20181009Staff 60-62 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
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7{]10 CCT - 9 Pil 2: 35
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
CHANGE ITS ELECTRIC AND NATURAL
GAS DEPRECIATION RATES
FOURTH 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 30, 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
31.01.01.228.
FOURTH PRODUCTION REQUEST
TO AVISTA
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CASE NO. AVU-8.18-03
AVU-G-I8-02
I OCTOBER 9,2018
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. 60: Please provide the detailed information and assumptions used in
determining the survivor curves for the following accounts:
o Electric Plant 356.00 - Overhead Conductors and Devices
o Electric Plant 365.00 - Overhead Conductors and Devices
o Gas Plant 352.00 - Storage Wells
o Gas Plant 352.20 - Reservoirs
o Gas Plant 352.30 - Non-Recoverable Gas
o Gas Plant 376.00 - Mains
o Gas Plant 385.00 - Industrial Measuring and Regulating Station Equipment
o Gas Plant 390.10 - Structures & Improvements
For each account please include information used in the determination of the survivor curves,
such as: informed judgements, Company policies and outlook, survivor curve estimates from
previous studies of the Company and other comparable utility companies and any other
information that was used in their determination.
REQUEST NO. 61: In reference to the Transmission account 356.0, OH Conductor &
Fixtures, the proposed Net Salvage is -30o%, in lieu of the current -10%. Pages VIII-47 and VIII-
48 of the Gannett Fleming study, show a historical 34-year average Net Salvage of -4o/o and a
five year moving average Net Salvage of -40Yo. Please explain the cause of the increases in the
Net Salvage over the last five years that would justify using a Net salvage of -30Yo.
REQUEST NO. 62: In reference to removal costs for account 367.0, UG Conductor &
Devices, page VIII-59 of the Gannett Fleming study indicates that removal costs increased by
524yo in 2015 relative to 2074, and 487%o rn20l6. Please provide an explanation for this
increase in removal costs in these two years.
FOURTH PRODUCTION REQUEST
TO AVISTA 2 OCTOBER 9,2078
Dated at Boise, Idaho, tnrs ff9 day of October 2018.
i :umisc:prodreq/avue I 8.3_avug I 8.2bkme prod req4
FOURTH PRODUCTION REQUEST
TO AVISTA J OCTOBER 9,2078
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General
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY oFOCTOBER2OIS,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
coMMrssroN STAFF To AVISTA CORPORATION, IN CASE NOS. AVU-E-18-03/
AVU-G-I8-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
PATRICK EHRBAR
SR MGR RATES & TARIFFS
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail : [e-mail]
avi stadockets@ avi stacorp.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 8370I
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. hauqen@clearwaterpaper. com
DAVID J MEYER
VP & CHIEF COLINSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: david.me)[e-mail]
TRAVIS RITCHIE
STAFF ATTORNEY
SIERRA CLUB
2101 WEBSTER ST STE I3OO
OAKLAND CA946I2
E-mail: travis.
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 837I6
E-mail : deanj [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail : [e-mail]
ELECTRONIC SERVICE ONLY
MARV LEWALLEN
E.MAIL:
marv. lewallen@ clearwaterpaper. com
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SECRETARY
CERTIFICATE OF SERVICE