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HomeMy WebLinkAbout200405068th Request of Staff to Avista.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff r~ECEIVEO ILED 2004 MAY -. PM 4: 23 . - U t~ U I tunES 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- EIGHTH 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 Avista Corporation (Avista; Company) provide the following documents and information on or before THURSDAY MAY 20, 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 behalfmay 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. EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO A VISTA MAY 6, 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. 224 THROUGH NO. 228 PERTAIN TO DEMAND-SIDE MANAGEMENT ISSUES Request No. 224: On page 45 , lines 2 and 3, of his direct testimony, Brian Hirschkorn states that , " Over 286 million kWh and 5.8 million therms have been saved through the Company energy efficiency programs since 1995." However, on lines 6 and 7 of page 45, Mr. Hirschkorn states that these amounts are annual savings. Please reconcile those two statements. Request No. 225: Please provide a brief description of each energy efficiency program implemented since 1995 and the Company s estimate of kWh and therm savings experienced by its Idaho customers as a result of each of those programs (including the Northwest Energy Efficiency Alliance (NEEAJ as a whole) for each year from 1995 through 2003 and projected energy savings for the remaining life of each program measure. Also provide actual utility funds spent for each program for each year and an estimate of additional amounts spent by customers receiving the program measures. Request No. 226: Please provide any available analyses of the cost effectiveness of NEEA's programs for Avista s Idaho customers. Request No. 227: On page 45, lines 7 through 10, Mr. Hirschkorn states that the 15-year levelized utility cost for its use of energy efficiency tariff rider funds has been 1.4~ per kWh and 14~ per thermo Please provide the step-by-step calculations used to arrive at these costs per kWh and thermo Request No. 228: On page 45 , lines 8 and 9 , Mr. Hirschkorn states that the levelized avoided cost for electricity over a "similar" period has been 4.7~ per kWh. Please define this similar" period and provide data and calculations supporting the 4.7~ per kWh levelized avoided cost. EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA MAY 6, 2004 STAFF PRODUCTION REQUEST NOS. 229 THROUGH NO. 233 PERTAIN TO THE ELECTRIC ISSUES Request No. 229: For the test year, please provide a bill frequency analysis for Service Schedule 1 for each month with incremental blocks of 100 kWh for usage from 0 to 1500 kWh; 1500 to 2 000 kWh; 2 000 to 2 500 kWh; 2 500 to 3 000 kWh; 3 000 to 4 000 kWh; 4 000 to 5 000 kWh and over 5 000 kWh. Include both number of bills in the block and energy use in the block. Please provide this in Excel 2000 format. Request No. 230: For the test year, please provide a bill frequency analysis for Service Schedule 11. Include both the number of bills in the block and energy use in the block for each month with incremental blocks of 500 kWh for usage from 0 to 3500 kWh; 3 500 kWh to 3 650 kWh; 3 650 kWh to 4 000, then increments of 1 000 kWh to 10 000 kWh, increments of 5 000 kWh to 50 000 kWh, then all over 50 000 kWh. Please provide this in Excel 2000 format. Request No. 231: For the test year, please provide a bill frequency analysis for Service Schedules 21 and 25. Include both the number of bills in the block and energy use in the block for all months. For usage from 0 to 500 000 kWh provide incremental blocks of 50 000 kWh; then from 500 000 kWh to 1 000 000 kWh, in increments of 100 000 kWh; 1 000 000 to 2 000 000 kWh; 2 000 000 to 5 000 000 kWh; 5 000 000 to 10 000 000 kWh; and over 10 000 000 kWh. Please provide this in Excel 2000 format. Request No. 232: For the test year, please provide a bill frequency analysis for Service Schedule 31 for each month. Include both the number of bills in the block and energy use in the block. The usage blocks are from 0 to 85 kWh; 85 to 100 kW, then 100 kWh to 500 kWh in increments of 100 kWh; then 500 to 5 000 kWh in increments of 500 kWh; 5 000 to 10 000 kWhs; 000 to 25 000 kWh; 25 000 to 50 000 kWh; 50 000 to 100 000 kWh; 100 000 to 350 000 and over 350 000 kWh. Please provide this in Excel 2000 format. Request No. 233: Please provide Hirschkorn Exhibits 20 and 23 in Excel 2000 format. EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO A VISTA MAY 6, 2004 Request No. 234: Please provide daily natural gas futures prices for delivery in each month from January 2004 through December 2005 as collected by Avista during the period between May 1 , 2003 and May 1 , 2004. Please provide the futures prices for delivery at the following locations: Henry Hub, Malin, Northeast combustion turbine, and Rathdrum. Please provide the data in an Excel format similar to the commodity and basis prices for December 10 2003 as used in the AURORA model. STAFF PRODUCTION REQUEST NOS. 235 THROUGH NO. 245 PERTAIN TO ACCOUNTING ISSUES Request No. 235: Please provide schedules (in a legible, readable to the naked eye format and in electronic format) showing the following information associated with vegetation management: All amounts, by account and by year, that were charged to Idaho Electric for the years 1998 through 2003; All amounts, by account and by year, that were budgeted to Idaho Electric for the years 1998 through 2003; Please provide the same information requested in items a and b on a system-wide basis. Request No. 236: Please provide a schedule showing the total amount budgeted for vegetation management for 2004 for Idaho Electric, and for the total system. Please break out the budgeted amount for 2004 by the regular, ongoing vegetation management program, and the amount for the "catch up" due to the deferral due to the cost cutting measures. Please identify these costs by FERC account, and by vegetation management activity. Request No. 237: Don Kopczynski's testimony, on page 17, lines 10- 12, refers to a reduction in the vegetation management program in 2001 and 2002 due to the extreme financial stress experience by the Company beginning in early 2001. Please provide the following information: An analysis for the vegetation management cost reductions; The budgeted amounts for vegetation management for those years; EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA MAY 6, 2004 The actual amounts expended during those years for vegetation management; Specifically provide a schedule showing what aspects of the vegetation management program were deferred until a later date, and what aspects, if any, were temporarily abandoned. Request No. 238: Don Kopczynski's testimony, on page 17, lines 16 - 17, refers to the annual vegetation management projects scheduled for 2004 through 2007. Please provide a schedule with at least the following information separately identified: The vegetation management projects; The total amount budgeted for each year; The amount broken out by project, by year; The FERC account where the amounts are recorded; Please provide the amounts on both a system-wide basis, and an Idaho jurisdictional basis. Production Request Nos. 239 through 244 relate to Coyote Springs II. Request No. 239: Please provide the journal entries associated with the sale of one half of the Coyote Springs II plant to Mirant. Request No. 240: Please provide a schedule showing what revenues were received from Mirant. Request No. 241: Show by year what revenues, if any, are still to be received from Mirant. Request No. 242: What effect has the bankruptcy of Mirant had on the Coyote Springs II project? Please provide the detail and description of all monetary and non-monetary effects. Please provide a schedule of all costs involved, by FERC account, showing both system and Idaho jurisdictional amounts. EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO A VISTA MAY 6, 2004 Request No. 243: Please provide copies of any and all contracts dealing with the maintenance and management of Coyote Springs II. Request No. 244: Please show how maintenance and management costs for Coyote Springs II are split with Mirant. Also, show how the costs are booked, by FERC account. Provide the costs both on a system level and at the Idaho jurisdictional level. Request No. 245: Don Falkner s testimony, on page 27, lines 7- 9, states that , " Test period wages and salaries are restated as if the wage and salary increases for 2002 2003, and 2004 were in place during the entire pro forma test period. Please provide the actual salary increases in 2002, 2003 and 2004? Were there salary increases that were budgeted but not implemented? What is the current level of salaries for 2004 for both the executive, and non- executive labor; provide the data both on a system wide basis and on an Idaho jurisdictional basis? The following paragraph relates to Production Request Nos. 246 through 249. Please consider this background information when answering the following requests. On pages 61 and 63 of Robert Lafferty s testimony, he states that a review of the Boulder Park project was conducted in June 2001 when the estimated total cost to construct the project was $23.7 million. On line 5, page 63 of Robert Lafferty s testimony the total cost to construct the Boulder Park project was identified as approximately $31.9 million. According to lines 10 and 11 page 22 of Don Falkner s testimony, the Boulder Park project became commercially operational in May 2002. However, in 2001 materials presented to the Company s Board of Directors, Boulder Park was anticipated to be operational September 1 , 2001. EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO A VISTA MAY 6, 2004 Request No. 246: Were any reviews of the Boulder Park project's continued economic feasibility conducted after June 2001? If so, please provide:a. a copy of each analysis a summary of the results, and the detail of Company actions taken based upon those results. Request No. 247: Were any changes made to the Boulder Park project based upon the economic reviews performed? If so, please provide a detailed description of those changes including costs that may have been reduced to improve the economics of the project. Request No. 248: Please provide a detailed analysis of the costs that exceeded the June. 2001 estimated proj ect cost of $23.7 million. Include within your response: the reason for the costs the amount of the costs any project reports or other documents discussing these costs, and an accounting/plant report that includes the transaction detail (amount posted, date posted, work order number, vendor description, transaction description, and document number) for the project costs exceeding the estimated project cost of $23.7 million. Request No. 249: Please provide a detailed description of the reasons for the delay in Boulder Park becoming operational. Please include in your response any project reports memorandums, e-mails, or other documents that relate to the project's delayed completion. The following paragraph relates to Production Request Nos. 250 through 253. Please consider this background information when answering the following requests. On page 65 of Robert Lafferty s testimony, he states that a review ofthe Kettle Falls project was conducted in September 2001. This review was updated in April 2002 although using the same forward market information used in the September analysis (Exhibit 9/Schedule 36, Page 10 of 11). According to Page 6 of Exhibit 9/Schedule 36 sponsored by Mr. Lafferty, the estimated EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO A VISTA MAY 6, 2004 total cost to construct the project was $8.5 million. On Z10 of Don Falkner s workpapers, it appears the Kettle Falls project cost approximately $9.2 million. According to lines 10 and 11 page 22 of Don Falkner s testimony, the Kettle Falls project became commercially operational in May 2002. However, in 2001 materials presented to the Company s Board of Directors, Kettle Falls was anticipated to be operational early in September 2001. Request No. 250: Were any reviews of the Kettle Falls project's continued economic feasibility conducted after September 2001 using forward price information as of the date of the review? If so, please provide: a copy of each analysis a summary of the results, and the detail of Company actions taken based upon those results. Request No. 251: Were any changes made to the Kettle Falls project based upon the economic reviews performed? If so, please provide a detailed description of those changes including costs that may have been reduced to improve the economics of the project. Request No. 252: Please provide a detailed analysis of the costs that exceeded the estimated project costs of $8.5 million. Include within your response: the reason for the costs the amount of the costs any project reports or other documents discussing these costs, and an accounting/plant report that includes the transaction detail (amount posted, date posted, work order number, vendor description, transaction description, and document number) for the project costs exceeding the estimated project cost of$8. million. Request No. 253: Please provide a detailed description of the reasons for the delay in Kettle Falls becoming operational. Please include in your response any project reports memorandums, e-mails, or other documents that relate to the project's delayed completion. EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO A VISTA MAY 6, 2004 Request No. 254: Please provide a schedule that identifies the number of hours that the Boulder Park project ran in 2002 and 2003 that includes the dates the project ran. Request No. 255: Please provide a schedule that identifies the number of hours that the Kettle Falls project ran in 2002 and 2003 that includes the dates the project ran. Request No. 256: Please describe in detail the purpose of the transmission projects pro- formed into rate base including any improvements in import/export capability outside the Avista control area and how these projects are reflected in the power supply model. Dated at Boise, Idaho, this 1h day of May 2004. Technical Staff:Lynn Anderson Dave Schunke Kathy Stockton Patricia Harms Rick Sterling i:umisc:prodreq/avueO4.avugO4.1sw8 EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA MAY 6, 2004 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF MAY 2004 SERVED THE FOREGOING EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA CORPORATION IN CASE NO. AVU-04-l/AVU-04-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: DAVID J. MEYER SR VP AND GENERAL COUNSEL AVISTA CORPORATION PO BOX 3727 SPOKANE WA 99220-3727 E-mail dmeyer~avistacorp.com KELLY NORWOOD VICE PRESIDENT - STATE & FED. REG. A VISTA 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. tv 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 CERTIFICATE OF SERVICE