20191121Staff 1-3 to Avista.pdf

MATT HLINTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC U'|ILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 l8
IDAHO BAR NO. I0655
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Strcet Address for Express Mail:
472 W. WASHINGTON
BOTSE. IDAHO 83702-5918
Attomey for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S PETITION FOR LIMITED )
WAIVER OF PENALTY TERMS SET FORTH IN)
ITS NATT]RAL (;AS TARII.'I-.FIRST PRODUCTION
REQUEST OF THE,
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney ol'record,
Matt Hunter, Deputy Attomey General, request that Avista Corporation (Company) provide the
following documents and inlbrmation as soon as possible. or by THURSDAY,
DECEMBER 5,2019.r
This Production Request is continuing, and the Company is requested to providc, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
Iater 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 ofthe record holder
I Staffis requesting an expedited response. tfresponding by this date will be problematic, please call Staffs
attorney at (208) 334-03 18.
FIRSl' PRODUCTION
R,EQUEST TO AVISTA
CASE NO. AVU.G-19-08
)
)
)
)
)
I NOVEMBER 2I. 20I9
and if different the witness who can sponsor the answer at hearing il'need be. Relerence IDAPA
31.01.01.228.
In addition to the wfitten copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. l: Did any other Idaho tr.ursportation cuslomers exceed their daily
nominations during the 2018-2019 winter time period? If yes, please provide by customer, the
number ofoccurrences, the number of therms exceeded, and ovcrrun penalties applied by the
Company.
REQUEST NO.2: Please provide all work papers used to calculate the overrun
entitlement penalty ol $926,202. In your response, please provide the lollowing information in a
spreadsheet with lormulas intact ior each ofthe eight dates the daily nomination was exceeded:
a. The daily amount of nomination Clearwater was entitled to;
b. The daily amount Clearwater consumed;
c. The net (amount of nomination exceeded) of items a and b;
d. Ovemrn penalty; and
e. Total ovemrn penalty.
REQUEST NO. 3: The Company stated in its Petition that it did not have to buy
additional gas to make up for Clearwater's use during curtailment and no financial harm was
incurred. Petition at 4. Please explain how the Company was ablc to accommodate Clearwater's
consumption during each ofthe eight days nominations were exceeded. Additionally, please
explain how the Company avoided financial harm.
Dated at Boise, Idaho, this )/
i umisc:prodreq/avug l9.Smhtncrk prod rcql
FIRST PRODUCTION
REQUEST 1'O AVISTA
-ttday olNovember 2019
Matt Hunter
Deputy Attorney General
2 NOVEMBER 21.2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2I't DAY OF NOVEMBER 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU.G.Ig.O8,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIRECTOR REGULATORY AFFAIRS
AVISTA CORPORATION
POBOX3727
SPOKANE WA99220-3727
E-mail: patrick.stacom.com
SECRET Y
CERTIFICATE OF SERVICE
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
POBOX3727
SPoKANE WA99220-3727
E-mail: rnichael.andrea([e-mail]