20150707Staff 1-36 to AVU.pdf

KARL T. KLEIN .. ,I
BRANDONKARPEN :.,,r., i,,, _l rllll:llDEPUTY ATTORNEYS GENERAL L, U .*
IDAHO PUBLIC UTILITIES COMMISSION ,| ,, ,
,POBOX83720 ,t " "
BOISE, IDAHO 83720-0074
(208) 334-03201334-03 s7
IDAHO BAR NOS. 515617956
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVTSTA CORPORATION DBA AVTSTA ) CASE NO. AVU-E-15-05
UTILITIES FOR AUTHORITY TO INCREASE )
ITS RATES AND CHARGES FOR ELECTRIC )
AVU-G-15-01
AND NATURAL GAS SERVICE IN IDAHO. ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAF'F TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, by
TUESDAY, JULY 28,2015.
This Production Request is continuing, and the Company 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, 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 holder
FIRST PRODUCTION REQUEST
TO AVISTA JULY 7,2015
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0t.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. 1: Please provide a copy of all data requests received and the
corresponding responses associated with the Company's current general rate case docket before
the Washinglon Utilities and Transportation Commission.
REQUEST NO.2: Please provide copies of the monthly trial balances from January
2010 through the most current month available.
REQUEST NO.3: Please provide a copy of the Company Chart of Accounts.
REQUEST NO. 4: Please provide all documentation related to the proceeds,
underwriter commissions and other expenses associated with any or all debt securities issued
during the years 2010-2015.
REQUEST NO. 5: Please list all cost-cutting measures undertaken by the Company
during 2012-2015, explain those measures in detail, and quantifu the results of those measures.
REQUEST NO. 6: Please list all expense reports for sales and management personrrel
for 2014.
REQUEST NO. 7: Please list all other consultants and external attorneys who
performed services for the Company or who were paid by the Company for 2014. For all
attorneys, show services performed, amounts paid, and accounts charged. If services were
performed in support of a docketed federal/state court or regulatory agency action, please
identifu the case name, case number and jurisdiction.
FIRST PRODUCTION REQUEST
TO AVISTA JULY 7,2015
REQUEST NO. 8: Please provide the total amount that the Company spent on the
following activities for 2014, and show how the Company allocated the amounts between its
Avista Utilities operating division and the rest of the Company and its subsidiaries:
a. Internal auditing expenses (by employees and consultants);
b. The Company's annual report;
c. Deloitte & Touche and Deloitte Consulting;
d. Rating agencies;
e. All software or information system-related issues;
f. Board of Directors compensation, travel expenses, and meeting expenses;
g. Corporate or chartered aircraft;
h. Travel and training for all shared executives of Avista Utilities and affiliates;
i. Insurance coverage;
j. Overhead items including utilities, property taxes, security services, and other
corporate headquarters expenses, and
k. All other allocated expense.
REQUEST NO. 9: Provide a copy of all regulatory orders relating to Avista Utilities or
the Company and its subsidiaries issued by state agencies in Oregon and Washington and the
Federal Energy Regulatory Commission (FERC) since 2012.
REQUEST NO. 10: Please summarize all of the Company's environmental cleanup
costs for the years 2012-2014. Please show all account numbers and the amount booked to each
sub account.
REQUEST NO. 11: Please provide copies of all employee newsletters issued between
20t2-20t5.
REQUEST NO. 12: Please provide a matrix identiffing the major capital expenditure
approval levels that includes 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 available.
FIRST PRODUCTION REQUEST
TO AVISTA JULY 7,2015
REQUEST NO. 13: Please provide an analysis of the sale of land and plant for the years
2072,2013,2014, and 2015 to date. Please show gains, losses, and supporting documentation
including accounting entries for removal of items from rate base.
REQUEST NO. 14: Please provide details of any planned sales of land and/or plant for
the remainder of 2015 and2016. Please include within your response the estimated date of these
sales and planned treatment (including accounting entries) of them.
REQUEST NO. 15: Please provide a list of "out-of-period adjustments" and
o'extraordinary items" for the years2012 through 2015 to date.
REQUEST NO. 16: Please provide the amounts the Company spent for injuries and
damages for the years 2010 through 2015 to date. Please include within your response the
description of each item, the amount for each item and the account charged.
REQUEST NO. 17: Please provide detail of all advertising expenses recorded above the
line including account and subaccounts where posted, dates posted, vendor names, explanations,
and amounts posted during 2014.
REQUEST NO. 18: Please provide copies of the ads used during 2014 and correlate the
ad copy with the specific detail provided in the preceding advertising expense production request
response.
REQUEST NO. 19: Please provide copies of all billing inserts for 2014. Indicate the
states where they were sent. Please also provide a schedule showing the amount and account
numbers charged for all costs to produce, print, and distribute inserts.
REQUEST NO.20: Please provide a copy of the cost/benefit analysis or similar
analysis for each capital project costing more than $3 million that the Company has included in
its rate base since the last general rate case.
FIRST PRODUCTION REQUEST
TO AVISTA JULY 7,2015
REQUEST NO.21: Please provide all documents the Company used to demonstrate the
benefits realized by the Company for each capital project costing more than $3 million thal the
Company has included in its rate base since the last general rate case.
REQUEST NO.22: Please provide copies of the narrative monthly, quarterly, and
annual comparison of operating and capital budget to actual expenditures for 2014 through 2015
to date. Please include within your response any narrative explanation for budget variations.
This should include, but not be limited to, written operating and capital budget variance reports
and explanations used by Company officers and managers to monitor and control budgets under
their areas of responsibility.
REQUEST NO. 23: Please prepare a schedule for plant in service that includes each
project name and description, the dollar amount of each project closed to plant in service in
excess of $3 million from 2012-2015 to date.
REQUEST NO.24: Please provide a copy of each adjusting journal entry proposed by
the Company's independent auditors in their two (2) most recent audits of the Company. Please
include within your response the documentation supporting these adjustments, and
documentation supporting any items that the Company decided to not adjust that are not reflected
in the Company's financial records and/or financial statements.
REQUEST NO.25: Please list all leased items in20l4 and 2015 to date. Please
sepamte capital leases from operating leases and show the dates, terms, amounts, and accounts
used for each lease.
REQUEST NO.26: Please provide a schedule of prepaid items for 2014 showing
amounts posted, vendor nermes, explanations, and accounts to which these items were booked.
Please include within your response any significant changes to prepaid items (by account)
occurring, or planned to occur, in 2015.
FIRST PRODUCTION REQUEST
TO AVISTA JULY 7,2015
REQUEST NO. 27: For each officer of the Company, please provide the total dollar
amount of remuneration for 2012,2013,2014, and 201 5 amounts included in the rate case with
the amounts separated by year, salary, incentive pay, options, benefits, and other. For each
officer, please provide the percentages of his or her total remuneration that are allocated to other
subsidiaries along with the basis for that allocation.
REQUEST NO. 28: Please provide the following direct labor related information as
recorded for the twelve months ended December 31,2010,2011,2012,2013, and20l4.
Information, where applicable, should be listed by O&M expense, other expense, construction
and other account groups (listed by functional categories, i.e. generation, transmission,
distribution, customer, A&G, etc.). Please provide the information on a system-wide basis, and
on an Idaho electric and Idaho gas jurisdiction basis. The response should include wages and
salaries for each employee category (officers, exempt, non-exempt, and union), paid time-off,
overtime, bonuses, incentive pay, and overheads for pension, benefits, and payroll taxes. Please
also include average and year-end number of employees by employee category. Include part-
time and temporary employees as full-time equivalents.
REQUEST NO.29: Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years. Are any additional workforce reduction programs
planned for 2015-2016?
REQUEST NO.30: Please summarize all benefit and retirement plans provided to any
classification of Company employees. Please also include any changes that have occurred to the
benefits/accruals during the past five years.
REQUEST NO.31: Please provide the amount of Supplemental Executive Retirement
Plan expense, if any, that is included in the test year.
REQUEST NO.32: Please provide copies of the Company's pension and actuarial
reports for the years 2010-2015. Also, provide any actuarial calculations and documentation that
FIRST PRODUCTION REQUEST
TO AVISTA JULY 7,20T5
show the development of FAS 87 expense (ASC 715 Compensation - Retirement Benefits as
codified), company contributions, balances and assumptions.
REQUEST NO.33: Please provide copies of Board of Directors' Materials distributed
forlat meetings from 2010-2015 to date. Please also include the same for the Compensation
Committee.
REQUEST NO. 34: To the extent not previously included in Request No. 33, please
provide access to copies of all studies used to determine employee compensation, including
executive compensation, and explanations of how the Company applied them in the years
2010-2015 to date.
REQUEST NO.35: Please describe the fixed costs associated with the use of the
Company-owned aircraft, such as pilot salaries, hangar fees, etc. Please provide the dollar
amount posted in20l4 at the system level, the account(s) posted, how those costs were allocated
or assigned to Idaho gas and Idaho electric operations.
REQUEST NO. 36: Please describe the variable costs associated with the use of the
Company-owned aircraft, such as fuel. Please provide the dollar amount posted in20l4 at the
system level, the account(s) posted, how those costs were allocated or assigned to Idaho gas and
Idaho electric operations.
Dated at Boise, Idaho, this ./ /A day of July 2015.
/u'/ ,/_
Karl T. Klein
Deputy Attorney General
Technical Staff: Donn English
i:umisc:prodreq/avue I 5.S_avugl 5. I dhdjhde prod req I
FIRST PRODUCTION REQUEST
TO AVISTA JULY 7,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY oF JULY 2015, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVTSTA CORPORATTON, IN CASE NOS. AVU-E-15-05/AVU-G-15-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
KELLY NORWOOD
VP _ STATE & FED REG
AVISTA CORPORATION
PO BOX3727
SPoKANE W A 99220-3727
E-mail: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83702
E-mail : j [e-mail]
PETER J zuCHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail : oeter(Eri chardsonadams.com
[e-mail]
DAVID J MEYER
VP & CHIEF COI.]NSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-mail: [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES
INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 837I6
E-mail : [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: dreadine@.mindspring.com
CERTIFICATE OF SERVICE