20110822Staff to Avista 75-117.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
2011 AUG 22 PM 2: 03
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. A VU-E-ll-ll
AVU-G-ll-1
FOURTH 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 MONDAY,
SEPTEMBER 12,2011.
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 wil 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
FOURTH PRODUCTION REQUEST
TO AVISTA 1 AUGUST 22,2011
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. 75: Please provide documentation showing the accounting treatment used
for all ARR grants received or expected to be received.
Request No. 76: Please provide the amount of ColumbiaGrid general funding expenses
for 201 1 per the General Funding Agreement with ColumbiaGrid for the RTO Development.
Request No. 77: Please provide the actual ColumbiaGrid PEFA Expenses for 2011 per
the Planing and Expansion Functional Agreement.
Request No. 78: Please provide the actual 2011 ColumbiaGrid OASIS Expenses per the
OASIS Functional Agreement.
Request No. 79: Please provide a schedule showing the monthly amounts paid to the
third party vendor for Electric Scheduling and Accounting Services for 2010 - 2011.
Request No. 80: Please provide the amounts paid by year for the Power Factor Penalty
to BP A for the years 2005-2010.
Request No. 81: Please provide the amounts paid by year in WECC Loop Flow charges
for the years 2005-2010.
Request No. 82: Please provide a current update on the progress of the Canada to
Northern California (CNC) Transmission project.
FOURTH PRODUCTION REQUEST
TO AVISTA 2 AUGUST 22, 2011
Request No. 83: Please provide a listing of all expenses to date associated with the CNC
transmission project, including vendor, date, amount, voucher number, and any other pertinent
information.
Request No. 84: Please provide the amount of revenue by year received from OASIS
Non-Firm and Short-Term Firm Transmission Services for the years 2005-2010.
Request No. 85: Please provide the amount of revenue by year received under the Dry
Gulch Use-of-Facilties agreement for the years 2005-2010.
Request No. 86: Please provide all officers' employee numbers, names, job titles,
detailed job descriptions, responsibilties, base salaries, and other compensation by year
beginning with Calendar Year 2006.
Request No. 87: Please provide details of all incentive plans included in the test period
and the criteria and goals used to grant employee incentive payments. Please identify any
changes made to the plans during the last six years.
Request No. 88: Please provide all offcers' salaries for the last five years for each
offcer by month, and please itemize by base salary, bonuses, and benefits, along with the
amount included in the test year and the amount paid for by shareholders.
Request No. 89: Please explain the basis for all officers' salar increases from 2006 to
2010. Also, please provide all documents that discuss the basis.
Request No. 90: Please provide the actual monthly vegetation management expenditures
incurred by the Company for the years 2006 through present, by jurisdiction and by function
(transmission and distribution). Please also provide a budget versus actual variance analysis for
this information for the same time period.
FOURTH PRODUCTION REQUEST
TO AVISTA 3 AUGUST 22,2011
Request No. 91: Regarding the direct testimony of Mr. Kopczynski, pages 8-9, his
reference to the "defined Benefit Pension Plan's benefit formula reduced" effective Januar 1,
2006, for new non-union hires and effective January 1,2011 for new union hires, please provide
the benefit formulas for both non-union and union new hires. Please also provide the benefit
formulas used prior to the changes.
Request No. 92: Please provide any and all studies used when determining the
appropriate level of benefits for the Company's pension plans.
Request No. 93: Regarding the direct testimony of Mr. Kopczynski, pages 8-9, his
reference to the Company's "bargaining unit's wages were kept in line with neighboring
investor-owned utilties and PUDs,"
a. Please state the dates over which these wages were "kept in line";
b. List the IOUs and COUs Avista refers to as "neighboring";
c. State specifically what A vista means by "kept in line"; and,
d. Provide all documents relied on to respond to this request.
Request No. 94: Please provide the effective dates and expiration dates of all new
contracts negotiated with collective bargaining units for the years 2007-2011.
Request No. 95: Regarding the direct testimony of Mr. Kopczynski, page 13, his
reference to the Company's "landlord workbench" program, please state the anual cost and the
anual cost savings of this program for each year it has been in effect.
Request No. 96: Regarding the direct testimony of Mr. Kopczynski, page 13, his
reference to the Company's "construction workbench" program, please state the anual cost and
the anual cost savings of this program for each year it has been in effect.
FOURTH PRODUCTION REQUEST
TO AVISTA 4 AUGUST 22,2011
Request No. 97: Regarding the direct testimony of Mr. Kopczynski, page 14, his
reference to the Company's energy conservation and efficiency at its own facilties, please state
the anual cost and the annual cost savings of this program for each year it has been in effect.
Request No. 98: Please provide the amounts spent in Idaho o:a atmospheric testing for
corrosion by month during 2011.
Request No. 99: What impact on Avista system reliabilty and renewable energy
integration costs would occur if only the BC Hydro "northern project" is constructed as part of
the Canada to Northern California (CNC) project?
Request No. 100: What were the primar issues between the paries that contributed to
the decision that the CNC project should not be developed as a single cooperative project?
Request No. 101: At this time, the "original" cooperative CNC project has completed
the WECC Project Review and Phase I Rating Study and is in the process of being evaluated in
the Phase II process for the single cooperative project. Given that this project is curently being
planned and developed as a "southern project" and a "northern project," wil the WECC project
review and evaluation process require additional steps and, if so, what are the estimated
additional expenses?
Request No. 102: How was the cost estimate for the Transmission Line Ratings
Confirmation Plan determined? Is this project being performed by A vista or a subcontractor?
What is the anticipated annual cost of this program after the initial verification of record drawing
planprofie and field confirmation is complete?
Request No. 103: How are the benefits of future transmission projects quantified for
puroses of developing a cost!enefit analysis? Is the cost avoidance ofNERC violations
included in this evaluation?
FOURTH PRODUCTION REQUEST
TO AVISTA 5 AUGUST 22,2011
Request No. 104: What methodology does A vista utilze to prepare cost estimates for
transmission and distribution projects? Historical cost database, industr standard costing
publications, consultation with utilty industry contractors?
Request No. 105: For major transmission and distribution projects, what average
percentage of the work is performed by A vista crews and what percentage of the work is
performed by contractors? Does A vista utilze a formal competitive bidding process for
contracted work?
Request No. 106: For large-scale transmission and distribution, what value engineering
steps are taen by A vista to ensure that all projects are constructed at the highest quality level at
the lowest reasonable cost? Is this value engineering process limited to internal review or is an
external value engineering process utilzed?
Request No. 107: How does Avista determine whether a project is categorized as
"Reliabilty Compliance" or a "Reliabilty Improvement?" Is the evaluation methodology the
same for determining the cost!enefit of each of these categories of projects?
Request No. 108: What process did Avista use to estimate the $1.55 milion, FY 2012,
cost of Transmission Minor Rebuilds investment as this category of projects is based on weather,
fire, wind and human caused damage?
Request No. 109: In FY 2010, Avista spent $3.053 milion and in FY 2011, Avista spent
$2.75 milion on Transmission Minor Rebuild projects. In FY 2012, A vista estimates only $1.50
milion on Transmission Minor Rebuild projects. Since the cost of these projects is not based on
controllable events, what is the rationale for the significant reduction in this investment category
and the downward trend since FY 201 O?
Request No. 110: What percentage of the historical and projected Transmission Minor
Rebuild replacement costs are caused by each of the individual categories (weather, fire, wind,
FOURTH PRODUCTION REQUEST
TO AVISTA 6 AUGUST 22,2011
human damage)? In the case of wind damage, is this an area of future expenditure that the
increased emphasis on the Vegetation Management Program should reduce?
Request No. 111: On a more detailed level than presented in the testimony provided by
Mr. Kinney, what are the input variables for the Asset Management Models? How is an
acceptable level of failures addressed by the model?
Request No. 112: As with most, if not all, infrastructue asset management models the
A vista model is statistically based. How are the individual component life expectacy durations
determined? What is the statistical methodology utilzed to address the level of acceptable and
unacceptable failure rates for each component type?
Request No. 113: The Irvin Integration: Irvin - Milwood 115kV transmission line
project ($1.15 milion) is cited in Mr. Kinney's testimony as "improving" reliabilty and that this
project is not useful until a "future" Irvin Substation is constructed. Is this correct? When is the
Irvin Substation planed to be constructed? Is this project required to meet NERC/WECC
reliability requirements? What would be the reliabilty impact to the A vista Spokane Valley
system if this project was not constructed?
Request No. 114: What reliabilty issues does the Spokane Valley system curently have
and has it become less reliable in the recent past? Does A vista have outage data and reliabilty
statistics to support the necessity to improve that system's reliabilty at this time?
Request No. 115: Has Avista incured any NERC/WECC fines for non-compliance,
either via self-reporting or audit, that were directly related to the Reliabilty Compliance projects
listed in Table 4 or Table 6 of Mr. Kinney's testimony?
Request No. 116: The Thornton 230 kV Substation is listed in Table 6 of Mr. Kinney's
testimony as a Reliability Compliance project. However, the project description indicates that
this project is solely required for wind integration and not reliabilty concerns. The project
FOURTH PRODUCTION REQUEST
TO AVISTA 7 AUGUST 22,2011
description does not list any NERC/WECC standards for this project. What NERC/WECC
reliabilty standards does the constrction of this project intend to meet? Is the sole purpose of
the project to provide for wind integration?
Request No. 117: Distribution reliability project investment to improve worst
performing feeders is $925,000 in 2011(pro forma Table 5) and is $1,075,000 in 2012 (pro forma
Table 7). Mr. Kinney's testimony indicates that distribution system reliability investment for
worst performing feeders has been on-going anually since 2008. The worst performing feeders
are determined using "a combination of reliability statistics, including CAIDI, SAIFI and CEMI
(Customers Experiencing Multiple Interrptions)." Have the fuds expended in 2008, 2009 and
2010 for distribution system reliabilty improvements positively impacted the above reliabilty
statistics for the worst performing feeders? If so, what have been the reliabilty statistics for the
improved feeders in succeeding year(s)?
Dated at Boise, Idaho, this ~ay of August 2011.
~~tl'~A~tine A. Sasser
Deputy Attorney General
Technical Staff: Donn English/75 - 98
Doug Cox/99 - 117
i:umisc:prodreqlavue~i I.ks prod req 4
FOURTH PRODUCTION REQUEST
TO AVISTA 8 AUGUST 22, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF AUGUST 2011,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA, IN CASE NOS. AVU-E-II-01_AVU-G-II-01, BY
E-MAILINGAND MAILING A COpy THEREOF, POSTAGE PREPAID, TO. THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: david.meyer§avistacorp.com
BRAD MPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ihotmaiL.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading§mindspring.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83702
E-MAIL: botto§idahoconservation.org
LARRY CROWLEY
ENERGY STRATEGIES INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 83716
E-MAIL: crowleyla§aoL.com
KELLY 0 NORWOOD
VP STATE & FED REG
AVISTA CORPORATION
PO BOX 3727
SPOKAE WA 99220-3727
E-MAIL: kelly.norwood§avistacorp.com/
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter§richardsonandolear.com
greg§richardsonando leary.com
E-MAIL ONLY:
MARV LEWALLEN
CLEARWATER PAPER CORP
E-MAIL:
marv.lewallen(aclearwaterpapercorp.com
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK ST
PO BOX 2564 (83701)
BOISE ID 83702
E-MAIL: joe§mcdevitt-miler.com
SECRETARY
CERTIFICATE OF SERVICE