20080715Staff to AVU 199-204.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 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
3: 31
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
NATURA GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO.
)
) CASE NO. A VU-E-08-1) AVU-G-08-1
)
) TENTH PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO A VISTA CORPORATION
)
The Staff of the Idaho Public Utilties 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 TUESDAY, JULY 29, 2008.
TENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 1 JULY 15,2008
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.
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 pursuat 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 IDAPA 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. 199: In response to Production Request No. 189, Avista identified that
Cabinet Gorge Wastewater project costs were written off to operating expenses in 2007. Please
identify the FERC account and subaccount to which the expenses were written off and the
corresponding amounts allocated to Idaho contained within the Company's general rate case.
REQUEST NO. 200: For each legal expense included in the rate case fiing please provide a
schedule with the following information:
Name of Vendor
Date Invoice Paid
Voucher Number
Accounts Invoice charged to
Description of Services Provided
While Staff may be in possession of the first four items requested, the description of each
transaction is not accessible from the curently provided information.
The description of services provided should clearly define what the expenses have been
incured for; however, on many invoices that Staff reviewed on site, these reference line statements
are vague, such as "Regulatory Monitoring". In this instace, a better description is needed.
Staf is requesting the information for all legal expenses in all accounts, not just those in
account 923.
TENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 2 JULY 15,2008
REQUEST NO. 201: In Order No. 29602, the Commission accepted Staffs adjustments
removing non-recurring extraordinary legal expense as reasonable and appropriate. Specifically Staff
removed legal expenses related to subsidiary activities, and extraordinary and non-recurrng events
such as the banruptcy proceedings of Enron Corporation and the FERC investigation into electrcity
trading practices. Please provide a listing of all legal expenses included in the rate case filings, both
gas and electric, for subsidiar activities, extraordinary events, and non-recuring events. Specifically
note any legal expenses related to subsidiaries, the banptcy proceedings of Enron Corporation or
the FERC investigation into electricity trading practices.
REQUEST NO. 202: Please provide the account transaction detail for FERC account 923 by
month in an Excel spreadsheet format with formulas activated, and including all sub accounts. Provide
the name of the vendor, voucher number, expenditure type, transaction description, and jurisdictional
allocation of the transaction. Please provide a print out as well as an electronic copy of the Excel
spreadsheet.
REQUEST NO. 203: Please provide a description of expenses reflected in the rate case fiing
for the Chicago Climate Exchange (CCX) and Carbon Financial Instruent (CFI). Please provide
dollar amounts and accounts where they have been booked.
REQUEST NO. 204: Please provide copies of all documentation associated with CFI
revenues, CFI expenses and CCX expenses.
Dated at Boise, Idaho, ths i~ n-i day of July 2008.
~ r1 f'n~Q !' daR!\ ,
Kri tine A. Sasser
Deputy Attorney General
Technical Staff: Patricia Hars
Kathy Stockton
Terr Carlock
i:umisc:prodreq/avue~08.ksphklstc prod reqlO
TENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 3 JULY 15,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF JULY 2008, SERVED
THE FOREGOING TENTH 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
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220
E-MAIL: david.meyertiavistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
601 WBANNOCKST (83702)
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cewtigivenspursley.com
BRAD M. PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE, ID 83702
E-MAIL: bmpurdytihotmail.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwoodtiavistacorp.com
DENNIS E. PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY STREET SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseautiexcite.com
~~-
SECRETARY.
CERTIFICATE OF SERVICE