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