20210713Staff 1-5 to Avista.pdf

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JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
TDAHO BAR NO. 5470
It it: Pli l,:?I'_ "'- i "r r';
Street Address for Express Mail:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA UTILITIES FOR AN ORDER
APPROVING A CHANGE IN RATES FOR
PURCHASED GAS COSTS AND
AMORTIZATION OF GAS.RELATED
DEFERRAL BALANCES
CASE NO. AVU.G-21-04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
John R. Hammond, Jr., Deputy Attomey General, requests that Avista Corporation provide the
following documents and information as soon as possible, but no later than TUESDAY:
JULY 27,2021.1
This Production Request is to be considered as continuing, and Avista Corporation is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behall may later obtain that will augment the documents or information
produced.
I Stuff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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I JULY I3,2O2I
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided in response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide supporting information for Lost and Unaccounted for
Gas, including:
a. Updated workpapers (2021values) with all formulas intact and enabled, used to
determine the Lost and Unaccounted for Gas values shown in Exhibit D; and
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 Excel workbooks for the GADD spreadsheets for
the months J:uly 2020 through May 2021. Staff intends to pull a sample from these months for
further review, including invoices and billing statements.
REQUEST NO. 3: Please provide the Excel workbooks for the 2020 and 2021 WA-ID
Deferral & Amort for the months included in the current PGA period, July 2020 through
May 2021.
REQUEST NO. 4: Please provide the Gas Costs Joumals - DJ 430, for the months of
Jr;,ly 2020 through May 2021.
REQUEST NO. 5: Please provide a current copy of the Company's natural gas
Procurement Plan (Application page 3). If changes and updates have been made to Company's
natural gas Procurement Plan since last PGA filing, please provide a detailed list of those
changes and updates.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 JULY 73,2021
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DATED at Boise, Idaho, this t . ) day of July 2021.
Johh R. Hammond
Attorney General
i:umisc:prodreq/avug2 l.4jhtnc prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION J ruLY t3,2021
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS l3th DAY OF ruLY 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF' THE COMMISSION
STAFF TO AVISTA CORPORATTON, IN CASE NO. AVU-G-2I-04, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
[e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W499220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE