20121101Staff 1-25 to Avista.pdf

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KARL T.KLE1N R IE C C jr:
WELDON B. STUTZMAN . .
DEPUTY ATTORNEYS GENERAL 2U1:2N.OV - I
IDAHO PUBLIC UTILITIES COMMISSION .,
- P0 BOX 83720 'OMMI C'
BOISE, IDAHO 83720-0074
[phone]/334-0318
IDAHO BAR NOS. 5 156/3283
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 AVISTA CORPORATION DBA AVISTA ) CASE NO. AVU-E-12-08
UTILITIES FOR AUTHORITY TO ) AVU-G-12-07
INCREASE ITS RATES AND CHARGES FOR )
ELECTRIC AND NATURAL GAS SERVICE ) FIRST PRODUCTION
IN IDAHO. ) REQUEST OF THE
) COMMISSION STAFF TO
) AVISTA CORPORATION
The Staff of the Idaho Public Utilities requests that Avista Corporation (Company;
Avista) provide the following documents and information as soon as possible, by FRIDAY,
NOVEMBER 23, 2012.
This Production Request is to be considered as continuing, and Avista 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
FIRST PRODUCTION REQUEST
TO AVISTA 1 NOVEMBER 1, 2012
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holder and if different the witness who can sponsor the answer at hearing if need be Reference
IDAPA31 0101228
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated
REQUEST NO 1 Please provide all data used in the regression analyses found in Ms
Knox's work papers entitled "2010 Electric Regressions xis" and "2010 Gas Regression xis"
Please provide the data in Excel format
REQUEST NO 2 Please provide the daily trade volume used to establish the 1-month
average of calendar-year 2013 monthly forward prices referenced on page 17 of Mr. Kalich's
direct testimony.
REQUEST NO 3 Please provide calendar-year 2013 monthly forward prices by day
from January 1, 2012 through present
REQUEST NO 4 Please identify the source for the monthly forward natural gas prices
found in the "Nucleus Data" spreadsheet in the Excel workbook
"Natural Gas 2013 073012 xis"
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those provided for Coistrip (Colstrip Maintenance _Finai.xls), Kettle Falls (Kettle Falls
Maintenance_Final xis), and Lancaster (Lancaster Maintenance_Final xis) Please provide the
file in Excel format
REQUEST NO 6 For calendar years 2007, 2008, 2009, 2010, 2011, and 2012 please
provide the trial balances by month, by FERC account, and by FERC sub-account in an Excel
spreadsheet with all formulas intact
FIRST PRODUCTION REQUEST
TO AVISTA 2 NOVEMBER 1, 2012
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REQUEST NO. 7: Please provide the economic analysis for the Coyote Springs 2
hydrogen gas generator.
REQUEST NO. 8: Please provide details of the costs for the individual items included
in the Colstrip Capital Additions.
REQUEST NO. 9: Please update the status on the Department of Ecology investigation
of the water rights for the Kettle Falls new water supply.
REQUEST NO. 10: Please detail the expenditures for the Clark Fork River
Implementation PM&E for 2012 and 2013.
REQUEST NO. 11: Please completely describe the items included in Failed Electric
Plant account.
REQUEST NO. 12: Please provide a schedule by project (including description) and
year showing the detailed amounts of Capital Expenditures for Failed Electric Plant for the years
2007, 2008, 2009, 2010 and 2011.
REQUEST NO. 13: Please provide a schedule by project (including description) and
year showing the detailed amounts of Capital Expenditures Transmission Minor Rebuilds for the
years 2007, 2008, 2009, 2010 and 2011.
Request Nos. 14-16 refer to the following information from the Investor Relations section
of Avista Corp's website:
See Reference webpage: http://investor.avistacorp.com/phoenix.zhtml?c=97267&p=irol-fund
BalanceA.
FIRST PRODUCTION REQUEST
TO AVISTA 3 NOVEMBER 1, 2012
Period Ended 12/31/2011 12/31/2010 12/31/2009 12/31/2008 12/31/2007
Employees 2,809 2,499 2,435 2,127 2,117
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REQUEST NO. 14: Please describe how the number of employees for each year is
calculated. For example, are only full-time employees included in the December 31, 20XX
number? Does the number reported include all employees or are part-time employees excluded?
Does the Company use the actual number of full-time employees or does the company use full-
time equivalents?
REQUEST NO. 15: How many employees, by year, are attributable to each subsidiary
of Avista? For example, how many employees, by year, are attributable to Avista Utilities, both
regulated and non-regulated operations? Flow many of the employees are attributable to Ecova?
Are any employees attributable to more than one subsidiary?
REQUEST NO. 16: Please explain, by calendar year beginning with 2008, the increase
in the total number of employees. Please include in your explanation job descriptions for new
positions, the Avista subsidiary for each new position or employee, (Avista Utilities, Ecova,
other subsidiary). For example, there was an increase of 10 employees in 2008 over 2007.
Please describe why there was an increase in employees, what subsidiary or subsidiaries the new
employee numbers are attributable to, and the justification for the increase in the number of
employees.
Request Nos. 17-25 pertain to the October 22, 2012 news release and the 8-K information
filed with the SEC that same day.
REQUEST NO. 17: The October 22, 2012 news release states: "Certain programs are
expected to be implemented at Avista Utilities in 2012 to achieve long-term cost savings."
Besides the voluntary severance incentive program, what other programs are being
implemented? Please provide a narrative description, including the costs and savings of the
other programs.
FIRST PRODUCTION REQUEST
TO AVISTA 4 NOVEMBER 1, 2012
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REQUEST NO 18 If Avista does not receive the required participation in the
voluntary severance incentive program, will the Company initiate a mandatory severance
program? Please explain
REQUEST NO 19 How many utility employees planned or needed to accept voluntary
severance to meet Avista' s savings goals?
REQUEST NO 20 Although the Company has not stated what it expects its severance
costs to be, please estimate those costs if (a) all utility employees identified in Request No 19
were to accept the buy-out, (b) 50% of those employees accept the buy-out, and (c) 25% of those
employees accept the buy-out
REQUEST NO 21 Please provide the calculation showing how the reduction in force
will affect pension costs on a system basis and an Idaho basis.
REQUEST NO 22 Please provide a calculation showing how the reduction in force
will affect post retirement benefits besides pension on a system basis and an Idaho basis
REQUEST NO 23 Please provide a revenue requirement calculation (System and
Idaho) based on 100% of planned utility employees accepting the buy-out, 50% accepting the
buy-out, and 25% accepting the buy-out If severance costs are included, please specify the costs
in a separate column or adjustment
REQUEST NO 24 Please provide a calculation showing the allocation of the voluntary
severance program savings between operating expenses and capitalized expenses on a system
basis and an Idaho basis
REQUEST NO. 25: Please provide any and all information about the voluntary
reduction in force provided to each regulatory jurisdiction
FIRST PRODUCTION REQUEST
TO AVISTA 5 NOVEMBER 1, 2012
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Dated at Boise, Idaho, this /'day of November 2012
K4K1ei
Deputy Attorney General
Technical Staff. Cathleen McHugh/1 -5
Joe Terry/6-13
Kathy Stockton/14-25
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FIRST PRODUCTION REQUEST
TO AVISTA 6 NOVEMBER 1, 2012
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF NOVEMBER 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-12-08
& AVU-G-12-07, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
DAVID J MEYER KELLY 0 NOR WOOD
VP & CHIEF COUNSEL VP STATE & FED REG
AVISTA CORPORATION AVISTA CORPORATION
P0 BOX 3727 P0 BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-MAIL: [e-mail] E-MAIL: [e-mail]
DEAN J MILLER LARRY A CR0 WLEY
McDEVITT & MILLER LLP THE ENERGY STRATEGIES
P0 BOX 2564 INSTITUTE INC
BOISE ID 83702 5549 5 CLIFFSEDGE AVE
E-MAIL: [e-mail] BOISE ID 83716
E-MAIL: [e-mail]
SECRETAJ
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