20100519AVU to Staff 11 B.pdf

Xan Allen
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Jean Jewell
Wednesday, May 19,201011 :43 AM
XanAllen
FW: Avista's Responses to IPUC Staff Production Requests - 5/19/10
Staff_PR_011 Attachment B.pdf
From: Kimball, Paul (mailto:PauI.Kimball(§avistacorp.com)
Sent: Wednesday, May 19, 2010 11:14 AM
To: Don Howell; KriSSasser; peter(§richardsonandoleary.com; greg(§richardsonandòleary.com;
howard. ray(§c1earwaterpaper .com; joe(§mcdevitt-miler .com; crowleyla(§aol~com; rowena(§idahocan.org;
leeann(§nwfco.org; bmpurdy(§hotmail.com; botto(§idahoconservation.org; kmiller(§snakeriveralliance.org;
robpluid(§gmail.com; energylogs(§gmail.com; oxford(§meadowcrk.com; Jean Jewell; Kathy Stockton; Patricia Harms
Cc: Ehrbar, Pat; Andrews, Liz; Olsness, Patt
Subject: Avista's Responses to ¡PUC Staff Production Requests - 5/19/10
Idaho Public Utilties Commission
t;~c:::~
May 19,2010
472 W. Washington St.
....
-0::Ñ."o0)
Boise, ID 83720-5918
Att: Donald L. Howell, II
Krstine A. Sasser
Re: Production Request of the Commission Staff in Case Nos. A VU-E-lO-Ol and A VU-G-1O-01
Attached is Avista's response in connection to Staff production requests in the above referenced docket.
Included in this email is A vista's response to the following Production Request:
StaffPR 11 (Part 2 of2 (Part 2 is Attachment B))
C:C:Staff_PR_011 Attachment B.pdf~~
If there are any questions regarding the attached information, please contact me at [phone] or via e-mail
at pau1.kimballcgavistacorp.com
Than you,
Paul Kimbal
Senior Regulatory Analyst
State & Federal Regulation
A vita Corporation
1411 E. Mission Ave, Box 3727
i
Spokane, W A 99220-3727
[phone] diect
[phone] cell
pauL. kimball(javistacorp. com
2
Docket UE-090134 and UG-090135
UTC Staff Data Request Nos. 1- 27 to Avista
Februar 5, 2009
Page 1
UTC STAF DATA REQUEST NO. 1:
a. Please provide copies of any and all data requests submitted to you by any par
to ths proceeding and your corresponding responses to those data requests.
b. Please provide copies of any and all data requests submitted to you by the Idao
Public Utility Commssion in Case Number A VU-E-09-01.
UTC STAFF DATA REQUEST NO.2:
Please provide a Cha of Accounts for A vista Utilities of all accounts (detaed by sub-
account) with a balance durg the test year in Excel or Access format.
UTC STAFF DATA REQUEST NO.3:
Please provide a columar, 12-month detailed (by sub-account) income statement in Excel
format for Avista Utilties' electric operations for the test period, with the 13th colum
showig the tota for the test year for each sub-account, and the 14th colum showing the
budgeted amount for each sub-account for the test year. The 15th colum should show the
varance amount and the 16th colum showing the varance percentage. For each priar
FERC account provide a columar total.
UTC STAFF DATA REQUEST NO.4:
Please provide a colum, 12-month detailed (by sub-account) income statement in Excel
format for Avista Utilities' natul gas operations for the test period, with the 13th colum
showing the total for the test year for each sub-account, and the 14th colum showing the
budgeted amount for each sub-account for the test year.The 15th colum should show the
varance amount and the 16th colum showing the varance percentage. For each priar
FERC account, provide a columar total.
UTC STAFF DATA REQUEST NO.5:
Please provide a columnar, 13-month detailed (by sub-account) balance sheet in Excel
format for Avista Utilities for the test period, with the 14th colum showing the average of
monthly averages (AM) for each sub-account, with a columar total for each priar
FERC account. The 15th Colum should show the Average Monthy Average Balance from
the prior calendar year with the 16th colum showing the change amount and the 17th colum
showig the percentage chage from the prior calenda year.
StafCPR_011 Attachment B Page 1 of264
Docket UE-090134 and UG-090135
UTC Staff Data Request Nos. 1- 27 to Avista
Februar 5, 2009
Page 2
UTC STAFF DATA REQUEST NO.6:
Please provide all officers' employee numbers, names, job titles, detailed job descriptions,
responsibilities, base salares, and other compensation by year beging with Calenda Year
2007.
UTC STAFF DATA REQUEST NO.7:
Please provide detais of all bonus plans included in the test period and the criteria and goals
used to grant employee bonuses.
UTC STAF DATA REQUEST NO.8:
Please provide all offcers' salares for the last two year for each offcer by month and
please itemie by base salar, bonuses, and benefits, along with the amount included in test
year and the amount paid for by shareholders.
UTC STAFF DATA REQUEST NO.9:
Please explain the basis for an officers' salary increases from the 2006 level to the 2007
leveL. Also, please provide all documents that are relevant to ths inquir.
UTC STAFF DATA REQUEST NO. 10:
Re: Customer Deposits
a. Please provide the test year average of the monthy averages of Washigton retail
jursdictional electrc and natu gas customer deposits as well as the amount of
interest paid on Washigton retail jursdictional electrc and natual gas customer
deposits durg the historic test year;
b. Please provide an allocation of Washigton customer deposits to services, ifnot
separately tracked;
c. Please identify the electrc workpaper and the natu gas workpaper that details
the amount of on customer deposits.
UTC STAFF DATA REQUEST NO. 11:
Re: Vegetation Management
a. Please provide the actul anua vegetation mangement expenditues incured
by the Company for the last thee years beging 2005, by jursdiction
(Washigton and Idao) and by fuction (trsmission and distrbution);
StafCPR_011 Attachment B Page 2 of 264
Docket UE-090134 and UG-090135
UTC Staff Data Request Nos. 1 - 27 to A vista
Febru 5, 2009
Page 3
b. Please provide the actul monthy vegetation mangement expenditues incured
by the Company for the last thee years beging 2005, or latest available, by
jursdiction (Washigton and Idaho) and by fuction (transmission and
distrbution);
c. Please provide a budget versus an actul varance analysis for the expenditues
requested in par b. of ths data request.
UTC STAFF DATA REQUEST NO. 12:
a. Please provide copies of al report on A vista by ratig agencies for the last thee
years.
b. Please provide copies of all reports on A vista by securty analysts for 2007 to the
present.
c. Please provide a schedule that lists the securty ratings of A vista for 1995 to the
present.
UTC STAFF DATA REQUEST NO. 13:
Please provide copies of ratig agency reports stating reasons for any rating chage in
A vista for 2000 to the present.
UTC STAFF DATA REQUEST NO. 14:
Please provide a schedule tht shows the capital strctues (common equity, preferred stock,
long-term debt, and short-term debt) by year for 2003 though 2008 and the most recent date
for which data is avaiable.
UTC STAFF DATA REQUEST NO. 15:
Please provide a curent organational cha for A vista that shows each of its subsidiares.
UTC STAFF DATA REQUEST NO. 16:
Please identify each instance since 2001 in which A vista has had a public offerig of
common stock. Also, please provide the amount of issuace costs associated with each
issuace.
StafCPR_011 Attchment B Page 3 of 264
Docket UE-090134 and UG-090135
UTC Staff Data Request Nos. 1- 27 to Avista
Febru 5, 2009
Page 4
UTC STAFF DATA REQUEST NO. 17:
Please provide an estimate of the anticipated public offerings of Avista's common stock
over the next five year.
UTC STAFF DATA REQUEST NO. 18:
Please provide a copy of the Company's weather normalization model, including all
supporting workpapers, in a workable electronic format, with all formulae intact, as well as
any hardware necessar to ru the modeL.
UTC STAFF DATA REQUEST NO. 19:
Please provide a listig of all penalties and fIDes included in the test year, citing the accountit is located in, the payee, and the amount. -
UTC STAFF DATA REQUEST NO. 20:
Please provide a listing of any costs included in the test year related to sporting or
entertinent events, includig but not limted to season tickets or sky boxes. If applicable,
please include any explantion as to the business purose.
UTC STAFF DATA REQUEST NO. 21:
Please provide a listig of all chartable contrbutions, including names and amounts,
included in the test year.
UTC STAF DATA REQUEST NO. 22:
Please provide a listing of dues or membership fees included in the test year, and please
include in the response the percent of dues or fees related to lobbyig or political activities.
. UTC STAFF DATA REQUEST NO. 23:
a. Please provide a listig of new large customers that have staed receiving
service with the last 12 month but are only parally reflected in the test year.
Provide: nae of customer, revenue and usage in test year, and expected anual
revenue and usage levels.
StafCPR_011 Attachment B Page 4 of 264
Docket UE-090134 and UG-090135
UTC Staff Data Request Nos. 1- 27 to Avista
Febru 5, 2009
Page 5
b. Please provide a listing of new large customers that wil begi receiving service
withn the next 12 month. Provide: name of customer, expected anual revenue
amounts and expected anual usage levels.
c. Please provide a listig and the related documents to any specific "power supply"
argements or acquisitions tht may have been made related to any new large
customers with the last two years.
UTC STAFF DATA REQUEST NO. 24:
Please provide a copy of the corporate federal tax returns and supporting "M" schedules for
2006, 2007 and 2008.
UTC STAFF DATA REQUEST NO. 25:
Please provide detailed calculations of federal income taes (budgeted and/or actul) for the
following accountig periods:
a. the yea ended December 31, 2006 (actu)
b. the year ended 2007 (actul)
UTC STAFF DATA REQUEST NO. 26:
For the last two years, please provide a copy of the u.s. Corporation Income Tax Retu.
UTC STAFF DATA REQUEST NO. 27:
Please explain any chages in accounting for GAA or FERC in the last thee years. ÌIclude
a copy of any narative incorporated in the Company's notes to its fInancial statements and
or FERC anual reports contemporaneous with the chage in accountig.
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 5 of 264
Docket UE-090134 and UG-090135
UTC Sta Data Request Nos. 28-33 to Avista
February 9, 2009
Page 1
UTC STAFF DATA REQUEST NO. 28:
Please provide a copy of the most recent actuaral studies of Avista'spension and post-
retirement benefits plans for the latest five years. Provide the actuarial studies of Avista's
pension and post-retiement benefits plan for 2009 when avaiable.
UTC STAFF DATA REQUEST NO. 29:
Re: Pension expense per Exhibit No. _ (MT-IT) at 34:1-14
a. Please provide the pension obligation, the fuding level, and the percentage of
fuding level to pension obligation for the years presented in Ilustrtion NO.7
on page 36.
b. Please provide the calculation of the 2008 and 2009 cash contrbutions to the
pension plan per the Penion Protection Act.
UTC STAFF DATA REQUEST NO. 30:
Re: Pension expense per Exhibit No. _ (MT-IT) at 35: 4-6
Please explain the differences between the F AS 87 assumptions and the calculations used to
determine the fuded status per the Pension Protection Act.
UTC STAFF DATA REQUEST NO. 31:
Re: Pension expense per Exhibit No. _ (MTT-IT) at 36, mustration No.7:
a. Please provide work papers showing the derivation of the pension expense for
the year 2005 though 2009. If the penion expense recorded for fiancial
reportg differs from Ilustrtion No.7, please state the difference and explain.
b. Please state the dates and amounts of cash contrbutions to the pension plan for
the years 2005 though 2009.
UTC STAFF DATA REQUEST NO. 32:
Re: Pension expense
a. Please describe and quatify the effects the change in the measurement date per
FASB 158 on Avista's finacial reportg for each year affected by FASB 158, if
any.
b. Is the implementation ofFASB 158 included in the preliin determintion of
the 2009 pension and post-retiement benefit expenes?
c. If so, present the porton of the 2009 expense relating to F ASB 158 and the
portion relatig to pension and post-retiement benefit expenses for the four
quarers of 2009.
StafCPR_011 Attachment B Page 6 of 264
Docket UE-090134 and UG-090135
UTC Staf Data Request Nos. 28-33 to Avista
Februar 9,2009
Page 2
UTC STAFF DATA REQUEST NO. 33:
Re: Pension fund returns
a. What long-term retu on assets was used to determe the pension expense for
each year in Ilustrtion NO.7 on page 361 When the inormation becomes
available, provide the long-term retu on assets for the 2009 pension expense.
b. What retu on pension assets was achieved in each year presented in Ilustration
No. 7 on page 361 When the information becomes available, provide the actul
retu on assets for the 2009.
c. What discount rate on the pension benefit obligation was used to determine the
pension expense for each year in Ilustrtion NO.7 on page 361 When the
inormation becomes available, provide the discount rate used for the 2009
pension expense.
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 7 of 264
Docket UE-090134 and UG-090135
UTC Staff Data Request Nos. 34 - 51 to Avista
Febru 25, 2009
Page 1
UTC STAFF DATA REQUEST NO. 34:
RE: Testimony of Dave B. DeFelice
Referrg to the description of capita projects beging on page 10 of the direct testiony,
please indicate what projects listed under "Generation" and "Electric Transmission" have
been completed to date. Please provide a status report for each of the projects listed if they
have not been completed and any updates on the actual costs of the project. Please continue
to update ths information durg the rate proceeding process.
UTC STAFF DATA REQUEST NO. 35:
RE: Testimony of Dave B. DeFelice
Please indicate the actual amounts expended to date on the item referred to as WSDOT
Highway Frachise Consolidation on page 14 of your testiony as of the date of receiving
ths request.
UTC STAFF DATA REQUEST NO. 36:
RE: Testimony of Dave B. DeFelice
Referg to the description of capital projects beging on page 10 of the direct testiony,
please provide all cost-benefit anlyses that the Company prepared for each of the projects
listed under "Generation" and "Electric Transmission." Please indicate how additional
revenues were accounted for in the Company's rate fiing for each of the projects listed.
UTC STAFF DATA REQUEST NO. 37:
RE: Testimony of Dave B. DeFelice
Please provide the latest status of the Noxon Unit #3 Upgrde, including any updates to the
completion date.
UTC STAFF DATA REQUEST NO. 38:
RE: Testimony of Dave B. DeFelice
Did the Company consider delayig any of the capital projects described in your testimony
as a result of the general overall economic conditions being experienced by customers and
the magntude of the proposed genera rate increases?
StafCPR_011 Attchment B Page 8 of 264
Docket UE-090134 and UG-090135
UTC Staff Data Request Nos. 34 - 51 to Avista
Febru 25, 2009
Page 2
UTC STAFF DATA REQUEST NO. 39:
RE: Testimony of Elizabeth M. Andrews
Please provide the latest updates to the Company's pro forma retail load forecast. Referg
to the discussion regarding pro forma retail loads on page 8 of your testiony, is the
Company expectig no changes to pro forma retal loads as a result of the general economic
conditions of the region? Please indicate the net effect on power supply expense of the
Company's pro forma increase in retail loads.
UTC STAFF DATA REQUEST NO. 40:
RE: Testimony of Eliabeth M. Andrews
Referrg to the discussion of the Pro Forma Noxon Generation 2010 on pages 25-26 of
your testiony, please indicate the change in power supply expense due to the inclusion of
ths project in the rate period. Please indicate the overall rate effect of including the project
in the rate period.
UTC STAFF DATA REQUEST NO. 41:
Re: Testimony of Richard L. Storro
Please provide copies of all presentations to the Company's Board of Directors relating to
the acquisition of the Lancaster Power Purchase Agreement (PP A).
UTC STAFF DATA REQUEST NO. 42:
Re: Testimony of Richard L. Storro
Referg to the Lancaster PP A, is the Company's available firm gas transporttion capacity
suffcient to meet the baseload requirements of the Lacaster PP A on a daily, monthy, and
anua basis?
UTC STAFF DATA REQUEST NO. 43:
Re: Testimony of Richard L. Storro
Please provide all cost-benefit analyses that were cared out by the Company or its agents,
regarding the Noxon Unit #1 and #3 upgrades. Please provide a status report on the progress
of both projects, as well as an updated completion date for each.
StafCPR_011 Attachment B Page 9 of 264
Docket UE-090134 and UG-090135
UTC Staff Data Request Nos. 34 - 51 to A vista
Februar 25,2009
Page 3
UTC STAFF DATA REQUEST NO. 44:
Re: Testimony of Richard L. Storro
Referrg to the discussion on Generation Plant Operation and Maintenace (O&M)
anlyses beging on page 23 of your testiony, please provide all documents, studies, and
anlysis related to the Colstrp, Kettle Fals, and Rathdr CT O&M amounts tht the
Company has included as par of its pro forma costs. Is the Company proposing to include
the Rathdrm CT "hot gas path maintenance" costs projected to be expended in 2010 and
2011 as pro forma O&M costs in ths proceedg?
UTC STAFF DATA REQUEST NO. 45:
Re: Testimony of Richard L. Storro
Please provide all documents, studies, and anlysis related to the Colstrp mercur emssions
pro forma costs as described in your testiony on page 24. Given that your testiony states
that the curent capital budget is expected to be sufficient to meet the requirements for ths
project, please explain the need for a pro forma period adjustment in ths proceedig.
UTC STAFF DATA REQUEST NO. 46:
Re: Testimony of Scott J. Kiney
For each of the Trasmission and Distrbution Capita Projects described beging on page
12 of your testiony, please provide all cost-benefit analyses prepared by the Company or
its agents. Please specifically identify any increases in revenues or decreases in costs as a
result of each project described in the testimony and included in pro forma period costs.
UTC STAFF DATA REQUEST NO. 47:
Re: Testimony of Scott J. Kiney
For each of the Tramission and Distrbution Capital Projects described in your testiony
beging on page 13. and contiuig though page 18, please provide any updates to the
actul or expected completion dates and any actul or projected chages to the completed
cost.
UTC STAFF DATA REQUEST NO. 48:
Re: Testimony of Clit G. Kalich
Please re-ru the Dispatch Model and provide the chage in net power supply cost from
removing the Noxon Unit #3 upgrde that is projected to be completed in 2010.
StafCPR_011 Attachment B Page 10 of 264
Docket UE-090134 and UG-090135
UTC Staf Data Request Nos. 34 - 51 to A vista
Febru 25, 2009
Page 4
UTC STAF DATA REQUEST NO. 49:
Re: Testimony of Clint G. Kalich
Please re-ru the Dispatch Model and provide the change in net power supply cost from
updatig the input natual gas prices based on the latest available forecast consistent with the
methodology used in the Company's fiing.
UTC STAFF DATA REQUEST NO. 50:
Re: Testimony of Clint G. Kalich
Please re-ru the Dispatch Model and provide the change in net power supply cost resulting
from incorporating the Company's latest available load forecast for rate period loads. Please
re-ru the Dispatch Model and provide the chage in net power supply cost resultig from a
1 % reduction (across all hours) of retail load as compared to the Company's fied rate period
loads.
UTC STAFF DATA REQUEST NO. 51:
Re: Testimony of Wiliam G. Johnson
Please determine and provide the chage pro-forma net power supply cost from
implementing the ''water fitering" methodology adopted by the parties in the Company's
last general rate case settement.
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 11 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 52-61 to Avista
March 10, 2009
Page 1
UTC STAFF DATA REQUEST NO. 52:
RE: Testimony of Wiliam G. Johnson
Referrg to the Power Supply pro forma workpapers, page 2, please provide the basis for
includig short-term fiancial tractions as an adjustment for the pro forma period.
UTC STAFF DATA REQUEST NO. 53:
RE: Testimony of Wilam G. Johnson
Referrg to the Power Supply pro forma workpapers, page 4, please provide the basis for
the escalation rate (2.9%) used to adjust actul year Rocky Reach expenses.
UTC STAFF DATA REQUEST NO. 54:
RE: Testimony of William G. Johnson
Referrg to the Power Supply pro forma workpapers, page 6, please provide the basis for
the escalation rate of 4.99 percent, parcularly given tht the Colvile shae agreement
appears not to conta any escalation factor over its ter.
UTC STAF DATA REQUEST NO. 55:
RE: Testimony of Wilam G. Johnson
Referrg to the Power Supply pro forma workpapers, pages 20 and 22, are the actul year
fixed capacity payments adjusted or tred up to reflect actual availability factors? If not,
why not? If they are tred up, wil those actul expense adjustments be reflected in the
ERM? Please answer the same questions as they relate to the varable O&M payments.
UTC STAFF DATA REQUEST NO. 56:
RE: Testimony of Willam G. Johnson
Referrg to the Power Supply pro forma workpapers, page 45, please provide the historical
payments over the last five years for expenses related to purhaing spining reserves durig
the high ruoff period. How are the most recent resoure acquisitions incorporated into the
need for additional sping reserves and the estiates for ths expense?
UTC STAFF DATA REQUEST NO. 57:
RE: Testimony of William G. Johnson
Referrg to the Power Supply pro forma workpapers, pages 47 though 51, please discuss
the need to acquire or maintai the renewable tags for the Washigton jursdiction. If not
needed, are these expenses offset by any additional revenues from selling the renewable
tags?
StafCPR_011 Attachment B Page 12 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 52-61 to Avista
March 10, 2009
Page 2
UTC STAFF DATA REQUEST NO. 58:
RE: Testimony of Wiliam G. Johnson
Referrg to the Power Supply pro forma workpapers, page 52, what is the basis for
including broker fees for the pro forma year at the same level as 2008 expenses? Are these
payments "known and measurable" for the pro forma year? Please provide the broker
payment amount for the last five years.
UTC STAFF DATA REQUEST NO. 59:
RE: Testimony of William G. Johnson
Referrg to the Power Supply pro forma workpapers, pages 63 and 64, please update the
CS2 gas trsportation costs reflecting any changes in actual or forecasted trsporttion
ratês, and also exchage rates. Does the pro forma power supply expense amount reflect
any revenue from capacity releases? Please answer the same questions as they relate to
Lancaster gas trporttion expenses, indicated on page 67 of the workpapers.
UTC STAFF DATA REQUEST NO. 60:
RE: Testimony of William G. Johnson
Referrg to the Power Supply pro forma workpapers, pages 98 though 100, please reru
the AURORA model to determine the effect on normalized power supply expense of
inclusion of the gross revenues of the SMU sale as well as the energy obligation. The
intent is to explore whether there are any additional benefits of the sale from utilizing the
company's fesource portfolio father than assuming that all energy obligations wil be met
though indexed pricing.
UTC STAFF DATA REQUEST NO. 61:
RE: Testimony of Wiliam G. Johnson
Referrg to the Power Supply pro forma workpapers, page 78, is the payment for PTP
wheeling for Lancaster a fixed payment for each month, or is the actual payment adjustment
to account for the actual energy from the facility?
GREGORY J. TRAUTAN
Assistat Attorney General
StafCPR_011 Attachment B Page 13 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 62-66 to Avista
March 11, 2009
Page I
UTC STAFF DATA REQUEST NO. 62:
On Exhbit No. _(TLK.2), Line 1, please provide the source of the $159,899 revenue
amount and the $615,840 rate base.
UTe STAFF DATA REQUEST NO. 63:
Starting May 2008, Tempora Investments increased by over $200 millon, and then
decreased once agai in March. Please explain the reason for the increase and the
subsequent decrease.
UTC STAFF DATA REQUEST NO. 64:
Staing May 2008, the Long Term Debt increased by over $292 milion and then decreased
once agai in Marh. Please explain the reason for the increae to Long Term Debt and the
subsequent decrease.
UTC STAFF DATA REQUEST NO. 65:
Please provide any reports, sumares, memos, discussions and presentations, prepared
from January 2008, to present, that provide explanations of, are related to, or provide
analysis of cost to budget varances experienced in 2007 though 2008.
UTC STAFF DATA REQUEST NO. 66:
Please discuss the impact on A vista of the recently enacted federal stimulus package. Please
include discussion on possible fudig of curently budgeted projects, and any creation of
new projects not contemplated prior to the passage of the federal stiulus package.
GREGORY J. TRAUTMAN
Assistat Attorney General
Staff_PR_011 Attachment B Page 14 of 264
Dockets UE-090134 and UG-090135
UTC Sta Data Request Nos. 67-68 to Avista
March 20, 2009
Page 1
UTC STAFF DATA REQUEST NO. 67:
Re: Pension expense response to UTC Staff data request No. 30:
Please be more specific in how the IRS derives the interest rate used to determe the fuded
status per the Pension Protection Act, and identify any options A vista has to meet the IRS
requirements.
UTC STAFF DATA REQUEST NO. 68:
Re: Pension expense response to UTC Staff data request No. 30:
Please state how the interest rates determed by F AS 87 and by the IRS are applied to
determine the pension benefit obligation.
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 15 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 69-70 to Avista
March 24, 2009
Page 1
UTC STAFF DATA REQUEST NO. 69:
Re: Pension expense response to UTC Staff data request No. 30:
Is Avista's Supplemental Executive Retirement Plan included as a utilty expense to be
recovered in rates?
UTC STAFF DATA REQUEST NO. 70:
Re: Pension expense response to UTC Staff data request No. 30:
Is Avista's Income Continuation Plan included as a utility expense to be recovered in rates?
If yes, please provide an explanation of the plan and a list of the employees who benefit
from the plan.
GREGORY J. TRAUTMA
Assistat Attorney General
StafLPR_011 Attachment B Page 16 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 71-87 to Avista
April 1, 2009
Page 1
UTC STAFF DATA REQUEST NO. 71:
Please provide a copy of the following Avista documents:
a. 2008 Anual Report to Stockholders
b. 2008 Statistical Supplement to Anual Report
c. 2008 Form 10-K
d. Most recent prospectus for sale of common stock
e. Most recent prospectus for sale oflong-term debt
UTC STAFF DATA REQUEST NO. 72:
Please provide a copy of all reports on A vista by ratig agencies for the period 2007 to the
present.
UTC STAFF DATA REQUEST NO. 73:
Please provide a copy of all reports on A vista by securty analysts for the period 2007 to the
present.
UTC STAFF DATA REQUEST NO. 74:
Please provide a schedule that lists the securty ratigs of A vista for the period 1995 to the
present.
UTC STAFF DATA REQUEST NO. 75:
Please provide a copy of rating agency reports stating reasons for any ratig change in
Avista for the period 1995 to the present.
UTC STAFF DATA REQUEST NO. 76:
Please provide a schedule that shows the capita strctues (common equity, preferred stock,
long-term debt and short-term debt) for each year 2003-2008, and the most recent date for
which data is available for A vista.
UTC STAFF DATA REQUEST NO. 77:
Please provide an organzational cha. for A vista that shows each of its subsidiares.
UTC STAFF DATA REQUEST NO. 78:
Please identify each instace in which A vista has had a public offering of common stock
since 2000. Please also provide the amount of issuance costs associated with each issuace.
StafCPR_011 Attachment B Page 17 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 71-87 to Avista
April 1,2009
Page 2
UTC STAFF DATA REQUEST NO. 79:
Please provide an estiate of the anticipated public offerigs of common stock of A vista
over the next five years.
UTC STAFF DATA REQUEST NO. 80:
Re: Testimony of Wilam E. Avera
Please provide a list of all the cost of capita testionies submitted by Dr. Avera for the
period 2000 to the present. For each of these testionies, please provide the following
information:
a. Name of company
b. Name of reguatory agency
c. Date of testimony
d. Retu on equity recommended
e. Retu on equity adopted
UTC STAFF DATA REQUEST NO. 81:
Re: Testimony of Mark T. Thies
Please provide a list of all the rate of retu testimonies submitted by Mr. Thies for the
period 2000 to the present. For each of these testimonies, please provide the following
information:
a. Name of company
b. Name of regulatory agency
c. Date of testiony
d. Retu on equity recommended
e. Retu on equity adopted
UTC STAFF DATA REQUEST NO. 82:
Re: Testimony of William E. Avera
Please identify each testiony in the prior response in which Dr. Avera concluded that the
subject company has less risk than his proxy group.
UTC STAFF DATA REQUEST NO. 83:
Re: Testimòny of Wilam E. Avera
Please indicate the anual revenue requiements tht would be associated with the approval
of Dr. Avera's proposed flotation cost adjustment for Avista.
StafCPR_011 Attchment B Page 18 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 71-87 to Avista
April 1, 2009
Page 3
UTC STAFF DATA REQUEST NO. 84:
Re: Testimony of Wiliam E. Avera
Please provide source documents cited in footnotes 3,5,6, 7, 8, 9, 10, 11, 14, 15, 16, 17, 18,
19,20,22,23,26,28,29,30,34,35,36,37,38,40,41,42, 43, 44, 45, 48, 49,51,52,53,
55, 56, 57, and 63.
UTC STAFF DATA REQUEST NO. 85:
Re: Testimony of Wiliam E. Avera
Please provide a table simlar to Exhbit No. _(WEA-4) tht shows short-term and long-
term debt for the utility proxy group.
UTC STAFF DATA REQUEST NO. 86:
Re: Testimony of Willam E. Avera
Please describe the parameters for "ilogical low- and high-end values" as referenced on
page 39 of Exhibit No. _(WA-lT).
UTC STAFF DATA REQUEST NO. 87:
Re: Testimony of Wiliam E. Avera
Where not included in the response to 84 above, please provide a copy of the source
documents used in preparg Exhibit No. _(WEA-4), Exhbit No. _(WEA-5), Exhibit No.
-,(WEA-6), Exhbit No. _(WEA-7), Exhibit No. _(WEA-8), Exhbit No. _(WEA-9),
Exhbit No. _(WEA-1O), and Exhibit No. _(WEA-l 1).
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 19 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 88-90 to Avista
April 2, 2009
Page 1
UTC STAFF DATA REQUEST NO. 88:
RE: Testimony of Brian J. Hirschkorn
Referrg to Brian J. Hirschkom' s direct testimony, Exhbit No. _ (BJH -1 T), page 19,
lines 18-22, he states that the proposed average increase to Schedule 146 is 0.8%. However,
the table in Exhbit No. _ (BJH-7), page 2 of 3, shows that the Schedule 13 1 average
increase is 0.8% and the Schedule 146 average increase is 6.8%. Please clarify the apparent
difference in the average increase to Schedule 146.
UTC STAFF DATA REQUEST NO. 89:
RE: Testimony of Brian J. Hirschkorn
Referg to Brian J. Hirschkom's direct testimony, Exhbit No. _ (BJH-IT) on page 23,
lines 15- 1 6, he states that "This methodology maintain the present relationship between the
schedules, and will minize customer shifting." (emphasis provided)
(a) On page 23, lines 12-15, Mr. Hirschkom describes the mathematical
derivation of the proposed increase to Schedule 1 1 1. Other than the
derivation aleady described, please provide fuer clarfication of the
methodology he refer to on line 15.
(b) Please indicate whether the same methodology referrd to on line 15 was
used in the electrc operation to reach the same cited goals as discussed in
Avista's gas operations.
(1) If so, please explain where the methodology was used, and specifically,
in what schedules.
(2) If the same methodology was not used, please explain why Avista did
not do so.
UTC STAFF DATA REQUEST NO. 90:
RE: Testimony of Tara Knox, Exhibit Nos._ (TLK-3) and (TLK-6)
Referrg to Tara Knox's Exhbit No._ (TLK-3), page 4 of9, lines 22-23, she states that
for the Electrc Cost of Service Study: "Customer service, customer information and sales
expenses are the core of the customer relations fuctiona unt which is included with the
distribution cost category. For the most par, they are classified as customer related.
Exceptions are sales expenses which are classified as energy related." However, for the Gas
Staff_PR_011 Attachment B Page 20 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 88-90 to A vista
April 2, 2009
Page 2
Cost of Service Study, sales expenses are "common costs" and classified as "customer
related costs." Tara Knox Exhibit No._ (TLK-6), page 1 of9, lines 11-14. Please
explai the different treatment for the electrc and gas cost of service studies, and provide
the rationale and supportg documents for the different treatment.
GREGORY J. TRAUTM
Assistat Attorney General
StafCPR_011 Attachment B Page 21 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 91-100 to Avista
April 14,2009
Page 1
UTC STAFF DATA REQUEST NO. 91:
Re: Pro Forma Labor-NoD-Exec
Please provide copies of the contrts tht support the Union (4.0%) and Adm (3.8%)
increases identified on workpaper pages PF3s (Electrc) and PF14 (Gas).
UTC STAFF DATA REQUEST NO. 92:
Re: Pro Forma Labor-NoD-Exec
a) Has the 3.8% increase, on workpaperpages PF3s (Electrc) and PF14 (Gas), listed
under UNION as "2010 increase for 2010 adjustment," been approved?
b) If so, please provide copies of the contracts tht support ths adjustment.
UTC STAFF DATA REQUEST NO. 93:
Re: Pro Forma Labor-NoD-Exec
a) Has the 3.8% increase, on workpaper page PF3s (Electrc) and PF14 (Gas), listed
under ADMIN as "2010 increase for 2010 adjustment," been approved by the Board
of Directors?
b) If so, please state the date of approval.
UTC STAFF DATA REQUEST NO. 94:
Re: Pro Forma Labor-Executive
a) Please provide the market data for salares, performance incentives, and benefits
referred to in Ms. Andrews's testimony, Exhibit No. _(EMA-lT), page 23, lines
12-14.
b) Please provide the support for evaluatig the total compensation and benefits
packages and how these are considered to be at market leveL.
UTC STAFF DATA REQUEST NO. 95:
Re: Pro Forma Labor-Executive
a) Please provide copies of the Compenation Commttee recommendations for
executive increases for each of the last thee year.
b) Please provide al presentations made to the Compensation Committee for each of
the last three years. If any presentations were oral, please provide a detailed, written
sumar of each ora presentation.
StafCPR_011 Attachment B Page 22 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 91-100 to Avista
April 14,2009
Page 2
UTC STAFF DATA REQUEST NO. 96:
Re: Pro Forma Labor-Executive
a) Please provide documentation to support the numbers listed under Electric WA, on
workpaperpage PF3ii (Electrc) of $88,409 and $1,301,176.
b) Please provide documentation to support the numbers listed under Gas North WA, on
workpaperpage PF3ii (Electrc) of $359,641 and $27,295.
UTC STAFF DATA REQUEST NO. 97:
Re: Pro Forma Coeur d'Alene Tribe Settlement
Please provide a copy of the Coeur d' Alene Tribe Settlement Agreement.
UTC STAFF DATA REQUEST NO. 98:
Re: Pro Forma Incentives
a) Please identify the budget amount for the incentive plan for 2008.
b) Please provide for each of the last seven years:
1) the budgeted incentive plan amounts; and
2) the amount of actu incentive plan payouts.
c) Please justify any discrepancies between the budgeted amounts and the incentive
plan payout amounts.
d) Please provide the Company's primar source document that describes terms of the
incentive plan, including what the payout measures or amounts are tied to.
UTC STAFF DATA REQUEST NO. 99:
Re: Pro Forma Incentives
a) Referring to Ms. Andrews's testimony, Exhibit No. _(EMA-IT), page 30, lines 2-
4, please explai the justification for using CPI to adjust actul incentives paid for
the years 2003-2007.
b) In Ms. Andrews testimony, Exhibit No. _(EMA-lT), page 31, lines 1-15, she
discusses". . . other examples where the use of an average has been used. ..." In the
examples provided, did the Company use the CPI to adjust its historical numbers?
c) If yes, please provide a copy of the adjustment that includes the detailed support of
the adjustment and the CPI used and worksheet calculations (in Excel format with
formulae intact) along with the associated docket number.
Staff_PR_011 Attachment B Page 23 of 264
Dockets UE-090134 and UG-090135
UTC Sta Data Request Nos. 91-100 to Avista
April 14,2009
Page 3
UTC STAFF DATA REQUEST NO. 100:
Re: Pro Forma Incentives
a) Please provide documentation to support the allocation factors shown on workpaper
page PF152 (Electrc) and PF72 (Gas), under Allocated to Washigton Electrc and
Allocated to Washigtn Gas, respectively.
b) On these same workpapers, what is meant by "Note 7" and "Note 4?"
GREGORY J. TRAUTM
Assistat Attorney General
StafCPR_011 Attachment B Page 24 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 10 1 - 104 to A vista
April 16,2009
Page 1
UTC STAFF DATA REQUEST NO. 101:
a) Please explain why replacement costs were used in the peak credit method to allocate
costs in the Electrc Cost of Service, refered to on Tar Knox workpaper, page
TLK-E-86. Please provide supportg documents.
b) Why did A vista not use embedded cost of plants to calculate demand and energy
costs?
c) Please explain how the "Installed Capacity KW" was determined. Please provide the
rationale behid, and supporting documents for, your conclusions.
UTC STAFF DATA REQUEST NO. 102:
Referrg to the Electrc Cost of Serice workpaper prepared by Tara Knox, page TLK-E-
86:
a) Please provide the 2007 Replacement Cost Report (with Colstrp added) identified in
footnote (1).
b) Please explain the rationale behid using 50/50 weightig for hydro and thermal
plants to determine the transmission peak credit. Please provide supporting
documents.
c) Please identify the criteria for determinng peakg unts (Kettle Falls CT -211,
Norteast Spokane CT-213, Boulder Park CT-2l6, and Rathdr CT-31O) used in
the Electrc Cost of Service workpaper, page TLK-E-86.
UTC STAFF DATA REQUEST NO. 103:
a) Please explain the dispatch decisions used to determe which plants listed in the
Electrc Cost of Service workpaper, page TLK-E-86, were used for peag
resources.
b) Please explai the dispatch decisions used to determe which plants listed in the
Electrc Cost of Service workpaper, page TLK-E-86, were used for serving base
load.
UTC STAFF DATA REQUEST NO. 104:
RE: Electrc Cost of Servce
Please explain how the dispatch and generatig decision of A vista Utilities is relevant to the
peak credit method of allocating the cost of thermal generation plants and hydro generation
plants to energy and demand.
GREGORY J. TRAUTMA
Assistat Attorney General
StafCPR_011 Attachment B Page 25 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 105-107 to Avista
April 20,2009
Page 1
UTC STAFF DATA REQUEST NO. 105:
Regardig Exhbit No. _ (TLK-IT), page 4, lies 17-19, Ms. Knox states, "In response
to concerns frm Commssion staff tht twenty-five years may be inufficient to determe
'normal', I performed additional analysis comparig twenty-five year rollng averges to
thirt year rolling averages for all available Spokane heating degree day data."
a) Please provide the additional anysis performed.
b) Please discuss and explain the results of the additional analysis.
UTC STAFF DATA REQUEST NO. 106:
Regardig Exhbit No. _ (TLK-1T), page 4, lie 20, thugh page 5, lie 1, Ms. Knox
states, "This analysis revealed that while both thir year averages and twenty-five year
averages captued the long ter trend in regional tempertues, the th year averages
produced more reliable statistical results."
a) Please provide the statistical results to which Ms. Knox refers.
b) Please provide a discussion of how the results were evaluated.
c) Please provide the anlysis tht shows tht there is a trend present in the data.
UTC STAFF DATA REQUEST NO. 107:
Regardig Exhbit No. _ (TLK-lT), page 5, lies 3-5, Ms. Knox states, "The proposed
averagig process maintains the advantage of reflectig curent weather trends by updating
the values anually, while providing a less volatile statistic though the use of additional
years of data."
a). Please provide the comparson of the statistical results for the use of the data set
with 25 years of data, and the data set with 30 yeas of data.
b) Was this analysis used in A vista's last general rate case, and, if so, why were the
results of the statistical anysis not evaluated in a similar way as in this year's
general rate case?
GREGORY J. TRAUTMAN
Assistant Attorney General
StafCPR_011 Attachment B Page 26 of 264
Dockets UE-090134 and UG-090135
UTC Staf Data Request Nos. 108-125 to A vista
April 22, 2009
Page 1
Re: Service Quality and Liabilty
UTC STAFF DATA REQUEST NO. 108:
Please describe the Company's current goals and/or standards regarding restoration of
service following an electrcal outage, applicable to the state of Washigton. Include in
your response:
a) The Company's perormance tagets for: (I) mobilizing crews and materials; (2)
getting them to the outage location; (3) accurately assessing the damage; and (4)
restorig service when an outage has been reported;
b) Monthly data for 2006 though 2008, sumariing the total average time to restore
an outage, broken down, if possible, by the following categories: (1) mobile crews
and materials; (2) correctly assess the daage; (3) get the crews and materials to the
outage location; and (4) respond and restore service after an outage has been
reported;
c) Please include a copy of any document identifyg any of these goals, and please
define any exceptions applicable to these goals or standads.
UTC STAFF DATA REQUEST NO. 109:
Please describe the Company's curent policies regarding meetig service appointments,
applicable to the state of Washigton. Include in your response the period oftime the
Company tells a customer tht a service person wil appear for an appointment (i.e., between
noon and 4 p.m., or 2 hour, 4 hour, etc.), and describe:
a) The target the Company sets for arving at appointments within the agreed upon
time period.
b) The percentage of serice appointments kept withn the agreed upon time period.
c) Monthy data for 2006 though 2008, sumaring the total number of serice
appointments, broken down, if possible, by appointments that were met on tie and
the number missed.
UTC STAFF DATA REQUEST NO. 110:
Please describe the Company's performance target to intiate electrc service at locations
that have meters, applicable to the state of Washigton. Include in your response:
a) The specific performance benchmarks to provide power from the date of a request
for service at an existig address (i.e., meter already installed).
StafCPR_011 Attachment B Page 27 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 108-125 to Avista
April 22, 2009
Page 2
b) Monthy data for 2006 though 2008 regardig the tota number of serice initiations,
broken down, if possible, by the requests for service at existig addresses tht are
tued on with the established taget.
UTC STAFF DATA REQUEST NO. 111:
Please describe the Company's performance target to estiate the date for service to new
customers (line extension) from the tie tht all the required information is provided by the
applicant, applicable to the state of Washigton. Please include in your response monthly
data regarding the total number of electrc line extensions made from 2006 though 2008,
broken down, if possible, by the number and percentage of line extensions completed withn
the estimate provided to the customer.
UTC STAFF DATA REQUEST NO. 112:
Please provide the Company's policies for improving servce in areas with underperformg
electrc circuits applicable to the state of Washigton. Include in your response:
a) A description of how the Company identifies underperformg circuits;
b) A description of the criteria used to identify underperformg circuits;
c) The tota number of underperorming circuits and their locations;
d) A description ofthe Company's project prioritization process to schedule a fix to the
underperormg circuit.
UTC STAFF DATA REQUEST NO. 113:
Please provide the Company's taget time for answerig calls at the customer service centers
that serve Washigton customers. Provide the call anwer times by month from 2006
though 2008, broken down, if possible, by calls answered withn the taget time.
UTC STAFF DATA REQUEST NO. 114:
Please provide the Company's policies to preclude equipment failure (i. e., deterioration due
to age; electrcal load above limits; reduced inulation qualties, etc.). Include in your
response an explanation regarding Company policy on use of equipment until it fails, and
identify each sitution in which the Company uses equipment until the tie of failure.
Sæff_PR_011 Attachment B Page 28 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 108-125 to Avista
April 22, 2009
Page 3
UTC STAFF DATA REQUEST NO. 115:
Does the Company perform customer service sureys to determe overall customer
satisfaction? If so:
a) Please provide the results of the two most recent sureys of ths natue;
b) Please identify each benchmark the Company uses to measure customer satisfaction
(e.g., overall satisfaction, response to biling inquires, etc.)?
c) Please explain the extent to which any of the sureys produced apply to service in
Washigton.
UTC STAFF DATA REQUEST NO. 116:
Please provide the number and percentage of Washigton customers the Company
disconnected for non-payment in 2006, 2007 and 2008. Please provide the data on numbers
of customers on a monthy basis.
UTC STAFF DATA REQUEST NO. 117:
Please describe the Company's current method of managing the incidence of customer
complaints in Washigton. Please include in your response:
a) A description of each benchmark regarding complaint levels;
b) Complaint statistics for 2006 though 2008 by month, and by type;
c) Each complaint analysis, conclusions, and proposed actions tg reduce complaint
levels.
UTC STAFF DATA REQUEST NO. 118:
Please provide any root cause anlyses of outage causes in Washigton prepared over the
last thee years.
UTC STAFF DATA REQUEST NO. 119:
Please provide:
a) A sumar of the Company's vegetation management budget for the past five years
(i.e., 2004 - 2008), applicable to the state of Washigton. Include in your response a
list of both programed budget and actual expenditues used each year.
StafCPR_011 Attchment B Page 29 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 108-125 to Avista
April 22, 2009
Page 4
b) The number of miles of line that were cleared/tred each year, and specify
whether the budget includes vegetation mangement both on and off the ROW
(right-of-way).
c) An explantion of whether the Company keeps separte vegetation mangement
records for trsmission lines and distrbution lines (i.e., can the company separte
the amounts budgeted for vegetation mangement for trmission lies versus
distrbution lines?).
UTC STAFF DATA REQUEST NO. 120:
Please provide a sumary of the Tmed for the IEEE 1366 method of computig SAIDI
(system average interrption durtion index) frm 1997 - 2008.
UTC STAFF DATA REQUEST NO. 121:
Please provide any data available on access issues tht could impact SAInI (i.e., fies, police
investigations, flooding, etc.), and explain whether the Company trcks access issues
separtely.
UTC STAFF DATA REQUEST NO. 122:
Please provide all data ling agig instrctue to SAInI or SAII (system average
interrption frequency index) miutes.
UTC STAFF DATA REQUEST NO. 123:
Does the Company have any data tht indicates that climate change is a factor for increasing
SAII? If so, please provide tht data.
StafCPR_011 Attachment B Page 30 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 108-125 to Avista
April 22, 2009
Page 5
UTC STAFF DATA REQUEST NO. 124:
Please provide the anua SAII and SAII performance from 2000 to present as an
undjusted total number, as the total number excluding major events, and as the total
number excluding both major events and normaliing events.
SAII Penormance
2008 2007 2006 2005 2004 2003 2002 2001 2000
Total
SAIDI
SAII
excludig -
major
events
SAIDI
excludig
normalizing
and major
events
SAIFI Penormance
2008 2007 2006 2005 2004 2003 2002 2001 2000
Total
SAIFI
SAIFI
excluding
major
events
SAIFI
excluding
normalizing
and major
events
StafCPR_011 Attchment B Page 31 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 108-125 to Avista
April 22, 2009
Page 6
UTC STAFF DATA REQUEST NO. 125:
Please provide the anual SAIDI and SAII performance from 2000 to present for each
Washigton circuit. Please provide a separate circuit code listig (i.e., code, county, etc.).
SAII Penormance by Circuit
CIRCUI 2008 2007 2006 2005 2004 2003 2002 2001 2000
SAIFI Performance by Circuit
CIRCUIT 2008 2007 2006 2005 2004 2003 2002 2001 2000
GREGORY J. TRAUTAN
Assistat Attorney General
&aff_PR_011 Attachment B Page 32 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 126-132 to Avista
April 28, 2009
Page 1
Re: Mercury Emissions
REQUESTS DIRECTED TO RICHARD STORRO
UTC STAFF DATA REQUEST NO. 126:
On page 24, line 7 of Mr. Storro's testimony, he states, "Mercury emissions laws in
Monta are going into effect Januar 1,2010...." Please provide a copy of the Montan
statute to which he refers, and any related rules and regulations.
UTC STAF DATA REQUEST NO. 127:
On page 24, lines 11 - 12 of Mr. Storro's testimony, he states, "Full mercur control
operations are expected to begi by mid-2009...." Please provide the date tht full mercur
control operation began. If operation has not yet staed, please provide the date that
operations will begin.
REQUESTS DIRECTED TO ELIZAETH ANDREWS
UTC STAFF DATA REQUEST NO. 128:
Avista's share of the Colstrip Mercury Emission O&M Expense is $2,900,000 for 2010, as
shown on Ms. Andrews' workpaper page PF14i.
a) Please provide the total share of the Colstrp Mercur Emission 0 & M Expense
for each of the other owners for 2010, and
b) Please provide the method of allocation used to allocate between the owners.
UTC STAFF DATA REQUEST NO. 129:
a) Wht is the account number for the Colstrp Mercur Emission O&M Expenses?
b) Please provide the amount of Colstrp Mercur Emission 0 & M Expenses
incured in the test year.
UTC STAFF DATA REQUEST NO. 130:
Please provide the documents and any spreadsheets with formulae intact to support the
$2,900,000 estimated 2010 Colstrp Mercur Emission 0 & M expense provided by Thomas
Dempsey as noted by "LMA 12110/08" on workpaper page PFI4i.
StafCPR_011 Attachment B Page 33 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 126-132 to Avista
April 28, 2009
Page 2
UTC STAFF DATA REQUEST NO. 131:
Please provide an electrnic copy of the grph shown on workpaper page PF 143, with all
formulae and lis intact.
UTC STAFF DATA REQUEST NO. 132:
Recent federal legislation provides tax benefits for "advanced coal-based" and "advanced
energy" projects. Please provide the Company's position ofthe applicabilty of the new
enacted tax benefits to the Colstrp Mercur Emissions Project. Assumg new ta benefits
are now available, please provide the Company's computation of the projected tax benefits
of the Colstrp Mercur Emission Project.
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 34 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 133-134 to Avista
May 14,2009
Page 1
DATA REQUESTS ELIZAETH ANDREWS
UTC STAFF DATA REQUEST NO. 133:
Re: Miscellaneous Restating Adjustments
Please provide the trsaction detail for the following account numbers and months for the
totals shown on Page 3 of 4 of Staff Data Request Response 3, Attchment A:
Account Month
908XX Customer Assistace Expenses Januar 2008, Febru 2003, April 2008
909000 Advertsing June 2008
912000 Demonstrating & Selling December 2007, April 2008
Expenses
913000 Advertising August 2008
921000 Offce Supplies & Expenses May 2008
923000 Outside Services Employed December 2007, March 2008, April 2008
930000 Miscellaneous General Expenses Janua 2008, May 2008
UTC STAFF DATA REQUEST NO. 134:
Re: Miscellaneous Restating Adjustments
Please provide the trsaction detail for the following account numbers and months for the
totals shown on Page 2 of 3 of Staff Data Request Response 4, Attchment A:
Account Month
908XX Customer Assistace Expenses December 2007, January 2008, June 2008
909000 Advertising August 2008
912000 Demonstrating & Selling Expenses December 2007, April 2008
913000 Advertising December 2007
921000 Offce Supplies & Expenses May 2008
923000 Outside Serices Employed December 2007, March 2008, June 2008
930000 Miscellaneous General Expenses Janua 2008, May 2008
GREGORY J. TRAUTMAN
Assistant Attorney General
StafLPR_011 Attachment B Page 35 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 135-140 to Avista
May 19,2009
Page 1
DATA REQUESTS ELIZETH ANREWS
UTC STAFF DATA REQUEST NO. 135:
Re: Pro Forma Incentives
Ms. Andrews testimony, page 30, lines 2 though 4, refers to the Consumer Price Index
(CPl). Please provide the Consumer Price Index (CPl) source data that was used to adjust
actual incentives paid and the associated payroll taes accrued for the years 2003 though
2007, as shown on workpaper pages PFl57 (Electrc) and PF77 (Gas).
UTC STAFF DATA REQUEST NO. 136:
Re: Pro Forma Incentives
The Company response to staff data request 98b shows taget incentive payout amounts and
actual incentives paid for 2002 though 2008. Please provide a reconciliation of the actul
incentives paid amount reflected in the Company's response to staff data request 98b and the
amounts shown on Ms. Andrews' workpaper pages PF157 (Electrc) and PF77 (Gas).
UTC STAFF DATA REQUEST NO. 137:
Re: Pro Forma Insurance
Workpaper pages PF183 (Electrc) and PF103 (Gas) show Directors & Officers Liabilty
Allocation Percentages as 66.7% for 2007 and 100% for 2008. Please explain why 66.7% of
liability insurance for directors and officers was allocated to utility in 2007, and 100% of
liability insurance for directors and officers was allocated to utility in 2008.
UTC STAFF DATA REQUEST NO. 138:
Re: Property Tax
On Febru 18,2009 Avista Coip. held an Eargs Cal for its 4th Quer 2008. In
response to a question by James Bellessa ofD.A. Davidson & Company, Mark Thes
responded, "We did some propert tax true ups in the fourt quarer and we used a
consultant and they were able to help us lower our propert taxes."
a) Please provide a detail of the propert tax tre-ups referred to by Mr. Thies.
b) Please provide all correspondence and/or reports provided by the "consultant"
discussing propert ta savings referred to by Mr. Thes.
c) Please provide the amount of propert tax saved by the use of the consultat.
d) Please provide a listing of all other ''te-ups'' that were preformed durg the four
quarer.
StafCPR_011 Attachment B Page 36 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 135-140 to Avista
May 19, 2009
Page 2
UTC STAFF DATA REQUEST NO. 139:
Re: Propert Tax
In the spreadsheet labeled "2008 Prop tax Est from Tax-unprotected.xls," the equalization
factors for Washigton for 2008 and 2009 are 0.910 and 0.920 respectively. Please provide
the computation and the support data for the derivation of these factors.
UTC STAFF DATA REQUEST NO. 140:
Re: Property Tax
Avista has appealed its propert taxes valuations for 2008. Please provide copies of the
appeals and a discussion of the impact on the estimated propert taxes computed in the
spreadsheet labeled "2008 Prop tax Est from Tax-unprotected.xls."
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 37 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 141- 1 50 to Avista
May 27, 2009
Page 1
DATA REQUESTS ELIZABETH ANDREWS
Re: Pro Forma Insurance
UTC STAFF DATA REQUEST NO. 141:
Please provide source and lor support of the statement from Ms. Andrews on page 34, lines
18 and 19, "Property insurance rates were volatile because of extensive energy industr
propert damage in 2008 and adverse investment retus at insurance companies."
UTC STAFF DATA REQUEST NO. 142:
On Ms. Andrews' workpapers labeled PF183 (Electrc) and PFl03 (Gas), the Company
shows 2009 estiates as of 12-05-2008. Please provide workpaper amounts updated to the
curent date.
UTC STAFF DATA REQUEST NO. 143:
On Ms. Andrews' workpapers labeled PF183 (Electrc) and PF103 (Gas), she refers to "as
quoted "or "quoted" as the basis for the 2009 estimate. Please provide a copy of the quote
along with a reconciliation of the amount provided in the quote and the amount shown on
the provided workpapers, if not self evident.
UTC STAFF DATA REQUEST NO. 144:
On Ms. Andrews' workpapers labeled PF183 (Electrc) and PFl03 (Gas), she refers to a "5-
08 letter" as the basis (or the 2009 estimate. Please provide a copy of the letter along with a
reconcilation of the amount provided in the quote and the amount shown on the provided
workpapers, if not self evident.
UTC STAFF DATA REQUEST NO. 145:
On Ms. Andrews' workpapers labeled PF183 (Electrc) and PFl03 (Gas), she refers to "as
invoiced" as the basis for the 2009 estimate. Please provide a copy of the invoice along with
a reconciliation of the amount provided in the quote and the amount shown on the provided
workpapers, if not self evident.
UTC STAFF DATA REQUEST NO. 146:
On Ms. Andrews' workpapers labeled PF183 (Electrc) and PFl03 (Gas), the basis for the
estimate for Continuity Credit and Second Excess includes ''tes & fees" of 2.40%. Please
provide documentation to support the 2.40% rate with a reconciliation of the amount shown
on the provided workpapers, if not self evident.
~aff_PR_011 Attachment B Page 38 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 141 -150 to Avista
May 27, 2009
Page 2
UTC STAFF DATA REQUEST NO. 147:
On Ms. Andrews' workpapers labeled PF183 (Electrc) and PF103 (Gas), the basis for the
estimate of Continuity Credit includes "Terrorism" of 20%. Please provide documentation
to support the 20% increase with a reconciliation of the percentage shown on the provided
workpapers, if not self evident.
UTC STAFF DATA REQUEST NO. 148:
With the last 24 months, has the Company solicited coverage proposals from other
insurce carers? If so, provide copies of the request for proposal and any related
responses.
UTC STAFF DATA REQUEST NO. 149:
Wht is the coverage amount for Director and Officer Insurance?
UTC STAFF DATA REQUEST NO. 150:
What percentage of Director and Officer Insurance is being allocated to the Company's
subsidiares?
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 39 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 151-153 to Avista
June 10, 2009
Page 1
UTC STAFF DATA REQUEST NO. 151:
Re: DSM Program
Please provide the most recent cost estimate per MWh of Avista's electric conservation
program. Indicate both the number of years (average measure life) and date of estimate used.
UTC STAFF DATA REQUEST NO. 152:
Re: Long-term Energy Cost Projection
Please provide the most recent system-wide cost estiate per MW for 20-year energy with
and without environmental attbutes. Describe the methodology and assumptions used
along with the date of the estiate used.
UTC STAFF DATA REQUEST NO. 153:
Re: Current Margial Energy Cost Projections
Please provide your curent incrementa market cost estiate(s) for acquisition or market
purchase of an additional MW of energy and the assumed tiefre(s) that the cost is (are)
projected to be valid. Describe the methodology and assumptions used in the acquisition or
market cost estimate(s).
GREGORY J. TRAUTMA
Assistat Attorney General
StafCPR_011 Attchment B Page 40 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 154-161 to Avista
June 17,2009
Page 1
UTC STAFF DATA REQUEST NO. 154:
Re: Long-term Debt
Please confirm (or deny) that the calculation oflong-term debt by Avista in its general rate
case filing in ths docket has been done in the exact maner as was approved by the
Commission in the last two general rate case proceedigs. If the answer is "deny," please
explain the difference(s).
UTC STAFF DATA REQUEST NO. 155:
Re: Board of Directors Meetings Expenses
Please provide a detailed accounting of all costs included in the test year related to Board of
Directors meetigs. Please clearly show expenses related to transporttion (e.g., limousines,
airline tickets), meals and entertinent costs (e.g., water cruises).
UTC STAFF DATA REQUEST NO. 156:
Re: Spokane River Relicensing
Please provide the curent status of the Spokane River relicensing. Please include the revised
expected date of issuace of the license.
UTC STAFF DATA REQUEST NO. 157:
Re: Property Tax
Please provide 2009 propert tax valuations recently issued by Washigton, Idaho and
Montan.
UTC STAFF DATA REQUEST NO. 158:
Re: Peak Credit calculation, Workpaper TLK-E-86
For each peaking unit combustion turbine identified in Ms. Knox's workpaper TLK-E-86,
please provide the following:
a) the actual number of hours the plant ran durg the test year;
b) the total megawatt-hours produced by the plant durg the test year.
UTC STAFF DATA REQUEST NO. 159:
Re: Peak Credit calculation, Workpaper TLK-E-86
For each thermal unit identified in Ms. Knox's workpaper TLK-E-86, please provide the
following:
a) the actual number of hour the plant ra durg the test year;
b) the total megawatt-hours produced by the plant durg the test year.
Staff_PR_011 Attachment B Page 41 of 264
Dockets UE-090134 and UG-û90135
UTC Staff Data Request Nos. 154-161 to A vista
June 17,2009
Page 2
UTC STAFF DATA REQUEST NO. 160:
Re: Peak Credit calculation
Please identify Avista's 200 hours of greatest demand in the test year.
UTC STAFF DATA REQUEST NO. 161:
Re: Peak Credit calcnlation
For each hour identified in UTC Staff Data Request No. 160 above, please provide:
a) the megawatt-hours produced by each Avista plant in each of the 200 hours;
b) the megawatt-hour purchased or interchanged under long-term contracts in each
hour (long-term defmed as greater than or equal to one year);
c) the megawatt-hours purchased or interchaged under short-term contracts in each
hour (short-term defmed as less th one year);
d) the megawatt-hour sales to native load customers in each hour;
e) the megawatt-hour sales for long-term contrcts in each hour;
f) the megawatt-hour sales for short-term contrcts in each hour.
If a varation in the defition of contracts as "long-term" or "short-term" better fits existing
data, please provide the data by your definition, and state the defmition of long versus short
term.
GREGORY J. TRAUT
Assistant Attorney General
StafCPR_011 Attachment B Page 42 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request No. 162 to Avista
June 24, 2009
Page 1
DATA REQUEST TO ELIZABETH ANREWS
REQUESTOR: AN LaRUE
UTC STAFF DATA REQUEST NO. 162:
Re: Pro Forma Insurance
a) Please provide the number of Director and Officer (D&O) inurce claims tht have
been fied againt A vista in the past thee years?
b) Wht was the amount of each of the claims?
c) Provide the description and basis of the original D&O claim.
d) Of all of the D&O insurance claims that were fied against A vista in the past thee
year, how many of those claims were paid?
Please provide copies of all the paid D&O insurance claims tht have been paid over the last
thee years with the correspondig outcomes.
GREGORY J. TRAUTMA
Assis~t Attorney General
Staff_PR_011 Attachment B Page 43 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request No. 163 to Avista
July 24, 2009
Page 1
UTC STAFF DATA REQUEST NO. 163:
Please reconcile the following amount for A vista debt and common equity as of September
30,2008:
Common Equity
$1,004,427,887
$978,652,000
per Exhbit No._ (MIT -2)
per 3rd Qt 2008 Balance Sheet from Avista Coip Web site.
Total Debt
$1,041,414,167 per Exhbit No._ (M -2)
Long-term Debt
L- T Debt to Affl Tr
Curent L- T Debt
Short-term Debt
$778,913,000
$113,403,000
$108,916,000
$86,500,000
TOTAL $1,087,732,000 per 3rd Qtr Balance Sheet from Avista Web site
GREGORY J. TRAUT
Assistat Attorney General
StafCPR_011 Attachment B Page 44 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 164-167 to A vista
July 30, 2009
Page 1
REQUESTS DIRECTED TO: Scott Kinney
UTC STAFF DATA REQUEST NO. 164:
Re: Transmission Expenses
Please provide the Northwestern Energy's (NWE) proposed Colstrip transmission plan that
proposes biling Avista $656,000 for Avista's share of the Colstrip O&M expense durg the
pro forma period described in Mr. Kinney's testimony pages 2-3. Please indicate the
derivation of the $656,000, if not self-evident in the document.
UTC STAFF DATA REQUEST NO. 165:
Re: ColumbiaGrid
Please provide the two-year general fuding extension with ColumbiaGrd in September
2008.
Please provide support for the 10.03% share cited in Mr. Kinney's testimony. (pg 3 line 15)
UTC STAFF DATA REQUEST NO. 166:
Re: NERC requriements
Please provide any pending NERC violations against A vista including any ''Notices of
Alleged Violations" received from NERC or its agents. Please provide all correspondence
with NERC or its agents related to any and all closed or settled NERC alleged violations.
REQUEST DIRECTED TO Dave DeFelice
UTC STAFF DATA REQUEST NO. 167:
Re: ColumbiaGrid Planning
Please provide for each project listed on pages 10 through 17 of Mr. DeFelice's testimony
the following:
(a) Name ofproject;
(b) Cost basis (estiated or actul);
(c) Updated system and Washigton cost;
(d) Reason Company instituted project;
(e) List benefits of the projects;
(f) In service date. Ifnot yet in service, state projected in service date;
(g) Cite adjustment project amount is included in (e.g., PFI 0).
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment B Page 45 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 168- 1 69 to A vista
July 31, 2009
Page 1
UTC STAFF DATA REQUEST NO. 168:
Please provide Excel copies of the Triple E Reports from 1999 to 2003, including the
supportg spreadsheets.
UTC STAFF DATA REQUEST NO. 169:
Please provide Excel or Word copies of the 2008 and 2009 business plans, including
supportg spreadsheets.
GREGORY J. TRAUT
Assistat Attorney General
StafCPR_011 Attachment B Page 46 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request No. 170 to Avista
August 19, 2009
Page 1
DATA REQUEST FOR ELIZABETH ANDREWS
REQUESTOR: AN LaRUE
UTC STAFF DATA REQUEST NO. 170:
Re: Pro Forma Labor-NoD-Exec
a) Please provide the authorized increase for admstrtive staff for 2009. On work
paper pages PF3s (Electrc) and PF14 (Gas), ths amount is identified as 3.80%,
under "ADMI, 2009 increase for 2009 adjustment."
b) Please reconcile the above 3.80% to the 2.5% testified to by Donn English (Page 7,
Line 6), from the Idaho Public Utilities Commission, on May 29,2009.
GREGORY J. TRAUTMAN
Assistat Attorney General
Staff_PR_011 Attachment B Page 47 of 264
Dockets UE-090l34 and UG-090135
UTC Staf Data Request Nos. 171-175 to Avista
August 20, 2009
Page 1
UTC STAFF DATA REQUEST NO. 171:
Wht are the income level eligibility requirements for LIR? What are the income level
eligibility requirements for low income DSM progrs?
UTC STAFF DATA REQUEST NO. 172:
What is the average cost to weatherize a home under the low income DSM progr? Using
that average cost and the Company's annual LIR report's information about repeat
customers, please estimate the anual cost of weatheriing all LIR and LIHEAP recipient
homes. Please explain how you would account for multifamy residences.
UTC STAF DATA REQUEST NO. 173:
Does Research Into Action, the fi tht completed the DSM Verification Reports,
specialize in impact evaluations or process evaluations? Please explain your anwer.
UTC STAFF DATA REQUEST NO. 174:
In the DSM verification process, did Research Into Action recommend using actual data to
adjust savings estiates? If so, please provide a citation.
UTC STAFF DATA REQUEST NO. 175:
Does the low income energy effciency progra report actu savings based on bil anaysis?
How is the TREET anlysis used in the low income energy effciency progr?
GREGORY J. TRAUTAN
Assistat Attorney General
StafLPR_011 Attachment B Page 48 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 176-180 to Avista
August 25,2009
Page 1
UTC STAFF DATA REQUEST NO. 176:
Please provide a list of customers receiving both energy efficiency rebates and LllAP or
LIR assistance in 2007 and 2008.
UTC STAFF DATA REQUEST NO. 177:
Does the Company have any anlyses of 2007 or 2008 indicia of bil payment or non-
payment such as frequency of late payment, issuace of disconnection notices,
disconnection itself, need for payment plans, declarations of medical emergency or demand
for deposit? If so, please provide it.
UTC STAFF DATA REQUEST NO. 178:
How does the decoupling surcharge affect the energy burden of a limited income customer?
How does the DSM surcharge affect the energy burden of a limited income customer?
Please provide analyses similar to the energy burden analysis in the Company's annual
LIR report.
UTC STAFF DATA REQUEST NO. 179:
How many customers receiving a high effciency fuace rebate in 2007 and 2008 installed
90 percent efficient fuaces? Ninety-five percent effcient fuces? How is ths difference
reflected in the Company's current savings assumptions? How do you explain making the
change from 72 to 123 therms for the high effciency energy savings? Did Researh Into
Action note these chages in any of its reports?
UTC STAFF DATA REQUEST NO. 180:
Avista's response to Public Counsel's data request 283, Attachment A, Revisions to Savings
column, shows changes to Avista's residential therm savings estimates. Please summarize
the changes to Avista's residential therm savings estimates by year. Do changes identified
as "Idaho" also apply to Washington? Were these changes reported to the Triple E when
they occured?
GREGORY J. TRAUTMAN
Assistat Attorney General
Staff_PR_011 Attachment B Page 49 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 18 I - I 82 to A vista
September 21, 2009
Page I
UTC STAF DATA REQUEST NO. 181:
Re: Decoupling
Mr. Hirschkorn's Rebuttal Testimony, page 7, says "It was the belief of the Advisory Group,
includig Staff, that it was more importt for the Paries to draw their own conclusions
based on the findings in the final Evaluation." Please provide all supporting documentation
for ths statement. Please include any recordigs of meetings and trscripts of the
meetings. Please provide all supporting documentation for the tig of Staff statements
about the Evaluation Plan.
UTC STAFF DATA REQUEST NO. 182:
Re: Decoupling
Mr. Hirschkorn's Rebuttal Testimony, page 7, says "the Evaluation Plan specifically did not
cal for the Evaluator to come to any conclusions regardig either the design of the
mechasm or decoupling in general." Please explain what was meant by the second
paragraph of the evaluation plan where it says "This Plan is comprised of a number of areas
to be examined as par ofthe evaluation."
GREGORY J. TRAUT
Assistant Attorney General
StafCPR_011 Attchment B Page 50 of 264
Dockets UE-090134 and UG-090135
UTC Staff Data Request Nos. 183-186 to Avista
September 29, 2009
Page 1
UTC STAFF DATA REQUEST NO. 183:
Re: Decoupling
Please provide an Excel spreadsheet with active calculations for the table shown on page 8
of Mr. Hirschkorn's Rebuttal Testimony.
UTC STAFF DATA REQUEST NO. 184:
Re: Decoupling
Page 8, lies 15-17 ofMr. Hirschkorn's Rebuttal Testimony state that the volumetric margin
is "determined by multiplying the average monthly usage of 69 therms by the present
margin of $0.2420 1 per therm." Please confirm that the volumetric margin for the Staff
proposal should be determined by multiplyig the Staff proposed rate of $0.20984 (Exhbit
No. _ (DJR_3T, page 1, line 21)) times 69 therms, which is $14.48. If you disagree,
please explain in detaiL.
UTC STAFF DATA REQUEST NO. 185:
Re: Decoupling
The table shown on page 8 of Mr. Hirschkorn's Rebuttal Testimony in the "100% of present
margin" column shows the total volumetric margin under the current tariff. Please confirm
that the lost margin porton of the total volumetrc margin is calculated by multiplyig
$0.00563 (Schedule 159 Decoupling Rate) times 69 therms, which is $0.39. If you disagree,
please explain in detaiL.
UTC STAFF DATA REQUEST NO. 186:
Re: Decoupling
The table shown on page 8 of Mr. Hirschkorn's Rebuttal Testimony in the "Company
rebuttl proposal" column shows 70% of the volumetric margin under the curent tariff. Is
volumetrc margin the same as lost margin? Please explain in detaiL.
GREGORY J. TRAUTMA
Assistat Attorney General
StafCPR_011 Attachment B Page 51 of 264
BEFORE THE WASHINGTON UTILITIES AN TRASPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Requests Nos. 1 through 8
To: Avista
PC- 1 Please provide paper copies of your responses to all data requests for information
from all pares in ths action to:
Simon J. fftch
Offce of the Attorney Genera
Public Counel
800 Fift Avenue #2000
Seatte, VVPL 98104-3188
Please provide electronic copies of al documents to Simon fftch,
simonf(fatg.wa.gov, Stefanie Johnson, stefaniej(IDatg.wa.gov, and to Carol
Willams, carolwØlatg.wa.gov.
PC-2 Re: The attached excel spreadsheet provided on CD entitled, "Copy of DR
set#4, Q2 Q3 - 2004 thru 2007 w g and fuel inc and fuel A vista 2 25 09
revised."
This spreadsheet contas completed commercial and industral DSM projects, by
customer and rate schedule, from Janua 1, 2004 though December 31, 2007.
Please view the worksheet labeled "Avista Response," which was sent by Avista
to the Staeholder Advisory Group in the Decoupling Evaluation on Februar 25,
2009:
For each of the 6 customer accounts highlighted in orange (Schedule 101 VV A
customer with estimated ther savings greater than 2,400 therms), tht were
shown as completed in 2004, please provide the following:
a. The customer nae, account number, and a description of the natue of the
commercial enterprise.
b. The customer address (meter location) where DSM measure(s) were installed.
c. A description of the DSM measure( s) installed by the customer.
d. The amount of incentive paid by A vista to the customer, as well as any
additional non-incentive costs incured by Avista to produce the estiated
therm savings.
e. Customer costs for the DSM measure(s).
StafCPR_011 Attachment B Page 52 of 264
To: David Meyer
Re: PC Data Requests Nos. 1-8 to Avista
Date: March 2, 2009
Page 2 of5
f. The date A vista confrmed instalation and paid incentives for each DSM
measure.
g. The estiated first year ther savings (as shown on the worksheet)
h. A biling history report for the customer, providing monthly actul therm sales
and monthy biled revenues by rate element for each of the 12 months prior to
the date in your response to part (t), as well as all available subsequent
months.
i. Complete copies of the documentation retained by A vista to support its DSM
transactions with the customer
PC-3 Re: The attached excel spreadsheet provided on CD entitled, "Copy of DR
set#4, Q2 Q3 - 2004 thrn 2007 w g and fnel inc and fuel A vista 2 25 09
revised."
This spreadsheet contains completed commercial and industral DSM projects, by
customer and rate schedule, from Janua 1, 2004 though December 31, 2007.
Please view the worksheet labeled "A vista Response," which was sent by A vista
to the Staeholder Advisory Group in the Decoupling Evaluation on Februar 25,
2009:
For each of the 3 customer accounts highlighted in orage (Schedule 101 WA
customers with estiated therm savings greater than 2,400 therms), that were
shown as completed in 2005, please provide the following:
a. The customer name, account number, and a description of the natue of the
commercial enterprise.
b. The customer address (meter location) where DSM measure(s) were installed.
c. A description of the DSM measure(s) installed by the customer.
d. The amount of incentive paid by Avista to the customer, as well as any
additional non-incentive costs incured by A vista to produce the estimated
therm savings.
e. Customer costs for the DSM measure(s).
f. The date Avista confied intaation and paid incentives for each DSM
measure.
g. The estimated fist year therm savings (as shown on the worksheet)
h. A billig history report for the customer, providing monthy actual therm sales
and monthy biled revenues by rate element for each of the 12 months prior to
the date in your response to par (t), as well as all available subsequent
months.
1. Complete copies of the documentation retained by A vista to support its DSM
transactions with the customer.
StafCPR_011 Attachment B .Page 53 of 264
To: David Meyer
Re: PC Data Requests Nos. 1-8 to Avista
Date: March 2, 2009
Page 3 of5
PC-4 Re: The attached excel spreadsheet provided on CD entitled, "Copy of DR
set#4, Q2 Q3 - 2004 thru 2007 w g and fuel inc and fuel A vista 2 25 09
revised."
This spreadsheet contas completed co~ercial and industral DSM projects, by
customer and rate schedule, from Janua 1,2004 thugh December 31,2007.
Please view the worksheet labeled "AvIsta Response," which was sent by Avista
to the Staeholder Advisory Group in the Decoupling Evaluation on Februar 25,
2009:
For each of the 8 customer accounts highghted in orange (Schedule loi W A
customers with estiated therm savings greater th 2,400 therms), tht were
shown as completed in 2006, please provide the following:
a. The customer nae, account number, and a description of the natue of the
commercial enterprise.
b. The customer address (meter location) where DSM measure(s) were installed.
c. A description of the DSM measure(s) instaed by the customer.
d. The amount of incentive paid by A vista to the customer, as well as any
additional non-incentive costs incured by Avista to produce the estimated
therm savings.
e. Customer costs for the DSM measure(s).
f. The date Avista.confed instaation and paid incentives for each DSM
measure.
g. The estimated first year therm savings (as shown on the worksheet)
h. A biling history reprt for the customer, providig monthy actual therm sales
and monthy biled revenues by rate element for each of the 12 months prior to
the date in your response to par (f), as well as all available subsequent
months.
1. Complete copies of the documentation retained by A vista to support its DSM
transactions with the customer.
PC-5 Re: The attached excel spreadsheet provided on CD entitled, "Copy of DR
set#, Q2 Q3 - 2004 thru 2007 w g and fuel inc and fuel A vista 2 25 09
revised."
This spreadsheet contas completed commercial and industral DSM projects, by
customer and rate schedule, from Janua 1, 2004 though December 31, 2007.
Please view the worksheet labeled "Avista Response," which was sent by Avista
to the Staeholder Advisory Group in the Decoupling Evaluation on Februar 25,
2009:
StafCPR_011 Attachment B Page 54 of 264
To: David Meyer
Re: PC Data Requests Nos. 1-8 to Avista
Date: March 2, 2009
Page 4 of5
For each of the 20 customer accounts highlighted in orage (Schedule 101 WA
customers with estiated therm savings greater than 2,400 therms), tht were
shown as completed in 2007, please provide the following:
a. The customer name, account number, and a description of the natue of the
commercial enterprise.
b. The customer address (meter location) where DSM measure(s) were intalled.
c. A description of the DSM measure(s) installed by the customer.
d. The amount of incentive paid by A vista to the customer, as well as any
additional non-incentive costs incured by Avista to produce the estimated
therm savings.
e. Customer costs for the DSM measure(s).
f. The date A vista confied instalation and paid incentives for each DSM
measure.
g. The estiated first year therm savings (as shown on the worksheet)
h. A billig history report for the customer, providing monthy actul therm sales
and monthy biled revenues by rate element for each of the 12 months prior to
the date in your response to part (f), as well as all available subsequent
months.
i. Complete copies of the documentation retained by A vista to support its DSM
transactions with the customer.
PC-6 Re: The attached excel spreadsheet provided on CD entitled, "nonres
completed therms 123108 for titus."
This spreadsheet contains completed commercial and industral DSM projects, by
customer and rate schedule, from Janua 1, 2008 though December 31, 2008.
Please view the worksheet labeled "Lori completed W A and ID gas projects,"
which was sent by Avista to the Staeholder Advisory Group in the Decouplig
Evaluation on Janua 7,2009:
For each of the 11 customer accounts highlighted in yellow (Schedule 101 WA
customers with estiated therm savings greater than 2,400 therms), tht were
shown as completed in 2008, please provide the following:
a. The customer name, account number, and a description of the natue of the
commercial enterprise.
b. The customer address (meter location) where DSM measure(s) were instaled.
c. A description of the DSM measure(s) installed by the customer.
d. The amount of incentive paid by Avista to the customer, as well as any
additional non-incentive costs incured by A vista to produce the estimated
therm savings.
e. Customer costs for the DSM measure(s).
f. The date A vista confed intallation and paid incentives for each DSM
measure.
StafCPR_011 Attachment B Page 55 of 264
To: David Meyer
Re: PC Data Requests Nos. 1-8 to Avista
Date: March 2, 2009
Page 5 of5
g. The estiated first year ther savings (as shown on the worksheet)
h. A biling history report for the customer, providig monthy actul therm sales
and monthy biled revenues by rate element for each of the 12 months prior to
the date in your response to par (f), as well as all available subsequent
months.
1. Complete copies of the documentation retaied by A vista to support its DSM
transactions with the customer.
PC-7 Provide the actu and weather normalized anua sales and average use per
customer for residential natul gas customers by category for the test period:
single famly, duplex/trplex, multi-famy, mobile home, and other.
PC-8 Provide the actual and weather normized anua sales and average use per
customer for residential electrc customers by category for the test period: single
family, duplex/trplex, multi-famly, mobile home, and other.
Staff_PR_011 Attachment B Page 56 of 264
BEFORE THE WASHIGTON UTILITffS AND TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Requests Nos. 9 through 39
To: Avista
PC-9 Fincial Statements - Please refer to Exhbit No. _(EMA-2) and
Exhbit No. _(EMA-3) and provide the fiancial statements (income
statement and balance sheet) each month of the test year ended September
30, 2008, which comprise the colum "Actu Per Results Report" for
both gas and electrc.
PC-LO Financial Information - If the colum entitled "Actul Per Results Report"
is based on an allocation of total Company information, provide total
Company fincial statements for the same period as requested in
Question 9.
PC-II Financial Information - Provide an allocation manua with descriptions of
how total Company financial data is allocated to Washigton and the other
state jursdictions. This document should include any deta necessar to
analyze allocations of total Company information.
PC-12 Financial Information - Provide the same inormation as requested in
Question 9 for each month subsequent to September 30, 2008 YTD and
contiue to provide the monthy fiancial information as such inormation
becomes available to the Company.
PC-13 Financial Information - Provide detaled tral balances for each month of
the test year, by sub-account, for both the Avista Corporation and the
Washigton jursdiction which comports with Exhbit No. _ (EMA-2)
and Exhbit No. _ (EMA-3).
PC-14 Financial Information - Provide detailed annual tral balances for the last
five years ending December 31, by sub-accoUnt, for both the A vista
Corporation and the Washigtn jurisdiction which comport with Exhbit
No. _ (EMA-2) and Exhbit No. _ (EMA-3).
PC-15 Financial Information - Provide anual balance sheet and income
statements for the five previous years ended December 31, on a
jursdictional basis for each of the gas and electrc operations.
StafCPR_011 Attachment B Page 57 of 264
To: David Meyer
Re: PC Data Requests Nos. 9-39 to Avista
Date: March 9, 2009
Page 2 of4
PC-16
PC-17
PC-18
PC-19
PC-20
PC-21
PC-22
PC-23
PC-24
PC-25
Fincial Information - Provide a copy of the Company's System of
Accounts with detailed explanations of what each account represents.
Financial Information - Please provide copies of al accountig
manuas/guidelies regarding the Company's policies and procedures for
capitaing plant additions.
Fincial Information - Pleae provide copies of al accountig
manuas/guidelies regarding the Company's policies and procedures for
treatment of maintenance expenditues.
Financial Information - Please provide copies of the Company's
accounting procedures utilied in distiguishig expenditues as either
capital expenditues or maitenance expenditues.
Fincial Information - Pleae provide copies of the Company's manuals,
policies, procedures, gudelies, etc. regardig the approval process for
capital expenditues.
Fincial Information - Please provide copies of the Company's manuals,
policies, procedures, guidelines, etc. regarding its work order process for
capita expenditues.
Financial Information - Please provide copies of the Company's manuals,
policies, procedures, guidelines, etc. regardig budget preparation.
Fincial Information - Please provide a copy of the Company's listig of
retirement unts.
Uncollectible Expense - Please provide the following inormation:
For the test-year, and for each of the prior five calendar years;
provide in separate colums:
a. The Company's wrte-offs for each yea;
b. The Company's recoveries for each yea; and
c. The Company's general business revenues associated with
the dollar amounts wrtten-off.
Uncollectible Expene - Provide the Company's calculation of the
uncollectible factor .002599 utilied in the revenue conversion factor.
Provide a detaled explanation of how ths factor was derived including
references for all data utiized in the calculation.
StafLPR_011 Attachment B Page 58 of 264
To: David Meyer
Re: PC Data Requests Nos. 9-39 to Avista
Date: March 9, 2009
Page 3 of4
PC-26
PC-27
PC-28
PC-29
PC-30
PC-31
PC-32
Washigton Excise Tax - Please provide the calculation of the Washigton
Excise Tax factor in the amount of .038629 utilized in the revenue
conversion factor shown on Elizabeth Andrews' workpaper A-3. Provide
a detailed explantion of how ths factor was derved including references
for all data utilized in the calculation.
Washington Excise Tax - Provide a copy of the Company's Washigton
Excise Tax retu for the most recent calenda year and the year prior to
that calenda year.
Electrc Rate of Retu Calculation - Please refer to witness Andrews'
Workpaper B-2 and provide a reconciliation of the electrc net rate base in
the amount of$934,538,7l 7 to the restatement sumar which is an
undated workpaper and shows the rate base to be $926,806,000 after
commission adjustments.
Alocations - Please refer to Workpaper B-IO of Elizabeth Andrews.
Provide a detaled explanation of why 87.23% ofmeterreading expense is
allocated to the State of Washigton while only 12.77% is allocated to the
State of Idao. Provide any workpapers, analysis, or other justification for
ths allocation.
Marketig - Does Avista have a marketing program in either its gas or
electrc division? If any individual or group of individuas are engaged in
marketing for either the gas or electrc deparent, please provide the
following information:
a. The number of individuals, their salares and all overhead
associated with marketig operations of A vista.
b. The accounts to which the marketig costs are charged.
c. State the revenue impact of including the marketig deparent
costs or other related costs in the Company's curent filing.
Advertising - Please provide a list of all adversing which the Company
does regardless of what FERC account it is charged to. Provide the
following inormation regarding the Company's advertsing expenses:
a. Provide a detailed list of all advertsing expense by vendor.
b. Provide a list of all advertising expense by tye.
c. Provide samples of advertising for any advertising progr which
exceeded $5,000.
Customer Assistace Expense - Provide an analysis of the total amount of
customer assistace expense shown in Account 908 in the amount of
$15,065,672.
Staff_PR_011 Attachment B Page 59 of 264
To: David Meyer
Re: PC Data Requests Nos. 9-39 to Avista
Date: March 9,2009
Page 4 of4
PC-33
PC-34
PC-35
PC-36
PC-37
PC-38
PC-39
a. Provide the level of customer assistace expense for the prior five
calenda yea.
b. Provide the basis of the diect chages to the State of Washigton.
Offce Supplies and Expense - Please provide the following information in
regards to Account 921 - Offce Supplies and Expense. Provide a listing
of every charge for the test year which exceeded $5,000 together with an
explantion of what tht chage resulted from.
Outside Services Employed - Provide an anysis of Account 923 -
Provide a listig of each chage to ths account and include an explanation
for any amount that exceeded $5,000.
Reguatory Commission Expense - Provide an explantion of why
$2,908,577 of Reguatory Commssion Expene has to be allocated.
a. State why these costs canot be determined on a jursdictional
basis rather th alocated.
Maintenace of General Plant - Provide an anlysis of Maitenance of
General Plant for the test-yea. Provide a listig of each expense that
exceeded $10,000 with a correspondig explantion.
Accounts Receivable Sold - Please refer to Workpaper B- 1 4 and provide
all the documentation and explantion for the amounts included in
Accounts 903.920 and 903.930.
a. Explain in detail what the Accounts Receivable Sold program is.
b. Provide a reference to a Commssion order which authories the
Company to sell accounts receivable.
c. Provide any cost benefit anlysis that the Company performed
prior to engaging in any sale of accounts receivable.
DSM Tarff Rider - Please provide a full explanation of the expense
shown on Workpaper B-15 in the amount of$12,810,339 on a tota
Company basis.
a. State how ths DSM expene is accounted for and how it relates to
the rider which is referred to in the description of the account.
DSM Amortzation - Provide an explanation of the amount in ths account
as shown on Workpaper B-15 and how it relates to the DSM Tarff Rider
expense which is shown on the same workpaper.
a. Provide an analysis of the amortation which is refered to in the
account description.
StafCPR_011 Attachment B Page 60 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. 00-090134 and UG-090135
Public Counsel Requests Nos. 40 through 52
To: Avista
PC-40 Marketig - If A vista has a marketig progra, please provide the
following inormation regarding ths progr:
a. An organzational char and description of job titles and
responsibilities;
b. The marketig deparent's work plan and description of its
responsibilities;
c. Description of the marketing departent's goals and achievements;
and
d. Any cost benefit analysis which the Company has performed
regarding the marketing deparent.
PC-4l Contrbutions in Aid of Constrction -
a. Please identify where in the fiing the Company has reduced the
rate base for contrbutions in aid of constrction.
b. If the Company ha not done so, please explain why the
contrbutions in aid of constrction have not been deducted from
rate base;
c. Provide the l2-months of monthy averages of contrbutions in aid
of constrction.
PC-42 Injures and Damages - Please provide the following inormation:
a. Please provide the amount of injures and daage expense
included in the test year.
b. Provide the actul injures and damages paid and chaged to the
accrued injures and damages; and
c. Provide the last five calenda year of actul charges to injures
and damages.
StafCPR_011 Attachment B Page 61 of 264
To: David Meyer
Re: PC Data Requests Nos. 40-52 to Avista
Date: Marh 12, 2009
Page 2 00
PC-43
PC-44
PC-45
PC-46
PC-47
Inures and Damages - Does the Company have an injures and damages
reserve? If so, please answer the following questions:
a. Has the Company deducted the injures and daages reserve from
the rate base?
b. If the Company has not deducted the injures and daages reserve
from the rate base, please provide a detailed explantion of why
the Company ha not; and
c. Please provide an average injures and daages reserve balance for
the test year.
Airlanes - Provide the following inormation regardig the airlanes:
a. Please identify each and every airplane which is on the Company's
books and is charged to ratepayers.
b. Provide the total cost of each aicraft and what dollar amount of
operatig expene of these airaft ha been charged to the State
of Washigtn ratepayers;
c. Provide detailed flight logs for the airlanes together with a
description of their utilization and who the passengers were; and
d. Provide a description of the purose and use of each airlane.
Redemption Expene Amortization -
a. Please provide the accountig and explanation for the Schedule M
adjustment shown on Workpaper B-17 titled "Redemption Expense
Amortzation" in the amount of $3,434,804 (tota Company).
b. Provide all the joural entres and other explantions in order to
understad ths trsaction.
Amortzation - Investient in Exchage Power - Please refer to Workpaper
B-17 of Ms. Andrews' testimony and explai the trsaction tht gives
rise to the amortzation of investment in exchange power. Provide any
supportg documentation, joural entres along with a complete
explantion.
Warsila Generators Amortzation - Please explai the traction which
gives rise to the schedule and adjustment shown on Ms. Andrews'
Workpaper B-1 7 in the amount of$785,184 of the Washigton
jursdiction. Provide any documentation, Commssion orders or other
authoriation which sets out the basis for the treatment of ths
amortzation.
StafCPR_011 Attachment B Page 62 of 264
To: David Meyer
Re: PC Data Requests Nos. 40-52 to Avista
Date: Marh 12, 2009
Page 3 of3
PC-48
PC-49
PC-50
PC-51
PC-52
BP A Residential Exchage - Please provide an explanation of the schedule
and adjustment shown on Ms. Andrews' Workpaper B-1 7 in the amount of
$4,145,039 for the Washigton jursdiction. Provide any supportg
calculations, documentations or Commission orders which results in ths
transaction affectig income taxes.
Washigton Deferred Power Cost - Please provide an explanation of the
Washigton Deferred Power Cost which is shown on Ms. Andrews
'Workpaper B-18 in the amount of$17,668,384. Provide any
documentation and supporting workpapers.
Third Federal Income Taxes - Please refer to Ms. Andrews' Workpaper B-
19. Please provide each tax timig difference that is represented by the
system defered tax and the calculation of tht ta such that the amounts
are reconcilable to the amounts shown on W orkpapers B- 1 7 and B-18.
Storm Resere-
a. Does the Company have a storm reserve?
b. If so, please identify where in the filing the Company has reduced
the rate base for the storm reserve.
c. If the Company has not done so, please explain why the storm
reserve has not been deducted from rate base;
d. Provide the 12-months of monthy averages of the storm reserve.
a.Provide the amount of storm daage expense for each of the last
five calendar years.
Please provide the amount of storm damage expense included in
the test year.
Provide the actul storm daage costs paid and charged to the
storm daage reserve.
b.
c.
Staff_PR_011 Attachment B Page 63 of 264
BEFORE THE WASHIGTON UTILITIES AN TRASPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests No. 53
To: Avista
PC-53 Please provide monthy tral balances for October, 2008 though the
present in the same format as those provided in response to PC- 1 3.
Update ths inormation as it becomes available for any subsequent
months.
StafCPR_011 Attchment B Page 64 of 264
To: Avista
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. 00-090134 and UG-090135
Public Counsel Data Requests Nos. 54 through 85
RE: Direct Testimony of Mark T. Thies:
PC-54
PC-55
Provide copies of the documents cited in footnotes 1 though 5 (on pages
18 though 21) of the Direct Testimony of Mark T. Thies.
Provide any studies or analyses A vista has prepared or obtained that assess
the sensitivity of its power supply expenses to the following risks cited at
page 19, lines 12-16 of the Direct Testimony of Mark T. Thies:
a. "the level and volatilty of wholesale electric market prices
and natural gas prices for fuel costs,"
b. "liquidity in the wholesale market (fewer counterparies and
tighter credit restrctions),"
c. "stream flow and weather conditions," and
d. "relicensing hydro projects".
RE: Direct Testimony of William E. Avera:
PC-56 Provide copies of the documents cited in footnotes 29 though 36 and 38
though 42 (on pages 23 to 26) of the Direct Testimony of
William E. Avera.
RE: Direct Testimony of Scott J. Kinney:
PC-57 Was the impact of the capital investments in trsmission projects
described on pages 12 to 15 of the Direct Testiony of Scott J. Kiney
included in the estiates of power supply expenses provided in the Direct
Testimonies of Messrs. Clint G. Kalich and Willam G. Johnson? If not,
please explain which of the above-referenced projects are not reflected in
such estimates and what the impact might be of including such projects in
preparng such estiates.
RE: Direct Testimony of David B. DeFelice:
PC-58 Was the impact of the capita investments in generation projects described
on pages 10 to 12 of the Direct Testiony of Dave B. DeFelice included
in the estimates of power supply expenses provided in the Direct
Staff_PR_011 Attachment B Page 65 of 264
To: David Meyer
Re: PC Data Requests Nos_ 54- to Avista
Date: March 27,2009
Page 2 of6
Testimonies of Messrs. Clit G. Kalich and Wiliam G. Johnson? If not,
please explain which of the above-referenced projects are not reflected in
such estimates and what the impact might be of including such projects in
preparg such estimates.
RE: Direct Testimony of Tar L. Knox:
PC-59
PC-60
Provide Exhbit No. TLK-2 to the Direct Testiony of Tara L. Knox in
electronic Excel-compatible format with data and formulae intact and
fuctionig.
Identify where in the Direct Testionies, related exhbits and workpapers
of Elizabeth M. Andrws and other A vista witnesses the figues shown in
Exhbit No. TLK-2 to the Direct Testimony of Tar L. Knox may be
found.
RE: Direct Testimony of Brian J. Hirschkom:
PC-61
PC-62
PC-63
Please provide the "company's power supply forecast", "projected
amortization of the deferral balance", and all other workpapers and data
that support the conclusion that ''the ERM deferral balance wil be reduced
to zero by Januar 2010", as stated at Page 6, lines 6 to 8 ofthe Direct
Testimony of-Brian J. Hirchkom.
Is A vista, when it states at page 6, lines 8 to 1 1 of the Direct Testiony of
Brian J. Hirschkom that it wishes to "fie Schedule 93 to reduce the
surcharge rate(s) to zero coincident with the general rate change, and any
remainig deferl balance would be cared forward for recover/refud
in the future", proposing to:
a. Eliminte Schedule 93 as a component of its taffs and rates?
Ifnot, what is Avista's intent as to the continuation of
Schedule 93?
b. Refud or recover any over-collection or under-collection,
respectively, of costs curently billed to ratepayers under
Schedule 93 in some other component of rates? If not, what
is Avista's intent regarding any such balances that may
remai if Schedule 93 is elimated? If so, to what other
accounts is A vista proposing to transfer any remaing
balances for later refud or recovery?
Describe and document with specificity any difference(s) between the
model, modeling method, model input data, and post-processing of model
Stff_PR_011 Attchment B Page 66 of 264
To: David Meyer
Re: PC Data Requests Nos. 54- to Avista
Date: March 27, 2009
Page 3 of6
output between "(t)he company's power supply forecast" for 2009
referenced at page 6, lie 6 of the Direct Testiony of Brian J. Hirschkom
and the power supply expense forecast for 2010 presented in the Direct
Testionies of Clint G. Kalich and Wiliam G. Johnson.
RE: Direct Testimony of Elizabeth M. Andrews:
PC~64
PC-65
PC-66
Provide an electronic copy of llustrtions NO.1 and 2 in the Direct
Testiony of Elizabeth M. Andrews and all data and workpapers used to
prepare these ilustrations. Provide such copies, data and workpapers in
electronic Excel format, with data and formulae intact and fuctionig.
Explai how each number shown on each line of Colum q of Exhibit
EMA-2 to the Direct Testiony of Eliabeth M. Andrews (and discussed
in such testiony at page 18, lines 6 to 12) was prepared or computed.
Explain how each number shown on each line of Colum PF 1 of Exhbit
EMA-2 to the Direct Testiony of Eliabeth M. Andrews (and discussed
in such testimony at page 21, lines lIto 19) was prepared or computed.
RE: Direct Testiony of Clint G. Kalich:
PC-67 Provide the following information regardig the electrc loads used to
model the power supply expenses reported in the Direct Testiony of
Clint G. Kalich:
a. Describe Avista's analytic process for preparg electrc load
forecasts.
b. Provide complete workpapers and source data used to
develop the load forecast used to estiate power supply
expenses in ths case. Provide such materials in electronic
Excel-compatible format with data and formulae intact and
fuctionig.
c. State when the electrc load forecast used to estimate electrc
power supply expenses in ths case was developed.
d. Describe Avista's schedule for making updates to its electric
load forecasts, whether done on a reguar basis or an "as
needed" basis.
e. State whether A vista has changed or wil change the load
forecast it used in ths case to reflect possible changes in load
due to the curent economic downtu. Explai why A vista
wil or will not make such updates.
StafCPR_011 Attachment B Page 67 of 264
To: David Meyer
Re: PC Data Requests Nos. 54- to Avista
Date: March 27, 2009
Page 4 of6
PC-68
PC-69
PC-70
PC-71
PC-72
PC-73
PC-74
Provide copies of Exhbits No. CGK-2 and No. CGK-3 to the Direct
Testiony of Clit G. Kalich in electronic Excel format with data and
formulae intact and fuctionig. Provide data workpapers, model outputs
and other materials used to prepare these Exhbits.
Please describe how eah lie shown in Exhbit No. CGK-2 of the Direct
Testiony of Clit G. Kalch is computed.
Provide a copy of the User Manual, F AQs, and other user documentation
for the AURORAXMP "Dispatch Model", which is first discussed at page
2, lies 8-9 of the Direct Testiony of Clint G. Kalch. (NB. This is not
a request for a copy or license of the model itself)
Provide AURORAXM input data sets and routiely-produced sumares
of such inputs, AURORAXM outputs and routiely-produced sumares
of such outputs, and tools Avista used to post-process AURORAXM
outputs and the results of such post-processing tht Avista used to forecast
its power supply expenes presented in the Direct Testiony of
Clint G. Kalich. When possible, provide such materals in electronic
Excel-compatible format with data and formulae intact and fuctioning
Verify that the spreadsheet "Electric Price Comparison_2010.xls", which
was provided with Mr. Kalich's Confidential Workpapers, provides the
data and analysis used to reach the conclusion that "the Dispatch Model
appropriately values the energy from Avista's resources..." as stated on
page 5, lines 3-4 of the Direct Testiony of Clint G. Kalich. If not,
provide al such data and analyses used to reach ths conclusion, and
provide such materals in electronic Excel-compatible format with data
and formulae intact and fuctionig
Provide source documents and workpapers used to prepare the gas and
electrcity price forecasts shown in Table NO.1 and Table NO.2 (at pages
7 and 8) of the Direct Testimony of Clit G. Kalich. Provide such
materials in electronic Excel-compatible format with data and formulae
intact and fuctionig.
State Avista's rationale for using its chosen means of forecasting gas and
electrcity prices (as provided in Table No. I and Table NO.2 of the Direct
Testiony of Clint G. Kalch) for submitt to a WUC proceedig.
StafCPR_011 Attachment B Page 68 of 264
To: David Meyer
Re: PC Data Requests Nos. 54- to A vista
Date: March 27,2009
Page 5 of6
PC-75
PC-76
PC-77
PC-78
PC-79
Provide the estiated gas price for the Lancaster plant, and related
documentation and workpapers, in the same level of detail provided in
response to the question 73 above.
Provide a sumar of the AURORAXMP input data used to model each
resource shown in Ex. CGK-3 of the Direct Testimony of Clit G. Kalich.
Describe the resources labeled "Market Contract 1," "Market Contract 2,"
"ST Puchases," "ST Sales," "Market Purchases" and "Market Sales" in
Ex. CGK-3 of the Direct Testimony of Clint G. Kalich and explain the
purose for including each of these specific resources in the Exhibit.
Explain each of the "Adjustments" shown at the bottom of the "Costs"
table in Ex. CGK-3 of the Direct Testiony of Clint G. Kalich. Provide
workpapers showing how each such line item is computed in electronic
Excel-compatible format with data and formulae intact and fuctionig.
Please provide the following inormation regarding the data provided in
Mr. Kalich's confidential workpaper titled "ST Deals as of l2-l-08.xls":
a. What are Avista's rationales and processes for making the
tyes of transactions documented in "ST Deals as of 12-1-
08.xls"? Provide any "risk management" policies applicable
to A vista Utilities and other documents that govern A vista
Utilities' evaluation and execution of such transactions.
b. Are the specific transactions identified in "ST Deals as of 12-
1-08.xls"included in Avista's estimate of power supply
expenses for 2009 and 201 O? If so, please explain how each
tye of transaction is included in makg such estiates.
c. How are the net costs of the tyes of transactions identified
in "ST Deals as of 12- 1 -08.xls" recovered from ratepayers?
d. Through the end of ths case, provide monthy updates of the
file "ST Deals as of 12- 1 -08.xls" for all transactions with
delivery periods tht fall at least parally within the years of
2009 or 2010.
RE: Direct Testiony of Wiliam G. Johnson:
PC-80 Provide the tables in the Direct Testimony of Wiliam G. Johnson (at pp. 3
and 5), and all supportg source data and workpapers, in electronic Excel
format with data and formulae intact and fuctionig.
Staff_PR_011 Attachment B Page 69 of 264
To: David Meyer
Re: PC Data Requests Nos. 54- to Avista
Date: March 27, 2009
Page 6 of6
PC-8l
PC-82
PC-83
PC-84
PC-85
Provide workpapers and supportg data supportg the conclusion about
the change in electric expense between the "with" and "without" Lancaster
scenaos, as discussed on page 5, lies 1 to 7 of the Direct Testimony of
Willam G. Johnson.
Explain why each of the "Factors" listed in the left-hand colum of the
table on page 5 of the Direct Testiony of Willam G. Johnon causes a
chage between 2009 and 2010 pro forma costs. Provide data and
workpapers showing how the impact of each such factor was determed.
Such workpapers should be in electronic Excel-compatible format with
data and formulae intat and fuctionig.
State whether chages in the levels of gas and electrc market prices are
considered as possible "Factors" (such as those listed on the table on page
5 of the Direct Testiony of Wilam G. Johnon) tht could cause
chages between the 2009 and 2010 pro forma costs. If so, please explain
where they are reflected in the table on page 5. If not, please explain why
A vista does not consider them to be such "factors".
What is Avista's process for makng the types of "short-term transactions"
discussed page 8, line 22 to page 9, line 2 of the Direct Testiony of
Wiliam G. Johnson? Provide any "risk management" policies or other
documents that govern Avista's execution of such transactions.
Has A vista made any additional "short-term transactions" for calendar
year 2009 and 2010 such as those described at page 8, line 22 to page 9,
line 2 of the Direct Testiony of Wiliam G. Johnson since its testiony
was fied? If so, provide the same inormation regarding these purchases
that was provided in "Johnson CONFIDENTIAL Workpapers.pdf', pages
P2 and P3. Update the response to this question as new short-term
tranactions are made.
StafCPR_011 Attachment B Page 70 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 86 through 137
To: Avista
RE: Direct Testimony of Richard L. Storro:
PC-86 Provide the following information about how A vista "utilizes short and
medium-term wholesale trsactions to balance resources with load
requirements," as stated at page 4, lines 4-5 of the Direct Testimony of
Richad L. Storro.
a) Define the terms "short( -term)" and "medium-term" as used in ths
sentence.
b) Describe the process( es) A vista uses to analyze and execute such
transactions
c) Provide any written documents that govern Avista's analysis and
execution of such transactions.
d) Provide a list of all the trnsactions that meet the above-stated
purose that A vista has entered that have delivery periods tht fall
at least parially withn the years of 2009 or 2010. Provide these
data in an electronic Excel-compatible format with data and
formulae intact, and in a level of detail comparble to data
provided in Mr. Kalich's confidential workpaper titled "ST Deals
as of l2-l-08.xls".
e) State whether Avista distingushes between the above-described
transactions and tractions it may mae pursuat to its Energy
Resources Risk Policy. If so, please describe how A vista
distiguishes between the two tyes of tranactions.
PC-87 Provide the schedules and sumare the results of any Request for
Proposals (RFPs) that A vista ha issued with the last five years with the
goal of making "(l)onger-term resource decisions for new resources,
upgrdes to existing resources, demand-side management (DSM), and
long-term contract purchases...", as described at page 4, lines 5-8 of the
Direct Testiony of Richad L. Storro.
StafCPR_011 Attachment B Page 71 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-090314 & UG-0903l5
Date: March 31, 2009
Page 2 of 14
PC-88
PC-89
PC-90
PC-9l
PC-92
Provide a table sumaring the energy positions (in aM Avista is
"currently projecting" through 2028, which are described at page 4, lines
9-22 of the Direct Testiony of Richard L. Storro.
Provide a table sumaring the capacity position (M A vista is
"currently projecting", consistent with the energy positions described at
page 4, lines 9-22 of the Direct Testimony of Richad L. Storro.
Provide any materials tht have been provided to date to the Techncal
Advisory Committee (TAC) regarding Avista's 2009 Electric IR, as
discussed at page 6, lines 1 -4 of the Direct Testiony of Richard L.
Storro. Update the answer to ths data request as additional materials are
provided to the TAC.
Did A vista envision intaing wind generation at the Rearden site before
the curent on-lie date of2013, which is provided on page 6, lie 16 of
the Direct Testiony of Richa L. Storr? If so, please state what such
earlier dates were and when A vista decided to delay development of the
Rearden site.
Provide the following information regarding Avista's risk management
program for energy resources discussed on page 7 of the Direct Testiony
of Richad L. Storro:
a) Provide a copy of the Energy Resources Risk Policy cited at lie 7,
including all amendments.
b) Provide a list of al tractions A vista has entered pursuat to its
Energy Resources Risk Policy that have delivery periods tht fall
at least parally with the years of2009 or 2010. Provide these
data in an electronic Excel-compatible format with data and
formulae intact, and in a level of detail comparble to data
provided in Mr. Kalich's confidential workpaper titled "ST Deals
as of l2-l-08.xls".
Smff_PR_011 Attachment B Page 72 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-090314 & UG-090315
Date: March 31, 2009
Page 3 of 14
PC-93
PC-94
Did A vista compare the benefits and costs of the Lancaster Power
Purchase Agreements (PP A) to the benefits and costs of other PP As
available in the market? If not, please explai why A vista did not do so.
If so, please provide all such analyses or provide citations to them in
Avista's testimony in this case.
Provide the following inormation regarding the sale of A vista Energy to
Cora Energy, discussed at page 9, lines 17-19 of the Direct Testimony of
Richard L. Storro:
a) Provide any and all analyses or sumares of the sale that were
presented internally within Avista, to Avista's Board of Directors,
to Cora Energy and its business parers (if any), to ratings
agencies and investors, and to other potentially-interested pares
about the sale of Avista Energy to Coral Energy.
b) Provide the contract, including al amendments and related
documents, under which A vista sold A vista Energy to Coral
Energy.
c) Provide the offers, counter-offers, and related communcations tht
A vista and Coral Energy exchanged durg the negotiation of the
sale of Avista Energy to Coral Energy.
d) Unless provided in sub-part 'a' above, provide any and all analyses
or sumares of the sale that were presented internlly within
Avista, to Avista's Board of Directors, to Coral Energy and its
business parers (if any), to ratings agencies and investors, and to
other potentially-interested partes about the acquisition of rights to
the Lancaster PP A from Coral Energy by A vista Utilities.
e) Unless provided in response to sub-part 'b' above, provide the
contract, includig all amendments and related documents, under
which "rights to the Lancaster PPA" were to be made available by
Cora Energy to A vista Utilities.
f) Unless provided in response to sub-par 'c' above, provide the
offers, counter-offers, and related communcations tht Avista and
Coral Energy exchaged durg the negotiation of Cora Energy's
provision to A vista Utilities of the "rights to the Lancaster PP A".
g) State whether any of the offers, counter-offers, and related
communications that A vista and Coral Energy exchaged durg
the negotiation of the sale of A vista Energy to Coral Energy also
StafCPR_011 Attachment B Page 73 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-0903l4 & UG-090315
Date: March 31,2009
Page 4 of 14
PC-95
PC-96
contaed any offer, counter-offers, or related communcations
regarding Coral Energy's provision to Avista Utilties of the
"rights to the Lancaster PPA".
Answer the following questions regarding the statement that "(t)he
opportty to acquire the power purchase agreement (tolling) rights for
Lacaster related to the sale of A vista Energy which held the rights to ths
tollng agreement" at page 9, lines 1 1-13 of the Direct Testiony of
Richard L. Storro:
a) Whch par to the negotiations between Avista and Cora Energy
first suggested that Cora Energy could make the rights to the
Lancaster PP A available to A vista Utilities?
b) Were the negotiations for the trfer of the rights to the Lacaster
PP A conducted separtely from the negotiations for the sale of
Avista Energy to Cora Energy, or were the negotiations regarding
the Lancaster PP A held wholly or parly in conjunction with the
A vista Energy sale negotiations?
c) What policies does A vista observe when conducting business on
behalf of A vista Utilties to protect the interests of A vista Utilities'
ratepayers? Were these policies observed durg the negotiations
tht led to the trfer of rights to the Lacaster PP A to A vista
Utiities?
d) Did any representative of A vista Utilities parcipate in any of the
negotiations with Coral Energy that resulted in the agreement that
made the Lancaster PP A available to A vista Utilities? If not,
please explain why no one from A vista Utiities so parcipated. If
so, please identify the individual(s) who parcipated, their titles
and their departents with A vista Utilities.
Provide copies of the documents related to the Lancaster PP A acquisition
described on pages 10 and 11 of the Direct Testimony of Richard L.
Storro, including the PPA (page 9, lines 4-9), the assignents of natul
gas tranporttion capacity (page 9, lines 10-18) and the assignent of
tranmission rights (page 9, line 19 to page 10, line 3), including al
amendments and other documents affecting their interpretation and
adinstrtion.
Staff_PR_011 Attachment B Page 74 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-0903l4 & UG-0903l5
Date: March 31, 2009
Page 5 of 14
PC-97
PC-98
PC-99
Answer the following questions regarding the sentence "As par ofthe
April 17, 2007 anouncement of the salè of A vista Energy to Cora
Energy, the Company also anounced that Avista Utilities would have
rights to the Lancaster PPA beging on January 1,2010", which is on
page 9, lines 18-19 of the Direct Testimony of Richard L. Storro:
a) As of Apri!7, 2007, was Avista Utilities fully committed to
makig fixed payments for the Lancaster project puruat to the
PPA as ofJanuar 1, 201O?
b) If the answer to sub-part 'a' above was 'No,' state what additional
conditions needed to be met or decisions made before A vista
Utilities was fully commtted to makg such fixed payments.
c) If the answer to sub-part 'a' above was 'No,' state what additional
conditions or decisions described in sub-par 'b' above have
aleady been met or made, and when A vista expects the other .
conditions to be met or decisions made.
d) If the answer to sub-par 'a' above was 'No,' state what additional
decisions A vista has made, or is still evaluatig, to assess whether
it wil be beneficial to ratepayers to complete the Lancaster PP A
acquisition and assume responsibility for making the PPA's fixed
cost payments.
e) If the answer to sub-part 'a' above was 'No,' state why Avista
engaged Thorndike Landing to provide an "independent
assessment" of the Lancaster PP A in August 2007, as described on
page 12, lines 10-19.
Provide the complete data and workpapers used to develop the values
shown in Ilustrtions NO.3 and NO.4 (pages 13 and 14) in the Direct
Testiony of Richard L. Storro.
Identify the author(s) of Exhbit No. _ (RLS-4) to the Direct
Testiony of Richard L. Storro, and the subsidiar and deparent of
A vista in which they worked at the tie the Exhbit was prepared.
Staff_PR_011 Attachment B Page 75 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-0903I4 & UG-090315
Date: March 31, 2009
Page 6 of 14
PC-lOO
PC-lOI
PC-102
PC-l03
PC-104
PC-105
Identify the individuals, and their titles and subsidiares or deparents of
A vista who "asked" Energy Resources "to determine if A vista utilities
would benefit from acquisition of the 275 MW Lancaster Generatig
Facility Power Purchase Agreement", as stated at page 1 of Exhibit
No. _ (RLS-4) to the Direct Testimony of Richard L. Storro.
On what date was Energy Resources fist asked to analyze the Lancaster
PPA, as stated at page 1 of Exhibit No. _ (RLS-4) to the Direct
Testiony of Richad L. Storro?
Please provide all internal communcations with A vista including
withn A vista Utities, and among A vista affiliates and subsidiares,
related to the request that Energy Resources analyze acquisition of the
Lacaster PPA and regarding Energy Resources' subsequent analyses that
resulted in Exhbit No. _ (RS-4) to the Direct Testiony of Richad L.
Storro.
Did A vista assess whether power from any of the CCCT resources listed
on Table 1 (p. 2) of Exhbit No. _ (RLS-4) to the Direct Testiony of
Richard L. Storro would be available puruat to a Power Purchase
Agreement? If not, why not?
Did Avista gather any data, simar to that in Table 2 (p. 3) of Exhibit No.
_ (RLS-4) to the Direct Testiony of Richard L. Storro, about the terms
of recent long-term Power Purchase Agreements from CCCT plants?
Provide workpapers documenting the estiated cost of $3 millon for
interconnecting the Lancaster plant diectly to the Avista transmission
system, as stated on page 3 of Exhbit No. _(RLS-4) to the Direct
Testiony of Richad L. Storro.
StafCPR_011 Attachment B Page 76 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-0903l4 & UG-0903l5
Date: March 31, 2009
Page 7 of 14
PC-106
PC-l07
PC-l08
Please answer the following questions regarding the statement on page 3
of Exhibit No. _ (RLS-4) to the Direct Testiony of Richad L. Storro
that "Under the assumption that A vista wil be able to interconnect
Lacaster diectly to its trasmission system, it wil not requie BP A
transmission during most ofthe year":
a) Please explain why A vista would apparently stil require BP A
trmission durg some of the year, even if Lancaster was
interconnected diectly to the Avista system.
b) Did Avista's analysis consider the possibility it would both build
the interconnection between Lancaster and its own transmission
system and procure trmission from BP A to transmit power from
Lancaster to A vista loads? If not, please explain why not.
In the middle of page 3 of Exhbit No. _(RLS-4) to the Direct
Testiony of Richard L. Storro, the statement is made that "only 25
percent of the existing firm trsmission contract is not recovered" and at
the bottom the statement is made that "(aJ 25 percent cost recovery is a
reasonable assumption". Please answer the following questions:
a) Whch assumption about transmission cost recovery did Avista use
to analyze the value of the Lancaster PP A?
b) What is Avista's basis for making the assumption described in sub-
part 'a'?
Provide data and workpapers documenting the assumption that the cost of
the Lancaster PP A would rise by $66 millon if no trsmission capacity is
re-marketed or otherwise optimized, as stated on page 3 of Exhibit No.
_ (RLS-4) to the Direct Testiony of Richard L. Storro. Provide such
inormation in an electronic Excel-compatible format with data and
formulae intact and fuctionig.
Staff_PR_011 Attachment B Page 77 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-0903l4 & UG-090315
Date: March 31, 2009
Page 8 of 14
PC-l09
PC-L 10
PC-1l1
PC-1l2
Provide data and workpapers documentig the assumption of 25 percent
cost recover ofBPA trsmission costs represents a cost of
approximately $42 millon on a present value basis, as stated on page 3 of
Exhbit No. _ (RLS-4) to the Direct Testiony of Richad L. Storro.
Provide such inormation in an electronic Excel-compatible format with
data and formulae intat and fuctionig.
Provide data documenting the statement tht an endig value for
"brownfield" plants, discussed on page 4 of Exhibit No. _ (RLS-4) to
the Direct Testimony of Richard L. Storro, of 10 percent is "in line with
industr estimates".
Provide data and workpapers documenting how the endig values of
"greenfield" plants discussed on page 4 of Exhibit No. _ (RLS-4) to the
Direct Testiony of Richad L. Storro are computed. Provide such
inormation in an electronic Excel-compatible formt with data and
formulae intat and fuctionig.
On page 5 of Exhbit No. _ (RLS-4) to the Direct Testiony of Richard
L. Storro, the statement is made tht thee start dates were evaluated for
the Lancaster PPA because "negotiations with Coral Energy are ongoing".
On what date was it known the date on which the Lacaster PP A would be
made available to A vista Utiities?
Staff_PR_011 Attachment B Page 78 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-0903l4 & UG-0903l5
Date: March 31, 2009
Page 9 of 14
PC-l 13 Provide the following information and answer the following questions
regarding the "IR methodology" under which ''the capital recovery and
other fixed costs associated with plant ownership" should be considered as
a value of a plant when the utility is short, as stated on page 4 of Exhbit
No. _ (RLS-4) to the Direct Testimony of Richad L. Storm:
a) What is Avista's basis or rationale for this assumption?
b) In A vista's opinion, has the WUC endorsed this policy? If so,
please provide citation(s) to relevant WUC decisions.
c) Does Avista believe that when it is short of capacity, the value of
any new resoure should include the capital recovery and other
fixed costs of such resource regardless of how high or low such
costs are? If the answer is No, please explain under what
conditions the resource's value would not include its own fixed
costs.
PC-114 Regardig Table 3 (p. 7) of Exhbit No. _ (RLS-4) to the Direct
Testimony of Richard L. Storro:
a) Provide Table 3 in electronic Excel-compatible format with all
data and formulae intact and fuctionig.
b) Provide all data and workpapers used to prepare all data shown in
Table 3 in electronic Excel-compatible format with all data and
formulae intact and fuctionig.
StafCPR_011 Attachment B Page 79 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-090314 & UG-0903l5
Date: March 31, 2009
Page 10 of 14
PC-115
PC-1l6
PC-I17
PC-1l8
Provide the following inormation regarding Avista's engagement of
Thorndike Ladig, LLC (TL) to perorm an analysis of the Lancaster
tolling agreement, as discussed on pages 1 and 3 of Exhbit No. _ (RLS-
5) to the Direct Testiony of Richard L. Storro:
a) Wht subsidiar or deparent of Avista engaged TL?
b) When did A vista fist contact TL regarding such an engagement?
c) When did A vista execute its contrct with TL for the engagement?
d) Was the TL analysis intended to help A vista make decisions prior
to its fil commitment to the Lancaster PP A and its related fied
costs, or was the study commssioned after A vista had aleady
made a fil commtment to the Lacaster PP A?
Did Avista's instrctions to TL, which are summarized on page 3 of
Exhbit No. _(RS-5) to the Direct Testiony of Richad L. Storro,
include any intrctions to assess the value of the Lacaster PP A from the
perspective of A vista ratepayers? If not, explain why not. If so, provide
the verbatim text of the intrctions A vista believes provided ths diection
to TL.
Provide complete workpapers for all aspects of the report provided Exhbit
No. _ (RLS-5) to the Direct Testiony of Richard L. Storm. Provide
such workpapers in electronic Excel-compatible format with data and
formulae intact and fuctionig.
Provide a timeline tht documents the following aspects of historic
Lacaster power plant ownership and operations from Januar 1, 2006
though the present and its expected ownership and operations from the
present though Janua 31, 2010:
a) Ownership of the plant. Identify the majority owner or controllig
interest and all known limted or miority interests.
b) Par with Operations and Maintenance contract for plant, as
referenced on page 5 of Exhibit No. _ (RLS-5) to the Direct
Testimony of Richard L. Storro.
c) Par with rights to electrc output of plant. Sumarze known
terms of any contracts for such output.
Staff_PR_011 Attachment B Page 80 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-0903l4 & UG-090315
Date: March 31, 2009
Page 11 of 14
PC-119
PC-l20
PC-12l
PC-122
Answer the following questions regardig the following aspects of
Lacaster power plant ownership and operations, which are rased on
pages 7 and 8, respectively, of Exhibit No. _(RLS-5) to the Direct
Testiony of Richad L. Storro:
a) To what "unrelated third par" was the toll assigned on July 1,
2007? Under what contractul or commercial arngements was
such assignent made?
b) Wht thd par manages the Lancaster plant pursuant to the
Operations and Maintenance agreement? Describe ths thd
part's relationship to A vista Corporation and its subsidiaries.
Provide the following information regarding TL's Integrated Energy and
Capacity Model (IECM), first described on page 7 of Exhibit No.
_(RLS-5) to the Direct Testiony of Richard L. Storro:
a) A copy of IECM user documentation.
b) Al IECM input and output files, includig post-processing tools,
TL used to prepare its anlysis report for each of the thee
scenaos TL simulated.
c) Workpapers compiling IECM results into TL's overall Discounted
Cash Flow analysis, includig separate energy and capacity
revenues, for each of the thee scenos TL simulated.
Did TL assess whether power from any Combined Cycle / Combustion
Turbine (CCCT) plants, such as those identified in the first paragraph of
page 11 or the table at the bottom of page 12 of Exhbit No. _ (RLS-5)
to the Direct Testimony of Richard L. Storro, was available to buyers
pursuant to tolling contrcts or other power purchase arangements?
Provide Tables 2 to 6 (pp. 17-19) of Exhbit No. _ (RLS-5) to the Direct
Testimony of Richad L. Storro in electronic format, including all
supportng workpapers and spreadsheets and data. Provide such
workpapers in electronic Excel-compatible format with data and formula
intact and fuctioning.
StafCPR_011 Attachment B Page 81 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-090314 & UG-0903l5
Date: March 31, 2009
Page 12 of14
PC-123
PC-124
PC-125
PC-126
Please answer the following questions regarding the high and low cases
TL developed, which are described on page 18 of the Exhbit No. _
(RLS'-5) Direct Testiony of Richard L. Storro:
a) How did TL develop its high and low cases?
b) Does Avista believe TL's high and low cases reasonably bound
possible outcomes as to the value of the Lacaster PP A?
c) Wht impact on capacity prices and energy prices did the
additiona 5,000 MW of combined cycle capacity have in the low
case?
d) Does Avista believe the Lacaster PPA's value would var as gas
prices var? It not, why not? If so, why didn't TL include such
varations in its high and low scenos?
Describe.the mean for capacity pricing in IECM, among those discussed
at page 20 of the Exhbit No. _ (RLS-5) Direct Testimony of Richad L.
Storro, tht TL used in the Lacaster PP A study for A vista.
Provide TL's "standard forecasts" for emissions allowances, as discussed
at page 21 of the Exhibit No. _ (RLS-5) Direct Testiony of Richard L.
Storro. Does TL have similar "standard forecasts" for other drvers of
value in power plants and contrcts? If so, provide them as well.
Answer the following questions about TL's "introduction of volatility"
into its modelig, as discussed at page 21 of the Exhbit No. _ (RLS-5)
Direct Testiony of Richad L. Storro:
t) Explain in general how TL "introduced" volatility into its
modeling.
g) As to the statement that TL introduced 'Just enough volatilty, on a
simple mean-reverting basis, to result in appropriate retus for the
flexible plants", explain how TL determined how much volatility
was 'Just enough". Provide data and workpapers documenting ths
determintion.
Staff_PR_011 Attachment B Page 82 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-0903l4 & UG-0903l5
Date: March 31, 2009
Page 13 of 14
PC-127
PC-l28
PC-129
PC-130
PC-13 1
PC-132
Were the varous assumptions listed in the table on page 21 of Exhbit No.
_ (RLS-5) to the Direct Testiony of Richard L. Storro developed
independently by TL, specified by A vista, or developed by some other
process? Provide data and workpapers supporting the development of
these assumptions in electronic Excel-compatible format with data and
formulae intact and fuctionig.
Provide tables in Appendix C of Exhbit No. _ (RLS-5) to the Direct
Testiony of Richard L. Storro and supporting data and workpapers in
electronic Excel-compatible format with data and formulae intact and
fuctionig.
Identify the author(s) of Exhibit No. _ (RLS-6) to the Direct Testimony
of Richad L. Storro, and the subsidiares and deparents of Avista in
which they worked at the tie the Exhbit was prepared.
Provide complete workpapers for all aspects of the report provided Exhibit
No. _ (RLS-6) to the Direct Testiony of Richard L. Storro. Provide
such workpapers in electronic Excel-compatible format with data and
formulae intact and fuctionig.
In using the verb "plans," the first line of Exhibit No. _ (RLS-6) to the
Direct Testimony of Richard L. Storro suggests that, as of November 2,
2007, A vista Utilities had not made a fial decision about whether to
"acquire" the Lancaster PPA. Is this implication of this first line correct?
State the date(s) on which Avista's various decisions about acquiring the
Lacaster PP A were made or otherwise became finaL.
Does A vista believe any other prudence criteria regarding the Lacaster
PP A are applicable in WUTC proceedigs besides the criteria cited on
page I of Exhibit No. _ (RLS-6) to the Direct Testiony of Richard L.
Storro (i.e., the 11th Supplemental Order and 19th Supplemental Order in
Docket No. UE-920433)? If so, please identify such criteria.
StafCPR_011 Attachment B Page 83 of 264
To: David Meyer
Re: PC Data Requests Nos. 86 though 137
Docket Nos. UE-090314 & UG-0903l5
Date: March 31, 2009
Page 14 of14
PC-133
PC-134
PC-135
PC-136
PC-137
Provide workpapers and source data used to prepare all Tables in Exhbit
No. _ (RLS-6) to the Direct Testiony of Richard L. Storr. Provide
such workpapers and data in electrnic Excel-compatible format with
formulae and data intat and fuctionig.
Where in Avista's 2007 IR does it state ''that 350 MW of additional
base-load CCCT capability (naeplate MW) should be included in the
overal PRS for the fit 10 years (2008-2017) of the 20-year plang
horizon", as stated on page 4 of Exhibit No. _ (RLS-6) to the Direct
Testiony of Richad L. Storr?
At what point durg the negotiations betwee A vista and Cora Energy
was the ''tansfer date" of Januar 1,2010 established (as opposed to the
alterntives dates of Janua 1 of 2009 or 2011 provided on page 4 of
Exhbit No. _ (RLS-6) to the Direct Testiony of Richad L. Storro)?
Does the term "brownfield" as used on page 5 of Exhibit No. _ (RLS-6)
to the Direct Testiony of Richad L. StorfO refer only to aleady-existing
plants, or does it also include new plants that could be built at an existing
power plant or industral site?
Provide workpapers and source data supporting the claim made at page 5
of Exhbit No. _ (RLS-6) to the Direct Testiony of Richard L. Storro
that Idaho's lack ofa fuel tax results in approximately $2 millon in
additional anual savings not documented in Exhibit No. _ (RLS-4) to
the Direct Testimony of Richard L. Storro.
Staff_PR_011 Attachment B Page 84 of 264
To: Avista
BEFORE THE WASHINGTON UTILITIES AN TRNSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. 00-090134 and UG-090135
Public Counsel And ICNU Data Requests Nos. 138 through 164
RE: Direct Testimony of Avista witness Dr. Wiliam E. Avera:
PC-138
PC-139
PC-140
PC-14l
PC-142
PC-143
On an electronic spreadsheet with all formulae intact, please provide a
copy of all analyses and workpapers used in support of Dr . Avera's direct
testiony and exhibits in ths proceeding.
Please provide copies of all credit reports published by Standard & Poor's
(S&P), Moody's and Fitch Ratings for Avista Corp. and all of its operating
utility affates tht were reviewed by Dr. Avera in support of his diect
testimony.
If not already provided in response to Public Counsel and ICNU Data
Request No. 139 above, please provide complete copies of all credit
report and publications referenced in the footnotes to Dr. Avera's direct
testimony and exhbits.
Referring to page 5 of Dr. Avera's direct testimony, please provide a copy
of all workpapers supporting the testimony: "S&P ranks A vista as 1 5 9 of
1 75 utilities with investment grade credit rating."
Referrng to page 6 of his testiony, please provide a copy of all reference
documents and workpapers in support of Dr. Avera's testiony that
"sensitivity to regulatory uncertainties has increased dramatically."
Referrg to page 33 of Dr. Avera's direct testimony, please identify
Avista's exposure to off-balance sheet debt such as purchased power
agreements, opertig leases, etc. On an electronic spreadsheet with all
formulae intact, please:
a) Provide a copy of the supportng analyses.
StafLPR_011 Attchment B Page 85 of 264
To: David Meyer
Re: PC Data Requests Nos. 138 though 164
Docket Nos. UE-0903l4 & UG-090315
Date: April 14, 2009
Page 2 of4
PC-144
b) Estiate the imputed interest and amortation expense associated
with off-balance sheet debt.
At pages 43-45 of Dr. Avera's direct testiony, he discusses the
application of flotation costs. Please identify if Dr. Avera's flotation cost
adjustment has ever been approved by the Washigton Utilities and
Trasporttion Commission or any other regulatory commssion. If in the
affiative, please provide the jursdiction, the docket number, utility and
order date where it was approved.
PC-145
Re: Direct Testimony of Mark T. Thies:
PC-146
PC-147
PC-148
PC-149
PC-150
Please provide copies of all credit reports published by S&P, Moody's and
Fitch Ratigs for Avista and al of its opertig utility affliates issued
over the last two years.
If not already provided in response to Public Counsel and ICNU Data
Request No. 145 above, please provide complete copies of all credit
reports and publications referenced in the footnotes to Mr. Thes's diect
testiony and exhbits.
Referrg to page 4 of Mr. Thies's diect testiony, please identify the
anual cost of the new $200 milion line of credit and $30 millon five-
year pnvate placement debt issuace.
Referrg to page 5 of Mr. Thies's direct testimony, please describe
Avista's Accounts Receivable Sales Program and identify its terms and
conditions, includig the curent amount of the accounts receivables sold
and its cost.
At page 5 of his direct testiony, Mr. Thies states that Avista maitain an
ongoing dialog with the rating agencies. Please provide a copy of all
presentations, correspondence and any other material A vista provided to
credit and equity analysts over the last two years.
At page 5 of his diect testiony, Mr. Thes states that the Company is
tring to recover its costs in a timely maner "so that eared returs are
closer to those allowed by regulators . . . because ths is one of the key
determints from the rating agencies' standpoint." Please provide a copy
of all documents and material tht support ths statement.
StafCPR_011 Attachment B Page 86 of 264
To: David Meyer
Re: PC Data Requests Nos. 138 though 164
Docket Nos. UE-0903l4 & UG-090315
Date: April 14, 2009
Page 3 of4
PC-151
PC-152
PC-153
PC-154
PC-155
PC-156
PC-157
PC-158
Referrg to Ilustrtion NO.1 at page 12 of Mr. Thies's testimony, on an
electronic spreadsheet with all formulae intact, please provide a copy of
the workpapers used to develop the grph shown on ths page.
At pages 12 and 13 of his direct testiony, Mr. Thies sumares the
rating actions tht occured in 2007 and 2008. Please provide complete
copies of the credit reports issued by the major credit rating agencies in
support of the described credit ratig actions.
Referrg to Ilustration NO.3 at page 15 of Mr. Thies's testimony, on an
electronic spreadsheet with all formulae intact, please provide a complete
copy of all workpapers used to derive the S&P ficial ratios for the 12-
month period ended September 30, 2008 for A vista.
At page 17 of his diect testiony, Mr. Thes states that S&P has
estimated a tota of $154 milion off-balance sheet debt equivalents.
Please provide:
a) The S&P report in support of ths statement and estiate the related
imputed interest and amortzation expense associated with ths ofI-
balance sheet debt equivalent.
b) An electronic spreadsheet simar to the one used by S&P, preferably
provided by S&P, that shows the calculations of the ratios shown on
Ilustration NO.3.
Please estimate Avista's jurisdictional credit metric fInancial ratios using
S&P's methodology based on Avista's current and proposed rates.
Provide all workpapers on an electronic spreadsheet with all formulae
intact.
Referrg to page 21 of Mr. Thies's direct testiony, please identify
Avista's historical and expected regulatory lag.
Referrg to page 23 of Mr. Thies's direct testimony, please identify and
provide a workpaper that develops Avista's cost of trst preferred
securties.
Referrg to pages 23 and 24 of Mr. Thes's direct testiony and
Ilustrtion No.5, please identify each outstading debt instrent tht
wil matue in the next thee year and provide a copy of all studies
StafCPR_011 Attachment B Page 87 of 264
To: David Meyer
Re: PC Data Requests Nos. 138 though 164
Docket Nos. UE-090314 & UG-090315
Date: April 14,2009
Page 4 of4
PC-159
PC-160
PC-161
PC-162
PC-163
PC-164
outlining the Company's assessment of economic debt refinancing
opportties.
Referrg to pages 27 and 28 of Mr. Thes's diect testiony, please
explain the reasons for Avista's decision not to issue preferred equity to
fice its capita requirements.
Please provide the monthy average balances for constrction work in
progress and short-term debt for the most recent 13-month period.
At page 28 of his diect testiony, Mr. Thies states tht Exhbit
No. _(MTT-2) shows the pro forma capital strctue as of December 31,
2010. However, ths exhbit only shows the capital strctues as of
December 31, 2008 and 2009. Please provide a pro forma capita strctue
as of December 31,2010, and copies of al supportg documents.
Referrg to pages 28 and 29 and Exhbit No. _(MIT -2), page 2, on an
electronic spreadsheet with al formulae intat, please provide a copy of all
workpapers used to:
a) Derve the actul long-term debt balance of $1,041,414 and its cost of
debt of 6.51 percent.
b) Determine the cost of the forecasted debt issuaces of $66.7 milion
and $150.0 million.
c) Estiate the cost of all varable long-term debt issuances of $40.0
million and $17.0 millon.
Referrg to pages 28 and 29 and Exhbit No. _(MTT -2), page 2, please
reconcile the long-term debt balance shown on tht exhibit with the
financial statements filed with the Federal Energy Regulatory Commission
(FERC) in its Form 1.
Referrg to page 29 of Mr. Theis's direct testiony, on an electronic
spreadsheet with all formulae intact, please provide a copy of all
workpapers in support of the statement: "The pro-forma weighted cost of
total debt was reduced from 3.51 percent to 3.45 percent."
StafCPR_011 Attchment B Page 88 of 264
BEFORE THE WASHINGTON UTILITIES AN TRASPORTATION
COMMSSION
To: Avista
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 165 through 176
RE: Avista's Response to Public Counsel Data Request No. 63
PC-165 Regarding this statement from A vista's response to Public Counsel Data
Request No. 63 "Forward gas and electric prices, however, were based on
prevailing forward market prices on a given day. To the extent that
generation or expense assumptions depared from normal, but were
expected to occur, this forecast model ru would also be different from a
normalized run":
a) Provide the forward gas and electrc prices being referenced in ths
response (that is, those used to prepare Avista's 2009 forecast of
power supply expenses referenced by Mr. Hirschkorn).
b) Identify, provide, and document those "generation or expense
assumptions (that) depared from normal, but were expected to
occur" that were used to prepare Avista's 2009 forecast of power
supply expenses referenced by Mr. Hirschkorn.
RE: Avista's Response to Public Counsel Data Request No. 64
PC-166 Provide, in electronic Excel-compatible format with data and formulae
intact and fuctionig, complete workpapers and data that document the
computation of the thee numbers provided in Attchment A to Avista's
response to Public Counsel Data Request No. 64.
RE: Avista's Response to Public Counsel Data Request No. 71
PC-167 Avista's response to Public Counel Data Request No. 71C appears to
include only modifications Avista made to the AURORAXMP input
assumptions in the database provided by EPIS, AURORA's vendor. State
whether this conclusion is correct, and if not, what specifically was
provided in such response.
&aff_PR_011 Attachment B Page 89 of 264
To: David Meyer
Re: PC Data Requests Nos. 165 though 176
Docket Nos. UE-0903l4 & UG-090315
Date: April 23, 2009
Page 2 of4
RE: Avista's Response to Public Counsel Data Request No. 71
PC-168 If not provided in Avista's answer to Public Counsel Data Request No.
7LC, provide the "AURORAXMP input data sets and routiely-produced
sumares of such inputs, AURORAXM outputs and routiely-produced
sumares of such outputs, and tools A vista used to post-process
AURORAXM outputs and the results of such post-processing that Avista
used to forecast its power supply expenses presented in the Direct
Testimony of Clint G. Kalich". If such information was provided inthat
response, please state specificaly where such inormation may be found.
RE: Avista's Response to Public Counsel Data Request No. 74
PC-169 Provide specific citations to which commission decisions A vista relies
upon as creatig the "commission precedent for forecasting gas and
electricity prices" that was referenced in Avista's response to Public
Counsel Data Request No. 74.
RE: Avista's Response to Public Counsel Data Request No.7
PC-170 Complete Avista's response to Public Counsel Data Request No. 77 by
statig what the terms "Market Purchases" and "Market Sales" mean in
Exhbit No. _ (CGK-3) of the Direct Testiony of Clint G. Kalich
mean and explain the purose of includig these specific resources in the
Exhbit.
RE: Avista's Response to Public Counsel Data Request No. 81
PC-17l Enhance Avista's response to Public Counsel Data Request No. 81 by
providing, for both the "with" and "without" Lancaster AURORAXMP
simulations referenced therein the AURORAXM input data sets and
routinely-produced sumares of such inputs, AURORAXM outputs and
routinely-produced sumares of such outputs, and tools A vista used to
post-process AURORAXM outputs and the results of such post-
processing.
StafCPR_011 Attchment B Page 90 of 264
To: David Meyer
Re: PC Data Requests Nos. 165 though 176
Docket Nos. UE-0903l4 & UG-0903l5
Date: April 23, 2009
Page 3 of4
RE: Avista's Response to Public Counsel Data Request No. 91
PC-l72 Enhance Avista's response to Public Counsel Data RequestNo. 91 by
explaining why "(i)n the second half of2008, the Company decided to
delay the (Reardan) project to 2013."
RE: Avista's Response to Public Counsel Data Request No. 93
PC-173 Clarify Avista's response to Public Counsel Data Request No. 93 by
stating where in that answer A vista discusses how it "compare( d) the
benefits and costs of the Lancaster Power Purchase Agreements (PP A) to
the benefits and costs of other PPAs available in the market".
RE: Avista's Response to Public Counsel Data Request No. 97
PC-174 Answer the following questions regarding Avista's response to Public
Counsel Data Request No. 97, in which the company stated in sub-par (b)
that "regulatory approval for cost recovery is the only remainig condition
that needs to be met before A vista Utilities becomes fuly commtted to
makg the fixed payments pursuant to the PPA beging on Januar 1,
2010":
a) What WUC cost recovery terms and conditions does A vista see
as mimally necessar to satisfy the above condition?
b) Are the terms and conditions outlined in sub-par (a) referenced or
documented in the agreement(s) between Avista Corporation and
Coral Energy related to the sale of A vista Energy to Cora Energy?
If so, provide such documents.
c) Are the terms and conditions outlined in sub-par (a) referenced or
documented in any other written form? If so, provide such
documents.
d) If the WUC makes a decision on cost recovery that does not
conform to the conditions described in sub-par (a) above, what
would A vista Turbine Power do with the power available to it
puruant to the Lancaster PP A after Janua 1, 201 O?
Staff_PR_011 Attachment B Page 91 of 264
To: David Meyer
Re: PC Data Requests Nos. 165 though 176
Docket Nos. UE-090314 & UG-0903l5
Date: April 23, 2009
Page 4 of4
RE: Avista's Response to Public Counsel Data Request No. 113
PC-175 Complete Avista's response to Public Counsel Data Request No. 113(b)
by providing the specific WUC Order Numbers and page references, and
not just docket numbers, in which the WUC has endorsed the policy tht
"the capital recovery and other fied costs associated with plant
ownership' should be considered as a value of a plant when the utility is
short."
RE: Avista's Response to Public Counsel Data Request No. 61
PC-176 Please provide the following inormation regardig Attchment A to
Avista's response to Public Counsel Data Request No. 61:
a) Provide Attchment A in electronic Excel-compatible format with
data and formulae intat and fuctionig.
b) Explain the process for estiatig each row of figues shown in
Attchment A, including the method for estiatig each monthy
value.
c) Provide workpapers and data documenting the development of each
number shown in Atthment A. Provide such workpapers in
electronic Excel-compatible format with data and formulae intact and
fuctionig.
StafCPR_011 Attachment B Page 92 of 264
BEFORE THE WASHINGTON UTILITIES AN TRASPORTATION
COMMSSION
To: Avista
PCC-177
PCC-178
PCC-179
PCC-180
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 177 through 188
Has A vista conducted any studies of its trends in weather adjusted gas or
electrc customer energy usage levels since Janua 1, 2007? If
affiative, please describe each such study and provide complete copies
of all documents associated with each study.
Please provide (in Excel electronic form) the following actual (not weather
adjusted) Washigton gas sales statistical data for each of the residential
and small commercial customer classes and rate schedules for each of the
past 10 years (1999 though 2008):
a. Actu number of gas customers served.
b. Actu gas therm sales.
c. Averge anual sales per customer.
Please provide (in Excel electronic form) weather normalized Washigton
gas sales statistical data for each of the residential and small commercial
customer classes and rate schedules for each of the past 10 years (1999
though 2008):
a. Actul number of gas customers served.
b. Actul gas therm sales.
c. Calculations showing adjustments to actul therm sales in par b
usingto sets of data, with one set calculating weather normalized
usage according to A vista's curent weather normalization
methodology, and the other set according to the weather
normalization methodology previously utilized in Washigton.
d. Resulting weather normalized anual therm sales per average
customer, under each weather normalization calculation
methodology.
Please provide (in Excel electronic form) the following actul (not weather
adjusted) Washigton electrc sales statistical data for each of the
residential and smal commercial customer classes and rate schedules for
each of the past 10 years (1999 though 2008):
a. Actul number of electrc customers served.
b. Actul electrc kwh sales.
c. Average anual kwh sales per customer.
Staff_PR_011 Attachment B Page 93 of 264
To: David Meyer
Re: PC Data Requests Nos. 177 thugh 188
Docket Nos. UE-090314 & UG-090315
Date: April 30, 2009
Page 2 of4
PCC-18l
PCC-182
PCC-183
PCC-184
PCC-185
Please provide (in Excel electronic form) weather normalized Washigton
electrc sales statistical -datafor each of the residential and small
commercial customer classes and rate schedules for each of the past 10
year (1999 though 2008):
a. Actual number of electrc customers served.
b. Actu electrc kwh sales.
c. Calculations showing adjustments to actul kwh sales in par b
using two sets of data (if applicable), with one set calculating
weather normalized usage according to Avista's current weather
normalation methodology, and the other set accordig to the
weather normalization methodology previously utilized in
Washigton.
d. Resulting weather normalied anua kwh sales per average
customer, under each weather normaliation calculation
methodology (if applicable).
Please provide an ilustrtion of any revisions to actul gas customer bil
tht were employed to disclose charges for Avista's pilot gas decoupling
mechasm.
What is the Company's best estimate of actual administrative and
regulatory costs incurred to date as a result of Avista's gas decoupling
mechanism in Washigton, including:
a. Intern labor and benefits costs for Company personnel involved
in preparg, explaing and implementig decoupling related
filigs.
b. Non-labor expenditues for consultats, auditors, plan evaluators
and other contractors requied to support the decoupling effort.
What is the Company's best estimate of required Commission staff time
(anualy in labor hours) associated with admstrtion and oversight of
gas decouplig mechansm filig reviews and/or audits, including staff
tie associated with the verification audits and evaluation report filed on
or about March 30, 2009? State al assumptions and provide calculations
associated with your response.
Re: March 25, 2009 Spokesman Review Article" Avista CEO earned
$2.2 Millon"
The attched March 25, 2009 aricle in the Spokesman Review quotes
A vista spokesperson Jessie Wuerst as stating that "about 22 cents of an
average utility bil goes toward executive compensation." Please describe
StafCPR_011 Attachment B Page 94 of 264
To: David Meyer
Re: PC Data Requests Nos. 177 though 188
Docket Nos. UE-0903l4 & UG-0903l5
Date: April 30, 2009
Page 3 of4
PCC-186
PCC-187
PCC-188
how the company pedormed ths calculation, and please identify the
specific executives and compensation amounts included in the calculation.
Please specify whether the 22 cent amount applies to electrc and gas
customers, and which rate schedule(s). Please provide the company's
calculation of the 22 cent amount in excel electronic form, and also
provide any and all memos or workpapers regarding this calculation.
Please indicate whether A vista has calculated the average customer bil
impact for any other cost or expense durg the past twelve months, in
addition to executive compensation. If so, please describe the calculation
and the result, and provide workpapers ilustrting the calculation in excel
electronic form.
Please provide the following information related to Avista's electrc
energy efficiency programs for each year from 2004 though 2008 in excel
electronic form:
a. Total kwh savings (system)
b. Tota kwh savings (Washigton)
c. Tota expenditues (system)
d. Total expenditues (Washigton)
e. Tota expenditues per kwh saved (system)
f. Tota expenditues per kwh saved (Washigton)
g. Please describe the methodology employed to allocate kwh savings
in par (b) and expenditures in part (d) to Washigton.
h. To the extend the data provided in response to pars (a, b, e, and f)
above includes "de-rated" kwh savings, please' provide the
following:
i. A description of Avista's "de-rating" methodology.
ü. The total amount of "de-rated" kwh included in the amounts
shown in the company's responses to pars (a) and (b) for each
year.
11. A listig of each DSM project with "de-rated" kwh in any year,
the total amount of kwh savings claimed each year for each
project, the date each DSM project was completed, and the date
Avista verified project completion for each project.
With regard to the curently employed gas weather normalization
methodology, please provide the following information:
a. Explai how the calculations of weather coefficients and constats
are developed, indicating the sources and specifications for all
StafCPR_011 Attachment B Page 95 of 264
To: David Meyer
Re: PC Data Requests Nos. 177 though 188
Docket Nos. UE-0903l4 & UG-090315
Date: April 30, 2009
Page 4 of4
input data tht is used and calculation tools tht are employed for
all weather normalization calculations in the pending rate case.
b. Provide representative statistical diagnostics for the gas weather
normalation calculations in the rate case test year.
c. Describe how the confdence interals and potential therm error
quatities associated with your responses to pars (a) and (b) of ths
data request regarg test yea weather normalization compare to
the estiated anua therm savings arsing from A vista DSM
measures.
StafCPR_011 Attachment B Page 96 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 189 through 192
To: Avista
PC-189 Interest Calculation - Please refer to Ms. Andrews' Workpaper B-20 and
explain why the net rate base of$934,538,7l 7 does not agree with the rate
base of $1,007,076 shown on Ms. Andrews' Workpaper A-2.
PC-190 Investment and Exchage Power - Please provide an explanation and the
documentation which support the addition to the rate base shown on
Ms. Andrews' Workpaper B-25 in the amount of $27,970,792.
PC-191 Allocation of Amortization Expense
a. Please provide a reference to where the allocations on
Ms. Andrews' Workpaper B-26 are reflected in the Company's
filig. Please show how these allocations are incorporated in the
Company's expenses for ratemakg puroses.
b. For the Company's allocation of common depreciation expense
shown on Workpaper B-27, provide the same inormation as
requested for the allocation of amortization expense.
PC-192 Common Plant - On Workpapers B-28 though B-36, the Company makes
allocations and sumares of direct cost related to common and intagible
plant. For each workpaper, B-28 though B-36, show how the data on
these workpapers were used to determe amounts in the Company's
filing. Provide references to where each amount was cared forward to in
the workpapers.
StafCPR_ 011 Attachment B Page 97 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. 00-090134 and UG-090135
Public Counsel Data Requests Nos. 193 through 199
To: Avista
PC-193 Deferred Income Taxes - Please refer to Ms. Andrews' Workpaper C-4. It
does not appear tht the amount shown on the line entitled "BAF and
Acquisition Adjustment" in the amount of ($848,308) was used in
calculatig the deferred income ta balance shown on Workpaper C-2 for
the Washigton jursdiction. Pleae explai why ths is so, and if ths
amount should have been reflected. If not, what are the reasons therefore?
PC-194 Deferred Income Taxes - Please refer to Ms. Andrews' Workpaper C-4
and explai why the Company did not use a monthy average balances
instead of using the begig and ending balance to calculate the deferred
income tax balance.
PC-195 Deferred Income Taxes - For any other balance that the Company
calculated related to deferred income taes, explain why the Company did
not use a monthy averge of the averge balance.
PC-196 Propert Taxes - Please refer to Ms. Andrews' Workpaper L-6.
a. Provide the actul electrc proper ta amounts for the year ended
December 31,2008, in the same format as shown on ths
workpaper.
b. Provide the actual tax bils that support the amounts shown for
each jursdiction and any allocation.
PC-197 Propert Taxes - Refer to Workpaper L-6.
a. Provide the basis on which the Company estimated the 2009
propert taes as shown on Workpaper L-6, i.e., any inormation
provided by assessors and ta rates which the Company used to
arve at the dollar amounts shown in the colum entitled
"Estiated 2009."
b. Provide any correspondence or other inormation on which the
Company ha relied in order to project the Coyote Sprigs
propert ta in the amount of $3,105,000.
&aff_PR_011 Attachment B Page 98 of 264
To: David Meyer
Re: PC Data Requests Nos. 193 though 199
Docket Nos. UE-090314 & UG-090315
Date: May 5,2009
Page 2 of2
PC-198 Regulatory Expense
a. Please provide invoices or other documentation related to the
FERC regulatory expense in the amount of$1,37l,226 chaged to
retail rates in the state of Washigton.
b. Provide an explanation of what FERC dockets the Company
parcipated in by docket number and case description and state
what benefit retail ratepayers receive from the paricipation of the
Company in these dockets.
c. State whether the FERC regulatory expense is an ~ngoing
recurg amount and why this amount should be recovered in
rates.
PC-199 Injures and Damages
a. Please provide the monthy data which the Company used to
calculate the revised anual accrual - direct of$369,493.
b. Provide an explanation and any documentation which justifies the
51.22% increase in the injures and damages accrul for the
Washigton electrc division.
c. If any individual or group of clais increased in any parcular
year please identify those clais and provide any supportg
documentation.
StafCPR_011 Attachment B Page 99 of 264
BEFORE THE WASmNGTON UTIliTI AND TRSPORTATION
COMMISSION
AVISTA GRC 2009
Docket Nos. UE090134 and UG-090135
Public Counsel Data Requests Nos. 200 thrugh 212
To: Avista
PC-200 Production Tax Creit
a. Please provide the documentation and calcultion 0 f the
Production Tax Credit whih was elimited in Exhit
No._EM-2, colum (P).
b. Provide the tax code sections, or any othe documenttion that
shows the elition of th Production Tax Credit.
c. Show th calcultion of th credit am the allocation by
jurisdiction
PC-201 Production Tax Creit - On workpaper P-8, it states "There wil be a new
credit availble in 2009 however, we nee to wait IDr the system to come
on-li and to receive a FERC liense in order IDr us to know what the
incrementl generation wil be in order to determe the credit Per the tax
deparment, they do not feel that the credit wil be materiai they estimte
that it wil be about the same as Cabinet Gorge aroun $60k. "
a. In regads to thi statement please provide the tax code sections or
documenttion whih authorizes, explain or details this credit.
b. Provide any other inormtion or explanations that the Company
has in its possession regading thi credit.
.
c. Please explain in full detail the statement "... FERC liense in
order to know what the incremental generation wil be . . ."
Identify the specifc FERC license and the specifc :lcility. In
addition, provide the projected generation from thi facilty by
year.
d. Provide the tax deparment's detailed analysis of thi credit and
why the tax deparment has concluded it would only amoun to
$60k.
StafCPR_011 Attachment B Page 100 of 264
To: David Meyer
Re: PC Data Requests Nos. 200 through 212
Docket Nos. UE-0903l4 & UG-090315
Date: May 11,2009
Page 2 of4
PC-202
PC-203
PC-204
PC-205
PC-206
PC-207
Deferred Income Taxes - In Ms. Andws' workpapers PI throughP8,
there is an adjustment to injuries and damages deferred inome taxes in
the amount of$36,000. Please explain whether the Company has
provided deferrd income taxes for injuries and damages accruls in years
prior to the test year and if so, explain why the injuries and damages
allcations imacts deferrd income taxes in the test year.
Defered Income Taxes - OnMs. Andews' workaperP-2, there are
changes in allocations for (1) residential exchange and (2) Montna Hydro
Settlements. Explain why these changes do not impact dererred income
taxes?
Working Capital - Does A vista Utilities request a working capital addition
to rate base in any other jurisdiction? If the answer to the above question
is yes, please provide the workpapers and working capital requested inany
jurisdiction in whih the Company is reguted.
Working Capital- Has Avista Utilities ever made a working capital
calculation for either the gas or electric operations in the State of
Washigtn? Ifso, please provide the most recent working capital
calculation and any supporting workpapers.
Working Capital - Please provide a full and adequate explanation of why
the Company ha not made a working capital calculation in the curent
dockets be:Ire the Washigtn Public Utilties Commssion.
Energy Recovery Mechanim- Please refer to workpaper Ql:
a. Provide a full and complete explanation of why the adjustment in
colum two (2) has any effect on net operating inome.
b. Explain how the ER does not match revenues with power
suplied expense such that there is no net income ef1ct since the
colltion of revenue should be matched with the power supply
expense.
c. Provide page refernces to the Commssion order in Docket No.
UE-070804 which causes the impact ofrecogning revenue or
expenses associated with power supply in different periods.
StafLPR_011 Attachment B Page 101 of 264
To: David Meyer
Re: PC Data Requests Nos. 200 thrugh 212
Docket Nos. UE-090314 & UG-090315
Date: May 11,2009
Page 3 of4
d. State wheher it is the purose of the Enegy Recovery Mechanism
to collect the exat net power supply expense.
PC-208 Energy RecoveryMechanism- Please rererto WorkpaperQ2: Provide a
detailed explanation 0 f how the amounts in Account 557.29 -
Amortiztion, Account 557.28 - De:1ls and Account 410.1 FIT are
calculated. Also, explain what each accoun represent and monthly debits
or credits to accoun
PC-209 (a)Rerer to the response to PC-024 (Attahment A). Plese separate
the inrmtion fur write-offs, reinstatement, reoveries and net
write offs between electJi and gas.
(b) Rerer to the response to PC-024 (Attahment B). Provide
separtely electric and ga sales to customers fur calendr yea
2008.
(c) Rererto the response to PC-024 (Attahment B). Update the
inormtion shown for March 2009 thrugh the most recent
availble.
PC-210 Rererto PC-013.
a. Provide separate monthly trial balances for the electric and gas
operations fur th same period through the most recent availble.
b. Provide a description of the inormtion contined in colums 3, 4
an 5 of the trial balances provided in response to PC-013. (fur
example, see PC_DR_03 Attchment A, page 1 of24, "CD", "AA"
an "DL')
c. Also provide a key explaing each of the letters utiled in
colum 3, 4 and 5.
PC-211 Rerer to the response to PC-042.
a. Provide an itemiation by subaccount ofthe amounts in accoun
925, separte by eletric and ga.
b. Provide a simla itemiation for the lat five calendar years (2004-
2008) separtely for electric and gas.
StafLPR_011 Attchment B Page 102 of 264
To: David Meyer
Re: PC Data Requests Nos. 200 through 212
Docket Nos. UE-0903l4 & UG-0903lS
Date: May 11, 2009
Page 4 of4
c. Itemie the inurnce premiums inluded in the test year by
category and accoun numer.
PC-2l2 (a)Identify the amoun ofD&O inurnce in the test year separtely
for electric and gas.
(b) Also, include the amount ofD&O insurnce for each of the last
five calend years (2004, 200S, 2006, 2007 and 2008) separately
for the electric and gas opertions.
StafCPR_011 Attachment B Page 103 of 264
BEFORE mE WASIßGTON UTIUTI AND TRSPORTATION
COMMISSION
To: Avista
PC-213
PC-2l4
PC-2l5
PC-216
PC-217
AVISTA GRC 2009
Docket Nos. UE90134 and UG-090135
Public Counsel Data Requests Nos. 213 thrugh 217
Answer the following questions regaing naturl gas prices:
a) Does Avista acknowledge that, as of May 1, 2008, curnt furward
natul gas prices are substantially below the furward natul gas
prices it used to furecast eletrc power supply expenses (provided on
Table NO.2 at Page 8 ofthe Dirct Testimony of Clit G. Kalich)? If
not, pleae explain why Avista does not believe curnt gas prices are
substantially below the prices it used to preare its power supply
expense furecast
b) Does Avista acknowledge that, as of December 31,2008, furward
natul gas prices wer substantially below the furwar natul gas
prices it used to furet eletric power supply expenses (provided on
Table NO.2 at Page 8 ofthe Dirct Testimony of Clit G. Kalich)? If
not, please explain why A vista does not believe that, as of Deember
31, 2008, ga prices were substantially below the prices it used to
prear its power supply expense foreast
Does A vista plan to engage in additional gas or electric hedging
trnsactions in 2009 to obtain the benefits in2010 ofcurent furward gas
an electric prices? Ifso, please explain when and how Avista wil do so.
If not, please explain why A vista will not do so.
Cite the passage(s) in the document provided in response to Public
Counel Data Request 79C that provide the justifcation(s) fur the answer
to Public Counel Data Request 214. If the justifcation(s) is not provided
in these documents, please state suchjustification(s) in response to this
question
Does Avista plan to update its fureast of20io electric power supply
expenses befure this current General Rate Case is concluded to reflct
furward ga prices at some fu date or period in2009? Ifso, when does
A vista plan to mae such an update?
Please re-ru the Dispatch Model exactly as was done to respond to Staff
Data Request 49, exceptthe exclusion of th Lancaster PPA from Avista
StafCPR_011 Attachment B Page 104 of 264
Utilities' resource portfolio. Provide results, including Attachmnt A, in
the same level ofdetail as was provided in response to Staff Data Request
49.
StafLPR_011 Attchment B Page 105 of 264
BEFORE THE WASIDGTON UTIUTI AND TRSPORTATION
COMMISSION
To: Avista
PC-218
PC-2l9
PC-220
PC-22l
A VISTA GRC 2009
Docket Nos. UE090134 and UG-090135
Public Counsel Data Requests Nos. 218 thrugh 228
Provide the following documnts in eletrnic Excel-compatible formt
with data and formulae intact and futionig:
a) Appendix C to Exhbit No. _ (RLS-S) to the Direct Testimony of
Richard L. Storr.
b) All workpapers provided in response to Public Counel Data
Request NO.1 l7C.
Provide, in electroni Excel-compatible formt with data and :frmulae
intat and futionig, th :fllowingadditionaldata from each of the thre
simulations ofthe value of Lancter PPA provided in Appendix C to
Exhit No. _ (RL-5) of th Dirct TestiinyofRicha L. Storr:
a) Expected generation
b) Expected ful use
c) Expected ful cost
d) Estimted hourly electricity prices, both be:fre and aftr
adjustment to reflect the impacts ofvolatility, and the hourly data
used to mae such adjustment for volatilty.
Provide, in electroni Excel-compatible formt with data and :frmule
intat and futionig, th :fllowing additional data from each of the six
simulations 0 f the value 0 f a CCGT provided in response to Public
Counel Data Request NO.1 l7C:
a) Expected generation
b) Expected ful use
c) Expected ful cost
d) Estimated hourly electricity prices, both be:fre and aftr
adjustment to reflect the impacts of volatility, and the hourly data
used to mae such adjustment for volatilty.
Explain why the simulations of the value ofLaIlaster provided in
response to Public Counel Data Request NO.1 L7C ened in a diferent
year than the simulations provided in Appendix C to Exhit No. _
(R-S) ofthe Direct Testimony of Richard L. Storr.
Staff_PR_011 Attachment B Page 106 of 264
PC-222
PC-223
PC-224
PC-22S
Re-estimate, using Thorndike Landing's Integrated Energy and Capacity
Model (IECM) and Discouned Cash F low (DF) models, the value ofthe
Lancaster PP A in a manner entirely consistent with the "Lancaster Base"
valuation presented in Appendix C of Exhbit No. _ (RLS-5) of the
Direct Testiiny of Richad L. Storro, except IDr a reduction in the price
of gas at AECO by $1.00/MMBtu IDr each simulted year. Provide the
results of thi simulation in the same IDrmt and same level ofdetail
provided in Appendix C and A vista's responses to Public Counel Data
Request Nos. 218 an 219 above IDr other valuations of the Lancaster
PPA.
Describe the following aspects of Thorndike Landing's (TL's) Integrated
Energy and Capacity Model (IEM), and TL's use ofIECM on behalf of
Avista:
a) Goo grphic scope 0 f electricity market modelig (e. g., entir
Western Electricity Coordinting Counil or smaller sub-area).
b) Soures ofdata regarding electric loads, resoures, trnsmision
paths, fuel costs, and other key aspects ofmodeled region's
eletricity system
c) IEM's algorithm IDr estimting hourly maket prices withi the
modeled region, beIDre any volatilty adjustment. Include
discussion of how impacts of energy-lited resoures and
trnsmission constrints are reflected in such prices.
d) Reasons for, and the processes TL and IECM use, to inroduce
price volatilty into IECM's final results.
e) Methods IDr estimating an individual generator's "Energy margin,
excluding allowances" and "Energy payment (toll)", as those line
items are defied in Appendix C of Exhit No. _ (RIB-S) of the
Direct TestiinyofRichad L. Storr.
t) Methods IDr estimating an individual generator's electric
generation, ful use, ful cost and other variable costs.
g) Numer of years modeled in the IECM and, if less than the full
numer of years in the analytic horizons shown in Appendix C of
Exhit No. _ (RLS-S) of the Direct Testiiny of Richad L.
Storro or Avista's response to Public Counel Data Request No.
l17C, how the results of non-modeled year were estimted.
Does TL have any cautions to offer about the use and interpretation of the
inividual generator data described or provided in response to Public
Counel Data Request Nos. 219,220,222 and 223(t) above? Ifso, please
state such cautions.
Provide the following inIDrmation regading the data shown in the lie
item titled ''Capacity revenues" shown in Appendix C of Exhibit No._
(RL-S) ofthe Direct Testimony of Richard L. Storro:
StafLPR_011 Attachment B Page 107 of 264
PC-226
PC~227
a) State whether TL's assumed capacity pripe can be determined by
simly dividing "Capacity revenues" by~he 'vrotal" shown under
''Capacity'' (262 MW from any of the tales in the fist three
pages of Appendix C. Ifoot, state what estimted capacity prices
are and how ''Capacity revenues" were c\)mputed.
b) Describe the methods, and provide the wlta and workpapers, 1L
used to estimte the capacit prices provkied in Appendix C.
c) Explain why capacity prices did notchartge in the "Low Case,"
despit the introductionof5,000 MW o~new CCGTcapacity
thoughout the WECC in that case (per ~age 18 of Exhbit No. _
(RLS-5) ofthe Direct TestimonyofRiclfrd L. Storr).
!
Provide the following infurmation regarding "t~ introduction of an
additional 5,000 MW of combined-cycle capaci~y throughout the WECC"
to develop the "Low Case," as described on Pagt 18 of Exhbit No. _
(RS-5) ofthe Dirt Testimony of Rihard L. $torr:
a) State the year s) in which such additiona1 capacity was assumd to
be added. .
b) State the specifc sub-area(s) with the WECC in which such
additional capacity was assum to be aqded.
c) Ifcapacity is added in more than one yel and more than one
WEC sub-ara, provne a table showing the annual capacity
additions by WECC su-ar.
I,
Answer the following questions regaing the fuillowing lie items in the
tables on pages 1 to 3 of Appendix C ofExhitjNo. _ (RS-5) ofthe
Direct Testimny of Richad L. Storm: !
,
a) Are "Energy margins, excluding allowaq'ces" meant to be
"margins" as generally defied, that is, die net amount of money
remaing aftr energy expenses are subkacted frm gross energy
revenues? If not, please state what amo$ts are included in such
"energy margin".
b) State the source of the estimated ''Mhs! generated" and "energy
charge" (as described in Footnote 1) usecl to compute the "Energy
payment (toll)". Cite the section(s) ofth~ PPA (or other sources)
whe such chages and their escalation are specifed.
c) State the source ofthe flat "$/kW-montht' O&M chage (as
described in Footnote 2) used to computt "O&M". Cite the
section(s) of the PPA (or other soures) irhere such chages and
their escalation are specified.
d) State whether the "Transmission" costs consitute the estimated 25
percent of the costs to be inur uner ~ trnsmission contct
with the Bonnvile Power AdmistrtIdn that are assumed not re-
StafCPR_011 Attachment B Page 108 of 264
maketed or otherwise used for utilty load service? If not, please
explain what these costs are.
e) Are the "Gas Transportation" costs the fied costs ofthe gas
pipelie contacts associated with the Lancaster project? If not,
please explain what these costs are.
f) State the source of the flat "$/kW-innth" "capital/capacity"
charge (as described in Footnote 3) used to comput "Capacity /
capitl toll payment". Cite the section(s) ofthe PPA (or other
source) where such chages and their escalation ar specified.
g) State the basis and tax depreciation schedule used to compute "Tax
Depreciation (based on purchase price)" and "Depreciation (tax)".
h) State whether "Total capital expenditures" reflects the assumption
A vista wil spend $3 milion to build a direct interconnection
between the Lancaster plant and its own electric system If not,
please describe what the $3 milion expenditure is fur.
i) Describe how was the "Terminal Value" was computed.
j) Cite the basis for 1L's choice ofan "Annual discount :fctor..." of
7.41 percent.
PC-228 Answer the following questions regaing the fullowing lie items
presentd in the table on page 4 of Appendix C of Exhit No. _ (RLS-
5) ofthe Dirt Testimony of Rihard L. Storro:
a) State why the figure entered for 2010 in ''Stream of capacity
payments" exceeds the figure shown fur 2010 on pages 1 to 3
under ''Capacity / capital toll payment" by $6.26 millon.
b) Cite the basis for 1L's choice ofa "Discount rate..." of8.28
perent
c) Provide the ''S&P guidelines" discussed in Footnote 1, including
thse recommending a "Risk factor" of25 percent.
d) Cite the basis for 1L's choice ofthe "A VA capitalization
structure" shown.
e) State the basis fur, including references to any ''S&P guidelines" or
other documents, for assuming that the PPA's Imputed Debt
should be computed based on the amounts shown in "Aftr-tax
cost ofequity" for each year through the PPA's termination in
2026.
StafCPR_011 Attachment B Page 109 of 264
BEFORE THE WASIDNGTON UTIUTI AND TRSPORTATION
COMMISSION
To: Avista
PC-229
PC-230
PC-231
A VISTA GRC 2009
Docket Nos. UE90134 and UG-090135
Public Counsel Data Requests Nos. 229 thrugh 237
Ar there any provisions withi any 0 f the contrats described on pages 10
an 11 of the Dirct Testimny of R£had L. Storm - the Lancaste PPA,
the gas transortation assignent agrements, and the trnsmision
agreemmt - tht reui them to be assigned trans furred and/or managed
in coajuntion with any ofthe other agrement? Ifso, please specif
what such provisions are.
Provide the following inrmtion regading the statement at page 8 in
Exhit No. _ (RL-5) to th Direct Testimony of Rihard L. Storro that
''Note that the total gas trnsportation exceeds the total gas needs ofthe
plant when operting at fu capacity by approxitely 20%
(approximately $550,000 in 2007)."
a) Provide a worlaper documenting the data and calculatims
suporting thi sttement
b) Did Avista perform any assessment ofthe optiml alOun of
additional fi gas transorttion capacity it should obtain upon
adding the Lancaste plant to its generating portfolio? If so, please
provide such assessments.
Provide the following inrmtion regading the Dllowing statements on
page 8 of Exhbit No. _ (RLS-5) to the Dirct Testimony of Richad L.
Storm, whih relate to the potential Dr Avista to offet the costs of the ga
trnsortation agreements:
a) Provide the data and analysis, in electroni Excel-compatible
furmt with data and furmule intact, supporting the statement that
".. .assuming perfuct optimization of pricing between the hubs, the
blended gas price Dr Lancaster would be approxitely
$.25/MBtu (1.9%) lower than pricing at the Alberta hub alone."
b) Provide the data and analysis, in electroni Excel-compatible
furmt with data and furmule intact, supporting the statement that
''lfthe gas transportation necessary to meet daily gas requirements
could be remaketed or otherwise utiled at cost, thi would
reresent an additional value of approximtely $9,000 pre-tax per
day ($6,000 aftr-tax)."
StafCPR_011 Attachment B Page 110 of 264
PC-232
PC-233
PC-234
Provide the following inrmtion regading the bullet at page 8 in Exhit
No. _ (RL-5) to the Direct Testimny of Richad L. StOlTO that reads
"Variable gas costs: (these are included in the energy margins modeled by
the IECM)".
a) Does the phrase "included in the energy margins modeled by the
IECM" mean that Thorndike Landing inluded these costs as a
component of the "energy margin" reported as a line item on
pages 1 to 3 of Appendix C of Exhbit No. _ (R-5)? If so,
please explain why. Ifnot, please clarif what this phrse mens.
Provide the following documnts that are rererenced in A vista's
confdential response to Public Counel Data Request 96:
a) Identif and provide any docum.nts that wil be re:fenced or
relied upon by "PC_DR _ 096C-CONFIDENTIAL Attchment A"
to set the costs to be incurd by A vista.
b) Identif and provide any documnts that wil be rererenced or
relied upon by ''PC_DR_096C-CONFIDENTIAL Attchment B"
and ''PC DR 096C-CONFIDENTIAL Attachment C" to set the
costs to be inurred by Avista, such as the exhbits whose cover
pages are included as the last two pages of each document
Provide the following infurmtion regading the material provided in the
confidential file ''PC DR 1 08C-CONFIDENTIAL Attachmnt A - Lease
Evaluation _04- 11_ Update.xls", which Avista provided in response to
Public Counel Data Request 108:
a) Describe the rationale for the estimates of ''Off-System CCGT"
transmission costs made in Colum J ofthe worksheet "Lease vs
CapRec". In particular, describe the computtion in Cell Jl6 and
the supporting data shown in cell 16, 18, 19, Q6 and Q7, and the
additional escalation data shown in cell Q8. Provide
documenttion fur each of these five assumtions, including any
document related to trnsmission co st and loss assumtions.
b) Explain whether the apparent inclusion of25 percent of Lancaster
O&M costs in Colum R - labeled ''25% X-miss" - of the
worksheet "Lease vs CapRec" was intentional or an error.
Validate whether the value of cell R70 - whih is referenced in
Avista's confidential responses to Public Counel Data Requests
108 an 109 - is correct or should be changed.
c) Explain the purpose ofthe worksheet titled "Trans Req" and
describe the computations made therein State whether the results
in the last three lies - labeled "Net Trans Req", "AVA Firm
XMiss" and ''Net ST Xmiss" - ar used anywhere else in thi
Excel file. If so, state where and how these values ar used.
StafCPR_011 Attachment B Page 111 of264
PC-235
PC-236
PC-237
Compare the follwing estimtes of Lancaster-related trnsmission costs
and explain which is most appropriate to use to set Avista's 2010 eletric
revenue requiement and wiUh is most appropriate to use to estimte
Lancaster-relate trnsmision costs fur puroses 0 f estimting the value
of the LancasterPPA:
a) The estimate of ''PTP Transmission fur Lancastr" provided on at
lie 57 (page 2) of Exhit No. _ (WGJ-2).
b) The estimate costs shown in the "Transmission" line item on
pages 1 to 3 of Appendix C ofExhbit No. _ (R-5).
c) The estimtes oftmnsmissioncosts shown in Colum J and R of
''PC_DR_I0SC-CONFIDENTIAL Attahment A - Lease
Evaluation_04-l I_Update.xls", which Avista provided in response
to Public Counel Data Request LOS
Provide the following inrmtion regading the fullowing statement mae
in the middle of page 3 of Exhbit No. _ (R-4): "The analysis
assums that only 25% ofthe exiting fi trnsmision contrct cost is
not recovered thrugh re-maeting ofthe BPA trnsmision or otherwise
optimized thrugh other power transtions."
a) Describe geneally how Avista would mae the contemplated sales
of such additional BP A transmision and how the revenues frm
such sales woul be credited back to customers.
b) Do Avista's proposed 2010 revenue requirments reflect the
revenues eaed from such re-marketing ofthe above BP A
trnsmision? If so, please specif whe these revenues are
identifed in Avista's testimony, supporting exhibits and
workapers. If not, please explain why no fureast of such
revenues has been provided.
c) Do A vista's proposed 2010 revenue requirements reflect any
benefits frm reducing such BPA trnsmission costs by "otherwise
optimiz(ing)" such trnsmission, as also contemplated above. If
so, please specif where such cost reductions are identifed in
Avista's testimny, supporting exhibits and workpapers. Ifnot,
please explain why no such furecast ofcost reductions has been
provided.
Provide the following infurmation regading the estimates of ' 'Pro Forma
Tmnsmission Revenues" provided in the Direct Testimony of Scott 1.
Kiney, pages 7 to 12, and in Exhbit No. _ (SJK -2):
a) Does Mr. Kiney's estimate include any furecast of the revenues
that woul be earned thrugh the resale of the BPA trnsmission
capacity to be allocated to electric mteayers along with the
Lancaster PP A? If so, please specify where such revenues are
StafCPR_011 Attachment B Page 112 of 264
included in hi testimony, supporting exhits and workpaper. If
not, please explain why no such furecast ha been inluded.
b) Defie the term "Borderline Wheeling", and what distinguishes
such trnsmision serices from the others identifed in Mr.
Kinney's Direct Testimony and Exhbit No. _ (SJK -2).
stafCPR_011 Attachment B Page 113 of 264
BEFORE THE WASIDNGTON UTIliTI AND TRSPORTATION
COMMISSION
AVISTA GRC 2009
Docket Nos. UE90134 and UG-090135
Public Counsel Data Requests Nos. 239 thrugh 260
To: Avista
PC-239 NEZ Perce Settlement - Please rerer to workpaper R-2.
(a) State the exact amoun of the NEZ Perce Settlement included in
the test ye ended September 30, 2008, including the adjustment
proposed by the Company.
(b) Identif any other costs associated with the Nez Perce Settlement
included in the test year by account and amount.
PC-240 Public utility excise tax - Pleae refer to the U workaper.
(a) Please explain why the public utilty excise taxes have any impact
on income.
(b) Explain in detail why th revenues collected ar not dererrd and
paid in the subsequent month rather than recording a revenue and
expense which ar mimatched.
(c) Provide a full detailed explanation of the Company's accouning
fur public utilty excise tax.
PC-241 Revenue normaliation workapers W-l thugh W-12.
(a) Please list and provide separtely any workpapers, calculations, or
other data which the Company used to calculte "known and
measurble changes" rererred to on page 20, lie 4 of
Ms. Andws' testimony.
(b) Identif, quantif, and explain each known and measurble change
an provide the basis on which it was calculated.
(c) For each item in subpart (b), state whether the method of
calculation and the specific adjustment was approved inthe last
litigated rate case.
Staff_PR_011 Attachment B Page 114 of 264
To: David Meyer
Re: PC Data Requests Nos. 239 thrugh 260
Docket Nos. UE-0903 14 & UG-090315
Date: Jun 2, 2009
Page 2 of5
PC-242 Revenue normaliation Provide a comparison of the revenues authoried
in the settlement in Docket No. UE-0804l6 by rate class with the
Company's revenue normaliation shown on the same basis.
PC-243 Revenue normaliation
(a) Please provide a schedule showing the revenues collected during
the test year uner Schedule 59 Residential Exchange and .
Schedule 91 Public Purose Tariff Rider.
(b) Also show the expenses incured during the test year associated
with those particulr riders.
(c) Identify, quantify, and explain any diferences in the revenues
collcted and the expenses inclled related to each rider or
schedule. (provide an explanation how the diferences identifed
in subpart (c) were trated in the Company's fied rate case.
PC-244 Revenue normaliation
(a) If not previously asked fur or provided, provide all the workpapers
associated with the Company's weather normliation
(b) Provide a narative of the process which Company fullowed in
calculating electric weather normaliation In particulr, explain in
detail what th Company used in its regrssion analysis oflO years
ofbiled usge per Company per customer in determg the
weather normliation adjustment
PC-245 Revenue normaliation
(a) Please provide the actul test year usage per customer fur the
months the company calculated a weather normliation
adjustmem.
(b) Provide a comparison of the actual test yea usage per customer fur
the months or periods a weather normaliation adjustment was
used to the consumtion developed by the Company using a
regression analysis. State the diference between the two usage
numers and the effect of using the IO-year regression analysis has
on the weather normliation
StafCPR_011 Attachment B Page 115 of 264
To: David Meyer
Re: PC Data Requests Nos. 239 thrugh 260
DocketNos. UE-0903l4 & UG-0903l5
Date: June 2,2009
Page 3 of5
PC-246
PC-247
PC-248
PC-249
PC-250
PC-25l
PC-252
(c) Provide a calcultion of the weather normliation adjustment
utilizing the actual consumption per customer during the test year
to the consumption that would have resulted ha the 30- year
average ofheating and coolig days occurd during the test year.
(d) Provide the weathe normliation adjustment uner this scenario.
Revenue normaliation State whether the weathr normaliation
methodology utiled by the Company was ever approved by the
Washigton Public Utilities Commsion ina litigated case.
Revenue normaliation-uniled revenue.
(a) Please provide a detailed explanation of the "reabultion of
uniled revenue" as rererr to on page 20, lie 4 of
Ms. Andws' testimony.
(b) State specifcally why the uniled revenue was recabulated and
the pmpose ofthe recalculation
(c) State why the Company did not utile the uniled revenue as
reflcte on its books and records as of September 30, 2008.
Revenue normliation-uniled revenue. Provide all workpapers,
document or other explanations of th calcultion of the uniled revenue
as rererred to in Ms. Andws' testimony.
Unbiled revenue, Provide a detailed explanation of why the recalcultion
of the uniled revenue resulted ina reductionoftest year revenues in the
amoun of$1,503,000.
Revenue normaliation-uniled revenue. Provide the actual uniled
revenue recorded on its books at September 30, 2008.
Revenue normliation - Gas Operations. Provide a lit of all pro:frm
gas sales volume adjustments whih the Company made in reflecting the
rate increse authorized in the Company's last docket
Revenue normaliation - Gas Opertions. Ifnot previously provided,
provide all workapers, analysis or other documntation related to the
anualiationofthe revenue inrease related to gas revenue normliation
StafCPR_011 Attachment B Page 116 of 264
To: David Meyer
Re: PC Data Requests Nos. 239 thrugh 260
Docket Nos. UE-090314 & UG-0903l5
Date: Jun 2, 2009
Page 4 of5
PC-253 Revenue normaliation - Gas Opertions. Provide a list and justifcation
fur any adjustment mae to the customer loads reflecte in the gas
revenue annualiation
PC-254 Revenue normaliation - Gas Opertions.
(a) Provide all workpapers, analysis or any other data relied on by the
Company to calculate or develop the gas weather adjustment.
(b) Provide the regression analysis fur the 10 years ofbiled usage per
customer in biling period heating degree day data rererred to on
page 6, lies 15 and 16 of Ms. Knox's testimony.
PC-255 Pole inspections.
(a) Provide the number of poles inpected in each ofthe years 2004,
2005,2006,2007,2008, the test year and YTD 2009.
(b) Provide the amoun of pole inspection expense for eachofthe
years 2004, 2005, 2006, 2007, 2008, the test year and YTD 2009.
(c) Provide the amoun of pole inspection expense inluded in the test
year by account number.
(d) Are pole inpections performe by outside vendors or inernl
labor? Ifperfurmd by outside vendors provide copies of the
curent contrcts.
(e) Provide copies of the wood pole inpection/capital expenditue
report for the year 2007 and 2009 submitte to the Commsion
as par of the settlement stipulation in Docket No. UE-070804
et al
(f) Provide monthly balances 0 f the wood po le balancing accoun for
2007,2008, the test year and YTD 2009.
(g) Provide a copy of the Company's pole inspectionpolicy/manua1.
StafCPR_011 Attachment B Page 117 of 264
To: David Meyer
Re: PC Data Requests Nos. 239 thrugh 260
Docket Nos. UE-090314 & UG-090315
Date: Jun 2, 2009
Page 5 of5
PC-256 Vegetation management Rererto Avista's Response to Staff Data
Request No. 011.
(a) Identif the amoun of vegetation management expense in the test
year.
(b) Provide the budgeted and actul amoun of mies trimmed fur each
year, 2004, 2005, 2006, 2007, 2008, the test year and YTD 2009.
PC-257 Vegetation management Is vegetation management performed by internl
labor or outside contctors? If perfurmed by an outside contrtor,
provide copies ofcurnt contrcts.
PC-258 Vegetation management Provide a copy of the Company's vegetation
management pro gram manual/po licy.
PC-259 Vegetation management. Provide any analyses or studies whih compare
inormation such as employees, distribution mies, customers, distribution
mies per employee, customers per employee, etc. ofAvista to other
utilities.
PC-260 Autmatic Meter Reading (AMR).
(a) Identif any costs by FERC account numer inluded in the test
year related to AMR devices.
(b) Wht is the statu of AMR deploymnt?
(c) Provide any report, analyses or other documenttion related to the
deploymnt of AMR devices.
(d) Identif costs by year spent on AMR devices sine the Company's
last rate case.
Sæff_PR_011 Attachment B Page 118 of 264
BEFORE mE WASmNGTON UTILITI AND TRSPORTATION
COMMISSION
To: AVIta
PC-26l
PC-262
PC-263
PC-264
PC-265
PC-266
A VISTA GRC 2009
Docket Nos. UE090134 and UG-090135
Public Counsel Data Requests Nos. 261 thrugh 266
Refèrring to Exhit No. _(MTT-2), Avista forecasted the interest rates
for two bond issuances: (1) $66.7 million at 6.75%, and (2) $150.0 millon
at 8.25%. Please provide the follwing:
a. Have the forecaste bond issuances been completed?
b. If affmative, please identif the actul coupon rate ofthe bond
issuances.
c. Ifnegative, please explain how the coupon rates of these projected
bond issuances were determed.
Please describe how Avista's short-term debt interest rate is set.
In response to PC-153, th Company provided the atthment titled
PC_DR_153 Attchmnt A - sp ratio backup. xIs. However, the
atthment is referencing data in other workheets that were not provned.
Please provide all the refèrenced worksheets in an Excel furmat with all
fu rmulas intact.
Please reconcile the off-balance sheet debt equivalent shown on
PC_DR_153 Attchment A - sp ratio backup. xIs with the offbalance sheet
debt equivalent shown on page 8, Table 3 of PC_ DR_l 54 Attachmnt A -
SP _08.29.2009.pdt:
Please update attachmnt PC_DR_153 Attchment A - sp ratio backup.xls
to include the most recent data availble. In addition, plese state whether
the data presented in thi schedule includes any jurisdictional allocation
adjustment. If afftive, please provide the jurisdictionalallocation
factor.
Please provide complete copies of all credit and equity reports discussing
the imlications ofdecoupling mechanisms on bond holders' risk, equity
holders' risk and ratepayers' costs.
StafCPR_011 Attachment B Page 119 of 264
BEFORE THE WASIlGTON UTIUTI AND TRSPORTATION
COMMISSION
AVISTA GRC2009
Docket Nos. UE90134 and UG-090135
Public Counsel and The Energ Project Data Requests Nos. 267 thrugh 269
To: AVIta
PC-267C A vista's Response to Public Counel Data Request No. 27C, confdential
atthment A and B, state that A vista received a "LIHEA" tax credit 0 f
fur fial year (FY) 2007, _ fur 2008, and
IDr 2009.
Avista's Response to Public Counel Data Request No. 32 inicates a
"LIHEA tax credit" of only $354,740 fur 2007, as well as an additional
$312,694, $305,362, $34,658, an $723,776 for calend years (CY) 2003-
2006.
a. Aside frm any discreaixy due to the use ofFY (July-June) in
th~ response to Data Reuest No. 27C an the use ofCY in the
respons to Data Request No. 32, the company's application fur
credit in January 2007 (date Feb. 13,2007) indicates that
$1,206,293.07 had alrady been taen. Yet the response to Data
Request NO.32 only inicates a credit of$723,776 in all of2006,
leaving at least $500,948 unccounted IDr. Please explain th
discrepaixybetween the figues fur 2007 given in Response to
Data Request No. 27C, Attachmnt A, and in the Response to Data
Request No. 32.
b. The document refèr to thi credit as a "LIHEAP" credit. LIHEA
is a fèderally fued program Why is the company receiving a tax
credit based on a fèerally fued pro grm?
c. If the tax credit is not granted based on the federal doll used to
fu LIHEA, please explain what the basis IDr the tax credit is,
an how it is deteed, and why the credit approved fur FY 2007
is so much lager than subsequent approvals?
d. How is th tax creit applied to utility revenues? That is, if the
credit is based on fus the utility collects frm rateayers thrugh
its conservation rider or another such mehanim, is the credit
retured to the various rate clases at the same rate the contibute
to the rider, does th fuing offset some other costs, or do
StafCPR_011 Attachment B Page 120 of 264
To: David Meyer
Re: PC Data Requests Nos. 267 thrugh 269
DocketNos. UE-0903l4 & UG-090315
Date: June 17,2009
Page 2 of2
shareholders benefit frm the reduction in the taxes tli utility has
to pay?
PC-268 A vista's Response to Public Counel Data Request No. 24, Attchmnt A,
inicates a 48% increase in gross write-ofl frm 2003 to 2008, whie net
write-ofl increase by 38%.
a. Wht exactly is a reinstatement and why have tli reintatements
increased?
b. Presuming "recoveries" rerer to bils that were writtn off but then
subsequently recovered thrugh collection or other means, plese
explain why these are dimishig when write-ofl are increasing
at such a rate.
PC-269 As Avista's Response to Public Counsel Data Request No. 24, Attchment
B, inicates write-offs inresed even more dramatically between 2007
an 2008.
a. Wht does the company see as the causes of such a rapid increase?
b. Wht optionS has the company considered to deal with thi
increase?
c. How are these write-offs distributd between rate clases?
StafCPR_011 Attachment B Page 121 of264
BEFORE mE WASmNGTON UTIliTI AND TRSPORTATION
COMMISSION
To: Avita
PC-270
PC-27l
PC-272
PC-273
PC-274
AVISTA GRC2009 andAVISTADECOUPLIG
Docket Nos. UE90134 I UG-90135, UG-060518
Publc Counsel Data Requests Nos. 270 thrugh 285
At page 4, line 22, Mr. Hirschkorn's Direct Testimony refers to "Avista's
.fixed costs". Please state with specificity and quantify (using amoùnts
from the Company's asserted test year gas revenue requirement) which of
Avista's gas costs incurd to provide service (other than the commodity
cost of ga) ar variable costs and which are "fixed costs". Please provide
refèrences into the Company's rate case exhibits where the amounts
provided in your response can be nentifed.
Using your respnse to tli imediately preeding data reuest, please
provide an estimte ofthe percntge of Avista's "fied costs" that are
recover thugh volumetric per-thermchages uner each rate schedule
an the complementay percentge that is recovered thrugh the fied
monthly customer charge.
Does Mr. Hirschkorn or Avista believe that the Company's "fied costs"
(Dirct Testimony, page 4, lie 22) are completely fied or do some of
such costs vary directly as a fuction ofthe number of customers being
served? If some or all of Avista's "fied cost" are believed to vary with
the numer of customers being sered, please state with specificity and
quantify (using amouns from the Company's asserted test year gas
revenue requirment) whih types and amouns ofcosts (other than ga
comidity) are believed to vary with the numer ofcustomer being
served. Please provide all calculations as well as refèrences to the
Company's rate case exhibits where the amounts provided in your
response can be identifed.
At page 9, lie 4, Mr. Hirchkorn states, "While there are many:fctors
that affect customers' energy usage, it appears that the Mechanism has not
created a disincentive fur customers to conserve." Please list and describe
each ofthe "many :fctors that aftct customers' energy usage" that are
being refèrenced.
At page 9, lie 16, Mr. Hirschkorn states, "The Company substantially
'ramped-up' its naturl gas DSM progrms and efforts during the term of
the Mechanism" Please respond to the fòllowing:
StafCPR_011 Attaçhment B Page 122 of 264
To: David Meyer
Re: PC Data Requests Nos. 270 thrugh 285
DocketNos. UE-090314 / UG-090315, UG-060518
Date: Jun 19,2009
Page 2 of7
a. Explain and quantif any changes that occurred regarding the level
of funding and effort dircted toward the Company's electric DSM
programs during the same period of time.
b. State whether and to what extent the Company woul not have
"ramped-up" its natural gas DSM progrms and efforts during thi
period in the absence ofthe Mechanim
c. Describe with specifcity and quantif how the CompanypJans to
change its future level of fuing and efforts regarding natul gas
DSM progrms if the Mechanim is not continue by the
Commssion
d. Describe with specifcity and quantif how the Company would
change its futue level of fuing and effort regarding electric
DSM progrms if the same form ofdecouplig Mechanim were
implemented by the Commission fur application to Avista's
electric utilty business.
PC-275 At page 11, line 8, Mr. Hirschkorn states, "Customers are reducing their
natul gas usge in ways other than thiough direct participation in the
company's DSM incentive progrms." Please provide the :lllowing
information:
a. List and explain each of the "other" drivers ofreductions in
customer usage that Mr. Hirhkorn is aware o~ including each of
the "other fàctors" referenced at line 16.
b. Explain whether the "Every Little Bit" program, or other specific
measures and inrmtIon soures, are being referenced at lie 10
as "customer education".
c. Explain and quantify what is being referenced as "price signals" at
lie 16.
d. Have any estimtes 0 f price elasticity 0 f demand or coeffcients
reJating gas commodity prices to demand levels been developed by
or :lr Avista since Januay 1, 2007 to assist in stuyig or
:lrecasting gas demand/sales levels or for any othe puroses
e. If your response to par (d) is afftive, please identif and
provide complete documntation associated with ga price
elaticity stuies, factors or coeffcients.
StafCPR_011 Attachment B Page 123 of 264
To: David Meyer
Re: PC Data Requests Nos. 270 thrugh 285
Docket Nos. UE-0903 14/ UG-0903 15, UG-0605l8
Date: Jun 19,2009
Page 30f7
PC-276
PC-277
PC-278
At page 11, lie 17, Mr. Hirchkorn states, "The fied costs recovered by
the Company thrugh the Decouplig Mechanism ar fied cost amounts
tht have been previously reviewed and approved to be reovered thrugh
base rates." Please describe and quantify the "fied cost amounts" that are
being rererenced and indicate where (by pinpoint citation) in the
Company's most recent gas rate order such amount was "approved to be
recovered through base rates."
At page 13, lie 5, Mr. Hirschkorn states, "If the Commssion approves
continuation of th Mechanim on a pernent basis, the Company would
adjust actul monthly custome usge to remove the net efft of
customers switchig between scheuls during the month." With regard
to the $74,000 ofdeferrls recorded over the 2007-2008 period related to
th issue, please provide complete copies of all reort, stuies,
workpapers, calculations and oth document requied to quantif the
needed adjustment and explain whether the same data soures and
calculations (or other data and calculations) would be requird
prospectively to identif and adjust IDr customers switchig between
schedules.
According to Mr. Hirchkorn's Direct Testimony at page 14, lies 5-9,
". . . as adjustment is made to remove the usage associated with new
customers added since the corresponding month of the test year." Please
provide the following inrmtion:
a. Provide copies ofthe soure documents and specimen calculations
associated with the new customers added adjustment fur a recent
actual month.
b. Explain all reasons why it is appropriate to mae an adjustment for
new customers, given the chacterization by Mr. Hirchkorn of
the Company's costs to provide service as "fixed costs" in earlier
testimony.
c. Provide complete copies of all reort, analyses, workpaper,
projections and other informtion supportive of the need for Avista
to adjust IDr usage by new customer as part of the decouplig
mechanim.
StafCPR_011 Attachment B Page 124 of 264
To: David Meyer
Re: PC Data Requests Nos. 270 through 285
DocketNos. UE-090314 / UG-0903l5, UG-060518
Date: June 19,2009
Page 4 of7
PC-279 RE: Avista response to PC-188, part c (Weather Normalization
Adjustme Bt).
The response states, ''For most sub-groups the annual predicted usage is
withi 2% of the actul usage fur the period. Estimted annual therm
savings from Avista DSM mesures as presente in Mr. Folsom's Exhibit
No. _(BWF-2) is approximtely 1.6% of Washigtn residential
Schedule 101 calendar actual booked usage. Please provide the fullowing
inormation:
a. Explain whether or not (and why) the referenced normlly
occuring percentage eror rates associated with Avista's weather
normaliation calculations exceed the entire estimted therm
savings from its gas DSM measures.
b. Provide complete copies of all studies, reports, analyses,
projections and other document associated with or supportive of
your response to par (a).
PC-280 RE: Avista response to PC-179, Attchment A (Weather Normalized
Average Gas Therm Sales per Customer).
The response provided, using either the curent or previous weather
normliation fur gas therm sales per average customer indicates a
declig usage trend fur Schedule 101 customers, but an inreasing usage
trnd fur Scheul III customers. Please provide the fullowing
inormtion:
a. Explain each known reason for the declig trnd in Schedule 101
weather normlied usge per customer.
b. Describe each known reason why usage trends are increasing fur
Schedule III customers in spite of the reasons for declig trends
in Schedule 101 usage.
c. Conf that decouplig calculations, if extnded to apply also to
Schedule 111, would produce negative deferrals ifthe hitorical
trnds fur increasing weather adjusted usage continue into the
future.
d. State and explain each reason why Mr. Hirschkom or Avista
belives that decouplig is properly applied to Schedule 101, but
StafCPR_011 Attachment B Page 125 of 264
To: David Meyer
Re: PC Data Requests Nos. 270 thrugh 285
Docket Nos. UE-090314 / UG-090315, UG-060518
Date: June 19,2009
Page 5 of7
not to Schedule 111, given your responses to part (a) thrugh (c),
above.
PC-28l RE: Avista response to PC-179, Attchment A (Weather Normalized
Average Electric KWH Sales per Customer).
The response provided" using eithe the curnt or previous weather
normaliation fur electric KWH sales per average customer inicates
generally stable usge trends for Schedule 1 and Schedule 11 customers.
Please provide the following inrmation:
a. Explain why decouplig is believed appropriate for gas Schedule
101 custoirrs, but not IDr eletric customers IDr whih A vista also
provides DSM progrms and faces th same fied cost recover
issues and disincentives to proimte conservtion
b. Describe each reon whether/why A vista woul object to
consisently applyig decouplig treatment to both its gas and its
eletric businesses, without rega to perceived diferences in the
trends in weathe normlied usage per customer.
PC-282 For each calendr year frm 2004 to 2008, please provide the following
inormtion fur each eletric residential DSM progrm Please provide
data fur W A, ID, and totals:
a. Progrm name.
b. Briefdescriptionofthe DSM irasure.
c. Amun of A vista inentive payment.
d. Numer of customers paricipating.
e. kWh savings claimed per participating customer andor measur
install. If there is a range of claimed kWh savings per paricipating
customer, please provide an explanation and basis fur claimed
kWh savings amoun
f If the amoun of the claimed kWh savings per customer or measur
ha changed from the prior yea, pleae provide the date the new
claimed kWh savings amount took effect, and an explanation fur
the change in claimed kWh savings.
StaftPR_011 Attchment B Page 126 of 264
To: David Meyer
Re: PC Data Requests Nos. 270 thrugh 285
DocketNos. UE-0903l4 / UG-0903l5, UG-0605l8
Date: June 19,2009
Page 6 of7
g. Total amount of claimed kWh savings from all customers
paricipating in the DSM progrm during the year.
PC-283 For eah calendar year frm 2004 to 2008, please provide the following
informtion for each natual gas residential DSM program Please provide
data fur W A, ID, OR and totals:
a. Progrm name.
b. Briefdescriptionofthe DSM measur.
c. Amoun of Avista inentive payment.
d. Numer of customers paricipating.
e. Therm savings claimed per participating customer andlor measur
install. If there is a range 0 f claimed therm savings per
paricipating customer, please provide an explanation and basis for
claimed therm savings amoun
f If the amoun ofthe claimed therm savings per customer or
measure has changed frm the prior year, please provide the date
the new claimed therm savings amoun took effect, and an
explanation fur the change in claimed therm savings.
g. Total amount of claimed therm savings frm all customers
paricipating in the DSM progrm during the year.
PC-284 For each calendar year frm 2004 to 2008, please provide the following
information fur each electric prescriptive commercial DSM progrm.
Please provide data for W A, ID, and totals:
a. Progrm name.
b. Briefdescriptionofthe DSM measur and type ofcommercial
customers paricipating.
c. Amoun of Avista inentive payment.
d. Numer of customers participating.
e. kWh savings claimed per participating customer andor measure
install. If there is a range 0 f claimed kWh savings per paricipating
customer, plese provide an explanation and basis fur claimed
kWh savings amoun.
f If the amoun of the claimed kWh savings per customer or measure
has changed from the prior year, please provide th date the new
StafCPR_011 Attachment B Page 127 of 264
To: David Meyer
Re: PC Data Requests Nos. 270 thrugh 285
Docket Nos. UE-0903l4 I UG-090315, UG-060518
Date: Jun 19,2009
Page 7 of7
PC-285
claimed kWh savings amount took effect, and an explanation IDr
the change in claimed kWh savings.
g. Total amount of claimed kWh savigs from all customers
paricipating in the DSM progrm during the year.
For each calendr year frm2004 to 2008, please provide the following
information IDr each natual gas prescriptive commercial DSM progrm
Please provide data for WA, ID, OR and totals:
a. Progrm name.
b. Briefdescriptionofthe DSM measur and type ofcommercial
customers paricipating.
c. Amoun of A vista inentive payment.
d. Numer of customers paricipating.
e. Ther savings claimed per paricipating customer and/or measure
install. If there is a range 0 f claimed therm savings per
paricipating customer, plese provide an explanation and basis for
claimed therm savings amoun
f If the amoun of the claimed thermsavings per customer or
measur has changed frm the prior year, please provide the date
the new claimed thrm savings amoun took effect, and an
explanation IDr the change in claimed ther savings.
g. Total amount of claimed therm savings from all customers
paricipating in the DSM progrm during the year.
Sæff_PR_011 Attachment B Page 128 of 264
BEFORE THE WASmNGTON UTILITIES AND TRSPORTATION
COMMISSION
A VISTA GRC 2009
Docket Nos. UE90134 and UG-090135
Public Counsel and The Energ Project Data Requests Nos. 286 thrugh 303
To: Avista
PC-286
PC-287
PC-288
PC-289
RE: Direct Testiny ofTaraL Knox, Exhibit No._(TLK-11), p.
11, line 15 through p. 12, line 3. Provide a detailed explanation with all
soure documnts, workpapers, spreadsheets, calculations, etc. that show
how the "direct assignment of distribution substation costs to the Exta
Lage General Service" and the extnsion ofthe direct assignment of
''primary voltage distribution 1àcilities connected to the specific
substations utiled by these twenty-two customers" were determined IDr
incorporation in the Company's electric cost of service study. Please
provide the response in hadcopy as well as in executable electrnic
furmat. If the direct assignent analyses is provided in pre- fied
workpapers, please also identif the fie(s).
RE: Exhibit No. _(TLK-3), p. 4 of9. Please provide a detailed
explanation ofthe Company's treatment of"sales expenses which are
classified as energy related" in the Company's electric cost ofservice
study.
RE: Exhibit No. _(TLK-3), P. 5 of9. Please provide all soure
document, workpapers, spreadsheets, calculations, etc. that show how the
"non-coinident peak for all customers except those that received directly
assignment (Schedule 25)" were determined and incorporated in the
Company's electric cost of service study to allocate distribution demand
related costs. Note: It appears that NCPs ar had keyed in the
Company's filed workpapers.
RE: Exhibit No. _(TLK-3), P. 5 of9. Please provide all soure
document, workpapers, spreadsheets, calculations, etc. that show the
development ofthe "Weighted customer allocators . . . . using typical
curent cost of meters, estimted meter reading time, and direct
assignent ofbillig costs for hand-biled customers." Include in this
response the specific customer costs by FERC account that allocated
"customer costs" in this manner in the Company's electric cost of service
study. Note: It appears that the filed workpapers only provide curent
meter costs and weights.
StafCPR_011 Attachment B Page 129 of 264
To: David Meye
Re: PC Data Requests Nos. 286 thugh 303
Docket Nos. UE-090314 & UG-090315
Date: Jun 22,2009
Page 2 of4
PC-290
PC-291
PC-292
PC-293
PC-294
RE: Exhibit No. _(TLK-4), P. 2 of3. Please provide detailed
explanations ofwhat is meant and reresented by the cost components
(dollrs and dollars per KWH) designated "current melded," ''uiform,''
"current uniform melded" in the panel current return by schedule, and
"proposed melded," ''uiform'' and "uniform melded" in the panel
proposed retu by schedule.
RE: Exhibi No. _(TLK-6), P. 3 of9. Please provide all source
document, workpapers, spresheets, calculations, etc. that show how the
"demand and commodity components of Account 804 have been
deteed dirctly frm the weighted average cost of ga (WACOG)
approved in the most recent purchased ga adjustment (pGA) fiing
effective November 1, 2008."
RE: Exhibit No. _(TLK-6), P. 3 of 9. Please provide all soure
document, workpapers, spresheets, calcultions, etc. that show how the
"Gas researh contributions have been assigned to sales schedules by test
period sales volumes weighte by the GTl Voluntay Collection rates
currently used to determine the contributions." Include in this response
the designtion(s) ofwhere these gas research contributions ar
incorporated in the Company's natural gas class cost of service study.
RE: Exhibit No. _(TLK-6), p. 4 of9. Please provide all soure
document, workpapers, spreadsheets, calculations, etc. that shows the
bases and rationale fur the allocations of20% and 80% of "underground
storage costs," i.e., storage rate base, operating and maintenance expenses,
to customer classes based, respectively, on annual throughput and sale s
therms.
RE: Exhibit No. _(TLK-6), p. 4 of9 and p. 50f9. With respect to
"demand side management investment costs and amortization expense,"
please inicate whether the classifcation and allocation ofthese costs is
unertaen in the same manner as the distribution mains and regulator
station equipment If this is not the case, please provide a detailed
explanation and attendnt calculations of how the demand side
management investment costs and amortI2tion expense ar treated in the
Company's naturl gas class cost ofservice study.
StafCPR_011 Attachment B Page 130 of 264
To: David Meyer
Re: PC Data Requests Nos. 286 through 303
DocketNos. UE-090314 & UG-0903l5
Date: June 22, 2009
Page 3 of4
PC-295
PC-296
PC-297
PC-298
RE: Exhibit No. _(TLK-6), p. 5 of9. Please provide all soure
document, workpapers, spreadsheets, calculations, etc. regarding the
following as each relates to the segrgation of mains between large and
small. mains:
(a) the basis fur the designation of small mains as less than fuur
inches;
(b) what is meant by the phrase "small main costs use the same
demand and commodity data;"
(c) what is meant by the phrase "large usage customers (Schedules
13 1 an i 46) that connct to large system main have been
excluded from the allocations;" and,
(d) based on the responses to (a) through (c), what is the assignent
and basis of the assignment ofmains to the "large usage customers
(Schedules 131 and 146)... (that are) .. .excluded:fm
allocations. "
RE: Exhibit No. _(TLK-6), P. 60f9. With respect to the "several
special contct customers that receive trnsporttion service frm the
Company," p lease provide all source documents, workpapers,
spreadsheets, calculations, etc. that support the "individually negotiated"
rates for these customers that "cover any incremental costs and retain
some contribution to margin."
Please provide all current contracts for each "inividually negotiated" rate
customer.
For each special contrct customer provide:
(a) the rate schedule uner whih the customer would be served absent
a negotiated rate;
(b) test year biling determint;
(c) curent negotiate rates;
(d) maxImumfi contct demand;
(e) test year fim throughput;
(f) test year interrtible throughput; and,
(g) explanation and documntation supporting the need for a
negotiated or discounted rate (e.g., threat ofby-pass, alternte
fuls) and all stuies and documents supporting the cost of
altrnate fuels and capabilty or the ability to by-pass Avista.
StafCPR_011 Attachment B Page 131 of 264
To: David Meyer
Re: PC Data Requests Nos. 286 through 303
DocketNos. UE-090314 & UG-090315
Date: Jun 22,2009
Page 4 of4
PC-299
PC-300
PC-30l
PC-302
PC-303
RE: Direct Testiony of Brin J. Hirschkorn Please explain and
identify where in the Company's filig, revenues from Schedule 191 are
reflcted.
RE: Direct Testiny ofBrianJ. Hirschkorn. Please explain and
identify where in the Company's filing, revenues from Schedule 91 are
reflcted.
RE: Direct Testiny ofBrinJ. Hirschkorn p. 7, line 1 through page
8, line 7. Please provide a liting of all of the Company's rate schedules
and designate in which of the customer class categories in the Company's
electric cost ofservice study each ofthe gas rate schedules is included.
RE: Direct Testiny of Brin J. Hirschkorn p.16, line 18 through p.
20, line 14. Please provide a lising of all ofthe Company's rate schedules
and designate in which ofthe customer class categories in the Company's
natul gas cost ofservice stuy eah of the electric rate scheduls is
included.
For each of the last five heating seaons, please provide a liting of all
natul gas curtailents ofinterrtible customers by rate schedul.
Please inlude date(s), durtion, and estimate load curtailed fur each
interrtion
StafCPR_011 Attachment B Page 132 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
AVISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Request No. 304
To: Avista
PC-304 In Avista's Response to Public Counsel Data Request Nos. 236 and 237,
A vista states: "The Company and BP A are in the process of conducting
studies regarding an interconnection between Lancaster and A vista's
system and BPA's transmission system." Please provide Avista's current
expectations as to the schedule for completing such studies, the makg of
a decision to build such an interconnection, and the constrction and
energization of such an interconnection. Please consider ths request as an
ongoing data request and update the answer as the above inormtion
changes.
StafCPR_011 Attachment B Page 133 of 264
BEFORE mE WASmNGTON UTIliTIS AND TRSPORTATION
COMMISSION
AVISTA GRC 2009
Docket Nos. UE90134 and UG-090135
Public Counsel and ICNU Data Requests No. 305
To: Avita
PC-30S Rererring to Avista's response to PC-26l(c):
a. Please provide the forecasted Treasur bond rates and yiekl spreads
used to fòrecast the coupon rate of the two bond issuances: (1) $66.7
milion at 6.7S%, and (2) $150.0 milion at 8.2S%.
b. Please provide the date these credit spreads and Treasur yields were
obtained.
c. Als, please update the projecte coupon rates of these two bond
issuances based on the curnt market data.
StafCPR_011 Attachment B Page 134 of 264
BEFORE mE WASffNGTON UTILITIES AND TRSPORTATION
COMMISSION
AVISTA GRC 2009 and A VISTADECOUPLIG
Docket Nos. UE90134 I UG-90135, UG-060518
Public Counsel Data Requests Nos. 306 thrugh 310
To: AVIta
PC-306 According to Mr. Powell's Dirct Testimony at page 4, lie 22, "The
Company does not include in its savings calculations the savings that ar
achieved thrugh outeach efforts or that ar not a par of a defied DSM
progmm Even though these energy savings are very rea~ they are
difficult to quantify and ar not included in our DSM savings results."
Please respond to the fullowing:
a) Please itemie and describe each of the referenced
"outreah efforts", by year and by campaign pro grm or
other intiative.
b) To what extern are the rererenced "outreach efforts"
tageted to gas versus electric energy consumers?
c) How does the Company know that "these energy savings
ar very real" if they ar "dificult to quantif"?
d) Provide copies of all stuies, reports, analyses, workapers,
projections and other document relied upon by Mr. Powell
or Avista to determe that "these energy savings are ver
real".
e) Would A vista fund less 0 f the "outreach efforts" if it were
denied co rninuation 0 f gas decoup lig in Washigtn?
f) Would Avista fund more of the rererenced "outreach
effort" if electricity usage were decoupled in Washigton?
g) Explain and quarnif, to the extern possible, you responses
to pars (e) and (f).
PC-307 Ref: Exhbit No. (BJH-2), page 27, Table C7-B (Every Little Bit
Progrm Costs). Please provide the following inrmtion regading the
Every Little Bit Progrm:
a) Explain how the costs of the Program are assigned or
allcated between Gas and Electric and by State in each of
the yea shown
b) Provide calculations ilustmting the total grss costs and the
development and application of each allocation fuctor or
StafCPR_011 Attachment B Page 135 of 264
To: David Meye
Re: PC Data Requests Nos. 306 thugh 3 10
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: Jun 29,2009
Page 2 of3
other assignment used for Every Little Bit costs for each
year.
c) Explain what inormtion and analyses ar perfurmed by or
fur Avista to determe the optimum level of spending on
Every Little Bit and other outrch campaign.
d) Provide complete copies of the reports, analyses,
projections, workpapers and other documnts associated
with your response to part (c) in support of expenditure
decisions made in 2007,2008 and 2009, to date.
e) Does Avista have any inormation that provides estimte
therm savings impacts or lost margin impacts attibutble to
its Every Little Bit or other outreach progrms?
f) If your response to par (e) is afftive, please provide
complete copies of all document associated with your
response.
g) Conf tht the costs fur Every Little Bit and other
outreh progrms is recovered in fu through Schedule
191 or explain anyalOunts not recoverable.
PC-308 Ref Exhbit No. (BJH-2), page 2, Table 1; page 45, Table E-2 (WA
Decouplig Deferrals and DSM Lost Margins). Please provide the
fullowing informtion:
a) State whether the Company believes the referenced tables
accurtely reflect the DSM lost magins and decouplig
deferrls set furth therein
b) If the Company believes the referenced tables are
inaccurte or incomplete in any way, please explain each
knwn correction or modifcation requird to more
completely and accurtely present thi inormation
c) Explain each reason why/whether Avista believes the
decouplig mechanim is reasonable and not overly
compenstory to A vista, given the much larger decouplig
deferls relative to the magins actully lost by A vista to
measurb Ie DS M activity.
d) Provide complete copies of all reports, analyses,
projections, workpapers and other documnts associated
with or supportive of your response to par (c).
StafCPR_011 Attchment B Page 136 of 264
To: David Meyer
Re: PC Data Requests Nos. 306 thrugh31O
DocketNos. UE-0903l4 / UG-090315, UG-060518
Date: June 29, 2009
Page 3 of3
PC-309 Ref: Exhbit No. ffJH-2), page 50, Table G3 (Decouplig Defurmls -
New customer Adjustment Impact). Please provide the fullowing
informtion:
a) State whether the Company believes the refurenced tables
accurtely reflect the imact ofthe New Customer
Adjustment upon the decouplig defumls set forth therein.
ó) If the Company believes the refurenced tables are
inccurte or incomplete in any way, please explain each
knwn correctim or modifcation requied to more
completely and accurtely present thi inormation
c) Explain each reason why/whether Avista would support a
decouplig measure that did not allow the Company a New
Customer adjustment ef:tively ensuring constant mther
thn inreasing gas margin revenues.
d) Provide complete copies of all reports, analyses,
projections, workpapers and other documnts associate
with or supportive of your response to par (c).
PC-310 Ref: Exhbit No. (BJH-2), page 74, Tables J8-B and J8-C; Avista
Response to PC- 1 79, Attchment A (WA Forecasted Customers and
Usage). Please provide the fullowing additional information:
a) State and explain whether the Company believes the
referenced tables accurtely reflect the best available
forecast ofW A gas customers and usage.
b) If your response to par (a) is negative, provide the most
curent a vailab le update inform tIon for the Tab les on
page 74.
c) Explain whether the projected usage per customer values in
Table J8-C are based upon norml weather, inicating
whether the amoun are utilizing the weather
normliation method per UG-090135 or the prior method.
d) Provide any additional inormation, calculations, or
explanations needed to mae the projected usage per
customer values in Table J8-C compamble to PC- 1 79,
Attachmnt 1, page 1 or page 2.
e) Explain why the Scheule 101 usage per customer values
in 2009 and 2010 are genemlly higher than recent actul
usage levels, as set furth inPC-179, Attachment 1.
StafCPR_011 Attachment B Page 137 of 264
BEFORE mE WASmNGTON UTILITIES AND TRSPORTATION
COMMISSION
To: AVIta
PC-311
PC-3l2
PC-313
A VISTA GRC 2009
Docket Nos. UE90134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 311 thrugh 347
Aircraft Costs
Rerer to Avista's Response to Public Counel Data Request No. 44:
a. Identif the annual opemting cost to opemte the airraft Dr each
ofthe yes 2004, 2005, 2006, 2007 and 2008. Provide ths on a
total system basis and identif the Washigtn Jurisdictional
amoun allocate to th electric and gas opemtions. Identif the
amoun allocated to shaholder.
b. Provide a detailed itemition by FERC accoun 0 f the $ 1 ,882,788
to opemte the airraft during the test period. Identif the amoun
allcate to shareholders.
c. Provide the name of the Company whih leases the aircraft to
Avista. Indicate whether the leasing company is an afflite of
Avista.
d. Provide copies ofleasing invoices Dr 2007,2008 and 2009 YTD.
e. Provide a copy 0 f the Company's airmft use policy.
f Provide an explanation of how the charges on the maniest are
derived.
Maintenance of General Plant
Rerer to A vista's Response to Public Counel Data Request No. 36,
Attachmnt A, page 3. Provide a description ofwhat the amount of
$925,210 shown in accoun 835 relates to.
Pole In pection Expense
Rerer to Avista's Response to Public Counel Data Request No. 255(a).
Identify the budgeted numer ofpoles inspection fur eachofthe year
2004, 2005, 2006, 2007, 2008, the test year, and 2009 Dr distribution and
trnsmision in a table simla to that shown in response to Public Counel
Data Request No. 255(a).
StafCPR_011 Attachment B Page 138 of 264
To: David Meyer
Re: PC Data Requests Nos. 311 thrugh 347
DocketNos. UE-0903l4/ UG-090315, UG-0605l8
Date: July 1, 2009
Page 2 of7
PC-3l4 Pole Inspection Expense
Re:rr to A vista's Response to Public Counel Data Request No. 255(b).
Provide the budgeted pole inection expense in a simla table fur each of
the year 2004 thrugh 2008, the test year, and 2009, separated by
jurisdiction fur the distribution and trnsmission operations.
PC-3l5 Vegetation Management
Re:rr to Avista's Response to Public Counel Data Request No. 256
Attachmnt A. Prövide a similr comparison of vegetation management
expense fur each 0 fthe year 2004, 2005, 2006, 2007, 2008 and 2009
YTD.
PC-316 Vegetation Management
Are vegetation management costs stil recorded in a one-way balancing
account? If not, inicate when vegetation management costs ceased being
recorded in thi mannr.
PC-3l7 Rate Case Expense
Identif the total rate case expense inluded in the test year separately fur
the W A electric and gas opertions. Also provide an itemiation fur this
expense by subaccount. Provide any invoices received to date, contrcts,
etc., supporting any charges fur outide services employed. Provide the
amoun ofrate case expense for the last five rate cases separtely for the
W A electric and gas operations. .
PC-318 Information Servces Expense
Re:rrto PF 102 ProIDrma IT expense. Provide a description of the new
work management system Provide copies ofany quotes or invoices
supporting thi system
PC-3l9 Inormation Services Expense
Re:rr to PF 102. Provide the amount of inormation services costs for each
ofthe yeas 2004, 2005, 2006, 2007 and 2008 (system tota~ and amoun
allcated to W A electric and gas.
StafCPR_011 Attchment B Page 139 of 264
To: David Meyer
Re: PC Data Requests Nos. 311 thrugh 347
DocketNos. UE-090314 I UG-090315, UG-060518
Date: July I, 2009
Page 3 of7
PC-320 Inormation Services Expense
Rererto PF 102. For each of the items listed, provide all costs incured to
date. If no costs have yet been occurd, provide an estimte of when such
costs are expected to occur.
PC-32l Inormation Services Expense
Rerer to PF 102. For eah project, provide the vendor name, copies of any
contrts or invoices.
PC-322 Asset Management Program
Rerer to PF 93 Asset Management Progrm For each of the ASSET
Mangement accouns shown (Account 562-595), provide in a similr
furmat, expenses for eah ofthe year 2004, 2005, 2006, 2007 and 2008.
For eah accoun that contains an aDDunt in the ''2010 proposed" colum,
provide an explanation fur the inreased expense in 2010.
PC-323 Inurance
Rererto PF 182 an 3. Provide simar detail for each of the year 2004,
2005 an 2006.
PC-324 Inurance
Rerer to PF 183. Provide invoices supporting 2007, 2008 and 2009
aDDun shown
PC-325 Executive Compnsation
Rerer to PF 39 Provide offcer compensation in a simla format fur each
of the yeas 2004, 2005, 2006, 2007, the test year and 2008.
PC-326 Customer Deposits
Rerer Avist's Response to Staff Data Request No. 10. Provide in a
sim formt as Attachment A, the monthly customer deposits balance
fur 2006,2007,2008 and 2009 year to date (excluding those months
already provided in response to Staff Data Request NO.1 0).
StafCPR_011 Attachment B Page 140 of 264
To: David Meyer
Re: PC Data Requests Nos. 311 thrugh 347
DocketNos. UE-0903l4 / UG-090315, UG-060518
Date: July 1, 2009
Page 4 of7
PC-327 Board of Directors Meetig Minutes
Please provide complete copies of Board ofDIrectors Meeting Minutes fur
2008 an year to date 2009.
PC-328 Board of Directors Fees
Identif the system aiount of Board of Dirctors fees inluded in the test
year, and separately fur the W A electric and ga operations. Also provide
sim inormtion fur each ofthe years 2004 through 2008.
PC-329 Accounting Adjustments
a. Please identif any aspects of the Company's accounting
adjustment and revenue requirement claim that represent a
conscious deviation frm the priniples and policies establihed in
prior Commsion Orders.
b. Identif each area of deviation, and fur each deviation, explain the
Company's perceptionofthe priniple establihed in the prior
Commssion Orders, and the collar impact resulting frm such
deviation
c. Show which accouns ar affecte and the dollar impact on each
account for each such deviation
PC-330 Incentive Compensation
a. Please provide a complete copy of all incentive compensation
plans.
b. Provide the actul percentage scores fur each of the performnce
goals for each of the year 2006,2007 and 2008.
c. Identif all intances where incentive bonuses were paid in the
years 2006 thrugh the present in any instance and show in detail
how the award amoun were related to the applicable perfurmnce
goals. Provide an explanation with each instance.
PC-33l Incentive Compensation
Please provide a detailed list ofresponsibilties and duties that eligible
incentive compensation employees must have or perform in addition to
thse necessar to meetthe standds fur base salay compensation in
order to receive incentive compensation
StafCPR_011 Attachment B Page 141 of 264
To: David Meyer
Re: PC Data Requests Nos. 311 thrugh 347
Docket Nos. UE-0903l4 / UG-0903l5, UG-060518
Date: July 1, 2009
Page 5 of7
PC-332 Incentie compnsation
Re:fr to PF 15 workpapers. Identif any additional incentive
compensation not shown on these workapers (including but not limited to
shrtlong-term inentive compensation, restricted stock, stock options,
option awards, perfurmnce shares, stock awars, dividend equivalents,
etc.), included in the test year by amount and account numer. Identif
the separte amoun allocated to the W A electric and gas operations.
Provide comparative inormation for the lat five calend years (2004,
2005,2006,2007,2008).
PC-333 AGAdues
Provide the amoun of AGA dues fur each ofthe year 2004, 2005, 2006,
2007, the test ye and 2008. Identif the amount allocated to W A gas
opertions.
PC-334 EEl Dues
Provide th amoun of EEl dues for each of the yeas 2004, 2005, 2006,
2007, the test ye and 2008. Identif the amount allocated to W A electric
operations.
PC-335 AGAdues
Provide copies of the AGA dues invoices fur the years 2007, 2008 and
2009.
PC-336 EEl Dues
Provide copies ofthe EEl dues invoices for the year 2007, 2008 and
2009.
PC-337 Severance Costs
Identif any costs or benefits in excess ofprior year associated with
M. K. Malquists retirment included in the test year by amoun and
subaccoun separately fur the W A electric and gas operations.
PC-338 Re:frto the Dirt Testimony of David B. DeFelice (Exhbit
No._(DBD-l1)) at pages 10-17. Foreachindividualprojectlisted
StafCPR_011 Attachment B Page 142 of 264
To: David Meyer
Re: PC Data Requests Nos. 311 thrugh 347
DocketNos. UE-0903l4 / UG-090315, UG-0605l8
Date: July 1, 2009
Page 6 of7
provide the projected and/or actul in service date as well as the total costs
expended to date.
PC-339 Please refer to page 21 of the Direct Testimony ofEliabethM. Andews
(Exhbit No._(EMA- 1 T)).
a. Provide the Company's explanationofthe "pro forma operating
period levels for known and measurble changes."
b. Provide references to Commssion orders and specifc languge
whih comports with the Company's defitions of "pro furma
operating period" and "known and measurble changes."
c. Provide Commsion orders with specific references to text in the
order which support the Company's defition of both "pro furm
operating period" and "known and measurble changes."
PC-340 Pro Forma Production Propert Adjustment PF2
Please refer to the Direct Testimony of Eliabeth M. Andrews (Exhit
No._(EM-l T)), page 22, lies 4-5.
a. Provide the calculation ofthe "ratio of2008 Washigtn test yea
retail load divided by the pro form period Washigtn retail
load."
b. Show how the Company arived at the ''pro furm Washigton
retail load" and any adjustment that the Company made to the
retail load.
c. Show the adjustments that the Company made to revenues to
captur the additional load between the Washigtn test year
ending September 30, 2008 and the pro furm adjustments mae
thugh December 31,2010.
d. Explain in detail how the workpapers entitled "PFI 1-3" resuls in
the adjustments shown on EM-2, page 8 of1l.
PC-341 Please refer to page 22 of the Direct Testimony of Eliabeth M. Andews
(Exhbit N o._(EMA- 1 T)).
a. Provide the factors and calculations rererrd to on lies 7-9.
b. Provide the 2009 calendar Washigton retail load used to
determe the mctor fur pro furmed capital costs and the 2010 rate
year Washigton retail load used to determe the mctor fur all
other pro formd production and transmision costs.
StafCPR_011 Attachment B Page 143 of 264
To: David Meyer
Re: PC Data Requests Nos. 311 thrugh 347
Docket Nos. UE-0903l4/ UG-0903l5, UG-0605l8
Date: July 1, 2009
Page 70f7
PC-342
PC-343
PC-344
PC-345
PC-346
PC-347
For eah month of the test yea ended September 30,2008, provide the
weather adjusted total system load and the Washigtn area adjusted
system load.
a. Provide the monthly weather adjusted system load and Washigtn
ara system load fur each month subsequent to September 30, 2008
to the month most clDently availble.
b. Provide any workpapers, analysis, or documntation which the
Company used to calculte the ratios refer to in Ms. Andws'
testimony.
Please provide refernces to Commssion orders and the specifc languge
in the Commsion orders whih authorizes the methodology which the
Company utiled to match the rate base with the pro forma rate year load
an customers.
Please show by month the increase in number of customer whih the
Company has experienced frm October, 2008 thrugh the most curnt
month availble ror the Washigtn jurisdiction
For each month October, 2008 thrugh the most curent month availble,
show the increase in kWh sales by month for the Washington
jurisdictional area.
Retail Sales Forecast
Please refer to workpaper PF 23. Provide the revenue which would be
generated in the year 2009 utilizing the rorecast for the Washigtn
jurisdiction in the total amount of 5,595,977 megawatt hours.
Retail Sales Forecast
Please refer to workpaper PF 23. Provide the revenue which would be
generate using the curnt effective rates rorthe Washigtonjurisdiction
in the total amoun of 5,763,971 megawatt hours.
StafCPR_011 Attachment B Page 144 of 264
BEFORE THE WASHINGTON UTILITIES AND TRSPORTATION
COMMISSION
A VISTA GRC 2009
Docket Nos. 00-090134 and UG-090135
Public Counsel and The Energy Project Data Requests Nos. 348 through 350
To: Avista
PC-348 Please provide a list of each five digit postal zip code in which the
Company serves retail natual gas customers in Washigton State; i.e., its
Washigton Service Area. In this response please provide in had copy as
well as in electronic format in Text, ASCn, or Excel format.
PC-349 Please provide a list of each five digit posta zip code in which the
Company serves retail electrc customers in Washigton State; i.e., its
Washigton Service Area. In ths response please provide in had copy as
well as in electronic format in Text, ASCn, or Excel format.
PC-350 Please provide any and all anual reports of the Limited Income Rate
Assistace Progr (LIR) since its inception to date.
StafCPR_011 Attchment B Page 145 of 264
BEFORE TH WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 351 through 363
To: Avista
PC-351 Re: Avista Response to Public Counsel Data Request PC-006
This data request included an excel spreadsheet. containg data regarding
completed commercial and industral DSM projects, by customer and rate
schedule, frm Janua 1,2008 though December 31,2008.
a. Please provide an updated version of ths excel spreadsheet, with
customer naes included. If the customer account number is also
available, please include tht information as well.
b. To the extent there are any other modifications to the excel
spreadsheet provided in response to ths request, other th the
inclusion of customer name and account number, please explain
any such modifications.
PC-352 Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 24625
a. Please provide an updated gas biling history for this customer
from October, 2007 to the present.
b. Confdential Attchment B for this DSM project includes Incentive
Calculator worksheets at p. 3 and p. 18. Please conf that the
worksheet shown at p. 3 is the final worksheet.
c. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2008
DSM therm savings of 5,600 for an "HV AC combined" DSM
project, at p. 36. Please confir ths refers to ths DSM
Application 24625.
d. Both versions of the incentive calculator provided in Confidential
Attchment B, shown at p. 3 and p. 18, indicate that ths customer
is a Schedule 111 gas customer. However, the excel worksheet
provided with ths data request shows ths customer as a Schedule
101 gas customer. The biling history provided in response to PC-
006 also shows ths customer as a Schedule 101 customer. Please
explai ths apparent inacurcy.
StafCPR_011 Attachment B Page 146 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-090314 / UG-0903l5, UG-0605l8
Date: July 2, 2009
Page 2 of 12
e. Please provide an explantion as to whether the ther savings
claim resultig from the DSM measure would be any different if
the incentive calculator worksheet( s) had shown ths customer as a
Schedule 10 i customer? If the therm savings amount would have
been different, pleae provide an estiate of what the therm
savings clai would have been had the worksheet identified the
customer as a Schedule 101 gas customer.
f. Confidential Attchment B refers to an individual at "The ETC
Group", at p. 15 and elsewhere, who performed an engineerig
review. Please explain whether ths individual is an Avista
employee. If this individual is not an A vista employee, please
describe the firm and the natue of the work performed for A vista.
g. The signed DSM agreement at pp. 9-12 of Confdential
Attchment B indicates the DSM incentive payment is capped at
30%, but the fil incentive amount appears to be 50%. Please
explai.
h. Confdential Attchment B, at p. 20, includes a table showing
"baseline" and "retrofit" therm usage (in dekatherms), for a seven
month period. Please confir that the colum labeled "retrofit"
reflects the customer's anticipated monthy therm usage if the
DSM measure is completed.
PC-353 Re: Avista Response to Public Counsel Data Request PC-006
DSM Application 25011
a. Subsequent to a discovery conference, an email from
Renee Coehlo at Avista, dated April 22,2009, was forwarded to
Public Counsel that indicated the following:
"There is a schedule I i i meter with ths customer,
but not for the production building where ths
project took place."
Please conf that the Schedule 101 gas meter usage
provided in Confdential Attchment B to PC-006 is for the
building where the DSM project occured. If the biling
sumar provided does not serve the building where the
DSM project occured, please provide gas and electrc
StafCPR_011 Attachment B Page 147 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: July 2, 2009
Page 3 of 12
biling sumares, from Januar, 2004 to the present, for
the meter(s) serving the building where the DSM project
occured.
b. Mr. Hirchkom's Workpapers, Exhbit C-L "DSM Savings
Calculations," include a WA Schedule 101 customer with 2008
DSM ther savings of 9,643 for an "HV AC combined" DSM
project, at p. 36. Please conf ths refers to ths DSM
Application 2501 1.
c. Confdential Attchment B for ths DSM project includes Incentive
Calculator workheets at p. 4 and p. 14. Please confirm tht the
worksheet shown at p. 4 is the fial version of the worksheet.
d. Both versions of the incentive calculator provided in Confdential
Atthment B, shown at p. 4 and p. 14, indicate that ths customer
is a Schedule 111 gas customer. However, the excel worksheet
provided with ths data request shows ths customer as a Schedule
101 gas customer. The biling history provided in response to PC-
006 also shows ths customer as a Schedule 101 customer. Please
explai ths appart incurcy.
e. Please provide an explantion as to whether the therm savings
clai resultig from the DSM measure would be any different if
the incentive calculator worksheet(s) had shown ths customer as a
Schedule 101 customer? If the therm savings amount would have
been different, please provide an estiate of what the therm
savings claim would have been had the worksheet identified the
customer as a Schedule 101 gas customer.
f. The biling sumar provided on p. 1 of Attchment B shows
actul anual usage for the 12-month period prior to incentive
payment for the DSM measure that is signficantly below the therm
savings clai from the DSM measure. In light of therm savings
clai levels exceeding actul usage levels, please provide an
explanation as to how the claimed therm savings levels are even
possible with ths customer?
PC-354 Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 25444 (and other DSM projects at this premise)
a. Confdential Atthment B, at p. 18, provides a sumar table of
four DSM projects. Please confirm the following:
i. Mr. Hirchkom's Workpapers, Exhbit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with
2008 DSM ther savings of9,500 for a "Shell" DSM
Staff_PR_011 Attachment B Page 148 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: July 2, 2009
Page 40f 12
project, at p. 37. Please conf ths refers to what is
shown as "Option 2" in the table on p. 18.
u. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include a WA Schedule 101 customer with
2008 DSM therm savings of 2,030 for a "HV AC
Combined" DSM project, at p. 36. Please conf this
refers to what is shown as "Option 3" in the table on p. 18.
m. Mr. Hirschkom's Workpapers, Exhbit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with
2008 DSM therm savings of 516 for a "Shell" DSM
project, at p. 37. Please conf ths refers to what is
shown as "Option 4" in the table on p. 18.
b. The incentive calculator at p. 4 of Confidential Attachment B and
the savings worksheet shown at p. 22 for the insulation project
indicate the customer is a Schedule 101 customer. However, the
existing and proposed usage levels shown at the bottom of p. 22
greatly exceed the tyical usage levels for a Schedule 101
customer. Please explain ths apparent inconsistency.
c. The "eQuest" calculations for the therm savings related to the 80%
unt heating project are shown on p. 24 of Confdential Attchment
B. Both the "baseline adjustments" table and the "EEM Run 1"
table show therm usage levels that greatly exceed the tyical usage
levels for a Schedule 101 customer. Please explain ths apparent
inconsistency.
d. The calculations provided in Confdential Attachment B appear to
indicate that A vista analyzed the thee gas DSM projects, and
prospective therm savings, separtely rather than in an interctive
fashion. Please confir that is the case.
e. Please confrm that according to Avista's DSM savings analysis
for ths building, the estimated anual therm usage at ths premise,
after implementation all thee gas DSM projects, would at a
minum be equivalent to the sum of the following thee amounts:
i) the "proposed" therm usage shown on p. 22 for the
insulation project,
ii) the total therms shown on p. 24 in the e-Quest "EEM Run
i" for the 80% heater, and
iii) the "proposed" therm usage shown on p. 25 for the
insulated overhead door.
f. Subsequent to a discovery conference held on April 16, 2009,
A vista indicated that ths premse "is being remodeled into 5
suites." Please explain when tht remodel occured or is scheduled
StafCPR_011 Attachment B Page 149 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-090314 / UG-090315, UG-0605l8
Date: July 2, 2009
Page 5 of12
to occur, and if that was known at the tie the DSM savings
calculations were pedormed. In addition, pleae provide a
quantification and explantion as to how the therm savings
amounts shown on p. 18 of Confdential Atthment Bare
applicable to each of the suites located at the premise identified as
"Building llW."
g. Please provide gas and electrc billing sumares from Januar 1,
2004 to the present for all meters serving the building identified as
"Buildig 11 W" at pp. 16 and pp. 18 of Confdential Attchment
B. To the extent there are separte meters sering smaller "suites"
at ths premise, pleae indicate which "suite" the meter seres, and
the associated therm savings values quantified in response to par
(t) of ths request for each "suite".
PC-355 Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 27841
a. Please explain why the gas biling history shows the "service status
open" date as being in 2009, but ther is biled usage prior to that
date. Does ths indicate tht usage prior to the "service open" date
was for a prior customer?
b. Mr. Hirchkom's Workpapers, Exhbit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2008
DSM therm savings of 7,662 for an "Shell" DSM project, at p. 37.
Please conf this refers to ths DSM Application 27841, shown
as Option 2 on p. 20 of Confdential Attachment B.
c. Mr. Hirchkom's Workpapers, Exhbit C-L "DSM Savings
Calculations," include a WA Schedule 101 customer with 2008
DSM therm savings of 177 for an "Shell" DSM project, at p. 37.
Please conf this refers to what is shown as Option 3 on p. 20 of
Confidential Attchment B. Please also provide the DSM
Application number for this overhead door project.
d. Confdential Attchment B for this DSM project includes Incentive
Calculator worksheets at p. 4 and p. 26. Please conf that the
worksheet shown at p. 4 is the fi version of the worksheet.
e. Both versions of the incentive calculator provided in Confdential
Attchment B, shown at p. 4 and p. 26, indicate that ths customer
is a Schedule III gas customer. However, the excel worksheet
provided with ths data request shows ths customer as a Schedule
101 gas customer. The biling history provided in response to PC-
StafCPR_011 Attachment B Page 150 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-090314 / UG-090315, UG-060518
Date: July 2, 2009
Page 6 of12
PC-356
006 also shows ths customer as a Schedule 101 customer. Please
explai ths apparent inccurcy.
f. Please provide an explanation as to whether the therm savings
claim resulting from each of the gas DSM measures (insulation and
overhead door) would be any different if the incentive calculator
worksheet(s) and the insulation calculators shown on pp. 24 and 25
of Confdential Attchment B, had shown ths customer as a
Schedule 101 customer? If either of the ther savings amounts
would have been different, please provide an estiate of what the
therm savings claim( s) would have been had the worksheet and
calculators identified.the customer as a Schedule 101 gas customer.
g. Please confirm that according to Avista's DSM savings analysis
for ths building, the estimated anual therm usage at ths premse,
after implementation both gas DSM projects, would at a minium
be equivalent to the sum of the following two amounts:
i. the "proposed" therm usage shown on p. 24 for the
inulation project, and
ii. the "proposed" therm usage shown on p. 25 for the
inulated overhead door.
h. In the event that the premise identified as "building 32W" has been
or wil be remodeled into smaller spaces or "suites", please explain
when that remodel occured or is scheduled to occur. In addition,
please provide a quatification and explanation as to how the
therm savings amounts shown on p. 20 of Confdential Attchment
B are applicable to each of the suites located at the premise
identified as "Building 32W."
i. Please provide an updated gas and electrc billig history for each
meter sering the building identified as '~Building 32W," from
Januar 1,2004 to the present. To the extent there are separate
meters serving smaller "suites" at ths premise, please indicate
which "suite" the meter serves, and the associated therm savings
values quatified in response to par (h) of this request for each
"suite".
Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 28231
a. Please explai why the gas biling history shows the "service status
open" date as occurg in 2008, but usage is shown for prior
months. Does ths indicate tht usage prior to the "serice open"
date was for a prior customer?
StafCPR_011 Attachment B Page 151 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-090314 I UG-090315, UG-060518
Date: July 2, 2009
Page 7 of 12
b. Please provide the gas and electrc biling history for eah meter
serving the building identified as "Buildig 15W," from Januar 1,
2004 to the present.
c. Mr. Hirchkom's W orkpapers, Exhbit C- 1 "DSM Savings
Calculations," include a WA Schedule 101 customer with 2008
DSM therm savings of 4,790 for a "Shell" DSM project, at p. 37.
Please confi ths refer to ths DSM Application 28231, shown
as Option I on p. 15 of Confdential Atthment B.
d. Mr. Hirchkom's Workpaper, Exhbit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2008
DSM ther savings of 446 for a "prescriptive food serice" DSM
project, at p. 36. Please indicate whether ths refers to the 80%
unt heater project shown as Option 3 on p. 15 of Confdential
Attchment B. If so, pleae provide the DSM application number
for ths meaure. In the event the ther savings of 446 for
"prescriptive food serce" in Mr. Hirshkom' s Workpapers C-L
does not refer to a DSM measure at ths premse, please provide
the inormtion requested in PC-006 for the "prescriptive food
serice" measure tht resulted in an estiated 446 therms savings
completed in 2008.
e. Confdential Attchment B for ths DSM project includes Incentive
Calculator worksheets at p. 3 and p. 22. Please confirm that the
worksheet shown at p. 3 is the fial version of the worksheet.
f. Both versions of the incentive calculator provided in Confdential
Attchment B, shown at p. 3 and p. 22, indicate that ths customer
is a Schedule 111 gas customer. However, the excel worksheet
provided with ths data request shows ths customer as a Schedule
101 gas customer. The billig history provided in response to PC-
006 also shows ths customer as a Schedule 101 customer. Please
explain ths apparent inccurcy.
g. Please provide an explanation as to whether the ther savings .
claim resulting from each of the gas DSM measures (inulation and
80% unt heater) would be any different if the incentive calculator
worksheet(s) and the insulation calculator shown on pp. 16 of
Confdential Attchment B, had shown ths customer as a Schedule
101 customer? If either of the therm savings amounts would have
been different, please provide an estimate of what the therm
savings clai( s) would have been had the worksheet and
calculators identified the customer as a Schedule 101 gas customer.
StafCPR_011 Attachment B Page 152 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-0903 14 / UG-0903 1 5, UG-0605 1 8
Date: July 2, 2009
Page 8 of12
PC-357
PC-358
h. Please provide fuer clarfication on the location of the two gas
DSM measures at ths premise. In parcular, p. 15 of Confdential
Attchment B indicates the upgrades are for "Buildig 15". Page 9
of the signed DSM agreement indicates the upgrades are for
"Building 15, Suite Z." The gas biling history provided at p. 1 of
Confdential Attchment B describes the premise as "Building
15A." Please provide a quantification and explanation as to how
the therm savings amounts shown on p. 15 of Confdential
Attchment B are applicable to the "suite(s)" located at the premse
identified as "Building 15."
1. Please provide an updated gas and electrc biling history for each
meter serving the buildig identified as "Buiding 15," from
Janua 1, 2004 to the present. To the extent there are separate
meters sering smaller "suites" at ths premse, please indicate
which "suite" the meter serves, and the associated therm savings
values quatified in response to par (h) of this request for each
"suite".
Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 28455
a. Please provide gas and electrc biling sumaries for each of the
eight unts identified at p. 2 of Confdential Attchment B as
having received new windows, from Januar 1, 2004 to the
present.
b. Mr. Hirchkorn's Workpapers, Exhbit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2008
DSM therm savings of 4,138.75 for a "UCON MF Shell" DSM
project, at p. 37. Please confirm ths refers to ths DSM
Application 28455.
Re: Avista Response to Public Counsel Data Request PC-006
DSM Application 28528
a. Please provide gas and electrc biling sumaries for each of the
eight unts identified at p. 2 of Confidential Attchment B as
having received new windows, from Janua, 2004 to the present.
b. Mr. Hirschkorn's Workpapers, Exhbit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2008
DSM therm savings of 4,434 for a "UCON MF Shell" DSM
StafCPR_011 Attachment B Page 153 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: July 2, 2009
Page 9 of 12
project, at p. 37. Please conf ths refers to ths DSM
Application 28528.
c. Page 5 of Confdential Atthment B shows a thers savings
amount associated with "duct inulation" at a parcular location.
Please indicate the number of unts receiving duct insulation as
par of ths project and provide biling sumares for al such unts,
from Januar 2004 to the present.
d. Page 5 of Confidential Attchment B shows a therms savings
amount associated with "floor insulation" at a paricular location.
Please indicate the number of unts receiving floor insulation as
par of ths project and provide biling sumares for all such unts,
from Janua 2004 to the present. In addition, please indicate
whether ths DSM project was completed in 2008, and if so, where
it appears in Mr. Hihkom's Workpapers, Exhbit C- 1 2008
Complete DSM Project Savings (therms). If ths project had a
separte DSM application number, pleae provide tht number.
PC-359 Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 28307
a. Mr. Hirchkom's W orkpapers, Exhbit C- 1 "DSM Savings
Calculations," include a WA Schedule 101 customer with 2008
DSM therm savings of 3,492 for a "Rooftop Service" DSM
project, at p. 36. Please conf ths refers to ths DSM
Application 28307. If ths reference in W orkpaper C-L does not
refer to ths project, pleae provide the inormation requested in
data request PC-006 for the "Rooftop Serice" project completed
in 2008 that resulted in an estiated 3,492 therms of savings. In
addition, if the reference above is not accurte, please identify
where in Workpaper C- 1 ths DSM application (28307) appears.
b. Please explain the hadwrtten notation "multiple RTUs" that
appears on page 1 of Confdential Attchment B.
c. Please provide billig sumares for each gas meter providing
service to each of the 4 units affected by ths DSM measure, from
Janua 2004 to the present. Please identify the biling sumares
provided in response to ths request and specify which of the four
unts shown on p. 3 of Confidential Atthment B are served by
which meter.
d. Please describe the natue of the "thermostat modification"
provided as part of ths measure.
Staff_PR_011 Attachment B Page 154 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-0903 14 / UG-0903 1 5, UG-0605 1 8
Date: July 2, 2009
Page 10 of12
PC-360 Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 22204
a. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2008
DSM therm savings of 2,665 for a "HV AC Combined" DSM
project, at p. 36. Please confi ths refers to ths DSM
Application 22204. If ths reference in Workpaper C-l does not
refer to ths project, please provide the inormation requested in
data request PC-006 for the "HV AC Combined" project completed
in 2008 that resulted in an estiated 2,655 therms of savings. In
addition, if the reference above is not accurate, please identify
where in Workpaper C-l ths DSM application (22204) appears.
b. Confdential Attchment B for ths DSM project includes Incentive
Calculator worksheets at p. 3 and p. 6. Please indicate which is the
final version of the worksheet.
c. Both versions of the incentive calculator provided in Confdential
Attchment B, shown at p. 3 and p. 6, indicate tht this customer is
a Schedule 111 gas customer. However, the excel worksheet
provided with ths data request shows ths customer as a Schedule
101 gas customer. The billg history provided in response to PC-
006 also shows ths customer as a Schedule 101 customer. Please
explain ths apparent inaccurcy.
d. Please provide an explantion as to whether the therm savings
claim resultig from the gas DSM measures (HV AC) would be any
different if the incentive calculator worksheets shown on pp. 3 and
6 of Confidential Atthment B, had shown ths customer as a
Schedule 101 customer? If the therm savings amount would have
been different, please provide an estimate of what the therm
savings claim would have been had the worksheet and calculators
identified the customer as a Schedule 101 gas customer.
e. Please provide a gas biling sumar for ths premise from
Janua, 2004 to the present.
PC-36l Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 28357
a. Mr. Hirchkom's Workpapers, Exhbit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2008
DSM therm savings of3,155 for a "Rooftop Service" DSM
project, at p. 36. Please confi ths refers to ths DSM
StafCPR_011 Attachment B Page 155 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-0903l4 / UG-090315, UG-060518
Date: July 2, 2009
Page 11 of12
Application 28357. If ths reference in Workpaper C-L does not
refer to ths project, please provide the inormation requested in
data request PC-006 for the "Rooftop Serice" project completed
in 2008 tht resuted in an estiated 3,155 therm of savings. In
addition, if the reference above is not accurate, please identify
where in Workpaper C-L ths DSM application (28357) appear.
b. Please provide a description of the ''termostat modification"
provided as ths DSM measure.
c. Page 3 of Confdential Atthment B provides a list of 9
"thermostat modifications," each with their own therm savings.
The "customer" indicated on ths page is the same customer for all
9 modifications. Please conf that all of the 9 modifications
were indeed for the customer shown on ths page.
d. Please explai why a biling sumar for a different customer,
with different nae and premse number, was provided on p. 2 of
Confdential Appendix B.
e. In the event there are additional customers that received ths DSM
measure as par of ths Application (App. 28357), please provide
the following inormation: customer(s) name, premise location,
and account number for each customer who received ths DSM
measure, and savings claim associated with each customer.
f. Please provide biling sumares for each meter serving the
premise(s) affected by ths DSM measure, from Janua, 2004 to-
the present. Please specify which billing sumar applies to each
of the 9 ther savings values shown on page 3 of Confdential
Attchment B.
PC-362 Re: A vista Response to Public Counsel Data Request PC-006
DSM Application 27640
a. Please indicate the number of unts that received new windows as
par of ths DSM measure.
b. Please provide a gas biling sumar for each premise tht
received new windows, from Janua2004 to the present.
c. The biling sumar provided in Confdential Attchment B
includes an RBC code of "Q" on a parcular date. Please conf
that indicates a new meter was intalled on tht date.
d. Mr. Hirschkorn's W orkpapers, Exhbit C-L "DSM Savings
Calculations," include a WA Schedule 101 customer with 2008
DSM therm savings of2,668 for a "Shell" DSM project, at p. 37.
Please conf ths refers to ths DSM Application 27640. If ths
StafCPR_011 Attachment B Page 156 of 264
To: David Meyer
Re: PC Data Requests Nos. 351 though 363
Docket Nos. UE-0903l4/ UG-090315, UG-0605l8
Date: July 2, 2009
Page 12 of 12
reference in Workpaper C- 1 does not refer to ths project, please
provide the information requested in data request PC-006 for the
"Shell" project completed in 2008 that resulted in an estiated
2,668 thers of savings. In addition, if the reference above is not
accurate, please identify where in W orkpaper C-L ths DSM
application (27640) appears.
PC-363 Re: Avista Response to Public Counsel Data Request PC-006
Please provide a complete listig and definition of eaëh and every
abbreviation tht may appear in the colum labeled "RBC" in the biling
sumares provided in response to ths data request.
StafCPR_011 Attachment B Page 157 of 264
BEFORE THE WASHIGTON UTITS AN TRSPORTATION
COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 364 to 368
To: Avista
PC-364 Re: PF2 2 Proforma Production Propert
a. Pleae provide a complete explanation of why the production
factor was applied to sales for resale in the amount of
$3,350,000, other revenues in the amount of $10,000, and other
revenues in the amount of $294,000.
b. Explai why these revenues were reduced in the Company's
adjustment to production facilities.
PC-365 Re: Workpaper PF2 3 Proforma Production Propert
a. Pleae provide a schedule which shows the actual test year kilowatt
hour by rate schedule as shown on the bottom of ths workpaper
and the effectof each of the adjustments tht the Company made to
arve at the proforma megawatt hour shown by rate schedule
which total to the proforma megawatt hour of $5,487,025.
b. State the schedule 26 actual megawatt hour for the test year and
any adjustments which have been made to tht schedule sales.
PC-367 Re_: Workpaper PF2 3 Proforma production propert
Please shown the 2009 and 2010 Washigton retail forecast by rate
schedule for the years 2009 and 2010.
PC-368 Re: Workpaper PF3 9.
a. Please provide in a simlar format individual executive base labor
costs and benefits for each of the years 2004, 2005, 2006,2007,2008,
the test year, 2009, and 2010.
StafCPR_011 Attachment B Page 158 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 369 to 387
To: Avista
PC-369 Labor
a. For each month in the test year ended September 30, 2008, provide
the number of employees by month broken down by unon, non
unon and mangement employees and by category of production,
trmission, customer accounts, customer service and
inormation, and sales and marketing.
b. Provide the same inormation for each month subsequent to the test
year though the most curent month avaiable.
c. Provide the same inormation for the years 200S, 2006, and 2007.
PC-370 Labor
a. Has the Company offered its employees an early retiement plan
either durg the test year ended September 30, 2008 or in any
period subsequent to that date?
b. Does the Company intend to offer any of its employees an early
retirement plan?
c. If the Company has or does intend to offer its employees an early
retirement plan, please provide al documentation and calculations
which show the effect of such an early retiement plan on wages,
pensions and other benefits.
PC-37l Please refer to the Direct Testimony of Elizabeth M. Andrews, Exhbit
No._(EMA-IT), page 23, line 17. Provide any studies, anyses, or other
documentation which A vista used to "benchmark agaist other similarly-
sized energy companes."
Staff_PR_011 Attchment B Page 159 of 264
To: David Meyer
Re: PC Data Requests Nos. 369 though 387
Docket Nos. UE-0903 14 / UG-0903 1 5, UG-0605 1 8
Date: July 8, 2009
Page 2 of5
PC-372 ColumbiaGrid (RTO Development)
Please refer to the Direct Testiony of Scott J. Kiey, Exhbit
No._(SJK-lT), page 3, line 18.
a. State whether the Company ha adjusted the proforma test year for
the $22,000 referred to in Mr. Kiney's testiony.
b. Explain whether the Company continued to accrue a monthy
amount of $20,720 as referred to on lie 13 of Mr. Kiey's
testiony. Explain how the monthy accrual of $20,720 does not
equal $248,640 of accrual of ths expense for the test year which is
$8,640 greater th the projected on-going expense.
PC-373 ColumbiaGrid Plannig
Please provide invoices for the actul payments on the ColumbiaGrd
plang for the test year and for each month subsequent to the test year.
PC-374 ColumbiaGrid Open Access Same-Time Information System (OASIS)
a. Provide of a copy of the invoice for the payment A vista has made
regarding ths open access development clause.
b. State where the Company has included ths cost in its filing and
what amount has been allocated to the Washigton jursdiction.
PC-375 WECC System Security Monitor and WECC Administration and Net
Operating Committee Systems
a. Provide the copies of the actul invoices for the WECC System
Securty Monitorig for Janua, 2008 and Janua, 2009.
b. Provide the WECC admstrtive and net operating fees biled to
the Company in all of 2008 and YTD 2009.
StafCPR_011 Attachment B Page 160 of 264
To: David Meyer
Re: PC Data Requests Nos. 369 though 387
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: July 8, 2009
Page 3 of5
PC-376 Transmission System
Please provide the Company's comparson of budgeted to actu
trmission expenditues for the A vista system by month from Janua
2006 though the most curent month available.
PC-377 Distribution System
Please provide the Company's comparson of budgeted to actu
expenditues for constrction in the distrbution system of A vista by
month from Janua, 2006 though the most curent month avaiable.
PC-378 Asset Management O&M Expenses
For the test year ended September 30,2008, provide a comparson of the
Company's actul O&M expenditues for the Washigton jursdiction to
the O&M expenditues allowed by the Washigton Utilities and
Transporttion Commission in rates.
PC-379 Asset Management O&M Expenses
a. For each increase in expenditues shown in Table 1 on page 22 of
the Direct Testiony of Scott J. Kiey, Exhibit No._(SJK - 1 T),
provide the cost benefit analysis that the Company performed to
arve at the dollar amount increase shown in each of the categories
on that page.
b. If no cost benefit anlysis exists, provide the analysis that the
Company performed that justified the increase of 58% in O&M
expenses over the test year ended September 30, 2008.
PC-380 Asset Management O&M Expenses
Show the increase in savings that ratepayers wil experience by fuding
the additional O&M expenses, and show where the Company has reflected
these savings in the Company's fiing in ths docket.
Staff_PR_011 Attachment B Page 161 of264
To: David Meyer
Re: PC Data Requests Nos. 369 though 387
Docket Nos. UE-0903l4 / UG-090315, UG-060518
Date: July 8, 2009
Page 4 of5
PC-381 Vegetation Management
a. Has A vista solicited competitive bids for its vegetation
management? If not, please explain why not.
b. If A vista has solicited competitive bids, provide copies of all
competitive bids submitted to the Company withi the last thee
years.
PC-382 Vegetation Management
State the basis on which A vista has accepted a 6% increase in vegetation
management costs durg the curent period of economic downtu.
PC-383 Vegetation Management - Distrbution and Transmission
Provide the actual vegetation mangement cost for the gas distrbution and
trmission system for the last five year and the test year.
PC-384 Vegetation Management - Distrbution and Transmission System
a. Provide the cost benefit analysis tht the Company performed to
determine tht a 50% increase in the vegetation management for
gas distrbution and transmission would be necessar.
b. If no cost benefit analysis was performed, provide any analysis
. which the Company has done which justifies the $2.813 millon
increase in increase in vegetation mangement for gas distrbution
and transmission.
c. Provide the benefits which ratepayers wil receive by the
expenditue of ths additional amount.
PC-385 Transmission Asset Management Plan
a. Provide the cost benefit analysis which supports the Company's
increase in operatig and maintenance expense of $401,000.
b. If no cost benefit anlysis exists, show how the Company arved
at this dollar amount.
~aff_PR_011 Attachment B Page 162 of 264
To: David Meyer
Re: PC Data Requests Nos. 369 though 387
Docket Nos. UE-0903l4 / UG-0903lS, UG-060S18
Date: July 8, 2009
Page 5 ofS
PC-386
PC-387
c. Identify the benefits to ratepayers tht the Company has calculated
as a result of spending ths level of O&M expense.
Transmission Asset Management Plan
Please provide the actul costs which the Company incured for each of
the last five calenda years and the test year separately in O&M fudig
for the trsmission Asset Management Plan.
Network Asset Management Plan
a. Provide the actul expenditues for the last five calendar years and
the test year separately for the Network Maitenance Program.
b. Provide the cost benefit analysis on which the Company relied on
to determe that an additional expenditue of$114,000 would be
beneficial to ratepayers.
c. Show where associated savings would be generated as a result of
the additional expenditues requested in ths case by the Company.
StafCPR_011 Attachment B Page 163 of 264
BEFORE THE WASHIGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 388 Through 402
To: Avista
PC-388 Please provide copies of any and all evaluations or reviews of A vista's gas
DSM progrs, conducted by or on behalf of Avista, frm Januar 1,
2004 to the present. For each such evaluation, please provide the
following inormation:
a. A copy of the fial evaluation report.
b. A description as to how Avista used the evaluation results to modify
its gas DSM progr(s), and when any such modifications were
implemented.
c. A description and quatification of the claied therm savings per
customer or per measure for the progr, and an explantion as to
whether the claied therm savings for the progr was adjusted
following the evaluation. If there were any changes in the claimed
therm savings per customer (or per measure), please describe the basis
for those changes, the date they were implemented, and documentation
of calculations supporting the adjustment to claied therm savings.
d. The tota cost of the evaluation.
e. The total amount of any electrc or gas DSM taff rider fuds used to
pay for the evaluation.
f. Please indicate if there are any evaluations of gas DSM progrs that
are planed but not yet completed. If ths is the case, please identify
the progr and the status of the evaluation.
g. Please consider ths an ongoing request and update the response as
necessar if additional evaluations are completed durg ths rate case.
PC-389 Avista Exhibit No. _ (JP-2) at p. 7 indicates that Avista ratepayers in
Oregon may qualify for a $200 rebate for a 90% efficient fuace, but tht
Washigton ratepayers may get a rebate of $400 for the same fuace.
Please explain why the rebate amount is different in Washigton and
Oregon, and provide any and all documentation, analysis, or memoranda
that were relied upon in establishig the Washigton fuace rebate level
and the Oregon fuace rebate leveL.
StafCPR_011 Attachment B Page 164 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-090314 / UG-0903 1 5, UG-0605 1 8
Date: July 9,2009
Page 2 of 13
PC-390 Avista witness Mr. Powell states the following at p. 8 of his testiony
(JP-l T), lines 5 though 8:
"The Company is undertking a review and revision of record
keeping and reportg processes. Based upon what we have
leared durng ths pilot, we have established improved
mechansms for trckig, documentig and reporting DSM savings
with a categoriation tht better meets the needs of a decoupling
mechanism."
a. Please identify and describe in more detail what A vista "learned"
durg the pilot regarding DSM record keeping and reporting.
b. Please provide an update of the "review and revision" that is referred
to in the testiony. In parcular, please describe the scope of the
review, when it commenced, a list and description of all findigs, and
when it is expected to conclude. Please provide copies of any and all
documents, memos, report, or analysis produced as par of ths
reView.
c. Please describe the "improved mechanisms" referred to at p. 8, line 7
of Mr. Powell's testimony. In parcular, please describe each such
improvement related to "tracking, documenting and reporting DSM
savings," the objective of each improvement, and the date it was
implemented.
PC-391 Mr. Powell's testimony at p. 7, lines 18-19 states: "These are augmented
by actual field measurements when useful and achievable."
a. Please define the term "field measurements" as it is used here.
b. Please identify each gas DSM program that included "field
measurements" in 2006,2007, or 2008.
c. For each such program identified in par (b) as including "field
measurements" please provide data regarding the number of customer
program. paricipants that received "field measurements," and the total
number of program paricipants, for each year, 2006 though 2008.
d. If A vista does not have the actul data requested in par ( c) of ths
request, please provide the company's best estimate of the number of
customer program participants that received "field measurements"
each year, 2006 though 2008, and the method and basis for
calculating such an estiate.
StafCPR_011 Attachment B Page 165 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-0903l4 / UG-0903l5, UG-0605l8
Date: July 9,2009
Page 3 of 13
PC-392 Mr. Powells testimony at p. 7, lines 19-22 states:
"Additional post-project analysis is often performed to
validate pre-project measurements or estiates. Actul pre-
and post-project energy usage is often measured when it is
possible to do so without interference from multiple end-
uses being operated from the same meter."
a. Please indicate whether the "post-project analysis" that is "often
performed" ever results in any modifications to the estimated therm
savings claied. If so, please provide documentation and
quatification of the number of parcipants for whom the amount of
claied therm savings was modified, and the amount of each such
adjustment frm the origi claied therm savings resultig from the
"post-project analysis."
b. Please provide an explanation as to how often, and for which gas DSM
programs, "actual pre- and post-project energy usage" is measured.
Please specify each gas DSM progr where such measurement
would occur.
c. For each gas DSM program identified in response to par (b) as
including "actual pre- and post-project energy usage," please provide
the percentage of customer progr parcipants who would have pre-
and post-project energy usage measurements taen, for each year 2006
though 2008.
d. For those program participants identified in response to par (c) of ths
request, please indicate whether the pre- and post-project energy usage
measurements would result in any modification or adjustment to the
claimed therm savings for the project. If so, please provide
documentation and quantification of the number of participants for
whom the amount of claimed therm savings was modified, and the
amount of each such adjustment from the origial claimed therm
savings resulting from the pre- and post-energy usage measurements,
for each year 2006 though 2008.
StafCPR_011 Attachment B Page 166 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-090314 / UG-090315, UG-060518
Date: July 9,2009
Page 4 of 13
PC-393 Mr. Powell's testimony at p. 8, lines 1-2 states:
"A vista is in the process of developing a revised measurement and
verification strtegy for review in the fal 2009 Triple-E board and
incorporation into the 2010 DSM Business Plan."
a. Describe the impetus behind the "revised measurement and
verification strtegy." In addition, please describe the purpose and
objectives of the "revised measurement and verification strategy."
b. Provide any and all documents, including but not limited to memos,
workplan, presentations, or reports related to the development of the
"revised measurement and verification strategy."
c. When does A vista anticipate this "revised measurement and
verification strategy" wil be developed by the company and ready to
be shared with the Triple E board?
d. Please consider this an ongoing request and provide any updates to the
company's response during the course ofthis proceeding.
PC-394 Mr. Hirschkom's testimony at p. 17, lines 7-10 states tht durg the pilot
perod the first $35,000 of the DSM verification was fuded though the
DSM tariff rider, but that "Going forward, the Company proposes that the
full cost" be funded through the DSM tariff rider.
a. Please provide an update of Table H-2, DSM Verification Costs, in the
Decoupling Evaluation Report prepared by Titus, and indicate whether
costs for the 2008 DSM Verification reflect total costs for the 2008
Verification.
b. In light of Mr. Powell's testimony at p. 8, lines 11 through 14
regarding development of "a verification methodology that wil
address the concerns and recommendations identified in the Evaluation
Report," please provide the Company's best estimate of futue annua
DSM Verification costs.
StafCPR_011 Attachment B Page 167 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-090314 / UG-090315, UG-0605l8
Date: July 9,2009
Page 5 of 13
PC-395 Re: A vista Response to Public Counsel Data Request PC-005
DSM Application 23993
a. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2007 DSM
therm savings of 14,980 for an "HV AC combined" DSM project, at p.
22. Please conf ths refer to ths DSM Application 23993.
b. The Avista prepared excel spreadsheet included with DR PC-005
refers to ths customer as a Schedule 101 gas customer. However,
accordig to Confdential Attchment B, at both the bil sumar on
p. 1, and the incentive calculator on p. 4, ths customer is a Schedule
111 gas customer. Please explain ths apparent inaccuracy.
c. Does Avista believe the DSM savings associated with ths project
should be attbutable to Schedule 101 or Schedule 1 II?
d. Confdential Atthment B, at p. 25, includes an EZ Sim Biling
Anysis for conversion frm electrc to gas heat. The bottom of the
page shows "anual energy consumption," ii therms, with potential
energy conseration measures (ECMs). Please provide an explantion
as to whether the amount shown as anua energy consumption, in
thers, reflects the estiated tota anua natu gas consumption for
ths customer.
e. Please explain why the amount shown on p. 25 of Confdential
Attachment B as the "annual energy consumption, in therms" is far
greater than the total anual therm consumption reflected in the bil.
sum on p. 1 of Confidential Attachment B.
PC-396 Re: A vista Response to Public Counsel Data Request PC-005
DSM Application 24655
a. Mr. Hirschkom' s Workpapers, Exhbit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2007 DSM
therm savings of 1 1,874 for a "Shell" DSM project, at p. 24. Please
conf ths refers to ths DSM Application 24655, and paricularly to
what is shown as Option 2 on p.18 of Confdential Attchment B.
b. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include a W A Schedule 101 customer with 2007 DSM
therm savings of 329 for a "Shell" DSM project, at p. 24. Please
conf ths refers to ths DSM Application 24655, and parcularly to
what is shown as Option 3 on p. 18 of Confdential Attchment B.
c. The incentive calculators provided in Confdential Attchment B,
shown at p. 4 and p. 22, and the inulation calculators shown at pp. 20-
StafCPR_011 Attchment B Page 168 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-0903l4/UG-0903lS, UG-060Sl8
Date: July 9,2009
Page 6 of 13
21, all indicate tht this customer is a Schedule 111 gas customer.
However, the excel worksheet provided with ths data request shows
ths customer as a Schedule 101 gas customer. In addition, the billig
history provided in response to PC-OOS also shows ths customer as a
Schedule 101 customer. Please explain ths apparent inaccuracy.
d. Please provide an explantion as to whether the therm savings claim
resultig from each of the gas DSM measures (ceiling insulation and
overhead door) would be any different if the incentive calculator
worksheet(s) and the insulation calculators shown on pp. 20 and 21 of
Confdential Attchment B, had shown ths customer as a Schedule
101 customer? If either of the therm savings amounts would have
been different, please provide an estiate of what the therm savings
claim( s) would have been had the worksheet and calculators identified
the customer as a Schedule 101 gas customer.
e. Please confirm that according to Avista's DSM savings analysis for
ths building, the estimated annual therm usage at ths premse, after
implementation both gas DSM projects, would at a minium be
equivalent to the sum of the following two amounts:
i) the "proposed" therm usage shown on p. 20 for the ceiling
insulation project, and
ii) the "proposed" therms shown on p. 21 of Confdential
Attchment B for the insulated overhead door.
f. With respect to the insulation calculator shown on p. 20, which shows
the estiated impact from an existing R-value of 2 to a proposed R-
value of 19, please explain whether the amount shown as "existing"
therms per year, at the bottom of ths page, reflects the actual historical
therm usage of ths premse. If ths amount is not based on the
historical usage of ths premise, please explain why not. If this amount
of "existing" annual therm usage is expected to reflect historical usage,
please explain why the amount shown is nearly thee times the actual
therm usage for ths premise in the year prior to installation of the
DSM measure, as shown in the bil sumary provided on p. 1 of
Confdential Attchment B.
g. Please confi that the therm savings amounts shown on p. 18 of
Confdential Attchment B are applicable to the premise identified as
"Building 21 W" as provided in the bil summar on p. 1 of
Confdential Attchment B. To the extent the therm savings amounts
are applicable to smaller "suites" within the premise identified as
"Building 21," please provide a quantification and explanation as to
how the therm savings amounts shown on p. 18 of Confdential
StafCPR_011 Attachment B Page 169 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-0903 14 / UG-090315, UG-0605 1 8
Date: July 9,2009
Page 7 of 13
Atthment B are applicable to eah of the "suites" or spaces located
at the premise identified as "Building 2 i" .
h. Please provide gas and electrc biling sumes from Janua 1,
2003 to the present for all meters serving the building identified as
"Building 21" at p. 18 of Confidential Attachment B. To the extent
there are separate meters serving smaller "suites" at this premise,
please indicate which "suite" the meter serves, and the associated
therm savings values quantified in response to par (g) of ths request
for each "suite".
PC-397 Re: A vista Response to Public Counsel Data Request PC-005
DSM Applications 24895 and 24872
a. Please explain why the electrc bil sumar provided on p. 3 of
Confdential Attchment B for DSM Application 24872 is identical to
the electrc bil sumar provided on p. 1 of Confdential Attchment
B for DSM Application 24895, in ters of the service number,
premise number, and begin and end meter reads and billed amounts for
June 2006 though Februar 2009, but these bil sumes show
different customer naes and account numbers. Please clarfy
whether both customers and accounts were biled for ths usage, and if
so, please explai why two different customers would be biled for
usage at a single meter.
b. Please explain why the gas bil sumar provided on p. 2 of
Confdential Attchment B for DSM Application 24872 is identical to
the gas bill sumar provided on p. 2 of Confidential Attachment B
for DSM Application 24895, in terms of the service number, premise
number, and begin and end meter reads and biled amounts for
September 2006 though March 2008, but these bil sumares show
different customer names and account numbers. Please clarfy
whether both customers and accounts were biled for ths usage, and if
so, please explain why two different customers would be biled for
usage at a single meter.
StafCPR_011 Attachment B Page 170 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: July 9, 2009
Page 8 of 13
PC-398 Re: A vista Response to Public Counsel Data Request PC-005
DSM Application 24895
a. Mr. Hirschkorn's Workpapers, Exhibit C-L "DSM Savings
Calculations," include two WA Schedule 101 projects with 2007 DSM
therm savings of 1 1,405 for a "Shell" DSM project, at p. 24. Please
confi that one of these 'projects refers to ths DSM Application
24895, and parcularly to what is shown as Option 3 on p. 14 of
Confdential Attchment B.
b. Mr. Hirschkorn's Workpapers, Exhibit C-L "DSM Savings
Calculations," include two W A Schedule 101 projects with 2007 DSM
therm savings of3,201 for a "HVAC" DSM project, at p. 21. Please
confirm that one of these projects refers to what is shown as Option 2
on p. 14 of Confdential Attchment B. Please confirm the DSM
Application number for this project is 24984.
c. Mr. Hirschkorn's Workpapers, Exhibit C-L "DSM Savings
Calculations," include a WA Schedule 101 projects with 2007 DSM
therm savings of 431 for a "Shell" DSM project, at p. 24. Please
confin that ths project refers to what is shown as Option 4 on p. 14
of Confdential Atthment B. Please provide the DSM Application
number for ths project.
d. Mr. Hirschkorn's Workpapers, Exhibit C-L "DSM Savings
Calculations," include two W A Schedule 101 projects with 2007 DSM
therm savings of 438 for a "Shell" DSM project, at p. 24. Please
confin that one of these projects refers to what is shown as Option 5
on p. 14 of Confidential Attchment B. Please provide the DSM
Application number for this project.
e. Please clarfy the location of the DSM projects shown on p. 14 of
Confidential Attchment B, due to confictig statements in ths
Attchment. Pages 8, 12, and 14 indicate the efficiency improvements
are for "Building l8WC," but the incentive calculators on page 5 and
21-25, the insulation calculators on pp. 18-19, and references on pp.
14- 15 all refer to upgrades at "Building l8EC."
f. The incentive calculators provided in Confidential Attchment B,
shown at p.5, and pp. 21-25, and the insulation calculator shown at p.
19 al indicate that ths customer is a Schedule III gas customer.
However, the A vista prepared excel worksheet provided with ths data
request shows ths customer as a Schedule 101 gas customer. The
biling history provided in response to PC-005 also shows ths
customer as a Schedule 101 customer. Please explain this apparent
inaccuracy.
StafCPR_011 Attachment B Page 171 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-090314 / UG-090315, UG-060518
Date: July 9,2009
Page 9 of 13
g. Please provide an explanation as to whether the therm savings clai
resulting from the DSM measures would be any different if the
incentive calculator worksheet(s) referenced above in par (f) of ths
request had shown ths customer as a Schedule 101 customer? If the
therm savings amount would have been different, please provide an
estiate of what the therm savings claim would have been ha the
worksheets identified the customer as a Schedule 101 gas customer.
h. Please confirm that according to Avista's DSM savings analysis for
ths building, the estimated anual ther usage at ths premise, after
implementation all four gas DSM projects shown at p. 14 of
Confidential Attchment B, would at a minum be equivalent to the
sum of the following four amounts:
i) the total therms shown on p. 17 in the e-Quest "EEM Run
1" for the unit heater replacement,
n) the "proposed" therm usage shown on p. 18 for the ceiling
and wal inulation project,
ni) the "proposed" therm usage shown on p. 19 for the
insulated overhead door, and
iv) the "proposed" therm usage shown in the window
replacement analysis on p. 20.
1. Please clarfy an apparent discrepancy between inormation on p. 14 of
Confdential Attchment B, which indicates the R-value of the ceiling
and wall insulation wil be R-19, and the insulation calculator on p. 18,
which indicates an R-value ofR-21 for ths insulation.
J. Subsequent to a discovery conference held on April 16,2009, Avista
indicated that some of the premises at ths location are being
remodeled into smaler suites. Please explain whether such a remodel
either has or is scheduled to occur at the buildig identified in par (e)
to ths request as receiving the energy effciency improvements, and if
that was known at the tie the DSM savings calculations were
performed. In addition, please provide a quatification and
explantion as to how the therm savings amounts shown on p. 14 of
Confdential Attchment B are applicable to each of the suites located
at the premise identified in response to par (e) of ths request.
k. Please provide gas and electrc biling sumares from Janua 1,
2003 to the present for all meters serving the building in response to
par (e) of ths request as receiving the efficiency improvements. To
the extent there are separate meters serving smaller "suites" at this
premise, please indicate which "suite" the meter serves, and the
StafCPR_011 Attachment B Page 172 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-090314 / UG-090315, UG-060518
Date: July 9,2009
Page 10 of 13
associated therm savings values quatified in response to par (j) of
this request for each "suite".
PC-399 Re: Avista Response to Public Counsel Data Request PC-005
DSM Application 24872
a. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include two W A Schedule 101 projects with 2007 DSM
therm savings of 1 1,405 for a "Shell" DSM project, at p. 24. Please
conf that one of these projects refers to ths DSM Application
24872, and paricularly to what is shown as Option 3 on p. 15 of
Confdential Attchment B.
b. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include two W A Schedule 101 projects with 2007 DSM
therm savings of3,20l for a "HVAC" DSM project, at p. 21. Please
confirm that one of these projects refers to what is shown as Option 2
on p. 15 of Confidential Attchment B. Please confirm the DSM
Application number for ths project is 24601.
c. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include a W A Schedule 101 projects with 2007 DSM
therm savings of 647 for a "Shell" DSM project, at p. 24. Please
confir tht ths project refers to what is shown as Option 4 on p. 15
of Confdential Attchment B. Please provide the DSM Application
number for this project.
d. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include two W A Schedule 101 projects with 2007 DSM
therm savings of 438 for a "Shell" DSM project, at p. 24. Please
confir that one of these projects refers to what is shown as Option 5
on p. 15 of Confdential Attchment B. Please provide the DSM
Application number for ths project.
e. The incentive calculators provided in Confdential Attchment B,
shown at pp. 22-27, and the insulation calculator shown at p. 20 all
indicate that ths customer is a Schedule 111 gas customer. However,
the A vista prepared excel worksheet provided with ths data request
shows ths customer as a Schedule 10 1 gas customer. The biling
history provided in response to PC-005 also shows ths customer as a
Schedule 101 customer. Please explain ths apparent inaccuracy.
f. Please provide an explantion as to whether the therm savings claim
resulting from the DSM measures would be any different if the
incentive calculator worksheet(s) referenced above in par (e) of ths
request had shown ths customer as a Schedule 101 customer? If the
StafCPR_011 Attachment B Page 173 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: July 9, 2009
Page 11 of 13
therm savings amount would have been different, please provide an
estite of what the therm savings claim would have been had the
worksheets identified the customer as a Schedule 101 gas customer.
g. Please conf that accordig to Avista's DSM savings analysis for
ths building, the estimated anual therm usage at ths premise, after
implementation all four gas DSM projects shown at p. 15 of
Confdential Attchment B, would at a minum be equivalent to the
sum of the following four amounts:
i. the tota thers shown on p. 18 in the e-Quest "EEM
Run 1" for the unit heater replacement,
11. the "proposed" therm usage shown on p. 19 for the
ceiling and wall inulation project,
ni. the "proposed" therm usage shown on p. 20 for the
inulated overhead door, and
iv. the "proposed" therm usage shown in the window
rePlacement analysis on p. 21.
h. Subsequent to a discovery conference held on April 16,2009, Avista
indicated tht some of the premses at ths location are being
remodeled into smaller suites. Please explain whether such a remodel
either has or is scheduled to occur at the building identified as
"Building l8EC" as receiving the energy effciency improvements,
and if that was known at the tie the DSM savings calculations were
pedormed. In addition, pleae provide a quatification and
explantion as to how the therm savings amounts shown on p. 15 of
Confidential Attchment B are applicable to each of the suites located
at the premse.
1. Please provide gas and electrc biling sumares from Janua 1,
2003 to the present for all meters serving the building in response to
par (h) of ths request as receiving the efficiency improvements. To
the extent there are separate meters serving smaller "suites" at this
premise, please indicate which "suite" the meter serves, and the
associated therm savings values quantified in response to par (h) of
this request for each "suite".
Staff_PR_011 Attachment B Page 174 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: July 9, 2009
Page 12 of 13
PC-400 Re: Workpapers of Mr. Hirschkorn, Exhibit C-L "DSM Savings
Calculations"
a. Please explain whether A vista entered into Energy Efficiency
Agreements, signed by A vista and the customer, for all ofthe "2006
Completed Commercial/Industrial Project" listed on pp. 11-18 of ths
exhibit. If A vista does not enter into such agreements for all projects
shown in ths portion of the exhbit, please provide an explantion
describing which DSM projects would include such a signed
agreement.
b. Please explai whether A vista entered into Energy Efficiency
Agreements, signed by Avista and the customer, for all of the "2007
Completed Commercial/Industrial Project" listed on pp. 21-33 of ths
exhbit. If A vista does not enter into such agreements for all projects
. shown in ths portion of the exhbit, please provide an explanation
describing which DSM projects would include such a signed
agreement.
c. Please explain whether A vista entered into Energy Effciency
Agreements, signed by A vista and the customer, for all ofthe "2008
Completed Commercial/Industrial Project" listed on pp. 36-39 of ths
exhibit. If A vista does not enter into such agreements for all projects
shown in ths portion of the exhbit, please provide an explanation
describing which DSM projects would include such a signed
agreement.
PC-401 Re: A vista Response to Public Counsel Data Request PC-005
DSM Application 24077
a. Please provide an updated gas billing sumar for the gas meter(s)
serving the premise where the gas DSM efficiency upgrades occured,
from Janua 2003 to the present. If there is more th one gas meter
providing service to the area( s) where the DSM efficiency
improvements were installed for ths customer, please provide an
explantion of the end uses served by each gas meter, a description of
which DSM efficiency improvements were installed at the area served
by the gas meter, and the associated therm savings for each efficiency
improvement.
b. Mr. Hirschkom's Workpapers, Exhibit C-L "DSM Savings
Calculations," include a WA Schedule 101 projects with 2007 DSM
therm savings of 6,500 for an "industrial process" DSM project, at p.
Staff_PR_011 Attachment B Page 175 of 264
To: David Meyer
Re: PC Data Requests Nos. 388 though 402
Docket Nos. UE-090314 / UG-090315, UG-0605 1 8
Date: July 9, 2009
Page 13 of 13
22. Please conf that ths project refers to ths DSM application
24077.
c. Confidential Attchment B, at p. 15, appears to refer to two different
natul gas DSM efficiency improvements for ths customer (EEM 2
and EEM 6). Please expla whether both of these improvements were
installed, and if so, the approximate dates of the DSM intallation as
well as confiration of the estimated therm savings claimed by A vista
for each project.
d. Confidential Attchment A does not provide an amount of incentive
payment for ths project, but does reflect non-incentive costs.
Confdential Attchment Bat p. 4 appea to indicate an incentive
payment was made. Please clarfy whether A vista provided any
incentive payment for gas DSM projects for ths customer, and if so,
the amount provided. If necessar, please update Confdential
Attchment A to PC-005.
e. Confdential Atthment B does not include a signed Effciency
Agreement. Please explain whether a signed Energy Efficiency
Agreement was entere into between A vista and ths customer for
these natu gas effciency improvements. If an Agreement was not
entered into, please explai why tht is the case. If there is a signed
Agreement, please provide a copy of the fial signed Agreement.
f. Confdential Attchment B does not include a DSM Incentive
Calculator for any gas projects for ths customer premise. If any
Incentive Calculators were completed for ths gas DSM project, please
provide copies. If no Incentive Calculators were completed for ths
natu gas DSM project(s), please explai why that is the case.
PC-402 Re: Avista Response to Public Counsel Data Request PC-283
a. Please provide an explanation as well as copies of any and all
analyses, documentation, or calculations supporting the Company's
chage in therms savings claimed for the residential fuce program
in Washigton frm 72 therms to 123 thers in 2008. Please indicate
the date ths chage in claied ther value became effective.
b. Please provide an explanation as well as copies of any and al
analyses, documentation, or calculations supporting the Company's
chage in therms savings claimed for the residential fuce progra
in Washigton from 75 therms to 72 therms in 2005. Please indicate
the date this chage in claimed therm value became effective.
StafCPR_011 Attachment B Page 176 of 264
BEFORE THE WASHINGTON UTILITIES AND TRASPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. 00-090134 and UG-090135
Public Counsel Data Request No. 403
To: Avista
PC-403 Budgetig -
a. Please provide the Company's constrction budget, by month for
the years 2006, 2007, 2008, 2009 and projected 2010.
b. For the historical year, provide the monthy actul expenditues
compared to budgeted expenditues by category of intagibles,
production, transmission, distrbution, and general.
Staff_PR_011 Attachment B Page 177 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
To: Avista
PC-404
PC-40S
PC-406
PC-407
PC-408
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 404 through 417
Proforma Capital Additions 2008
Please restate the 2008 plant, accumulated reserve for depreciation and
accumulated deferred income ta balances to add any new revenue
producing capital additions which the Company removed from the capital
additions for the last quarer of 2008. Show each addition separately and
the source of the amounts from the Company's workpapers PF6i-7.
Proforma Capita Additions 2009
Please provide the same inormtion in the same format in the above
question for the yea 2009.
Proforma Depreciation
Please refer to workpaper PF62 and provide the workpapers or reference
to the workpapers where the anual depreciation expense shown on tht
workapaper was calculated for 2008 and 2009.
Proforma capital additions 2008
a. Please refer to workpaper PF62 and provide the source
documentation for the colum labeled "adjustments" for gross
plant, accumulated depreciation and deferred federal income ta.
b. If no source documentation exists, please describe in detai how
each colum was calculated and provide any supportng
calculations.
Proforma Adjustment Calculation
a. Please refer to workpaper PF63 and provide the source documents
for each of the colums and numbers shown on tht workpaper.
b. If no source documentation exists please describe in detail where
each number was obtaed and provide any supportg
calculations.
StafCPR_011 Attachment B Page 178 of 264
To: David Meyer
Re: PC Data Requests Nos. 404 though 417
Docket Nos. UE-0903l4 & UG-0903l5
Date: July 15, 2009
Page 2 of3
PC-409
PC-410
PC-411
PC-4l2
PC-413
PC-414
PC-415
PC-416
Proforma Adjustment Calculation
Please refer to workpaper PF64
a. provide the source of the DFIT accrued on 2007 total plant and
each of the numbers shown in the fist colum labeled 2008
b. Is this reference to "DFIT accrued on 2007 total plant" incorrectly
labeled? Should it instead be labeled as "2008 total plant"?
Proforma Adjustment Calculation
Please refer to workpaper PF64 and provide the source of each of the
numbers in the colums for 2009 and 2010.
Proforma Adjustment Calculation
Please refer to workpaper PF6s
a. Explai the purose of the workpaper and explain where the
numbers are utilized in the calculation of proforma plant additions.
b. Provide the CIAC associated with the $7,325,180 shown on ths
workpaper.
Capital Additions
Please refer to workpapers PF66 and PF67 and state where the dollar
amounts calculated on these workpapers have been utilized in the
calculation of plant additions.
Proforma Noxon Generation
Provide the contracts or other supportg documents for the gross plant
addition to the Noxon plant of $8,460,000.
Noxon Generation
Provide the basis of the depreciation rate used to calculate the anual
depreciation of $244,494 shown on PF83.
Noxon Plant Addition
Provide the propert tax bil which justifies the 1.5% of gross plant for the
property tax calculation used by the Company on PF82.
Noxon Generation
Provide the basis of the calculation of the accumulated deferred federal
income tax shown on PF83 of $68,251.
StafCPR_011 Attchment B Page 179 of 264
To: David Meyer.
Re: PC Data Requests Nos. 404 though 417
Docket Nos. UE-0903l4 & UG-0903l5
Date: July 15, 2009
Page 3 of3
PC-4l7 Pro Forma Information Servces
Please refer to workpaper PFlO 3 and provide the cost benefit analysis for
each of the progrs or costs which the Company ha requested additional
fuds for. If no cost benefit anysis exists, please so state and state the
basis or provide the documentation which supports each requested cost
mcrease.
Sæff_PR_011 Attachment B Page 180 of 264
BEFORE THE WASHINGTON UTILITIES AN TRASPORTATION
COMMSSION
To: Avista
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 418 through 431
PC-4L8 Incentive Compensation.
Provide the Company's philosophy regarding the establishment of
compensation levels and the inclusion of incentive compensation and
varable pay in rates.
PC-4l9
PC-420
PC-421
PC-422
PC-423
PC-424
Incentive Compensation.
Provide for each of the years 2004 -2008 the established goals (theshold
taget and maximum) and the actul results for each of the goals.
Incentive Compensation.
Identify the tota amount of offcer compensation expensed for each of the
years 2004 - 2008 and identify the total amount included in rates
established for each of the respective years. Provide ths inormtion
separtely for the W A electrc and gas operations.
Incentive Compensation.
Provide for each of the years 2004-2008, the total costs for each of the
varous incentive plans and/or varable pay plan, the amount of expense
for the W A electrc and gas opertions separtely for each plan and the
percentage of target for each plan.
Incentive Compensation.
Provide for each year 2004-2008 the number of employees eligible for
incentive compensation and the number of eligible employees that did not
receive varable pay.
Incentive Compensation.
Provide for each year 2004-2008 the retu on equity achieved before and
after expensing incentive and varable pay (show all calculations) and the
retu on equity allowed for each year as well as any supporting
calculations.
Incentive Compensation.
Provide a copy of all incentive compensation plans for 2007, 2008 and
2009.
StafCPR_011 Attachment B Page 181 of 264
To: David Meyer
Re: PC Data Requests Nos. 418 though 431
Docket Nos. UE-090314 & UG-090315
Date: July 16, 2009
Page 2 of2
PC-425
PC-426
PC-427
PC-428
PC-429
PC-430
PC-43 1
Incentive Compensation.
Identify al studies the Company has where Company employee
compensation was compared to where the compensation in the studies was
adjusted based on regulatory disallowance of base pay and/or incentive
compensation.
Proforma Spokane River Relicensing.
Please refer to page 27, lie 5, of the Direct Testiony Elizabeth M.
Andrews, Exhbit No. _ (EMA- 1 T) and provide the cost included with
ths adjustment for the "CDA Tribe Settlement 4( e) relicensing
conditions...". Provide a detaed explantion of these costs and why they
are included in ths PF adjustment rather th PFI2.
Colstrip Mercury Emissions O&M Costs.
Provide a detailed anlysis of each cost includig supportg invoices
incured in the year 2009 YTD for Colstrp Merur Emission mitigation.
Proforma Colstrp Mercury Emissions O&M Costs.
Provide a breakdown of the 2010 Merur Emissions costs for Colstrp in
the amount of $2,900,000. Provide documentation for each cost including
competitive bids for calcium bromide solution and other chemcal which
wil be used to mitigate mercur emissions.
Proforma O&M Generating Plant Expense.
Please provide the cost benefit analysis, budget justications, project
descriptions, budget approval of projects, contrts and all other
documentation associated with the "major overhaul of Unit NO.4 and No.
3 in 2009 and 2010, respectively" as described in Company Witness
Storro testimony page 23, lies 21-22.
Proforma O&M Generatig Plant Expense.
Please provide the cost benefit analysis, budget justifications, project
descriptions, budget approval of projects, contrcts and all other
documentation associated with the Kette Falls Turbine Overhaul in 2009.
Accounts Receivable Sold, Re: Avista's Response to Public Counsel
Data Request No. 037. Provide a copy of the Receivables Purchase
Agreement and the March 31, 2009 amendment.
Staff_PR_011 Attachment B Page 182 of 264
BEFORE THE WASHINGTON UTILITIES AND TRNSPORTATION
COMMSSION
To: Avista
PC-432
PC-433
PC-434
PC-435
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 432 through 436
Pensions
Please refer to the Direct Testiony of Elizabeth M. Andrews, page 32,
lines 17 and 18, where she states "Due to the timing of ths report,
additional inormation may become known durg the course of ths
proceeding tht may require modification to ths adjustment."
a. Please provide a detailed description of what information may
become available.
b. Provide copies of any information which the Company has thus far
received, either formlly, or inormally from its actu or any
other pary which might impact the Company's pension expense.
c. Provide a calculation of the pension expense based on the curent
market value of the Company's pension assets.
Pensions
Please provide the quarerly performance and complaints report of the
asset plan as mentioned in the Direct Testimony of Mark T. Thies, page
33, line 18. Provide the quaerly report for the quaers endig
December 31, 2008; March 31,2009; June 30, 2009; and any other report
tht the Company has regarding the performance of the Company's plant
assets.
Pensions
Please refer to the Direct Testiony of Mark T. Thies, page 36 and
provide, by yea, the amount of pension expense allowed in rates for each
of the years shown, 1992 though 2008.
Medical Insurance Expense
Provide the studies, actuaral anysis or any other documentation which
supports the Company's request for a total medical insurance expense of
$17.9 milion as referred to in Direct Testimony of Elizabeth M. Andrews,
page 33, line 21.
StafCPR_011 Attachment B Page 183 of 264
To: David Meyer
Re: PC Data Requests Nos. 432 thugh 436
Docket Nos. UE-090314 & UG-0903l5
Date: July 17, 2009
Page 2 of2
a. Provide the amount tht an employee co-pays by year from 2003
though 2008 and yea-to-date 2009.
b. Provide the Company's policy regarding employee co-pays.
PC-436 Medical Insurance Expense
By year, show the Company's self-fuded plan accrus as shown on its
balance sheets for the years 2004 though 2008 and year-to-date 2009.
StafCPR_011 Attachment B Page 184 of 264
BEFORE THE WASHINGTON UTILITIES AND TRSPORTATION
COMMISSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 437 through 441
To: Avista
PC-437 RE: Avista Response to DR PC-005, DSM Application 26036
a. Please describe the natue of the therostat modifications installed and
a description of the intended efficiency gais.
b. Please clarfy the number of premses affected by this DSM project.
c. If additional premises are affected by ths project, in addition to that
shown in the biling history provided at p. 1 of Confdential
Attchment B, please provide such billig histories for all premises
served by the thermostats modified as par of this DSM project, from
Januar 200S to the present.
d. Please explain why the project is characterized as "Rooftop Service" in
Mr. Hirschkom's workpapers at Exhibit C-l, p. 24 and at p. 8 of
Confidential Attchment B, if ths was a thermostat modification.
PC-438 RE: Avista Response to DR PC-005, DSM Application 26022
a. Please describe the natue of the thermostat modifications installed and
a description of the intended efficiency gains.
b. Please clarfy the number of premises affected by this DSM project.
Confdential Attchment B at p. 8 indicates that 2 thermostats were
modified, resulting in differig therm savings. Billig histories were
provided for 3 premises, at pp. 2-4 of Confdential Attchment B.
Please clearly indicate the number of premises affected by ths project,
and for each premise, indicate which thermostat on p. 8 they are served
by, and the anticipated therm savings attbutable to each premise as a
result of ths DSM project.
c. If additional premises are affected by this project, in addition to those
shown in the biling histories provided at pp. 2-4 of Confidential
Attchment B, please provide such biling histories for all premises
served by the thermostats modified as par of ths DSM project, from
Januar 200S to the present.
d. Please explain why the customer naes shown on the biling histories
at pp. 3-4 of Confdential Attchment B are different th the customer
name shown on Confdential Attachment A for ths DSM project.
StafCPR_011 Attachment B Page 185 of 264
To: David Meyer
Re: PC Data Requests Nos. 437 though 441
Docket Nos. UE-090314 I UG-0903 1 S, UG-060S 1 8
Date: July 17, 2009
Page 2 of4
e. Please explain why the project is characterized as "Rooftop Service" in
Mr. Hirschkom's workpapers at Exhibit C-l, p. 24 and at p. 8 of
Confdential Attchment B, if ths was a thermostat modification.
PC-439 RE: Avista Response to DR PC-005, DSM Application 26236
a. Please describe the natue of the thermostat modifications intalled and
a description of the intended effciency gai.
b. Please clarfy the number of premses affected by ths DSM project.
Confdential Attchment B at p. 8 indicates that 6 thermostats were
modified, resulting in differig therm savings. Billig history was
provided for 1 premse, at p. S of Confidential Atthment B. Please
clearly indicate the number of premises affected by ths project, and
for each premise, indicate which therostat on p. 8 they are served by,
and the anticipated therm savigs attbutable to each premse as a
result of ths DSM project.
c. If additiona premses are affected by ths project, in addition to those
shown in the biling histories provided at p. S of Confdential
Attchment B, please provide such bilg histories for all premises
served by the thermostats modified as par of ths DSM project, from
Janua 200S to the present.
d. Please explain why the project is characterized as "Rooftop Service" in
Mr. Hirschkom's workpapers at Exhibit C-l, p. 24 and at p. 8 of
Confdential Attchment B, if ths was a thermostat modification.
PC-440 RE: Avista Response to DR PC-005, DSM Application 26220
a. Please describe the natue of the thermostat modifications intalled and
a description of the intended effciency gains.
b. Please clarfy the number of premises affected by this DSM proj ect.
Confdential Attchment B at p. 8 indicates that 4 thermostats were
modified, resulting in differig therm savings. Billig history was
provided for 2 premses, at p. 6-7 of Confdential Attchment B.
Please clearly indicate the number of premises affected by ths project,
and for each premise, indicate which thermostat on p. 8 they are served
by, and the anticipated therm savings attbutable to each premise as a
result of ths DSM project.
c. If additional premises are affected by ths project, in addition to those
shown in the biling histories provided at pp. 6-7 of Confdential
Attchment B, please provide such bilg histories for all premises
served by the thermostats modified as part of ths DSM project, from
StafCPR_011 Attachment B Page 186 of 264
To: David Meyer
Re: PC Data Requests Nos. 437 though 441
Docket Nos. UE-090314 / UG-09031S, UG-060S 1 8
Date: July 17,2009
Page 3 of4
PC-441
Januar 200S to the present. If only the two premises shown in the
biling histories at pp. 6-7 are served by ths DSM project, please
provide updated billing histories for these premises from Janua 200S
to the present.
d. To the extent not clarfied in response to earlier par of ths request,
please explain why the address for ths DSM project shown at p. 8 of
Confdential Attchment B is slightly different than those shown in the
biling histories at pp. 6-7.
e. Please explain why the biling history at p. 7 indicates service was
open in 2007, but usage is shown for 2007.
f. The biling history shown at p. 6 indicates ths customer is a Schedule
1 1 1 gas customer and has been for several year. Please explain why
this DSM project would be categorized as a 'Schedule 101' project in
Mr. Hirchkom's workpapers exhibit C-L at p. 24. In addition, to the
extent not answered elsewhere in response to ths request, please
clarfy the therm savings attbutable to the thermostat serving ths
premise. If the thermostat serves multiple premises, please
approximate the therm savings attbutable to this premise.
g. Please explain why the project is characterized as "Rooftop Service" in
Mr. Hirschkom's workpapers at Exhibit C-l, p. 24 and at p. 8 of
Confdential Attchment B, if ths was a thermostat modification.
Re: Avista Response to Public Counsel DR PC-283
For each of the explanations shown in colum K of the excel spreadsheet
provided in Attachment A, titled, "Revisions to Savings (f)", please
provide the following:
a. DSM Program or measure nae.
b. An explanation of the change in claimed therm savings for the
program or measure (clearly explain previous method and new
method)
c. An explantion of the inormation and analysis A vista relied upon to
support the change.
d. Date the change in claimed progr or measure therm savings became
effective.
e. Copies of any and all analyses, evaluations, reports, documentation, or
calculations supporting the Company's change in therms savings,
includig but not limted to materials referenced in response to par (c)
of ths request. If any of the materials provided in response to ths
Staff_PR_011 Attachment B Page 187 of 264
To: David Meyer
Re: PC Data Requests Nos. 437 though 441
Docket Nos. UE-090314 I UG-0903 1 5, UG-060518
Date: July 17, 2009
Page 4 of4
request were not prepared by A vista, please identify who prepared the
document(s) and for whom they were prepared.
f. For those DSM progrs or measures that provide an incentive and/or
therm savings on a squae foot basis, please provide an explantion as
to exactly how the incentive amount is calculated and/or the therm
savigs amount is calculated. Please also provide an example of each.
g. Copies of any materals provided to the Commssion regardig the
chage in progr or measure claied ther savings, and if
appropriate, the docket number in which such materials were
submitted.
h. Copies of any materials provided to Avista's Triple-E board regarding
the chage in program or measure claimed therm savings, and the date
those materials were provided to the Triple E. If materials were
provided as par of a presentation or report, please provide the
complete copy of any presentation or report and a citation to relevant
sections discussing the change in claied therm savings.
StafCPR_011 Attachment B Page 188 of 264
BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION
COMMSSION
To: Avista
PC-442
PC-443
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 442 through 443
Ref: Avista's response to Request No. PC-278(b) (New Customer
Adjustment). According to the response, "Otherwise, if new customer
usage is not excluded, additional margin wil be included without
associated additional/incremental costs resulting in an improper
comparison." Please respond to the following:
a) State with specificity each tye of "additional/incremental" cost
that is being referenced.
b) Provide calculations, workpapers, references into prefied data and
all other information supportve of the notion that such
"additional/incremental" costs exist and provide quantification of
all such costs in the test year.
c) Provide calculations estiating the amount of
"additional/incremental" rate base investment cost that is incurred
by A vista in serving a tyical new residential customer with a
newly developed area tht was not previously served by A vista.
d) Provide calculations estiating the amount of
"additional/incremental" rate base investment cost (if any) that is
incured by A vista in serving a typical new residential customer
with an area already being served by A vista (assume inll
development adjacent to an existing main).
e) Provide calculations estimating the amount of
"additional/incremental" annual expense that is incured by Avista
in serving a tyical new residential customer under the
assumptions stated in pars (c) and (d), above.
f) Provide all available statistical data indicatig the approxiate
percentage of new residential customers added in each of the years
2006, 2007 and 2008 with inll development where new mai
constrction is not requied, versus new area development where
new mains investment was required.
Ref: Avista's response to Request No. PC-309(c) (New Customer
Adjustment). According to the response, "A decoupling mechanism that
includes the margi from new customers without acknowledgement of the
associated additional/incremental costs would be inappropriate." Please
respond to the following:
StafCPR_011 Attachment B Page 189 of 264
To: David Meyer
Re: PC Data Requests Nos. 442 thugh 443
Docket Nos. UE-090314 & UG-0903l5
Date: July 20, 2009
Page 2 of2
a) State with specificity each tye of "additional/incremental" cost
tht is being referenced.
b) Provide calculations, workpaper, references into prefied data and
all other inormation supportve of the asserted
"additional/incremental costs" that A vista claims should be
"acknowledged" .
c) Provide complete copies of all studies, reports, workpapers,
anlyses, projections and other documents relied upon by Avista to
conclude tht any of its rate base investments or operatig and
maintenace expenses var directly as a result of adding new
customers.
StafCPR_011 Attachment B Page 190 of 264
BEFORE THE WASHINGTON UTILITIES AN TRASPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel and The Energy Project Data Requests Nos. 444 through 451
Corrected Nos. 450 and 451
To: Avista
PC-444
PC-445
PC-446
PC-447
PC-448
Re: Rate Schedule 91. Please provide a test year Revenue Proof by rate
schedule (e.g., Schedule 1, 11 & 12,21 & 22, etc.) showing revenues
booked separately for the DSM portion and LIRA portions of Schedule
91. In ths response, please provide in suffcient detail to show any
chages in rates for Schedule 91 durng the test year. Explain any
varance between the proof of revenues and revenues (or adjustments) for
Schedule 91 in the rate fiing.
Re: Rate Schedule 191. Please provide a test year Revenue Proof by rate
schedule (e.g., Schedule 101, 111 & 112, 121 & 122, etc.) showing
revenues booked separately for the DSM porton and LIR portons of
Schedule 191. In ths response, please provide in sufficient deta to show
any changes in rates for Schedule 191 durg the test year. Explain any
varance between the proof of revenues and revenues (or adjustments) for
Schedule 91 in the rate filing.
Please provide a detailed itemization of test year expenditues associated
with costs incured for electrc DSM services and LIR Programs.
Please provide in sufficient detail to identify the specific progr and
payee as available. In ths response, please provide test year beging
and ending balances separtely for DSM and LIR programs
(categories), and explain any varance with the test year expense
adjustment in the rate filing.
Please provide a detailed itemization of test year expenditues associated
with cost incured for natu gas DSM services and LIR Programs.
Please provide in suffcient detail to identify the specific program and
payee as available. In this response, please provide test year begig
and endig balances separately for DSM and LIR progrs
(categories), and explain any varance wit the test year expense adjustment
in the rate filing.
Please provide a copy of all revisions to and tariff sheets for, Schedule 91
subsequent to July 1, 2002.
StafCPR_011 Attachment B Page 191 of 264
To: David Meyer
Re: PC Data Requests Nos. 444 though 551
Docket Nos. UE-090314 & UG-0903l5
Date: July 20, 2009
Page 2 of2
PC-449 Please provide a copy of all revisions to and tarff sheets for, Schedule
191 since this Schedule's inception.
PC-450 Please provide tota anual dollar amount of revenues collected by rate
schedule and total Washigton for calenda year 2007 and 2008 for the
following:
(a) Schedule 91; and,
(b) Schedule 191.
PC-45 1 Please provide tota anual amount of expenditues for costs associated
with DSM and LIR (separtely) for calendar year 2007 and 2008
associated with:
(a) electrc (Schedule 91); and,
(b) natual gas (Schedule 191).
StafCPR_011 Attachment B Page 192 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMISSION
To: Avista
PC-452
PC-453
PC-454
PC-455
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 452 through 456
Refer to the response to PC -31 1. Identify the amounts allocated to the
WA electrc and gas operations for each of the years 2004 though 2008.
If no costs were allocated to the W A electrc and gas operations, please
explain why not and why the Company has allocated costs to the W A
operations in the curent test year.
Refer to the response to PC-3l2.
a. Provide comparable inormation for each of the months subsequent
to the test year through the most rent month available.
b. Please provide a more detailed explanation of what the "expene
for utility offce buildigs and serice centers" is comprised of.
c. Explain why the amounts for the months Januar though March of
2008 are signficantly higher than the other months shown.
d. Provide an itemization with descriptions of all amounts over
$10,000 for each of the months in the test year.
Refer to the response to PC-052, Provide the monthy amounts of "all
other trouble O&M" for Janua 2009 though the most recent month
available. Provide ths inormation on a total system and W A electrc
jursdictional basis.
Refer to the response to PC-20l(d). Identify the amount of the different
ta credit the Company has elected to use, including all supporting
calculations.
Staff_PR_011 Attachment B Page 193 of 264
To: David Meyer
Re: PC Data Requests Nos. 452 though 456
Docket Nos. UE-0903l4 & UG-090315
Date: July 21, 2009
Page 2 of2
PC-456 Refer to the Company's response to PC-322.
a. Provide the Company's justification for utilizing an 6% ination
rate for existig costs.
b. Provide a detailed description of each ofthe progrs identified in
ths response (i.e., Circuit Switcher Maintenance and Replacement,
Network Handhold and Manole Inpections, etc.)
c. For each progr staed in 2009, explain how the Company
previously addressed these matters. If no program previously
existed, explain the need for creatig it.
d. Provide 2009 expenes incured to date in a simar format as
Attchment A.
e. For each applicable enhanced progr specify the additional
inspection requirements beyond what was previously done.
StafCPR_011 Attachment B Page 194 of 264
BEFORE TH WASHINGTON UTILITIES AN TRANSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 457 through 469
To: Avista
PC-457 EEl Dues.
Has the Company removed any portion of EEl dues associated with
lobbyig, advertsing, marketing? If, so identify the amount and account
number.
PC-458 AGADues.
Has the Company removed any portion of AGA dues associated with
lobbyig, advertising, marketig? If, so identify the amount and account
number.
PC-459 Other Revenues.
a. Please provide the amount of "Other Revenues" by subaccount
included in the test year on a tota system basis and any amounts
allocated to the W A electrc and gas operations.
b. Provide similar historical information for each of the years 2004
though 2008.
PC-460 Legal expenses.
a. Identify the amount of legal expenses included in the test year by
vendor. Provide ths on a total system basis as well as any
amounts allocated to the W A electrc and gas operations.
b. Provide similar historical inormation for each of the years 2004
though 2008.
PC-46 1 Pole inspections.
Refer to the Avista's Response to Public Counsel's Data Request No.
313.
a. Identify separately the total number of distrbution and
transmission poles.
b. Explain the signficant increase in pole inspections in recent years.
StafCPR_011 Attachment B Page 195 of 264
To: David Meyer
Re: PC Data Requests Nos. 457 thugh 469
Docket Nos. UE-0903l4 & UG-0903l5
Date: July 21, 2009
Page 2 of4
PC-462
PC-463
PC-464
O&M Plant Expense.
Refer to PF16 3.
Provide in a simlar formt, production & genertion O&M plant expense
for each of the year 2004 though 2008.
Office Supplies.
Refer to the Attachment provided in Avista's Response to Public
Counsel's Data Request No. 033.
Provide an of explantion of what the explantion the US Ban Analysis
Fees in the amount of$193,720 relates and how it relates to the provision
of electrc or gas utility service.
Re: Pension expense.
Please refer to PF 17(3), specificaly for the projected 2009 pension
expense of $22,200,000.
Please provide all inormation and correspondence received from the
Company's actuarial firm showing, in detail, how the amount was derived.
Also include with the response a copy of all intrctions and inormation
provided by the Company to its actual fi regarding the selection of
the actual assumptions to use in estiatig 2009 expense. Also provide
a detailed description of any verbal instrctions and directives given by
the Company to the actual fi with regards to determing the
projected 2009 pension expense.
StafCPR_011 Attachment B Page 196 of 264
To: David Meyer
Re: PC Data Requests Nos. 457 though 469
Docket Nos. UE-090314 & UG-0903l5
Date: July 21, 2009
Page 3 of4
PC-465 Re: Pension expense.
Refer to the Avista;s Response to WUTC Staff Data Request No. 031,
subpart (a).
According to the response to subpart a, the 2009 estimate of the net
periodic pension cost was determined using an expected return on assets
based on the minium required contrbutions durg the fiscal year.
a. Please identify specifically what contrbutions were used in
projecting the amounts.
b. Please provide a revised 2009 net periodic pension cost estiate,
with the same level of detail as the response to subpart a, based on
the actual contrbutions made in 2008 and the Company's curent
best estiate of the contrbutions to be made in 2009. Identify
specifically what the curent best estiate of the contrbutions, by
quaer, for 2009.
c. Please provide a reconciliation of the 2009 estimated net perodic
pension cost in the response to $22,525,999 with the $22,200,000
shown on PFI7(3) ofthe Company's filing as the pension expense
for 2009.
PC-466 Re: Pensions
Please refer to Exhibit No._(MTT -1 T), page 34, lines 20 - 22.
Please provide all inormation and correspondence received from the
Company's actuarial firm showing, in detail, how the projected amount of
pension fuding for 2009 of $42 millon to a curent estimate of $67
million was derived. Also include with the response a copy of all
instrctions and inormation provided by the Company to its actuaral fi
regardig the selection of the actuaral assumptions to use in estiating
2009 expense. Also provide a detailed description of any verbal
instrctions and directives given by the Company to the actual firm
with regards to determing the projected 2009 pension expense. If not
evident from the inormation being provided, show, in detail, how the $42
milion to $67 millon fuding estiates identified in the testiony were
derived and indicate who the projections were prepared by.
StafLPR_011 Attachment B Page 197 of 264
To: David Meyer
Re: PC Data Requests Nos. 457 though 469
Docket Nos. UE-0903l4 & UG-0903l5
Date: July 21, 2009
Page 4 of4
PC-467 Re: Pension
Please provide the actul retu on plan assets experienced for the
Company's pension plan for 2009 year to date and describe, in detail, any
impacts the actu retu on assets ha on the company's projected 2009
cash contrbutions.
PC-468 Re: Pension
Please refer to Exhibit No._(MTT-1T), page 34, lines 3 - 22.
a. In derving the projected fudig for 2009 identified on lies 21
and 22, please specify whether or not the projection is tied to the
94% fudig level identified on lines 5 - 6.
b. Does the Company agree tht under the Pension Protection Act it
does not have to reach the 94% fudig level in 2009 but can add
the deficit between 80% and 94% fudig level to contrbutions
over the next seven year? If no, pleae explai in detail, why not.
c. Does the Company agree tht if the pension plan assets ear a
higher retu in 2009 than it projected in deriving the estiated
2009 contrbutions that the level of contrbutions necessar to
achieve an 80% to 94% fuding level would decline? If no, please
explai.
d. Please provide the amount of cash contrbutions the Company
projects it would have to make to the pension plan in 2009 in order
to achieve an 80% fudig leveL.
e. Please provide the Company's current best estimate of the
mium pension fudig requiements for 2009 under the ERISA
requiements.
PC-469 Re: Pensions.
Please refer to Exhibit No._(MTT-1T), page 37, lines 6 through page
39, line 7.
Please identify any other utilities which are allowed under a Commssion
order a balancing account for the dollar differences between cash
payments and pension expense as requested by the Company. Provide a
citation to the respective Commssion order and a copy of the section of
the order authoriing the balancing account treatment.
StfCPR_011 Attachment B Page 198 of 264
BEFORE THE WASHINGTON UTILITIES AN TRANSPORTATION
COMMSSION
AVISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 470
To: Avista
PC-470 Rerun the Dispatch Model exactly as was done in Avista's Response to
Staffs Data Request No. 49, except for using gas prices computed as of
July 24, 2009 consistent with the gas pricing methodology used in the
Company's filing. In providing these results of the Dispatch Model:
a. State the average Stafield gas price used in the simulations.
b. Provide two separate Attchments comparble to the Attchment A
provided in Avista's Response to Staffs Data Request No. 49, one
showing estiated power supply costs assuming the Lancaster
PPA is par of Avista's portfolio (labeled as "AVA Portfolio With
Lancaster" in Staff DR 49 Attchment A) and one showing
estiated power supply costs assuming the Lancaster PP A is not
part of Avista's portfolio (labeled as "Avista Portfolio" in Avista's
Response to Staffs Data Request No. 49 Attchment A).
StafCPR_011 Attachment B Page 199 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel And ICN Data Requests Nos. 471 through 477
To: Avista
PC-471 The Section on Corporate Governance Matters of Avista Corporation's
Form DEF 14A dated March 24,2009, indicates tht the board held eight
meetings in 2008. Avista's Response to Public Counsel's Data Request
No. 327 provided the Febru, May and August board meeting minutes
for 2008. Please provide copies of the November 14, 2008, and June 17,
2008 meetig miutes as well as any other 2008 meetig miutes.
PC-472 Are any costs related to the purhase of the Cadence Network by
Advantage IQ allocated or included in the test year? If so please state the
amount.and account number and indicate whether they are charged to the
electrc or gas operations.
PC-473 Refer to Attchment Al (Detail Pivot) provided in Avista's Response to
Public Counsel's Data Requests Nos. 133. For each of the following
items, provide a description of what the cost relates to as well as the
vendor.
FERC ACCOUN 908
200712 # NA 65,535.70
200801 #NA 53,375.54
200802 #NA 70,218.32
200804 #NA 56,247.75
200806 #NA 54,457.39
StafCPR_011 Attachment B Page 200 of 264
To: David Meyer
Re: PC Data Requests Nos. 471 through 477
Docket Nos. UE-0903l4 & UG-090315
Date: July 23,2009
Pagelof2
PC-474
PC-475
PC-476
PC-477
Refer to Attachment B (Detail Pivot) provided in Avista's Response to
Public Counsel's Data Request No. 133. For each of the following items,
provide a description of what the cost relates to as well as the vendor.
FERC ACCOUNT 909
200806 #NA 10,868.54
200808 #NA 10,688.77
Refer to Attachment C (Detail Pivot) provided in A vista's Response to
Public Counsel's Data Request No. 133. For each of the following items,
provide a description of what the cost relates to as well as the vendor.
FERC ACCOUNT 912
200712 #NA 58,852.07
200804 #NA 60,592.54
Refer to Attachment E (Detail Pivot) provided in Avista's Response to
Public Counsel's Data Request No. 133. For each of the following item,
provide a description of what the cost relates to as well as the vendor.
FERC ACCOUN 921
200805 #NA 37,934.63
Refer to Attachment G (Detail Pivot) provided in Avista's Response to
Public Counsel's Data Request No. 133. For each of the following item,
provide a description of what the cost relates to.
FERC ACCOUN 930
200805 Kom Ferr International (3rd instalment) $56,072
Staff_PR_011 Attachment B Page 201 of 264
To: Avista
BEFORE THE WASHINGTON UTITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. 00-090134 and UG-090135
Public Counsel Data Requests Nos. 478 through 483
PC-478 Refer to Avista's Response to Public Counsel's Data Request No. 210.
Provide a tral balance in a simar format for the month ended September
30,2007
PC-479
PC-480
PC-481
PC-482
Refer to Andrews' workpaper 0 3
Wht does the Jursdictional Code "AS" stad for?
Provide the injures and daages reserve monthy balance for each of the
months September 2007 though September 2008. Separately identify the
amounts alocated to the W A electrc and gas operations as well as the
allocation factors used.
EEl Dues
Refer to Avista's Response to Public Counsel's Data Request No. 022,
Attchment A pages 2 and 4 (Detail Pivot); Avista's Response to Public
Counel's Data Request No. 334, Attchment A; and Avista's Response to
Public Counel'sData Request No. 336.
The EEI Dues invoice provided in Avista's Response to Public Counsel's
Data Request No. 336 show 2008 dues of$27l,020 ($263,520 and
$7,500).
In Avista's Response to Public Counsel's Data Request No. 022,
Attchment A, it appears that $55,313 was chaged to Acct 426400 and
amounts of $203,207 and $7,500 were charged to accounts 930200 and
570000 respectively. Avista's Response to Public Counsel's Data
Request No. 334, Attachment A, shows $153,728 was charged to utility
operations. Please identify what accounts the remaing amount of EEl
dues were chaged to.
Refer to Avista's Response to Public Counsel's Data Request No. 332.
Provide a copy of the Company's policy describing the criteria for grantig
rewards under the Pacesetter Award Program.
StaftPR_011 Attachment B Page 202 of 264
To: David Meyer
Re: PC Data Requests Nos. 478 though 483
Docket Nos. UE-090314 & UG-0903l5
Date: July 29, 2009
Page 2 of2
PC-483 Provide the production plant balance for 2008 used in the Aurra Model
and the corresponding depreciation and propert tax balances. Provide the
same information for 2009.
StafCPR_011 Attachment B Page 203 of 264
BEFORE TH WASmNGTON UTILITIES AN TRSPORTATION COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 484 through 491
To: Avista
PC..484 RE: Avista's Response to Public Counsel's Data Request No. 283 and Data
Request No. 402 and Mr. Hirschkorn's Workpapers, 2008 DSM Verification
Report.
Please clarfy the savings estimates for the window replacement gas DSM program,
from 2006 though 2008.
Avista's Response to Public Counsel's Data Request No. 283 does not indicate that
any chages were made affectig the therm savings estiates from ths progr. The
2008 DSM Verification Report, at p. 43, shows the ther savings as being .83 per sq
ft. for 2006 though 2008. (M. Hirchkom's workpapers, at p. E-625)
However, Attachment A to Avista's Response to Public Counsel's Data Request No.
402 appears to indicate tht the savings estiate for replacement windows is 1.24
therms per sq. ft.
a. Please provide clarfication as to the savings estiated by A vista per sq foot
of replacement windows for each year, 2006 though 2008.
b. If Avista's savings estimate has changed during the period January 1,2006
though December 31, 2008, please provide the date the chage became
effective.
c. If the response to (b) above is affirative, and A vista has adjusted its savings
estimate for ths progr, please provide copies of any and all analyses,
evaluations, reports, documentation, or calculations supportg the Company's
chage in therms savings. If any of the materials provided in response to this
request were not prepared by A vista, please identify who prepared the
document(s) and for whom they were prepared.
d. Please provide an explantion as to exactly how the incentive amount is
calculated and the therm savings amount is calculated for ths progr.
Please also provide an example of an incentive and therm savings calculation.
StafCPR_011 Attachment B Page 204 of 264
To: David Meyer
Re: PC Data Requests Nos. 484 though 491
Docket Nos. UE-0903 14 I UG-0903 15, UG-0605 1 8
Date: July 29,2009
Page 2 of4
e. If the response to (b) above is affiative, and A vista has adjusted its savings
estiate for ths progr, please provide copies of any materials provided to
the Commission regarding the change in progr or measure claimed therm
savings, and if appropriate, the docket number in which such materals were
submitted.
f. If the response to (b) above is affirative, and A vista has adjusted its savings
estimate for ths progr, please provide copies of any materals provided to
Avista's Triple-E board regarding the change in program or measure claimed
therm savings, and the date those materials were provided to the Triple E. If
materials were provided as par of a presentation or report, please provide the
complete copy of any presentation or report, and a citation to relevant sections
discussing the change in claimed ther savings.
PC-485 Re: Avista's Response to Public Counsel's Data Request No. 283, Gas
Replacement Window DSM Program.
Avista's response to this data request indicates that from 2006 to 2008, partcipation in
ths program increased approximately two-fold (711 parcipants in 2006 to 1,591
parcipants in 2008), but reported therm savings durg ths period increased
approximately five-fold (29,191 therms in 2006 vs. 149,429 therms in 2008).
Please provide an explanation identifyg any and all factors tht A vista believes
would contrbute to ths disproportionate increase in therm savings compared to the
increase in paricipation levels from 2006 to 2008.
PC-486 Re: Avista's Response to Public Counsel's Data Request No. 283, Attachment A-
Oregon.
Attchment A to this response indicates that the therm savings estimate for Avista's
high efficient gas fuace program in Oregon was reduced from 90 therms to 70
therms based on the following: "Adjusted savings claims therms based on ETO's
measurement and evaluation"
Please provide a full and complete copy of the 'measurement and evaluation' by ETO
that is referenced in the response, including the fil report or anysis provided to
Avista.
StafCPR_011 Attchment B Page 205 of 264
To: David Meyer
Re: PC Data Requests Nos. 484 though 491
Docket Nos. UE-090314 / UG-090315, UG-0605 1 8
Date: July 29,2009
Page 3 of4
PC-487 Re: Avista's Response to Public Counsel's Data Request No. 283, Attachment A-
Oregon.
Atthment A to ths response indicates tht Oregon ha a state mandated
weatherization program and fuer indicates these are: "site specific, shell measures
only. Therm savings and incentive based on a site specific energy analysis."
Please provide any and all documents, memos, reports, or explanations that describe
the basis upon which the incentive amount and therm savings amounts are calculated
for these progrs.
PC-488 Re: Avista's Reponse to Public Counsel's Data Request No. 402.
Please provide any and all anysis, memos, or reports conducted by or on behalf of
A vista from 2005 to the present examining the proporton of progr participants in
Avista's high effcient gas fuace rebate program who purchase a furnace with an
efficiency level greater th 90% (e.g. 95%), as compared to the proporton
purchasing a 90% effcient fuaces purchased by parcipants. Please indicate
whether such analysis applies to Avista's Washington, Idaho, or Oregon service
terrtory.
PC-489 Re: Avista's Response to Public Counsel's Data Request No. 283, Attachment A.
a. Please conf tht ths excel spreadsheet represents a duplicated count of
program paricipants in Avista's DSM programs. That is, a customer
parcipatig in both the window replacement and fuace program would
appea in both sections of ths spreadsheet.
b. Please provide any inormation or anlysis the company has regarding the
unduplicated count of customers participating in A vista's gas DSM programs
in Washigton and Idao for each year, from 2006 though 2008. In addition,
for those customers paricipatig in more than one gas DSM program with
the same calendar year, please provide any and all inormation or analysis the
company has regardig which progrs such customers are most likely to
paricipate in.
Staff_PR_011 Attachment B Page 206 of 264
To: David Meyer
Re: PC Data Requests Nos. 484 though 491
Docket Nos. UE-0903l4 / UG-090315, UG-060518
Date: July 29,2009
Page 4 of4
PC-490 Re: Avista's Response to Public Counsel's Data Request No. 283, Attachment A.
With respect to the following entr in Avista's Response to Public Counsel's Data Request No.
283, Attchment A, row 14713:
RE9 GINS - CEIL/ATTIC 213 10,837 426 WA 2008
a. Please clarfy whether the therm savings estimate of 10,837 therms for ths ceiling insulation
program was correctly reported by A vista.
b. If the therm savings estiate of 10,837 is correct, please explain why it is so large in
comparson to other progra paricipants. In addition, please explain why the therm savings is
so large in comparson to the total project cost and the amount of incentive, as compared to
other progr parcipants.
c. If ths savings level is incorrect, please provide an explanation as to whether savings of
10,837 thers for ths program paricipant was included in the 133,253 reported Washigton
savings for the Insulation programs, as reported in Table H3-E of the Decoupling Evaluation?
d. If ths savings level is incorrect, please provide an explanation as to whether savings of
10,837 therms for ths program paricipant was included in the 153,026 verified Washigton
savings for the Insulation programs, as reported in Table H3-E of the Decoupling Evaluation?
PC-49L Re: Avista's Response to Public Counsel's Data Request No. 283, Attachment A.
The excel spreadsheet provided as Attchment A to ths response includes several
dashes (-), paricularly in the column labeled "project cost." Please provide an
explanation as to how these notations should be interpreted. In addition, if a dash ( -)
appears in the "project cost" column, please indicate whether therm and/or kwh
savings were neverteless stil reported by Avista for such projects.
StafCPR_011 Attachment B Page 207 of 264
BEFORE THE WASIDNGTON UTILITIES AN TRASPORTATION COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Request No. 492
To: Avista
PC-492 Re: Avista's Response to Public Counsel's Data Request No. 283, New Window
DSM Program, Attachment A.
Avista's response to this data request indicates that from 2006 to 2008, participation in
ths program by Washigton customers decreased by approximately 30% (88
parcipants in 2006 to 6 I parcipants in 2008), but reported therm savings durg ths
period increased approximately 77% (3,767 therms in 2006 vs. 6,783 therms in 2008).
a) Please provide an explantion identifyg any and all factors tht
A vista believes would contrbute to ths disproportonate increase in
therm savings compared to the decrease in partcipation levels from
2006 to 2008.
b) Please clarfy whether the savings estiated by A vista for ths measure,
for each year 2006 though 2008, is 0.42 therms per sq foot, as shown
in the 2008 DSM Verification Report, at p. 43.
c) If A vista has adjusted the savings estiate for ths progrm durg the
period 2006 to 2008, please provide copies of any and all anlyses,
evaluations, reports, documentation, or calculations supportg the
Company's change in therms savings. If any of the materials provided
in response to ths request were not prepared by A vista please identify
who prepared the document( s) and for whom they were prepared.
d) If A vista has adjusted the savings estiate for this program durg the
period 2006 to 2008, please provide copies of any and all materials
provided to the Commission regarding the chage, as well as
documents provided to the Triple E.
StafCPR_011 Attachment B Page 208 of 264
BEFORE THE WASHINGTON UTILITIES AN TRASPORTATION COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135,UG-060518
Public Counsel Data Request No. 492
To: Avista
PC-492 Re: Avista's Response to Public Counsel's Data Request No. 283, New Window
DSM Program, Attachment A.
Avista's response to this data request indicates that from 2006 to 2008, participation in
ths program by Washigton customers decreased by approximately 30% (88
paricipants in 2006 to 61 parcipants in 2008), but reported therm savings durg ths
period increased approximately 77% (3,767 therms in 2006 vs. 6,783 thers in 2008).
a) Please provide an explanation identifyg any and all factors that
A vista believes would contrbute to ths disproportonate increase in
therm savings compared to the decrease in partcipation levels from
2006 to 2008.
b) Please clarfy whether the savings estimated by A vista for ths measure,
for each year 2006 though 2008, is 0.42 therms per sq foot, as shown
in the 2008 DSM Verification Report, at p. 43.
c) If A vista has adjusted the savings estimate for ths progr durg the
period 2006 to 2008, please provide copies of any and all analyses,
evaluations, reports, documentation, or calculations supportg the
Company's change in therms savings. If any of the materials provided
in response to ths request were not prepared by A vista please identify
who prepared the document( s) and for whom they were prepared.
d) If A vista has adjusted the savings estimate for this progr durg the
period 2006 to 2008, please provide copies of any and all materials
provided to the Commssion regarding the change, as well as
documents provided to the Triple E.
StafCPR_011 Attachment B Page 209 of 264
(Type text)
To: Avista
PC-493
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-60518
Public Counsel Data Request No. 493
Re: Avista's Response to Public Counsel's Data Request No. 309, New
Customer Adjustment, Attachment A.
Avista's response to this data request provides calculations that do not comport
with the Evaluation Report Table G3, representing Avista's apparent
disagreeent with Titus with the statement in par b suggesting tht Titus,
".. .should have reflected the deferral calculated by a comparison of all current
weather adjusted usage to the base (test year) volumes adjusted for the change in
number of customers ties average test year usage per customer. PC_DR _309
Attchment A shows meangfu values for the table which indicate tht without
the new customer adjustment which identified actu usage of new customers,
the resultig deferrls would have been slightly greater th those recorded in the
pilot mechansm." Please respond to the following:
a) State with specificity and explain each and every error, omission or
inaccuracy tht is believed by Avista to exist with Table G3 of the
Evaluation Report.
b) Explai each reason why, in Attchment A, the elimination of amounts
within the "Deduct new Customer Usage" row near the top of the calculation
is not suffcient by itself (without the change described in part c, below) to
elimnate the impacts of the New Customer Adjustment.
c) Explain each reason why, in Attchment A, A vista has added a new row
captioned "Less Test Year Adjustment" that appears to account for
incremental Customers at average usage levels.
d) State and explain why the new "Less Test Year Adjustment" row is
believed to be necessar, indicating each other row/amount in Attchment A
that does not reasonably calculate decoupling deferral amounts without ths
new row.
e) Explain whether the changes made in Attchment A, as referenced in
pars (b) and (c) of ths data request, have been presented to or approved by
Titus, the Commssion Staf, or any regulatory authority.
StafCPR_011 Attachment B Page 210 of 264
To: David Meyer
Re: PC Data Request No. 493
Docket Nos. UE-0903l4 / UG-0903l5, UG-0605l8
Date: July 31,2009
Page 2 of2
f) If your response to par (e) is affiative, provide complete copies of all
correspondence, electronic files, data requests and other documents
associated with your response.
StafCPR_011 Attachment B Page 211 of 264
BEFORE THE WASHINGTON UTITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Request No. 494
To: Avista
PC-494 Ref: Avista's Response to Public Counsel's Data Request No. 442,
part b, Attachment A (Cost per New Customer).
In Attchment A, A vista provided 2008 "New Residential Investment"
amounts divided by "Services/Lots" to calculate a "Total Anual Cost" to
sere new gas customers. Please provide the following additional
inormation:
a. Complete copies of all reports, anlyses, workpapers, accountig
records and other document relied upon to prepare Atthment A.
b. Explai the procedur and accountig systems that are used by
Avista in the normal coure of business to track and categorie its
budgeted and actu gas utiity constrction expenditues by
progr, project and other classification, indicatig each category
tht is employed in such trckig.
c. Provide the most detailed avaiable report of 2008 actual gas utility
constrction expenditues and additions to gas Plant in Service,
broken down into the categories stated in your response to par (b).
d. Provide a detailed breakdown of Avista's actual Gas Utility Plant
in Service new investment completed in 2008, indicating
separtely the amounts invested in each of the following
categories:
1. Residential main - new constrction for connection of
new customers.
2. Residential mains for replacement of existing main.
3. Residential mains for expansion of capacity (rather than
service to new areas)
4. Non-residential mais for new constrction and connection
of new customers.
5. Non-residential mains for replacement of existig mains.
6. Non-residential mais for expanion of capacity (rather
than servce to new areas).
7. Residential services - new constrction for connection of
new customer.
8. Residential services for replacement of existig services.
StafCPR_011 Attachment B Page 212 of 264
To: David Meyer
Re: PC Data Request No. 494
Docket Nos. UE-090314, UG-0903l5 & UG-060518
Date: August 5, 2009
Page 2 of2
9. Non-residential services - new constrction for connection
of new customers.
10. Non-residential services for replacement of existig
services.
1 1. Residential Regulator Stations - new constrction.
12. Residential Regulatory Stations for replacement of existig
Regulator Stations.
13. Non-residential Regulator Stations - new constrction.
14. Non-residential Regulatory Stations for replacement of
existig Regulator Stations.
15. Provide and explain all additional inormation needed to
reconcile your response to par (c) to the amounts set fort
as Mains, Service and Reg Station investment amounts
used to calculate depreciation in footnote (1).
16. Provide and explain al additional information needed to
reconcile your response to par (c) to the amounts set fort
as Main, Serice and Reg Station investment amounts
used to calculate depreciation in footnote (1).
17. Provide supportg documentation and explanations for the
"2008 Cost of Domestic Gas Meter" amount of $56.83.
18. Provide the monthy number of residential gas customers
served in 2008, with inormation necessar to reconcile
this data to the 3,534 "Services/Lots" included in
Atthment A.
19. Provide supportg calculations for the cost of equity and
cost of debt percentages used in Attchment A.
20. Provide supportg documentation and explanations for the
"Incremental Biling cost per Bil" amount of .5430.
StafCPR_011 Attachment B Page 213 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Request No. 495
To: Avista
PC-189 Provide a ful description of account 232545 - Accounts Payable and what
the relationship of ths account is with Jackson Prae Storage.
StafCPR_011 Attachment B Page 214 of 264
BEFORE THE WASHINGTON UTILITIES AN TRASPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Request No. 496
To: Avista
PC-496 Rerun the Dispatch Model and other aspects of Company's various
revenue requirements models with the identical data and methods as was
done to prepare Company's original fiing in this case, EXCEPT for using
gas prices computed as of August 5, 2009 consistent with the gas pricing
methodology used in the Company's fiing. Then provide an update to
Public Counsel Data Request 81, which estiated the impact on costs of
service in "with" and "without" the Lancaster PPA scenarios. Include in
the answer:
a) The annual average AECO and Staeld gas prices.
b) The benefit of AURORA production costs due to the Lancaster
plant.
c) The increase in other expenses due to the Lancaster plant, as was
shown in Exhibit No. (WGJ-2), on lines 10, 11,46, and 57.
StafCPR_011 Attachment B Page 215 of 264
BEFORE THE WASIDNGTON UTILITIES AN TRSPORTATION COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 497 through 508
To: Avista
PC-497 RE: Avista's Response to Public Counsel Data Request No. 442, part b,
Attachment A (Cost per New Customer).
In Attachment A, Avista provided 2008 "New Residential Investment" amounts
divided by "Services/Lots" to calculate a "Total Anual Cost" to serve new gas
customers. Please provide the following additional inormation:
a. Explai whether or not the investment cost shown has been reduced by the
amounts of advanced mium payments received from customers pursuant to
Schedule l5lA gas main extension rues.
b. Identify and describe the genera procedures, calculations and collection policies
employed by Avista to interpret and apply Schedule 151 and 151A extension rues
to new service lots.
c. Provide complete copies of the calculations of actual service/main extension costs
and advance mium payment analyses performed by A vista for the thee most
expensive individual service lot facilities extension projects in 2008 tht did not
requie any advance payments by propert owners/developers.
d. Provide complete copies of the calculations of actu servce/mai extension costs
and advance mium payment analyses performed by A vista for the thee most
expensive individua service lot facilties extension projects in 2008 that did
require any advance payments by propert owners/developers
e. Provide the total number of transactions (serice lots) and amounts of all 2008
advanced payments received from customers pursuat to Schedule 151 and l5lA.
f. State and explain whether or not A vista rigorously applies the "extension rules" set
fort in Schedule 151 and l51A to all newly served "service lots" and describe
each instace (if any) where the full amount of advanced mium payments
chageable under the rues was not biled and collected by A vista in 2008.
g. Provide detailed fuer calculations, if any, tht would be necessar to restate
Attchment A to fully and accurately account for the reduced investment actually
required to serve new customers because of the extension rules.
StafCPR_011 Attchment B Page 216 of 264
To: David Meyer
Re: PC Data Requests Nos. 497 though 508 to A vista
Docket Nos. UE-0903l4 / UG-0903l5, UG-0605l8
Date: August 19,2009
Page 2 of8
PC-498 RE: Avista's Response to Public Counsel's Data Request No. 283, Attachment A
and Mr. Hirschkorn's Exhibit No._ (BJH-2) "Titus Evaluation Report".
a. Please provide an explanation for the following discrepancy between Avista's
reported results of its Idaho high efficiency fuace progr in 2006:
i. Mr. Hirschkom's Exhibit No. _ (BJH-2) ("Titus Report") at Table H3-
B, p. 55, shows Avista estimated savings of 144,642 therms for the Idaho
fuace program.
11. A vista's Response to the Public Counsel Data Request referenced above,
at line 5217, shows 31,104 therms as A vista reported savings from the
Idaho fuce progr.
b. Please indicate what the correct amount of A vista reported therm savings
should be from the high efficiency fuace program offered to Idao customers
in 2006.
c. Please confir that the amount shown in part (a) (i) of this question (144,642
therms) was included in Avista's "verified" therm savings for 2006 in the
company's fiing in Docket. No. UG-07l863.
d. Ifthe company's response to part (c) of ths question is affiative, and if
144,642 therms is not the correct amount of savings from the Idaho fuce
program in 2006, please indicate and provide an explantion as to what actions
Avista intends to tae, if any, to correct ths error.
PC-499 Re: Attached Excel fie labeled, "PC DR No 6 'nonres completed therms 123108
for Titus"'.
The attched Excel spreadsheet was provided by A vista to the Stakeholder Advisory
Group and Titus durg the Decoupling Evaluation. It was also attched to Public
Counsel's Data Request NO.6 to Avista in this proceeding.
a. Please provide a version of ths Excel spreadsheet that includes the customer
naes for each of the approximately 500 entres shown.
b. If there are any other revisions, modifications, or any other chages to the
spreadsheet, other than the inclusion of customer names, please indicate and
explai each such revision, modification, or chage.
Staff_PR_011 Attachment B Page 217 of 264
To: David Meyer
Re: PC Data Requests Nos. 497 though 508 to A vista
Docket Nos. UE-090314 I UG-090315, UG-060518
Date: August 19,2009
Page 3 of8
PC-500 Re: Mr. Hirschkorn Workpaper Excel file C.xls, worksheet "2008 CI".
a. Please conf tht the Excel Worksheet referenced above, included in Mr.
Hirschkom's Workpapers, includes the followig therm savings amounts for the
Rooftop Service Progr in 2008 as shown in the table below:
2008 R ft S P00 op ervice r02lam
State and Rate Schedule Reported Savin2s (therms)
1.W A - Schedule 10 1 34,033
2.WA- Schedule 111 35,981
3.WA RooftoTJ 70,014
4.ID - Schedule 101 40,786
5.ID - Schedule 1 1 1 88,175
6.IDRooftoTJ 128,961
7.WA & ID Rooftop Total 198,975
b. Please conf that in 2008, Avista origiy reported savings of 198,975 therms
for the Rooftop Services progr in Washigton and Idaho. If Avista believes ths
amount is not correct, please provide the correct amount and an explanation as to
why the company believes 198,975 is not the correct amount of A vista reported
savings.
c. Please confi that the Excel workpaper referenced above, in the Section labeled
"DSM Savings with Audit Adjustments," shows "verified" savings of 56,350
therms for the Washigton Rooftop Service progra in 2008 and 119,396 therms
for Idao in 2008.
d. Please confin that the amounts referenced above in par ( c) of ths request as
"verified" savings for the Rooftop Service Program in 2008 represent
approximately 80.4% of the Washigton original estimate, and 92.5% of the Idaho
original Avista reported estiate of the amounts shown in the Table above in par
(a) of ths request.
e. Please explain why the two percentage amounts (80.4% and 92.5%), referenced in
par (d) above are different.
f. Please explai whether the DSM Verifier conducted distinct and separate analyses
of Washigton rooftop projects and Idao rooftop projects in 2008. That is, were
the Washigton estimated savings examined separtely from the Idao estiated
savings?
StafCPR_011 Attchment B Page 218 of 264
To: David Meyer
Re: PC Data Requests Nos. 497 though S08 to A vista
Docket Nos. UE-090314 I UG-0903lS, UG-060Sl8
Date: August 19,2009
Page 4 of8
pc-soi Re: Mr. Hirschkorn's Exhibit No._ (B-2) "Titus Evaluation Report", Tables
H3-E and H3-F (2008), pp. 58-59.
a. Please provide an explantion as to why each of the following amounts in the
columns labeled "% of claimed therms verified" in these two tables are not
identical:
1. Limited Income - ai inltration
11. Limited Income - inulation
iii. Limted Income - Windows/Doors
iV. Limted Income - FuraceslW ater Heaters
v. Other non-res site specific
V1. Nonres prescriptive programs
b. For each DSM program referenced in par (a) of this request, please provide an
explanation as to whether the DSM Verifier conducted distinct and separte
analyses of Washigton estiated savings and Idaho estiated savings. That is,
were the Washigton estimated savigs examied separtely from the Idaho
estimated savings?
PC-S02 Re: Mr. Hirschkorn's Exhibit No. _ (B-2) "Titus Evaluation Report",
Tables H3-B (Idaho 2006), H3-D (Idaho 2007), and H3-F (Idaho 2008), pp. 55, 57
and 59.
Please confirm that the columns in each ofthese Tables labeled "Therms in related
WA population" should instead read: "Therms in related il population." If Avista
believes these colum headings are not incorrectly labeled, please provide an
explantion.
PC-S03 Re: Mr. Hirschkorn's Exhibit No. _ (B-2) "Titus Evaluation Report",
Tables H3-C and H3-D (2007), pp. 56-57.
a. Please explain why Table H3-C shows that "0%" of claimed therms were
verified for the Rooftop Program in Washigton in 2007, but then shows
24,376 therms as the "Adjusted Therm Claim," which represents 29.6% ofthe
original Avista estiate of 94,377 therms. Please clarfy whether Table H3-C
should instead show that 29.6% oftherms were verified for ths progr.
b. Please explain why Table H3-C shows that "0%" of claimed therms were
verified for the Rooftop Progr in Washigton in 2007, but Table H3-D
shows that 29.6% oftherms for this program were verified in Idaho.
Staf"-PR_011 Attachment B Page 219 of 264
To: David Meyer
Re: PC Data Requests Nos. 497 though S08 to A vista
Docket Nos. UE-0903l4/UG-09031S, UG-060Sl8
Date: August 19, 2009
Page S of8
PC-S04
PC-SOS
Re: 2007 DSM Verification Report, Mr. Hirschkorn's Workpapers.
The 2007 Finl DSM Verification Report includes the following recommendation to
Avista at p. 79:
Complete a separate evaluation ofPECI's AirCare Plus progra to
detere the accuracy of reported energy savings.
a. Please describe any and all actions A vista has taen in response to ths
recommendation, and the date such actions were taken.
b. Please provide copies of any and all materials prepared by or on behalf of
A vista related to ths recommendation, includig but not lited to reports,
memos, analysis, or requests for proposals.
Re: Mr. Hirschkorn's Exhibit (B-2) "Titus Evaluation Report", Tables H3-C
and H3-D (2007), and H3-E and H3-F (2008), pp. 56-59.
a. Please confirm that Avista's reported savings from the "Rooftop Program" in 2008
were examined by the DSM Verifier as part of a "stratum" that was referred to as
"Other non-res site specific" in Tables H3-E and H3-F referenced above.
b. Please explain why the Tables reporting the 2007 verified savings (H3-C and H3-
D) provide a separte reportg of verified savings for the Rooftop Program in the
"Other nonres site specific" category, but the comparable Tables reporting the
2008 savings (H3-E and H3-F) do not provide a separate reporting of verified
savings for ths progr.
c. Please provide an explantion as to whether there were any chages in the Rooftop
Program in 2008 as compared to 2007, including but not limited to any changes in
progra adminstrtion, offerigs, or methods for estiating program savings.
StafCPR_011 Attachment B Page 220 of 264
To: David Meyer
Re: PC Data Requests Nos. 497 though 508 to A vista
Docket Nos. UE-090314/UG-0903l5, UG-060518
Date: August 19, 2009
Page 6 of8
PC-506 RE: Avista's Response to Public Counsel's Data Request No. 283, Attachment A
and Mr. Hirschkorn's Exhibit No. _ (BJH-2) "Titus Evaluation Report,"
Tables H3-A and H3-B (2006).
a. Please clarfy whether the row labeled "Windows" in the "Residential Projects"
section of Tables H3-A and H3-B is intended to refer only to Avista's window
replacement program, or to all windows progras, including Energy Sta windows
for new constrction.
b. Please provide an explanation for the following discrepancy between A vista's
reported results of its windows program in 2006:
i. Mr. Hirschkom's Exhibit No. _ (BJH-2) ("Titus Report") at
Table H3-B (Idao), p. 55, shows Avista estiated savings of
21,387 therms for Idaho residential windows progr.
11. Avista's Response to the Public Counsel data request referenced
above, at lines 2951, 3915, 3916, 16278, and 16952, shows a total
of 16,582 therms as Avista reported savings from all windows
programs in Idao in 2006.
c. Please identify each of the Residential DSM progrs included in the category
shown as "Other Res Sampled" in Tables H3-A and H3-B.
d. Please provide an explanation for the following discrepancy between Avista's
reported results of its windows progr in 2006:
11. Mr. Hirschkom's Exhibit No. _ (BJH-2) ("Titus Report") at
Table H3-A (Washigton), p. 54, shows Avista estimated savings
of 66,135 therms for Washigton residential windows program.
iv. Avista's Response to the Public Counsel Data Request referenced
above, at lines 3478, 16480, and 18442, shows a total of 47,655
therms as A vista reported savings from all windows progrs in
Washigton in 2006.
StafCPR_011 Attachment B Page 221 of 264
To: David Meyer
Re: PC Data Requests Nos. 497 though 508 to A vista
Docket Nos. UE-0903 14 I UG-0903 1 5, UG-060518
Date: August 19,2009
Page 7 of8
PC-507 RE: Avista's Response to Public Counsel's Data Request No. 283, Attachment A
and Mr. Hirschkorn's Exhibit No. _ (B-2) "Titus Evaluation Report,"
Tables ID-C and ID-D (2007).
a. Please clarify whether the row labeled "Windows" in the "Residential
Projects" section of Tables H3-C and H3-D is intended to refer only to
Avista's window replacement program, or to all windows programs, including
Energy Sta windows for new constrction.
b. Please provide an explanation for the following discrepancy between Avista's
reported results of its windows program in 2007:
i. Mr. Hirschkom's Exhibit No. _ (BJH-2) ("Titus Report") at Table
H3-B (Idao), p. 57, shows Avista estiated savings of28,018 therms
for Idao residential windows progr.
ii. Avist's Response to the Public Counel Data Request referenced
above, at lines 3042, 16356, and 17176, shows a total of2l,058 therms
as Avista reported savings from all windows programs in Idaho in
2007.
c. Please identify each of the Residential DSM programs included in the category
shown as "Other Res Sampled" in Tables H3-C and H3-D.
d. Please provide an explanation for the following discrepancy between Avista's
reported results of its windows progr in 2007:
1. Mr. Hirschkom's Exhibit No. _ (BJH-2) ("Titus Report") at Table
H3-C (Washigton), p. 56, shows Avista estimted savings of 105,260
therms for Washigton residential windows progra.
11. Avista's Response to the Public Counsel Data Request referenced
above, at lines 3870, 16629, and 19392, shows a total of 78,642 therms
as A vista reported savings from all windows programs in Washigton
in 2007.
StafCPR_011 Attachment B Page 222 of 264
To: David Meyer
Re: PC Data Requests Nos. 497 though S08 to A vista
Docket Nos. UE-0903 14 / UG-0903 1 S, UG-060S 1 8
Date: August 19,2009
Page 8 of8
PC-S08 RE: Avista's Response to Public Counsel's Data Request No. 283, Attachment A
and Mr. Hirschkorn's Exhibit No. _ (B-2) "Titus Evaluation Report,"
Tables H3-E and H3-F (2008).
a. Please clarify whether the row labeled "Windows" in the "Residential
Projects" section of Tables H3-E and H3-F is intended to refer only to Avista's
window replacement program, or to all windows progras, including Energy
Sta windows for new constrction.
b. Please identify each of the Residential DSM programs included in the category
shown as "Other Res Sampled" in Tables H3-E and H3-F.
StafCPR_011 Attachment B Page 223 of 264
BEFORE THE WASHINGTON UTILITIES AND TRASPORTATION COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Request No. 510
To: Avista
PC-5io RE: Avista's Responses to Public Counsel Data Request No. 485 and Data
Request No. 283, Attachment A
Public Counsel's Data Request No. 283 asked Avista to provide the number of
parcipants in each natual gas DSM progr from 2004 though 2008, as well as
other information. Avista's Response, at Attchment A, included a colum labeled
"paricipants" with total customer counts shown for each gas DSM program.
A vist's Response to Public Counsel Data Request No. 485 suggests that with respect
to the Windows Replacement progr, the data provided in response to PC-283,
Attchment A, does not in fact represent the number of customers partcipatig in the
program, but instead reflects the number of "incentives" paid.
a. Due to the inconsistency described above, please prepare and submit a Revised
Response to Public Counel Data Request No. 283 that accurately provides all of
the inormation requested, including the number of customers paricipatig in each
gas DSM program.
b. Please provide an explantion for any modification, correction or revision to the
data originlly provided in response to Public Counel Data Request No. 283.
StafCPR_011 Attachment B Page 224 of 264
BEFORE THE WASIDNGTON UTILITIES AN TRNSPORTATION COMMISSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Request Nos. 511 through 519
To: Avista
PC-511 Re: Avista's Responses to Public Counsel Data Requests Nos. 489 and 506.
Avista's Response to Public Counsel Data Request 489, at Attachment A, does not
appear to include data regarding measure tyes RR8, RR9, and RR. Avista
explained in response to Public Counsel Data Request No. S06 tht the company had
failed to include data for these progrs in the response to Public Counsel Data
Request No. 283. It appear that A vista has also faied to include ths data in its
response to Public Counsel Data Request No. 489, at Attchment A.
a. Accordigly, please provide a supplementa response to Public Counsel Data
Request No. 489 with an Excel spreadsheet similar to that provided as Attchment
A to the original response. Please ensure that ths supplementa response (Excel
spreadsheet) includes data for all residential DSM progras, including those
referenced above, as well as any other programs that were not originally included
in Avista's original response to Public Counel Data Request No. 489, Attchment
A, if the company deternes that additional data was also mistaenly excluded
from the original response. That is, the Excel spreadsheet provided in response to
this request should include all of the data originally included in Avista's response
to Public Counsel Data Request No. 489 and any additional data not included with
the original response. Please provide an explanation identifyg the additional
data included in the revised supplemental response.
b. Please confir tht the Excel spreadsheet provided in response to par (a) of ths
request provides the necessar data to calculate the number of customers (as
opposed to the number of incentives or rebates provided) paricipating in each
DSM program.
c. If the company's response to part (b) of this request is not affrmative, please
provide an explanation.
PC-512 Re: Avista's Responses to Public Counsel Data Requests Nos. 283, 489, and 506.
Please provide a listing and an explanation for each measure code for al DSM
programs (e.g. RR7, RR8, etc.), as shown in Avista's responses to the Public Counel
Data Requests referenced. For each such measure code, please provide a brief
description of the DSM progra, from 2004 though 2008.
Staff_PR_011 Attachment B Page 225 of 264
To: David Meyer
Re: PC Data Requests Nos. 511 though 519 to A vista
Docket Nos. UE-090314 I UG-090315, UG-û60518
Date: September 9,2009
Page 2 of6
PC-513 Re: Avista's Responses to Public Counsel Data Requests Nos. 283 and 506.
a. Please clarfy whether the DSM Program with the Measure Code "RR" refers to
the natul gas energy sta new windows for new constrction, as indicated by the
Company's response to Public Counsel Data Request No. 283, Attchment A, or
whether ths refers to a replacement window progra (N facing), as appears to be
suggested in Avista's response to Public Counsel Data Request No. 506.
b. Please clarify whether the DSM programs with the measure codes "RRC," "RR,"
and "RR" are all replacement windows programs.
c. Please clarfy whether the DSM programs with the measure codes "RR7", "RR8,"
and "RR9" all refer to EnergyStar new windows for new construction programs.
PC-514 Re: Testimony of Bruce Folsom, Exhibit No. _ (BWF-2) and Avista's Response
to Public Counsel Data Request No. 490.
Exhbit No. _ (BWF-2) includes certin data and calculations tht were based upon
Januar to November, 2008, likely due to the timing of the company's rate case filing.
This request asks for an updated version of ths exhbit with fial and complete 2008
data, as described below.
a. Please provide a revised, updated version of ths Exhbit (BWF-2), as an Excel
workbook with all formulae intact, tht reflects the fil, corrected savings and
costs for 2008. With respect to the gas cost effectiveness calculations, please be
sure to use the fil verified savings amount for 2008, as corrected by Avista on
or about August 10, 2009 and shown in the Titus Evaluation Report (Exhbit No.
_ (BJH-2), Corrected.) Please ensure that the Excel workbook fie provided
in response to ths request includes any and all worksheets referenced in the
cost-effectiveness calculations. In addition, please subtract 11,603 therms from
the final verified gas savings for 2008 in light of Avista's admission in response
to Public Counel Data Request No. 490 tht 10, I 08 therms were incorrectly
included in the tota Avista reported savings of 133,253 therms for residential
insulation, which were subsequently verified for a tota of 153,026 therms, (ths
error of 10,108 therms was then verified at 114.8%, as shown in Table H3-E of
the Titus Report (Exhbit BJH-2) (10,108 * 114.8% = 11,603 therms).
b. Please provide separte cost-effectiveness calculations for each state,
Washigton and Idao, as an Excel workbook with all formulae intact, that
reflects the final, corrected savings for 2008. With respect to the gas cost
effectiveness calculations, the fil savings amount for 2008 should be the
verfied savings, as corrected by A vista on or about August 10, 2009 and shown
in the Titu Evaluation Report (Exhbit No. _ (BJH-2), Corrected.) Please
Staff_PR_011 Attachment B Page 226 of 264
To: David Meyer
Re: PC Data Requests Nos. 511 though 519 to A vista
Docket Nos. UE-0903l4 I UG-0903l5, UG-0605l8
Date: September 9, 2009
Page 3 of6
ensure that the Excel workbook fie provided in response to ths request includes
any and all worksheets referenced in the cost-effectiveness calculations. In
addition, please subtrct 11,603 therms from the final verified gas savings for
Washington for 2008 in light of Avista's admission in response to Public
Counel Data Request No. 490 tht 10,108 therms were incorrectly included in
the total Avista reported savings of 133,253 therms for residential insulation,
which were subsequently verified for a total of 153,026 therms, (ths error of
10,108 therms was then verified at 114.8%, as shown in Table H3-E of the Titus
Report (Exhibit BJH-2) (10,108 * 114.8% = 11,603 therms.)
c. Please provide an Excel worksheet with the avoided cost calculations shown in
ths Exhbit, as revised pursuat to ths request, with al formulae intact. Please
ensure that the Excel fie provided in response to ths request includes any and
all worksheets referenced in the avoided cost calculations.
PC-515 Re: Avista's Response to Public Counsel Data Request No. 498.
a. Please explain why the multi-family direct install program "is tracked in
(Avista's) non-residential database."
b. Please provide a general description of the "multi-family direct install program"
referenced in Avista's response to part (a) ofthe above data request. Please also
provide any inormation A vista has regardig the size of the buildings that receive
DSM measures as par of ths program, in terms of the number of unts in the
buildings and total squae feet. In addition, please explain whether ths progr
is admstered by A vista diectly, or by a subcontrctor. Lastly, please explain
who is responsible for installing the DSM measures (e.g. tenant, building owner,
contractor, program adminstrtor.)
c. Please clarify and explain whether the "multi-family direct install program"
referenced in the response referenced above is the same as the multi-family direct
install program described in the progra specifications document provided as
Attachment B to Avista's Response to Public Counsel Data Request No. 388.
d. Please provide a description of any and all measures included in Avista's multi-
famy direct install progra. For each such measure, please provide an
explanation of the savings estimate (kwh or therms) used by Avista to calculate
savings for ths progr.
e. Please provide an explantion regarding the type(s) of fuaces, boilers, or HV AC
equipment installed as part ofthe "multi-famiy direct install program" referenced
in Avista's response to Public Counsel Data Request No. 498.
f. Please provide the total savings (therms and kwh) attibuted to the "multi-famy
direct install program" for each year, 2001 though 2008, for Washigton, Idaho,
Staff_PR_011 Attchment B Page 227 of 264
To: David Meyer
Re: PC Data Requests Nos. 511 though 5 I 9 to A vista
Docket Nos. UE-0903l4 / UG-090315, UG-060518
Date: September 9,2009
Page 4 of6
and Oregon (if applicable ) and total. In addition, for each year, please provide
savings data (by state) for each measure included in this program (e.g. CFLs,
showerheads, aerators, water pipe wrap).
g. For each year, 2006 though 2008, please provide an explanation as to where the
savings amounts referenced above in response to par (f) of ths request, are
shown in Tables H3A though H3F in the Titus Report (Exhbit No. _ (BJH-2),
at pp. 54-59.
PC-516 Re: Avista's Response to Public Counsel Data Request No. 498.
Please provide additional documentation and inormtion regarding the multi-famy
direct instal program that resulted in 113,178 therm savings in 2006, as discussed in
the above data response. Please provide the following:
a. Any data the company has regarding the total number of instalations, as well as
the number of multi-famly buildigs that received measures as par of ths
progr. If possible, provide data for each measure tye in the program (e.g.
CFLs, showerheads, aertors, water pipe wrp).
b. Therm and kwh savigs claied per parcipatig customer or measure install.
c. Amount of Avista incentive payment, if applicable, or value of benefit provided
by Avista.
d. Customer project cost.
e. Tota savings (kwh and therm) for each measure tye in ths progrm.
f. Any additional documentation retained by A vista supporting these DSM
tranactions.
g. Please provide an explanation for the data provided in response to par (a)
though ( e) of ths request to indicate whether A vista trcks progra paricipation,
savings, and costs for eah unt with a building, and/or for the entire building.
PC-517 RE: Mr. Hirschkorn's Exhibit No. _ (BJH-2) ("Titus Report"), Exhibit C-l.
Please provide the results of any analysis conducted by A vista to exame possible
inccurcies with Exhbit C-l referenced above. Please identify any errors or
inccurcies Avista has identified with ths exhbit, including but not limted to:
a. Commercial and Industral customers shown as having a Schedule 101 completed
DSM project, but who are curently served by a different rate schedule.
b. Commercial and Industral customers shown as having completed DSM projects
from 2004 though 2008, but who mistaenly appea more than once in ths
exhbit (duplicate entres.)
StafCPR_011 Attachment B Page 228 of 264
To: David Meyer
Re: PC Data Requests Nos. 511 though 519 to A vista
Docket Nos. UE-090314 / UG-0903 1 5, UG-0605 1 8
Date: September 9,2009
Page 5 of6
c. For any such error or inccurcy, please identify the year, DSM project, rate
schedule, ther savings, and explanation (e.g. identified as Schedule 101 but
served on Schedule 111, or duplicate entr.)
PC-518 RE: Avista's Response to Public Counsel Data Requests Nos. 6 and 360.
Please provide a corrected, supplemental response to Public Counel Data Request No.
6, Confdential Attchment A, with the correct address for DSM Application Number
22204 resulting in estimated savings of 2,665 therms. Documentation provided by
Avista indicates the relevant project was at a warehouse. Accordingly, please provide
the address of the warehouse where this DSM project occurred by submitting a
revised, corrected version of Confidential Attachment A to Avista's Response to
Public Counsel Data Request NO.6.
PC-519 RE: Avista's July 31, 2009 Filng in Docket Nos. UE-082272 & UG-090052
The filing referenced above includes the following information regarding Avista's
natul gas taff rider for Washigton:
Ending balance (as of 6/30/09)
Estimated taff rider revenue to be collected by EOY 2010
Estiated taff rider expense though EOY 20 I 0
Net activity though EOY 2010
Projected taff rider balance at year end 2010
$2,469,752
(7,043,000)
4,499,179
(2,543,821)
$(74,069)
a. Please confirm tht the information shown above indicates that as of June 30, 2009
A vista had a "negative balance" of almost $2.5 millon, indicating that in recent
years Avista's natural gas tariff rider expenses have exceeded revenues collected
from ratepayers.
b. Please provide the most curent balance available for the Washigton natual gas
taff rider account.
c. Please indicate whether Avista continues to project that for the period July 1,2009
though December 3 I, 20 I 0, the company will spend 64% of total tarff rider
revenues on Washigton natul gas DSM program expenses, while the remaing
36% of taff rider revenues wil be devoted to a write-down of the negative
balance.
d. Please explain whether Avista contiues to project that the Washigton natual gas
taff rider account wil be positive (company owes ratepayers) by the end of 2010,
StaftPR_011 Attachment B Page 229 of 264
To: David Meyer
Re: PC Data Requests Nos. 511 though 519 to Avista
Docket Nos. UE-0903l4 I UG-0903l5, UG-0605l8
Date: September 9,2009
Page 6 of6
as shown in this filing. If the company's projection has changed significantly,
please provide an explantion and reason for any changes.
e. The fiing referenced above includes the following notation:
"*** This projection does not tae into account additional spending that may result
from the implementation of stiulus progr sta-up."
Please provide a detailed explanation of ths notation. Please explain why any
potential activities and expenses related to stiulus programs would impact the
tariff rider accounts (either electrc or gas). In addition, pleaše provide an
explantion as to what, if any, stiulus fudig A vista either has sought or plans
to apply for related to demand side management or any activities that might affect
the electrc or gas DSM tarff rider accounts. Please consider ths an ongoing
request and provide updates as appropriate durg ths proceedig.
Staff_PR_011 Attachment B Page 230 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Requests Nos. 520 through 527
To: Avista
Re: Kelly O. Norwood's Rebuttal Testimony
PC-520 At page 34, Mr. Norwood's Rebuttal Testimony refers to Avista's "Every
Little Bit program and states, "The facts are that the Every Little Bit
program does lead to customers undertakg no-cost and low-cost steps
towards being more effcient." Please identify with specificity each study,
report, analyses, projection and other document relied upon to support ths
asserton and provide complete copies of same.
PC-52l At page 34, line 17, Mr. Norwood's Rebuttl Testimony states, "In 2008,
18,467 customers completed the Home Energy Audit." Please provide the
following inormation:
a) How many of these 18,467 customers paricipated in one or more
ofthe Company's DSM programs and rebates?
b) How many of these customers have undertaken no-cost or low-cost
steps toward being more effcient?
c) Please identify with specificity each study, report, analyses,
projection and other document relied upon to support your
response to par (a) of ths data request and provide complete
copies of same.
d) Please identify with specificity each study, report, anyses,
projection and other document relied upon to support your
response to par (b) of ths data request and provide completecopies of same .
Staff_PR_011 Attachment B Page 231 of 264
To: David Meyer
Re: PC Data Requests Nos. 520 though 527
Docket Nos. UE-090314 / UG-0903l5, UG-060518
Date: September 15,2009
Page 2 of8
PC-522 At page 34, line 23, Mr. Norwood's Rebuttl Testimony states, "Furher
the Company actively parcipates in varous groups and organations that
push for tougher energy codes and stadads; the results of which fuer
impact the deferrals." Please provide the following information:
a) Identify and explain each "tougher energy code" or "standard" that
was enacted as a direct result of the Company's participation in
"various groups and organizations", indicating why the
code/stadad would not have been effected without Avista
involvement.
b) Describe with specificity all steps taen by A vista though its
parcipation in ''various groups and organizations" that caused the
codes/stadads set fort in your response to par (a) to occur.
c) Explain and quantify how Avista's average gas usage per customer
has been impacted in each of the past five years by each of the new
codes/standards that were enacted due to Avista's involvement in
the processes described in the referenced testiony.
d) Explain the extent to which any of the codes/stadads changes or
any related gas usage impacts described in your responses to ths
data request would have occured without Avista's involvement.
StafCPR_011 Attachment B Page 232 of 2E)4
To: David Meyer
Re: PC Data Requests Nos. 520 though 527
Docket Nos. UE-0903 14 / UG-090315, UG-0605 1 8
Date: September 15,2009
Page 3 of8
PC-523 At page 35, line 3-4 and lines 8-9, Mr. Norwood's Rebuttl Testimony
refers to, "fixed costs" and to, "recovery of costs approved by the
Commission." Please provide the following information:
a) To what extent are Avista's "fixed costs" actually variable rather
than "fixed" from year to year because of:
1. Changes in the number of customers being served?
2. Inflationary impacts upon wage rates, benefit costs and
materials and supplies purchaed to provide serice?
3. Productivity gai caused by the utilization of technology
and or improved mangement of resources?
4. Changes in business regulations or revisions in ta
codes/rules?
5. Changes in the cost of capital and interest rates?
b) Is it the Company's opinion that the Commission's rate orders are
intended to insure "full recovery" of the specific amount of cost
recovery revenues that are established in each test year, without
regard to the chages in cost levels that may occur after the test
year?
c) Is it the Company's opinion that the Commission's rate orders are
intended to insure "full recovery" of the specific amount of cost
recovery revenues that are established in each test year, without
regard to the changes sales volumes that may occur due to general
economic conditions, customer conservation, customer additions,
price elasticity or other factors?
d) Provide copies of all documents associated with or supportve of
your responses to pars (a) though (c) of ths data request.
StafCPR_011 Attachment B Page 233 of 264
To: David Meyer
Re: PC Data Requests Nos. 520 though 527
Docket Nos. UE-090314 I UG-090315, UG-060518
Date: September 15,2009
Page 4 of8
PC-524 At page 35, lines 14-19, Mr. Norwood's Rebuttl Testimony states,
"However, the Company is aware that there are varables outside of the
normal ebb and flow of customer usage over time. The Company's
curent mechansm calls for 90% recovery of the Decouplig deferral if
100% of the DSM test is met. The Company agrees, only in par, with
NWC Witness Ms. Glaser, that the recovery levels should be adjusted.
The Company proposes the following recovery strctue, whereby the
Company would only recover 70% of the decoupling deferrl instead of
90% assuming tht the Company achieves 100% of Target DSM Savings."
Please respond to the followig:
a. Explai in deta eah of the, "....varables outside of the normal
ebb and flow of customer usage over tie" that are being
referenced.
b. State with specificity the basis for the new 70% recovery level now
being proposed, indicating each reason why it is more appropriate
than the existing 90% recovery leveL.
c. Explain what has changed since the Company's initial testimony
filing tht now makes 70% a more appropriate recovery level th
the 90% that was recommended by A vista intially.
d. Explain each reason why 70% recovery is more appropriate th
60% or 50%.
e. Provide complete copies of all studies, reports, analyses,
projections, workpapers and other documents relied upon by
A vista to determine that 70% is the most appropriate recovery
level, relative to all other alternatives that were considered.
StafCPR_011 Attachment B Page 234 of 264
To: David Meyer
Re: PC Data Requests Nos. 520 though 527
Docket Nos. UE-0903l4 / UG-090315, UG-0605l8
Date: September 15, 2009
Page 5 of8
PC-525 At page 36, line 20, Mr. Norwood's Rebuttal states, "The presence, or lack
thereof, of some mechasm for fixed cost recovery is a major factor that
wil be considered as the Company develops its futue DSM plans."
Please provide the following inormation:
a. State specifically how the Company expects to chage its
development of DSM plans in Washigton if the Commssion does
not allow contiuation of decoupling at the 90% level intially
proposed by A vista, but instead allows some reduced level of
decoupling deferraL.
b. State specifically how the Company expects to chage its
development of DSM plans in Washigton if the Commission does
not allow any contiuation of decoupling in Washigton.
c. Explain whetherlhow the Company's development of electrc
DSM programs in Washigton has been affected by the absence of
any electrc decoupling mechansm in the State.
d. Does A vista have any intention of not fuly supporting the
development and admstrtion of cost effective gas DSM
programs in Washigton if its decoupling contiuation proposal is
rejected?
e. If your response to par (d) is affirmative, please identify and
provide complete documentation associated with all changes that
are anticipated with respect to futue gas DSM activities.
f. Does A vista intend to fuly support the continued development and
adminstrtion of cost effective electrc DSM progrs in
Washigton, even if decoupling is not intiated for the electrc
portion of the Company's utility business?
g. Wht, if any, changes in the scope or annual cost of A vista's
"Every Little Bit" campaign wil be implemented if Washington
gas decoupling is continued versus termted?
StafCPR_011 Attachment B Page 235 of 264
To: David Meyer
Re: PC Data Requests Nos. 520 though 527
Docket Nos. UE-0903 14 / UG-090315, UG-0605 1 8
Date: September 15,2009
Page 6 of8
h. What, ifany, changes in the scope or annual cost of Avista's non-
programatic conservation support efforts other than the "Every
Little Bit" campaign wil be implemented if Washington gas
decoupling is contiued versus terminted?
PC-526 At page 40, line 17, Mr. Norwood's Rebuttal states, "One reason for the
decision by senior magement to rap up energy effciency was the
expectation tht the commssions would provide some form of recovery of
fixed costs related to our DSM efforts." Please respond to the following:
a. To what extent did Avista expect each of its state regulatory
commssions to implement gas revenue decoupling before ramping
up DSM efforts and costs?
b. To what extent did Avista expect each of its state reguatory
commssions to implement electrc revenue decoupling before
raping up DSM effort and costs?
c. Does the Company expect to chage its emphasis or commitment
to support cost-effective DSM programs dependent upon gas or
electrc decoupling implementation or contiuation in any states?
d. If your response to par (c) is affirmative, please explain and
quantify in detail all chages tht are anticipated.
PC-527 Re: Avista's Responses to Public Counsel Data Request No. 442(b)
and Public Counsel Data Request No. 494(d) Uncremental Fixed Cost
to Serve New Customers).
At page 4 of his Rebuttal, Mr. Hirschkom references certin estimated
incremental fixed cost per average new residential customer values,
including the amounts provided in response to Public Counel Data
Request No. 442 totaing $32.42 per month, and then states, "Therefore,
the Company does not realize new margin in excess of its incrementa
costs for new customers." Please provide the following information:
a. Explai whether or not the Company believes tht it tyically loses
money for each averge residential new customer that is connected
and sered (at least between rate cases).
b. At lie 10 of page 4, Mr. Hirschkom provides an estimated,
"monthly incremental cost per customer in 2007" of $20.32.
StafCPR_011 Attachment B Page 236 of 264
To: David Meyer
Re: PC Data Requests Nos. 520 though 527
Docket Nos. UE-090314 / UG-090315, UG-0605l8
Date: September 15,2009
Page 7 of8
Please provide the support for ths value in the format of the
Company's Response to Public Counsel Data Request No. 442 (b)
and explain each reason for the signficantly lower result in 2007
than in 2008.
c. In the Company's Response to Public Counsel Data Request No.
442 (b), Avista provided an "estimated rate base" of $2,476.87 per
new customer added. Please confi that ths value does not
consider the incremental accumulated deferred income taes that
are recorded by A vista due to accelerated and bonus depreciation
on new investment that is deductible for income tax puroses and
provide the necessar revisions to the calculations to fully account
for such ta benefits.
d. In the Company's Response to Public Counsel Data Request No.
494, Atthment D, page 18, A vista reconciles its 2,031 change in
Customers in 2008 to the 3,534 of "Total 2008 Residential Service
Connections and Lots", indicating that 998 "Development Lots
Installed" are part of the difference. Please explain what these
"development lots" are and whether A vista is including investment
for development connections for which it has added no new
customers or new revenues.
e. What measures are taen by A vista to protect itself and its
ratepayers from the financial risk of constrcting new gas utility
plant to serve development lots for which compensatory new
revenues and margins may not be realized.
f. In the event A vista collects any incrementa advances,
contrbutions or deposits from developers to reduce its risk in
extending new facilities into developments or buildig lots, please
explain and quantify how these funds would impact the "estimated
rate base" of$2,476.87 per new customer that was estiated in
Avista's Response to Public Counsel Data Request No. 442(b).
g. In the Company's Response to Public Counsel Data Request No.
494, Attachment D, page 18, Avista indicates a 2,031 increase in
the number of gas customers served in 2008. How many ofthese
new customers were added as a result of electrc DSM switch to
gas conversions?
StafCPR_011 Attachment B Page 237 of 264
To: David Meyer
Re: PC Data Requests Nos. 520 though 527
Docket Nos. UE-0903l4/UG-090315, UG-0605l8
Date: September 15,2009
Page 8 of8
h. What amount of total Washigton gas utility capital expenditues
in 2008 were not for the extension of utility plant to serve new
customer?
1. Wht perentage of tota Washigton gas utility capital
expenditues in 2008 were not for the extension of utility plant to
serve new customers?
j. What amount of annual depreciation expense is included in the
Company's gas utility revenue requirement for the test year?
Staff_PR_011 Attachment B Page 238 of 264
BEFORE THE WASIDNGTON UTILITIES AND TRASPORTATION COMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-0901341UG-090135, UG-060518
Public Counsel Data Requests Nos. 544 through 545
To: Avista
PC-544 RE: Avista's Responses to Public Counsel's Data Request Nos. 283, Attachment
A, and Nos. 506, and Mr. Hirschkorn's Exhibit No. _ (BJH-2) "Titus
Evaluation Report," Tables H3-A and H3-B (2006).
Please provide an explanation for the following discrepancy between Avista's reported
results of certain residential DSM programs in 2006, as shown in the Titus Report,
Tables H3-A (W A) and H3-B (Idao), and the results reported by Avista in the
referenced data request responses. According to the 2006 DSM Verification Report,
Table A.3 (Appendix A), the category "All Other Measures, Residential" includes the
programs shown in the Table below. The Titus Report, at Tables H3-A and H3-B,
shows total Avista reported savings in ths category of 88,271 therms (39,650 therms
for WA, and 48,621 therms for il). However, Avista's responses to data requests
indicate a total of 67,359 therms for these programs, as shown in the Table below
(47,800 for WA, and 19,559 for il).
2006 - "All Other Measures - Residential" (Stratum 3)
Data Program ID WA
Source (therms)(therms)
Water Heater 40 g 220 550
Water Heater 50g 248 624
Avista Insulation-ceilingl attic 5,162 15,010
Response Insulation-floor 4,762 5,020
to PC-283,Inulation-wall 5,347 19,286
Att. A.Energy Sta homes 0 0
New windows-RR7 1,844 3,767
Avista
Response New windows-RR8 1,209 1,850
to PC-506,
Att. A.New windows-RR9 767 1,693
Total per Avista Data Responses 19,559 47,800
Total per Titus Report Tables H3-A, H3-B
(A vista Savings Estimates Reported to DSM 48,621 39,650
Verifer).
StafCPR_011 Attachment B Page 239 of 264
To: David Meyer
Re: PC Data Requests Nos. 544 though 545 to A vista
Docket Nos. UE-0903l4 / UG-0903l5, UG-060518
Date: September 22, 2009
Page 2 of2
PC-545 RE: Avista's Responses to Public Counsel's Data Request Nos. 283, Attachment
A, and Nos. 506, and Mr. Hirschkorn's Exhibit No. _ (B-2) "Titus
Evaluation Report," Tables H3-A and H3-B (2006).
Please provide an explantion for the following discrepancy between Avista's reported
results of the residential window replacement DSM programs in 2006, as shown in the
Titus Report, Tables H3-A (WA) and H3-B (Idaho), and the results reported by Avista
in the referenced data request responses.
Please note that while Avista's Response to Public Counsel Data Request No. 506 (a)
indicates that the Residential windows category of the 2006 DSM verification report
(Strtu 2) included both replacement windows and new windows, the 2006 DSM
Verification Report shows tht ths category only included replacement windows in
2006. (See Appendix A, Tables A.2. and A.3).
Accordig to the 2006 DSM Verfication Report Table A.2 (Appendix A), the
residential windows category (strtu 2), included only replacement windows. The
Titus Report, at Tables H3-A and H3-B, shows total Avista reported savings in the
windows category of 87,522 therms (66,135 therms for WA, and 21,387 therms for
ID). However, Avista's responses to data requests indicate a total of only 76,392
therms for these progrs, as shown in the Table below (58,825 for WA, and 17,567
for ID).
2006 - "Window Replacement - Residential" (Stratum 2)
Data Program ID WA
Source (therms)(therms)
Avista
Response Window Replacement - RRC 9,498 29,191
to PC-283,(East/ est facing)
Att. A.
Avista
Response Window Replacement - RR 4,100 14,697
to PC-506,(Nort facing;)
Att. A.Window Replacement - RR 3,969 14,937
(South facing)
Total per Avista Data Responses 17,567 58,825
Total per Titus Report Tables H3-A, H3-B
(A vista Savings Estiates Reported to DSM 21,387 66,135
Verifer)
StafCPR_011 Attachment B Page 240 of 264
BEFORE THE WASHINGTON UTILITIES AN TRNSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134 and UG-090135
Public Counsel Data Requests Nos. 552 through 556
To: Avista
PC-552 Refer to the response to PC -311. Identify the amounts allocated to the
W A electrc and gas operations for each of the years 2004 though 2008.
If no costs were allocated to the W A electrc and gas operations, please
explain why not and why the Company has allocated costs to the W A
operations in the curent test year.
PC-553 Refer to the response to PC-3l2.
a. Provide comparble inormation for each of the months subsequent
to the test year though the most rent month available.
b. Please provide a more detailed explanation of what the "expense
for utility office buildings and service centers" is comprised of.
c. Explain why the amounts for the months Januar though March of
2008 are signficantly higher than the other months shown.
d. Provide an itemization with descriptions of all amounts over
$ 10,000 for each of the months in the test year.
PC-554 Refer to the response to PC-052, Provide the monthly amounts of "all
other trouble O&M" for Janua 2009 though the most recent month
available. Provide ths information on a total system and W A electrc
jursdictional basis.
PC-555 Refer to the response to PC-20l(d). Identify the amount of the different
ta credit the Company has elected to use, includig all supporting
calculations.
StafCPR_011 Attachment B Page 241 of264
To: David Meyer
Re: PC Data Requests Nos. 552 though 556
Docket Nos. UE-0903l4 & UG-090315
Date: July 20, 2009
Page 2 of2
PC-556 Refer to the Company's response to PC-322.
a. Provide the Company's justification for utilizing an 6% ination
rate for existig costs.
b. Provide a detaed description of each of the programs identified in
ths response (i.e., Circuit Switcher Maitenace and Replacement,
Network Handhold and Manole Inpections, etc.)
c. For each progr stared in 2009, explain how the Company
previously addressed these matters. If no progr previously
existed, explai the need for creatig it.
d. Provide 2009 expenses incured to date in a simlar format as
Attchment A.
e. For each applicable enhanced program specify the additional
inpection requiements beyond what was previously done.
StafCPR_011 Attachment B Page 242 of 264
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. UE-090134, UG-090135 & UG-060518
Public Counsel Data Requests Nos. 528 through 541
To: Avista
PC-528 Re: Robert J. Laffert's Testimony
Provide the following information regarding the discussion on lines 1 to
15 on page 4 of Exhbit No._(RJL- 1 T) regarding the joint BP A-A vista
study of "interconnecting Avista's transmission to the BPA Lancaster
substation" (lines 3-4):
a. Describe and document the curently-expected scope of work and
schedule for Avista'sjoint effort with BPA to study such an
interconnection.
b. State specifically what the rage of potential on-line dates for such
an interconnection might be.
c. Provide any and all prelimar cost estiates of such an
interconnection.
PC-529 In the Company's Response to Public Counsel Data Request No. 304,
A vista stated "The Company anticipates having more information
concerng the studies and projected tImelines for interconnection
available in August 2009. More detas about the interconnection of
Lancaster to Avista's system wil be provided as they become available."
Did the anticipated additional information become available in August
2009? If so, please provide such inormation. If not, please state when
such inormation wil be available and provide such inormation as it does
become available.
StafCPR_011 Attachment B Page 243 of 264
To: David Meyer
Re: PC Data Requests Nos. 528 though 541
Docket Nos. UE-0903l4, UG-0903l5 & UG-060518
Date: September 15,2009
Page 2 of6
PC-530 Re: Robert J. Laffert's Testimony
Provide workpapers and sources tht document the following figues
provided in Exhbit No._(RJ- IT). Provide such workpapers in
electronic Excel-compatible format with data and formulae intact and
fuctionig:
a. Gas "delivery capabilty" of"25,742 Dth/day from Albert and
25,000 Dth/day from Malin" (4:19-20).
b. Lancaster gas consumption of"43,000 nth/day for the combustion
turbine and 5,000 Dth/day for the duct burner" (4:22-23).
c. All numbers shown in Table 2 (p. 5) in the column labeled "Gas
Consumption wi Duct Burner". Show the consumption for the
"combustion tubine" and "duct burer" portions of the Lancaster
plant separtely.
d. All figures shown in Table 3 (p. 6) in the columns labeled "CS2
Gas Consumption wi Duct Burer" and "CS2 Gas Transport".
Show the consumption for the "combustion turbine" and "duct
burer" portions of the CS2 plant separately.
PC-531 Re: Robert J. Laffert's Testimony
Provide the following inormation regarding Char 1 in Exhibit
No._(RJ-IT) (p. 7) in electronic Excel-compatible format with data
and formulae intact and fuctionig:
a. Provide all data used to prepare Char 1. Theterm "all data"
includes daily metered gas demand (and sub-daily biling
increments, if available).
b. For all the months shown in Char 1, provide Avista's hourly retail
loads and data showing which resources A vista used to meet such
hourly loads.
~aff_PR_011 Attachment B Page 244 of 264
To: David Meyer
Re: PC Data Requests Nos. 528 through 541
Docket Nos. UE-0903l4, UG-0903l5 & UG-0605l8
Date: September 15,2009
Page 3 of6
PC-532 Re: Robert J. Lafferty's Testimony
Provide the following information regarding A vista's procurement of gas
for its gas-fired electrc generation plants:
a. Provide Avista's current formal plans for procuring gas for each of
its gas-fired generators.
b. Citing the materials provided in subpar 'a' above, describe how
Avista procures gas for its gas-fired generators, individually and
collectively, when they are operating at or near their maximum
capacity.
c. Explain why Avista's current "CS2 Gas Transport" is less than
"CS2 Gas Consumption wi Duct Burner" (as both terms are used
in Table 3 of Exhibit No._(RJL-l T)), and for how many years
such "Transport" has been less than its "Consumption wI Duct
Burer",
d. Explain how Avista met the CS2 gas demands shown in Cha 1 of
Exhbit No._(RJL-l T) if it did not have suffcient gas pipeline
capacity. Provide detailed daly data as to how such additional gas
was delivered to CS2 on those days from Januar 2008 to August
2009 when gas usage exceeded 43,000 Dthday.
PC-533 Provide workpapers documenting Avista's current estimates of the future
fixed costs of its gas transporttion agreements for the Coyote Sprigs 2
plant and the Lancaster plant. Provide such workpapers in electronic
Excel-compatible format with data and formulae intact and fuctioning.
StafCPR_011 Attachment B Page 245 of 264
To: David Meyer
Re: PC Data Requests Nos. 528 though 541
Docket Nos. UE-090314, UG-090315 & UG-060518
Date: September 15,2009
Page 4 of6
Re: Clint G. Kalich's Rebuttl Testimony
PC-534
PC-535
Please answer the following questions regarding the statement made in
Exhbit No._(CGK-4T) at 3:1-5: "Resources raely come into service
on a schedule that perfectly meets a Company's needs. A vista discussed
the 'lumpiness' of resource acquisitions in its 2007 IR on page 8-8.
Resoure acquisitions must be evaluated over their lifeties, not againt a
specific deficit year or set of conditions, especially when an opportty
arses to procure a resource such as Lancaster at a signficant discount."
a. When did the Lacaster plant "come into service"?
b. When and how did A vista Corp. mangement determine that it
would assign the Lacaster Contrcts to A vista Utilities in 2010
rather th 2009 or 2011? What was the basis for ths decision?
Provide al documents tht show when and how the decision was
made as to the tig of the assignent of the Lacaster Contrcts.
Please anwer the following question regarding the statement made in
Exhbit No._(CGK-4T) at 3:18-4:1: "Avista performed a detailed
anysis of the Lacaster project, comparg it to greenfeld (new) and
brownfield (existig) plants. We considered the plant as par of our 2007
IRP and found the facility was a least-cost acquisition that would reduce
customer costs by approximately 2.3 percent as compared to a CCCT built
in 2011, or $43 milion over the Lancaster contract term. (footnote
omitted)"
a. Did A vista perorm any analysis of the Lancaster Project to
compar it to a CCCT built in 2009 or 201 O? If not, please explain
why Avista did not perform such anyses. If so, please provide
such any and al such analyses, includig those that have not been
previously published.
Sæff_PR_011 Attachment B Page 246 of 264
To: David Meyer
Re: PC Data Requests Nos. 528 through 541
Docket Nos. UE-0903l4, UG-0903l5 & UG-060518
Date: September 15, 2009
Page 5 of6
PC-536
PC-537
PC-538
Please answer the following questions regardig the statement made in
Exhbit No._(CGK-4T) at 4:17-21: "...Exhibit No. _(RS-6) of
Company Witness Storro provides a discussion of the key prudence tests
outlined in Eleventh Supplemental Order and the Nineteenth Supplemental
Order, both in Docket No. UE-920433. The Exhbit explains that
Lacaster meets each test of prudence It was a prudent decision when
made and remains so today. It is needed for utility service and is cost-
effective, among other points."
a. Provide a list of each of "the key prudence tests" referenced in this
passage, and cite where these tests are found in the two referenced
Orders.
b. For each of "the key prudence tests" referenced in subpart 'a',
identify where such tests are addressed in Exhbit No. _(RLS-6)
by page and paragrph.
Provide data sources and electronic Excel-compatible workpapers with
data and formula intact and fuctionig documenting the results shown in
the following tables of Exhibit No._(CGK-4T):
a. Table 1 (p. 5).
b. Table 2 (p. 6), includig the computation of the "Washington Gas
Tax Adj."
c. Table 3 (p. 7).
Please answer the following question regarding the statement made in
Exhbit No._(CGK-4T) at 9:4-6: "...there were very few CCCT plants
not already owned by a utility company or under long-term contracts, and
there were no such plants available for acquisition.".
a. How did Avista determine that "there were no such plants
available for acquisition"?
Staff_PR_011 Attachment B Page 247 of 264
To: David Meyer
Re: PC Data Requests Nos. 528 thugh 541
Docket Nos. UE-090314, UG-090315 & UG-û60518
Date: September 15,2009
Page 6 of6
PC-539
PC-540
PC-541
Please answer the following questions regardig the statement made in
Exhbit No._(CGK-4T) at 12: 1-4: "The Company relied not only on its
estimates of the costs of new CCCT plants, but on the professional work
of other nortwest utilities and the Nortwest Power and Conservation
Council, as well as an assessment of the marketplace for other resource
options, such as a long-term power purchase".
a. How did Avista conduct its "assessment of the marketplace"? Did
that assessment include requests from thd pares for bids to
provide fi capacity resources to A vista Utiities? If so, please
provide such any and all requests and responses thereto.
Provide data soures and workpapers in electronic Excel-compatible
format with data and formulae intat and fuctionig supportg the
statement and number below frm Exhbit NOo_(CGK-4T) at 12: 10-11:
"Averging post-Lacaster project costs from Table 2 above indicates an
average cost of $1,121 per kW".
Please answer the following questions regardig the statement made in
Exhbit NOo_(CGK-4T) at 14:22-15:4: "If the marketplace has adequate
resources to meet peak demand periods because it cares a plang
margin, wholesale electrcity prices wil be relatively lower on average
and below the total cost to own and operate a firm resource. But if
planng magins are not maintaed in the marketplace as a whole, prices
in the wholesale marketplace skyocket. By building to a plang
margi more volatie markets and higher prices to customers are
avoided."
a. Does A vista contend that if the Commission rejects its proposal to
assign the Lancaster Contracts to A vista Utilities that "price in the
wholesale market prices (wil) skyrocket"? Explain why or why
not.
b. If the anwer to subpar (a) above is 'No,' what does Avista
believe the impact on wholesale electrc prices would be of a
Commission rejection of Avista's proposal to assign the Lancaster
Contracts to A vista Utilities.
StafCPR_011 Attachment B Page 248 of 264
BEFORE THE WASHINGTON UTILITIES AND TRSPORTATION
COMMSSION
A VISTA GRC 2009
Docket Nos. 00-090134, UG-090135 & UG-060518
Public Counsel Data Request No. 542
To: Avista
PC-542 Update Avista's response to Public Counsel Data Request No. 79(d) to be
curent as of September 16,2009.
Staff_PR_011 Attachment B Page 249 of 264
BEFORE THE WASIDGTON UTILITIES AN TRASPORTATION CQMMSSION
A VISTA GRC 2009 and A VISTA DECOUPLING
Docket Nos. UE-090134 I UG-090135, UG-060518
Public Counsel Data Request No. 543
To: Avista
PC-543 Re: Avista's Responses to Public Counsel Data Requests Nos. 498 and 515.
Please provide additional documentation and information regarding the "site specific"
projects tht resulted in 113,178 therm savings in 2006, as discussed in the above data
responses. Please provide the following:
a. Any inormation A vista has regardig the size of the buidigs tht received DSM
measures tht resulted in the estiated therm savings referenced above in 2006, in
terms of the number of unts in the buidings and tota squae feet. Avista's
Response to Public Counel Data Request No. 515 (b) appears to indicate that
measures were intalled at thee buidigs in Idao. Accordigly, please provide
information about the size (unts, tota square feet) of these buildigs.
b. Any data the company has regarding the total number of installations, as well as
the number of multi-famly buildigs that received DSM measures tht resulted in
the estiated therm savings referenced above. If possible, provide data for each
measure tye in the progr (e.g. HV AC, windows, water heating, insulation).
c. Therm and kwh savings claied per measure at each site. Please also provide the
total therm and kwh savings claimed for each site.
d. Amount of A vista incentive payment, if applicable, or value of benefit provided
by A vista, at each site.
e. Customer project cost.
f. The name of the customer account for each site, and the DSM Application
numbers for each measure or project at each site.
g. Any additional documentation retained by A vista supportg these DSM
tractions.
h. Please provide an explantion for the data provided in response to pars (a)
though (f) of ths request to indicate whether Avista tracks program parcipation,
savings, and costs for each unt with a building, and/or for the entire building.
StafLPR_011 Attachment B Page 250 of 264
To: David Meyer
Re: PC Data Request No. 543 to Avista
Docket Nos. UE-0903 14 / UG-0903 15, UG-060518
Date: September 21,2009
Page 2 of2
1. Please indicate whether the savings associated with these "site specific" projects,
which A vista has indicated in Public Counsel Data Request No. 515 (a) are
''tracked in (Avista's) non-residential database", appear in the completed non-
residential section of Exhbit C- 1, at pp. 10- 1 8. (Appendix C to the Titus Report,
Mr. Hirschkorn's Workpapers).
StafCPR_011 Attachment B Page 251 of 264
BEFORE THE
WASilNGTON UTILITIES AN TRSPORTATION COMMSSION
00-090134
WASHINGTON UTILITIES AND
TRANSPORTATION COMMISSION,
Respondent.
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THE INUSTRI CUSTOMERS
OF NORTHWST UTILITIES'
FIRST SET OF DATA REQUESTS
TOAVISTA
Complaiant,
v.
AVISTA CORPORATION d//a
AVISTA UTILITIES,
Dated: Febru 18, 2009
1.DEFINITIONS
1. "Documents" refers to all writings and records of every tye in your possession, control,
or custody, whether or not claied to be privileged or otherwise excludable from
discovery, includig but not limted to: testiony and exhbits, memorada, papers,
correspondence, letters, reports (includig drfts, prelimin, intermediate, and final
reports), sureys, analyses, studies (including economic and market studies), sumares,
comparsons, tabulations, bils, invoices, statements of services rendered, chas, books,
pamphlets, photogrphs, maps, bulletins, corporate or other miutes, notes, diares, log
sheets, ledgers, transcripts, microfilm, microfiche, computer data (includig E-mail),
computer fies, computer tapes, computer inputs, computer outputs and pritouts,
vouchers, accountig statements, budgets, workpapers, engineerig diagrs (includig
"one-line" diagrams), mechanical and electrical recordings, telephone and telegraphic
communcations, speeches, and all other records, wrtten, electrcal, mechanical, or
otherwise, and drafts of any of the above.
"Documents" includes copies of documents, where the originals are not in your
possession, custody or control.
"Documents" includes every copy of a document which contains handwritten or other
notations or which otherwise does not duplicate the original or any other copy.
"Documents" also includes any attachments or appendices to any document.
PAGE 1 - INUSTRIAL CUSTOMERS OF NORTHWEST UTILITIES' FIRST SET OF
DATA REQUESTS TO AVISTA
StafCPR_011 Attachment B Page 252 of 264
2. "Identification" and "identify" mean:
When used with respect to a document, stating the natue of the document (~, letter,
memorandum, corporate minutes); the date, if any, appearg thereon; the date, ifknown,
on which the document was prepared; the title of the document; the general subject
matter of the document; the number of pages comprising the document; the identity of
each person who wrote, dictated, or otherwise paricipated in the preparation of the
document; the identity of each person who signed or initiated the document; the identity
of each person to whom the document was addressed; the identity of each person who
received the document or reviewed it; the location of the document; and the identity of
each person having possession, custody, or control of the document.
When used with respect to a person, stating his or her full name; his or her most recently
known home and business addresses and telephone numbers; his or her present title and
position; and his or her present and prior connections or associations with any parcipant
or par to ths proceeding.
3. "Avista" refers to Avista Corporation, Avista Utilities, any affliated company, or any
officer, director or employee of A vista or any affiliated company.
4. "Person" refers to, without limiting the generality of its meaning, every natual person,
corporation, partership, association (whether formally organed or ad hoc), joint
ventue, unt operation, cooperative, muncipality, commission, governental body or
agency, or any other group or organzation.
5. "Studies" or "study" includes, without limitation, reports, reviews, analyses and audits.
6. The terms "and" and "or" shall be constred either disjunctively or conjunctively
whenever appropriate in order to brig with the scope of ths discovery any inormation
or documents which might otherwise be considered to be beyond their scope.
7. The singuar form of a word shall be interpreted as plur, and the plural form of a word
shall be interpreted as singuar, whenever appropriate in order to brig with the scope
of ths discovery request any information or documents which might otherwise be
considered to be beyond their scope.
PAGE 2 - INUSTRL CUSTOMERS OF NORTHWEST UTILITIES' FIRST SET OF
DATA REQUESTS TO A VISTA
StafCPR_ 011 Attachment B Page 253 of 264
II. INSTRUCTIONS
I. These requests call for al inormation, includig inormation contaed in documents,
which relate to the subject matt of the Data Request and which is known or available to
you.
2. Where a Data Request has a number of separate subdivisions or related pars or portons,
a complete response is requied to each such subdivision, par or portion. Any objection
to a Data Request should clearly indicate the subdivision, par, or portion of the Data
Request to which it is diected.
3. The tie perod encompassed by these Data Requests is from 1999 to the present uness
otherwise specified.
4. Each response should be fushed on a separte page. In addition to a hard copy,
electrnic versions of the document, includig studies and analyses, must also be
fushed, if available, in the origitig softare, with all formulae intact.
5. If you canot anwer a Data Request in fu, after exercising due diligence to secure the
inormation necessary to do so, state the anwer to the extent possible, state why you
canot answer the Data Request in fu, and state what inormation or knowledge you
have concerng the unanwered portons.
6. If, in answerig any of these Data Requests, you feel that any Data Request or defintion
or instrction applicable thereto is ambiguous, set fort the languge you feel is
ambiguous and the interpretation you are using in responding to the Data Request.
7. If a document requested is unavailable, identify the document, describe in detail the
reasons the document is unavailable, state where the document can be obtained, and
specify the number of pages it contains.
8. If you assert that any document has been destroyed, state when and why it was destroyed
and identify the person who directed the destrction. If the document was destroyed
puruat to your document destrction progr, identify and produce a copy of the
gudeline, policy, or company manua describing such document destrction program.
9. If you refuse to respond to any Data Request by reason of a clai of privilege,
confidentiality, or for any other reason, state in wrtig the type of privilege claimed and
the facts and circumstaces you rely upon to support the claim of privilege or the reason
for refusing to respond. With respect to requests for documents to which you refuse to
respond, identify each such document, and specify the number of pages it contains.
Provide: (a) a brief description of the document; (b) date of document; (c) name of each
author or preparer; (d) name of each person who received the document; and (e) the
reason for witholdig it and a statement of facts constitutig the justification and basis
for witholding it.
PAGE 3 - INUSTR CUSTOMERS OF NORTHWEST UTILITIES' FIRST SET OF
DATA REQUESTS TO AVISTA
StafCPR_011 Attchment B Page 254 of 264
10. Identify the person from whom the information and documents supplied in response to
each Data Request were obtained, the person who prepared each response, the person
who reviewed each response, and the person who wil bear ultimate responsibility for the
trth of each response.
11. If no document is responsive to a Data Request that calls for a document, then so state.
12. These requests for documents and responses are contiuing in chaacter so as to requie
you to fie supplementa answers as soon as possible if you obtain fuer or different
inormation. Any supplemental answer should refer to the date and use the number of the
original request or subpart thereof.
13. Whenever these Data Requests specifically request an answer rather thn the
identification of documents, the answer is required and the production of documents in
lieu theroofwil not substitute for an anwer.
14. Please provide the responses to these data requests by Wednesday, March 4,2009, to:
Donald W. Schoenbeck
RCS, Inc.
900 Washigton Street
Suite 780
Vancouver, WA 98660
E-Mail: dws~r-c-s-inc.com
S. Braley Van Cleve
Davison Van Cleve, P.C.
333 S.W. Taylor
Suite 400
Portland, OR 97204
mail~dvclaw.com
PAGE 4 - INUSTRIAL CUSTOMERS OF NORTHWEST UTILITIES' FIRST SET OF
DATA REQUESTS TO AVISTA
StafCPR_011 Attachment B Page 255 of 264
II. DATA REOUESTS
1.1 With regard to the testiony of Mr. Morrs, page 5, lines 23 to 31, please provide a
complete copy of the Brattle Group report.
1.2 With regard to the testiony of Mr. Storro, page 8, lines 1 to 11, please provide a copy of
all documents associated with the sale of the 400,000 metrc tons of credits at an average
price of $6.44 per ton. Also explain how and when the revenue from the sale(s) was
flowed though the ERM.
1.3 With regard to the testiony of Mr. Storr, page 8, lines I to 11, please provide a copy of
all documents indicatig the curent value of CCX credits and the number of credits
available for sale (either actul or estimated) for 2007, 2008 and 2009.
1.4 With regard to the testimony of Mr. Storro, page 10, lines 1 to 3, please provide a copy of
all the documents noted in ths sentence.
1.5 With regard to Exhbit RLS-4, page 3 of 7, please provide an explanation or update of the
curent plans for directly connectig the Lacaster plant to the A vista tranmission
system.
1.6 With regard to Exhbit RLS-5, page 24 of3l, please provide an explantion of how green
house gas costs are accounted for under the tollg agreement and the valuation modeling
done by Thorndie Lading.
1.7 With regard to Exhbit RLS-5, page 24 of 3 1, please provide the key assumption table for
each year of the analysis. (That is though the year 2026.)
1.8 With regard to Exhbit RLS-5, page 24 of 3 1, please provide the Appendix C analysis
(exhibit pages 28,29 and 30) for each scenario using a constat 201 1 market heat rate
value. For example, the Base Case analysis would use a market heat rate of 8,526
BTU/kWh for every year (2010 thugh 2026) and the Low Case would use a value of
8,128 BTU/kWh. Ifpossible, provide the analysis in an electronic spreadsheet (~,
EXCEL) along with all supporting files.
1.9 With regard to Exhbit RLS-6, page 13 of 14, please provide Table No. lOin an
electronic spreadsheet~, EXCEL) along with all supporting files.
1.10 With regard to the testiony of Mr. Kalch, page 6, lines 18 to 19, please update and
extend the fuel price EXCEL file (Fuel Price WorkSheet_120l08.xls) to the most recent
forward price date available. Also, please explain the source for all forward prices (both
electrc and gas).
1.11 With regard to the testiony of Mr. Kalich, page 7, lines 4 to 6, please provide a
complete copy of the study, if possible in electronic form.
1.12 With regard to the testiony of Mr. Kalch, page 8, Table No.2, please explain the
source and price of gas for the Lacaster genertig facility used for deriving the
normaled test period cost.
PAGE 5 - INUSTRI CUSTOMERS OF NORTHWEST UTILITIES' FIRST SET OF
DATA REQUESTS TO AVISTA
StafCPR_011 Attachment B Page 256 of 264
1.13 With regard to the workpapers of Mr. Kalich, please provide an update to the short term
trsaction EXCEL file (ST Deals as of 12-01-08.xls) reflecting any additional
trsactions executed for delivery (or receipt) durng 2010.
1.14 With regard to the workpapers of Mr. Kalich, please provide an update to the Colstrp
performance EXCEL file (Colstrp Performance 1996-2007.xls) so that it includes 2008.
1.15 With regard to the workpapers of Mr. Kalich, the EXCEL fie entitled colstrip jùel
forecasts 12-11-08.xls, please provide in a similar monthy format the actual fuel costs
for 2008 and 2009 to date.
1.16 With regard to the workpapers of Mr. Johnson staing with the Priest Rapids Project
costs along with other facilities (P 10 though P 19), please provide these workpapers in
EXCEL spreadsheets with all formulae intact.
1. 1 7 With regard to the workpapers of Mr. Johnson for the WN-3 costs, please provide the
P24 workpaper in an EXCEL spreadsheet along with all supportg documentation.
1.18 With regard to the workpapers of Mr. Johnson for Lancaster trsporttion expene,
please provide the P67 workpaper in an EXCEL spreadsheet along with all supportg
documentation.
1.19 With regard to the testiony of Ms. Knox, page 17, lines 9 and 10, please provide the
hourly loads for each Schedule 25 customer for the 12 months ended September 2008 in
an EXCEL spreadsheet.
1.20 With regard to the testimony of Ms. Knox, page 21, lines 1 though 6, please provide the
class contrbution to the 100 highest system peak hours for each class in an EXCEL
spreadsheet. At a mium, please include the system peak load, date and time of each
of the 100 hours.
1.21 Please provide a copy of A vista's data responses to requests of all other paries.
PAGE 6 - INUSTRIL CUSTOMERS OF NORTHWEST UTILITIES' FIRST SET OF
DATA REQUESTS TO AVISTA
StafCPR_011 Attachment B Page 257 of 264
BEFORE THE
WASIDNGTON UTILITIES AN TRNSPORTATION COMMISSION
WASHINGTON UTILITIES AN
TRASPORTATION COMMISSION,
Complaiant,
v.
A VISTA CORPORATION d//a
A VISTA UTILITIES,
Respondent.
UE-090134
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)
)
)
)
)
)
)
)
)
THE INUSTRI CUSTOMERS
OF NORTHWEST UTILITIES'
SECOND SET OF DATA REQUESTS
TOAVISTA
Dated: April 1, 2009
Please provide the responses to these data requests by Wednesday, April 15,2009, to:
Donad W. Schoenbeck
RCS, Inc.
900 Washigton Street
Suite 780
Vancouver, W A 98660
E-Mail: dws§r-c-s-inc.com
DATA REQUESTS
S. Braley Van Cleve
Davison Van Cleve, P.C.
333 S.W. Taylor
Suite 400
Portland, OR 97204
mail§dvclaw.com
2.1 With regard to Avista's response to data request Staff-044, addressing the Rathdr hot
gas path maintenance amount, why isn't the Company amortizing this expense for rate
makg puroses based on the service hours of the required maintenance interval?
2.2 With regard to Avista's response to data request Staff-044, Attachment A, has the
Company updated the estimated cost amount of $1.2 milion for Rathdrm's hot gas path
maintenance?
2.3 With regard to Avista's response to data request Staff-OM, Attchment H, please provide
an update to the EXCEL spreadheet including the actul costs for all months of 2008
and any updates to the forecast of operation and maintenance costs for 2009 and 2010.
PAGE I - INUSTRIAL CUSTOMERS OF NORTHWEST UTILITIES' SECOND SET OF
DATA REQUESTS TO AVISTA
StafCPR_011 Attachment B Page 258 of 264
2.4 With regard to Avista's response to data request Staff-048, please provide an electronic
copy of all workpapers, including AURORA files, used fo support the Noxon Rapids
Unit #3 upgrade impact.
2.S With regard to Avista's response to data request Staff-049, please provide an electronic
copy of all workpapers, includig the AURORA files and daily forward gas prices, used
to support the impact from updating the gas prices used in AURORA.
2.6 With regard to Avista's response to data request Staff-OSO, please provide an electronic
copy of all workpapers, including AURORA fies, used to support the load reduction
sensitivity. In addition, please provide a complete explanation on how this sensitivity
was performed. For example, did the Company just reduce the A vista portfolio load by
1 % or did it reduce the entire regional loads used in AURORA by 1 %?
2.7 With regard to Avista's response to data request Staff-OS 1, please provide an electronic
copy of all workpapers, including AURORA fies, used to support the hydro fiterig
amount.
2.8 With regard to workpaper TLK-E-149, please provide a copy ofthe Company's system
loss study used to support the trsmission, priar and secondar loss factors
differentiating the losses that occur over lines (conductors) from those which occur
though voltage trsformation (transformers) for each of these categories. Ifno such
study exists, please provide an estimate based upon tyical transformer loss factors for
each category.
PAGE 2 - INUSTRI CUSTOMERS OF NORTHWEST UTILITIES' SECOND SET OF
DATA REQUESTS TO A VISTAStafCPR_011 Attachment B Page 259 of 264
DATA REQUEST NOS. 1-14 FROM THE NW ENERGY COALITION ("NWEC" OR
"COALITION") TO AVISTA
Docket Nos. UE-090134, UG-090135 and UG-0605l8 (Consolidated)
The following data requests are directed to Avista. The word "Mechanism" means and refers to
Avista's Pilot Decoupling Mechasm. The words "Approval Date" mean and refer to Januar 1,
2007, when accounting deferrls under the Mechansm were authoried to begi.
NWEC - i. Please provide copies of wrtten communications, reports, analyses, presentations,
and conclusions that A vista made to, or received from, ratig agencies since the Approval Date,
and that involved the Mechansm or one of the progrs that A vista identified in its responses to
Public Counsel Data Request Nos. 283-285.
NWC - 2. Please provide copies of wrtten communcations, reports, anyses, presentations,
and conclusions that were made by or to Avista's senior management since the Approval Date,
and tht involved the Mechansm or one of the progrs that A vista identified in its responses to
Public Counel Data Request Nos. 283-285.
NWC - 3. Please provide copies of wrtten communcations, reports, anyses, presentations,
and conclusions that were made to Avista's Board of Directors or to a Board committee since the
Approval Date, and that involved the Mechansm or one of the progrs that A vista identified in
its responses to Public Counel Data Request Nos. 283-285.
NWC - 4. Please provide copies of the meeting minutes for Avista's Board and its Board
committees if such minutes reference the Mechasm or one of the progrs that A vista
identified in its responses to Public Counsel Data Request Nos. 283-285.
NWC - 5. Since the Approval Date, has the Mechansm served by itself or in conjunction
with other factors to determine, shape, or otherwise infuence a decision by A vista to tae a
paricular fiancial, budgeta, programatic, or strtegic coure of action? If so, please
describe the decision tht A vista made and explain how the Mechansm served to determe,
shape, or inuence that decision.
NWC - 6. Since the Approval Date, has Avista prepared or commissioned anlyses, report,
studies, or related documents tht assess the Mechanism's implementation, merits, success,
impacts, and/or cost? If so, please provide copies of all such documents and explain why Avista
prepared or commissioned them.
StafCPR_011 Attachment B Page 260 of 264
NWC - 7. Since the Approval Date, has A vista prepared or commssioned analyses, reports,
studies, or related documents that assess the Mechansm either in the context of decoupling
mechasms tht other utilities employ or in the context of other potential decoupling
mechanisms (whether or not employed by other utilities)? If so, please provide copies of all such
documents and explai why A vista prepared or commissioned them.
NWC - 8. The sub-pars in ths data request refer to the letter dated December 17,2008 that
Bruce Folsom with A vista wrote to Nancy Hirsh with the Coalition regarding A vista's energy
efficiency efforts. Mr. Folsom copied his letter to the service list in Docket No. UG-060518.
a. Please update the inormation provided in the letter to the present, i.e., from
December 17,2008 to the date of Avista's response to this data request.
b. Please explain when and why A vista joined each organation identified on the
bottom of Page 1 of the letter.
c. Please explain how, if at all, each organation identified on the bottom of Page 1 of
the letter advances energy efficiency or natural gas effciency requirements to reduce
greenhouse gas emissions.
d. Please describe the support tht A vista provides to each organation identified on the
bottom of Page 1 of the letter, e.g., fiancial, managerial, advisory, strtegic, or some
other tye of support.
e. Please elaborate on the "increased support" that A vista provides or has provided to
each organzation identified on the top of Page 2 of the letter. From what level has
the support increased, and to what level?
f. Please explain how, if at all, each organation identified on the top of Page 2 of the
letter advances energy efficiency or natual gas efficiency requirements to reduce
greenhouse gas emissions.
g. Please explain how, if at all, an increase in the direct use of natual gas (see
description of American Gas Association and Nortwest Gas Association on the top
of Page 2 of the letter) serves to advance energy efficiency or natul gas efficiency
requirements to reduce greenhouse gas emissions.
NWC - 9. Please identify and describe the most signficant obstacles, if any, tht Avista
faced as it expanded its investments since the Approval Date in cost-éffective gas effciency
programs. How, if at all, did the Mechansm assist or hider Avista in addressing these
obstacles?
NWC - 10. Please identify and describe the most significant obstacles, if any, tht Avista
expects to face as it plan its investments in cost-effective gas effciency programs though the
nea futue (i.e., though 2015). Assumng that the Commssion approves the Mechasm on a
StafCPR_011 Attachment B Page 261 of 264
peranent basis, how if at all would the Mechansm assist or hider A vista in addressing these
obstacles?
NWEC - 1 1. Please provide copies of any documents tht A vista has prepared or reviewed
since the Approval Date and that reference or otherwse relate to investments by other utilities in
gas and electrc effciency progrs, respectively. For each such utility, please sumarie the
simlarties and/or differences between the effciency progr(s) offered by tht utility and the
efficiency program(s) offered by Avista.
NWC - 12. Does A vista contend tht it is a leader in the gas utility industr in terms of its
investments in, and/or its commtment to, gas effciency progras? If so, please explain the
basis for ths leadership position and indicate the performance metrcs, if any, that A vista uses to
determine ths leadership position.
NWEC - 13. Does A vista contend tht it is a leaer in the electrc utility industr in terms of its
investments in, and/or its commtment to, electrc effciency programs? If so, please explai the
basis for ths leadership position and indicate the performance metrcs, if any, that A vista uses to
determine ths leadership position.
NWC - 14. Please provide the therm savings from Avista-sponsored DSM programs in
Washigton State in total, and by customer class and/or rate schedule, for each year 2000,2001,
2002, and 2003.
&aff_PR_011 Attachment B Page 262 of 264
DATA REQUESTS EP 2-16 TO A VISTA
FROM THE ENERGY PROJECT
Case No UE-090134, UG-090135 andUG-060Sl8
The following questions are directed to Avista's testimony and evaluation of its Decoupling
Mechasm:
EP-2. Provide the monthy and anual average usage for natual gas customers who
are identified as "limited income" as that term is defined in the Evaluation for
200S though 2008 and 2009 to date. In your response, identify the program
or basis for your identification of these customers as "limited income." Please
provide this inormation in electronic spreadsheet file format with formulas
intact.
EP-3. Provide the basis for your use of the average per therm usage for limted
income customers in your Evaluation (Table KlO), including but not limted
to, the source of the data, whether ths average includes all parcipants or
some statistical sampling (and, if so, describe in detail the sampling
methodology), for what year this average represents, and whether ths average
is weather normalized (and, if so, the method used to normalize ths
information). .
EP-4. Describe any difference, if any, to calculate the limited income average usage
compared to the average usage for non-limited income residential customers. .
EP-S. Provide any information in Avista's possession concerning the applümce
penetration for your limited income natual gas customer compared to
residential customers generally.
EP-6. With respect to the limited income customers known to Avista and relied upon
to calculate the usage and bil impact inormation in the Evaluation, provide a
distrbution cure for these customers based on anual usage and average
monthy bil amount for each calendar year of 200S though 2008 so tht it
wil be clear how many or what percentage of these customers fall into the
following categories: low usage, average usage, and high usage (and the same
for bil amount).
Sæff_PR_011 Attachment B Page 263 of 264
EP-7. Does Avista agree tht limited or low income customers tyicaly move more
frequently than higher income residential customers?
EP-8. Based on the same technque used in the Evaluation to identify the percentage
of lited income customers sered by Avista (which used a l2S% of federa
povert guidelies defintion), provide the same inormation assumg tht
low income is defied as 17S% of federal pover gudelies.
EP-9. Explain why the DSM savigs for limited income customers in Table K2-A of
the evaluation report shows a figue for 200S that signficantly in excess of the
savings for any subsequent year.
EP-10. Are the increased DSM savings for lited income customers shown for 2008
due to increased number of customers served by the DSM measures or a
chage in the measurs tht are delivered? Please explain.
EP-11. With regard to Table KI0, please identify whether the Schedule 10 1 average
customer reflects only residential customers in ths Schedule. If not, please
provide the Table using a comparson to residential customers only.
EP-12. Does Avista have any inormation or theory as to why the Limited Income
customer usage is lower th the average Schedule 101 usage (beyond the
possible explanations listed in the Evaluation Report on page 82)?
EP-13. Do Tables KII-A, K11-B, and Kl L-C data reflect all Schedule 101 customers
or only Schedule 101 residential customers? If the former, please provide the
table using Schedule 101 residential customer data.
EP-14. Does Table K12 data reflect all Schedule 101 customers or only Schedule 101
residential customers? If the former, please provide the table using Schedule
101 residential customer data.
EP-lS. Does Avista receive any report from its CAP agencies as to their expenditure
of the A vista DSM program fudig and resultig therms saved on an anual
(or lesser) basis? If so, provide a copy of these reports from each CAP agency
for the 200S-2006, 2006-2007, 2008-2009 progr years.
EP-16. Identify the average monthy and average bil impact for an average
residential Schedule 101 customer for the recovery of the LIR surcharge
for 200S, 2006, 2007, and 2008.
~aff_PR~011 Attchment B Page 264 of 264