20121109Staff 26-47 to Avista.pdf

KARL T. KLEIN
WELDON B. STUTZMAN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0318
IDAHO BAR NOS. 5156/3283
I DAH u 13L -
UTILtTi5 L,0MfISSUN
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
UTILITIES FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
ELECTRIC AND NATURAL GAS SERVICE
IN IDAHO.
CASE NO. AVU-E-12-08
AVU-G-12-07
SECOND PRODUCTION
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 3O, 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
SECOND PRODUCTION REQUEST
TO AVISTA 1 NOVEMBER 9, 2012
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 files on CD with formulas activated.
REQUEST NO. 26: Please provide the line item detail for the Information Technology
Refresh Blanket by project for 2010, 2011, 2012, and 2013. Please include both budgeted and
actual-to-date costs for each project.
REQUEST NO. 27: Please provide the line item detail for the Information Technology
Expansion Blanket by project for 2010, 2011, 2012 and 2013. Please include both budgeted and
actual-to-date costs for each project.
REQUEST NO. 28: Please provide all economic analysis including risk analysis of
installing the new Rathdrum CT controller.
REQUEST NO. 29: Please provide all economic analysis including risk analysis of
installing the new Water Supply System for Kettle Falls.
REQUEST NO. 30: Please provide the economic analysis for the CNC project,
including any risk analysis done. Please also provide a copy of the agreement for the project.
REQUEST NO. 31: Please provide the line item detail for the Elect Distribution Minor
Blanket by project for 2010, 2011, 2012, and 2013. Please include both budgeted and actual-to-
date costs for each project as available.
REQUEST NO. 32: Please provide the entire budgeted and actual costs for each of the
following projects by year:
a.Noxon Rapids Living Facility Additions;
b.Bronx-Cabinet 115kV Rebuild/Reconductor;
c.Moscow City-N Lewiston 115 kV Reconductor; and
SECOND PRODUCTION REQUEST
TO AVISTA 2 NOVEMBER 9, 2012
d. Burke-Thompson A&B 115 kV Reconductor
REQUEST NO. 33: Please detail the expenses and budget for the Post Falls Intake Gate
Replacement. If this project was proposed through a bidding process, please provide the
competing bids and contract for the project as well.
REQUEST NO. 34: Please reference Witness Andrews' Exhibit No. 10, Schedule 1,
page 9, adjustment No. 3.08 Workpaper Reference E-ISIT and Schedule 2 page 9 Adjustment No
3.07 Workpaper Reference G-DS. In Witness Andrews' electronic workpapers, titled "IS & IT
Costs," there is a $1,154,313 adjustment for Common Plant and a $230,029 adjustment for
Generation Plant. Please provide the backup detail for those adjustments.
REQUEST NO. 35: Please provide the total dollar amount paid for the "Performance
Excellence Initiative" consultant Booz and Company contract. Please identify where these
amounts are included in this rate case. Please illustrate the allocation of total system costs to
each jurisdiction. Further break this amount down to its effect on electric and natural gas
operations. Include with this information the completion date for this contract and the cost of
service accounts posted.
REQUEST NO. 36: In reference to Andrews, Exhibit No. 10 Adj. 3.07 Property Tax
(Elec.) and 3.05 Property Tax (Gas), please provide actual property tax payments for each year
from 2005 through the present.
REQUEST NO. 37: Please provide the details of any land and plant sales assigned to
Idaho during 2011 and 2012. Please include within your response the accounting treatment of
those sales.
REQUEST NO. 38: Please provide copies of the narrative monthly, quarterly and
annual comparison of operating and capital budgets to actual expenditures for Idaho for the years
2011 and 2012 to date. Please include within your response any narrative explanations for budget
variations. Your response should include, but not be limited to, written operating and capital
SECOND PRODUCTION REQUEST
TO AVISTA 3 NOVEMBER 9, 2012
budget variance reports and explanations used by Company officers and managers to monitor
and control budgets under their areas of responsibility.
REQUEST NO. 39: Please list each capital project assigned to Idaho that was limited,
deferred, rejected or reduced in scope in 2011 and 2012. In your response, please identify the
original amount of each capital project and the amount that the capital actually contributed to the
overall capital budget.
REQUEST NO. 40: Please describe in detail the Company's capital expenditure
process. Your description should include, without limiting, the following information:
a.method to establish total capital expenditure budget;
b.prioritization and allocation of that budget to specific and blanket projects;
c.reassignment of budget allocations based upon project variances (if one project is
under budget is another project added to expend those unused dollars or the opposite);
d.methodology to determine which projects are high priority and which can be deferred
until the economic climate (or other factors) are improved;
e.asset management transactional process (how projects are entered into that system
and ultimately closed to the general ledger and by whom); and
f.other items relevant to the process including a listing and copy of all documents and
reports required and maintained throughout the process.
REQUEST NO. 41: If not included within the response to the previous request, please
identify all forms/studies/analyses required to substantiate the need for a project, including but
not limited to, cost-benefit analyses and offsetting savings/revenues.
REQUEST NO. 42: Please provide a matrix identifying the major capital expenditure
approval levels. Please include with the matrix the dollar level of authorization by employee
title, division, and company. Please include within your response the dollar level at which
individual capital expenditure projects require approval by the Board of Directors or highest
threshold of approval.
SECOND PRODUCTION REQUEST
TO AVISTA 4 NOVEMBER 9, 2012
REQUEST NO. 43: Please provide an updated schedule of the 2011 capital additions as
proposed in Case Nos. AVU-E-1 1-01 and AVU-G-11-0l that includes the following by project:
a.planned dates in service as proposed in those rate cases;
b.actual dates in service;
c.budgeted capital expenditures as proposed in those rate cases; and
d.actual capital expenditures incurred.
REQUEST NO. 44: Please provide copies of the contracts associated with plant
additions listed on Exhibit 10, Schedule 2, page 5 for gas pro forma capital additions 3.08 and
3.09.
REQUEST NO. 45: Please provide a schedule that identifies the expected Date in
Service of all 2012 and 2013 natural gas capital projects included within the Company's case, the
budgeted expenditures, and actual expenditures to date and identify the source of this
information for each project. Please consider this an ongoing request and provide all updates to
those dates in service and expenditures during the course of this case. Please provide the
printout of this information and the underlying electronic file in Excel format with formulas
activated.
REQUEST NO. 46: For the natural gas pro forma capital additions 3.08 and 3.09 listed
on Exhibit 10, Schedule 2, page 5, please provide the following information for Idaho separately
for each project: invoice number, description of payment, vendor name, date posted and amount,
from inception of project to date. Please provide the printout of this information and the
underlying electronic file in Excel format with formulas activated.
SECOND PRODUCTION REQUEST
TO AVISTA 5 NOVEMBER 9, 2012
For Request No. 47, please reference Dave DeFelice Testimony, page 7, Table 1 in Case
Nos. AVU-E-12-08 and AVU-G-12-07 below:
Planned
Expenditures
($ millions)
Actual Expenditures
($ millions) Percentage of
Planned
2007 $183.6 $198.4 108%
2008 $190.0 $205.4 108%
2009 $202.0 $199.7 99%
2010 $228.3 $213.5 94%
2011 $249.1 $237.7 95%
Five Year Average $210.6 $210.9 100.0%
Please also reference Dave DeFelice Testimony, page 6, Table 1 in Case Nos. AVU-E-
11-01 and AVU-G- 11-01 below:
Planned
Expenditures
($millions)
Actual Expenditures
($millions)
Percentage of Planned
(%)
2007 $183.6 $198.4 108%
2008 $194.2 $205.4 106%
2009 $202.0 $199.7 99%
2010 $210.0 $206.8 98%
REQUEST NO. 47: Please provide the supporting detail of the budgets and
expenditures for each year. For those years where the planned expenditures and/or actual
expenditures do not match (2008 and 2010), please provide a detailed explanation, including
supporting documentation of the reason for those differences.
Dated at Boise, Idaho, this day of November 2012.
u -) ~L-
Karl T. Klein
Deputy Attorney General
Technical Staff: Joe Terry/26-34
Shelby Hendrickson/35-46
Patricia Harms/47
i:umisc:prodreq/avuel2.8avugl2.7kkjtshph prod req2
SECOND PRODUCTION REQUEST
TO AVISTA 6 NOVEMBER 9, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF NOVEMBER 2012,
SERVED THE FOREGOING SECOND 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
VP & CHIEF COUNSEL
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
P0 BOX 2564
BOISE ID 83702
E-MAIL: [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
515 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
greg(ZirichardsonandoIeary.com
KELLY 0 NOR WOOD
VP STATE & FED REG
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
LARRY A CR0 WLEY
THE ENERGY STRATEGIES
INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 83716
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadingmindspring.com
ELECTRONIC SERVICE ONLY:
Howard Ray
Clearwater Paper Corporation
[e-mail]
SECRETARY/
CERTIFICATE OF SERVICE