20210211Staff 1-34 to Avista.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR ELECTRIC AND NATURAL
GAS SERVICE TO ELECTRIC AND NATURAL
GAS CUSTOMERS IN THE STATE OF IDAHO.
Street Address for Express Mail:
1 I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE,ID 837I4
Attorneys for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU-E.2l-OI
AVU-G-21-01
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,
John R. Hammond, Jr., Deputy Attorney General, requests that Avista Corporation dba Avista
Utilities ("Avista" or the "Company") provide the following documents and information as soon
as possible, or by THURSDAY, MARCH 4,2021.
This Production Request is continuing, and Avista 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 ar€,
the source of information used in calculations. Avista 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 CORPORATION
FEBRUARY II,2O2I
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 Jantary 2019
through the most current month available. Please supplement your response when additional
months become available throughout 2021.
REQUEST NO. 2: Please provide a copy of the Company Chart of Accounts
REQUEST NO. 3: Please provide a list of all external attomeys who performed services
for the Company or who were paid by the Company for services during 2019 and2020. 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 identiff 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 2019 and2020, and show how the Company allocated the amounts
between the 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 & 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 headquarter expenses; and
k. All other allocated expenses.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY II,2O2I2
R-EQUEST 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 in 2019 through 2021to date.
REQUEST NO. 6: Please summarize all of the Company's environmental cleanup costs
during 2019 and2020. Please show all account numbers and the amount booked to each
subaccount.
REQUEST NO. 7: Please provide access to all employee newsletters issued in 2019 and
2020
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 Company's Board of Directors ("Board of Directors").
REQUEST NO. 9: Please provide an analysis of any sales of land and/or plant for the
years 2019 through 2021to 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 2021through 2022. 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
'oextraordinary items" for the years 2079 through 2021 to date.
REQUEST NO. 12: Please provide a schedule showing injuries and damages claims over
$1,000 for the years 2019 through 2021. Please include within your response the description of
each item, the amount for each item, and the account charged.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY I1,2O2IJ
REQUEST NO. 13: 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 2019 and2020.
REQUEST NO. 14: Please provide copies of all advertisements used during 2019 and
2020 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 for2019 and2020. Please
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.
RE,QUEST 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 2019 through 2021to date.
REQUEST NO. 17: Please provide copies of the cost/benefit analysis, internal rates of
retum, 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 2018 through202l to date.
Please include within your response a 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 2021.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY 11,20214
REQUEST NO. 20: Please provide copies of all Audit Reports issued by the Company's
intemal auditors for all audits completed during 2019 through2}2l to date.
REQUEST NO. 21: Please provide a copy of each adjusting joumal 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 and/or financial statements.
REQUEST NO. 22: Please provide a list of all leased items from 2019 through 2021to
date. Please separate capital leases from operating leases and show the dates, terms, amounts, and
accounts used for each lease.
REQUEST NO. 23: Please provide a schedule of prepaid items for 2019 through 2021 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 in202l and2022.
REQUEST NO.24: For each officer of the Company, please provide the total dollar
amount of remuneration for 2018 through2}2l. 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 is allocated to other subsidiaries each year along with the basis for that
allocation.
REQUEST NO. 25: Please provide the following direct labor related information as
recorded for the twelve months ended December 31,2078 through 2020. 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
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY 71,20215
(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. 26: 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 2021through 2022.
REQUEST NO.27: 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.28: Please provide the amount of Supplemental Executive Retirement
Plan expense, if any, which is included in the test year.
REQUEST NO. 29: Please provide copies of the Company's pension and actuarial
reports for the years 2018 through 2020. Also, please provide any actuarial calculations and
documentation that shows the development of FAS 87 expenses (ASC 715 Compensation -
Retirement Benefits as codified), Company contributions, balances, and assumptions.
REQUEST NO.30: Please provide access to the Board of Directors' meeting minutes for
each meeting in 2019 through 2021to date.
REQUEST NO.31: Please provide copies of the Board of Directors' materials
distributed forlat meetings from 2019 through 2021 to date. Please also include the same for the
Compensation Committee.
REQUEST NO. 32: To the extent not previously included in the Company's response to
Request No. 3 l, please provide access to copies of all studies used to determine employee
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
6 FEBRUARY II,2O21
compensation, including executive compensation, and explanations of how the Company applied
them in the years 2018 through2}2l to date.
REQUEST NO.33: Please provide the fixed costs associated with the use of the
Company-owned aircraft, such as pilot salaries, hangar fees, etc. Please provide the total dollar
amount posted in2019 and 2020 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.34: Please provide the variable costs associated with the use of the
Company-owned aircraft. Please provide dollar amount posted in 2019, 2020 and 2021 ro date, at
the system level, the account(s) posted, and how those costs were allocated or assigned to the
Idaho electric and gas operations.
Dated at Boise, Idaho, this ltuauv of February 2021.
Hammond
Attorney General
i :umisc/prod req/avue2 L l_avug2 l. ljhbl prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
7 FEBRUARY II,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS llTH DAY oF FEBRUARY 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THECOMMISSION sTAx'F TO AVISTA CORPORATION, IN CASE NoS.
AVU-E-21-01/AVU-G-21-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail : [e-mail]
avi [e-mail]
DAVID J MEYER
VP & CHIEF COLINSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE