20080529Staff to AVU 69-122.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
2UOB r1AY 29 PM 2= 27
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 NO. AVU-E-08-1
) A VU-G-08-1
)
) THIRD PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TOAVISTACORPORATION
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Avista Corporation (Company;
Avista) provide the following documents and information on or before MONDAY, JUNE 16,
2008.
THIRD PRODUCTION REQUEST
TO A VISTA CORPORATION 1 MAY 29, 2008
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. 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
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 69: Please provide a schedule that identifies the expected Date in
Service of all 2008 capital projects included within the Company's case and identify the source
of this information for each project. Please consider this an ongoing request and provide updates
to those dates during the course of this case. Please provide the printout of this information and
a CD in Excel format with formulas activated.
REQUEST NO. 70: Please provide the Capital Budget Group Year to Date (YTD)
Actuals Capital Budget spreadsheets for 2005, 2006, 2007 and 2008 to date with a printout
provided and a CD in Excel format with formulas activated. Staffhas already received the April
2008 YTD Actuals spreadsheet. Please consider this an ongoing request and provide these
spreadsheets monthly for the remainder of the case.
REQUEST NO. 71: Please provide all materials prepared and used to project the costs
of 2008 plant in service by project contained in this rate case. In addition to printouts, please
also provide any materials in Excel format on CD with formulas activated.
REQUEST NO. 72: Please provide all materials prepared and presented regarding the
cost benefit of the Spokane River Relicensing capital project. Please include within your
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MAY 29, 2008
response the ongoing licensing costs referenced by Company witness Howard on page 11 of his
direct testimony. In addition to printouts, please also provide any materials in Excel format on
CD with formulas activated.
REQUEST NO. 73: Please provide detail supporting the costs included in this case for'
Spokane River Relicensing not already included in Company witness Howard's workpapers
(reference Company witness Howard, page 9, lines 10 - 22). In addition to printouts, please also
provide any materials in Excel format on CD with formulas activated.
REQUEST NO. 74: Please provide all materials prepared and presented regarding the
purchase decision of the Rathdru CT project. Please include within your response the purchase
documents and how the purchase was recorded by the Company. In addition to printouts, please
also provide any materials in Excel format on CD with formulas activated.
REQUEST NO. 75: Please provide a report, printout and an electronic version on CD in
Excel format with formulas activated, for ER #4134, Rathdru CT Purchase, which includes at
least the following: the project number, expenditure type, vendor description, transaction
description, transaction amount, date posted, document/transaction number, and total amount
posted.
REQUEST NO. 76: Please provide reports, printout and an electronic version on CD in
Excel format with formulas activated, by project, which includes at least the following items: the
project number, expenditue type, vendor description, transaction description, transaction
amount, date posted, document/transaction number, and total amount posted. Please provide a
report(s) showing each of the following projects:
a. Pine Creek Substation,
b. Beacon-Rathdrum 230 kV,
c. Dry Creek Substation,
d. Beacon-Bell #4 230 kV,
e. Beacon-Bell #5230 kV,
f. Spokane Valley Reinforcement,
g. WoH Telecom,
h. WoH Telecom Line Upgrades,
THIRD PRODUCTION REQUEST
TO A VIST A CORPORATION 3 MAY 29, 2008
1. Clark Fork RAS,
J. Palouse Reinforcement, and
k. Lolo Substation.
REQUEST NO. 77: If the project totals of the reports provided in response to the
previous request do not equal those delineated by Company witness Kinney's Direct Testimony,
page 17, Table 1, please provide a reconcilation in Excel format that accounts for any
differences. Please include within your response the reason for any differences.
REQUEST NO. 78: Please provide reports, printout and an electronic version on CD in
Excel format with formulas activated, by project, which includes at least the following items: the
project number, expenditure type, vendor description, transaction description, transaction
amount, date posted, document/transaction number, and total amount posted in each year.
Please provide a report(s) showing each of the following projects:
a. ER # 7001 Structures and Improv for $18 milion in 2005,
b. ER # 1000 Electric Revenue Blanet for 2005,2006 and 2007,
c. ER # 1003 Distribution Line Transformers for 2005,2006 and 2007,
d. ER # 2106 Boulder Construction for 2005,
e. ER # 5000 Computer Software for 2005, 2006, 2007 and 2008,
f. ER # 4116 Colstrip Capital Additions for 2005,2006,2007 and 2008,
g. ER # 5001 Computer/Network Hardware for 2005,2006,2007 and 2008,
h. ER # 6103 Clark Fork Implement PME Agreement for 2007 and 2008,
1. ER # 4135 Noxon Unit 4 Runer Upgrade for 2007,
j. ER # 7000 Transportation for 2006,2007 and 2008,
k. ER # 8000 Accounting Transfer Adjustments for 2006 and 2008,
1. ER # 4105 Noxon Capital Projects for 2005 and 2006,
m. ER # 4130 Cabinet Gorge Unit # 4 Runer Replacement for 2007,
n. ER # 4109 Upper Falls Capital Projects for 2005,
o. ER # 2059 Failed Electric Plant - Unkown for 2006 through 2008,
p. ER # 7400 Avista Mobile Dispatch for 2006,
q. ER # 7050 Productivity Initiative for 2007,
r. ER # 4136 Noxon Rapids Unit I Turbine for 2008,
s. ER # 7101 COF HVAC Improvement for 2008,
t. ER # 7106 Construct Ross Cour Office Building for 2008,
u. ER # 2055 Electric Distribution Minor Blanet for 2008,
v. ER # 2060 Wood Pole Mgmt for 2005 through 2008,
If any of these reports are exceedingly voluminous, please contact Patricia Hars to
discuss alternate and/or summar information that may be provided.
THIRD PRODUCTION REQUEST
TO A VISTA CORPORATION 4 MAY 29, 2008
REQUEST NO. 79: Please provide all materials prepared and presented regarding ER
# 7106 Construct Ross Cour Offce Building. Please include within your response all
documentation demonstrating the need for the project.
REQUEST NO. 80: Please provide all the expenses included within the case associated
with the Company's maintenance/response to the failure of the 80-year old cables mentioned in
Company witness DeFelice's Direct Testimony (page 16, lines 5 and 6).
REQUEST NO. 81: Please provide all the expenses included within the case associated
with the Company's maintenance/response to the 2007 failure of the Mark 5 controller and low
voltage bus duct mentioned in Company witness DeFelice's Direct Testimony (page 16, lines 25
through 28).
REQUEST NO. 82: Please identify all insurance reimbursements received by the
Company for plant destroyed by storm damage, fires and other damages if not already provided.
Please also identify all insurance reimbursements received by the Company for any other items
or events. Please include within your response how and where those reimbursements were
recorded for 2007. For all the insurance reimbursements received in 2007 and 2008 to date,
please provide the detailed accounting information, in an Excel spreadsheet format, including the
FERC account number, Service allocator, Jurisdiction, period, GL Transaction ID, Sub-ledger
Transaction ID, Source ID, Transaction Amount, Electric Amount, Gas North Amount, Gas
South Amount, Joural Name, Project Number, Task Number. Also provide the name of the
vendor, voucher number, expenditue type, transaction description, and jurisdictions where the
transaction is allocated. Please provide a printout as well as an electronic copy of the Excel
spreadsheet(s) with formulas activated.
REQUEST NO. 83: Please identify all events for which insurance reimbursements are
pending or considered. Please include within your response the current status of these
reimbursements.
THIRD PRODUCTION REQUEST
TO A VISTA CORPORATION 5 MAY 29, 2008
REQUEST NO. 84: Please provide the account transaction detail for FERC account
923, in an Excel spreadsheet format, including all sub accounts. Provide the name of the vendor,
voucher number, expenditure type, transaction description, and jursdictions where the
transaction is allocated. Please provide a print out as well as an electronic copy of the Excel
spreadsheet with formulas activated.
REQUEST NO. 85: Please provide the account transaction detail for FERC account
930, in an Excel spreadsheet format, including all sub accounts. Provide the name of the vendor,
voucher number, expenditure type, transaction description, and jursdictions that the transaction
is spread to. Please provide a print out as well as an electronic copy of the Excel spreadsheet
with formulas activated.
REQUEST NO. 86: Please provide copies of all reports on Avista by rating agencies
and securities analysts for 2007 through 2008 as they become available.
REQUEST NO. 87: Please provide a narrative explaining how the therm savings and
kWh savings for the DSM programs were calculated. Please provide all data and calculations.
REQUEST NO. 88: Please provide the cost-benefit analysis, the Total-Resource Cost
Test and the Utilty Cost Test for all DSM programs offered from 2003 to present.
REQUEST NO. 89: Please provide a schedule of all meter reading expenses by year
from 1995 through 2007. Please also include monthly meter reading expenses for January 2008
through present and additional months as they become available.
REQUEST NO. 90: Please provided the amount budgeted by Avista for meter reading
expenses for 2008 and 2009.
REQUEST NO. 91: Please provide a schedule ofInjuries & Damages for the years
2003-2007, and 2008 forecasted.
THIRD PRODUCTION REQUEST
TO A VISTA CORPORATION 6 MAY 29, 2008
REQUEST NO. 92: Please provide a list, in Excel format with formulas activated, all
charges to the following accounts. The list should include date, vendor, amount, a brief
description, and some method of tracking, i.e. voucher number or invoice number.
a. Acct 514000 Maint Misc Steam Plant
b. Acct 539000 Hydro Gen Oper-Misc
c. Acct 545000 Maint Misc Hydro
d. Acct 549000 Other Gen Oper-Misc
e. Acct 554000 Other Gen Maint-Misc
f. Acct 566000 Misc Transmission Exp
g. Acct 573000 Transmission Service Misc Plant
h. Acct 588000 Distribution Oper-Misc
1. Acct 598000 Distribution Maint-Misc
J. Acct 910000 Customer Service & Info Exp-Misc
k. Acct 916000 Misc Sales Expenses
1. Acct 923000 Outside Services Employed
m. Acct 930200 Misc General Expenses
REQUEST NO. 93: Please provide the total straight time payroll (excludes overtime
and bonuses) per year for each of the past ten years for non-officers. Please separate the
bargaining unit employee payroll from the non-bargaining unit employee payroll.
REQUEST NO. 94: Please provide the amount of the anual salar adjustment
(percentage of pay) for the past ten years for non-officer employees. Please separate the
increases for the bargaining unit employees from the non-bargaining unit employees.
REQUEST NO. 95: Please provide the cost!enefit analysis of outsourcing the bil
printing and mail services.
REQUEST NO. 96: Please provide a written update on Avista's proposed holding
company. Please state which jurisdictions have approved the holding company, any stipulations
those jurisdictions have placed on A vista, and any reasons for any jurisdiction that has yet to
approve the proposed holding company.
THIRD PRODUCTION REQUEST
TO A VISTA CORPORATION 7 MAY 29, 2008
REQUEST NO. 97: Please provide a list of expenses (internal and external) associated
with Avista's application of forming a holding company. The list should include at least the
following: a brief description of the expense, date incured, amount, the FERC account to which
the expense was charged and all allocations.
REQUEST NO. 98: Please provide a narative summarzing the new technologies and
techniques used by A vista to insert Mercapta into its natural gas distribution system.
REQUEST NO. 99: Please provide a list of all expenses associated with the
decommissioning of odorant tans previously used to insert Mercaptan in the natual gas
distribution system. The list should include all expenses (internal and external) with the date
incured, FERC account charged, amount and a brief description.
REQUEST NO. 100: Please provide the calculation resulting in Avista's reported O&M
costs per customer of$280.92 and $280.65 for 2006 and 2007, respectively. Please highlight
any O&M accounts that are excluded from the calculation and explain the rationale for such
exclusion.
REQUEST NO. 101: Please provide a narrative explaining the Company's paricipation
in Green Volts. Please include a description of the Green Volts program or entity and the extent
in which Green Volts receives financial support from A vista.
REQUEST NO. 102: What retail load was used by Company witness Hirshcorn to
develop proposed rates? How was the load developed?
REQUEST NO. 103: What would be the proposed rate increase if the proposed revenue
requirement had been spread among 2009 loads with associated revenues and the
production/transmission asset adjustment eliminated?
THIRD PRODUCTION REQUEST
TO A VISTA CORPORATION 8 MAY 29, 2008
REQUEST NO. 104: What was the incremental revenue requirement of adjusting the
2007 test year for production/transmission rate base, expense and revenues through 2009?
REQUEST NO. 105: What is the estimated additional retail revenue generated from
proforming test year 2007 load to 2009 load?
REQUEST NO. 106: What is the total anual revenue requirement requested in this
case due to relicensing the five Spokane River hydroelectric projects (excluding Little Falls)?
REQUEST NO. 107: What is the curent average cost per kWh for energy generated
from the five hydroelectric projects?
REQUEST NO. 108: What is the estimated cost per kWh for energy generated from the
five hydroelectric projects if the relicensing costs requested by the company in this case are
included in rates?
REQUEST NO. 109: In addition to the costs requested for recovery in this case,
Company witness Howard states on page eleven that the estimated costs over the 50 year life of
the license could be $400 to $500 milion for the Post Falls project and $175 to $225 milion for
the downstream Spokane River project. Please provide all economic analysis showing the
estimated levelized costs per kWh for the two projects over the life of the license and how those
costs compare to expected resource alternatives.
REQUEST NO. 110: Company witness Kopczynski references one of Avista's
customer support programs as the Senior Outreach Program. Is that program available to Idaho
customers? If so, how many Idaho customers in 2007 received assistace from this program and
what was the average amount received per customer?
REQUEST NO. 111: How many Avista customers who were assessed a deposit in 2007
had received LIHEAP funds within the previous 12 months?
THIRD PRODUCTION REQUEST
TO A VISTA CORPORATION 9 MAY 29, 2008
REQUEST NO. 112: For each of the past four calendar years (2004-2007), please
provide the total dollar amount contributed to Project Share by: a) Avista's shareholders; b)
Avista's employees; c) contributions from Idaho customers; and, d) other sources.
REQUEST NO. 113: What was the total dollar amount received by Avista's Idaho
customers from Project Share in each of the past four calendar years (2004-2007)?
REQUEST NO. 114: Other than Project Share, did the Company or its shareholders
contribute to community-based organizations for the purose of providing services to or paying
energy bils of low-income customers in Idaho? If so, please identify the organization and the
dollar amount contributed by Avista in each of the past four years (2004-2007).
REQUEST NO. 115: Have the duties of Avista's CARES (Customer Assistance
Referral and Evaluation Service) Representatives changed since 2004? If yes, please elaborate.
REQUEST NO. 116: Are the Avista CARES representatives stil sponsoring the "We
Personally Care" program? If so, in 2007 how many pounds of personal care items were
collected and distributed to low-income familes?
REQUEST NO. 117: How many Idaho customers were signed up for Moratorium
protection from disconnection in each of the last 4 calendar years (2004-2007)?
REQUEST NO. 118: How many of those customers who declared the need for
Moratorium protection were placed on the Winter Payment Plan?
REQUEST NO. 119: In each of the last 4 calendar years (2004-2007), how many
customers who were on the Winter Payment Plan did not declare the need for winter protection
from disconnection (Moratorium)?
THIRD PRODUCTION REQUEST
TO A VISTA CORPORATION 10 MAY 29, 2008
REQUEST NO. 120: How does Avista educate and inform customers of the availabilty
of protection from disconnection during winter months and availabilty of the Winter Payment
Plan? Please provide copies of any written brochures or documents sent or otherwse provided
to customers.
REQUEST NO. 121: How much money did Avista provide for weatherization
programs in Idaho for each of the past 4 years (2004-2007)? By year, please identify the number
of recipients and the average dollar amount received for weatherization purposes.
REQUEST NO. 122: Please provide the Company's written record of complaints and
requests for conferences for calendar year 2007 kept pursuant to Rule 403 of the Commission's
Utility Customer Relations Rules (UCRR) IDAPA 31.21.01.403.
Dated at Boise, Idaho, this i~".t day of May 2008.
~l iJ. &z,l4b
Kr' tine A. Sasser
Deputy Attorney General
Technical Staff: Patricia Hars
Kathy Stockton
Donn English
Randy Lobb
Marilyn Parker
i:umisc:prodreq/avue ..8.l swphklsdemprl prod req3
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 11 MAY 29, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF MAY 2008,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-08-01
& AVU-G-08-01, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220
E-MAIL: david.meyer~avistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwood~avistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
601 W BANNOCK ST (83702)
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew~givenspursley.com
DENNIS E. PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY STREET SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseau~excite.com
BRAD M. PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE,ID 83702
E-MAIL: bmpurdy~hotmai1.com
~.~
SECRETARY
CERTIFICATE OF SERVICE