20160608Staff 1-35 to AVU.pdf

BRANDON KARPEN l:: c'f. trrrre n
DEPUTY ATTORNEY GENERAL + V T- I 'J I-U
IDAHO PUBLIC UTILITIES COMMISSION iLrl6 _ili:i _g pi{ 2: 32PO BOX 83720
BOISE,IDAHO 83720-0074 :, , r.';jlrc(208)334-03s7 i I :0t{:"'i5Stoll
IDAHO BAR NO. 7956
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE, THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVISTA CORPORATTON DBA AVTSTA ) CASE NO. AVU-E-I6-03
UTILITIES FOR AUTHORITY TO INCREASE )
ITS RATES AND CHARGES FOR ELECTRIC ) FIRST PRODUCTION
SERVICE IN IDAHO. ) REQUEST OF THE
) COMMISSTON STAFF TO
) AVISTA CORPORATTON
)
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, and no later than
WEDNESDAY, JUNE 29, 2016.
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 and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0r.0t.228.
FIRST PRODUCTION REQUEST
TO AVISTA JLTNE 8,2016
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 copies of all data requests received and the
corresponding responses associated with the Company's current general rate case docket before the
Washington Utilities and Transportation Commission.
REQUEST NO. 2: Please provide copies of the monthly trial balances from January 2014
through the most current month available. Please supplement your response when additional
months become available throughout 2016.
REQUEST NO.3: Please provide a copy of the Company Chart of Accounts.
REQUEST NO. 4: Please list all cost-cutting measures undertaken by the Company during
2014-2016. Explain those cost-cutting measures in detail, and quantify the results of those
measures.
REQUEST NO. 5: Please list all expense reports for management personnel for 2015.
REQUEST NO. 6: Please list all other consultants and external attorneys who performed
services for the Company or who were paid by the Company for services in 2015. For all attorneys,
show services performed, amounts paid, and accounts charged. If services were performed in
support ofa docketed federal/state court or regulatory agency action, please identify the case nrune,
case number, and jurisdiction.
REQUEST NO. 7: Please provide the total amount that the Company spent on the
following activities for 2015, 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;
FIRST PRODUCTION REQUEST
TO AVISTA JUNE 8,2016
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
headquarter expenses, and
k. All other allocated expenses.
REQUEST NO. 8: Please 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) in 2015 and20l6 to date.
REQUEST NO.9: Please summarize all of the Company's environmental cleanup costs
during 2015. Please show all account numbers and the amount booked to each sub account.
REQUEST NO. 10: Please provide copies of all employee newsletters issued in 2015 and
20t6.
REQUEST NO. 11: Please provide a matrix identifring 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
expenditures require approval by the Board of Directors or highest threshold available.
REQUEST NO. 12: Please provide an analysis of the sale of land and plant for the years
2014 - 2016 to date. Please show gains, losses, and supporting documentation including accounting
entries for removal of items from rate base.
FIRST PRODUCTION REQUEST
TO AVISTA JUNE 8,2016
REQUEST NO. 13: Please provide details of any planned sales of land and/or plant for the
remainder of 2016 and20l7. Please include within your response the estimated date of these sales
and planned treatment (including accounting entries).
REQUEST NO. 14: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years 2014-2016 to date.
REQUEST NO. 15: Please provide a schedule showing injuries and damages for the years
2010-2016 to date. Please include within your response the description of each item, the amount for
each item, and the account charged.
REQUEST NO. 16: 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 2015.
REQUEST NO. 17: Please provide copies of the ads used during 2015 and correlate the ad
copy with the specific detail provided in the Company's response to Request No. 16.
REQUEST NO. 18: Please provide copies of all billing inserts for 2015. Indicate the states
where they were sent. Please also provide a schedule showing the amount and account numbers
charges for all costs to produce, print, and distribute inserts.
REQUEST NO. 19: Please prepare a schedule for plant in service that includes each
project name and description, and the dollar amount of each project closed to plant in service in
excess of $3 million from 2014-2016 to date.
REQUEST NO. 20: Please provide a copy of the cosVbenefit analysis, intemal rate of
retum, 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 4 JUNE 8,2016
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 that 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 - 2016 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 responsibility. Please
supplement your response as additional information becomes available throughout 2016.
REQUEST NO. 23: Please provide a copy of each adjusting journal entry proposed by the
Company's independent auditors in the two most recent audits of the Company. Please include
within your response the documentation supporting these adjustments, and the 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. 24: Please provide a list of all leased items in 2015 and 2016 to date.
Please separate capital leases from operating leases and show the dates, terms, amounts, and
accounts used for each lease.
REQUEST NO. 25: Please provide a schedule of prepaid items for 2015 showing amounts
posted, vendor names, 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 2016.
REQUEST NO. 26: For each officer of the Company, please provide the total dollar
amount of remuneration for 2012-2015, ard20l6 and20l7 amounts included in the rate case.
Please separate 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.
FIRST PRODUCTION REQUEST
TO AVISTA JUNE 8,2016
REQUEST NO.27: Please provide the following direct labor related information as
recorded for the twelve months ended December 3l,20ll-2015. 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 (officer, 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.28: Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years. Please provide any additional workforce reduction
programs planned for 2016-2017.
REQUEST NO. 29: 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. 30: Please provide the amount of Supplemental Executive Retirement
Plan expense, if any, that is included in the test year.
REQUEST NO. 31: Please provide copies of the Company's pension and actuarial reports
for the years 2010-2016. Also, please provide any actuarial calculations and documentation that
show the development of FAS 87 expense (ASC 715 Compensation - Retirement Benefits as
codifi ed), company contributions, balances and assumptions.
REQUEST NO.32: Please provide copies of the Board of Directors' Materials distributed
forlat meetings from20l4-2016 to date. Please also include the same for the Compensation
Committee.
FIRST PRODUCTION REQUEST
TO AVISTA JUNE 8,2016
REQUEST NO. 33: To the extent not previously included in Request No. 32, 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-
2016 to date.
REQUEST NO. 34: Please provide 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 in 2015 at the system level, the account(s) posted, and how those costs were allocated or
assigned to Idaho electric operations.
REQUEST NO. 35: Please describe the variable costs associated with the use of the
Company-owned aircraft, such as fuel. Please provide the dollar amount posted in 2015 at the
system level, the account(s) posted, and how those costs were allocated or assigned to Idaho electric
operations.
DATED at Boise, Idaho, this 8UU*of June 2016.
Technical Staff: Donn English (1-35)
i :umisc:prodreq/avue I 6.3bkdkmlmmrkyybejbmrde prod reql
FIRST PRODUCTION REQUEST
TO AVISTA JLINE 8,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8th DAY OF JI.INE 2016, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-16-03, 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]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail : [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
CERTIFICATE OF SERVICE