20110803Staff 31-60 to Avista.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
201' AUG -3 PM 2: 23
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF A VISTA CORPORATION DBA A VISTA )
UTILITIES FOR THE AUTHORITY TO )
INCREASE ITS RATES AND CHARGES FOR )
ELECTRIC AND NATURAL GAS SERVICE )IN IDAHO. )
)
)
)
CASE NO. AVU-E-11-l1
AVU-G-11-1
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilties Commission, by and through its attorney of
record, Kristine A. Sasser, Deputy Attorney General, requests that Avista Corporation (Company;
Avista) provide the following documents and information on or before WEDNESDAY,
AUGUST 24, 2011.
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementary responses, additional documents that it or any person acting on
its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, including supporting workpapers that provide
detail or are the source of information used in calculations. The Company is reminded that
responses pursuant to Commission Rules of Procedure must include the name and phone number
of the person preparing the document, and the name, location and phone number of the record
SECOND PRODUCTION REQUEST
TO AVISTA 1 AUGUST 3, 2011
holder and if different the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
Request No.3 1: Please provide a printout of all expenses charged to Accounts 920, 921,
923,925,926,928,930,931 and 935 during 2010 and 2011 to date and continuing when
available. Please include amounts paid, vendor, date, and a brief explanation of the expense.
Please also include the amounts allocated to Idaho and show the allocation. This information
should be provided on CD in Excel format with all formulas intact.
Request No. 32: Please provide an analysis of the sale or disposition of land and plant for
the years 2010 and 2011 to date. Please show gains, losses and supporting documentation
including accounting entries for removal of items from rate base.
Request No. 33: Please provide details of any planned sales or disposition of land and/or
plant for the remainder of 20 11. Please include within your response the estimated date of these
sales and planed treatment (including accounting entries) for them.
Request No. 34: Please provide a list of "out-of-period adjustments" and "extraordinary
items" for the years 2010 through 2011 to date and continuing when available.
Request No. 35: Please provide a list of all pending legal cases and their status including
description of the issue, estimates of liability and possible ramifications to the Company.
Request No. 36: Please provide a list of all external legal expenses. Please include
vendor, amount, date, a brief description of the case, and how the amount was allocated to Idaho.
If par of a docketed case, please provide the case number and jurisdiction.
SECOND PRODUCTION REQUEST
TO AVISTA 2 AUGUST 3, 201 i
Request No. 37: Please provide detail of all advertising expenses recorded above the line
including account and subaccount where posted, dates posted, vendor names, explanations, and
amounts posted during 2010. Please identify each expense that is related to safety. In addition,
please provide copies of the ads used during 20 I 0 and correlate the ad copy with the specific
detail provided in this production request response.
Request No. 38: Please provide a list of all consultants who performed services for
A vista Utilities for the years 2010 and 20 i 1 to date. Please include within your response the
services performed, amounts paid, the accounts charged, the allocation factor and amount
allocated to the Idaho jurisdiction.
Request No. 39: Please provide copies of all internal audit reports for the years 20 i 0 and
20 i i to date and continuing when available.
Request No. 40: Please provide a description of all audits/organizational reviews
curently in progress or planed through 20 i 2 year-end. Please include within your response the
description of reviews that are curently underway for which no report has been issued and the
estimated report date.
Request No. 41: Please provide a copy of the policy for bad debt write-offs and
collection of past due amounts.
Request No. 42: Please provide a schedule of bad debt amounts for 2010 and 201 1 to
date and continuing when available.
Request No. 43: Please provide copies of the monthly, quarerly, and anual
presentations to the Company's Executive Board and Chief Executive and Operating Officers for
20 i 0 and 20 i i to date and continuing when available. Please include within your response a
paper copy of any slides and notes used in such presentations.
SECOND PRODUCTION REQUEST
TO AVISTA 3 AUGUST 3, 201 i
Request No. 44: Please provide a copy of each adjusting journal entry proposed by the
Company's independent auditors in the two (2) most recent audits of the Company. Please
include within your response the documentation supporting these adjustments and documentation
supporting any items that were "passed upon" and not reflected in the Company's financial
records and/or financial statements.
Request No. 45: Please provide a copy of all A vista Corporation's policies and other
relevant materials provided as an "employee handbook" for the Company's employees. If the
employee handbook is only available on the Company's intranet, please provide access to the
Company's employee handbook on the Company intranet.
Request No. 46: Please provide the total amount spent on food, meals, snacks, coffee,
and bottled water for the year 2010 and 201 1 to date. Please provide this information by month,
by FERC account, and by category, such as coffee, meals, bottled water, meeting snacks, etc.
Request No. 47: Please provide copies of the employee newsletters issued during 2010
and 201 1 to date.
Request No. 48: Please provide a listing of all penalties and fines included in the test
year, citing the account it is located in, the payee, and the amount.
Request No. 49: Please provide a listing of any costs included in the test year related to
sporting or entertainment events, including but not limited to season tickets or sky boxes. Provide
the accounts where these costs are booked and if above the line and not already removed in this
fiing, please include any and all explanations as to the business purose.
Request No. 50: Please provide a listing of all charitable and political contributions,
including names, amounts and account numbers included in the test year. Please include all
accounts other than Account 930, where charitable contributions are also booked.
SECOND PRODUCTION REQUEST
TO AVISTA 4 AUGUST 3, 2011
Request No. 51: Please provide a listing of licenses paid for by the Company, such as
PE, CPA, Legal, etc., included in the test year by FERC account and sub-account included in the
test year.
Request No. 52: Please provide the audit workpapers from the external auditors for 2010.
Request No. 53: Please explain why the amount biled in 201 1 from NortWestern
Energy for O&M costs associated with the Colstrip transmission system have increased over 26%
from the 2010 test year. Please provide any and all documentation supporting this adjustment
described on page 4 of Mr. Kinney's direct testimony.
Request No. 54: Please provide a complete listing of the $886,000 of expenditures the
Company incurred for the CNC transmission project. Please include date, amount, vendor, a brief
description of the expense, and how the amounts were allocated to Idaho. Reference Kinney
direct testimony, page 17.
Request No. 55: Please provide detailed documentation supporting the $533,000 capital
improvements to the Colstrip Transmission projects.
Request No. 56: Please provide a current listing of all expenditures during 2011 for the
renewal of Tribal Permits.
Request No. 57: Please provide the total number of electric customers and total number
of gas customers (system) as of December 31,2010.
Request No. 58: Please provide the total number of employees as of December 31, 2010.
Please also provide the number of employees whose responsibilities include only A vista gas
operations and only Avista electric operations (time not allocated between the two).
SECOND PRODUCTION REQUEST
TO AVISTA 5 AUGUST 3, 2011
Request No. 59: Does the Company have a program to refurbish and reuse old
transformers when they are taken out of service. If not, why not?
Request No. 60: For each item listed on Table 4 of Kinney's direct testimony, please
provide the most recent projected in-service date.
Dated at Boise, Idaho, this .~ ~ day of August 2011.
4Ab~u a . ~4A,"Kristine A. Sasser
Deputy Attorney General
Technical Staff: DE/31 -60
i:umisc:prodTeq/avue~1 i. lks prod req2
SECOND PRODUCTION REQUEST
TO AVISTA 6 AUGUST 3,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF AUGUST 2011,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA, IN CASE NOS. AVU-E-11-01_AVU-G-II-0l, BY
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: david.meyerCiavistacorp.com
BRAD M PURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyCihotmail.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadingCimindspring.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83702
E-MAIL: bottoCiidahoconservation.org
LARRY CROWLEY
ENERGY STRATEGIES INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 83716
E-MAIL: crowleylaCiaol.com
KELL YO NORWOOD
VP STATE & FED REG
A VIST A CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: kelly.norwoodCiavistacorp.com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peterCirichardsonandolear.com
gregCirichardsonando leary.com
E-MAIL ONLY:
HOWARD RAY
CLEARWATER PAPER CORP
E-MAIL: howard.rayCiclearaterpaper.com
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK ST
PO BOX 2564 (83701)
BOISE ID 83702
E-MAIL: joeCimcdevitt-miler.com
.Koe
SECRETARY
CERTIFICATE OF SERVICE