20100519AVU to Staff 11, A, C.pdf

Xan Allen
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Jean Jewell
Wednesday, May 19, 201011 :19 AM
Xan Allen
FW: Avista's Responses to IPUC Staff Production Requests - 5/19/10
Staff_PR_011 Attachment C.pdf; Staff_PR_011.doc; Staff_PR_011 Attachment A.pdf
From: Kimball, Paul (mailto:PauI.Kimball(§avistacorp.com)
Sent: Wednesday, May 19, 2010 11:11 AM
To: Don Howell; Kris Sasser; peter(grichardsonandoleary,com; greg(§richardsonandoleary,com;
howard . ray(§clearwaterpa per ,com; joe(§mcdevitt-miler ,com; crowleyla(9aol.com; rowena(§idahocan .org;
leean n(§ nwfco ,org; bmpu rdy(§ hotma iI,com; botto(§ ida hoconservation ,org; km iIer(§sna keriverallance ,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 IPUC Staff Production Requests - 5/19/10
May ¡9, 2010
Idaho Public Utilities Commssion
Krstine A. Sasser
~~Ct:::i-e472 W. Washington St.
Boise, il 83720-5918 \0
Attn: Donald L. Howell, II
p::.......c(.
Re: Production Request of the Commission Staff in Case Nos. A VU-E-10-0l and A VU-G-10-01
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:
Staff PR 11 (Part 1 of 2 (Part 2 is Attachment B))
C:C:Staff_PR_011 Attachment C.pdf~~ c:c:StafCPR_011.doc~~ C:C:StafCPR_011 Attachment A.pdf~~
If there are any questions regarding the attached information, please contact me at [phone] or via e-mail
at pau1.kimball((avistacorp.com
Than you,
Paul Kimball
Senior Reguatory Analyst
State & Federal Regulation
A vista Corporation
1411E. Mision Ave, Box 3727
i
Spokane, W A 99220-3727
[phone] diect
[phone] cell
paul.kimball(Qavistacorp.com
2
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
JURSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-10-01 / A VU-G-10-01
IPUC
Production Request
Staff-Oll
DATE PREPARD:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
05/14/2010
N/A
Paul Kimball
State & Federal Reg.
[phone]
REQUEST:
Please provide a copy ofthe data requests received by A vista from other jursdictions pertaining to
general rate cases currently underway and/or concluded within the last 12 months.
RESPONSE:
See attachment StafCPR_016 Attachment A for a list of the data requests received for the current
Washington general rate case.
See attachment StafCPR_016 Attachment B for a list of the data requests received within the last
12 months for the Washington general rate case concluded in 2009.
See attachment StafC PR _016 Attachment C for a list of the data requests received within the last
12 months for the Oregon general rate case concluded in 2009.
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 1-26 to Avista
Apn19,2010
Page 1
UTC STAFF DATA REQUEST NO.1:
a) Please provide copies of any and all data requests submitted to you by any par to
ths proceedig and your corresponding responses to those data requests.
b) Please provide copies of any and all data requests submitted to you in the Idao
Public Utility Commission Case Numbers A VU-E-1 0-0 1 and A VU-G-1 0-01.
UTC STAFF DATA REQUEST NO.2:
a) Please provide a Char of Accounts for A vista Utilities of all accounts (detaed by
sub-account) with a balance durng the test year in Excel or Access format.
b) Please provide a Chart of Accounts for A vista Corporation of all accounts (detailed
by sub-account) with a balance durng the test year in Excel or Access format.
UTC STAFF DATA REQUEST NO.3:
Please provide a columnar, 12-month detailed (by sub-account) operatig income statement
in Excel format for A vista Utilties' electric 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.4:
Please provide a colum, 12-month detailed (by sub-account) operating income statement
in Excel format for A vista Utilities' natu gas opertions 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.
UTe STAFF DATA REQUEST NO.5:
Please provide a colum, 13-month detailed (by sub-account) portayal of electrc and gas
utility plants and accumulated depreciation & amortzation in Excel format for A vista
Utilities for the test penod, with the 14th colum showing the average of monthy averages
(AM) for each sub-account, with a columar total for each priar FERC account. The
15th Colum should show the Average Monthly Average Balance from the prior calenda
StafCPR_011 Attachment A Page 1 of62
Dockets DE-100467 and UG-1 00468
UTC Staff Data Request Nos. 1-26 to Avista
Apn19,2010
Page 2
year with the 16th colum showing the chage amount and the 17th colum showing the
percentage change from the prior calenda year.
UTC STAFF DATA REQUEST NO.6:
a) Please provide a column, 13-month detailed (by sub-account) consolidated balance
sheet in Excel format for A vista Corporation for the test penod, with the 14th colum
showing the average of monthy averages (AM) for each sub-account, with a
colum total for each priar FERC account. The 15th Colum should show the
Averge Monthy Average Balance frm the pnor calendar year with the 16th colum
showing the change amount and the 17th colum showing the percentage change
from the pnor calenda year.
b) For each Avista utility and non-utilty entities' balance sheet used in the
consolidation, please provide a colum, 13-month detaled (by sub-account)
balance sheet in Excel formt for Avista entities for the test period, with the 14th
colum showing the average of monthy averages (AM) for each sub-account, with
a columar total for each priar FERC account. The 15th Colum should show the
Average MontWy Average Balance from the pnor calendar year with the 16th colum
showing the change amount and the 17th colum showing the percentage change
from the prior calenda year.
UTC STAFF DATA REQUEST NO.7:
Please provide a colum, 12-month detailed (by sub-account) consolidated financia1
income statement in Excel format for Avista Corporation for 2009, with the 13th colum
showing the tota for each sub-account, and the 14th colum showing the budgeted amount
for each sub-account. The 15th colum should show the varance amount and the 16th
colum showing the varance percentage. For eah priar FERC account provide a
columar tota.
UTC STAFF DATA REQUEST NO.8:
Please provide all officers' employee numbers, narnes,job titles, detailed job descriptions,
responsibilities, base salares, and other compensation by year begig with calendar year
2008.
UTC STAFF DATA REQUEST NO.9:
Please provide detais of al bonus plans included in the test penod and the cntena and goals
used to grant employee bonuses.
StafCPR_011 Attachment A Page 2 of 62
Dockets UE-100467 and UG-100468
UTC Sta Data Request Nos. 1-26 to Avista
April 9, 2010
Page 3
UTC STAFF DATA REQUEST NO. 10:
Please provide all officers' salaries and other compensation for the last two years for each
offcer by month, and please itemize by base salar, bonuses, and benefits, along with the
amount included in test year and the amount paid for by shareholders. Please provide the
expenditue distrbution into vanous operating and capita accounts.
UTC STAFF DATA REQUEST NO. 11:
Please explain the basis for all officers' salary increases from 2007 to 2010. Also, please
provide all studies and/or sureys used in the determination of the salar levels.
UTC STAFF DATA REQUEST NO. 12:
Please provide a curent organiational char for A vista that shows each of its subsidiaries
with the names and positions of executive officers.
UTC STAFF DATA REQUEST NO. 13:
Please provide a copy of the Company's weather normalization model, including all
supportng 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. 14:
Please provide a listig of all penalties and fines included in the test year, citing the account
it is located in, the payee, and the amount.
UTC STAFF DATA REQUEST NO. 15:
Please provide a listing of any costs included in the test year related to sportg or
entertinent events, includig but not limited to season tickets or sky boxes citing the
account it is located in, the payee, and the amount. If applicable, please include any
explanation as to the business purose.
UTC STAFF DATA REQUEST NO. 16:
Please provide a listing of all charitable contrbutions, including naes and amounts,
included in the test year, citing the account it is located in, the payee, and the amount.
StafCPR_011 Attchment A Page 3 of 62
Dockets DE-I 00467 and UG-100468
UTC Staff Data Request Nos. 1-26 to Avista
April 9, 2010
Page 4
UTC STAFF DATA REQUEST NO. 17:
Please provide a listig of dues or membership fees included in the test year citing the
account it is located in, the payee, and the amount, and please include in the response the
percent of dues or fees related to lobbyig or political activities.
UTC STAF DATA REQUEST NO. 18:
a) Please provide a listig of new large e1ectnc (Schedule 25) and gas (Schedule
121/122) customers tht have staed receiving serice with the last 12 months 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.
b) Please provide a listig of new large customers that wil begi receiving service
with the next 12 month. Provide: nae of customer, expected anual revenue
amounts and expected anua usage levels.
c) Please provide a listig and the related documents to any specific "power supply"
arangements or acquisitions tht have been made related to any new large customers
with the last two years.
UTC STAFF DATA REQUEST NO. 19:
a) Please provide a copy of the corporate federal ta retu includig all supporting
schedules/exhbits and for 2007,2008 and 2009.
b) Please provide the detailed reconciliation of reported net income with taxable income
for federl income taes for each ta ýear in par a) of ths request.
c) Please provide a copy of all FIT accrul workpapers used as basis for the 2009 tax
year expenditues includig revisions and updates booked in 2010.
d) Please provide all pnor period FIT amounts recorded durg the test year including
amounts, description, sub-account, and allocation to W A.
UTe STAFF DATA REQUEST NO. 20:
Please explain any chages in accounting for GAA or FERC in the last thee years. Include
a copy of any narative incorporated in the Company's notes to its financial statements and
or FERC anua reports contemporaeous with the chage in accounting.
StafCPR_011 Attachment A Page 4 of 62
Dockets DE-100467 and UG-100468
UTC Staff Data Request Nos. 1-26 to A vista
April 9, 2010
Page 5
UTe STAFF DATA REQUEST NO. 21:
Re: Vegetation Management
a) Please provide the actual anual vegetation mangement expenditues incured by
the Company for the last thee years beginng 2007, by junsdiction (Washington
and Idao) and by fuction (transmission and distrbution);
b) Please provide the actul monthly vegetation mangement expenditues incured by
the Company for the last thee year beging 2007, or latest available, by
. junsdiction (Washigton and Idaho) and by fuction (transmission and distrbution);
c) Please provide a budget versus an actul vanance anysis for the expenditues
requested in par b. of ths data request.
UTC STAFF DATA REQUEST NO. 22:
Re: Working Capital
a) Please provide all documents submitted by the Company, including but not limited
to, testimony, exhibits, legal briefs, data request responses, and workpapers that
propose, support, or oppose workig capital adjustments in any regulatory
proceedings, past or present, involving the Company.
b) Please provide copies of all orders or decisions by reguatory agencies related to sub-
par (a) of ths data request.
UTC STAFF DATA REQUEST NO. 23:
Re: Working Capital
Referrng to Company witness Ms. Andrews's testiony Exhbit No. _ (EMA-1T), page
25 (lines 22-26), page 26 (lines 1-8), and page 43 (lines 11-21):
a) Please provide any and all studies, analyses, and supporting documents validatig
that for A vista specifically there are approximately 45 days that elapse between
payments for operating expenses associated with providing service to customers and
receipt of payments from customers.
b) Please provide any and all studies, analyses, and supportng documents proving that
A vista investors supply the fuds to finance operations durg the payments lag
referred to in sub-part (a) of ths data request.
StafCPR_011 Attachment A Page 5 of 62
Dockets DE-I 00467 and UG-1 00468
UTC Staff Data Request Nos. 1-26 to Avista
April 9, 2010
Page 6
UTC STAFF DATA REQUEST NO. 24:
Re: Working Capital
Did the Company perform any studies, anlyses, or evaluations that compare the proposed
"45" day method with other methods to calculate working capital? If so, please provide
copies of such documents. If not, please explain the reason and basis of the Company's
decision.
UTC STAFF DATA REQUEST NO. 25:
Re: Working Capital
A vista is proposing to include in Washigton e1ectnc and gas rate bases approximately $24
milion and $4 million respectively of workig capita.
a) Are those amounts purorted to be consistent with the other average of monthy
averages (AM) rate base components? Please explain how those workig capital
amounts satisfy consistency with the AM rate base presentation.
b) Considerig that the proposed workig capital additions to rate base were calculated
using the" 1/8 of O&M" formula, is it the Company's position that the working
capital requiements of the Company for each of the eight 45-day penods are equa
and not afected by the seasonality of e1ectnc and gas utility services provided?
Please explai how such position is appropriate and reaonable. If the response is not
affiative, please provide the amounts for each 45-day penod that reflect
differences due to seasonal impacts.
UTC STAFF DATA REQUEST NO. 26:
Re: A vista Corporation Financial Statements
Please provide a reconciliation of the 2008 and 2009 fiancial statements of A vista as
reported in pages 110-119 ofFERC Forms 1 and 2 and as reported in SEC lO-K for the
same periods. Please explain the differences.
Please provide all responses in hardcopy and electronic formats, with all links and
formulas intact.
GREGORY J. TRAUT
Assistat Attorney General
Staff_PR_011 Attachment A Page 6 of 62
Dockets DE-100467 and UG-100468
UTC Staff Data Request Nos. 27-28 to Avista
Apnl13,2010
Page 1
UTC STAFF DATA REQUEST NO. 27:
Re: Adj. j. Andrews, Exhibit No._(EMA-3)
a. Please provide a descnption of the propert tax cycle for each of the states in which
A vista is taxed. Please include dates and any additional inormation that wil help
staff understad the tax process for each of the jursdictions.
b. Please provide updates to all propert ta calculations as they occur.
UTC STAFF DATA REQUEST NO. 28:
Re: Andrews Workpapers "Estimate #2a 20100202," Tab "REVISED 2010 Proptax
forecast."
a. For al the estiated figues in 2009 (colum J), please provide a date at which tie
they wil be expected to reflect an actul figue.
b. For 2009 (colum J), please provide the source documents and calculations to
substatiate the hard numbers entered in ths spreadsheet.
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment A Page 7 of 62
Dockets DE-100467 and UG-100468
UTC Staf Data Request No. 29 to Avista
Apn115,2010
Page 1
UTC STAFF DATA REQUEST NO. 29:
Re: Adj. s. Andrews, Exhibit No._(EMA-2)
Please describe the methodology each jurisdiction used to assess the value of Avista's
operatig assets durg the test year.
GREGORY J. TRAUTMAN
Assistat Attorney General
Staff_PR_011 Attachment A Page 8 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 30-31 to Avista
Apri121,2010
Page 1
UTC STAFF DATA REQUEST NO. 30:
Please provide the data tht was used in estiating the sensitivity factors for weather
normalizing customer usage and revenue in the curent rate case, including all the raw data
sheets used in the calculation, and degree day data and meter inormation.
UTC STAFF DATA REQUEST NO. 31:
Please provide the support for the calculation of the 2008 weather sensitivity factors that is
mentioned at pages 4 and 5 of Tara Knox's testimony, and that was provided in workpaper
2008_Factors_ WC, including degree day data and meter information.
GREGORY J. TRAUTMAN
Assistant Attorney General
StafCPR_011 Attachment A Page 9 of 62
Dockets UE-100467 and UG-100468
UTC Staf Data Request Nos. 32-48 to Avista
Apn123,2010
Page 1
UTe STAFF DATA REQUEST NO. 32:
~Re: Service Quality and Reliabilty
Please descnbe the Company's curent goals and/or stadads regardig restoration of
service followig an e1ectncal outage, applicable to the state of Washigton. Include in
your response:
a. The Company's perormance tagets for: (1) mobilizing crews and materials; (2)
getting them to the outage location; (3) accurtely assessing the daage; and (4)
restonng serviçe when an outage has been reported;
b. Monthy data for 2006 though 2009, sumaring the total average tie to restore
an outage, broken down if possible by the following categones: (1) mobilize crews
and materials; (2) correctly assess the daage; (3) get the crews and matenals to the
outage location; and (4) respond and restore serice after an outage has been
reported;
c. Please include a copy of any document identifyg any of these goals, and please
defie any exceptions applicable to these goals or stadads.
UTC STAFF DATA REQUEST NO. 33:
Re: Servce Quality and Reliabilty
Please describe the Company's current policies regardig meetig service appointments,
applicable to the state of Washigton. Include in your response the period of time the
Company tells a customer tht a serice person wil appea for an appointment (i.e., between
noon and 4 p.m., or 2 hour, 4 hour, etc.), and describe:
a. The taget the company sets for arvig at appointments withi the agreed upon time
penod.
b. The percentage of serice appointments kept with the agreed upon time period.
c. Monthy data for 2006 though 2009, sumnzing the tota number of service
appointments, broken down if possible by appointments tht were met on time and
the number missed.
StafCPR_011 Attachment A Page 10 of 62
Dockets UE-100467 and UG-100468
UTC Staf Data Request Nos. 32-48 to A vista
Apn123,2010
Page 2
UTC STAFF DATA REQUEST NO. 34:
Re: Servce Quality and Reliabilty
Please descnbe the Company's performance target to intiate e1ectnc 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 existing address (i.e., meter already installed).
b. Monthy data for 2006 though 2009 regardig the total number of service intiations
broken down if possible by the requests for service at existig addresses that are
turned on with the established taget.
UTC STAFF DATA REQUEST NO. 35:
Re: Servce Quality and Reliabilty
Please describe the Company's performance target to estimate the date for service to new
customers (line extension) from the time that all the required inormation is provided by the
applicant, applicable to the state of Washigton. Include in your response:
a. Monthy data regarding the total number of e1ectnc line extensions made from 2006
though 2009 broken down if possible by the number and percentage of lie
extensions completed with the estiate provided to the customer.
UTC STAFF DATA REQUEST NO. 36:
Re: Service Quality and Reliabilty
Please provide the Company's policies for improving service in areas with underperforming
e1ectnc 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 total number of underperformg circuits and their location;
d. A descnption of the Company's project pnoritiation process to schedule a fix to the
underperorming circuit.
StafCPR_011 Attachment A Page 11 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 32-48 to Avista
Apri123, 2010
Page 3
UTC STAFF DATA REQUEST NO. 37:
Re: Service Quality and Reliabilty
Please provide the Company's taget time for anwerg calls at the customer service centers
that serve Washigton customers. Provide the cal answer times by month from 2006
though 2009, broken down if possible by calls answered with the taget time.
UTC STAFF DATA REQUEST NO. 38:
Re: Service Quality and Reliabilty
Please provide:
a. The Company's policies (applicable to Washigton) to preclude equipment faiure
(i.e., service age replacement evaluation cntena or schedule; e1ectncal1oad above
liits, reduced insulation quaities, etc.). Include in your response an explanation
regarding Company policy on use of equipment until it fails, and identify what
equipment is subject to the "use equipment until failure" policy.
b. The proporton of the frequency of sustaed interrptions caused by equipment
failure. How many of the equipment failures were beyond the replacement
evaluation critena or schedule?
UTC STAFF DATA REQUEST NO. 39:
Re: Service Quality and Reliabilty
Does the Company perorm customer service sureys to determine 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 inquies, etc.)?
c. Please explain the extent to which any of the sureys produced apply to service in
Washigton.
Smff_PR_011 Attachment A Page 12 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 32-48 to A vista
Apri123,2010
Page 4
UTC STAFF DATA REQUEST NO. 40:
Re: Servce Quality and Reliabilty
Please provide the number and percentage of Washigton customers the Company
disconnected for non-payment from 2006 through 2009. Please provide the data on numbers
of customers on a monthy basis.
UTC STAFF DATA REQUEST NO. 41:
Re: Service Quality and Reliabilty
Please descnbe the Company's current method of managing the incidence of customer
complaints in Washigton. Please include in your response:
a. A descnption of each benchmark regarding complaint levels;
b. Complaint statistics for 2006 though 2009 by month and by tye;
c. Each complaint analysis, conclusions, and proposed actions to reduce complaint
levels.
UTC STAFF DATA REQUEST NO. 42:
Re: Service Quality and Reliabilty
Please provide any root cause anlyses of outage causes in Washigton prepared over the
last thee years.
UTC STAFF DATA REQUEST NO. 43:
Re: Service Quality and Reliabilty
Please provide the following as applicable to Washigton:
a. A sumar of the Company's vegetation mangement budget for the past 5 year
(i.e., 2005 - 2009). Include in your response a list of both programed budget and
actu expenditures each year.
b. The number of miles of line that were cleared/tred each year, and specify
whether the budget includes vegetation management both on and off the ROW
(right-of-way).
c. An explanation of whether the Company keeps separate vegetation management
records for trsmission lines and distrbution lines (i.e., can the company separate
the amounts budgeted for vegetation management for tranmission lies versus
distrbution lines)?
Staff_PR_011 Attachment A Page 13 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 32-48 to Avista
Apri123,2010
Page 5
UTC STAFF DATA REQUEST NO. 44:
Re: Servce Quality and Reliabilty
Please provide the SAII (system average interrption durtion index) time theshold for a
Major Event Day (TMED) using the IEEE 1366 stadard for 2000 to the present.
UTC STAFF DATA REQUEST NO. 45:
Re: Service Quality and Reliabilty
Please provide any data available on access issues that could impact SAIDI (system average
interrption durtion index) (i.e., fies, police investigations, floodig, etc), and explain
whether the Company tracks access issues separtely.
UTe STAFF DATA REQUEST NO. 46:
Re: Service Quality and Reliabilty
Does the Company have any data that indicates that climate chage is a factor for increasing
SAIDI (system average interrption durtion index)? If so, please provide that data.
UTC STAFF DATA REQUEST NO. 47:
Re: Service Quality and Reliabilty
Please provide the anual SAII (system average interrption durtion index), SAIPI
(system average interption frequency index), and CAII (customer average interrption
duration index) performance from year 2000 to present using the curent version of the IEEE
1366 Stadard calculation methods.
Note: The IEEE 1366 Stadard requires calculation of SAID I, SAIPI and CAIDI using the
following assumptions:
. All calculations are perormed on events that are sustained interrptions
. Sustained interrptions are those with a duration of more than five minutes
. Calculated values are normlized only by excluding events that exceed the time
theshold for a Major Event Day, called T MED.
SAII Penormance (avera2e minutes interrupted per svstem customer)
2009 2008 2007 2006 2005 2004 2003 2002 2001 2000
SAIDI
(IEEE
1366)
StafCPR_011 Attachment A Page 14 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 32-48 to A vista
Apri123,2010
Page 6
SAIFI Performance (~ercent of interrupted customers in system)
2009 2008 2007 2006 2005 2004 2003 2002 2001 2000
SAII
(IEEE
1366)
CAII Penormance (avera2e minutes of interruption per interrupted customer)
2009 2008 2007 2006 2005 2004 2003 2002 2001 2000
CAIDI
(IEEE
1366)
UTC STAFF DATA REQUEST NO. 48:
Re: Servce Quality and Reliabilty
Please provide the anual SAII (system average interrption duration index) and SAIFI
(system average interrption frequency index) performance from 2000 to present for each
Washigton circuit. Please provide a separate circuit code listing (i.e., code, county, etc).
e ormance IrcUl
CIRCuiT 2009 2008 2007 2006 2005 2004 2003 2002 2001 2000
SAIDIP ri b C' .t
er ormance ircUl
CIRCUIT 2009 2008 2007 2006 2005 2004 2003 2002 2001 2000
SAII P ti b C. .t
GREGORY J. TRAUTMA
Assistat Attorney General
StafCPR_011 Attachment A Page 15 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 49-54 to Avista
Apri126,2010
Page 1
Re: Low Income Rate Assistance Program
UTC STAFF DATA REQUEST NO. 49:
Please provide the low income rate assistace progr revenue and expenditues by month
for the test penod. (Generl ledger preferred.)
UTC STAFF DATA REQUEST NO. 50:
Please provide the low income rate assistace program anual revenue and expenditues for
2004 though 2009. Please provide the dollar and percentage amounts for CAP agency
adminstrtive costs and Company adstrative costs for the same tie penod.
UTC STAFF DATA REQUEST NO. 51:
Please explain how the expenes and lost revenues from the low income rate assistance
program are included in the Company's cost of service. Please provide FERC account
numbers and genera11edger account number.
UTC STAFF DATA REQUEST NO. 52:
What is the basis of the low income rate assistace surhage rate spread?
UTC STAFF DATA REQUEST NO. 53:
Please provide a copy of any report concerng the low income rate assistace program.
UTC STAFF DATA REQUEST NO. 54:
Re: Miscellaneous Restating Adjustments
Please provide the traction detail for the following account numbers and months for the
totals shown on Page 3 of3 of Avista's Response to Staff Data Request No. 3, Attchment
A (e1ectnc):
Account Month
908XX Customer Assistace Expenses March 2009, August 2009, December 2009
909000 Advertising Apn12009, August 2009
912000 Demonstrating and Selling Expenses May 2009, June 2009
913000 Advertising August 2009
921000 Office Supplies and Expenses May 2009
923000 Outside Services Employed Marh 2009, Sept. 2009, November 2009
930000 Miscellaneous Genera Expenses March 2009, July 2009, December 2009
StafLPR_011 Attachment A Page 16 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 49-54 to A vista
Apn1 26, 2010
Page 2
Please provide the traction detail for the following account numbers and months for the
totals shown on Page 2 of 2 of Avista's Response to Staff Data Request No.4, Attchment
A (natul gas):
Account Month
908XX Customer Assistance Expenses February 2009, March 2009, December 2009
909000 Adversing Apri12009, August 2009
912000 Demonstrtig and Selling Expenses May 2009, December 2009
913000 Adversing August 2009, November
921000 Office Supplies and Expenses Apn12009, August 2009, December 2009
923000 Outside Serices Employed March 2009, Sept. 2009, November 2009
930000 Miscellaneous General Expenses Janua 2009, October 2009, Dec. 2009
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment A Page 17 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 55-60 to Avista
Apn127,2010
Page 1
Re: Cost of Servce Study
UTC STAF DATA REQUEST NO. 55:
According to the Ninth Supplementa Order C1anfyg Commssion Order on Rate Design
in Dockets UE-920433, UE-920499 and UE-921262, page 11, fist pargrph, only service
drops and meters are classified as customer-related distnbution costs. Referrg to the
Direct Testimony of Tar Knox, line 17, footnote no. 8, Ms Knox included street lights as
customer-related distnbution costs. Please justify Ms, Knox's reasonig.
UTC STAFF DATA REQUEST NO. 56:
Please provide all assumptions used by Mr. Kalich in his calculation of demand
classification in his Exhbit 3, and the rationales for each individual assumption.
UTC STAFF DATA REQUEST NO. 57:
In Mr. Ka1ich' s Exhibit 3, Mr. Ka1ich used a 1 o percent discount rate to calculate the
1eve1ized capita costs. Please identify if ths 10 percent discount rate is also used in the
Company's other calculations (e.g., cost of capital).
UTC STAFF DATA REQUEST NO. 58:
Please state whether the Company's proposed method to allocate the demand portion of
production and transmission costs is supported by NARUC Cost Allocation ManuaL. If the
answer is yes, please explai in detaiL.
UTC STAFF DATA REQUEST NO. 59:
Has the Company's proposed method to allocate demand portion of production and
transmission costs been used by any other state commission? If the answer is yes, please
explain in detaiL.
UTC STAFF DATA REQUEST NO. 60:
Please list the total demand requirements for each of Avista's special contracts;
GREGORY J. TRAUTMA
Assistat Attorney General
StafCPR_ 011 Attachment A Page 18 of 62
Dockets UE-100467 and UG-1 00468
UTC Staff Data Request Nos. 61-67 to A vista
Apn1 28, 2010
Page 1
UTC STAFF DATA REQUEST NO. 61:
Re: Pro Forma Labor-Non-Exec
a. Has the 3.5% increase, on workpaper pages PF43 (Electrc) and PFh (Gas), listed
under UNION as "2010 increase for 2010 adjustment," been approved? If so, please
provide copies of the contracts tht support ths adjustment.
b. Has the 3.0% increase, on workpaper pages PF43 (Electrc) and PFh (Gas), listed
under UNION as "2011 increase for 2011 adjustment," been approved? If so, please
provide copies of the contrts that support this adjustment.
UTC STAFF DATA REQUEST NO. 62:
Re: Pro Forma Labor-Non-Exec
a. Has the 2.8% increase, on workpaper page PF43 (Electrc) and PF13 (Gas), listed
under ADMIN as "2010 increase for 2010 adjustment," been approved by the Board
of Directors? If so, please state the date of approval.
b. Has the 2.4% increase, on workpaper page PF43 (Electrc) and PFh (Gas), listed
under ADMIN as "2011 increase for 2011 adjustment," been approved by the Board
of Directors? If so, please state the date of approval.
UTe STAFF DATA REQUEST NO. 63:
Re: Pro Forma Labor-Executive
a. Please provide copies of the Compensation Commttee recommendations for
executive increases for each of the last thee years.
b. Please provide all 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.
UTC STAFF DATA REQUEST NO. 64:
Re: Pro Forma Labor-Executive
a. Has the 2.86% increase for executives, discussed in Ms. Andrews' testimony (EMA-
1 T), page 29, line 21, been approved?
b. If so, please state the date of approval and the effective date of the increase.
StafCPR_011 Attchment A Page 19 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 61-67 to Avista
Apri12B,201O
Page 2
UTC STAFF DATA REQUEST NO. 65:
Re: Pro Forma Insurance
On Ms. Andrews' workpapers labeled PF123 (E1ectnc) and PF73 (Gas), she refers to
"quoted" as the basis for 2010. 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. 66:
Re: Pro Forma Insurance
On Ms. Andrews' workpapers labeled PF123 (E1ectnc) and PF73 (Gas), she refers to
"invoiced" as the basis for 2010. Please provide a copy ofthe invoice along with a
reconciliation of the amount provided in the invoice and the amount shown on the provided
workpapers, if not self evident.
UTC STAFF DATA REQUEST NO. 67:
Re: Pro Forma Insurance
a. Please provide the number of Director and Offcer (D&O) insurance claims that have
been flied agait A vista from the yea 2000 to present.
b. What was the amount of each of the claims?
c. Provide the description and basis of the original D&O insurce claim.
d. Of all of the D&O insurance clais tht were fied against Avista in the past 10
years, how many of those claims were paid?
Please provide copies of all the D&O insurance clais that have been paid over the last 10
years with the correspondig outcomes.
GREGORY J. TRAUTMA
Assistat Attorney Genera
StafCPR_011 Attachment A Page 20 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 68-70 to Avista
Apri130,2010
Page 1
UTC STAFF DATA REQUEST NO. 68:
Re: PF7 Capital Additions
For each of the 43 capita projects listed on Exhbit No. DBD-1 T, pages 11 though 13,
please provide:
a. Actual dollars by ER number and description, month, jursdiction, FERC account,
voucher number, vender number, transaction description, and any related cost
element detail or trsaction detail, from the ER sta date to March 31, 2010. Please
sumane ths data in an Excel file by month and calendar year, and provide the
detail in a format suitable for a pivot table. Please include all accounts, includig
under constrction and expense.
b. An explanation and support for the Company's process used, expense and revenue
areas considered, and ultimate identification of all or any offsetting factors, and
related revenues and expenditues included in the test year. Please include ths
inormation for all capital projects includig those without any offsetting factors or
test year revenue or expense identified. This request is in addition to the support
provided in Exhbits DBD-5, DBD-6, DBD-7, SJK-4, SJK-6 and RLS-5.
c. Please provide the approval process and requirements for all capita projects of
A vista, and the level of approval received by project.
UTC STAFF DATA REQUEST NO. 69:
Re: Capital Additions
Please provide reference to the actual order and schedule that provides the book depreciation
rates used in the calculation of Capital Additions as provided in DeFelice workpapers, Par
1, page P5.
UTC STAFF DATA REQUEST NO. 70:
Re: Andrews Workpapers
Regardig excel file "2) W A-il PF Plant Add 2010 2-15-1O.x1s," please explain what new
method is referenced in sheet "2010 DeprExp Alloc09 - New Method."
Please provide all responses in hardcopy and electronic formats, with all links and
formulas intact.
GREGORY J. TRAUTMA
Assistat Attorney General
StafCPR_011 Attachment A Page 21 of62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 71-76 to Avista
May 5,2010
Page 1
UTC STAFF DATA REQUEST NO. 71:
RE: Natural Gas Cost of Servce Study
Referrg to the Direct Testiony of Tar Knox, page 21, lie 7, Ms Knox states that system
facilities are classified by the pea and average ratio tht reflects the system load factor, then
allocated by coincident peak demand and thoughput, respectively. Please provide the most
recent natual gas system load study.
UTC STAFF DATA REQUEST NO. 72:
RE: Natural Gas Cost of Servce Study
Referring to Tara Knox's natural gas workpaper, page 42 or 54, labeled TLK-G-42 or 54
(same data), the data for 2006-2007 heatig season and 2007-2008 heatig season should be
the same data as in the last general rate case (U-090134 and UG-090135) natual gas work
paper, TLK-G-46 or 60 (same data). Please reoncile the differences and provide the
rationale for the differences.
UTC STAFF DATA REQUEST NO. 73:
RE: Natural Gas Cost of Servce Study
Referring to Tara Knox's natural gas workpaper, page 55, labeled TLK-G-55, please
explain why the daily firm therms (consumptions) are estimated instead of using actual
consumptions for all schedules durg the peak day for the 2006-2007,2007-2008, and
2008-2009 heating seasons.
UTC STAFF DATA REQUEST NO. 74:
RE: Natural Gas Cost of Servce Study
Referrg to Tara Knox's natural gas workpaper, page 55, labeled TLK-G-55, please
explain why the peak therms are adjusted and estimated instead of using actu pea
consumptions for al schedules for the 2006-2007,2007-2008, and 2008-2009 heating
seasons.
UTC STAFF DATA REQUEST NO. 75:
RE: Natural Gas Cost of Servce Study
Referring to Tara Knox's natural gas workpaper, page 55, labeled TLK-G-55, please provide
detailed documents to support the amounts of "Losses & Estimation Error" shown on the
middle of the left-had side of the first colum for the 2006-2007,2007-2008, and 2008-
2009 heating seasons.
StafCPR_011 Attachment A Page 22 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 71-76 to Avista
May 5,2010
Page 2
UTC STAFF DATA REQUEST NO. 76:
RE: Rate Spread! Rate Design
Referg to the Direct Testiony ofPatnck D. Ehrbar, page 13, lines 15-16, it states that
the Company's present monthly demand charges range from $3.50-$4.25/KW, dependig on
service schedule. Please provide explanations to support the calculations of the present
monthy demand charges ranging from $3.50-$4.25/KW.
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment A Page 23 of 62
Dockets UE-1 00467 and UG-1 00468
UTC Staff Data Request Nos. 77-87 to Avista
May 5,2010
Page 1
UTC STAFF DATA REQUEST NO. 77:
Re: Enron Settlement
Please explain in detail how Avista accounted for the approximately $460,000 Enron
settlement money distrbuted by the Attorney Genera in December 2009, and descnbe the
treatment in the results of operations for ratemakg puroses.
UTC STAFF DATA REQUEST NO. 78:
Please reconcile the MW sales per Exhbit WGJ-5 and MW shown on page 2 of Exhibit
TLK-2, and explain the difference.
UTC STAFF DATA REQUEST NO. 79:
Please provide the kWh associated with the schedules shown in Exhbit PDE-4 and the
therms associated with the schedules shown in Exhbit PDE-7.
UTC STAFF DATA REQUEST NO. 80:
Re: Jurisdictional plant in servce
Referrg to Avista's response to Staff Data Request 5, please provide the electrc and gas
plant balances as assigned and allocated to varous junsdictions.
UTC STAFF DATA REQUEST NO. 81:
Re: Working Capital
Please relate the 2009 test year ended utiity balance sheet provided in Avista's response to
Staff Data Request 24, Attachment A, to the response to Staff Data Request 6, Attchment
D, "A vista Utilties Stand-Alone" balance sheet and provide a reconciliation and explanation
of the differences due to account classification and grouping or other reasons.
UTC STAFF DATA REQUEST NO. 82:
Re: Working Capital
Please provide an aggregation into account groups of the December 2008 though December
2009 monthly account balances provided in A vista's response to Staff Data Request 6,
Attchment I, and equate each aggregated group total to the correspondig monthy balance
provided in response to Staff Data Request 24, Attchment A.
UTC STAFF DATA REQUEST NO. 83:
Re: Working Capital
Please refer to Avista's response to Staff Data Request 24.
StafCPR_011 Attachment A Page 24 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 77-87 to A vista
May 5,2010
Page 2
The response states that there was specific analysis and evaluation of two commonly used
methodologies, the FERC "one-eighth" formula or "45 day" method and the ISWC
methodology. The analysis of the FERC method included research and review of vanous
industr related books and other rate cases. More specifically, Avista says they reviewed
past rate cases and testimony for PacifiCorp, and noted severa comments that speak to the
complexities of the ISWC method.
a. Please provide a list of the books and rate cases that were reviewed including book
titles, authors, and relevant pages of the books, docket numbers, related order
paragraphs, and relevant portions of testimonies and/or exhibits.
b. Please provide the rationale for the exclusion of fuel (accounts 501 and 547) and
purchased power (account 555) in the FERC "45 day" method.
c. Please provide the rationale for the exclusion of purchased gas (accounts 804, 805,
and 808) in the FERC "45 day" method.
UTe STAFF DATA REQUEST NO. 84:
Re: Working Capital
Please explain the basis of Avista's statement and belief tht the calculation of working
capital depicted in Attchment A to Avista's response to Staff Data Request 24 is a
calculation purortedly using the ISWC method.
UTC STAFF DATA REQUEST NO. 85:
Re: Working Capital
For each of the workig capital adjustments shown in Attchment A to Avista's response to
Staff Data Request 24, please explain the natue of each adjusted account and the rationale
for makg the adjustment.
UTC STAFF DATA REQUEST NO. 86:
Re: Working Capital
Please provide a list of all A vista filgs with FERC tht incorporate an allowance for
working capital calculated based on the "45 day" method. Please include a copy ofthe
supportng workpaper showing the calculation.
UTC STAFF DATA REQUEST NO. 87:
a. Please reconcile the W A electnc net operating income before FIT as shown in
e1ectnc workpaper BlO, with the income shown on page 3 of Avista's response to
Staff Data Request 3, Attchment A. Please explai the difference and provide
documentation supporting the validity and accuracy of one over the other.
StafCPR_011 Attachment A Page 25 of 62
Dockets UE-1 00467 and UG-100468
UTC Staff Data Request Nos. 77-87 to A vista
May 5, 2010
Page 3
b. Please reconcile the W A gas net operatig income before FIT as shown in gas
workpaper B7, with the income shown on page 2 of Avista's response to Staff Data
Request 4, Attchment A. Please explai the difference and provide documentation
supporting the valdity and accurcy of one over the other.
Please provide aU responses in hardcopy and electronic formats, with aU liks and
formulas intact.
GREGORY J. TRAUTMA
Assistat Attorney General
StafLPR_011 Attachment A Page 26 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 88-91 to Avista
May 7, 2010
Page 1
UTC STAFF DATA REQUEST NO. 88:
Re: PF 8 Pro Forma Noxon Generation
a. For ER 4138,4137 and any other ER related to PF 8, please provide actul dollar by
ER number and description, month, jursdiction, FERC account, voucher number,
vender number, vender name, traction descnption, and any related cost element
detail or trsaction detail, from the ER sta date to March 31, 2010. Please
sumanze ths data in an Excel fie by month and calendar year, and provide the
detail in a format suitable for a pivot table. Please include all accounts, including
under constrction and expense.
b. Regarding the property tax calculation of 1.5 percent of gross plant, please provide
justification, rationale and support for ths calculation.
c. Andrews' work paper PF8 3 reflects the calculation of investment ta credit and
related amortization. Please provide support for ths calculation, includig the code
section giving rise to the investment ta credit, time period involved and the
deterintion of amortization period.
d. Andrews' work paper PF8 4 includes a depreciation rate of2.89 percent. Please
reference support for ths rate.
UTC STAFF DATA REQUEST NO. 89:
Re: Account 923 Outside Services and Account 935 Maintenance of General Plant
For Account 923 Outside Services and Account 935 Maintenance of General Plant, for the
years 2007 though 2009, please provide transaction detail by project, deparent,
organzation, ER number and descnption, month, jursdiction, FERC account, voucher
number, vender number, vender name, transaction description, and any related cost element
detail or transaction detaiL. Please sumarze this data in an Excel fie by month and
calenda year, and provide the detail in a format suitable for a pivot table.
UTC STAFF DATA REQUEST NO. 90:
Re: PF 10 Information Servces
a. For Exhibit JM-3 Schedule 1, page 1 of 47, please provide the pro forma amount of
$380,205 by month FERC account, project, and transaction description. Please
provide ths detail in an Excel file and tie the dollar amount and FERC account to the
summar provided in Andrews' work paper PF10i.
b. For Exhbit JM-3 Schedule 2, page 1 of 9, please provide the pro forma amount of
$252,512 by month, FERC account, project, and transaction description: Please
provide ths detail in an Excel file and tie the dollar amount and FERC account to the
summar provided in Andrews' work paper PF10i.
c. For Exhibit JM-3 Schedule 3, page 1 of 13, please provide the pro forma amount of
$908,545 by month FERC account, project, and transaction description. Please
StafCPR_011 Attachment A Page 27 of 62
Dockets UE-100467 and UG-100468
UTC Staff Data Request Nos. 88-91 to Avista
May 7, 2010
Page 2
provide ths detail in an Excel file and tie the dollar amount and FERC account to the
summary provided in Andrews' work paper PF102.
d. For Exhbit JM-3 Schedule 4, page 1 of 153, please provide the pro forma dollar
amount for professional services, by month, FERC account, project, and transaction
descnption. Please provide ths detail in an Excel fie and tie the dollar amount and
FERC account to the summar provided in Andrews' work paper PF102.
e. For Exhbit JM-5 Schedule 5, page 1 of 5, please provide the pro forma amount of
$1,488,757 for professional services by month, FERC account, project, and
transaction description. Please provide ths deta in an Excel fie and tie the dollar
amount and FERC account to the summar provided in Andrews' work paper PF102.
f. For Exhbit JM-3 Schedule 6, page 1 of5, please provide the pro forma dollar
amount for 2011 operatig cost increases, by month FERC account, project, and
transaction description. Please provide ths detail in an Excel file and tie the dollar
amount and FERC account to the summary provided in Andrews' work paper PF102.
UTC STAFF DATA REQUEST NO. 91:
Re: PF 4 Jackson Prairie Storage
a. Please provide the proposed joural entres associated with the trsfer of the
Jackson Praine Storage facility from Avista Energy to Avista Utilities.
b. Please provide the book values for the Jackson Praine Storage facility as of March
31,2010, as reflected by Avista Energy.
Please provide all responses in hardcopy and electronic formats, with all links and
formulas intact.
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment A Page 28 of 62
Dockets UE-100467 and UG-1 00468
UTC Staff Data Request Nos. 92-96 to A vista
May 11,2010
Page 1
UTC STAFF DATA REQUEST NO. 92:
Re: Electric Cost of Servce Study
As a result ofStafts meetig with Mr. Kalich on Apn123, 2010 at the UTC, Mr. Kalich
agreed to makes cerin changes to his Exhbit 3. Please ru Avista's curent e1ectnc class
cost of service study using all updated changes in Mr. Ka1ich's Exhibit 3 (the energy and
demand percentage for generation and trmission facilities).
UTC STAFF DATA REQUEST NO. 93:
Re: Electric Cost of Service Study
Please ru A vista's curent e1ectnc class cost of service study using A vista's prior method to
allocate total production costs and tranmission costs tht is mentioned in Tara Knox's direct
testiony, page 14, lines 19-21.
UTC STAFF DATA REQUEST NO. 94:
Re: Electric Cost of Service Study
Referring to Tara Knox's direct testimony, page 14, line 21 and page 151ines 1-2, the
Company's proposed revised peak credit method shifts cost away from high load factor
customer groups (Schedule 21 and 25) as well as customer groups which have a limited
contnbution to system peak usage. Please itemize the amounts of shifted costs. Please also
indicate specifically which costs have been shifted from one rate schedule to another.
UTC STAFF DATA REQUEST NO. 95:
Re: Electric Cost of Service Study
Referrg to Tara Knox's direct testimony, page 14, lines 19-20, please provide all
supportg documents and explantions for the calculation of 24% of total production costs
and 36% of total trsmission cost as demand-related costs.
UTC STAFF DATA REQUEST NO. 96:
Re: BOAR OF DIRECTORS MEETING EXPENSES
Please provide copies of the following voucher numbers with all supportg documentation
shown in Ms. Andrews' work paper pages AE14 - AE16.
. 428127
. 378768
. 402324
. 377080
. 395520,
. 440353
GREGORY J. TRAUTMAN
Assistat Attorney General
StafCPR_011 Attachment A Page 29 of 62
Rob McKenna
ATTORNY GENERAL OF WASHINGTON
800 Fift Avenue #2000 · Seattle WA 98104-3188
Apn1 16, 2010
SENT VIA E-MAL &U.S.MAIL
David J. Meyer, Esq,
P. O. Box 3727
1411 E. Mission Avenue, MSC 13
Spokane, W j\ 99220-3727
Re: WUTC v. Avista Corporation d/b/a Avista Utities,
Docket Nos. UE-I00467 and UG-I00468
Public Counsel Data Request Nos. 1 though 47
Dear Mr. Meyer:
Please respond to the attached Data Requests of Public Counsel Nos. 1 though 47, in the above-
captioned matter. Please provide the respnse to the following requests on a separate piece of
paper, repeating the request at the top of the page on which the request begins. Pleae provide
each response (text and attachment) in electonic format and hard copy.
Where a document or other information is requested, the request refers to information and/or
documents held by the company or its contractor/consultant. Also, please indicate the date the
reponse was prepared and the name and phone number of the individual who prepared the
response and the witness who ca be cross-examined on it.
If the company's response to any request is that the requested documents are too voluminous to
produce, or that the document is only available for review at your offces, please provide an
index of all of the relevant documents, a descnption of each document, and the number of pages
of each document.
StafCP~achment A Page 30 of 62 G
ATTORNY GENERA OF WASHIGTON
To: David Meyer
Re: Docket Nos. UE-I00467 / UG-100468
Apn116,2010
Page 2
These requests are continuing in nature. If, subsequent to the response, additiona information
becomes available which is within the purew of the request, the response should be
supplemented.
in this matter.
Fó
SARAH
Assistant
Public Co
[phone]
SAS/meh
Attachments
cc: Serice List (Firt Class Mail & E-mail)
.r.:..StafCPR_011 Attachment A Page 31 of62
BEFORE THE WASmNGTON UTS AN TRSPORTATION
COMMSSION
WUTC v. Avista
Docket Nos. UE-I00467 and UG-I00468
Public Counsel Request No. 1-47
To: AVISTA
PC-1 Please provide paper copies of your resp9nses to all data requests for information
from all pares'in ths action to:
Sar A. Shiey
Offce of the Attorney General
Public Counsel
800 Fif Avenue #2000
Seatte, WA 98104-3188
Please provide electronic copies of al docents to Sar Shiey,
Sarah.Shifley(gtg.wa.gov, Simon fftch, SimonF~TG,WAGOV, Mar Kimball,
MarK2ißatg.wa.gov, Stefane Johnn, StefaneJcg.wa.gov, Lea Daeschel,
LeaDtßatg.wa.gov, Carol Wiliams, CaroIW(gtg.wa.gov; and May Harer,
Mary,Harerißatg, wagov.
PC-2 Incentive Compensation
a. Pleae provide a complete copy of all incentive compenation
plans.
b. Provide the actual percentage scores for each of the performce
goal for the year 2007, 2008 and 2009.
c. Identi all instaces wher incentive bonuses were paid in the
year 2007 thugh the present in any intance and show in detail
how the awar amounts wer related to the applicable performance
goals. Provide an explanation with each instance.
PC-3 Incentive Compensation
Pleae provide a detailed list of responsibilties and duties tht eligible
incentive compensation employees must have or perform in addition to
those necessar to meet the standads for base salar compensation in
order to reeive incentive compenation.
PC-4 Incentive Compensation
Provide for each of the yea 2004 -2009 the established goals (theshold
target and maximum) and the actual results for each of the goals.
StafCPR_011 Attachment A Page 32 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 1 though 47
Docket Nos. UE-100467 & UG-1 00468
Date: April 16, 2010
Page 2 of9
PC-5
PC-6
PC-7
PC-8
PC-9
PC-lO
Incentive Compensation
Identify the tota amount of offcer compensation expensed for each of the
year 2004 - 2009 and identify the tota amount included in rates
established for each of the respective years. Provide this information
separately for the W A e1ectnc and gas operations.
Incentive Compensation
Provide for each of the yeas 2004-2009, the total costs for each of the
varous incentive plans and/or varable pay plan, the amount of expense
for the W A electnc and gas operations separtely
for each plan and the percentage of target for each plan..
Incentive Compensation
Provide for eah year 2004-2009 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 2004-2009 the retu on equity achieved before and
afer expensing incentive and varable pay (show all calculations) and the
retu on equity allowed for each year as well as any supportg
calculations.
Incentive Compensation
Identify all studies the Company has where Company employee
compensation was compared to where the compensaton in the studies was
adjusted based on reguatory disallowance of base pay and/or incentive
compensation.
Incentive Compensation
What percent of Washington natual gas and electnc customers parcipate
in the Voice Satisfaction Surey since the surey was implemented?
Overll, how may total calls did A vista receive frm Washington
customers eah year (i.e. opportties for customers to complete
the Surey)? Please separate by Washigton gas and Washington electnc
operations. Is completion of the surey lited at all? Does Avista track
from whom or where calls are placed?
StafCPR_011 Attachment A Page 33 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 1 thugh 47
Docket Nos. UE-I00467 & UG-100468
Date: April 16, 2010
Page 3 of9
PC-ll
PC-12
PC-13
PC-14
PC-is
PC-16
Incentive Compensation
How does A vist hadle cusmer inuies an complaits? Please
provide a taly of all inquiries and complaits received by A vista from
Washigton customer in 2006, 2007, 2008, and 2009, broken down by
gas and e1ectnc operatons. Please also include any categoriation tht
Avista may pedorm on such calls, e.g. whether the call is a request for
new services, billng inquiry, safety complaint, etc,
Incentive Compensation
Pleae provide a full list and copies of al cusomer sureys tht A vista
pedorms, either interally or thugh outside contrtors.
Incentive Compensation
Pleae provide the operag and maitence cost-per-customer targets
(thshold and maximum) for each year of the perod of 2004 though
2009. For each taget, please include the year, the cntera and
methodology used for settng the target, the number of customers for the
taget yea, the metodology used to calculate executive bonus payments,
and wheter the taget was met, exceeded, or not met.
Incentive Compensation
Please provide the customer service reliabilty targets and customer
satisfaction targets (theshold and maum) for each year of the perod
of2004 thugh 2009. For eah taget, please include the year, the cntera
and methodology used for settg the taget, the levels of customer
reportg, the methodology used to calculate executive bonus payments,
and whether the taget was met, exceeded, or not met.
Compensation
Please provide a list of the 30 highest-compensated employees, includig
position title, base salar, and all other types of compensation. Please
provide the amount paid to each employee from 2004 thugh
2009 by month, and itemized by base salar, bonuses, and benefits.
Pension Costs
Please list the tota amount incud dug the test year in relation to
Avista's Supplementa Executive Retient Plan. Pleae show where
these amounts have bee removed from test year operations.
StafCPR_011 Attachment A Page 34 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 1 tlugh 47
Docket Nos. UE-I00467 & UG-I 00468
Date: Apn1l6, 2010
Page40f9
PC-17
PC-I8
PC-I9
PC-20
PC-21
Labor Cost Allocations
Pleae respnd to the followig, providig all source data and
supportng evidence within Avista 's possession:
a, Please provide all soure data used to justify the allocation of base
salar expenes between utility and non-utilty operations, This should
include all documentary evidence in Avista's possession to support the
90/1 0 alocation, includig but not limited to employee reports,
communcatons, activity logs, etc.
b. Please provide all source data used to justify the allocation of incentive
and allother forms of compensation between utilty and non-utility
operations. Ths should include all documentary evidence in Avista's
possession to support its curent allocation, includig but not limited to
employee reports, communcations, activity logs, etc.
Boar of Directors' Fees
Please provide a list of all compensation paid to Avista's board of
dictors, including individual forms of compenation (e.g. per-meeting
compenation) and overall amounts, Identify the system amount of Board
of Directors fees included in the test year, and separately for
W A electnc and gas operations. Also provide simar inormation for each
of the year 200 though 2009.
Dividends
Please provide a complete list of all payouts mae in the last 15 years on a
per-share and tota (all shes) basis.
Board of Directors' Expenses
Please provide a list identifyng all non-compensation expenses related
to Avista's Boar of Directors included in the test year. Please indicate
how and where these expenses are accounted for in the test year,
Marketing
Does Avista have a marketing program in either its gas or electnc
division? If any individual or group of individuals are engaged in
marketing for either the gas or e1ectnc deparent,
please provide the following inormation:
a. The number of individuals, their salmes and all overhead
associated with marketing 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 filig.
StafCPR_011 Attachment A .Page 35 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 1 thugh 47
Docket Nos. UE-100467 & UG-I0048
Date: Apnl16, 2010
Page 5 of9
PC-22
PC-23
PC-24
PC-25
Marketing
Please provide a complete descnption of each form of communcation
produced by A vista for marketing puroses, such as but not limited to
materals provided at trade shows or diectly to developers, regardless of
what FEC account it is charged to. For eah, please desribe the vanous
types of costs incur in creation and distbution, includig required
stang, outside contrts for supportserces, inter costs for materals
(such as pnntig, postig, maling), and costs of distrbution.
hi addition, please provide copies of al such materals.
Customer Communications! Advertsing
Please provide a list of all adverising and/or customer communcations
that the Company does regaress of what FERC account it is charged to.
Provide the following inormaton regag the Company's customer
communcations/adversing exenes:
a. Provide a detled list of al customer communcations/adversing
expene by vendor.
b. Provide a list of all cusmer communcationsadvertising expense
by type.
c. Provide copies of al customer communcations/adversing,
regardless of medum and include the following inormation
regardig each:
(1) how was the communication acomplished?
(2) what were the intern and extern costs of each?
(3) how were costs allocation amongjunsdictions for any mu1ti-
state communcations?
D&O Insurance
Please identify the amount of Diretors' and Officers' (D&O) insurce in
the test year separately for electnc and gas. Also, include the amount of
D&O insurce for each of the last five calendar year (2005, 2006, 2007,
2008, 2009) separly for the electrc and gas operations.
EEl Dues
Has the Company removed any porton of test year expenses
for EEl dues associated with lobbying, adversing, marketing? If so
identify the amount and account number,
StafCPR_011 Attachment A Page 36 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 1 though 47
Docket Nos. 00-100467 & UG-100468
Date: Apnl 16,2010
Page 6 of9
PC-26
PC-27
PC-28
PC-29
PC-30
PC-31
PC-32
AGADues
Has the Company removed any porton oftest year expenses for AGA
dues associated with lobbying, adversing, marketig? If, so identify the
amount and account number,
EmployeeJirector gif
For the test year list all payments made for Board of Director and/or
employee gifts, awards, luncheons and dinners, picncs and all other
similar tye items, For each, list the dollar amount
paid, the payee, the account chaged and state the puiose. Provide
copies of invoices which exceed $5,000,
Sportig Events
Identify all expenses incured durng the test year for athletic events,
tickets, sky boxes and all sportg activities.
a, Specifically identify the activity, dollar amount and account
charged.
b. Provide copies of paid voucher and invoices supportng these
expenditues,
Sporting, Entertainment, and Charitable Costs
Please indicate where and how the curent fig reflects and complies
with the Thurton County Superor Cour's decision in Case No. 09-2-
00171-2 (Public Counsel Section v. WUTC and Avista Corp.), reversing
the Commssion's decision alowing inclusion of sportg events and
enterent costs, and chatable donations, in Avista's revenue
requirement.
For the test-year operatig results, please indicate the dollar change
(increase or decrease) in all costs frm the previous test year.
Please identify any new expenses included in the test year tht were not
included in the pnor rae case,
Identify all proposed O&M expense increases exceedng 10% included in
the test year expenses from the previous test year. Provide a detaled
explantion of any increases exceedg 10%.
Staff_PR_011 Attachment A Page 37 of 62
To: David Meyer
Re: Public Counel Data Request Nos, 1 thugh 47
Docket Nos. UE-100467 & UG-1 00468
Date: April 16, 2010
Page 7 of9
PC-33
PC-34
PC-35
PC-36
PC-37
Regarg non-recurg chages, please respnd to the followig:
a. For each expene account in the test year, list each non-recumng
chage or credt which exceed $25,000.
b. For eah such chage or credt, state the amount, the basis and provide
copies of all jour entres and supportg documentation.
c, Reconcile the dollar amounts included above to any adjustments
proposed by the Company.
Cost Alocation
Please provide Avista's most reent Budget Varance Report, Ifno such
report exists, pleae explai why Avist does not complete such a report
and what, if any, simlar/substtute reort ar relied upon.
Pleae provide Avista's Wasngtn-alocated utility reenues for all year .
frm 1998 to date.
Regulatory Expenses
Please provide invoices or other documentation related to the FERC
regulatory expense charged to retail rates in the stae of Washington, In
addition:
a. Provide an explantion of what PERC dockets the Company
paricipated in by docket number and case description and state
what benefit retail ratayers receive
from the parcipation of the Company in these dockets,
b. State whether the FERC regulatory expense is an ongoing
recurng amount and why ths amount should be recovered in
rates.
Regulatory Expenses
Please respond to the followig:
a.. Identify the total rate case expense included in the test year
separtely for the W A electnc and gas opertions, as well as an
itemation for ths expene by subaccount.
b, Provide any invoices received to date, contracts, etc., supporting
any charges for outside serces employed.
c. Please provide the inormation reuest in (a) and (b) for the las
five (5) Wasngton rate cases.
StafCPR_ 011 Attachment A Page 38 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 1 though 47
Docket Nos. UE-100467 & UG-1 00468
Date: Apnl 16,2010
Page 8 of9
PC-38
PC-39
PC-40
PC-41
PC-42
PC-43
PC-4
Regulatory Expenses
Please provide the contract between Avista and Dr. Willam E. Aver
for Mr. Avera's work on ths case. Ifnot specified in the contrct, please
also provide the following information:
a. Dr. Avera's hourly rate for serices,
b, Estited maximum contract amount.
Regulatory Expenses
Wht steps ha A vist taen to minimize the amount it spends on
reguatory mater, parcularly in pursuig rat increases though general
rate case filings?
Legal Fees
Please identify how.and where all costs for internal legal work are
accounted for. Please identify the specific amounts included in the test
year related to interal legal work and a description of what these costs are
related to, i.e. specific transactions, litigation, etc.
Legal Fees
Please provide the hourly rate used for Avista's in-house counsel. If an
hourly rate is not set, please provide the total compenation paid to each of
Avista's in-house attrneys for the test year, as well as for the previous
five (5) calendar years.
Legal Fees
List all expenses over $50,000 included in the test yea (on a direct chage
basis, afliate biling, or allocation) which are the result of lawsuits or
other legal matter,
Legal Settements
List all amounts over $50,000 included in the test year
(Qn a diect charge basis, afliate biling, or allocation) which ar the
result of the settement of lawsuits or other legal settements.
Legal Fees
Please provide all evidentiary support and source data regarding the
allocation of in-house legal costs between regulated and non-regulated
operations.
Staff_PR_011 Attachment A Page 39 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 1 thugh 47
Docket Nos. UE-I00467 & UG-I00468
Date: Apri116, 2010
Page 9 of9
PC-45
PC-46
PC-47
Extrnal Legal Expenses
Identify the amount of legal expenes included in the test yea by vendor.
Prvide ths on a tota system basis as well as any amounts allocated to the
W A electrc and gas operations. Provide similar histoncal infonnation for
each of the year 2004 though 2009,
Internal Legal Expenses
Identify the tota costs, regardless of what FERC account they are booked
to, associated with trsactional or litigaton matters utility, non-utility
and/or subsidiar matter.
Aircraft
Prvide the followig inonnaton regarding aircraft costs.
a. Pleae identify each and ever aicraf which is on the Company's
books and is chaged to rateaye,
b. Provide the total cost of each aiaf and what dollar amount of
operatig expense of these airra ha been chaged to
Washington rateayers.
c. Identify the anual operting costs to operte the airaf for each
of the year 2005 though 2009, and 2010 to date. Provide ths on
a total sysem bas~s and identify the Wasgtn Junsdctional
amounts alocated to the electrc and gas operations.
Identify the amounts allocated to shareholder.
d. Provide detailed flght logs for the aircraft together with a
descnption of their utilization and who the passengers were as well
as an explanation of how the chages on the manfest are denved.
e. Provide a description of the purose and use of each aicraf.
f. Provide a copy of the Company's airaf use policy.
g. If a company leases airaf to A vista, identify such company and
indicate whether the leasing company is an afliate of Avist
h. Provide copies of any leasing invoices for 2007,2008 and 2009,
2010 YTD.
StafCPR_011 Attachment A Page 40 of 62
BEFORE THE WASHINGTON UTILITIES AND TRSPORTATION
COMMSSION
WUTC v. Avista
Docket Nos. 00-100467 and UG-I00468
Public Counsel Request No. 48 through 52
To: AVISTA
PC-48 Electric Cost of Servce Study
Please ru your curent e1ecmc class cost of service study with all costs
and parameters identical to those fied in Avista's most current cost of
service study (discussed in the Direct Testimony of Tar L. Knox, Exhibit
No. TLK -1 T), except: utilize the energy and demand percentages for
generation and transmission facilities used in Avista's 2009 general rate
case (U-090 134/UG-090 135).
PC-49 Bil Frequency
Please respond to the following:
(a) Provide an electric residential "bil frequency" analysis for each
month of the test year.
(b) Provide a natul gas "bil frequency" analysis for each month of
the test year.
PC-50 Customer Usage
Please provide 2006, 2007, and 2008 usage on a monthy basis for the
following types of residential customers:
(a) Heating;
(b) Non-heating;
(c) Low Income; and,
(d) Non-Low Income.
PC-51 Customer Usage
Please provide test year usage by month for the following tyes of
residential customers:
(a) Heatig;
(b) Non-heatig;
(c) Low Income; and,
(d) Non-Low Income.
StafCPR_011 Attachment A Page 41 of62
To: David Meyer
Re: Public Counsel Data Request Nos. 48 though 52
Docket Nos. UE-100467 & UG-1 00468
Date: April 21, 2010
Page 2 of9
PC-52 Base Rate History
Please provide a history of Avista's retail base rates by customer class
from 1999 to present. In addition, pleae present ths data on a
single grph includig base rate inormation for al customer classes on a
single graph.
StafCPR_011 Attachment A Page 42 of 62
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMSSION
WUTC v. A vista
Docket Nos. UE-I00467 and UG-I00468
Public Counsel Data Request Nos. 53 through 65
To: AVISTA
PC-53 Re: Avista Response to Staff Data Request No. 10, CONFIDENTIA
Attachment A
(a) Please also provide a title and description of each FERC account
that appears in CONFIDENTIA Attachment A to Avista's
Response to Staff Data Request No. 10.
(b) Please provide an explanation for why each compensation amount
was allocated to parcular FERC accounts listed in
CONFIDENTIAL Attchment A.
(c) Please explain the column titled "Benefits Loading at 12/31/2008"
and all expenses included in ths category.
(d) Please explain the column titled "Benefits Loading at 12/31/2009
at 58%" and all expenses included in this category. Additionally,
please explain what is.meant by "at 58%" as well why this
distinction is provided for 2009.
PC-54
PC-55
PC-56
Re: Avista Response to Staff Data Request No. 10, CONFIDENTIAL
Attachment B
Please provide a spreadsheet showing where the amounts of incentive
compensation were accounted for by FERC account.
Re: Avista Response to Staff Data Request No. 15
Please provide a complete list of all sponsorship agreements entered by
A vista Corporation durg the test year, including the tye, amount/cost,
and duration, regardless of whether all or some of the amount/cost was
included in test year expenses. Please indicate which account each cost is
recorded in, if and how any costs were removed from the test year, and,
where costs were not removed, if and how they are allocated to
Washington.
Re: Avista Response to Staff Data Request No. 16
Please conf that the list provided in Attchment A is a complete list of
all chartable contrbutions made by A vista dug the test year regardless
of whether they are included in the test year. If the list provided in
. Attchment A is not a complete list of al chartable contrbutions, please
StafCPR_011 Attachment A Page 43 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 53 thugh 65
Docket Nos. UE-100467 & UG-100468
Date: Apri129,2010
Page 2
PC-57
PC-58
provide such a list, as well as where eah contnbutionlcost is accounted
for and iflow it has been allocated to Washigton.
Re: Avista Response to Staff Data Request No. 11
Please provide all amounts paid to Towers Watson (formerly Towers
Perr) in 2007,2008, and 2009, for:
(a) consultation on offcer and director compenation; and
(b) any and all other issues.
Incentive Compensation
Please provide the tota amount of at-risk incentive compensation paid to
employees anually frm 1998 to present, in the following format:
Year Number of Maximum Budgeted Actu Payout Amount
Employees Potential Payout Allocated to W A
Payout Operations
1998
1999
,..
PC-59
PC-60
Customer complaits
Please respond to the following:
(a) Provide the records maintained by Avista pursuat to WAC 480-
90-173(4) (all natual gas customer complaints received in the last
thee (3) year). If doing so would requie production of
voluminous documents, please provide a sumary of the
information required under WAC 480-90-173(4)(b)(c) and (d) for
each complait on an anua basis.
(b) Provide the records maitaed by A vista pursuat to WAC 480-
100-173(4) (all e1ectnc customer complaits received in the last
thee (3) year). If doing so would requie production of
voluminous documents, pleae provide a sumar of the
inormation requied under WAC 480-1 00-173( 4)(b)( c) and (d) for
each complaint on an anua basis.
Operation and Maintenance Costs
Please provide Avista's budgeted O&M costs on an anual basis from
2001 though present.
StafCPR_011 Attachment A Page 44 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 53 though 65
Docket Nos. UE-100467 & UG-100468
Date: Apri129,2010
Page 3
PC-61
PC-62
PC-63
PC-64
PC-65
Operation and Maintenance Costs
Please provide a narative explanation of how Avista determines its
budgeted O&M costs.
Operation and Maintenance Costs
Please provide the amounts included in rates for O&M costs on an anual
basis from 2001 through present. If these costs are different than actu
O&M costs, please also provide Avista's actul O&M costs on an anua
basis from 2001 though present.
Rate Case Expense
Please respond to the following:
(a) Provide the amount of time spent by each in-house witness and in-
house counsel in Avista's previous general rate case (Docket Nos.
UE-090 134/UG-090 135) on case-related work, including but not
liited to review of prior cases, initial analysis, prepartion of
testiony and exhbits, responding to data requests, propoundig
data requests, analyzing testiony, exhibits, and data request
responses of other paries, preparation and paricipation in
settlement discussion, prepartion and parcipation in the
evidentiar hearg, and post-hearg brief drftg/editing.
(b) If in-house witnesses do not trk time spent on rate cases, please
explai why ths is so.
(c) If rate case time is not trcked, provide a by-witness estiate of
tie spent.
Rate Case Expense
Please provide the anual base salares and total compensation for all in-
house witnesses who presented testiony in Avista's previous general rate
case (Docket Nos. UE-090134/UG-090135).
Rate Case Expense
Please provide the total amount paid to Dr. Avera for his paricipation in
Avista's previous general rate case (Docket Nos. UE-090134/
UG-090135). Please also provide an explanation and any supporting
documentation showing what such costs were attbutab1e to (i.e. drftng
testiony, settement preparation, etc.).
StafCPR_011 Attachment A Page 45 of 62
Rob McKenna
ÀTTORNEY GENERAL OF WASHINGTON
800 Fifth Avenue #2000 · Seattle WA 98104-3188
Apn130,2010
SENT VIA E-MAIL &U.S.MA
David J. Meyer,
P. O. Box 3727
1411 E. Mission Avenue, MSC 13
Spokanei Wi\ 99220-3727
Re: WUTC v. Avista Corporation d//a Avista Utiities,
Docket Nos. UE-100467 and UG-I00468
Public Counsel Data Request Nos. 66 through 76
Dea Mr, Meyer:
Please repond to the athed Data Requests of Pulic Counel Nos. 66 though 76, in the
above-captioned matter, Please provide the resons to the followig requests on a separate
piece of paper, repeatig the reuest at the top of the page on which the request begins. Pleae
provide each response (text and attachment) in electronic formt and had copy.
Where a document or other information is reuested, the request refers to information and/or
documents held by the company or its contractor/consultat. Also, please indicate the date the
response was prepared and the name and phone number of the individual who prepared the
response and the witness who can be cross-examed on it. rfthe company's response to any
request is th the requested documents are too volumnous to produce, or tht the document is
only available for revew at your offces, please provide an index of all of the relevant
documents, a descnption of each document, and the number of pages of each document.
These requests are continuing in natue. If subsequent to the response, additiona information
becomes available that is within the puriew of the request, the response should be
supplemented. Than you for your assistance in ths matter.
Sincerely,~.
SAR A. SHIPLEY
i\ssistant Attorney Gener
Public Counel
[phone]
SAS/meh
i\ttachments
cc: Service List (First Class Mail & E-mail)
StafCPR~chment A Page 46 of 62 o
BEFORE THE WASHINGTON UTILITIES AN TRSPORTATION
COMMISSION
WUC v. Avista
Docket Nos. UE-100467 and UG-I00468
Public Counsel Data Request Nos. 66 through 76
To: AVISTA
PC-66 Pleae provide A vista Utilities' anual eags per shae from the years
2001-2009,
PC-67 Please provide all external and internal expenses, including but not
lited to: transaction costs, time spent by Avista employees (in-house
counel, accounting personnel, other offcers), administratve costs and
fiancing costs incured durg the test year related to Avist's acquisition
ofEcos. Please indicate which account(s) each of these costs were booked,
PC-68 Incentive Compensation
Regardig the Pace Setter Incentive Program, please respond to the
followig.
(a) Provide a list of all Pace Setter awars granted dunng the test year.
Include the amount of the reward, the reason for the reward, and
the date the reward was granted,
(b) Provide the total amount of Pace Setter awards granted in 2006,
2007, and 2008.
(c) Confirm the amount of Pace Setter award costs included in the test
year and the FERC account to which they ar assigned.
PC-69 Re: Morris Direct Testimony, p. 33
a. Provide copies of all cerficates that qualify Spokane River
hydrelectnc projects as renewable resources under Californa
gudelies,
b. Provide a list of total "green tags.. sold by Avista including
revenues received per sale, the date of each sale, and to which
utility the sale was mae. Please also provide the total
cumulative net proceeds from green tag saes.
c. Provide all contracts for sales of "green tags'. to Californa utilities.
d. Provide al analyses conducted by the Company that demonstrte
green tags were sold to Californa utilties at a ''premium'..
e. Provide all workpapers supportg the adtional value from these
sales included in ths rate case,
PC-70 Re: Avista Response to Public Counsel Data Request 10
Please provide a break-down for all calls by whom and from where
they wer placed.
StafCPR_011 Attchment A Page 47 of 62
To: David Meyer
Re: Public Counel Data Reques Nos, 66 though 76
Docket Nos. UE-100467 & UG-100468
Date: Apnl 30, 2010
Page 2
PC-71
PC-72
PC-73
PC-74
PC-75
Re: Avista Response to Publie Counsel Data Request 10
Pleae provide documentaon th demonstes the staistcal signficance
of Avista's VOC Surey.
Re: Avista Response to Publie Counsel Data Request 25
Please break down the total costs for EEl dues included in the test year by
gas and electrc operations.
Re: Avista Response to Pub lie Counsel Data Request No. to
Pleae provide the followig informtion (as previously reuested):
(a) What percetage of Washigtn natu gas customer paricipated
in the 2009 VOC surey?
(b) Wht pertae of Washigton electrc customer paricipated in
the 2009 VOC stdy?
(c) What pertage of Washigtn natu gas cusomer caled
Avista's ca center and wer given the opportty to complete the
VOC surey in 2009?
(d) What perentage of Washigtn electrc customers called Avista's
call center and wer given the opportity to complete the VOC
surey in 2009?
(e) What percentage of Washigton natu gas cusmer received
servces (i.e. complete jobs or orders) thugh an A vista
opertions offce and were thus in the pool eligible to be par of the
sample group for the VOC surey in 2009?
(f) Wht pertage of Washigton electrc cusmers received
serces (i.e. complete jobs or ord) thugh an Avista
opertions offce and were thus in the pool eligible to be par of the
sample grup for the VOC surey in 2009?
Re: Avista Response to Public Counsel Data Request No. 10
Please provide the employee titles for, and tota number of, Avista
employee who are reguarly in contat with customer:
(a) thugh cal center,
(b) thugh operations offce, and
(c) on-site while completig field requests,
Re: Avista Response to Publie Counsel Data Request No. 14
Please provide the following information (as previously requested):
(a) Critera an methodology for deterg the taget for SAII
(average outage per customer) expectation in Avista's 2009
Incentive Compensation Program.
StafCPR_011 Attachment A Page 48 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 66 thugh 76
Docket Nos. UE-i00467 & UG-I 00468
Date: Apnl 30, 2010
Page 3
PC-76
(b) Cntena and methodology for deternig the target for CAII (average
outage time) expectation in Avista's 2009 Incentive Compensation
Program.
(c) Crtena and methodology for determinig the target for Cutomer
Satisfaction Ratig expectation in Avista's 2009 Incentive CompensationProgr.
Re: Avista Response to Public Counsel Data Request No. 20
Please provide a narative explanation for the following expenditues
including, where applicable: vendor, reipient, serce received, and/or
product received. Where there are multiple single transactions included in
a single expenditue amount, please provide ths informtion for each:
(a) Professional Servces - BOAR VANTAGE SERVICES, 90-10
(b) Professional Serces - PROXY PREPIPRI
(c) Aifare - Wells Fargo cc Payment
(d) Employee Business Meals - BOAR EXPENSES -
ADVANAGE IQ
(e) Employee Business Meals - BOAR MEETING - FEB 2009
(f) Employee Business Meals - BOAR MTGS - NOV, 09
(g) Employee Business Meals - BOAR OF DIRCTORS MTGS -
MAY
(h) Employee Business Meals - Wells Fargo cc Payment
(i) Employee Car Rental- ADVANAGE IQ
G) All (3) expenses included under expenditu type "Conference
Fees"
(k) Employee Lodging - BOAR EXPENSES - ADVANTAGE IQ
(1) Employee Mise Expenes - Wells Fargo cc Payment
(m) Dues - SUSAN Y. MINR - DUES 2009
(n) Dues - Wells Fargo cc Payment
(0) License Fees - ANAL STATUTORY REP
(P) License Fees - SPOKANE BUSINSS LICENSE
(q) License Fees - Wells Fargo cc Payment
(r) Miscellaneous - BD OF DIRCTORS TRAVEL EXP
(s) Miscellaneous - BOAR MEETIG - FEB 2009
(t) Miscellaeous - EXPENSE REIMUREMENT
(u) Miscellaneous - PORTR BOAR MEMBER
(v) Miscellaneous - TRAVEL EXPENSES
StafCPR_011 Attachment A Page 49 of 62
BEFORE THE WASHIGTON UTITS AN TRSPORTATION
COMMSSION
WUC v. Avista
Docket Nos. UE-I00467 and UG-I00468
Public Counsel Data Request Nos. 77 through 101
To: AVISTA
PC-77 Re: Avista Response to Staff Data Request No.8, CONFIDENTIA
Attachment C
Please provide Avista's annual Marketing Plan and Planning procedures
for 2007, 2008, and 2009 (referenced on page 28 of CONFIDENTIAL
Attchment C).
PC-78 Re: A vista Response to Staff Data Request No. 12
For each subsidiar (17 total), please provide test-year operating costs and
revenues in the formt shown below. An example of a joint cost would be
executive compensation, 10 percent of which is curently spread between
subsidiares, but specific cost allocations to individual subsidiares (i.e.
each subsidiaries' portion of the 10 percent) should be provided below.
Subsidiary Description of Total Subsidiary-Joint subsidiary
Name Operations Revenues only costs utity costs
allocated to
individual
subsidiary.
PC-79 Re: Avista Response to Staff Data Request No. 12
Please provide a list and dates of all subsidiary board meetings, or portons
of general board meetings that included discussion of subsidiar
operations, that took place in 2009.
PC-80 Re: Avista Response to Staff Data Request No. 17, Attachment A
Please provide a naative descnption of the following expenses, includingthe specific transactions and vendors: .
(a) All expenses with transaction description, "Wells Fargo cc
Payment," and vendor name, "CORP CREDIT CAR," which
appear at least 14 ties in varous FERC accounts.
(b) All expenses with the transaction description of "dues" and a
person's name listed under "vendor name." Such expenses appear
multiple ties in varous FERC accounts.
StafCPR.011 Attchment A Page 50 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 77 though 101
Docket Nos. UE-100467 & UG-100468
Date: May 7,2010
Page 2
PC-81
PC-82
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(c) "ASSESSMENT" and "FIRST BILLING" transactions to vendor,
"US DEPARTMENT OF TRNSPORTATION," which appear in
Account No. 874000 under the project description, "Gas Integrity
Mgt Program."
(d) "2009 DUES" transaction to vendor, "INLAN EMPIR
UTILITY," which appears in Account 874000 under the project
description, "Gas System Operations -956."
(e) "COMPANY ID 249731lMMBERSHIP R" transaction to
vendor, "WASHINGTON TECHNOLOGY INUSTRY
ASSOCIATION" in Account No. 921000 under the project
description, "Common IT Operations."
(f) "MEMBERSHIP RENEWAL" transaction to vendor, "UTILITIES
TELECOM COUNCIL" in Account No. 921000 under the project
description, "Common IT Operations."
Re: Avista Response to Staff Data Request No. 17, Attachment A
Please provide the amounts included in the curent Washigton test year
for all expenses listed in ths spreadsheet.
Re: A vista Response to Public Counsel Data Request No. 02,
CONFIDENTIA Attachment C
Please provide a list of employee positions (including salar levels) for the
"market levels" listed in the chart on page 3 of CONFIDENTIAL
Attchment C. Please also provide the number of employees in each
"market level" as of December 2009.
Re: A vista response to Public Counsel Data Request 12,
Attachment A.
Based on the results of the "Wattson" Awareness Benchmark Research,
does the Company anticipate continuing the Wattson Energy Conservation
Program for Chidren? If yes, please explain why, if no, please explain
why not.
Re: Avista CONFIDENTIAL Response to Public Counsel Data
Request No. 15
(a) Please provide a nartive explanation of the difference between
"annual base salary" and regular earnings" compensation tyes that
appear in CONFIDENTIAL Attchment A. What would account
for any difference in these amounts?
(b) Please provide a nartive description of the tyes of compensation
included in the "other earings" category that appears in
CONFIDENTIA Attchment A.
Staff_PR_011 Attachment A Page 51 of62
To: David Meyer
Re: Public Counel Data Request Nos. 77 thugh 101
Docket Nos. UE-I00467 & UG-100468
Date: May 7,2010
Page 3
(c) Please provide the tota compensation for the 30 highest paid
employees in the following format (showing the porton of base
salar, incentive, and other compensation alocated between utility
and non-utility operations):
Employee Base Base Short-Short Long-Long ter Oter Oter
Title Salar Salar ter ter ter incentive non-Compo Compo
Utilty Non-incentive incentive incentive utility Utility Non-Utility
Utility Utility Non-Utility
Utility
PC-85
PC-86
PC-87
PC-88
Re: Avista Response to Public Counsel Data Request No. 17(a)
(a) Please identify where in Andrews' electronic workpapers
individual offcer percentage splits are provided.
(b) Please provide the "individual time spent on non-utilty activities"
estiates for 2009 as prepared by each individual executive.
(c) Please provide all updates made during 2009 to the "individual
time spenton non-utility activities" estimates prepared by
individual executives.
Re: A vista Response to Public Counsel Data Request 23
Please provide the Washigton tota test year costs related in any way to
Avista's "Buck-A-Block" program. Please indicate which FERC accounts
these costs are booked to and how they are allocated between utility and
non-utility operations and between junsdictions.
Re: Avista Response to Public Counsel Data Request No. 27
Please provide the specific FERC Accounts in which the 2009 Tralblazer
Banquet expenses ($16,898.49) are recorded.
Re: Avista Response to Public Counsel Data Request No. 27
Please provide the specific FERC Account(s) in which the 2009 Employee
Sumer Picnic ($72,124,70) expense is recorded. Please confi that ths
expense has been booked to utity operations and, if so, how it has
been allocated between junsdictions.
StafCPR_011 Attachment A Page 52 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 77 through 101
Docket Nos. UE-100467 & UG-100468
Date: May 7,2010
Page 4
PC-89
PC-90
PC-91
Re: Avista Response to Public Counsel Data Request No. 27
Please respond to the following:
(a) Provide the number of each of the following tye of attendee at the
2009 Tralblazer Banquet:
i. Curent employees
ii. Previous (retired) employees
iii. Guests of curent employees
iv. Guests of previous (retired) employees
(b) Provide the number of each of the following whose travel costs for
the 2009 Trailblazer Banquet were paid by Avista (via classic
limousine/sunset coach, reimbursement for expenses, or other
means):
1. Curent employees
11. Previous (retied) employees
111. Guests of curent employees
iv. Guests of previous (retired) employees
Re: Avista Response to Public Counsel Data Request No. 27
Please provide a breakdown of costs associated with entertinent, food,
and/or beverages provided at the 2009 Employee Sumer Picnic.
Re: Avista Response to Public Counsel Data Request No. 30,
Attachment A
Please provide the specific items included in the following accounts:
a) Electric FERC Account 905000 titled "Misc Customer Accounts"
b) Electrc FERC Account 908XX titled "Customer Assistace
Expense"
c) Electrc FERC Account 90900 titled "Advertising"
d) Electric FERC Account 912000 titled "Demonstrating & Selling
Expenses"
e) Electric FERC Account 913000 titled "Advertising"
t) Electric FERC Account 916000 titled "Miscellaneous Sales
Expenses"
g) Electrc FERC Account 925XX titled "Injuries and Damages
h) Gas FERC Account 912000 titled "Demonstrating & Sellng
Expenses
i) Gas FERC Account 913000 titled "Advertising"
j) Gas FERC Account 916000 titled "Miscellaneous Sales Expenses"
StafCPR_011 Attchment A Page 53 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 77 though 101
Docket Nos. UE-100467 & UG-100468
Date: May 7, 2010
Page 5
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PC-94
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PC-96
Re: Avista Response to Public Counsel Data Request No. 37
(a) Please provide the tota amount included in the curent test yea
before pro-forma adjustments for Washigton reguatory expenses
and identify which FERC accounts these amounts are recorded in.
(b) Please also provide the amount of, and documentar support for,
all pro forma adjustments to test year Washigton regulatory
expense amounts identified in (a).
(c) Please provide the total amount included in the previous test year
(Docket No. UE-090135/UG-090135) before adjustments for
Washigton reguatory expenses. Pleae also provide the amount
of any pro forma adjustments made to these amounts.
Re: Avista Response to Public Counsel Data Request 37(b)
Please explain what the Compliance Load study is and provide a copy of
this document. Please also provide a copy of Avista's contract with
KEMA Inc. for ths service.
Re: Avista Response to Public Counsel Data Request No. 40,
Attachment A
Please indicate which specific expenses listed on pages 1 and 2 of
Attchment A are allocated in Washigton and therefore included in the
curent test year.
Re: AvistaResponse to Public Counsel Data Request No. 40,
Attachment A
Please provide an updated version of Attchment A (spreadsheet for
Expenditue Organation UO 1) to include an additional colum indicatig
the specific case, matter, conference, or on-going issue tht each expense
relates to. If an expense does not relate to a case or matter, please indicate
that it is general. Please include ths colum directly to the right of the
current "Employee Name" column.
Re: Avista Response to Public Counsel Data Request No. 45,
Attachment B
Please provide the inormation presented in Attchment B for Accountig
Year 2009 in the form that it curently appears, but updated to include an
additional colum indicatig the specific case, matter, or issue related to
each individual expense entr. Please include ths colum directly to the
right of the current "Vendor Name" column.
StafCPR_011 Attachment A Page 54 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 77 though 101
Docket Nos. UE-100467 & UG-100468
Date: May 7, 2010
Page 6
PC-97
PC-98
PC-99
PC-100
PC-101
Re: Avista response to Public Counsel Data Request 47(d).
Please conf tht all trps taen for businesses puroses in Oregon and
Idaho were not included in test year expenses for Washigton ratepayers.
Re: Avista response to Public Counsel Data Request 47(e).
(a) Please describe when the cost analysis is performed and by whom
and provide all cost-effectiveness analyses completed for trps
taen durg the test year.
(b) Please break down total trps by destination, for the test year.
Include the number of trps to each destiation and the percent of
trps to each location compared to total trps.
Executive Benefits
(a) Please provide the system total, and Washigton-allocated amounts
included in the test year for the following:
i. Qualified Retirement or Pension Plan amounts for all
executive officers
11. 401(k) Plan amounts for all executive officers
111. Health and dental coverage for all executive officers
iV. Company-paid term life insurance for all executive officers
v. Disability insurance for all executive officers
Vi. Workers compensation and/or social securty benefits for
all executive offcers
vll. Executive Deferred Compensation Plan
V11. Self-Funded Death Benefit Plan
ix. Supplemental Executive Disability Plan
x. Pre-Set Diversification P1an(s)
(b) Please explain if and how the amounts provided above are
allocated between utility and non-utility operations.
Incentive Compensation
Please provide the tota amount included in the Washigton test year for
incentive compensation. Please also identify which FERC account( s)
incentive compensation expense(s) are booked.
Insurance
Please explain whether the following genera11iabi1ity and propert
insurce plans cover A vista Corporation, or A vista Utilities specifically:
(a) First Excess (AEGIS)
(b) Continuity Credit (AEGIS)
(c) Terrorism (AEGIS)
(d) Taxes & Fees (AEGIS)
( e) Second Excess (ElM
StafCPR_011 Attachment A Page 55 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 77 thugh 101
Docket Nos. UE-100467 & UG-100468
Date: May 7,2010
Page 7
(f) ElM Surlus (ElM
(g) Additional Limt of $50 milion (AEGIS London)
(h) Taxes & Fees (AEGIS London)
(i) Propert -- $250 milion Limt
(j) Propert -- $300 million Limt
(k) Proper - Inspection Serices
StafLPR_011 Attchment A Page 56 of 62
BEFORE THE WASHINGTON UTILITIES AN TRNSPORTATION
COMMSSION
WUTC v. Avista
Docket Nos. UE-I00467 and UG-I00468
Public Counsel Data Request Nos. 102 through 137
REDACTED VERSION
To: AVISTA
PC-102
PC-103
PC-l04
PC-105
PC-106
Re: Avista Response to Public Counsel Data Request No. 21
Please provide (1) position titles, and (2) all overhead costs for the
following Deparents:
(a) Marketig and Service Development Deparent
(b) Corporate Communcations Deparent.
Re: Avista Response to Public Counsel Data Request No. 21
Please provide the FERC accounts in which all costs of the Marketing and
Service Development Deparent and Corporate Communcations
Deparent were recorded for the test year, and explain how these costs
were allocated to Washigton gas and e1ectnc operations.
Re: A vista Response to Public Counsel Data Request No. 23
Please provide a narative description of the "Power Breakfasts" referred
to on page 2. Please also provide a list of all costs associated with "Power
Breakfasts," in which such costs are recorded, and how the amounts are
allocated between operations for test year revenue puroses.
Re: Avista Response to Public Counsel Data Request No. 23
Please provide a break out of all costs associated with Natu Gas
Advertsing, including amounts paid to outside vendors, as well as internl
overhead costs (such as employee sa1anes and miscellaneous
adminstrative expenses). Please also provide the FERC accounts in
which all such costs are recorded and how they are allocated to the curent
. Washigton test year operations.
Re: Avista Response to Public Counsel Data Request No. 23
Please provide all costs associated with the following customer
communications, includig in which FERC accounts each cost is recorded
for the curent test. year:
. "Compensation One Sheet" (in "Community Outreach"
folder).
. "Letter to the Community" (in "Community Outreach"
folder).
StafCPR_011 Attachment A Page 57 of 62
To: David Meyer
Re: Public Counel Data Request Nos. 102 though 137
Docket Nos. UE-100467 & UG-100468
Date: May 14,2010
Page 2
Redacted Version
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PC-lIO
PC-1I1
. "Regulated Utilty Ad" (in "Community Outreach" folder).
. "Avista Rates Video" (in "Energy Pricing" folder).
. "Renewable Energy Progras" material (in "Renewable
Energy" folder).
. "Avista Renewable Energy Brochure" (in "Generation,
transmission..." folder).
. "Wind Far" video (in "Generation, transmission..."
folder).
. "A vista Sustainabi1ity Report" (in "Corporate
Communications" folder).
. "Profits and Shareholders" one-sheet (in "Corporate
Communications" folder).
Re: Avista Response to Public Counsel Data Request No. 23
(a) Please provide a complete list of al costs incured durg t
he test year related to promotion of Avista's gas and
e1ectnc bil assistace progrs, includig the accounts in
which each expene was recorded.
(b) Please provide copies of all "Bil Assistance Advertising"
produced and/or underten durg the 2009 test year.
Re: Avista Response to Public Counsel Data Request No. 23
Please provide a complete list of all costs incured durg the test year
related to Avista's Wattson campaign, including the accounts in which
each expense was recorded.
Re: Avista Response to Public Counsel Data Request No. 23
Please provide an explanation of how Avista has used the "Wind Farm"
video, provided in the "Generation, transmission, and infrastructure
information" folder.
Re: Avista Response to Staff Data Request No. 54, Attachments
BandC
Were any costs removed from test year expenses (either as par of
Andrews' miscellaneous pro forma adjustment or otherwise) from
Accounts 912000 or 909000?
Re: Avista Response to Staff Data Request No. 54, Attachment B,
Tab A
Please explain what tye of Washigton advertsing expenses are included
in entnes with the Transaction Description, "OPTIONAL WIN
POWER".
StafCPR_011 Attachment A Page 58 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 102 though 137
Docket Nos. UE-100467 & UG-100468
Date: May 14,2010
Page 3
Redacted Version
PC-112 Re: A vista Response to Staff Data Request No. 54, Attachment A,
TabA2
Please describe the trsactions listed on lines 29,50, and 91, which
provide no vendor name or trsaction descnption.
PC-l13 Legal Costs
Please provide all expenses, both external and in-house, associated with
negotiation and/or litigation of the following matters (as identified in
Avista's most recent, publicly available Annual Report) included in the
curent Washigton test year, regardless of which FERC account in which
they are booked:
. Californa Refud Proceeding
. Pacific Nortwest Refud Proceeding
. Californa Attorney Genera Complaint
. Market conduct investigations by the FERC
. Complaints filed by varous pares related to the alleged
misconduct by pares in western power markets
. Waste oil delivered to the Harbor Oil, Inc. site in Portland,
Oregon
. Alumum dross located on a parcel of land owned by
A vista near the Spokane River
PC-114 Re: Avista Response to Public Counsel Data Request No. 40
Please provide the amounts of al11abor related overhead expenses not
included in Attachments A and B. Please also show in which FERC
accounts these amounts are recorded and how they have been allocated for
curent test year puroses.
PC-115 Re: Avista Response to Public Counsel Data Request No. 40
Please provide an explanation ofthe "Incentive!Bonus Pay" expenditure
that appears in FERC Account 930200 on page 2 of Attchment B.
PC-116 Re: Avista Responses to Public Counsel Data Requests Nos. 40 and 45
Please provide an explanation of what the entr "#N/A" refers to (as it
appears in the Vendor Name and/or Employee Name colums of the
attchments to these responses).
PC-I 17 Re: Avista CONFIDENTIAL Response to Public Counsel Data
Request No. 43
Be 'n Confidential)
Staff_PR_011 Attchment A Page 59 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 102 though 137
Docket Nos. UE-100467 & UG-100468
Date: May 14,2010
Page 4
Redacted Version
PC-118 Re: Avista Response to Staff Data Request No. 67
Please state all defendats naed in the:
(a) 2000 Clais,
(b) 2002 Claims.
PC-119
PC-120
PC-121
PC-122
PC-123
PC-124
Re: Dues
Please provide a complete list of all organations and/or associations to
which Avista paid dues durng the test year.
Re: Avista Response to Public Counsel Data Request No. 25 and 26
Please provide a copy of the 2007, 2008, and 2009 Anual Reports EEl,
AGA, and every other organation of which the Company was/is a
dues-payig member durg such yea.
Re: Avista Response to Public Counsel Data Request No. 25 and 26
Please provide complete copies of invoices received from EEl and AGA
for 2009 (test year) dues.
Re: Avista Response to Public Counsel Data Request No. 25 and 26
Has the Company included in test year operatig expenses any amount for
EEVAGA Media Communcations? If so, state the amount, indicate in
which account ths has been recorded, and provide a citation to any and all
COIlission Orders or other author upon which the Company is relyig
for the inclusion of such expense(s) in the test year.
Re: Avista Response to Public Counsel Data Request No. 25 and 26
List all travel and enterinent expenses incured in the test year by
Avista employees in relation to EEVAGA and other industr association
activities. Show accounts, amounts, descnptions, job titles, and reason( s)
for the expense(s).Provide a copy of any employee time and expense
reports and invoices documenting such expenses.
Re: Avista Response to Public Counsel Data Request No. 25 and 26
Do any Àvista personnel actively parcipate on Commttees and/or any
other work for any industr organation to which the Company belongs?
If so:
(a) State specificaly which employees paricipate, how they
are compenated for their tie, and the purose and
accomplishments of any such association-related work.
StafCPR_011 Attachment A Page 60 of 62
To: David Meyer
Re: Public Counsel Data Request Nos. 102 though 137
Docket Nos. UE-100467 & UG-100468
Date: May 14,2010
Page 5
Redacted Version
PC-125
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PC-131
(b) List any and all reimbursements received from industr
associations for work performed for such organzations by
Avista employees.
Re: Avista Response to Public Counsel Data Request No. 25
Please provide any documents in Avista's possession that show how EEl
spends the dues it collects, including the percentage that goes to legislative
advocacy, legislative policy research, campaign contnbutions, other
political activity, regulatory advocacy, regulatory policy reseach,
advertsing, marketing, utility operations and engineerig, fince, legal
plang, customer service, and public relations.
Re: Avista Response to Public Counsel Data Request No. 26
Please provide any documents in Avista's possession that show how AGA
spends the dues it collects, including the percentage that goes to legislative
advocacy, legislative policy research, campaign contnbutions, other
political activity, reguatory advocacy, regulatory policy research,
advertsing, marketing, utility operations and engineerig, finance, legal
planng, customer service, and public relations.
Re: Avista Response to Staff Data Request No. 35
Please indicate for each year listed (2006-2009) whether A vista met their
taget tie for answerg calls.
Re: Avista Response to Staff Data Request No. 41
Please explai how A vista at fault complaints are deterined from all
complaints. Please provide the actual complaint level taget for 2009 and
indicate whether the Company met or did not meet its taget.
Please provide in table format a list of all service quality indices and their
tagets and results for the years 2000-2009 and indicate whether the
Company met or did not meet the tagets.
Please provide the monthly SQI performance data for both gas and e1ectnc
service for 2009.
Please provide any internl studies, audits, analyses, or other reports, that
evaluate or discuss Avista's customer service, credit and collections
programs, reliability of service, and operation of the customer call center
in terms of progr efficiency, and any other indicia of cost effect
operations.
StafCPR_011 Attachment A Page 61 of62
To: David Meyer
Re: Public Counsel Data Request Nos. 102 thugh 137
Docket Nos. UE-100467 & UG-100468
Date: May 14, 2010
Page 6
Redacted Version
PC-132 Please provide a complete descnption of the gas and electrc meters used
by A vista in its Washigton serice terntory. Please also indicate whether
Avista uses automatic meter readig (AM) technology in its Washigton
service terntory. If not, please explain why.
PC-133
PC-134
PC-135
PC-136
PC-137
Please provide all quarterly and/or anual reports associated with Avista's
meter and billig perormance.
Please provide the tota numbers of meter errors that occured on a
monthy basis from 2009 to date.
Please provide the total number of bils issued to correct metenng errors
by month from 2009 to date. This is a contiuig request and should be
updated as additional data becomes available durg the pendency of ths
rate case.
For each bil issued to correct metenng errs from 2009 to date, please
provide the number of unbiled months from the tie the meter failed to
the tie the corrected bil was issued.
Please provide a break down of Washigton customer complaits related
to meter erors for the year 2006-2009. Please also indicate where these
are accounted for in the complait statistic categories provided in response
to Staff Data Request 41(b).
StafCPR_011 Attachment A Page 62 of 62
June 26, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 1 -7
Response Due By
July 13,2009
-
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or ifyou need more time. '
1. Please provide a breakout of non-labor and labor expense for all expense
accounts by FERC account (or subaccount) for each year 2006 through 2008. If
an account is directly assigned to Oregon, please note it as such. If an account
is allocated to Oregon, please provide the break out on a system and on an
Oregon basis.
2. Please provide in electronic format, on a system basis (for Gas operations) a
breakout of all revenues by FERC Account beginning with FERC account 440
through FERC account 450. Please demonstrate how the revenues are
allocated or directly assigned to Oregon by FERC account. Please include an
explanation for all revenues collected by the Gas operations that are not either
allocated or directly assigned to Oregon.
3. Please provide in electronic format, on a system basis (for Gas operations) a
breakout of all revenues by FERC Account beginning with FERC account 500
through 598 as well as FERC accounts 900 through 935. Please demonstrate
how the expenses are allocated or directly assigned to Oregon by FERC
account.
4. Please show a breakout of all wholesale sales for the years 2005 through 2008.
Please indicate which transactions were allocated to Oregon; whether the gas
was physically delivered to an Oregon location and where the corresponding
revenues were allocated. Please also show the corresponding expenses
associated with each wholesale transaction, where the expenses were assigned
and provide a narrative description of the expenses.
StafLPR_011 Attachment C Page 1 of 100
A vista Corporation
June 26, 2009
Page 2
5. Please provide separate electronic worksheets with formulae intact showing the
weather-normalizing calculations and all assumptions for 2006, 2007 and 2008.
6. Please provide electronic worksheets showing any adjustments to the 2008
actual revenues and the basis for the assumptions related to each adjustment.
In addition, please show the indices applied to each category of revenues in
order to formulate the 2010 test period.
7. In reference to Avista/501, Andrews/1, Column b please explain the following
variances as they relate to the UG 171 Phase II docket, Exhibit Avista/502,
Pluth/1 :
a. O&M expenses are stated as $11.5 millon in the UG 186 test period
rather than $11.0 millon in the UG 171 case.
b. Taxes other than income are stated as $5.9 milion in the UG 186 test
period rather than $4.5 millon in the UG 171 case.
c. Current Federal Income taxes are stated as $414,000 in the UG 171 case
rather than $236,000 in the UG 186 test period.
d. State Income Taxes in the UG 186 test period are zero in the UG 171
case while they are in a refund status of $161 ,000 in the UG 186 test
period.
e. Utility Plant -in-service is stated as $230 milion in the UG 186 test period
rather than $213 millon in the UG 171 case.
f. Accumulated Deferred taxes increases from $19.2 millon in the UG171
case to $21.9 milion in the UG 186 test period.
g. Materials & Supplies increase from $3.2 millon in the UG 186 test period
to $5.1 milion in UG 171.
StafCPR_011 Attachment C Page 20f100
A vista Corporation
June 26, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-
2148; (puc.datarequeststâstate.or.us) and one complete copy to the attention of
counsel for PUC Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem,
OR 97301-4096 (jason.w.jonestâstate.or.us).
"
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsontâstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Carla Owings
cc: Service List
StafCPR_011 Attachment C Page 3 of 100
June 30, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR8
Response Due By
July 15, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
8. In exhibit AVIST Al501 Andrews/Page 4 of 6 please provide full details for the
"Other Gas Expenses" of $544,000 at line 8. Provide all workpapers and other
documentation for these expenses in electronic format.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequests(âstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jones(âstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson(âstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Ken Zimmerman, ken.zimmerman(âstate.or.us
cc: Service List
StafLPR_011 Attachment C Page 4 of 100
July 2,2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DRs 9-12
Response Due By
July 21, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
9. Please provide the amount in rate base for storage cushion gas approved in the
last general rate review, the current amount in rate base, and the amount
proposed in UG 186. Explain and document any differences.
10. Deducting the rate base level for storage cushion gas, what is the remaining level
of storage in rate base? Compare this with the same approved in the last
general rate review and the amount proposed in UG 186. Explain and document
any changes.
11. At Avista/500 Andrews/Page 15, please explain and document the $18,943
proposed increase in underground storage expenses.
12.ln Knox's incremental investment cost analysis what was the investment level
included for the 2008 Jackson Prairie expansion? Please explain and document.
Over what time period does the cost analysis assume this investment wil be paid
off in full?
Staft'pR_011 Attachment C Page 5 of100
July 2,2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestsßìstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonesßìstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsonßìstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Ken Zimmerman, ken.zimmermanaystate.or.us
cc: Service List
StafCPR_011 Attachment C Page 6 of 100
July 16, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
72 - 90
Response Due By
July 30, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
72. In reference to Avista's calculation of Net-to-Gross Factors, please provide a
narrative explanation of the "Energy Resource Supplier Assessment' and the
"Oregon Excise Tax" and the basis used to determine the assessment or tax.
a. Please provide ledger documentation of actual Resource supplier
assessments paid by Avista for the years 2005 through 2008, the forecast
for 2009 as well as how the forecast for 2010 was developed.
73. Please provide in electronic format a breakout between Depreciation Expense
and Amortization Expense that reconciles with Avista's forecasted total for the
test period of $5.5 millon. Please separately provide a breakout of the total
adjustment to Depreciation and Amortization for the forecasted period of $2.2
millon with an explanation to what the depreciation and amortization apply to and
the in-service dates for the associated plant.
74. What is the percentage of working capital Avista assumes as part of this case?
75. Please provide detail for the following category of expenses:
a. Working Capital-what is the percentage used by Avista to determine
working capital?
b. Fuel Stock
c. Materials and Supplies
d. Contributions to Aid in Construction (CIAC)
76. Please provide the historic balances for each of these categories named above
in question no. 75: working capital, fuel stock, materials and supplies and CIAC
StafLPR_011 Attachment C Page 7 of 100
Avista - UG 186
July 16, 2009
Page 2
(on both a system-wide basis and an Oregon allocation) for the years 2005
through 2008, with the forecast for 2009 (based on actuals to date and six
months of estimates) and 2010. Please demonstrate what allocators are used to
allocate these expenses to Oregon and the base assumptions related to those
allocators.
77. Please provide all the work papers in electronic format associated with the
calculations used to determine each adjustment in the revenue requirement
model, not just the summary of each adjustment, but the work papers and details
behind each adjustment.
78. Please provide a narrative description and purpose for adjustment "f' - "Eliminate
Pass-Through Revenues". Please provide historic information related to "Pass-
Through Revenues" for 2005 through 2008 and a forecast for 2009 (based on
actuals to date and six months of estimates) and 2010.
79. Please provideseparate electronic work papers showing how Avista performed
the weather normalization calculation for the years 2005 through 2008. Please
also provide an electronic worksheet showing how the calculation was performed
for the 2010 test period.
80. Please provide in a format similar to that provided on workpaper Andrews/d6 a
breakout of the number of FTEs for Officers, Exempt Employees, non-exempt
employees and union workers (in electronic format) for the years 2006 through
2008, a forecast for 2009 (based on actuals to date and six months of estimates)
and 2010*.
81. Please provide in a format similar to that provided on workpaper Andrews/d6 a
breakout of the number of vacancies in each category of Officers, Exempt
Employees, non-exempt employees and union workers (in electronic format) for
the years 2006 through 2008, a forecast for 2009 (based on actuals to date and
six months of estimates) and 2010*.
82. Please provide a breakout of the dollars paid in 2006 - 2008 for Offcers, Exempt
Employees, non-exempt employees and union workers (in electronic format) and
an estimate of dollars expected to be paid in 2009 (based on actuals to date and
six months of estimates) and 2010 for the same category of workers.* Please
indicate the percentage of these amounts that were attributed to capital costs as
well as to O&M expenses. Please provide a narrative for the 2010 rate case
amount explaining how the test period breakout for capital and O&M was
determined.
StafCPR_011 Attachment C Page 8 of 100
Avista - UG 186
July 16, 2009
Page 2
83. Please separately identify (from request no. 81) the amount of overtime that wil
be paid for for Officers, Exempt Employees, non-exempt employees and union
workers (in electronic format) and an estimate of dollars expected to be paid in
2009 (based on actuals to date and six months of estimates) and 2010*.
84. Please provide a breakout of amounts for each type of bonus paid in 2006 - 2008
for Officers, Exempt Employees, non-exempt employees and union workers (in
electronic format) and an estimate of dollars expected to be paid in 2009 (based
on actuals to date and six months of estimates) and 2010*1. Please include an
explanation for the various types of bonuses paid, the percentage of these
bonuses that are currently included in.base rates.
85. Please provide any market -studies performed by Avista that demonstrate that in
2005 or 2006 Avista's employees were at or below market for comparable and
like industries. To the extent Avista has not performed any such market studies,
please provide the market -information for the time periods 2005 and 2006 that
demonstrate how Avista's employees compare to market for each of the various
positions for exempt and non-exempt employees as well as officer salaries.
86. Related to the current adjustment included in Avista's application pursuant to the
Wages & Salary study, please provide a narrative explanation for why Avista
believes that the Commission should increase expenses related to wages and
salaries if Avista's actual wages and salaries expense is lower in the test period
than what may be demonstrated by using the three-year wage analysis.
87. Please provide a detailed explanation of how Avista determined the deferred
income tax amount for the test period and any work sheets (both hard copy and
electronic format) associated with how this amount was determined. Please
provide the historic balances for each of these categories (on both a system-wide
basis and an Oregon allocation) for the years 2005 through 2008, with the
forecast for 2009 (based on actuals to date and six months of estimates) and
2010.
88. Please provide ledger detail showing what is being amortized in Avista's category
labeled "Amortization of Leasehold improvements". Please reconcile on both a
system basis and an Oregon basis the amount requested for the test period
associated with Amortization. In addition, please demonstrate what factors are
1 * To the extent the information requested above has been provided in hard-copy workpapers with the
oridinal filing, please provide the electronic version of the workpapers and a narrative explanation...or
futher electronic information if requested...associated with these requests.
StafCPR_011 Attachment C Page 9 of 100
Avista - UG 186
July 16, 2009
Page 2
used to allocate these amounts to Oregon. Please provide the historic balances
for.each of these categories (on both a system-wide basis and an Oregon
allocation) for the years 2005 through 2008, with the forecast for 2009 (based on
actuals to date and six months of estimates) and 2010.
89. Please provide electronic.workpapers showing how ratebase was determined for
the test period. Please identify per year all ratebase additions and include an
explanation for the ratebase being added, the in-service dates and the location of
the new ratebase. In addition, please include how depreciation was calculated
for each addition and show the accumulated depreciation balances, the
estimated useful life new and the salvage values that relate to the additions.
Please provide the historic balances for each of these categories (on both a
system-wide basis and an Oregon allocation) for the years 2005 through 2008,
with the forecast for 2009 (based on actuals to date and six months of estimates)
and 2010.
90. Please provide a breakout of all taxes other than income tax. Please provide the
historic balances for each of these categories (on both a system-wide basis and
an Oregon allocation) for the years 2005 through 2008, with the forecast for 2009
(based on actuals to date and six months of estimates) and 2010.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestsCcstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonestãstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson(Çstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Carla Owings
Lisa Gorsuch
cc: Service List
StafLPR_011 Attachment C Page 10 of 100
July 17, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
91-94
Response Due By
July 31,2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
91. Please demonstrate the numbers represented in testimony at Avista/500,
Andrews/8 Lines 9-10 where Avista describes an increase to A&G expenses of
$2.6 milÎion. Please provide a breakout that demonstrates the same A&G
expenses for 2006 and the changes for 2007,2008 and 2009.
92. Please demonstrate the numbers represented in testimony at Avista/500,
Andrews/8 Lines 17-18 where Avista describes an increase to O&M expenses of
$1.4 millon. Please provide a breakout that demonstrates the same O&M
expenses for 2006 and the changes for 2007,2008 and 2009.
93. Please demonstrate the numbers represented in testimony at Avista/500,
Andrews/9 Lines 1-4 where Avista describes an increase to ratebase of $76
millon along with the offsets for accumulated depreciation and increase in DFIT.
Please show the actual plant additions from 2006 through 2008 and indicate the
additions that had been proformed in the 2006 test period for UG 181.
94. Please provide the actual expenses for FERC Account 907, Supervision;
Account 908, Customer Assistance Expenses and Account 909, Informational
and Instructional Expenses for the years 2005-2008, a forecast of 2009 (based
on six months of actuals and six months forecast) and a forecast for 2010.
StafLPR_011 Attachment C Page 11 of 100
Avista - UG 186
July 17, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestscæstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonescæstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsoncæstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Carla Owings
cc: Service List
StafCPR_011 Attachment C Page 12 of 100
July 20, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 95 - 97
Response Due By
August 3, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
95. Please provide transaction summaries for non-labor costs recorded in FERC
accounts 870 through 894 (Oregon Situs and Oregon allocated) for January 2008
through December 2008. (See Avista Andrews work papers be and b7) Please
place in Excel and include:
a. Amount charged;
b. Description of cost;
c. Name of vendor (if applicable);
d. Business Unit (Profit Center) being charged;
e. Oregon allocated cost (for Oregon allocated); and
f. Service provided (e.g. lease, etc.).
96. For each account 870 through 894 (Oregon Situs and Oregon allocated), please
provide 2007, 2008, and 2009 to-date (as of June 30) non-labor cost information
in the following table format:
Account.2007 2008 2009 To-date
870
871
Etc.
97. Concerning Andrews work papers FI3 (ex. Account 870), please provide the CPI
used to escalate 2008 to 2009 and 2009 to 2010. (It appears that a 3.8%
escalation was used for both years.)
StafCPR_011 Attachment C Page 13 of 100
UG 186
July 20, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-
2148; (puc.datarequestsCâstate.or.us) and one complete copy to the attention of
counsel for PUC Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem,
OR 97301-4096 (jason.w.jonesCâstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsonCâstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Marion Anderson/Michael Dougherty
cc: Service List
StafLPR_011 Attachment C Page 14 of 100
July 21, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 98 -115
Response Due By
August 4, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
98. Please provide, in the below format, the following information concerning
Property Damage loss from January 2006 to June 2009:
Loss Description Date of Total Insured Loss Uninsured Type of
Loss Claim (Without Loss Loss
deductible)(Uninsured,(Deductible,
Self-insured,Self-
and/or insured,
Deductible)Uninsured)
99. Please provide, in the below format, the following information concerning
Liability loss from January 2006 to June 2009 (please do not duplicate any
item in the table above):
Loss Description Date of Total Insured Loss Uninsured Type of
(include D&O,Loss Claim (Without Loss Loss
Business deductible)(Uninsured,(Deductible,
Interruption,Self-insured,Self-
Terrorism, etc.)and/or insured,
Deductible)Uninsured)
StafCPR_011 Attachment C Page 15 of 100
UG 186
July 21, 2009
Page 2
100. Please provide, in the below format, the following information concerning
Workers Compensation loss from January 2006 to June 2009:
Loss Description Date of Loss Total Claim Insured Loss Uninsured
(Without deductible)Loss
101. Please provide transaction summaries for non-labor costs recorded in FERC
accounts 901 through 905 and 920 through 935 (Oregon Situs and Oregon
allocated) for January through December 2008. Please place in Excel and
include:
a. Amount charged;
b. Description of cost;
c. Name of vendor (if applicable);
d. Business Unit (Profit Center) being charged;
e. Oregon allocated cost (for Oregon allocated); and
f. Service provided (e.g. reports to stockholders, lease, etc.).
102. For each account 901 through 905 and 920 through 935 (Total Company and
Oregon allocated), please provide the 2007 and 2009 (Jan-June) non-labor
expense information in the following table format:
Account Jul - Dec 2007 Jul - Dec 2007 Jan - Jun 2009
901
902
Etc.
103. For FERC accounts 930 and 935, please provide work papers, supporting \
documentation and an explanation demonstrating how the 2010 expenses of
$431,347 and $772,142 were developed? Please also explain the reason(s)
why these accounts are forecasted to increase significantly compared to 2006
- 2008 historical costs.
104. In the following table format, please provide the FAS 87 and FAS 106
Postretirement Plan information for 2006 through 2008 and an estimated for
2009 and 2010. Please explain any variation between Long-term Rate of
Return on Assets, and Actual Rate of Return on Assets.
StafCPR_011 Attachment C Page 16 of 100
UG 186
July 21, 2009
Page 3
.
2006 2007 2008 2009 (est)2010 (est)
Obligation at
December 31
Fair Value of Plan
Actual Return on
Assets
Benefits Paid .
Funded Status
Accumulated
Benefit ObliQation
Funded Ratio
Service Cost
I nterest Cost
Expected Return on
Assets
Amortization Of
Transition Asset
Amortization Of
Prior Service Cost
Recognized (Gain)
Loss
Net Periodic
Pension Cost
(Income)
Avista's Contribution
to Plan
Discount Rate for
Benefit ObliQation
Discount Rate for
Annual Expense
Long-term Rate of
Return on Assets
Actual Rate of
Return on Assets
105. For FAS 87 and FAS 106, please provide the estimated effect on 2010 Net
periodic postretirement cost (income) if the discount rate is changed 25 basis
StafCPR_011 Attachment C Page 17 of 100
UG 186
July 21, 2009
Page 4
points in both directions and expected rate of return is changed 25 basis
points in both directions.
106. In what accunts (FERC) are SERP costs recrded? What were the costs for
each year 2006 through 2008, and January through June 2009?
107. Please provide a breakdown of the costs involved in the director's fees. Are
any of these fees paid to directors who are also officers of Avista? Please
explain. Also, please explain the type and method for any director
compensation paid in stock (Le., stock awards, stock options, etc).
108. In the following table format, please provide medical benefi costs for the years
2006 through June 2009 and estimated for 2009 and 2010. Please also
explain if the amounts reflected in the Company's response are before or after
employer/employee sharing. For the 2009 and 2010 estimates, please
explain the assumptions relied upon (Le. increased employees, specific
escalation factor to premiums, etc) in arriving at the forecasted amounts.
2006 2007 2008 Jan - Jun Jul- Dec 2010 (est)
2009 (act)2009 (est)
Medical
Dental
401(k)
Group Life
Insurance
Retiree Life
Insurance
Long-Term
Disabilitv
Other
(please
label)
Total
109. Please provide the current employer/employee contribution for each labor
group (non-represented, and each union group) for medical (health, dental,
and vision) plans (Le. 90/10, 85/15, 80/20, etc.). Is the Company anticipating
any change to these percentages for 201 O? Please explain.
110. Please provide "term" sheets from providers that cite the premium costs for
fiscal year 2008 (and 2009 if applicable) for medical, dental, vision, life, short-
StaftPR_011 Attachment C Page 18 of 100
UG 186
July 21, 2009
PageS
term disability, and long-term disability insurance. Please include a summary
table of the costs.
111. In the following table format, please provide the following information for
insurance premiums/self-insurance costs.
Cost January-January-January-Forecasted
December 2006 December 2007 December 2008 Calendar Yr 2010
Property Insurance
Premiums
Property-
Uninsured Loss
Liability Insurance
Premiums
Liability -
Uninsured Losses
Terrorism -
Premiums
Terrorism -
Uninsured losses
Workers
Compensation
Premiums
Workers
Compensation -
Uninsured Losses
Other Risk
Management
Expenses (FERC
accounts 924 and
925)
112. When were property insurance, liability insurance, workers compensation
insurance, and other insurance policies last updated? What is the termination
date of these policies?
StafCPR_011 Attachment C Page 19 of 100
UG 186
July 21, 2009
Page 6
113. Please provide "term" sheets that cite the premium costs for all current
insurance premiums.
114. If the policies above are set to terminate in the next three months, has Avista
received any preliminary estimates of renewal costs? If so, please provide
these estimates.
115. Please identify all policy holder (insurance) credits/bonuses that Avista has
received since 2004. Does Avista anticipate receiving any policy holder
credits/bonuses during 2009 or 201 O? If so, please identify each individual
credit and the amount of each credit.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-
2148; (puc.datarequeststâstate.or.us) and one complete copy to the attention of
counsel for PUC Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem,
OR 97301-4096 (jason.w.jonestâstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsontâstate.or .us
[phone]
Fax: [phone]
Staff Initiator: Dustin Ball
cc: Service List
StafCPR_011 Attachment C Page 20 of 100
July 21 , 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
116 - 123
Response Due By
August 4, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
116. Please identify the advertising expenses included in the UG 186 test year; including
references to the appropriate UG 186 testimony and/or exhibit pages.
117. Describe the programs and activities associated with the expense identified in response to
Data Request No. 116 above, including how the expense is allocated between the categories
identified in OAR 860-026-0022(2) and to which FERC and internal Avista accounts the
expense wil be booked.
118. Please identify any other budgeted advertising expense for the same period that wil NOT
be included in rates.
119. Describe the programs and activities associated with the expense identified in response to
Data Request No. 118 above, including how the expense is allocated between the categories
identified in OAR 860-026-0022(2) and to which FERC and internal Avista accounts the
expense wil be booked.
120. Please provide a work paper that shows the calculation of the UG 186 Category A limit
provided in OAR 860-026-0022(3)(a).
121. If the UG 186 test year Category A advertising expenses exceed the
OAR 860-026-0022(3)(a) limit, please provide support for including the additional expense in
rates.
StafCPR_011 Attachment C Page 21 of 100
July 21, 2009
Page 2
122. If the UG 186 test year includes any Category C advertising expense associated with a
promotional activity or a promotional concession proram, please describe the activity or
program, identify any related labor and non-labor expenses, the FERC and internal Avista
account to which the expense wil be booked and include references to appropriate exhibit
pages. Please demonstrate the reasonableness of each promotional activity and concession
identified consistent with the requirements of Division 026 of the Commission's administrative
rules.
123. Please describe the activities and associated expense associated with marketing research
and sales activities (including retention of customers) that is included in the
UG 186 test year. Please include references to the UG 186 testimony and exhibits, and to
which FERC and internal Avista accounts this expense is booked.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-
2148; (puc.datarequests(istate.or.us) and one complete copy to the attention of
counsel for PUC Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem,
OR 97301-4096 (jason.w.jones(istate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson(istate.or. us
[phone]
Fax: [phone]
Staff Initiator: Lisa Gorsuch
Carla Owings
cc: Service List
StafCPR_011 Attachment C Page 22 of 100
July 22, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 124 -126
Response Due By
August 5,2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
124. Please explain the method Avista uses to record CWIP projects when information
is available that construction will not be completed and an asset not be placed in
service.
a. If expensed, are projects recorded in above the line or below the line
accounts? Please provide accounts projects are expensed in?
b. Please provide the 2007,2008, and 2009 amounts of canceled CWIP
projects that were expensed. For each year, please provide accounts
canceled CWIP projects were expensed.
125. Please provide a detailed breakdown on the Account 813,2010 cost of $47,831
attributable to Resource Management and Planning.
126. Concerning Account 897, please explain:
a. The significant 2008 to 2009 increase in Preventive Maintenance;
b. A detailed breakdown of 2009 and 2010 projected costs;
c. A 3-year average of failed maintenance costs; and
d. The 2007,2008, and 2009 to-date failed maintenance costs.
StafCPR_011 Attachment C Page 23 of 100
UG 186
July 22, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-
2148; (puc.datarequests(ãstate.or.us) and one complete copy to the attention of
counsel for PUC Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem,
OR 97301-4096 (jason.w.jones(ãstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
iudy. johnson(ãstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Marion Anderson/Michael Dougherty
cc: Service List
StafCPR_011 Attachment C Page 24 of 100
July 22, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
127-138
Response Due By
August 5,2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time. .
127. For Capital Expenditures listed at Avista/400, DeFelice/5 in Table 3, please
provide a breakout description of the projects that match to the totals given in the
table for 2005 through 2008 similar in format to the descriptions provided in Table
, 1 at Avista/400, DeFelice/4.
128. Please provide work papers demonstrating how the amounts for capital projects
listed in Table 3 for 2009 and 2010 were derived. If these amounts were derived
using an escalation factor that was applied to the 2008 actual amounts, please
provide a break-out that shows the escalation factor, an explanation of why the
2008 base period is the best estimate of cost and the basis for escalation factors
for any period in which an escalation factor is applied.
129. Please separately provide the actual forecasted "in-service" and "close-to-books"
dates (by the month and year) for each project listed in Tables 1 and 2 found at
Avista/400, DeFelice/4. Please explain how each project is allocated to Oregon,
the basis of the allocation and whether this is a historic allocation or an updated
allocation.
130. For each projects listed as General Plant Capital Expenditures in Table 1, please
indicate whether the project is a System-wide project that wil provide service to
the entire Avista Corporation (which includes Electric Operations) or whether
these are System-wide projects for only Gas Operations. For any project where
the System-wide project also includes Electric Operations, please provide the
total System-wide amount (if it differs from the amount in the table...if not, please
indicate that the amount in the table is the system-wide amount) and explain how
Staf"-PR_011 Attachment C Page 25 of 100
Avista - UG 186
July 22, 2009
Page 2
the capital expenditure was allocated between Electric Operations and Gas
Operations.
131. Please provide all of the information provided in Exhibit/703, Hirshkorn/Page 1 of
4 for 2007 in the same format previously provided in the named exhibit.
132. In reference to Exhibit/703, Hirshkorn/Page 1 of 4, please explain why the total
sales volume in 2008 is only 82.8 milion. Please reconcile this amount with
Avista's FERC Form 1, Oregon Supplemental, page 45. In this report Avista
indicates that Total Therm Amounts for Oregon were 88.8 millon.
133. Please reconcile the average number of customers (both total and by schedule)
used in Exhibitl03, Hirshkorn/Page 1 of 4 with Avista's FERC Form 1, Oregon
Supplemental, page 2 for 2006, 2007 and 2008. Please provide a work paper
showing how the numbèrs are adjusted, the base assumptions for the
adjustments and how Avista calculated the forecasted number of average
customers for 2010 (both for the total and by schedule).
134. In reference to Staff's Data Request NO.1 01, if Avista used escalators to
estimate the number of average customers for the test period (both the total and
by schedule), please provide a breakout of those escalators for 2009 separate
from 2010.
135. Please provide the actual number of customers by schedule in the same format
provided in Exhibit/703, Hirshkorn/Page 1 of 4, for each month between January
and June of 2009.
136. Please reconcile the number of therms (both the total and by schedule) used in
Exhibit/703, Hirshkorn/Page 1 of 4 with Avista's FERC Form 1, Oregon
Supplemental, page 2 for 2006, 2007 and 2008. Please provide a work paper
showing how this number is adjusted, the base assumptions for the adjustment
and how Avista calculated the forecasted number of average customers for 2010.
137. In reference to Staff's Data Request NO.1 04, if Avista used escalators to
estimate the number of therms (both the total and by schedule) for the test
period, please provide a breakout of those escalators for 2009 separate from
2010.
138. Please provide the actual number of therms served by schedule in the same
format provided in Exhibit/703, Hirshkorn/Page 1 of 4, for each month between
January and June of 2009.
StafCPR_011 Attachment C Page 26 of 100
Avista - UG 186
July 22, 2009
Page 3
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequeststãstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonestãstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsontãstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Carla Owings
cc: Service List
StafLPR_011 Attachment C Page 27 of 100
July 22, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
139
Response Due By
August 5, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
139. Please provide the actual system transmission losses for 2003 to 2008 that
would be reported as total sales and other deliveries unaccounted for in the
FERC Form 1, Oregon Supplemental.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequeststCstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonestCstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
i udy. johnsontCstate. or. us
[phone]
Fax: [phone]
Staff Initiator: Carla Owings
cc: Service List
StafLPR_011 Attachment C Page 28 of 100
July 23, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 140-142
Response Due By
August 6, 2009
Please provide responses to the following request for information. Contactthe
undersigned before the response due date noted above if the request is unclear or if
you need more time.
JURISDICTIONAL COST AllOCATIONS
140. Please provide electronically a listing for each state jurisdiction of all
allocation factors and their corresponding percentage values used to prepare
Exhibit 501 Andrews (pages 1,4-6). This should include data on common to
gas and electric services expenses, revenues, and rate base (FERC
accounts) used to derive the factors for both 2008 actual and 2010 projected
test period.
141. Please provide electronically information on system gas allocation factors for
each state jurisdiction, listing separately for each state, used by Avista for
both 2008 actual and 2010 test period.
OREGON WEATHER SENSITIVITY
142. Please provide in electronic format the work papers, explanation of
assumptions, methods and regression model used by Avista to derive its
Oregon Weather sensitivity results (response to DR 005, Attachment B)
StafCPR_011 Attachment C Page 29 of 100
July, 23 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequeststâstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonestâstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsontâstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Irina Philips
cc: Service List
StafCPR_011 Attachment C Page 30 of 100
July 23, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 143-147
Response Due By
August 6, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
Uncollectibles
143. For the years 2006 through 2008, please provide on an Oregon basis:
a. Net actual net write-offs for each year.
b. Number of non-arrearage equal pay accounts for each year.
c. Total number of arrearage payment agreements initiated in each year
(e.g., Levelized payment agreements, Equal pay arrearage plans, etc.).
d. Energy assistance applied to customer's accounts (e.g., L1EAP and other
public funds, outside agency funds, internal company funds of
shareholder/customer voluntary funds, other, etc.).
e. Total non-payment disconnections for each year.
f. Direct Gas Revenues less "Sales for Resale".
Membership and Dues
144. Please provide the equivalent Membership and Dues listed on work paper C2
and C3 for the years 2006, 2007, and 2008. Please include FERC account
number, title, description, and amount.
Other Revenues
145. On an Oregon basis, please provide all the Operating Revenue accounts and
their annual actual amounts that have associated uncollectible expenses for the
years 2006,2007, and 2008. Please include FERC account number and title.
StafCPR_011 Attachment C Page 31 of 100
UG 186
July 23, 2009
Page 2
Materials and Supplies
146. Does Avista Corporation have a Materials and Supplies adjustment in its General
Rate Case filing? If so, please provide an explanation.
Prepaid expenses
147. Does Avista Corporation have a Prepaid Expense (FERC account number 165)
adjustment in its General Rate Case filing? If so, please provide an explanation.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551 ; (puc.datareguests(âstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonescmstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson(âstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Paul Rossow
cc: Service List
StafCPR_ 011 Attachment C Page 32 of 100
July 27, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 148
Response Due By
August 7, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
148. For Exhibit Avista/400 by Dave DeFelice, please provide in electronic Excel
spreadsheet format, work papers and calculations used to develop capital
additions, depreciation expenses and reserves in sufficient detail to allow staff to
replicate the company's numbers. The electronic worksheets should show:
(1) How adjustments were made to the plant in service by December 31,
2008 to accumulated depreciation,
(2) How adjustments were made to reflect 2009 and 2010 plant additions and
associated accumulated depreciation,
(3) Capital Additions in Service Date for each account by FERC functions,
(4) Depreciation Rates used for each account by FERC functions,
(5) Allocation Factors (in %) used for each account by FERC functions,
(6) Average 12 Month Capital Additions for each account by FERC functions.
(7) Depreciation and Amortization Expenses and Reserves including monthly
calculations for each account by FERC functions.
StafCPR_011 Attachment C Page 33 of 100
Avista Corporation
July 27, 2009
Page 2
Please provide an original and one complete copy of your response to the attention. of
Vikie Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-
2148; (puc.datarequeststãstate.or.us) and one complete copy to the attention of
counsel for PUC Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem,
OR 97301-4096 (jason.w.jonestãstate.or.us).
Judy Johnson
Program. Manager
Rates and Tariffs
judy. johnsonCCstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Ming Peng
Ming .pengtãstate.or .us
[phone]
cc: Service List
StafCPR_011 Attachment C Page 34 of 100
July 29, 2009
DAVID J MEYER
AVISTA CORPORATION
POBOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
POBOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 149
Response Due By
August 12, 2009
Please provide a response to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
149. Reference is made to Note 6. Accounts Receivable Sale for the 2008 10K
Report. The ongoing factoring of these current assets to Avista Receivables
Corporation, mentioned therein, requires an affliated interest application. There
is particular interest in the percentage of face value realized and comparison to
some market percentage realization index, if no RFP was utilized in this
arrangement.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestscæstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonescæstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. iohnsoncæstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Marion Anderson/Michael Dougherty
cc: Service List
StafCPR_011 Attachment C Page 35 of 100
July 30, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 150-155
Response Due By
August 13,2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
BATTERY REPLACEMENT PROJECT
150. Please provide supporting documentation regarding the economic life of
Gas ERT batteries, mentioned in Avista/100 Morris/Page 5 and Avistal400
DeFelice/Page 11 (ER3265).
CAPITAL PROJECTS 2010
151 . Provide more information on account ER 1 OOO-Gas Revenue Projects-
2010:$5,555,000, mentioned in Avistal400 DeFelice/Page 10.
COSTS AND EXPENSES
152. Please provide supporting data and work papers to arrive at the table in
Avista/500 AndrewslWork papers/ Page F24.
153. Provide detailed information in electronic format on Account 908
Weatherization Rebate Account.
154. Provide Expense Adjustment Summary 12/31/2010 for FERC Accounts
804-812 in the same format used in Avista/500 AndrewslWork papers/Page
FI1-7.
PRICE ELASTICITY OF DEMAND
155. Please provide estimates of price elasticity of demand for each class of
customers and for each rate schedule. Indicate the timeframe over which the
demand effects of any price change are fully realized.
StafCPR_011 Attachment C Page 36 of 100
July 30,2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datareguestscmstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonescmstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsoncmstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Irina Philips
cc: Service List
StafCPR_011 Attachment C Page 37 of 100
July 30, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 156
Response Due By
August 13, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
156. Regarding Avista/302 Avera/Page 6, please provide Dr. Avera's article: "Some
Thoughts on the Rate of Return to Public Utility Companies," with Bruce H.
Fairchild in Proceedings of the NARUC Biennial Regulatory Information
Conference (1978).
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE,
Ste 215, Salem, OR 97301-2551; (puc.datarequestscæstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonescæstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsoncæstate .or. us
[phone]
Fax: [phone]
Staff Initiator: Jorge Ordonez, jorge.ordonez~state.or.us, 503-378-4629
cc: Service List
StafCPR_011 Attachment C Page 38 of 100
July 31,2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-:3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DRs 157 and 158
Response Due By
August 14, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time. -
157. In Knox Exhibit 601, please explain and provide rationale for the use of
existing rather than incremental costs for gas commodity (excluding
transportation) cost.
158. Please explain how this commodity cost flows through the long-run
incremental cost study into revenue requirements.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestscæstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonescæstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsoncæstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Ken Zimmerman, ken.zimmermanaRstate.or.us
StafCPR_011 Attachment C Page 39 of 100
July 31,2009
Page 2
cc: Service List
StafCPR_011 Attachment C Page 40 of 100
July 31,2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 159-176
Response Due By
August 14, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
CAPITAL STRUCTURE
159. Regarding Avista/201 Thies/Page 2, please define what "Total Debt" includes in
the context of the capital structure "Forecasted Cost of capital as 04 '09 - 04 '10
Avg" and "Embedded Cost of Capital as of December 31,2008."
160. Regarding Avista/201 Thies/Page 2, please explain the Company's use of "Total
Debt" instead of "Long-term debt" in the capital structure, the latter of which is the
practice in Oregon rate case proceedings.
161. Regarding Avista/201 Thies/Page 2, please explain usage of the term "Total Debt"
instead of the terms "Long-term debt" and "Long-term pebt to affliated trusts" used
in previous Avista general rate case proceedings; i.e., UG-153 and UG-181.
162. Regarding Avista/201 Thies/Page 2, assumption 4, please explain what is included
in "Other comprehensive Income and capital stock expense of $23.4."
163. Regarding Avista/201 Thies/Page 2, assumption 5, please explain what is included
in the "Forecasted issuance of $31 milion of equity during 2010 using different
company programs."
164. Regarding Avista/201 Thies/Page 2, actual "Embedded Cost of Capital as of
December 31,2008", please explain which line items of Avista's 2008 10-K
Consolidated Balance Sheet (page 64) were included in the calculation of the total
debt of $1,005,800,000.
165. Regarding Avista/201 Thies/Page 2, actual "Embedded Cost of Capital as of
December 31 , 2008," please identify which line items of Avista's 2008 10-K
Consolidated Balance Sheet (page 64) were included in the calculation of the
common equity of $1,016,663,291.
StafCPR_011 Attachment C Page 41 of 100
July 31,2009
Page 2
166. Regarding Avista/201 Thies/Page 2, please provide, in electronic format, with all
formulae and cell references intact, the outputs of forecast DEC 11 model,
allowing Staff to track the equity and debt (Total Debt) used to calculate the
"Forecasted Cost of capital as 04 '09 -04 '10 Avg."
COST OF DEBT
167. Regarding Avista's response to DR-39, Staff_DR_039 Attachment B, page 2, line
21, please explain the rationale used by the Company to forecast the coupon of
7.25% for the "FMBs Series 7.25%." Please include the calculations in electronic
format with all formulae and ceil references intact.
168. Regarding Avista's response to DR-39, Staff_DR_039 Attachment B line 29, page
2, please describe the characteristics of "Trust Preferred Security Avista Capital
Ii." Additionally, for this security, please provide the following:
a. Trust indenture;
b. Final Prospectus;
c. Final Prospectus supplement;
d. The customary Report of Securities Issued and Disposition of Net
Proceeds filed with the Commission, showing that the issuance was cost-
effective and consistent with competitive market prices.
169. Regarding Avista's response to DR-39, Staff_DR_039 Attachment B, page 2, lines
29 and 36, please explain the rationale used by the Company in calculating the
coupons of 2.440% and 0.730% respectively for variable rates. Please include the
calculations in electronic format with all formulae and ceil references intact.
170. Regarding Avista's response to DR-39, Staff_DR_039 Attachment C, page 2, line
17, please explain the rationale to forecast the coupon of 7.75% for the "FMBs
Series 7.75%." Please include the calculations in electronic format with all
formulae and ceil references intact.
171. Regarding Avista's response to DR-39, Staff_DR_039 Attachment C, page 2, lines
28 and 35, please explain the rationale used by the Company to calculate the
coupons of 2.730% and 1.140%, respectively. Please include the calculations in
electronic format with all formulae and cell references intact.
172. Regarding Avista's response to DR-41, Staff_DR_041 Attachment A, please
explain why the security "5% Colstrip PCBs" (Line 35, page 2, of response to DR-
36, Staff_DR_039 Attachment B) was not included in the Long-term debt principal
and interest projection.
173. If the Company believes that the security "5% Colstrip PCBs" (Line 35, page 2 of
response to DR-36, Staff_DR_039 Attachment B) should not be included in
StafCPR_011 Attachment C Page 42 of 100
July 31, 2009
Page 3
response to DR-41 please provide the projection of principal and interest for each
long-term debt outstanding as of December 31, 2010. Otherwise, please provide
the projection of principal and interest for each long-term debt outstanding as of
December 31, 2009 and December 31, 2010 including the "5% Colstrip PCB."
174. Regarding the Company's response to DR-042, StafCDR_042 Attachment, pages
1 and 2, lines 10, 13 and 14, please explain the nature of "Swap Cost" and
"Insurance LC." If the company has any swap contract in any security please
explain the general conditions of such contract( s).
175. Regarding the Company's response to DR-45 "d," please provide a comparison
between the rates at which the $17 milion PCRBs have been remarketed since
January 2009 to present with the SIFMA Swap index.
COST OF EQUITY
176. Regarding the Company's response to DR-53, please provide the specific section
of the Value Line Investment Survey showing the Market Capitalization in $Milion
figures (e.g., AGL Resources $ 1,930.75 millon) instead of $ Billon figures as
shown in the left side "capital structure" of Value Line Investment Survey Company
sheets (e.g., AGL Resources $ 2.0 billon of page 508 in Dr. Avera's work papers).
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE,
Ste 215, Salem, OR 97301-2551; (puc.datarequestsßRstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonesßRstate.or.us).
Judy Johnson
J Program Manager
Rates and Tariffs
judy. johnsonßRstate. or. us
[phone]
Fax: [phone]
Staff Initiator: Jorge Ordonez, jorge.ordonez~state.or.us, 503-378-4629
cc: Service List
StafLPR_011 Attachment C Page 43 of 100
August 3, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 177
Response Due By
August 17, 2009
Please provide a response to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
177. Please provide explanations for the projected percentage increases/decreases
shown in the "change 2007-2009" column on the attached worksheet.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestsCãstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonesCãstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsonCãstate.or. us
[phone]
Fax: [phone]
Attachment
Staff Initiator: Marion Anderson/Michael Dougherty
cc: Service List
StafCPR_011 Attachment C Page 44 of 100
August 5, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 178
Response Due By
August 19, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
Please provide transaction summaries for non-labor costs recorded in FERC accounts
908, 909, 910, 911, 912, 913, and 916 (Oregon Situs and Oregon allocated) for January
through December 2008. Please place in Excel and include:
a. Amount charged;
b. Description of cost; and,
c. Name of vendor (if applicable).
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestsßùstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonesßùstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsonßùstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Lisa Gorsuch
~ cc: Service List
StafCPR_011 Attachment C Page 45 of 100
August 7, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 179-191
Response Due By
August 21, 2009
179. Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear
or if you need more time.
180. Please provide the final costs for Phase i of the East Medford Reinforcement
Project.
Oregon Major Capital Additions:
181. Please explain the following improvements listed as "Common Propert" for 2009
by specifying what improvements these represent, whether they are new
improvements, upgrades orenhancements to existing assets:
5002 Security II'ltiative _________508,000 504:!.900
3,360,007 3,205,000 565,2477001Structures & 1m rov
~06 Tools ~ab & Shop Equipment
I _?905___ StQres E.9lJip
_~~~!-9ß7 508,PQQ__!-54,383
598,164 1 ,~?~!QQQ--_l!,632
I
I 7000____ TransPQ..a!ion E~p e,6~S.!_QOJL~e!32,00(L..344,624
4,159,000 3,327,000 644,5457101COF HVAC Improvmt
StafCPR_011 Attachment C Page 46 of 100
Avista UG 186
August 7, 2009
Page 2
---~----------
Offce Furniture 450,003 350,000 68,880
Information Technology Refresh Blanket-
,____,§9~___S~~~!~_______________._____4~~1Q,QQ~__~,~~7 ,000 __e07!360
Information Technology Expansion
i 5006 Blanket-Softare 981,000 1,105,000 179,605
AFM Product Development Program-5007 Softare 1,115,100 1,256,000 204,152¡----_._--------_._--_._----_._~_._---~_._._------_._--_...__.._..._-------
Nucleus Product Development Program-
5008 ____So~are _____________________________~~§Jl~~___ 6~e,000___JQ1!Z~L_
Web Product Development Program-
5009 Softare 627,192 706,000 114,788
5010 Enterprise Business Continuity-Softare 472,704 532,000 86,505
i 5106 Next Generation Radio Svstem 1,500,000 1,500,000 258,300
Technology Projects Minor Blanket-
i 5111 Softare 345,795 3,005,000 288,503
5011 Enterprise Data Architecture-Softare 216,000 243,000 39,520
7200 ApDren Craft Train-Softare 70,209 74,000 12,416
5,140,357
182. For each project listed in the table above, please explain what each of the
projects consists of in the form of a narrative description explaining the project;
the basis for the 2009 budget and the basis of the 2010 budget. Please provide
all actual costs associated with similar projects for the previous years from 2003
through 2008.
2
StafCPR_011 Attachment C Page 47 of 100
Avista UG 186
August 7, 2009
Page 3
183. For each of the following blanket costs, please provide a narrative description of
what the projects represent as well as actual costs on a system basis and
separately the amount that was allocated to Oregon from 2003 through 2008 for
each category of projects related to the blanket costs described below:
Industrial Gas Customer Minor Blanket
184. Please identify what projects are associated with Phase II of the East Medford
Reinforcement Project, the current status of the project and the forecast of the
total costs for future phases shown in the capital additions for 2009 and 2010.
185. Please provide the final costs for the 2008 Phase i portion of the East Medford
Reinforcement project that went into base rates in November of 2009.
186. Please provide the final costs for the 2008 Jackson Prairie Project for both the
entire project and for the Oregon portion of the project.
187. Please identify what project is related to the Jackson Prairie Storage for 2010
with an Oregon allocated portion of 149,000 on the shown on the last line of work
paper F73?
188. Please identify what projects are scheduled to take place on the Grants Pass 8-in
HP Reinforce Project for $2.0 millon scheduled to be in-service 11/2010.
189. Please identify what projects are associated with the Roseburg Reinforcement
projects totaling nearly $2.0 million shown on the bottom of work paper F73
190. Please explain Avista's planning strategy related to how it can justify all the major
reinforcement projects for the majority of its Oregon service territory over such a
short period of time (I.e., approximately a three year span).
3
StafCPR_011 Attachment C Page 48 of 100
Avista UG 186
August 7, 2009
Page 4
Wages and Salaries:
191 . Please prepare a workpaper demonstrating 2007 Labor in the same format as
previously provided and labeled "Commission Basis Labor 2005 and
"Commission Basis Labor 2008."
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datareguestscæstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonescæstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsoncæstate. or. us
[phone]
Fax: [phone]
Staff Initiator: Carla Owings
cc: Ming Peng
Service List
4
StafCPR_011 Attachment C Page 49 of 100
August 7, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 192 -193
Response Due By
August 21, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
192. For each category of employees, please provide a detailed explanation for the
increases in FTE Staff levels from 2006 and 2007, particularly given that the number of
customers increased only 1.80 percent during the same period.
Percent
2006 2007 change
Officers 12.0 14.0 16.67%
Exempt 455.5 493.5 8.34%
Non-
exempt 274.4 311.4 13.48%
Union 654.2 747.9 14.32%
Total FTE 1,396.1 1,566.8 12.23%
I #of 92,355 94,015 1.80% Icustomers
193. Please explain why the number of Oficers has increased 50 percent from 10 in
2004 to 15 in 2009.
StafCPR_011 Attachment C Page 50 of 100
DR 192-193
August 7, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequests(âstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jones(âstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson(âstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Lisa Gorsuch
cc: Service List
StafCPR_011 Attachment C Page 51 of 100
August 11, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
194 -196
Response Due By
August 25, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
194. As discussed today in a conference call between Staff and Avista employees,
please provide the current source documents that describe in detail the incentive
plans listed below that includes, but is not limited to, the following information: an
explanation of which employees are eligible to participate, a description of the
goal(s) that must be met for an employee to qualify for a payout.
a. All employee incentive plan(s);
b. Officer incentive plan(s); and,
c. Any other incentive plan(s).
195. For any incentive plan where the expense is subject to the allocation(s) listed as
follows, please specify the percentage allocated to each category, and the
justification for the allocations.
a. Allocated between Avista's electric and gas operations;
b. Allocated between non-utility and utility expense; and,
c. Allocated between states.
196. Please provide details regarding how many times a year bonuses are paid under
each incentive plan and when they are distributed.
StafCPR_011 Attachment C Page 52 of 100
August 11, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestsßistate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonesßistate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson((state. or. us
[phone]
Fax: [phone]
Staff Initiator: Lisa Gorsuch
Carla Owings
cc: Service List
StafCPR_011 Attachment C Page 53 of 100
August 11, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 197-200
Response Due By
August 25,2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
197. Regarding Avista/100/Morris/Page 8/lines 13-22 and Avistal100/Morris/Page
9/lines 1-9: Have any Avista Utilities' employees now, or at any other time, been
temporarily assigned to Advantage 10 on a part-time or full-time basis? Have any
Avista Utilities' employees now, or at any other time, allocated their time between Avista
Utilities and Advantage 10? If the answer to any part of these questions is yes, please
provide the following information for calendar years 2006 through 2008 (actual) and
2009 and 2010 (forecast):
a. The number of employees and the work areas or divisions of Avista Utilities' in which
they did, do, or wil work.
b. The dates in which they did, do, or wil work on a, full-time or part-time allocated
basis.
c. A breakout for each year that demonstrates that the amount of wages, overtime,
overheads, and incentives were booked into the appropriate FERC categories.
To the extent that Avista has supplied this information in previous data responses or
work papers associated with this docket, please indicate where, and provide a
reconciliation.
198. Regarding Avista/100/Morris/Page 12/Lines 24-30:
a. For each year 2006-2008 (actual) and 2009 -2010 (projected):
Please provide a breakout that shows the total dollars associated with bill printing,
inserting, and mailing services and any storage. Please identify which services or
percentages of services (and associated expense), if any, were provided by a3rd part.
Please include the price per unit and the approximate annual cost per customer.
StafCPR_011 Attachment C Page 54 of 100
UG 186 DR 197-200
August 11, 2009
Page 2
b. Please identify the third party provider with whom Avista has contracted to provide
billng, insert, mailng, and storage services. When (did) the contract go into effect?
c. Please provide a breakout that shows the savings between Avista-provided and third
party-provided services for each of the categories.
d. Please provide the amount and where the reduction in costs associated with Avista's
change to its billng operations are included in this case.
199. Regarding Avista/100/Morris/Page 13/lines 4-8: Please provide a detailed
explanation of where cuts to operating expenses have been made and the decision-
making process associated with "limiting growth in these costs."
200. Regarding Avista/100/Morris/Page 16/lines 1-7: For years 2006 - 2008 (actual)
and 2009 - 2010 (projected);
Please explain how the number of employees and associated expense (wage & salary,
overtime, loadings, and incentives) located in all of Avista's call centers are allocated
between Oregon, Washington, and Idaho. In the explanation, please include the total
number of employees (and associated expense) in each call center, and the number of
customers in each state.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datareguestsCãstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonesCâstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsonCâstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Lisa Gorsuch
Carla Owings
cc: Service List
StafCPR_011 Attachment C Page 55 of 100
August 11 , 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 201-211
Response Due By
August 25, 2009
Please provide responses to the following request for information. Contact the undersigned
before the response due date noted above if the request is unclear or if you need more
time.
201. For FERC account 926, please provide workpapers, supporting documentation and
an explanation demonstrating how the 2010 expense of $71,982 was developed.
Please explain the reason(s) why this accunt is forecasted to increase significantly
over the 2006,2007,2008, and 2009 (through June) historical costs. Please explain
the actual 2009 costs are trending compared to the 2009 budgeted amount of
$69,214 and explain the reasons for any significant differences.
202. Please provide an explanation for the "Additional OR Staff increase to A&G of
$145,000, shown on workpaper F32, and provide all documents, workpapers, and
other analyses used to calculate this increase.
203. Regarding the projected 2010 pension expense of $20,818,200 (total company),
shown on workpaper F3a, please provide all documents, workpapers, and
explanations of assumptions used in calculating this expense.
204. Regarding the projected 2010 medical expense of $20,800,000 (total company),
shown on workpaper F3a, please provide all documents, workpapers, and
explanations of assumptions used in calculating this expense.
205. Please provide a workpaper which wil reconcile the projected 2010 medical expense
of $20,800,000 shown on workpaper F3a to the 2010 medical expense of
$24,531,638 shown in response to Staff DR No. 108.
206. As a follow up to DR NO.1 08, please provide documentation supporting the
statement "Based on an increase in large claims and an older population within the
medical plan, our broker is estimating a 12.7% increase in Medical. "
StafCPR_011 Attachment C Page 56 of 100
UG 186
August 11, 2009
Page 2
207. Regarding the current 90/10 employer/employee sharing for union employees, is this
sharing something that was negotiated with the union(s)? If so, please provide
copies of the relevant pages from the most recent union contract(s). When wil the
contracts be renegotiated?
208. Regarding the current 90/10 employer/employee sharing for nonunion employees,
please explain how this sharing structure compares to industry standards and other
utilties?
209. As a follow up to DR NO.1 08, please provide documentation supporting the
statement "Our vendor has indicated that rates will increase 20% for the L TO plan... "
210. As a follow up to DR No. 108, please provide a breakdown of "other- tuition aid &
service awards" into individual categories for each year. Additionally, please explain
and provide supporting documentation for the forecasted increase to each individual
category.
211. As a follow up to DR No. 115, please provide documentation supporting the
statements "AEGIS announced recently that there wil not be continuity credits for
general liability insurance policies on our next renewal and that continuity credits for
the next renewal of 0&0 Liability insurance wil be significantly smaller." and "2009:
ElM notified A vista that no surplus distribution wil be made."
Please provide an original and one complete copy of your response to the attention of Vikie
Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-2148;
(puc.datarequests(âstate.or.us) and one complete copy to the attention of counsel for PUC
Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem, OR 97301-4096
(jason. w.jones(âstate.or. us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson(âstate .or. us
[phone]
Fax: [phone]
Staff Initiator: Dustin Ball
cc: Service List
StafLPR_011 Attachment C Page 57 of 100
August 12, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DRs 212-213
Response Due By
August 26, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
212. In Exhibit 501 Andrews please explain and provide all workpapers for the
entries in all columns of line 6, "City Gate Purchases." Provide the
workpapers in electronic format fully functional, linked, and unlocked.
213. Verify that the amount in Exhibit 501 Andrews line 6, column b is
$160,985,000 and that this amount is for the Oregon jurisdiction only.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequests~state.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonestãstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsontãstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Ken Zimmerman, ken.zimmermantãstate.or.us
Staff_PR_011 Attachment C Page 58 of 100
August 12,2009
Page 2
cc: Service List
StafCPR_011 Attachment C Page 59 of 100
August 18, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 214 - 220
Response Due By
September 1, 2009
Please provide responses to the following request for information. Contact the undersigned
before the response due date noted above if the request is unclear or if you need more time.
214. As a follow up to DR No 101, please provide an explanation on the services provided
and/or purpose for each of the following vendors for which expenses were booked to
various A&G accounts in 2008:
a. Cutaway Media
b. Korn Ferr International
c. Pat Newman
d. Edith Poor
e. Thompson Property Tax Services
f. Pear Press LLC
g. Eddison Electrical Institute
h. Western Electricity
215. Please identify all 2008 legal fees (amount, date, and vendor/payee) associated each of
the following commitments/contingincies as reported in Avista's 2008 10-K:
a. California Refund Proceedings
b. Pacific Northwest Refund Proceedings
c. Federal Energy Regulatory Commission Inquiry
d. State of Montana Proceedings
e. Coalstrip Generation Project Complaints
f. Coalstrip Rotalty Claim
g. Lake Coeur d'Alene
h. Spokane River Relicensing
i. Clark Fork Settlement Agreement
j. Air Quality
k. Residential Exchange Program
216. Please explain the "Payroll Loading - A&G" debit and credit entries in FERC account
920. Also please address the majority of entries offsetting with the exception of two, in
the amounts (OR) of $63,050.62 and -$4,026.36.
StafCPR_011 Attachment C Page 60 of 100
UG 186
August 18, 2009
Page 2
217. For the FAS 87 and FAS 106 discount rate of 6.25 percent, please provide a copy of the
actuarial report which supports this assumed discount rate. Also please identif the
specific highly rated corporate bond portolios on which this discount rate is based. If
there is no actuarial report, please provide all other reports and internal reports, memo's,
and documents which support the assumed discount rate.
218. For FAS 87, what is the assumed rate of compensation increase for 2007,2008, and
assumed for 2009, and 2010? Also, what is the estimated effect on 2010 net periodic
postretirement cost (income) if the rate of compensation increase is changed 10 basis
points in both directions?
219. Please provide the actuarial report which supports the forecasted 2010 rate of
compensation increase. If there is no actuarial report, please provide all other reports
and internal reports, memo's, and documents which support the rate of compensation
increase.
220. For the escalation of FERC accounts 921, 924, 930, and 935 please provide a complete
explanation and any supporting documentation which wil clearly show why these
accounts are expected to increase at historical rates as opposed to CPI. This should
specifically identify the individual cost categories/items, included in each FERC account,
which are the main contributors for the company relying on historical data as opposed to
CPI.
Please provide an original and one complete copy of your response to the attention of Vikie
Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-2148;
(puc.datareguestsßìstate.or.us) and one complete copy to the attention of counsel for PUC
Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem, OR 97301-4096
(jason. w. jonesßìstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy.johnsonßìstate.or.us
[phone]
Fax: [phone]
Staff Initiator: Dustin Ball
cc: Service List
StafCPR_ 011 Attachment C Page 61 of 100
August 18, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 221 - 224
Response Due By
September 1, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
Rate base Additions:
221. In reference to Avista's response to Data Request No. 93, in the 2009 and 2010
forecast of rate base additions, are these additions net of estimated retirements?
222. The rate base listed under 101100, Capital Lease, Common, Allocated to All in
FERC account 397 has a balance as of December of 2008 of approximately
$515,850 (see Line 72 of DR# 93, Attachment B,excel work paper). Please
provide the following information:
a. Is this communication equipment? Please provide the name of the
Lessor, the terms of the lease (I.e., escalation factors, purchase options,
termination date), the origination date of the lease and the monthly (and
annual) obligation.
b. Does Avista include the monthly (or annual) expense associated with this
lease in its operating expenses? If so, please provide documentation
showing where this lease is booked and how it has been handled for the
rate case filing.
c. Does Avista amortize or claim depreciation related to this equipment? If
so, please provide the amount and where it appears in the Amortization or
Depreciation Reserves.
StafCPR_011 Attachment C Page 62 of 100
Avista UG 186
August 18, 2009
Page 2
Exhibit 703 Hirschkorn:
223. In reference to Avista's response to Staff's data request no. 133, Attachment A,
please explain why there is a difference between the number of customers
reported on Schedule 420 for FERC purposes as opposed to what is reported to
PUC staff. In addition, specifically please address why there are 15 customers
classified as Large Industrial on Schedule 420 for 2008 (14, in 2007).
224. In reference to Avista's response to Staffs data request no. 133, please explain
what "interdepartmental sales" are. Please explain why "interdepartmental sales"
would be found on Schedule 420.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequests((state.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jones((state.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson((state. or. us
[phone]
Fax: [phone]
Staff Initiator: Carla Owings
Ming Peng
Deborah Garcia
cc: Service List
StafCPR_011 Attachment C Page 63 of 100
August 19, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 225
Response Due By
September 2, 2009
Please provide a response to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
225. Reference the response to DR 125, what specific services are received from
GTI?
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestscastate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonescastate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsoncastate.or. us
[phone]
Fax: [phone]
Attachment
Staff Initiator: Marion Anderson/Michael Dougherty
cc: Service List
StafCPR_011 Attachment C Page 64 of 100
August 24, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request Nos. Response Due By
DR 226-231 September 8, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
COST OF DEBT
226. Regarding Avista's response to Staff Data Request 39, Staff_DR_039
Attachment B, footnote on page 2, please explain the nature of the "Costs
associated with long-term debt, i.e. series costs, repurchase cost and other."
Please provide, in electronic format with cell references and formulae intact, both
amortized and unamortized costs and both the actual and projected amortization
schedules.
227. Regarding Avista's response to Staff Data Request 39, Staff_DR_039
Attachment B, page 2, line 21, please provide the date Avista fied a Financial
Application with the Public Utility Commission of Oregon regarding issuance of
$150,000,000 of new First Mortgage Bonds (FMBs). If such an application has
not been filed, please provide a tentative schedule involving the issuance of this
security.
228. Regarding Avista's response to Staff Data Request 39, Staff_DR_039
Attachment B, page 2, lines 35, 36and 39, please provide the periods during
which the Company held the securities as part of the remarketing process.
During each period of time the company held the securities (i.e., involving self-
payment of interest), please explain the accounting treatment of the interest
payments. Please also explain if the Company has requested cost recovery of
such payments in any part of the current proceeding.
229. For all the securities with variable rate in Avista's response to Staff Data Request
39, Staff_DR_039 Attachment B, please compare, in a monthly basis, the rate on
StafCPR_011 Attachment C Page 65 of 100
August 24, 2009
Page 2
how much the securities were remarketed (monthly payment of interest) and the
monthly average London Interbank Offered Rate (L1BOR).
230. Regarding Avista's response to Staff Data Request 40, please provide the
following information for "5% Colstrip PCBs" (Line 35, page 2, of response to
DR_039, Attachment B):
a) CUSIP number;
b) Issuer;
c) Trustee;
d) Underwriter(s) and amounts for each Underwriter;
e) Denomination;
f) Trust indenture fiing date;
g) Final Prospectus filing date;
h) Final Prospectus supplement filng date;
i) Coupon and Interest rate description (If variable please provide the underlying
benchmark and margin);
j) Dates of payment of coupons;
k) Assets upon which the bonds are secured;
I) Description of any sinking fund provision;
m) Description of any call provision;
n) Description of any put provision;
0) Description of any redemption provision;
p) Description of any remarketing provision;
q) Description of early/regular refunding provision;
r) The Order Number under which the debt was issued
231. As follow-up to Staff Data Request 174, for each swap associated with each
particular financing on lines 10, 13 and 14 of Avista's response to Staff Data
Request 42, please provide, in electronic format with all cell references and
formulae intact:
a) All analysis supporting the decision to engage in the swap transaction (Ex-
ante);
b) An updated cost-benefit analysis demonstrating the cost effectiveness of
each transaction (Ex-post); and
c) If and how the Company is currently recovering these "swap costs" in rates.
StafCPR_011 Attachment C Page 66 of 100
August 24, 2009
Page 3
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE,
Ste 215, Salem, OR 97301-2551; (puc.datarequestsßìstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonesßìstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsonßìstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Jorge Ordonez, jorge.ordonez(gstate.or.us, 503-378-4629
cc: Service List
StafCPR_011 Attachment C Page 67 of 100
August 25, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 232 -237
Response Due By
September 9,2009
Please provide responses to the following request for information. Contact the undersigned
before the response due date noted above if the request is unclear or if you need more
time.
232. Please provide an explanation along with supporting workpapers, showing how the
forecasted 2010 liabilty insurance expense of $1,716,253 was calculated. Does this
amount include all liabilty insurance policies booked to FERC account 925? If not,
please provide the information for all other liabilty insurance policies and explain
why the information for other liabilty policies was not provided in response to
DR No. 111.
233. Please identify the entries in the transaction summary, provided in response to DR
NO.1 01, which wil tie to the 2008 liabilty insurance premiums of $1 ,315,610 (total
company) as reported in response to DR No. 111. Please explain and reconcile any
differences.
234. In what FERC account are D&O insurance premiums booked? What is the amount
of D&O insurance premiums (total Company and Oregon) that were booked during
2008? What is the amount of D&O insurance (total Company and Oregon) included
in UG 186?
235. As a follow up to DR No. 101(b), please provide an explanation on the following
expenses transaction descriptions which were booked to FERC account 925 during
2008. Please also identify all individual insurance policies/premiums or other
expenses which are being recorded with these postings.
a. "Annual Premium - Umbrella" totaling $280,994.37 (OR).
b. "WAID Gas Provision for Majot' totaling $250,571.55 (OR).
236. Please provide documentation supporting the 2008 medical expense of
$17,324,549, shown on workpaper F38, in the same format as what was provided in
StafCPR_011 Attachment C Page 68 of 100
UG 186
August 25, 2009
Page 2
response to DR No. 204. Also, please tie the 2008 medical expense of $17,324,549,
on workpaper F3s, to the 2008 medical expense of $20,918,463, provided in
response to DR No. 108.
237. Regarding Attachment B provided in response to DR No. 204, please provide the
following:
a. An explanation on the "Funding Calculation". What does this represent, and
how does it affect the calculating the medical expense?
b. Documentation supporting the annual escalations of 11.25 percent for
medical and 12.5 percent for Rx.
c. An explanation on the required revenue calculation of $24,397,098. What
does this represent and how does it affect the medical expense?
d. Explanations on the "Medical" and "Rx" columns. What do these represent
and are both factored into UG 186?
e. Why is a deductible of $250,000 added to the "Medical" column in arriving at
the $16,283,095 amount?
Please provide an original and one complete copy of your response to the attention of Vikie
Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-2148;
(puc.datareguests((state.or.us) and one complete copy to the attention of counsel for PUC
Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem, OR 97301-4096
(jason. w.jones((state.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
i udy. johnsonCâstate .or. us
[phone]
Fax: [phone]
Staff Initiator: Dustin Ball
cc: Service List
StafCPR_011 Attachment C Page 69 of 100
August 26, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request Nos.
DR 238-240
Response Due By
September 10,2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
COST OF DEBT
238. Regarding Avista's response to Staff Data Request 42, Staff_DR_042
Attachment, page 1, securities in lines 10, 13 and 14, please provide an
electronic worksheet, with cell references and formulae intact, detailing all
issuance expenses in column "f'.
239. Regarding Avista's response to Staff Data Request 39, Staff_DR_039
Attachment B, security in line 29, please provide in electronic format, with cell
references and formulae intact:
a. The detail of all issuance expenses (column "i") and of all redemption
expenses (column "j".
b. A cost-benefit analysis demonstrating the cost effectiveness of the
redemption of this security. Additionally, please describe the market
conditions prevailing at the date of redemption.
240. As follow up on Data Request 174, please provide a summary explanation of how
the swap contracts on the following securities work:
Staff_PR_011 Attachment C Page 70 of 100
August 26, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, POBox 2148, Salem, OR 97308-2148, or 550 Capitol St NE,
Ste 215, Salem, OR 97301-2551; (puc.datarequests(âstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jones(âstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy.johnson(âstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Jorge Ordonez, jorge.ordonez~state.or.us, 503-378-4629
cc: Service List
StafCPR_011 Attachment C Page 71 of 100
August 27, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR241-242
Response Due By
September 11,2009
Please provide responses to the following request for information. Contact the undersigned
before the response due date noted above if the request is unclear or if you need more
time.
241. As a follow up to DR No. 210, please provide a breakdown of the 2006, 2007 and
2008 tuition aid and service awards expenses in a semi-annual format (Jan-Jun and
Jul-Dec).
242. Please provide a copy of the 2009 BENVAL Study referred to in response to
DR No. 208.
Please provide an original and one complete copy of your response to the attention of Vikie
Bailey-Goggins, PO Box 2148 or 550 Capitol St NE Ste 215, Salem, OR 97308-2148;
(puc.datarequestscrstate.or.us) and one complete copy to the attention of counsel for PUC
Staff, Jason Jones, Department of Justice, 1162 Court St NE, Salem, OR 97301-4096
(jason. w.jonescrstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
i udy. johnsoncrstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Dustin Ball
cc: Service List
StafCPR_011 Attachment C Page 72 of 100
August 28,2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 243-244
Response Due By
September 14, 2009
Please provide responses to the following requests for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
243. Per discussions between Company personnel and Staff, please provide
written confirmation/clarification of Staff's understanding of the long-
standing utility accounts receivable arrangement with Avista Receivables
Corporation:
a. There is no discounting of accounts receivable or affilate
compensation involved in this relationship, only pass throughs of the
assets and cash collections.
b. This arrangement has no revenue requirement impact.
244. How does Avista Receivables Corporation maintain staff and economic
viability if there is no cost reimbursement from the utility?
StafCPR_011 Attachment C Page 73 of 100
August 28, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequests((state.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jones((state.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnson((state.or. us
[phone]
Fax: [phone]
Staff Initiator: Marion Anderson/Michael Doughert
cc: Service List
StafCPR_011 Attachment C Page 74 of 100
August 31, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 245 - 246
Response Due By
September 15, 2009
Please provide a response to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
245. Please provide total normalized sales/throughput by month for each of the
rate schedules listed in Avistal700 (Hirschkorn/page5) for calendar years
2006,2007, and 2008 for the state of Oregon.
246. Please provide a monthly breakdown of the therms shown in Avistal703,
Hirschkorn/page 3 of 4, column (f), for each of the corresponding rate
schedules.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestsßRstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jones((state.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
i udy. johnson((state.or. us
[phone]
Fax: [phone]
Staff Initiator: Robert Clark
cc: Service List
StafCPR_011 Attachment C Page 75 of 100
September 2, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 247
Response Due By
September 17, 2009
Please provide responses to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
Rate base Additions:
247. In reference to Avista's supplemental testimony published September 1,2009,
Witness DeFelice states that Avista is removing $4.1 milion of costs attributable
to the East Medford Reinforcement project for the 2010 test period. In an Exhibit
provided in Avista's original filing entitled "2010 Capital Additions" Avista includes
approximately $4.7 milion in costs attributable to the East Medford
Reinforcement project. Is it Avista's intention to remove only a portion of costs
($4.1 milion) attributable to this project due to construction delays? If so, please
explain whether the remaining costs of $600,000 wil be used and useful during
the test period. If so, please clarify how Avista can support the claim that a
portion of a phase of construction wil be used and useful during the test period.
StafCPR_011 Attachment C Page 76 of 100
Avista UG 186
September 2, 2009
Page 2
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequeststWstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonestWstate.or.us).
Judy Johnson
Program Manager
Rates and Tariffs
judy .johnsontâstate.or. us
[phone]
Fax: [phone]
Staff Initiator: Carla Owings
Ming Peng
cc: Service List
StafCPR_011 Attachment C Page 77 of 100
September 18, 2009
DAVID J MEYER
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
KELLY NORWOOD
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
RE:Docket No.
UG 186
Staff Request No.
DR 248
Response Due By
October 2, 2009
Please provide a response to the following request for information. Contact the
undersigned before the response due date noted above if the request is unclear or if
you need more time.
248. Please provide an estimate of the incremental administrative cost to the
Company, if any, associated with administering a seasonally differentiated
commodity rate with one rate for the months of November through March and
a second rate for the remaining months of April through October. Please
provide estimates of such incremental administrative costs, on an annualized
basis, for each of the following cases:
a) If the seasonally differentiated commodity rate were to replace the
existing (seasonally undifferentiated) commodity rate in each of the
following schedules: 410, 420,424, and 440; Le., a "one-time" switch;
and
b) If the seasonally differentiated commodity rate were added as a
customer-selected option to the existing commodity rate in each of
schedules 410, 420, 424 and 440; assuming customers' selections
change no more frequently than annually.
Please provide an original and one complete copy of your response to the attention of
Vikie Bailey-Goggins, PO Box 2148, Salem, OR 97308-2148, or 550 Capitol St NE
Ste 215, Salem, OR 97301-2551; (puc.datarequestsßYstate.or.us) and one complete
copy to the attention of counsel for PUC Staff, Jason W. Jones, Department of Justice,
1162 Court St NE, Salem, OR 97301-4096 (jason.w.jonesßYstate.or.us).
Staff_PR_011 Attachment C Page 78 of 100
September 18, 2009
Page 2
Judy Johnson
Program Manager
Rates and Tariffs
judy. johnsonßìstate. or. us
[phone]
Fax: [phone]
Staff Initiator: Robert Clark
cc: Service List
StafCPR_011 Attachment C Page 79 of 100
Citizens' Utiliti Board of Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone] .cub(§oregoncub.org . ww.oregoncub.org
July 16th, 2009
David J. Meyer
A vista Corporatíon
PO Box 3727
Spokane, W A 99220-3727
Kelly Norwood
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
Re: UG 186 Data Request 1
Please send responses to the following data requests to Gordon Feighner at
gordon~oregoncub.org, or, for confdential material, at the address above. Please assume
that these are on-going requests if any additional informatíon becomes available during
the pendency of the cac;e. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronically only, and in the original electronic format.
1. Please provide the responses to Staf data requests: # 1 - 71.
Thank you for your prompt attention to these requests,
Sincerely,
J ~ /". ....- ...._..._-.._- 1.....:__._..._....................-..."
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordonrmoregoncub.org
ce. Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C Page 80 of 100
Citizens' Utilitl ,Board, of Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone] . cub(aoregoncub.org . www.oregoncub.org
July 17th, 2009
David J. Meyer
Avista Corporation
PO Box 3727
Spokane, W A 99220-3727
Kelly Norwood
A vista Corporation
PO Box 3727
Spokane, WA 99220-3727
Re: UG '186 Data Request 2
Please send responses to the following data requests to Gordon Feighner at
gordon(foregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available during
the pendency of the case. Answers are due withn i 0 days of service. If you have any
questions, please call us at (503) 227- i 984.
Please prOl'ide responses electronically only, and in tiie original electronic format.
2. Please provide the responses to Staff data requests: # 72 - 90.
Thank you for your prompt attention to these requests.
Sincerely,~ /'
f"''''--''',-"",- ~-2._,,, __._..__".,~..,--_.-,--_...-.. ,;r
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Stc 308
Portland, OR 97205
[phone]
gordon(ioregoncu q.org
ce. Service List
UG 186 - CUB Data Requests to Avista Corporation
StaftPR_011 Attachment C
1Page 81 of 100
Citizens' Itilitl Board of Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone] . fax [phone] . cub~oregoncub.org . ww.oregoncub.org
July 21 si, 2009
David J. Meyer
A vista Corporation
PO Box 3727
Spokane, WA 99220-3727
Kelly Norwood
A vista Corporation
POBox 3727
Spokane, WA 99220-3727
Re: UG 186 Data Request # 3
Please send responses to the following data requests to Gordon Feighner at
gordoncÐoregoncub.org, or, for confdential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available durng
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone];
Please provide responses electronically only, and in the original electronic format.
3. Please provide the responses to Sta data requests: # 91 - 97.
Thank you for your prompt attention to these requests.
Sincerely,~ /"
t).__...___.......... 1-..~:..-.._._-_._.._--.-..-...f"~' \...
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordon(aoregoncub.org
cc. Service List
UG 186 - CUB Data Requests to Avista ~f)_qr¡e!l5~ Attchment C Page 82 of 100 1
Citizens' Utilitl Board 01 Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone]. cub(goregoncub.org . ww.oregoncub.org
July 23rd, 2009
David J. Meyer
A vista Corporation
POBox 3727
Spokane, WA 99220-3727
Kelly Norwood
A vista Corporation
PO Box 3727
Spokane, WA 99220-3727
Re: UG 186 Data Request # 5
Please send responses to the following data requests to Gordon Feighner at
gordon(ioregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available during
the pendency ofthe case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronically only, and in the original electronic format
5. Please provide the responses to Staff data requests: # 124 - 139.
Thank you for your prompt attention to these requests.
Sincerely,
0/ R ""1-'
/ -_. . -. ',. j- "_:. _... ._.. ... --".
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordon~oregoncub.org
cc. Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
1
Page 83 of 100
Citizens' Utilitl Board 01 Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone]. cub(goregoncub.org . ww.oregoncub.org
July 28th, 2009
David J. Meyer
A vista Corporation
PO Box 3727
Spokane, WA 99220-3727
Kelly Norwood
A vista Corporation
POBox 3727
Spokane, WA 99220-3727
Re: UG 186 Data Request # 7
Please send responses to the following data requests to Gordon Feighner at
gordon(foregoncub.org. or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available during
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone],
Please provide responses electronically only, and in the original electronic format
7. Please provide the responses to Staff data request: # 148.
Than you for your prompt attention to these requests.
Sincerely,
'\/-_. --.K .." 1'...... ....-...\, .. _...... ....
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordon§oregoncub.org
cc, Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
1
Page 84 of 100
Citizens' Utilitl Board 01 Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone] . fax [phone] . cubtæoregoncub.org . ww.oregoncub.org
July 30th, 2009
David J. Meyer
A vista Corporation
POBox 3727
Spokane, WA 99220-3727
Kelly Norwood
A vista Corporation
POBox 3727
Spokane, WA 99220-3727
Re: UG 186 Data Request # 8
Please send responses to the following data requests to Gordon Feighner at
gordon~oregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available during
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronically only, and in the original electronic format.
8. Please provide the responses to Staff data request: # 149.
Thank you for your prompt attention to these requests.
Sincerely,
C\ () .,..1'.
I _.. . -. t, . /- .._:..... .... ... ._...
Gordon Feighner
Utilty Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordonúVoregoncub.org
cc. Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
1
Page 85 of 100
Citizens' Utilitl Board of Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone] . cub~oregoncub.org . ww.oregoncub.org
August 3fd, 2009
David J. Meyer
A vista Corporation
PO Box 3727
Spokane, WA 99220-3727
Kelly Norwood
A vista Corporation
POBox 3727
Spokane, WA 99220-3727
Re: UG 186 Data Request # 9
Please send responses to the following data requests to Gordon Feighner at
gordon~oregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available during
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronically only, and in the original electronic format.
9. Please provide the responses to Staff data requests: # 150 - 176.
Thank you for your prompt attention to these requests.
Sincerely,
C\/-_. --.R .'" ""1... ..' '_".
".;l _...'" ....
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordonúVoregoncub.org
cc, Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
1
Page 86 of 100
Citizens' Utilitv Board of Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]' fax [phone]' cubcæoregoncub.org' ww.oregoncub.org
August 4th, 2009
David 1. Meyer
A vista Corpration
PO Box 3727
Spokae, WA 99220-3727
Kelly Norwood
A vista Corporation
PO Box 3727
Spokane, WA 99220-3727
Re: UG 186 Data Request # 10
Please send responses to the following data requests to Gordon Feighner at
gordoncÐoregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available dunng
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronically only, and in the original electronic format.
10. Please provide the responses to Staff data request: # 177.
Than you for your prompt attention to these requests.
Sincerely,
f ~1--~_"'_~h"_"_',.,~.", -" '-~:.__~._._..~"""''''~---'''''. "
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordoncæoregoncub.org
CC. Service List
UG 186 - CUB Data Requests to Avista cs~Rl_thlj Attchment C Page 87 of 100 1
Citizens' Utilitl Board 01 Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone]. cub(goregoncub.org . ww.oregoncub.org
August 12th, 2009
David J. Meyer
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
Kelly Norwood
A vista Corporation
POBox 3727
Spokane, W A 99220-3727
Re: UG 186 Data Request # 11
Please send responses to the following data requests to Gordon Feighner at
gordon(goregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional inormation becomes available durng
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronicaly only, and in the original electronic format.
11. Please provide the responses to Staf data request: # 178 and 180-211.
Than you for your prompt attention to these requests.
Sincerely,
J ~:f...'.--.~. - ..~-... .....--.---0-_ .. ..... _._"__,--,--'~'-
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordon (g oregoncub.org
cc. Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
1
Page 88 of 100
Citizens' Utilitl Board 01 Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone] . cub(goregoncub.org . ww.oregoncub.org
August 21,2009
David J. Meyer
A vista Corporation
POBox 3727
Spokane, W A 99220-3727
Kelly Norwood
A vista Corporation
POBox 3727
Spokane, W A 99220-3727
Re: UG 186 Data Request # 12
Please send responses to the following data requests to Gordon Feighner at
gordon(goregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available durng
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronically only, and in the original electronic format.
12. Please provide the responses to Staff data request 212-225.
Than you for your prompt attntion to these requests.
Sincerely,
t ~:f'. ----.~..~..._-. .... ... .- '. -::...-._...~..-_.~..--_...,~
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordon (g oregoncub.org
CC. Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
1
Page 89 of 100
Citizens' Utiliti Board of Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone]. cub(§oregoncub.org . ww.oregoncub.org
August 24, 2009
David J. Meyer
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
Kelly Norwood
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
Re: UG 186 Data Requests -# 13 - 46
Please send responses to the following data requests to Gordon Feighner at
gordon(goregoncub.org, or, for confidential matenal, at the address above. Please assume
that these are on-going requests if any additional information becomes available dunng
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronically only, and in the origial electronic format.
13. Please provide an organizational char identifyg any company or entity with any
ownership interest in A vista. Include all afliates and all subsidiares.
14. Please provide a complete copy of any Cost Allocation Manual which shows how
costs that are included in A vista's Oregon rate fiing were/are allocated among and
between Oregon operations and other A vista operations.
15. Please provide a complete set of Avista's accounting manuals, policies, and
procedures and/or a detailed description of the organzation's accounts and sub-accounts.
All descriptions should fully and completely explain expenses included in each account.
16. Please provide an employee organzational char detaling deparents, job titles, and
positions for al employees and employee levels. All employees included in the base and
test year expenses should be included. Identify the accounts to which each employee's
time is biled and the maner in which, and the basis for, any allocation of time among
accounts.
17. Please provide the data that was input into the forecast model that is discussed by Mr.
Thies at page 2 of his testimony. If the data was taken directly from the Company's
general ledger at a point in time, provide the date for that point in time and a copy of the
tral balance of the general ledger. If amounts other than the general ledger numbers
were input into the forecasting software, provide details of all differences between the
amount input and the general ledger balances.
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
1
Page 90 of 100
18. With regard to the factoring of accounts receivable, provide a study that demonstrates
that the program provides a cost benefit to the utility's customers.
19. Please provide all studies in the Company's possession that shows that the sale of
accounts receivable
20. Please discuss the company's accounts receivables factoring program in detaiL. What
amount is included in the Company's proposed revenue requirement related to this
program?
21. Referrng to the electronic file named 2010 forecast.x1s provided in response to Staff
DR-77,
a. What does "AA" mean in column B?
b. Provide the calculation of the allocation factor described as "CD AA Four Net Direct
Plant" on line 35.
c. Provide detals of the intangible plant to which the deferred taes on line 14 relate.
Where is ths plant included in the Oregon rate base?
22. Referrng to the electronic spreadsheet named "ASR summer 2010 prices last 66 days
5 5 2009.x1s" provided in response to Staff DR 77, please explain which adjustment(s)
this fie supports and provide a fully functional copy of the spreadsheet including all
other fies necessar to make it function. It appears that ths fie links to other fies that
were not provided.
23. Please explain in detail which costs are categorized as "AA" and allocated to alL.
24. Is the Oregon gas system physically connected to the "north" gas system in any way?
If so, please describe how they are connected.
25. Is the gas supply for Oregon shared in any way with the "north" gas system?
Explain.
26. Referring to the electronic spreadsheet "Recon2008.x1s" (925200-2008 tab) provided
in response to Staf DR 77,
a. Explain why the State of Idaho permt fee of $100 was allocated to Gas South.
b. Explain the nature of the charge labeled "OR Gas-Provision for MajorlM" and why a
portion was allocated to Gas North when the description implies it is an Oregon cost.
c. Explain how the annual premium for the umbrella policy of $227,166 was allocated
among jursdictions. How are the percentages determned and how often are the
metrcs updated?
d. Provide the total anual umbrella premium.
e. Explain why the "Gas accrual nort" is allocated to Gas South.
UG 186 - CUB Data Requests to Avista Corporation
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2
Page 91 of 100
27. Please provide whatever documentation exists that explains how costs ar allocated,
shared, assigned, etc between Gas Nort, Gas South, and any other par of A vista
Corporation.
28. Please provide a schedule which shows all plant additions proposed to be included in
the Company's rate base. Provide ths information by project, the date it is expected to
be in operation, the estimated total costs at completion, and the deferred tax adjustment
associated with each project. For each project, provide a description and the reason it is
being added to the system (customer growth, safety, etc.).
29. Please provide the following inormation about the Company's Oregon operations'
wages and sa1anes for each of the calendar years 2004, 2005, 2006, 2007, 2008:
. a. Total base wages for employees whose wages are charged solely to Oregon
operations.
b. Total overtme wages for employees whose wages are charged solely to Oregon
operations.
c. Officers wages for officers whose wages are charged solely to Oregon operations.
d. Wages charged to expense accounts for employees whose wages are charged solely to
Oregon operations.
e. Wages charged to capita accounts for employees whose wages are charged solely to
Oregon operations.
f. Bonuses for employees whose wages are charged solely to Oregon operations.
g. Incentive compensation for employees whose wages are charged solely to Oregon
operations.
30. Please provide the following wages and sa1anes information for each of the calendar
years 2004, 2005, 2006, 2007, 2008:
a. The total base wages allocated/apportoned to Oregon operations.
b. Total overtme wages allocated/apportioned to Oregon operations.
c. Offcers wages for officers whose wages are alocated/apportoned to Oregon
operations.
d. Wages allocated/apportoned to Oregon operations that were charged to expense
accounts.
e. Wages allocated/apportoned to Oregon operations that were charged to capital
accounts.
f. Bonuses allocated/apportioned to Oregon operations.
g. Incentive compensation allocated/apportioned to Oregon operations.
31. Please provide the following information for each of the calendar years 2004, 2005,
2006,2007,2008:
a. Total base wages for Oregon based employees that were allocated/apportoned to
Avista's operations in another state.
b. Total overtme wages for Oregon based employees that were allocated/apportoned to
A vista's operations in another state. ."
c. Bonuses for Oregon based employees that were allocated/apportoned to A vista's
operations in another state.
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C 3
Page 92 of 100
d. Incentive compensation allocated/apportoned to Oregon operations.
32. Please provide the overhead/oading rate used to "load" payroll costs that were
charged to work orders and/or constrction projects in:
a. 2004
b. 2005
c. 2006
d. 2007
e. 2008
f. 2009
For each year, break down the rate into its component pieces (i.e., medical, pension,
401K, payroll taxes, etc.).
33. Please provide all workpapers, source documents, assumptions, projections, studies,
and any other information necessary to replicate each of the Company's proposed
adjustments to the Results of Operations Report shown on A vista50 1.
34. Please provide a complete, fully indexed and cross-referenced set of workpapers,
including fully functional electronic medium, supportng each witness' testimony. Ths
should include workpapers supporting each pro forma adjustment to the base year, test
period, or futue test year.
35. Please provide a trial balance of Avista's general ledger for its Oregon operations in
an excel fie for calendar years 2007 and 2008 and for the twelve months ended June 30,
2009.
36. Please provide a tral balance of A vista's general ledger for its Oregon operations in
an excel fie for each month subsequent to June 2009 and continue to provide this
information until the hearng in this docket.
37. Please provide a list of the budgeted and actual number of employees and their annual
salares as of December 31, 2006, December 31, 2007, and December 31, 2008 for all
employees included in the revenue requirement and/or invested capital in this docket.
Segregate the list by position.
38. Please provide a list of the employees and their annual salares as of December 31,
2009 and December 31, 2010 for all. employees included in the revenue requirement
and/or invested capital in this docket. Segregate the list by position. Indicate any
position not filled as of the date the response is prepared.
39. Please provide a list of the budgeted and actual number of contract employees by
function as of December 31, 2006, December 31, 2007, and December 31, 2008 for all
contract employees included in the revenue requirement and/or invested capital in ths
docket. Segregate the list by position.
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
4
Page 93 of 100
40. Please provide a list of the contract employees by function as of December 31,2009,
and December 31, 2010 for al contract employees included in the revenue requirement
and/or invested capita in ths docket. Segregate the list by position.
41. Please provide complete copies of Avista's operating budgets for each calendar year
2007 though 2012. Provide the same information for Avista's Oregon operations.
42. Please provide complete copies of A vista's capital budgets for each calendar year
2007 though 2012. Provide the same information for Avista's Oregon operations.
43. Please provide a schedule showing all plant retirements since 0110112007. Include a
detailed description of the plant retied, the plant account numbers afected and the
journal entres made to record each retiement.
44. Please provide a schedule showing all plant retiements planned to occur after
September 30,2009 though December 31,2010.
45. Please provide a copy of Avista's work order policy. If no such policy exists, please
provide a detailed descnption of how A vista uses work orders.
46. Please provide the work orders for the three projects of significant size that are
curently under contrction in Oregon.
Than you for your prompt attention to these requests.
Sincerely,
~,___~__"_~"_,O.1/-
i~;. '\v
Gordon Feighner
Utilty Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portand, OR 97205
[phone]
gordon (g oregoncub.org
cc. Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
5
Page 94 of 100
Citizens' Utiliti Board of Oregon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone] . cub(goregoncub.org . ww.oregoncub.org
August 26, 2009
David J. Meyer
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
Kelly Norwood
A vista Corporation
POBox 3727
Spokane, W A 99220-3727
Re: UG 186 Data Requests # 47 - 65
Please send responses to the following data requests to Gordon Feighner at
gordon(goregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional information becomes available durng
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronictily only, and in the original electronic format.
47. Please provide the responses to Staf Data Requests 226-237.
48. Please explain what is included in sales for resale that is reported in the Company's
Oregon Supplement to PERC Form 2 each year.
49. Please provide the following information regarding sales for resale:
a. To whom are sales for resale made?
b. Are all gas sales for resale made by A vista Corporation that are delivered within the
state of Oregon reported as gas sales for resale in the Oregon Supplement to PERC
Form 2? If not, explain why not.
c. Does the cost of gas reported in the Oregon Supplement to PERC Form 2 include the
gas that is recorded in sales for resale? If not, explain.
50. Under what circumstances are gas sales for resale made?
51. Is the gas related to the gas sales for resale included in the calculation of lost and
unaccounted for gas in the Oregon Supplement to PERC Form 2? If not, why not?
52. Refer to Avista/501, page 4. Please confi that the amounts in column (b), Per
Results of Operations Report, are for the twelve months ended December 31, 2008.
53. Please provide a complete copy of the Results of Operations Report upon which the
values in column (b) on A vista/50l page 4 are taken.
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
1
Page 95 of 100
54. Reconcile gas plant in service by primar plant account per Avista501, page 4 of
$230.167 millon to the 2008 Oregon Supplement to PERC Form 2. Please provide
references for the sources of all amounts included in the reconciliation.
55. Reconcile accumulated depreciation per Avista/501, page 4 of $88.453 milion to the
2008 Oregon Supplement to PERC Form 2. Please provide references for the sources of
all amounts included in the reconcilation.
56. Is the acquisition adjustment included in the Company's proposed rate base?
57. Please provide a schedule in the same format as page 33 of the 2008 Oregon
Supplement to PERC Form 2 that shows the additions, retiements, adjustments, transfers
and ending balances of plant in service by primar plant account from Januar 1,2007
though December 31,2007.
58. Please provide a schedule in the same format as page 33 of the 2008 Oregon
Supplement to PERC Form 2 that shows the additions, retiements, adjustments, transfers
and ending balances of plant in service by primar plant account from Januar 1, 2008
though December 31,2008.
59. Please provide a schedule in the same format as page 33 of the 2008 Oregon
Supplement to PERC Form 2 that shows the additions, retirements, adjustments, transfers
and ending balances of plant in service by primar plant account from Januar 1, 2009
through June 30, 2009.
60. With regard to allocated expenses, are any expenses diectly assigned? If they are,
explain what costs are diectly assigned and what costs are allocated?
61.
a.
b.
c.
62.
a.
b.
c.
d.
Refer to the fie "Labor-2oo5-2008.x1s."
Offcer wages increased by approximately 18% from 2005 to 2006. Please provide
the reasons for ths increase.
Offcer wages increased by 11.6% from 2006 to 2007. Please provide the reasons for
ths increase.
Offcer wages decreased by 9.6% from 2007 to 2008. Please provide the reasons for
ths increase.
Refer to the fie "Labor-2005-2008.xls."
Explain the increase in the number of exempt FlEs from 2006 to 2007.
Explain the increase in the number of exempt FlEs from 2007 to 2008.
Why are exempt employees paid for overtme?
Under what circumstaces are exempt employees paid for overtime?
63. Refer to the file "Labor-2005-2008.x1s." Please explain the increase in the number of
non-exempt Fls from 2006 to 2007.
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
2
Page 96 of 100
64. Refer to the fie "Labor-2005-2008.x1s."
a. Explain the increase in the number of Union Fls from 2006 to 2007.
b. Explain the decrease in the number of Union Fls from 2005 to 2006.
c. Explai the decrease in the number of Union FTEs from 2007 to 2008.
65. Refer to the fie "Labor-2005-2008.x1s." In 2006, overtme wages were
approximately 12.5% of regular wages. In 2006, overtime wages were approximately
19.4% of regular wages. Please provide the reasons for the increase.
Than you for your prompt attention to these requests.
Sincerely,
J".~'1'...----..---"--__.._ ..... --- ~-.._c----.---------~. ..\...
Gordon Feighner
Utilty Analyst
Citizens' Utilty Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordon (goregoneub.org
ce. Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
3
Page 97 of 100
Citizens' Utilitv Board 01 Oreuon
610 SW Broadway, Suite 308
Portland, OR 97205
[phone]. fax [phone] . cub(§oregoncub.org . ww.oregoncub.org
September 11, 2009
David J. Meyer
A vista Corporation
POBox 3727
Spokane, W A 99220-3727
Kelly Norwood
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
Re: UG 186 Data Requests # 67-81
Please send responses to the following data requests to Gordon Feighner at
gordonWoregoncub.org, or, for confidential material, at the address above. Please assume
that these are on-going requests if any additional inormation becomes available during
the pendency of the case. Answers are due within 10 days of service. If you have any
questions, please call us at [phone].
Please provide responses electronicaly only, and in the original electronic format.
67. Please provide the responses to Sta Data Request 247.
68. Mr. DeFelice at page 5-6 of his testimony refers to the Bratte Group study of rising
constrction costs in the utility industr. Did ths study specifically focus on the gas
utilty industry? If not, why type of utilty was the focus? Also, please discuss why Mr.
DeFelice believes the study should be equally applicable to the gas utility industr.
69. Please explain why Phase I of the East Medfòrd Reinforcement Project ran over
budget by approximately $2.8 millon and was completed approximately four months
later than scheduled. Please provide an analysis comparng the original cost estimate, the
actual total costs, and a copy of the work order.
70. Phase II of the East Medford Reinforcement Project was expected to be completed by
October 2008 at a cost of $5 millon. (See UG 181 Avista/4oo/Chrstie/13)
a. Why was Phase II delayed?
b. Has constrction begun?
c. If constrction has begun, on what date?
d. Please provide a copy of the work order for this project as of the date the response to
this DR is prepard.
71. Phase il of the East Medford Reinforcement Project was expected to be completed
by October 2009 at a cost of $6 millon. (See UG 181 A vista/4oo/Chrstie/13).
UG 186 - CUB Data Requests to Avista Corporation
Staff_PR_011 Attachment C
1
Page 98 of 100
a, Why was Phase il delayed?
b. Has constrction begun?
c. If constrction has begun, on what date?
d. Please provide a copy of the work order for this project as of the date the response to
this DR is prepared.
72. What is the status of the Integrity Management Pipe Replacement Project?
a. When was the project completed?
b. What was the total cost?
73. What is the status of the Merlin Gate Station Project?
a. When was the project completed?
b. What was the tota cost?
73. Does A vista plan to continue to sell accounts receivable?
74. Are accounts receivable sold each month? Are they sold more than once each month?
If so, please provide the typical points durng the month that they are sold.
75. Does Avista receive the payment for the receivable sold on the same day of the sale?
If not, how many days later is payment received?
76. How many biling cycles does Avista Oregon have each month? Please provide the
meter read dates for each cycle.
77. Please identify each of the aicraft owned by A vista. Include the number of
passengers each aicraft can accommodate.
78. Please provide the ongina1 cost and the accumulated depreciation for each aicraft
owned by A vista and provide the FERC account in which these items are recorded.
Identify the amounts included in Avista's Oregon rate filing related to each aicraf
and explain how the allocation to Oregon was determned.
79. What were the actual operating and maintenance costs for each aircraft for the year
ended December 31, 2008?
80. Please explain how the aicraft operating and maintenance costs are allocated among
the jurisdictions. Please quantify the amount included in A vista's Oregon revenue
requirement in this case by FERC account and provide the detailed calculations.
81. What is the cost ora trp in each of the corporate aircraft between Spokane and
Salem? Please provide all calculations and assumptions.
Thank you for your prompt attention to these requests.
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
2
Page 99 of 100
Sincerely,~ ./
tt-..._~_.,..__ . ...... . ~_;~~.._.._._~-;¡-~ .-v
Gordon Feighner
Utility Analyst
Citizens' Utility Board of Oregon
610 SW Broadway Ste 308
Portland, OR 97205
[phone]
gordon (goregoncub.org
cc. Service List
UG 186 - CUB Data Requests to Avista Corporation
StafCPR_011 Attachment C
3
Page 100 of 100