20100428Staff 10-38 to AVU.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
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FIPR 28 PM 2: 35
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF A VISTA CORPORATION DBA A VISTA )
UTILITIES FOR THE AUTHORITY TO )
INCREASE ITS RATES AND CHARGES FOR )
ELECTRIC AND NATURAL GAS SERVICE )IN IDAHO. )
)
)
)
CASE NO. A VU-E-I0-l
AVU-G-I0-l
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that A vista Corporation (Company;
Avista) provide the following documents and information on or before WEDNESDAY,
MAY 19,2010.
SECOND PRODUCTION REQUEST
TO AVISTA APRIL 28, 2010
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 wil 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 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. 10: Please provide a listing of all Avista proceedings currently before
other regulatory agencies/jurisdictions. Please include within your response a description of the
proceeding, its current status and docket number or other referencing information.
REQUEST NO. 11: Please provide a copy of the data requests received by Avista from
other jurisdictions pertining to general rate cases curently underway and/or concluded within
the last 12 months.
REQUEST NO. 12: Please provide the electronic fie(s) with formulas intact that are
the basis for Ilustration No.2, Primar Electric Revenue Requirement Factors, on page 7 of
Andrews' direct testimony.
REQUEST NO. 13: If not provided in response to the previous request, please provide
the electronic fie(s) with formulas intact that delineate the amounts included within Ilustration
NO.2 by account and the underlying source for each amount.
SECOND PRODUCTION REQUEST
TO AVISTA 2 APRIL 28, 2010
REQUEST NO. 14: Please provide an electronic fie(s) with formulas intact that
identify the natural gas revenue requirement factors in graphic form similar to Ilustration No.2,
Primar Electric Revenue Requirement Factors, on page 7 of Andrews' direct testimony.
REQUEST NO. 15: If not provided in response to the previous request, please provide
the electronic fie(s) with formulas intact that delineate the amounts by account and the
underlying source for each amount.
REQUEST NO. 16: Please provide all documentation supporting the Company's
request for working capital (Reference Andrews, pps. 33 and 34). Please include within your
response the Company's balance sheet analysis demonstrating that investors supply the funds to
operate during the lag period and the Company's lead-lag study.
REQUEST NO.1 7: Please provide a detailed written description of the Company's
capital expenditure process. Please include within your response a full description with at least
the following: a) method to establish total capital expenditure budget; b) prioritization and
allocation of that budget to specific and blanket projects; c) reassignment of budget allocations
based upon project variances (if one project is under budget is another project added to expend
those unused dollars or the opposite); d) methodology to determine which projects are high
priority and which can be deferred until the economic climate (or other factors) are improved; e)
asset management transactional process (how projects are entered into that system and ultimately
closed to the general ledger and by whom), and f) other items relevant to the process including a
listing and copy of all documents and reports required and maintained throughout the process.
REQUEST NO. 18: Ifnot included within the response to the previous request, please
identify all forms/studies/analyses required to substantiate the need for a project, including but
not limited to, cost-benefit analyses and offsetting savings/revenues.
REQUEST NO. 19: If not included in response to the previous two requests, please
describe the Internal Rates of Retum (IRR) studies that the Company performs indicating
SECOND PRODUCTION REQUEST
TO AVISTA 3 APRIL 28, 2010
projects wil produce a reduction in future costs. Please identify whether IRRs are a requirement
of the capital expenditure process, how they are performed, documented and utilzed.
REQUEST NO. 20: Please provide a matrix identifying the major capital expenditure
approval levels that includes the dollar level of authorization by employee title, division and
company. Please include within your response the dollar level at which individual capital
expenditure projects require approval by the Board of Directors or highest threshold of approvaL.
REQUEST NO. 21: Please provide the Capital Budget Group Year to Date (YTD)
Actuals Capital budget spreadsheets for the calendar years ended 2006, 2007, 2008 and 2009
with a printout provided and the underlying electronic fie in Excel format with formulas
activated.
REQUEST NO. 22: Please provide the monthly Capital Budget Group Year to Date
(YTD) Actuals Capital budget spreadsheets for 2010 to date with a printout provided and the
underlying electronic fie in Excel format with formulas activated. Please consider this an
ongoing request and provide updates to these spreadsheets for the remainder of the case.
REQUEST NO. 23: Please provide the electronic spreadsheet (in Excel with formulas
activated) underlying Exhibit No.9, Schedule 2 that contain the amounts per capital expenditure
category graphed. If previously provided, please provide a detailed reference to the previously
provided information.
REQUEST NO. 24: Please provide a schedule that identifies the expected Date in
Service of all 2010 capital projects included within the Company's case, the budgeted
expenditures, actual expenditures to date and identify the source of this information for each
project. Please consider this an ongoing request and provide all updates to those dates in service
and expenditures during the course of this case. Please provide the printout of this information
and the underlying electronic fie in Excel format with formulas activated.
SECOND PRODUCTION REQUEST
TO AVISTA 4 APRIL 28, 2010
REQUEST NO. 25: Please provide all materials prepared and used to project the costs
of 20 1 0 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. 26: Please provide an updated schedule of the 2009 capital additions as
proposed in Case Nos. AVU-E-09-1 and AVU-G-09-1 that includes the following by project:
a. planed dates in service as proposed in those rate cases,
b. actual dates in service,
c. budgeted capital expenditures as proposed in thQse rate cases, and
d. actual capital expenditures incured.
REQUEST NO. 27: Please provide an updated schedule of the 2008 capital additions as
proposed in Case Nos. AVU-E-08-1 and AVU-G-08-1 that includes the following by project:
a. planed dates in service as proposed in those rate cases,
b. actual dates in service,
c. budgeted capital expenditures as proposed in those rate cases, and
d. actual capital expenditures incurred.
REQUEST NO. 28: Please provide capital project reports, printouts and electronic
versions in Excel format with formulas activated, by project, which include 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. Please
provide a report(s) for each project greater than $500,000 on Exhibit No.9, Schedule 3 with
costs assigned and/or allocated to Idaho.
REQUEST NO. 29: Please provide capital project reports, printouts and electronic
versions in Excel format with formulas activated, by project, which include 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. Please
SECOND PRODUCTION REQUEST
TO AVISTA 5 APRIL 28, 2010
provide a report(s) for each project greater than $500,000 in Case No. AVU-E-09-1 on Exhibit
No.9, Schedule 2 with costs assigned and/or allocated to Idaho.
REQUEST NO. 30: Please describe the method A vista uses to track the cost of
materials and equipment that it routinely uses. Reference DeFelice, p. 11, lines 4-8.
REQUEST NO. 31: Please provide a copy of the most recent analysis performed by the
Company of costs accounted through its inventory system. Reference DeFelice, p. 11, lines
9-15.
REQUEST NO. 32: Please describe the methodology for the study referenced in
,
witness DeFelice's testimony, p. 12, lines 12-15 and p. 13, lines 1-16. Please include a copy of
the study within your response.
REQUEST NO. 33: Please identify all costs associated with issuing the RFP for
Washington qualified renewable energy described by witness Storro, p. 10, lines 1-5. Please
include within your response how those costs were assigned/allocated to Washington and Idaho
(if any) and the total amounts recorded by account posted. If any costs were assigned/allocated
to Idaho, please describe in detail the benefit received by Idaho ratepayers associated with this
cost.
REQUEST NO. 34: Please identify all costs associated with Avista's proposed Reardan
wind project including, but not limited to, the rights to develop the project, leases, permits, and
wind studies. Please include within your response how those costs were assigned/allocated to
Washington and Idaho (if any) and the total amounts recorded by account posted by year. Please
also identify separately within your response how these costs were excluded from the general
rate case fied amounts. Reference Storro p. 10, lines 6-23 and p. 11, lines 1:19.
REQUEST NO. 35: Please provide the details of any sales of land and/or plant during
2009. Please include within your response the accounting treatment of those sales.
SECOND PRODUCTION REQUEST
TO AVISTA 6 APRIL 28, 2010
REQUEST NO. 36: Please provide details of any planed sales of land and/or plant
during 2010. Please provide in those details the planed date of disposition and the proposed
accounting treatment.
REQUEST NO. 37: Please calculate the revenue requirement requested in this case
associated with the April 2011 Noxon Upgrade for Unit #2. Please include within your response
the underlying electronic fie with formulas activated that identifies each revenue requirement
component and the source of the underlying data by account and amount.
REQUEST NO. 38: Please provide reports, printouts and electronic versions in Excel
format with formulas activated, by year, which include at least the following items for the
Spokane River Relicensing: the project number, expenditure type, vendor description,
transaction description, transaction amount, date posted, document/transaction number, and total
amount posted.
.-Q .,",Dated at Boise, Idaho, this ¡M -day of ApriL.
Ki~I1.. ~4fA._'stine A. Sasser
Deputy Attorney General
Technical Staff: Patricia Harms/1 0-38
i:umisc:prodreq/avue_gl O. I ksrps prod reql.doc
SECOND PRODUCTION REQUEST
TO AVISTA 7 APRIL 28, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF APRIL 2010,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA, IN CASE NOS. AVU-E-I0-0l_AVU-G-10-01, BY
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: david.meyer(iavistacorp.com
PETER J RICHARDSON
GREG M ADAMS
RICHARDSON & O'LEARY
515 N 27TH ST
BOISE ID 83702
E-MAIL: peter(frichardsonandoleary.com
greg(irichardsonandoleary.com
DEAN J MILLER
MCDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(fmcdevitt-miler.com
ROWENA PINEDA
ID COMMUNITY ACTION
NETWORK
3450 HILL ROAD
BOISE ID 83703
E-MAIL: Rowena(iidahocan.org
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
KELL YO NORWOOD
VP STATE & FED REG
A VIST A CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: kelly.norwood(favistacorp.com
HOWARD RAY
CLEARWATER PAPER CORP
803 MILL ROAD
PO BOX 1126
LEWISTON ID 83501-1126
E-MAIL: howard.ray(fclearaterpaper.com
LARRY CROWLEY
ENERGY STRATEGIES INSTITUTE
5549 S CLIFFS EDGE AVE
BOISE ID 83716
E-MAIL: crowleyla(faol.com
LEEANNHALL
3518 S EDMUNDS ST
SEATTLE WA 98118
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
POBOX 844
BOISE ID 83701
E-MAIL: botto(fidahoconservation.org
St..CL~ ,kf. .SECRETARY
CERTIFICATE OF SERVICE