20220919Staff 1-7 to Avista.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. II7I4
_ i.__:
Street Address for Express Mail:
1 133I W CHINDEN BLVD, 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.22.O6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Avista Corporation provide the
following documents and information as soon as possible, but no later than THURSDAY,
SEPTEMBER 29, 2022.1
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 behalf, may later obtain that will augment the documents or information
produced.
I Staffis requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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I SEPTEMBER 19,2022
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 identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide the Excel workbooks for the GADD spreadsheets
for the months June 2021through June 2022. Staff intends to pull a sample from these
months for further review, including invoices and billing statements
REQTIEST NO.2: Please provide the Excel workbooks for the 2021 and2022W&-
ID Deferral & Amount for the months included in the current PGA period, June 2021
through Jane2022.
REQUEST NO. 3: Please provide the Gas Costs Journals - DJ 430. for the months
of June 2021ttvough June 2022.
REQUEST NO.4: Please provide a current copy of the Company's natural gas
Procurement Plan and Risk Management Policy. If changes and updates have been made to
Company's natural gas Procurement Plan since last PGA filing. please provide a detailed list
ofthose changes and update
REQUEST NO.5: 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.
REQTIEST NO. 6: Please explain how the Company assures that costs and physical
delivery of natural gas to each state are properly tracked and recorded.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 SEPTEMBER 19,2022
REQIIEST NO. 7: Please explaln the criteria used to detennine pipeline capacity
releases and howthey are allocated between jurisdictions.
DATED at Boise, Idaho, tt i, /?tt day of September 2022.
Michael Duval
Depuf Attorney General
i:umiso:prodreq/avug22.6mdrm pod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION J SEPTEMBER19,2A22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF SEPTEMBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
CoMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-G-22-06,
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]
doc kets @avi stacorp. com
DAVID J MEYER
VP & CHIEF COI.INSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W499220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE