20230321Staff 35-51 to AVU.pdf

CHRIS BURDIN 0 0
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 2 i ŸÔ
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.AVU-E-23-01
AVISTA CORPORATION FOR THE )AVU-G-23-01
AUTHORITY TO INCREASE ITS RATES AND )CHARGES FOR ELECTRIC AND NATURAL )SECOND PRODUCTION
GAS SERVICE TO ELECTRIC AND NATURAL )REQUESTOF THE
GAS CUSTOMERS IN THE STATE OF IDAHO.)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Avista Corporation dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and information as soon as
possible,but no later than TUESDAY,APRIL 11,2023.
This Production Request is to be considered as continuing,and Avista 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.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 1 MARCH 21,2023
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.
REQUESTNO.35:Please provide any studies the Company has in its possession,or
any studies the Company has reviewed on the electric and/or gas consumption of low-income
customers.
REQUESTNO.36:Please provide a schedule of rate cases in other states or by other
subsidiaries of Avista Corp since January 1,2020.If those rate cases were settled with a stated
return on equity,please provide the stipulated return on equity.
REQUESTNO.37:Please provide a worksheet that details a list of all Operation and
Maintenance("O&M")expenses incurred for the Wildfire Resiliency Plan ("WRP")for July 1,
2020,to date.In your response,please provide vendor name,amount,date,FERC account
number,a brief description of the expense,and breakdown expenses by rate year.
REQUESTNO.38:Please provide a worksheet that details a list of all Capital expenses
incurred for the WRP for July 1,2020,to date.In your response,please provide vendor name,
amount,date,FERC account number,a brief description of the expense,and breakdown
expenses by rate year.
REQUESTNO.39:Please provide a worksheet that has a detailed listing of the pro
forma WRP O&M Expenses for 2023,2024,and 2025.
REQUESTNO.40:Please provide a worksheet that has a detailed listing of the pro
forma WRP Capital Expenses for 2023,2024,and 2025.
REQUESTNO.41:Please explain why the forecasted budget for the Dry Land
Substation SCADA is expected to nearly double in 2023 from 2022 actuals.Company witness
Howell Exhibit 10,Schedule 1 at 29.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MARCH 21,2023
REQUESTNO.42:In the WRP,the Company states there are 15 remote substations in
high fire risk areas.WRP at 55.
a.Please provide the number of remote substations located in high fire risk areas
that are in Idaho;and
b.Please provide a worksheet detailing the actual Dry Land Substation SCADA
costs for the 2022 calendar year including the name of each substation,allocation
of costs for each substation completed,and the state where each substation is
located.
REQUESTNO.43:Please explain why the forecasted budget for the Safe Tree
program is expected to nearly double in 2023 from 2022 actuals.
a.Please provide a worksheet detailing the actual cost of the Safe Tree program in
the 2022 calendar year includingthe allocation of costs to each state.
REQUESTNO.44:As part of the Fuel Reduction program,please describe if there was
any cost sharing between partners.If any,please provide a worksheet detailing how costs were
allocated between partners.
REQUESTNO.45:In Company witness Howell's direct testimony,he describes the
first phase of the Wildfire Resiliency Communication Plan.Howell stated:"No communications
began until the organization was ready from an operational and regulatory standpoint."Howell
Direct at 49.
a.Please explain when communication first occurred;and
b.Please provide the incremental costs to make the communication systems ready
for additional use.Please provide supporting workpapers.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 3 MARCH 21,2023
REQUESTNO.46:In Company witness Howell's testimony,he stated:"As part of the
2023 Wildfire strategy,we will commit to underground facilities in connecting new customers in
high fire threat districts whenever financially feasible."Howell Direct at 61.
a.Please provide the Company's undergrounding project guidelines;
b.Please explain the specific criteria used to evaluate "financially feasible";
c.Please explain the selection process for undergrounding;and
d.Provide a cost-benefit analysis for completed and future undergrounding projects.
REQUESTNO.47:Please provide all funding alternatives and sources that the
Company has pursued and/or received for its WRP.Please provide supporting workpapers.
REQUESTNO.48:Please provide the Company's process guidelines and all least-cost,
least-risk,analysis used to evaluate pilotprojects and for converting pilotprojects to full
programs.
REQUESTNO.49:The WRP references how the Company has been replacing wooden
poles with steel poles since 2006 as standard construction.WRP at 20.
a.Please provide the number of steel poles that were installed outside the scope of
the WRP since implementation in 2020;and
b.Please provide the annual costs of steel pole replacements outside the scope of the
WRP since implementation in 2020.
REQUESTNO.50:Please provide a worksheetthat details a list of all the O&M
expenses incurred for the Company's existing vegetation management program,but not for the
WRP,for July 1,2020,to date.In your response,please provide vendor name,amount,date,
FERC account number,a brief description of the expense,and breakdown expenses by rate year.
REQUESTNO.51:Please explain if the Company is required to comply with any
orders or laws in relation to its WRP for the state of Washington.Please provide a brief
description of the order or law and include a list of all costs required for compliance.Please
include any workpapers with formula intact.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 4 MARCH 21,2023
DATED at Boise,Idaho,this ;day of March 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/avue23.1 avug23.lcbde prod req 2
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 5 MARCH 21,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 216'DAY OF MARCH 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NOS.AVU-E-23-01/
AVU-G-23-01,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:david.meyer avistacorp.com
avistadockets avistacorp.com
SECRETAARY
CERTIFICATE OF SERVICE