Unit 4,the depreciation study proposes a
Net Salvage of -7o/o for Account 315.0 (Accessory Electric Equipment) instead of the currently
approved Net Salvage of |Yo. The analysis provided on pages VIII-I3 and VIII-I4 of the
Gannett Fleming study indicates an historical 30-year average Net Salvage of -1o/o, and a five-
year average Net Salvage of -3Yo. Please provide justification for using a Net Salvage of -7o/o.
REQUEST NO. 54: In reference to the calculation of the Net Salvage for Account 331
(Structures and Improvements) on pages VIII- 17 and VIII- 1 8 of the Gannett Fleming study,
THIRD PRODUCTION REQUEST
TO AVISTA 2 OCTOBER 2,2018
please provide a detailed description of the retirements that occurredin2014 and 2015. Please
also describe the removal costs incurred associated with these retirements that totaled 1060/o and
343% of the retirements, respectively.
REQUEST NO. 55: In reference to the calculation of the Net Salvage for Account332
(Reservoirs, Dams and Waterways) on pages VIII-20 and VIII-2l of the Gannett Fleming study,
please provide a detailed description of the retirements that occurred in2014. Please also
describe the removal costs incurred associated with these retirements that totaled 213% of the
retirement.
REQUEST NO. 56: In reference to the calculation of the Net Salvage for Account 335
(Miscellaneous Power Plant Equipment) on pages yIlI-26 andYIIl-27 of the Gannett Fleming
study, please provide a description of the $l I1,920 removal costs incurred in 2016.
REQUEST NO. 57: Given that the removal costs for 2016 referenced in the previous
question make up 87.24oh of the removal costs incurred in the previous 30 years combined, and
that the 3O-year average of Net Salvage for Account 335 is -llyo, please explain why the
proposed Net Salvage of -l6oh for Account 335 for the Cabinet Gorge plant is appropriate.
REQUEST NO. 58: The settlement stipulation filed with the Oregon Public Utilities
Commission identifies an increase in Net Salvage for common plant in Accounts 392 and396.
Please provide the impact to Idaho natural gas depreciation rates and depreciation expense if the
Net Salvage in those accounts were changed to match the agreement in Oregon.
REQUEST NO. 59: Referring to the Northeast Turbine plant, please provide a narrative
explaining in detail the rationale for increasing the depreciation rate from 1 .64%o to 30.78%.
Please provide any documentation supporting this increase.
THIRD PRODUCTION REQUEST
TO AVISTA aJ OCTOBER 2,2018
JDated at Boise, Idaho, this li dav of October 2018.
u/tL€,('. Brandon Karpen
Deputy Attorney General
i:umisc:prodreq/avuel8.3_avugl E.2bkberkrfsd prod req3
THIRD PRODUCTION REQUEST
TO AVISTA 4 OCTOBER 2,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OFOCTOBER2OI8,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-I8-03/
AVU-G-18-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
PATRICK EHRBAR
SR MGR RATES & TARIFFS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
avi stadockets@avistacorp. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 8370I
E-mail : [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-mail : [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail: [e-mail]
ELECTRONIC SERVICE ONLY
LARRY CROWLEY, DIR
ENERGY STRATEGIES INST.
E-MAIL : [e-mail]
ELECTRONIC SERVICE ONLY
CAROL HAUGEN
E.MAIL:
caro l. hau [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
TRAVIS RITCHIE
STAFF ATTORNEY
SIERRA CLUB
2101 WEBSTER ST STE 13OO
OAKLAND CA946I2
E-mail : [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
ELECTRONIC SERVICE ONLY
MARV LEWALLEN
E-MAIL:
marv. lewal len@ clearwaterpaper. com
CERTIFICATE OF SERVICE
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 837I6
E-mail: deanjmiller@,cableone.net
'.L- /]A-r-
SECRETXRY