062820041st Request of Avista to Staff.pdf

DAVID J. MEYER, Esq.
, CHIEF COUNSEL
for REGULATORY AND GOVERNMENTAL AFFAIRS
VISTA COROPRA TION
O. BOX 3727
1411 E. MISSION AVE., MSC-
SPOKANE, W A 99220-3727
david.meyer~avistacorp .com
Attorney for A vista Utilities
[phone]
[phone] (FAX)
F~ECEIVEO illlLED
208'1 JUr~2e AH ~:2'
to i" UbL Ie
UTILrrlES COHrl15S10N
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. A VU-04-
A VU-04-
FIRST PRODUCTION
REQUEST OF A VISTA
CORPORATION
TO IPUC STAFF
A vista Corporation (A vista, Company), by and through its attorney of record, David 1.
Meyer, VP, Chief Counsel for Regulatory and Governmental Affairs, requests that IPUC Staff
(Staff) provide the following documents and information on or before July 6th, 2004.
This Production Request is to be considered as continuing in nature and Staff is requested to
provide, by way of supplementary responses, additional documents that it or any person acting on
its behalf may later obtain or become aware of that will augment the documents produced.
In answering each request, please provide the name of the person(s) preparing the answer
along with the title and function such individual holds with your organization and the witness who
can sponsor the answer at the hearing.
For the following responses, please provide all workpapers, diskettes (3.5 in.), CDs and all
underlying formulas intact in Excel 2000 compatible language.
FIRST PRODUCTION REQUEST OF
VISTA TO IPUC STAFF Page 1
Request No.1: Please provide all supporting documentation for the statement "There has been
growing concern among accounting professionals regarding the use of F AS 87 and the potential for
manipulation of financial statements." Please also include all information you have regarding the
Financial Accounting Standards Board review of this item on any current or future agendas.
(English, D. (Di) page 6, line 7-12)
Request No.2: Please provide a complete copy of the source documents for the 3.5 - 3.
percent dividend yield cited on page 12, In. 11 of Ms. Carlock's testimony.
Request No.3: Please provide a copy of the analysis of historical and projected growth
indicators, including copies of all source documents, cited on p. 13, Ins. 4-9 of Ms. Carlock'
testimony.
Request No.4: Please provide a copy of the analysis of historical and projected growth
indicators, including copies of all source documents, cited on p. 13 , Ins. 4-9 of Ms. Carlock'
testimony.
Request No.5: Please provide a copy of all source documents and calculations used to
determine the 4.36 percent dividend yield and 5% growth rate cited on p. 12, Ins. 16-18 of Ms.
Carlock's testimony.
Request No.6: Please provide a copy of all materials, other than those already provided in
response to Question No., that Ms. Carlock relied on in determining the 6% - 6.5% growth rate
range cited on p. 13 , In. 4 of her testimony.
Request No.7: Please provide copies of all underlying analyses, including copies of all source
documents supporting the 10.0% - 11.0% cost of equity under Ms. Carlock's comparable earnings
approach, as cited on p. 9 , Ins. 1-4 of her testimony.
Request No.8: With respect to the 10.0% - 11.0% cost of equity under Ms. Carlock'
comparable earnings approach cited on p. 9, Ins. 1-, please describe the basis for the earned
returns that Ms. Carlock used to determine this range, including 1) the time period( s) examined
and 2) a list of all firms and/or industries that formed the basis of her calculations.
FIRST PRODUCTION REQUEST OF
AVISTA TO IPUC STAFF Page 2
Request No.9: Please provide copies of all analyses and documents prepared and/or relied on
by Ms. Carlock in the "review of the market data and comparables, average risk characteristics for
Avista" cited on p. 14, Ins. 22-23.
Dated at Spokane, Washington, this 25th day of June, 2004.
~!/
, Chief Counsel for Regulatory
and Governmental Affairs
A vista Corporation
FIRST PRODUCTION REQUEST OF
AVISTA TO IPUC STAFF Page 3