20080515Staff to Avista 1-28.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
15 Pf1 lq: 44
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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
)
) CASE NO. A VU-E-08-1) A VU-G-08-1
)
) FIRST PRODUCTION REQUEST
) OF THE COMMISSION STAFF
) TO A VISTA CORPORATION
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, requests that Avista Corporation (Company; Avista)
provide the following documents and information on or before Friday, June 6, 2008. Please
provide access to as much of this information as possible for the Staff audit on May 19-23,
2008.
FIRST PRODUCTION REQUEST
TO A VISTA CORPORATION 1 MAY 15,2008
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparng 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 ID AP A 31.01.01.228.
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparng the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.1: Please provide a copy of all data requests received and the
corresponding responses associated with the Company's curent general rate case docket before
the Washington Utilties and Transportation Commission.
REQUEST NO.2: Please provide copies of the monthly trial balances from Januar
2004 through the most current month available. Please provide the monthly trial balances for
2008 through April and for each month in 2008 as they become available.
REQUEST NO.3: Please provide a copy of the Company Char of Accounts.
REQUEST NO.4: Please provide all documentation related to the proceeds,
underwiter commissions and other expenses associated with any or all debt securities issued
during the years 2003-2008.
REQUEST NO.5: Please provide any or all underwiting documentation, including
competitive bids from investment bans or broker-dealers associated with any or all Company
debt or equity issuaces occuring during 2003 through 2008.
FIRST PRODUCTION REQUEST
TO A VISTA CORPORATION 2 MAY 15,2008
REQUEST NO.6: Please provide a detailed list with explanation of all cost-cutting
measures undertaken by the Company during 2005-2008. Please also provide the quatifiable
results of those measures.
REQUEST NO.7: Please provide a list of all expense reports for sales and management
personnel for 2007.
REQUEST NO.8: Please provide a list showing a summar of all other consultants and
attorneys (internal and external) who pedormed services for A vista or who were paid by A vista
for 2007. For all attorneys, show services performed, amounts paid, and accounts charged. If
services were performed in support of a docketed federal/state court or regulatory agency action,
please identify the case name, case number and jurisdiction.
REQUEST NO.9: Please provide the total amounts spent on the following activities
during 2007 and show how the amounts were allocated between A vista Utilties and A vista Corp
and its subsidiaries:
a. Internal auditing expenses (by employees and consultats);
b. Avista's anual report;
c. Deloitte & Touche and Deloitte Consulting;
d. Rating agencies;
e. All software or information system-related items;
f. Board of Directors compensation, travel expenses, meeting expenses;
g. Corporate or charered aircraft;
h. Travel and training for all shared executives of A vista Utilties and affiliates;
1. Insurance coverage;
J. Overhead items including utilities, propert taes, security services, and other
corporate headquarers expenses, and
k. All other allocated expenses.
FIRST PRODUCTION REQUEST
TO A VISTA CORPORATION 3 MAY 15,2008
REQUEST NO. 10: Provide a copy of all regulatory orders relating to Avista Utilities
or A vista Corp and its subsidiaries issued by state agencies in Oregon, Washington and the
Federal Energy Regulatory Commission (FERC) since 2005.
REQUEST NO. 11: Provide a sumar of all environmental cleanup costs for the years
2003-2007. Please show all account numbers and the amount booked to each sub account.
REQUEST NO. 12: Please provide copies of all employee newsletters issued since
2004.
REQUEST NO. 13: Please provide a matrix identifying the major capital expenditue
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 individual capital
expenditure projects require approval by the Board of Directors or highest threshold of approval.
REQUEST NO. 14: Please provide an analysis of the sale ofland and plant for the years
2005,2006,2007 and 2008 to date. Please show gains, losses and supporting documentation
including accounting entries for removal of items from rate base.
REQUEST NO. 15: Please provide details of any planed sales of land and/or plant for
the remainder of2008. Please include within your response the estimated date of these sales and
planed treatment (including accounting entries) of them.
REQUEST NO. 16: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years 2005 through 2008 to date.
REQUEST NO. 17: Please provide the amounts spent for injuries and damages for the
years 2005 to date. Please include within your response the description of each item, the amount
for each item and the account charged.
FIRST PRODUCTION REQUEST
TO A VISTA CORPORATION 4 MAY 15,2008
REQUEST NO. 18: Please provide detail of all advertising expenses recorded above the
line including account and subaccount where posted, dates posted, vendor names, explanations,
and amounts posted during 2007.
REQUEST NO. 19: Please provide copies of the ads used during 2007 and correlate the
ad copy with the specific detail provided in the preceding production request response.
REQUEST NO. 20: Please provide copies of all billng inserts for 2007. Indicate the
states where they were sent. Please provide a schedule showing the amount and account
numbers charged for all costs to produce, print, and distribute inserts.
REQUEST NO. 21: Please provide a copy of the cost!enefit analysis or similar
analysis study performed for each capital project of more than $3 milion that has been rate based
since the last general rate case. Please exclude from this request plant that was reviewed in Case
No. AVU-E-05-1 (Coyote Springs 2 - Costs and Rates).
REQUEST NO. 22: Please provide any and all documents used by the Company to
demonstrate the benefits realized by the Company for each capital project of more than $3
milion that has been rate based since the last general rate case.
REQUEST NO. 23: Please provide copies of the narative monthly, quarerly and
anual comparson of operating and capital budget to actual expenditures for 2005 to date.
Please include within your response any narative explanations for budget variations. This
should include, but not be limited to, written operating and capital budget variance reports and
explanations used by Company offcers and managers to monitor and control budgets under their
areas of responsibilty.
REQUEST NO. 24: Please provide a copy of each adjusting joural entry proposed by
the Company's independent auditors in their two (2) most recent audits of the Company. Please
include within your response the documentation supporting these adjustments and documentation
FIRST PRODUCTION REQUEST
TO A VISTA CORPORATION 5 MAY 15,2008
supporting any items that were "passed upon" and not reflected in the Company's financial
records and/or financial statements.
REQUEST NO. 25: Please provide a list of all leased items in 2007 and to date in 2008.
Please separate capital leases from operating leases and show the dates, terms, amounts and
accounts used for each lease.
REQUEST NO. 26: Please provide a schedule of prepaid items for 2007 showing
amounts posted, vendor names, explanations and accounts posted. Please include within your
response any significant changes to prepaid items (by account) occurring in, or planed for 2008.
REQUEST NO. 27: For each officer of the Company, please provide the total dollar
amount of remuneration for 2007, 2008 and 2009 amount included in the rate case with the
amounts separated by year, salary, incentive pay, options, benefits and other. For each officer,
please also provide the percentages of his or her total remuneration that is allocated to other
subsidiaries along with the basis for that allocation.
REQUEST NO. 28: Please prepare a schedule for plant in service that includes, by
project name and description, the dollar amount of each project closed to plant in service in
excess of $3 milion from 2005 to 2008.
7Å
DATED at Boise, Idaho, this /5 day of May 2008.
Scott Woodbur
Deputy Attorney General
Technical Staff: Donn English
Patricia Hars
Kathy Stockton
i:umisc:prodreq/avue--8. i swks prod req i
FIRST PRODUCTION REQUEST
TO A VIST A CORPORATION 6 MAY 15,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF MAY 2008, SERVED
THE FOREGOING FIT PRODUCTON REQUEST OF TH COMMSSION STAF
TO AVISTA CORPORATION, IN CASE NOS. AVU-E-08-01 & AVU-G-08-01, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220
E-MAIL: david.meyer(ßavistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
601 W BANNOCK ST (83702)
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(ßgivenspursley.com
BRAD M. PURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE,ID 83702
E-MAIL: bmpurdy(ßhotmail.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwood(ßavistacorp.com
DENNIS E. PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY STREET SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(ßexcite.com
~~SECRETAR ~
CERTIFICATE OF SERVICE