20190604Staff 1-35 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
RECEIVED
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Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney 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
SERVICE IN IDAHO.
CASE NO. AVU-E'.I9-04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Avista Corporation (Company) provide
the following documents and information as soon as possible, or by TUESDAY,
JUNE 25,2019.
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
31.01.01.228.
FIRST PRODUCTION REQUEST
TO AVISTA
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I JUNE 4,2019
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 the monthly trial balances from January
2017 through the most current month available. Please supplement your response when
additional months become available throughout 2019.
REQUEST NO.2: Please provide a copy of the Company Chart of Accounts.
REQUEST NO.3: Please provide a list of all external attorneys who performed services
for the Company or who were paid by the Company for services during 2017 and 2018. Please
list the amounts paid, accounts charged, and date of payment. Please also provide a brief
summary of the services performed. If services were performed in support of a docketed
federal/state court or regulatory action, please identify the case name, case number, and
jurisdiction. For each expense, please illustrate how the charge was allocated to the Company's
jurisdictions.
REQUEST NO. 4: Please provide the total amount that the Company spent on the
following activities for 2018, 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;
b. The Company's annual report;
c. Deloitte;
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
FIRST PRODUCTION REQUEST
TO AVISTA 2 JUNE 4,2019
k. All other allocated expenses
REQUEST NO. 5: Please provide a copy of all regulatory orders relating to Avista
Utilities or the Company and its subsidiaries issued by state agencies in Oregon, Washington,
Alaska, or the Federal Energy Regulatory Commission (FERC) in2017 through 2019 to date.
REQUEST NO. 6: Please summarize all of the Company's environmental cleanup costs
during 2017 and 2018. Please show all account numbers and the amount booked to each sub
account.
REQUEST NO. 7: Please provide access to all employee newsletters issued in 2018 and
2019.
REQUEST NO. 8: Please provide a matrix identifying 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 the individual capital
expenditures require approval by the Board of Directors.
REQUEST NO. : Please provide an analysis of any sales of land and/or plant for the
years 2017-2019 to date, if any. Please show gains, losses, and supporting documentation
including accounting entries for removal of items from rate base.
REQUEST NO. 10: Please provide details of any planned sales of land and/or plant for
the remainder of 2019 through 2020. Please include within your response the estimated date of
these sales and planned accounting treatment.
REQUEST NO. 11: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years 2017 -2019 to date.
FIRST PRODUCTION REQUEST
TO AVISTA J JUNE 4,2019
REQUEST NO. 12: Please provide a schedule showing injuries and damages claims
over $2,000 for the years 2016-2018. Please include within your response the description of
each item, the amount for each item, and the account charged.
REQUEST NO. 13. Please provide detail of all advertising expenses recorded above the
line including account and subaccounts where posted, dates posted, vendor nalnes, explanations,
and amounts posted during 2018.
REQUEST NO. 14: Please provide copies of all advertisements used during 2018 and
correlate the advertisement with the specific detail provided in the Company's response to
Request No. 13.
REQUEST NO. 15: Please provide copies of all billing inserts for 2018, and 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 the inserts.
REQUEST NO. 16: Please prepare a schedule for plant in service that includes project
name and description, and the dollar amount of each project closed to plant in service in excess
of $2 million from 2017-2019 to date.
REQUEST NO. 17: Please provide copies of the cost/benefit analysis, internal rates of
return, or similar analysis for each capital project included in the Company's response to Request
No. 16.
REQUEST NO. 18: Please provide all documents the Company used to demonstrate the
benefits realized by the Company for each capital project included in the Company's response to
Request No. 16.
REQUEST NO. 19: Please provide copies of the monthly, quarterly, and annual
comparison of operating and capital budget to actuals expenditures for 2016-2019 to date.
Please include within your response a narrative explanation for budget variations. This should
FIRST PRODUCTION REQUEST
TO AVISTA 4 JUNE 4,2019
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 2019.
REQUEST NO.20: Please provide copies of all Audit Reports issued by the
Company's internal auditors for all audits completed during 2011-2019 to date.
REQUEST NO.21: 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 not to adjust that are not reflected
in the Company's financial records andlor financial statements.
REQUEST NO. 22: Please provide access to the workpapers of the Company's
independent external auditors for 2017 and 2018.
REQUEST NO.23: Please provide a list of all leased items in 2017,2018, and 2019 to
date. Please separate capital leases from operating leases and show the dates, terms, amounts,
and accounts used for each lease.
REQUEST NO. 24: Please provide a schedule of prepaid items for 2018 and 2019 to
date 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
occurring, or planned to occur in2019 and2020.
REQUEST NO. 25: For each officer of the Company, please provide the total dollar
amount of remuneration for 2015-2018. Please separate by year, salary, incentive pay, options,
benefits, and other. For each officer, please provide the percentages ofhis or her total
remuneration that is allocated to other subsidiaries each year along with the basis for that
allocation.
FIRST PRODUCTION REQUEST
TO AVISTA 5 JLINE 4,2019
REQUEST NO. 26: Please provide the following direct labor related information as
recorded for the twelve months ended December 31,2016-2018. 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. 27: 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 2018-2019.
REQUEST NO. 28: Please summarize all benefit and retirement plans provided to any
classif,rcation of Company employees. Please also include any changes that have occurred to the
benefits/accruals during the past five years.
REQUEST NO. 29: Please provide the amount of Supplemental Executive Retirement
Plan expense, if any, which is included in the test year.
REQUEST NO.30: Please provide copies of the Company's pension and actuarial
reports for the years 2016-2018- Also, please provide any actuarial calculations and
documentation that shows the development of FAS 87 expenses (ASC 71 5 Compensation -
Retirement Benefits as codified), Company contributions, balances, and assumptions.
REQUEST NO. 31: Please provide access to the Board of Directors' meeting minutes
for each meeting in2017-2019 to date.
FIRST PRODUCTION REQUEST
TO AVISTA 6 JI.INE 4,2019
REQUEST NO.32: Please provide copies of the Board of Directors' materials
distributed forlat meetings from2017-2019 to date. Please also include the same for the
Compensation Committee.
REQUEST NO. 33: To the extent not previously included in the Company's response to
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 2017-2019 to date.
REQUEST NO. 34: Please provide the fixed costs associated with the use of the
Company-owned airuaft, such as pilot salaries, hangar fees, etc. Please provide the total dollar
amount posted each year for 2016-2018 at the system level, the account(s) posted, and how those
costs were allocated or assigned to the Idaho electric and gas operations.
REQUEST NO.35: Please provide the variable costs associated with the use of the
Company-owned aircraft. Please provide dollar amount posted in each year 2016-2018, at the
system level, the account(s) posted, and how those costs were allocated or assigned to the Idaho
electric and gas operations.
t4PDated at Boise, Idaho, this day ofJune 2019.
Edward
Deputy
Technical Staff: Donn English (l-35)
i:umisc:prodreq/avuel 9.4ejde prod req I
FTRST PRODUCTION REQUEST
TO AVISTA 7 JUNE 4,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF JL]NE 2019, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-19-04, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL : patrick.chrbar(ilavistacorrc.com
avi stadockets (?.)avi stac orp. co m
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPoKANE W A 99220-3727
E-MAIL : david.meyer(Oavistaccirp.corn
Y
CERTIFICATE OF SERVICE