20121113Avista to Staff 1-6,14-25.pdf

Avista Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
TOIL Free 800-727-9170
:i 13 At t11O:3
AVISTA'
Corp.
• ••- u
November 12, 2012 j SION
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83720-0074
Attn: Karl T. Klein
Weldon B. Stutzman
Deputy Attorney General
Re: Production Request of the Commission Staff in Case Nos. AVU-E-12-08 and
AVU-G- 12-07
Dear Mr.Klein and Mr. Stutzman,
Enclosed are an original and three copies of Avista's responses to IPUC Staffs production
requests in the above referenced docket. Included in this mailing are Avista's responses to
production requests 001 - 006, 014 - 025. The electronic versions of the responses were emailed
on 11/12/12 and are also being provided in electronic format on the CD included in this mailing.
Also included are Avista's CONFIDENTIAL responses to PR 003C, 005C, and 025C. This
response contain TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and
is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code,
and pursuant to the Protective Agreement between Avista and IPUC Staff dated October 15,
2012. It is being provided under a sealed separate envelope, marked CONFIDENTIAL.
If there are any questions regarding the enclosed information, please contact Paul Kimball at
[phone] or via e-mail at [e-mail]
Sincerely,
Paul Kimball
Regulatory Analyst
Enclosures
CC: all parties
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
R E CE I VE 0
JURISDICTION: IDAHO DATE PREPARED: 11/06/201-2
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Tara IlWi NOV 1 3 AMID: l3
REQUESTER: IPUC RESPONDER: Tara Knox
TYPE Production Request DEPARTMENT State
REQUEST NO.: Staff-001 TELEPHONE: (509) 432'
REQUEST:
Please provide all data used in the regression analyses found in Ms. Knox's work papers entitled
"2010 Electric Regressions.xls" and "2010 Gas Regression.xls." Please provide the data in Excel
format.
RESPONSE:
Please see the Staff _PROO1 Attachment A, an Excel file which contains the data that was loaded
into the E-Views program where the regressions were calculated. I have also provided the E-views
work file as Staff PR 001 Attachment B. Do to the voluminous nature of the files they are being
provided in electronic form only.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/15/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Clint Kaliich
REQUESTER: WUC RESPONDER: James Gall
TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-002 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Avista does not receive forward natural gas price trade volumes from ICE (see PR 4); therefore
Avista is unable to provide this data. The Company believes the ICE is the most liquid natural gas
futures market available. These prices provided are used for multiple company initiatives
including mark to market calculations reviewed by our external auditors and used for the forward
market projections incorporated into the Purchased Gas Cost Adjustments. A rolling four day
Henry Hub-trade information page is available on the ICE website, and includes daily trade
volumes.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/15/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Clint Kalich
REQUESTER: IPUC RESPONDER: James Gall
TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-003 TELEPHONE: [phone]
REQUEST:
Please provide calendar-year 2013 monthly forward prices by day from January 1, 2012 through
present.
RESPONSE:
Please see Avista's response 003C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and exempt from public view and is separately filed under
IDAPA 3 1.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
Please see Staff_PR_003C Confidential Attachment A for the requested forward price data.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE -PREPARED: 11/15/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Clint Kalich
REQUESTER: IPUC RESPONDER: James Gall
TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-004 TELEPHONE: [phone]
REQUEST:
Please identify the source for the monthly forward natural gas prices found in the "Nucleus Data"
spreadsheet in the Excel workbook "Natural_Gas_20 1 3_0730 1 2.xls."
RESPONSE:
The data for the forward prices is provided by the IntercontinentalExchange "ICE". More
information about the IntercontinentalExchange can be found on their website www.theice.com .
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/15/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Clint Kalich
REQUESTER: IPUC RESPONDER: James Gall
TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-005 TELEPHONE: [phone]
REQUEST:
Please provide a maintenance file for Coyote Springs similar to those provided for Coistrip
(Coistrip Maintenance_Final.xls), Kettle Falls (Kettle Falls Maintenance_Final.xls), and
Lancaster (Lancaster Maintenance Final.xls). Please provide the file in Excel format.
RESPONSE:
Please see Avista's response 005C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and exempt from public view and is separately filed under
IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
Please see Staff PR_005C Confidential Attachment A for the Coyote Springs 2 maintenance file.
The outages included on this worksheet are considered planned outages.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/15/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Paul Kimball
TYPE: Production Request DEPARTMENT: Rates& Tariff Admin.
REQUEST NO.: Staff-006 TELEPHONE: [phone]
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.
RESPONSE:
Please see Staff_PROO6 Attachment A.
Do to the voluminous nature of the files they are being provided in electronic form only.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Rates & Tariffs
REQUEST NO.: Staff-014 TELEPHONE: [phone]
REQUEST:
Request Nos. 14-16 refer to the following information from the Investor Relations section of
Avista Corn's- website:
Period Ended 1 12/31/2011 12/31/2010 1 12/31/2009 12/31/2008 12/31/2007
Employees 1 2,8091 2,499 -------- 2,435 2,127 2,117
See Reference webpage: http://investor.avistacorp.comlphoenix.zhtml ?c=97267&pirol-fund
BalanceA.
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?
RESPONSE:
These numbers represent the number of full-time, part-time and seasonal employees, as reported,
as of the fiscal period end date. Each employee is counted as one body. The numbers include
utilities operations and all subsidiary employees. Please also see Staff _PR_015 and
Staff PR _0 16.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Rates & Tariffs
REQUEST NO.: Staff-015 TELEPHONE: [phone]
REQUEST:
Request Nos. 14-16 refer to the following information from the Investor Relations section of
Avista Corn's website:
Period Ended 12/31/2011 12/31/2010 1 12/31/2009 1 12/31/2008 1 12/31/2007
Employees 2,809 1 2,4991 2,435 1 2,1271 2,117
See Reference webpage: http://investor.avistacorp.com/phoenix.zht l?c=97267&p=irol-fund
BalanceA.
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? How many of the employees are attributable to Ecova? Are any employees
attributable to more than one subsidiary?
RESPONSE:
Please see Staff-0 15 Attachment A. Note that the Investor Relations employee data (included in
the question above) varies slightly from the attached information. This is due to employee count
information received from Ecova and the timing of when the information was received and
presented. Employees are counted as one body and are not reflected in multiple subsidiaries.
Avista Utilities and Subsidiaries
utility(l) Subsidiary Total
# of Employees # of Employees # of Employees
2008 1482 727 2,209
2009 1538 925 2,463
2010 1554 1,030 2,584
2011 1594 1,356 2,950
Utility Subsidiary Total
# Increase # Increase # Increase

2008-2009 56 198 254

2009-2010 16 105 121

2010-2011 40 326 366
Employee Count by Subsidiary
2008 2009 2010 2011
Ecova, Inc.*
Advanced Mfg and Dev, Inc.
Steam Plant Brew Pub, LLC
727 925 1,030 1,356
(1) Utility employees who perform non-utility operating activities charge their time to non-operating expenses.
This typically equates to less than .2% of total hours.
* Consolidated, Includes Ecos IQ
Staff _PR_015 Attachment A.xlsx Page 1 of 1
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
-CASE NO: AVU-E- 12-08-] AVU-G- 12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Rates & Tariffs
REQUEST NO.: Staff-016 TELEPHONE: [phone]
REQUEST:
Request Nos. 14-16 refer to the following information from the Investor Relations section of
Avista Corp's website:
Period Ended 1 12/31/2011 12/31/2010 1 12/31/2009 1 12/31/2008 1 12/31/2007
Employees 1 2,809 2,4991 2,435 1 2,1271 2,117
See Reference webpage: http://investor.avistacorp.comlphoenix.zhtml ?c=97267&pirol-fund
BalanceA.
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.
RESPONSE:
Please see Staff _PR_015 Attachment A
The Company does not have in place a mechanism to track each individual position added.
However, the largest increases in number of employees for the utility occurred between 2008 and
2009, where 56 employees were added, and between 2010 and 2011, where 40 employees were
added. The increase for 2008-2009 was driven by our Process Improvement initiatives, Smart
Grid projects, 14 additional customer service rep positions, 4 additional positions for the housing
facilities at the(cabinet and noxon hydro generating facilities and replacement of vacant positions
from 2008 and early 2009 hiring freeze.
The increase for 2010-2011 was driven primarily from the Enterprise Technology sourcing
realignment project (29 positions added with an offsetting reduction in contracted employees),
regulatory compliance of different types, and analytical positions due to technology enhancements
and additions.
The majority of subsidiary increases, mainly Ecova, were driven by the acquisition of new
companies and additional employees to support revenue growth.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
CASE NO: AVU-E-12-08 / AVTJ-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews
TYPE: Production Request DEPARTMENT: State & Federal Reg.
REQUEST NO.: Staff-017 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Please see Avista's response to Staff's PR 025. At this time no other specific programs have been
implemented or identified for cost savings. We are, however, evaluating all operating and
maintenance activities, including administrative and general expenses, to identify where we can
slow the growth in expenses.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews
TYPE: Production Request DEPARTMENT: State & Federal Reg.
REQUEST NO.: Staff-018 TELEPHONE: [phone]
REQUEST:
If Avista does not receive the required participation in the voluntary severance incentive program,
will the Company initiate a mandatory severance program? Please explain.
RESPONSE:
The Company has not made that determination at this time. Please see Avista's response to Staff
PR 025.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews
TYPE: Production Request DEPARTMENT: State & Federal Reg.
REQUEST NO.: Staff-019 TELEPHONE: [phone]
REQUEST:
How many utility employees planned or needed to accept voluntary severance to meet Avista's
savings goals?
RESPONSE:
The savings that will be realized from the Voluntary Severance Incentive Plan (VSIP) will be a
part of the planned $14 million reduction to 2013 O&M/A&G expense. As stated in Avista's
response to Staff PR 025, we do not know at this time how many employees will sign up for the
VSIP, or whether the Company will say "Yes" to all those that sign up (under the double "Yes"
provision of the Plan). We currently do not have an estimate of the costs associated with the VSIP,
or the future reduction in expense associated with the VS[P. Please see Avista's response to Staff
PR 025.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11109/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews
TYPE: Production Request DEPARTMENT: State & Federal Reg.
REQUEST NO Staff-020 TELEPHONE [phone]
REQUEST
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.
RESPONSE:
Please see the Company's response to Staff PR 019.
AVISTA CORPORATION
RESPONSE To REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews
TYPE: Production Request DEPARTMENT: State & Federal Reg.
REQUEST NO.: Staff-021 TELEPHONE: [phone]
REQUEST:
Please provide the calculation showing how the reduction in force will affect pension costs on a
system basis and an Idaho basis.
RESPONSE:
This information is not available at this time. Please see Avista's response to Staff PR 019 and
Staff PR 025.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews
TYPE: Production Request DEPARTMENT: State & Federal Reg.
REQUEST NO.: Staff-022 TELEPHONE: [phone]
La 1'J pa
Please provide a calculation showing how the reduction in force will affectpost retirement benefits
besides pension on a system basis and an Idaho basis.
RESPONSE:
This information is not available at this time. Please see Avista's response to Staff PR 019 and
Staff PR 025.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED 11/09/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews
TYPE: Production Request DEPARTMENT: State & Federal Reg.
REQUEST NO.: Staff-023 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
This information is not available at this time. Please see Avista's response to Staff PR 019 and
Staff PR 025.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/09/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews
TYPE: Production Request DEPARTMENT: State & Federal Reg.
REQUEST NO.: Staff-024 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
This information is not available at this time. Please see Avista's response to Staff PR 019 and
Staff PR 025.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 11/15/2012
CASE NO: AVU-E-12-08 / AVU-G-12-07 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Paul Kimball
TYPE: Production Request DEPARTMENT: Rates & Tariff Admin.
REQUEST NO.: Staff-025 TELEPHONE: [phone]
REQUEST:
Please provide any and all information about the voluntary reduction in force provided to each
regulatory jurisdiction.
RESPONSE:
Please see Avista's response 025C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and exempt from public view and is separately filed under
IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
Please see Staff PR 025C Confidential Attachment A.
Do to the voluminous nature of the files they are being provided in electronic form only.