20090331Staff 90-109 to AVU.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3366
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
i009 MAR 3\ AM \0: 29
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-09-1) A VU-G-09-1
)
) FIFTH 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,
Kristine A. Sasser, Deputy Attorney General, requests that A vista Corporation (Company; A vista)
provide the following documents and information on or before TUESDAY, APRIL 21, 2009.
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 wil augment the documents produced.
FIFTH PRODUCTION REQUEST TO A VISTA 1 MARCH 31, 2009
Please provide answers to each question, and 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
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 90: On Page 12-13 of his testimony, Mr. Defelice describes utilty
infrastructure cost increases that have occurred through October of 2008. Please provide any
analysis conducted by the Company showing how utility infrastructure costs have changed since
that time. Is it the Company's position that costs have continued to climb?
REQUEST NO. 91: Please provide a detailed listing of the Clark Fork PME measures
planned for 2009, describe what they are intended to accomplish and where they are identified as
required in the settlement agreement and FERC License.
REQUEST NO. 92: Please explain and justify the projects included in the $2.2 milion
transmission replacement program listed on page 18 of Mr. Defelice's direct testimony.
REQUEST NO. 93: Please describe and justify the distribution investment amounts
shown on page 18 of Mr. Defelice's direct testimony that are part of the distribution asset
management program.
REQUEST NO. 94: Please explain and justify the productivity initiative listed on page
20 of Mr. Defelice's testimony.
REQUEST NO. 95: Please describe how annual replacement projects for electric and gas
transmission are identified and budgeted. Include any economic analysis used by the Company to
prioritize projects.
FIFTH PRODUCTION REQUEST TO A VISTA 2 MARCH 31, 2009
REQUEST NO. 96: Please describe the Company's guidelines and justification for
replacement of $9.6 milion in transportation equipment. Please include any economic analysis
used to justify the project.
REQUEST NO. 97: Please describe the Company's refresh cycles and the justification
used to replace $11.5 milion in technology equipment.
REQUEST NO. 98: Please itemize the revenue producing 2009 capital additions stated
on page 24, line 14-16 of Mr. Defelice's testimony as being excluded. Please explain the
rationale for the exclusions.
REQUEST NO. 99: What is the total anual revenue requirement requested by Avista in
this case to paricipate in Columbia Grid?
REQUEST NO. 100: What is the total anual revenue requirement aside from Columbia
Grid and Grid West requested by Avista in this case for transmission planing functions?
REQUEST NO. 101: Please identify and explain any overlap between Avista fuctions
for Columbia Grid and other A vista transmission planing functions and why these functions are
not duplicative.
REQUEST NO. 102: Please provide total reimbursement received by Avista in each of
the last five years for generation interconnection planing studies.
REQUEST NO. 103: Please explain and provide any analysis showing how the
Company determines which replacement program projects are justified and cost effective in terms
of improved reliabilty and customer service. See Page 21 of Mr. Kinney's testimony staing on
line 11.
REQUEST NO. 104: Please provide the level of O&M expenses incurred for the
Company's distribution asset management program for the years 2004 through 2008. What
FIFTH PRODUCTION REQUEST TO A VISTA 3 MARCH 31, 2009
annual distribution O&M expenditures, in excess of those for asset management, were incurred
for the years 2004 through 2008? What were the annual distribution O&M expenditures prior to
the Asset Management Plan for the years 2000 through 2003?
REQUEST NO. 105: Isn.'t the Network Management plan described on page 36 of Mr.
Kinney's testimony for the city of Spokane directly assigned to the Washington electric
jurisdiction? If not, why not?
REQUEST NO. 106: Has the Company applied for federal fuding under the American
Recovery and Reinvestment Act? If not, why not? If so, please describe the amount of funding
sought and the proposed purpose.
REQUEST NO. 107: Given the curent and near-term economic conditions in your
northern Idaho service territory, what actions or specific measures has the Company undertaken
to reduce costs and mitigate the requested rate increase?
REQUEST NO. 108: In response to Staff Production Request No. 24, Avista reported its
actual service level in December of 2008 was 66.10%. Please explain the reason(s) for the low
service leveL.
REQUEST NO. 109: For the year 2008 please provide by month the number of e-mails
received by the Customer Service Center.
Dated at Boise, Idaho, this 3/ ~ day of March.
-:~.a. ~tL1
Kri me A. Sasser
Deputy Attorney General
Technical Staff; RL/90-107
MP/i08 & 109
i:umisc:prodreq/avue~09. lksrl prod request 5.doc
FIFTH PRODUCTION REQUEST TO A VISTA 4 MARCH 31, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31ST DAY OF MARCH 2009,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA, IN CASE NOS. AVU-E-09-1 & AVU-G-09-1, BY MAILING A
COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DA VID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220
E-MAIL: david.meyer(favistacorp.com
KELL Y NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE W A 99220
E-MAIL: kelly.norwood(favistacorp.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(fmcdevitt-miler.com
SCOTT ATKINSON
PRESIDENT
IDAHO FOREST GROUP LLC
171 HIGHWAY 95 N
GRANGEVILLE ID 83530
E-MAIL: .scotta(fidahoforestgroup.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(fgivenspursley.com
mcc(fgivenspursley.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
SUITE 250
1500 LIBERTY STREET SE
SALEM OR 97302
E-MAIL: dpeseau(fexcite.com
BETSY BRIDGE
ID CONSERVATION LEAGUE
710 N SIXTH STREET
PO BOX 844
BOISE ID 83701
E-MAIL: bbridge(fwildidaho.org
ROWENA PINEDA
ID COMMUNITY ACTION NETWORK
3450 HILL RD
BOISE ID 83702-4715
E-MAIL: Rowena(fidahocan.org
CARRIE TRACY
1265 S MAIN ST, #305
SEATTLE WA 98144
CERTIFICATE OF SERVICE