20190703Staff 36-62 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 l4
IDAHO BAR NO. 10446
REC E IVED
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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.19.O4
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attorney General, request that Avista Corporation (Company) provide
the following documents and information as soon as possible, or by WEDNESDAY,
JULY 24,2019.
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
3t.01.0r.228.
SECOND PRODUCTION REQUEST
TO AVISTA
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I JULY 3,2019
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. 36: Please provide a copy of Avista's Policy on Travel for employees
and executives.
REQUEST NO. 37: Please provide actual uncollectible amounts for 2019 to date.
REQUEST NO. 38: Regarding the Company's response to Production Request No. 12,
please provide copies of invoices, settlement agreements, insurance payments, vendor payments
for the following invoice numbers:
a. L-871640R
b. L-871640RA
c. L-743569R
d. L-890699R
REQUEST NO.39: In Andrews workpapers, SIT Expense Folder, 1) ID SIT for 2018,
Row 36, there is a note stating a company error of recording ITCs using old method (flow-
through). Please explain what processes have been added to ensure proper recording for 2019
and future years.
REQUEST NO. 40: In Adjustment 2.08 - Miscellaneous Restating, workpaper 2018 -
Plane Reclass - ID, Transaction detail tab, please provide additional information to show the
purpose of the following flights and justification for inclusion in Idaho rates:
a. New York Rating Agency Meetings - $114,290
b. ERM Workshop WUTC Open Meeting -I-937 RPS and Conversation - $15,290
REQUEST NO. 41: Per Andrews Direct Testimony, Page 26,Line 13-18, please
provide the confidential third party salary surveys used to determine salary increases and salary
range updates.
SECOND PRODUCTION REQUEST
TO AVISTA JULY 3,20192
REQUEST NO. 42: Please provide additional descriptions of the internal factors used to
determine Executive Labor adjustments. Also, please provide the Compensation Committee
minutes showing approval for the level of executive officer base salary effective March 2019.
REQUEST NO. 43: Company witness Andrews mentions a comprehensive benefit
evaluation study, BENEVAL, on page 29 of her testimony. Please provide a copy of this study
REQUEST NO. 44: In response to Andrews workpaper labeled 3.06 PF - IS IT
Adjustment, Tab ISIT - 2 - Non-Labor, please provide a detailed list that makes up Column e
and f, rows 7 through 12 for 201 8 and 2019. Please include the following for each item in the
lists:
a. Original cost;
b. Date put in use;
c. Location (pending request to see items when onsite);
d. Depreciation life;
e. Depreciation rate;
f. RFP or PO if required;
g. Additional fees on top of original cost;
h. Item/product replaced or retired; and
i. Expected cost benefit provided to customers.
REQUEST NO. 45: Regarding Kensok Direct Testimony, Page 8-9, please identify the
number of cyberattacks Avista's system has experienced in each year for 2016,2017 ,201 8, and
2019 to date.
REQUEST NO. 46: Regarding Kensok Direct Testimony, Page 14, please provide the
expected completion date, project completion percentage, cost to date, remaining costs to incur,
and the expected total cost of the fiber network lease service replacement program.
REQUEST NO. 47: Regarding the "Financial & Accounting Technology" business case
(Kensok Direct Testimony, Page 15), please provide a detailed list of all accounting, financial,
SECOND PRODUCTION REQUEST
TO AVISTA J JULY 3,2019
and human resource computer applications that are currently being used, and a list of other
applications needed. Of the applications currently being used, please provide when they were
last updated and expected to be replaced or retired.
REQUEST NO. 48: Please provide the specific dollar amounts incurred in 2018 and
2019 to date on the mobile application referenced in Kensock Direct Testimony, Page 19.
REQUEST NO. 49: Regarding the Request above, when are the upgrades to the mobile
application expected to be released?
REQUEST NO. 50: Regarding Kensok Direct Testimony, Page 19, please provide the
cost savings to Idaho customers by implementing the payment card industry compliance (PC|
business case.
REQUEST NO. 5l: Please provide a list of transactions that are charged to the
following Expenditure Types. In responding to this request, please identify all transactions that
have been removed from the Company's revenue requirement in its Miscellaneous Restatement
Adjustment or by any other adjustment.
a. 557170 - Broker Fees - Power
b. 588000 - Misc Expenses
c. 909000 - Info and Instruct Advert Exp
d. 910000 - Cust Svc & Info Exp-MISC
e. 930000 - Education - Informational
f. 930200 - Misc General Expense
g. 928000 - Regulatory Fees
REQUEST NO. 52: Regarding the Company's response to Production Request No. 3,
please provide copies of the following invoices:
a. AY-2:4,795.22
b. I18034:$1,041.15
c. 104844: $3,349.50
SECOND PRODUCTION REQUEST
TO AVISTA 4 JULY 3,2019
d. 40831 53 : $36,365.29
e. 4084910: $26,338.87
f. wwNovEMBER2Ol8 : $18,550.00
g. 110934: $10,805.00
h. 225536: $16,177.50
REQUEST NO. 53: Regarding the Company's response to Production Request No. 4,
please provide copies of invoices, contracts, workpapers for Rating Agencies - Moody amount
of $110,000.
REQUEST NO. 54: Regarding the Company's response to Production Request No. 20,
please provide reports for the following:
a. 2017 FiServ Data Conversion Review
b. 2017 FiServ Implementation Review
c. 2018 Deloitte Breach Risk Assessment Audit
d. 2018 Fraud Monitoring Analytics
e. 2018 Mobile Payment Review
f. 2019 Advanced Metering Infrastructure (AMI) Prudence Review
g. Local 77 90110 Healthcare Premium True-Up Review
REQUEST NO. 55: Regarding the Company's response to Production Request No. 23,
please provide copies of lease agreements and journal entries for the following leases:
a. Mt. Riverbed, Noxon, Mt - Land lease for Generation Facilities
b. West Twin, Moscow, ID - Communication Site
REQUEST NO. 56: Regarding the Company's response to Production Request No. 24,
please provide copies of invoices, agreements/contracts, and journal entries for the following
prepaids:
a. EIM #35043
b. ErM#35227
c. McGriff #095053
SECOND PRODUCTION REQUEST
TO AVISTA JULY 3,20195
REQUEST NO.57: In Company witness Rosentrater's Direct Testimony,Page25,
there is a capital project for building a Company owned hangar on leased land at Spokane
International Airport. Please provide all analysis and documentary evidence that supports this
solution over the other four options that were considered.
REQUEST NO.58: In Company witness Rosentrater's Direct Testimony, Pages 15 and
2l,there are two capital projects for Storms. Please provide all supporting documentation used
to determine the budgeted amounts. Please also include in your response the historical amounts
spent on Storm damages for the previous five years and the accounts to which they were booked.
REQUEST NO. 59: Pages 4 and 5 of Ms. Knox's Direct Testimony describe the l0-year
regression analysis used to normalize electric consumption for weather effects. Please provide,
in electronic format, the predictor (CDD, HDD and Trend) and consumption data for the date
range January 2007, through December 2016. Please provide, in electronic format, workpapers
showing how the regression analysis was performed, and how the resulting sensitivity factors
were applied to each rate class'consumption.
REQUEST NO. 60: Please provide, in electronic format with links enabled, the data
and calculations used to calculate the 30-year rolling average of heating and cooling degree days
described on page 5 of Ms. Knox's Direct Testimony.
REQUEST NO. 6l: Please provide workpapers in electronic format with links enabled,
for the Electric Cost of Service studies described on pages 8 through l7 of Ms. Knox's Direct
Testimony, and presented in Schedules 2 through 5 of Exhibit I l.
REQUEST NO. 62: In its 2015,2016, and2017 electric rate cases (AVU-E-15-05,
AVU-E-16-03, and AVU-E-I7-01), the Company based its Cost of Service allocators on a Load
Research Study performed by DNV-GL (dated January 22,2015). Were the Cost of Service
allocators for the present case based on the same study? If not, please provide the information
used as a basis for the allocators in the present case.
SECOND PRODUCTION REQUEST
TO AVISTA 6 JULY 3,2019
j.)Dated at Boise, Idaho, this day of July 2019
Edward
Deputy
i:umisc:prodreq/avue l9.4ejde prod req2
SECOND PRODUCTION REQUEST
TO AVISTA
General
7 JULY 3,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF JULY 2019, SERVED
THE FOREGOING SECOND 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 BOX 3727
SPOKANE W A 99220-3727
E-MAIL: patrick.elrrbar(davistacorp,qogt
a vi stad o ckets (l=ljavi stac orp. c o rn
DAVID J MEYER
VP & CHIEF COLINSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAI L : cla vid. mc.v"er(g;)avi stacorp. corn
S Y
CERTIFICATE OF SERVICE