20231121Staff 1-8 to AVU.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 3:4 6
PO BOX 83720
BOISE,IDAHO 83720-0074 iMSSION
[phone]
IDAHO BAR NO.9917
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 THE APPLICATION OF )AVISTA CORPORATION,D/B/A AVISTA )CASE NO.AVU-G-23-08UTILITIES,FOR AN ORDER AUTHORIZING )DEFERRED ACCOUNTING FOR COSTS )RELATED TO THE NOVEMBER 2023 )FIRST PRODUCTION
WILLIAMS NORTHWEST PIPELINE )REQUESTOF THE
OUTAGE )COMMISSION STAFF
)TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy Attorney General,requests that Avista Corporation ("Company")provide
the followingdocuments and information as soon as possible,but no later than TUESDAY,
DECEMBER 4,2023.1
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,additional documents that it,or any person
acting on its behalf,may later obtain that will augment the documents or informationproduced.
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
I Staff 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 1 NOVEMBER 21,2023
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 with formulas intact and enabled.
REQUESTNO.1:Please provide any documents,statements and other workpapers,
with all formulas intact and enabled,includingsource documents,used to calculate actual and
estimated costs to restore Natural Gas service to Avista's customers during this unforeseen
incident.
REQUESTNO.2:Please provide any spreadsheets or documents used to develop
response plans,restoration activities,customer communications,and other measures to respond
to this incident.Please include the timeline of this outage from when first notified through
completion.Also,please provide updates as to when each step was completed or estimated time
of completion.
REQUESTNO.3:In the Application,the Company states that recovery of costs could
include proceeds from any claims made by Avista.Please provide any information or a list of
these claims being made,along with the potential recovery and amount of each claim.
REQUESTNO 4:Please provide any information received as to how this incident
happened and the identityof the third-partythat caused Williams NW Pipeline to experience a
"dig in"and if there were any injuries reported due to this incident (when it happened to the
completion of reconnecting services).
REQUESTNO.5:Please provide the Company's rationale for seeking recovery of
interest (carrying charge)on these deferred costs.
REQUESTNO 6:Please explain if Avista has any insurance that would cover incidents
like this one that happened November 8,2023.If so,please provide documents that show what
is covered and the amount.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 NOVEMBER 21,2023
REQUESTNO.7:Please provide Avista's procedures/policy on how to handle similar
emergency events.If a procedure/policy was used:how did this help Avista in reducing the
impact to the customers and if any,how did this incident help Avista reduce these types of
incidents in the future.
REQUESTNO.8:Please provide an estimated cut-off date for all expenses requested to
be deferred as a regulatory asset in this case.
DATED at Boise,Idaho,this 21st day of November 2023.
n Hardie '
Deputy AttorneyGeneral
i:umise:prodreq/AVU-G-23-08 PR#l
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 NOVEMBER 21,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21th DAY OF NOVEMBER 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-G-23-08,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:[e-mail]
[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE