200403123rd Request of Staff to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF A VISTA 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.
CASE NOS. AVU-04-
A VU-04-
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that Avista Corporation (Avista; Company)
provide the following documents and information on or before MONDAY, MARCH 22, 2004.
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. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and A vista 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.
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MARCH 12 2004
For each item, please indicate the name of the person(s) preparing the answers, along with the
job title of such person(s) and the witness who can sponsor the answer at hearing. For all responses
to the following requests, please provide all workpapers, diskettes (3.5 in.), CDs and all
underlying formulas intact in Excel 2000 compatible language.
STAFF PRODUCTION REQUEST NOS. 149 - 157 PERTAIN TO ACCOUNTING ISSUES
Request No. 149: Please provide the following direct labor related information as recorded
for the twelve months ended December 31 , 2001 , 2002, and 2003. Information, where applicable
should be listed by O&M expense, other expense, construction and other account groups (list by
functional account categories, i.e. production, 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.
a. Wages and salaries for each employee category (officers, exempt, nonexempt and union).
Include paid time-off and exclude overtime, bonuses, incentive pay, and overheads for
pensions, benefits and payroll taxes.
b. Average and year-end number of employees by employee category. Include part-time and
temporary employees as full-time equivalents.
c. Overtime costs by employee category.
d. Bonus and incentive pay for each employee category.
Request No. 150: Have there been any cost/workforce reduction programs during the past 5
years (1999-2004)? Are any planned for 2004 and 2005? If yes, please provide details including
amounts, number and salary levels ofFTEs affected.
Request No. 151: Please provide all consulting or administrative services invoices for any
retirement plan offered to Avista employees for the years 2001-2003.
Request No. 152: Please provide summaries of all benefit and retirement plans provided to
any classification of Avista employees to the extent not previously provided in Company response to
Audit Request No. 31.
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MARCH 12 2004
Request No. 153: Please provide the amount of Supplemental Executive Retirement Plan
expense that is included in the test year.
Request No. 154: Are there anyone-time charges, out-of-period charges, adjustments or
accounting changes that impact 2002 test year revenues, operating expenses, other taxes and/or
current and deferred income taxes? Include any costs in the test year that are expected to either be
substantially less or discontinued in future years. Please provide detailed descriptions and
documentation including FERC accounts and amounts.
Request No. 155: Please provide copies of Avista s pension and actuarial reports for the
years 1999-2002, and 2004 when available. Also, provide any actuarial calculations and
documentation that show the development ofFAS 87 expense estimates, company contributions
balances and assumptions for 2003 through 2011.
Request No. 156: Please provide the allocation percentages for labor for O&M, Construction
and Other for the years 2001 , 2002, and 2003. Provide a workpaper that shows the development of
these factors.
Request No. 157: Please provide copies of Board of Directors ' Materials distributed for/at
meetings from 2001 , 2002, 2003, and 2004. Include the 2001 Strategic Plan Board Summary and
any similar summaries since 2001.
STAFF PRODUCTION REQUEST NOS. 158 - 170 PERTAIN TO CONSUMER ISSUES
Request No. 158: Please provide Avista s protocol for allocating a partial payment in a
situation where a customer is billed for both gas and electric monthly service on the same bill and
remits a payment less than what is billed. For example, how would the Company allocate a payment
if a customer sent a $75 payment but was billed $100 for electric service and $50 for gas service for
the month?
Request No. 159: If a customer is billed for both gas and electric service and is disconnected
for nonpayment, does the Company disconnect both gas and electric service?
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 12, 2004
Request No. 160: Please provide a sample copy of a regularly issued monthly bill that has
both gas and electric charges included on the statement.
Request No. 161: Please provide sample copies of deposit billings that include the following
types of deposits: for gas customers, electric customers, and combination gas and electric customers.
Request No. 162: Please provide a sample copy of a delinquent notice that would be sent to
a customer who was late paying his or her deposit.
Request No. 163: Please provide the number of deposits currently held by Avista for
residential customers. Please include this information for gas, electric and combination customers by
individual service type. What is the average amount of the deposits?
Request No. 164: How are deposits calculated for gas and electric residential customers?
a customer has both gas and electric service and requires a deposit for both, how is that deposit
calculated?
Request No. 165: Please provide a copy of the Customer Satisfaction Survey mentioned in
Company witness Morris' Direct Testimony, page 21 , line 21.
Request No. 166: At what time of day does the Company start charging an after hours
service establishment charge for customers requesting establishment of service? Is the time
determined by when the customer makes his or her request, or when the Company s employee
physically connects service? If a residential customer called at 4:55pm for a connection of service
for that same day and a physical connection of the meter was required, would the customer be
charged an after hours service establishment charge?
Request No. 167: Regarding Avista s E-bill option, does Avista administer the program
internally using its own employees or is a third-party vendor used? If a third party vendor is used
please provide the name of the vendor. If a third-party vendor is used, what is the per-bill fee
charged to Avista by the vendor to handle the E-bill program?
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 12 2004
Request No. 168: Regarding Avista s E-billing, how many customers need to signup for E-
billing to reach the break-even point wherein the savings from not mailing bills equals the cost of
offering E-billing? How many Idaho customers are now signed up for E-billing?
Request No. 169: For each of the past 4 years, please provide the number of meter readers
employed by Avista? If other employees routinely read meters, please provide numbers for those
employees as well.
Request No. 170: Do meter readers perform any other duties aside from reading meters?
, what other duties do they perform?
STAFF PRODUCTION REQUEST NO. 171 PERTAINS TO THE COMPANY'S NATURAL
GAS OPERATIONS
Request No. 171: Please provide the full electronic version with formulas intact of the rate
case Commission Basis Report (Jurisdictional Separation Model) for the natural gas utility.
ST AFF PRODUCTION REQUEST NO. 172 PERTAINS TO THE COMPANY'S ELECTRIC
OPERATIONS
Request No. 172: Please provide the full electronic version with formulas intact ofthe rate
case Commission Basis Report (Jurisdictional Separation Model) for the electric utility.
Dated at Boise, Idaho, this (;). day of March 2004.
(~~a Sco Woodbury
~ ~
Deputy Attorney General
Technical Staff: Marilyn Parker
Patricia Harms
Kathy Stockton
Donn English
Michael Fuss
i:urnisc:prodreq/avueO4.- avugO4.1 swphrnpklsde3
THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 12 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF MARCH 2004
SERVED THE FOREGOING THIRD PRODUCTION REQUEST TO A VISTA
CORPORATION, IN CASE NO. A VU-04-l/A VU-04-, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J. MEYER
SR VP AND GENERAL COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail dmeyer~avistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220-3727
E-mail Kelly.norwood~avistacorp.com
E-mail don.falkner~avistacorp.com
E-mail cew~givenspursley.com
~~.
SECRETARY
CERTIFICATE OF SERVICE