200404055th Request of Staff to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
:""("'
(1-,t"Lcl',LI ITJ
:: ':"'
r-'"1
L-.
" ,
'1:;;11. !\Pp -PH 3: 48
,-"
'J ,I'd ,I.
; Li ,- ~" i
'11 il;:::; CUl"\\SSION! ILo
' ",,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO.
CASE NOS. A VU-04-
A VU -04-
FIFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through itsattorne~ of record
Scott Woodbury, Deputy Attorney General, requests that Avista Corporation (Avista; Company)
provide the following documents and information on or before FRIDAY, APRIL 16,2004.
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. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and A vista 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.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
FIFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA APRIL 2, 2004
For all responses to the following requests, please provide all workpapers, diskettes (3.
in.), CDs and all underlying formulas intact in Excel 2000 compatible language.
STAFF PRODUCTION REQUEST NO. 179 PERTAINS TO THECOMP ANY'
NATURAL GAS OPERATIONS
Request No. 179: Please recalculate the jurisdictional allocation model and subsequent
cost of service model with the following adjustment. Please adjust the following Schedule M
Additions that were allocated by footnote 5 to footnote 4 (account 1999.09 Hardware/Software/
Furniture Lease Payments, 1999.13 Airplane Lease Payments, 1999.14 Sale Leaseback of
General Office Building). This adjustment is to reflect equivalent allocators in similar accounts
and the four-factor methodology.
STAFF PRODUCTION REQUEST NOS. 180 -182 PERTAIN TO ACCOUNTING
ISSUES
Request No. 180: Please provide copies of all income tax returns filed by the Company
for tax year 2002.
Request No. 181: Avista has entered into a Purchase and Sale Agreement to sell its
interest in the Skookumchuck hydroelectric plant. Please provide the corresponding pro forma
adjustments as if all components related to this sale were to be reflected in the current A vista rate
proceeding. Include the detailed workpapers supporting this adjustment within the Company
response.
Request No. 182: The following questions are a follow-up to Production Request 22:
a. Please provide the contracts, agreements, e-mails and correspondence between A vista
Energy and A vista Corporation pertaining to the expansion of the Jackson Prairie storage facility.
b. Please include any such correspondence with outside contractors and Avista
Corporation or A vista Energy.
c. Please provide all accounting entries and expense allocations for the storage
expansion project.
FIFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA APRIL 2, 2004
d. Please provide copies of all the work orders associated with the expansion, as well as
copies of any and all invoices associated with the expansion project, even those that are only
remotely associated with the expansion project.
e. Please provide a detailed schedule showing all revenues received by A vista Energy as
a result of the expansion of the Jackson Prairie Storage facility. Please provide all workpapers
and supporting documentation.
f. Please provide a detailed schedule showing all revenues received by A vista Corp as a
result of the expansion of the Jackson Prairie Storage facility. Please provide all workpapers and
supporting documentation.
Dated at Boise, Idaho , this e:::;;day of April 2004.
Technical Staff: Michael Fuss
Kathy Stockton
Patricia Harms
i :umisc:prodreq/avueO4, 1- avugO4, 1 sw5
FIFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA APRIL 2, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF APRIL 2004
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO A VISTA CORPORATION, IN CASE NO. A VU-04-lIA VU-04-, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J. MEYER
SR VP AND GENERAL COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail dmeyer~avistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
AVISTA UTILITIES
PO BOX 3727
SPOKANE W A 99220-3727
E-mail Kelly.norwood~avistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-mail cew~givenspursley.com
DENNIS E PESEAU, PH. D.
UTILITY RESOURCES INC
1500 LIBERTY ST SE, SUITE 250
SALEM OR 97302
E-mail dpeseau~excite.com
CHARLES L A COX
EV ANS KEANE
111 MAIN STREET
PO BOX 659
KELLOGG ID 83837
E-mail ccox~usamedia.
E-mail don.falkner~avistacorp.com
~~'
SECRETARY
CERTIFICATE OF SERVICE