20200721Staff 1-9 to Avista.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
CHANGE ITS NATURAL GAS RATES AND
CHARGES (2020 PURCHASED GAS COST
ADJUSTMENT)
E *EtVEB
It?il JUL 2l Pll 3: 38
'*r,,:it' ii i iiirffi#$$i,{
Street Address for Express Mail:
1133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
CASE NO. AVU-G.20-04
F'IRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Matt Hunter, Deputy Attomey General, request that Avista Corporation (Company) provide the
following documents and information as soon as possible, or by TUESDAY, AUGUST 1112020.
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.
FIRST PRODUCTION
REQUEST TO AVISTA 1 ruLY 21,2020
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. 1: Please provide supporting information for Lost and Unaccounted for
Gas, including:
a. The workpapers with all formulas intact and enabled, used to determine the Lost
and Unaccounted for Gas values shown in Exhibit D,Page 12.
b. The Lost and Unaccounted for Gas numbers reported to Pipeline and Hazardous
Material Safety Administration (PHMSA) for the five-year period reported in this
PGA filing and explain any differences between what is reported in the PGA
filing and reported to PHMSA. Please reconcile any differences.
REQUEST NO.2: Please provide the workpapers, with all formulas intact and enabled,
used to determine the capacity release values for this PGA. Include the total capacity release and
share by jurisdiction.
REQUEST NO.3: Please provide the GADD spreadsheets for the months July 2019
through May 2020. Staff intends to pull a sample from these months for further review,
including invoices and billing statements.
REQUEST NO.4: Please provide the2019 and2020 WA-ID Deferral & Amort
spreadsheets for the months included in Schedule 155.
REQUEST NO. 5: Please provide the Gas Costs Journals - DJ 430, for the months of
July 2019 through May 2020.
REQUEST NO. 6: Please explain the Company's process steps for purchasing natural
gas and transmission capacity needed for direct service to gas customers and compare it to the
steps used to purchase natural gas and transmission capacity needed for electric power
generation from natural gas. In addition, please answer the following:
FIRST PRODUCTION
REQUEST TO AVISTA 2 ruLY 21,2020
a. Are the entities within Avista who are responsible for purchasing natural gas and
transmission capacity for natural gas customers the same entities that purchase
natural gas and pipeline capacity for electricity generation? If so, please explain
which parts of the process are common and which parts are kept separate.
b. For Avista entities and process steps that are common to both natural gas and
electricity, please explain how the Company ensures purchases for natural gas are
not being sub-optimized for electricity generation, or vice versa.
REQUEST NO. 7: Please explain how the Company assures that costs and physical
delivery ofnatural gas to each state are properly tracked and recorded.
REQUEST NO. 8: Please explain the criteria used to determine pipeline capacity
releases and how they are allocated between jurisdictions.
REQUEST NO. 9: Please provide a current copy of the Company's natural gas
Procurement Plan (Application page 3). In addition, please provide any and all associated risk
management policies and procedures.
-efDated at Boise, Idaho, this >l day of July 2020.
ffi ffi
Matt Hunter
Deputy Attomey General
i:umisc:prodreq/avug20.4mhkls prod req I
FIRST PRODUCTION
REQUEST TO AVISTA J ruLY 21,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21't DAY OF JULY 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA CORPORATION, rN CASE NO. AVU-G-20-04, By E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
POBO)(3727
SPoKANE WA99220-3727
E-MAIL: patrick.ehrbar @avistacom.com
avistadockets @ avistacorp.com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
POBO){3727
SPOKANE WA99220-3727
E-MAIL: david.meyer@ avistacorp.com
Y
CERTIFICATE OF SERVICE