200405047th 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
RECEIVED 0FILED
2UUI.; MAY -4 AM I:
PUBLIC
UTiliTiES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF A VISTA 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. AVU-04-
A VU-04-
SEVENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission (IPUC), by and through its attorney of
record, Scott Woodbury, Deputy Attorney General, requests that A vista Corporation (A vista;
Company) provide the following documents and information on or before MONDAY, MAY 17,
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 IDAP A 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.
SEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 3, 2004
For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.
CDs and all underlying formulas intact in Excel 2000 compatible language.
STAFF PRODUCTION REQUEST NOS. 207 THROUGH NO. 213 PERTAIN TO
DEMAND-SIDE MANAGEMENT ISSUES
Request No. 207: Beginning on page 13 of his direct testimony, Robert Lafferty described
an independent review of Avista s analyses of supply-side resources. Was a similar independent
review of A vista s analyses of demand-side resources conducted? If so, please provide the review.
If not, please explain why such a review was done for supply-side but not for demand-side.
Request No. 208: In Exhibit No., Schedule I, page 10 is a statement that in September
2000 the DSM workgroup evaluated energy efficiency bids parallel to evaluation of supply-side
bids. Please list names, titles and job descriptions of who comprised the "DSM workgroup.
Please list the name, responsibilities and authority of the workgroup leader. Please provide the
DSM workgroup s evaluation ofDSM bids.
Request No. 209: In Exhibit No., Schedule 1 , page 14 is a statement that in September
2000 "The DSM RFP team acted in concert with the supply-side evaluators to develop a clear and
consistent means of evaluating all proposals received under the RFP." Please list names, titles and
job descriptions of who comprised the "DSM RFP team." Please list the name, responsibilities and
authority of the DSM RFP team leader. Please provide the DSM RFP team s evaluation of DSM
bids.
Request No. 210a: In Exhibit No., Schedule 1, page 15 is a statement that in September
2000 "The eight DSM proposals received were advanced to a three-person DSM screening team.
Please list names, titles and job descriptions of who comprised the "DSM screening team." Please
list the name, responsibilities and authority of the DSM screening team leader. Please provide the
DSM screening team s evaluation of the eight DSM proposals.
SEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 3, 2004
Request No. 210b: In the same paragraph is discussion ofa "wholly deficient" proposal.
Was that proposal from Washington State University (WSU)? What does the statement "Five days
later representatives of WSU indicated that they would not be phase." mean?
Request No. 211: In Exhibit No., Schedule 1 , page 15 is a statement that in
OctoberlNovember 2000 "Seven preliminary evaluation teams were formed to evaluate the
remaining proposals." Please list names, titles and job descriptions of who comprised each of the
seven "preliminary evaluation teams." Please list the name, responsibilities and authority of each
of the preliminary evaluation team leaders. Please provide each of the seven teams' preliminary
evaluations of the remaining proposals.
Request No. 212a: In Exhibit No., Schedule 1 , page 16 is a statement that in
OctoberlNovember 2000 "Three of the five proposals under negotiation were selected as successful
proposals by the negotiating team. Please list names, titles and job descriptions of who comprised
the "negotiating team." Please list the name, responsibilities and authority of the negotiating team
leader.
Request No. 212b: In the same paragraph are the words
, "
The proposal was consequently
eliminated in the screening." Please explain whether three or four proposals were selected as
successful and whether one or two of the proposals were eliminated? Please provide explanations
for selecting or rej ecting each proposal.
Request No. 213: In Exhibit No., Schedule I , page 16 is a statement that in
December/February 2000/2001 "Those proposals that had been selected were advanced to due
diligence. The due diligence team..." Please list names, titles and job descriptions of who
comprised the "due diligence team." Please list the name, responsibilities and authority of the due
diligence team leader. Please provide the due diligence team s evaluations ofthe selected
proposals. Also, please describe the contracts and implementation status of those proposals.
SEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MAY 3, 2004
STAFF PRODUCTION REQUEST NOS. 214 THROUGH NO. 223 PERTAIN TO
ACCOUNTING ISSUES
Request No. 214: In Production Request No. 107, which was due to Staff on March 19
Staff requested a schedule of legal expenses allocated and assigned to Idaho Gas Operations in
2002 and Idaho Electric Operations in 2002. Staff requested that the Idaho totals be separated by
Gas and Electric Operations. Staff also requested that the schedule include totals by legal project.
This Production Request was formerly Audit Request No. 103, dated on-site September 12 2003.
The Company has provided Staffwith legal expenses by vendor. Please provide legal expenses by
project with accompanying accounting detailed reports that supports the amounts scheduled.
Request No. 215: Please provide an accounting report that includes the detail of
transactions posted to legal expenses (dollar amount posted, date posted, accounting document
number, vendor name and work order) subtotaled by work order. Please also provide a copy of
each work order that included postings to legal expenses so the nature of the expense can be readily
determined.
Request No. 216: Please provide separate work order detail reports similar to that provided
by plant accounting (Howard Grimsrud and/or Stephen Beal) for Boulder Park work order number
8298 for the remaining Boulder Park work orders closed in 2002, Cabinet Gorge, Kettle Falls, and
the Transmission Projects pro-formed by the Company in its rate case.
Request No. 217: Please provide the increased revenues and decreased expenses (such as
for maintenance, power supply costs, etc.) associated with all capital projects pro-formed by the
Company in its rate case.
Request No. 218: In recent years the Internal Revenue Service ruled that electricity is
inventoriable. As a result, Avista identified and filed with the IRS past deductions (1987 to 2003)
for costs previously capitalized as fixed assets that can now be allocated to electricity inventory.
Please describe in detail the Company s implementation of this ruling including (but not limited to)
the tax benefit captured in 2003 - 2004, the tax benefit anticipated for future years, any tax
SEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MAY 3 , 2004
reversals that would increase future taxes above current levels, and the effect on utility operations
and ratemaking.
Request No. 219: The Company reports employees' volunteer hours to its Board of
Directors. Please identify how these hours are tracked and whether the Company compensates
employees for these volunteer hours. If the Company compensates for volunteer hours, please
identify the amounts recorded/allocated to Idaho Gas and Electric Operations.
Request No. 220: The Company s response to Production Request No. 87 indicates Avista
Corp. contributions to the Avista Foundation are not recorded to the utility. Please provide the
accounting entries requested by Production Request No. 87 so that Staff can verify the Company
response.
Request No. 221: The Company s response to Production Request No. 89 indicates the
Company s renovation of a downtown hotel building was recorded by Avista Development, Inc.
Please provide the accounting entries requested by Production Request No. 89 so that Staff can
verify the Company s response.
Request No. 222: In reference to the Nez Perce agreement associated with adjustment u on
Company Exhibit No. 14, please provide copies of all insurance settlements. Please provide the
accounts to which any insurance payments were booked. Please provide copies of any journal
entries, etc. where the insurance proceeds were recorded, including any below the line or non-
utility accounts.
Request No. 223: The Company s response to Production Request No. 109 indicates that
Tom Matthews' severance was charged "below the line" to non-utility operations. Please provide
the accounting entries so that Staff can verify the Company s response.
SEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 3, 2004
Dated at Boise, Idaho, this day of May 2004.
cott Woodbury
Deputy Attorney General
Technical Staff:Lynn Anderson
Donn English
Kathy Stockton
Patricia Harms
i:umisc:prodreq/avueO4.- avugO4.1sw7
SEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 3 , 2004
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF MAY 2004 SERVED
THE FOREGOING SEVENTH 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.
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-mail bmpurdy~hotmail.com
MICHAEL KARP
147 APPALOOSA LANE
BELLINGHAM W A 98229
E-mail michael~awish.net
E-mail don.falkner~avistacorp.com
~~.
\C~
SECRETARY
CERTIFICATE OF SERVICE