20100610Staff 107-139 to AVU.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
RECEiVED
ioin JUN 10 PM 3= 19
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 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF A VISTA CORPORATION DBA A VISTA )
UTILITIES FOR THE AUTHORITY TO )
INCREASE ITS RATES AND CHARGES FOR )
ELECTRIC AND NATURAL GAS SERVICE )IN IDAHO. )
)
)
)
CASE NO. AVU-E-I0-l
AVU-G-I0-l
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 Avista Corporation (Company;
Avista) provide the following documents and information on or before THURSDAY,
JULY 1,2010.
FIFTH PRODUCTION REQUEST
TO AVISTA 1 JUE 10,2010
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementay 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. 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 files on CD with formulas activated.
REQUEST NO. 107: Please provide Staff with unredacted Kensok exhibits JMK-2 and
JMK-3, fied in the curent Washington Case, Case No. UE-10467 and Case No. UE-10468.
REQUEST NO. 108: The Company identified in its response to Production Request
No. 17 that the Board of Directors approves the capital expenditure budget. Please identify how
the dollar amount approved is determined. For example, is the amount approved a certain
percentage of available financing and if so, what is the percentage and how it is derived? Or, is
the amount approved based upon the dollar amount of projects submitted?
REQUEST NO. 109: Staffhas reviewed the Company's fied Application and
testimony. Please identify in detail how the Company's revenue requirement request has been
reduced as a result of operational decisions that eliminated and/or minimized operating and
capital expenditure outlays in response to the economic recession.
FIFTH PRODUCTION REQUEST
TO AVISTA 2 JUE 10,2010
REQUEST NO. 110: In Kinney's testimony, page 21, lines 18-20, he stated that "Avista
is required to perform system studies in both the near term (1-5 years) and long term (5-10
years)." Please provide copies of these studies. In addition:
a. What is the schedule for the revision of these documents? Does the Company
have a cycle of revising these studies?
b. Does the North American Electric Reliability Corporation (NERC) review these
studies and help the Company identify potential violation from its standards?
c. When does the Company regularly fie these documents with NERC?
REQUEST NO. 111: In Kinney's testimony, page 21, lines 20-23, he stated that "If a
potential violation is observed in the future years, then A vista must develop a project plan to
ensure that the violation is fixed prior to it becoming a reality." (Emphasis in original). Please
provide copies of the project planes) that identify the compliance projects in this rate case.
a. If a potential violation is identified, does NERC have a guideline or stadard for
the time frame that this violation needs to be fixed? Please cite that guideline.
REQUEST NO. 112: According to Kinney's testimony, page 22, lines 9-11, he stated
the Company "goes through a thorough internal review process that includes multiple
stakeholder review" to address system needs. If the Company has a stadard document it uses
durng this review process, please provide that document.
a. Please explain in detail how the Company evaluates each project and the criteria
used in the evaluation such as project cost, system benefits and other criteria.
b. Please include any analysis used by the Company to prioritize projects.
c. The review process identified the system needs based on NERC stadards but
other projects not selected stil have the potential for non-compliance. How does
the Company deal with those projects?
REQUEST NO. 113: Each of the Reliability Compliance Projects, the Lolo 230 kV
Substation, Spokane/Coeur d Alene relay upgrade, Nez Perce 115 kV Substation Rebuild and
Capacitor Ban, SCADA Replacement, System Replace/Install Capacitor Ban at Airway
FIFTH PRODUCTION REQUEST
TO AVISTA 3 JUE 10,2010
Heights, Airway Heights-Silver Lake 115 kV Transmission Line, and Mos230-Pullman 1 l5
Reconductor, are projects required to meet reliabilty compliance requirements associated with
NERC Standards. For each project identified and justified based on meeting those standards:
a. Please describe the process and assumptions used to forecast violations ofNERC
reliabilty criteria.
b. Please describe the natue of the actual or anticipated violation and penalties if the
project is not completed.
c. Please provide the alternative solutions considered to meet compliance
requirements and justify how the final solution is selected.
d. Please explain how the Company undertakes the construction of these projects to
assure reasonable cost of compliance requirements. Are the projects contracted
in-house, competitively bid or sole sourced?
e. Please quantify the impact of completing each of these projects to improve
reliability .
f. Please provide the schedule of these projects and the cost per year.
g. After completion of a project, is the Company required to file documentation with
NERC to validate it has fulfilled the reliabilty compliance requirement? If so,
please provide these documents. If not, how does NERC become aware of the
compliance?
REQUEST NO. 114: The Beacon Storage Yard is an Environmental Regulation Project.
Please cite the environment regulation requirement for this project.
a. Please cite where the Company has included this project in its plans.
b. Please identify the specific components of this project that fulfilled the
environment regulation.
FIFTH PRODUCTION REQUEST
TO AVISTA 4 JUNE 10,2010
REQUEST NO. 115: The Company identified Colstrip Transmission and Tribal Permits
as contractually required projects. What role does the Company play in assuring these
contractual projects are least cost and cost effective? If no role, why not?
a. How can customers be assured that these additional costs are reasonable?
b. Please justify the 20 percent cost increase for the Colstrip Transmission expense
and describe any activity by the Company in an attempt to control this cost
Increase.
REQUEST NO. 116: Please cite where the Boulder-Rathdr 115kV Transmission
Line has been identified as one of the priority projects in the Company's plans.
a. The intent of this project is to improve reliabilty but is not mandatory under
NERC standards. What other standard is used to justify this project?
b. Please provide outage data and cost-benefit analysis used to justify this project.
c. According to Mr. Kinney, this is year two of the multi-year project. How much
time is needed to complete the project?
d. Please provide a schedule showing the anual work projects and the expected cost
per year for this project.
REQUEST NO. 117: In Kinney's testimony, page 25, lines 40-42, he stated, "The
Company wil also spend approximately $5.516 milion in transmission system equipment
replacements associated with storm damage or aging/obsolete equipment."
a. Please provide the standard the Company uses to justify replacement project
decisions and identify each transmission replacement project in that stadard.
b. Please explain how each project is prioritized.
c. The purose of some of the replacement projects is to improve reliabilty. Please
describe how the Company identifies which areas need reliabilty improvement.
Include any documents or analysis the Company uses to identify reliabilty issues.
d. Please cite the reliability standards and the specific components of the project that
satisfy those standards.
FIFTH PRODUCTION REQUEST
TO AVISTA 5 JUNE 10,2010
e. Please quantify the impact of completing each of these projects to improve
reliabilty.
f. Please list the projects under the "Other Small Transmission Projects" as stated in
Kinney's testimony, page 27, lines 12-14, with their corresponding cost and a
description of their impact on the system.
g. Please explain how the Company undertakes the construction of these
transmission replacement projects to assure reasonable cost. Are the projects
contracted in-house, competitively bid or sole sourced?
h. Please explain how risks are evaluated on proposed replacements that are not
funded.
REQUEST NO. 118: The Distribution Projects, as stated in Kinney's testimony, page
27, lines 22-24, "are necessary to meet capacity needs of the system, improve reliabilty, and
rebuild aging distribution substations and feeders." Please describe how each of these projects
were identified and prioritized.
a. Please provide analysis (i.e., load growth, load flow, etc.) to demonstrate the need
for additional system capacity and the locations of system capacity constraints.
b. Please quantify the impact of these projects on reliabilty.
c. Please describe the process for the Company's assessment for aging distribution
substations and feeders.
d. Please provide the results of the analysis (i.e., life cycle or outage failure studies,
etc.) used by the Company to justify replacement of this distribution equipment.
e. Please explain how the Company undertakes the construction of these distribution
projects to assure reasonable cost. Are the projects contracted in-house,
competitively bid or sole sourced?
FIFTH PRODUCTION REQUEST
TO AVISTA 6 JUE 10,2010
REQUEST NO. 119: Please justify the benefits of the transformation of Dear
substation from a wood substation to a steel substation on the system.
a. Please cite any applicable standard regarding this transformation.
REQUEST NO. 120: Please provide the analysis used by the Company to identify the
Worst Performing Feeders and how the Company prioritizes these feeders for improvement.
REQUEST NO. 121: Please provide the results from SynerGee modeling showing the
four feeders at Coeur d Alene East and North are thermally constrained.
a. Please describe the effects of a thermally constrained conductor to the system.
REQUEST NO. 122: Please describe how the Company identifies and prioritizes the
projects in the Electric Distribution Minor Blanket Projects.
a. Please explain how the Company undertkes the construction of these blanet
projects to assure reasonable cost. Are the projects contracted in-house,
competitively bid or sole sourced?
REQUEST NO. 123: Please provide the handbooks for the Company's Wood Pole
Replacement Program and Capital Distribution Feeder Repair.
a. Does the Company have a revision schedule for these handbooks? If so, how
often?
b. Please include the studies and results which cite the Company's investment under
these programs.
c. How often does the Company conduct these studies for these programs?
d. Please explain how the Company undertakes the constrction of these projects to
assure reasonable cost. Are the projects contracted in-house, competitively bid or
sole sourced?
FIFTH PRODUCTION REQUEST
TO AVISTA 7 JUE 10,2010
REQUEST NO. 124: Please list the projects involved in the T &D Line Relocation.
Please include the requesting entity, costs and completion date.
REQUEST NO. 125: Please list the distribution equipment replaced in the Failed
Electric Plant. Please include costs, the location and in-service date.
REQUEST NO. 126: Please list the projects under the "Other Small Distribution
Projects" category from Kinney's testimony, page 30, lines 34-40.
a. Please explain how the Company undertakes the constrction of these projects to
assure reasonable cost. Are the projects contracted in-house, competitively bid or
sole sourced?
REQUEST NO. 127: In Kensok's testimony, page 4, lines 12-15, he stated that
"increasing requirements related to reliabilty and security related to our operations and
communications have required significant ongoing investment in our IS hardware, software and
staff." Please cite those NERC stadards and/or other compliance requirements.
a. Please list the measures the Company has taken to fulfill those security
compliance requirements and completion date(s).
REQUEST NO. 128: In Kensok's testimony, page 7, line 12, Table 2 provides a
summar of the 2010 Net Operating Cost Increases. Please provide documentation and further
cost breakdown per component (i.e., staff, training, tools, software, etc.) for each of the
categories in Table 2.
a. Please provide any cost!enefit analysis conducted to justify these expenditures.
b. Please provide the number of additional staff needed and justify each staffng
position.
FIFTH PRODUCTION REQUEST
TO AVISTA 8 JUE 10,2010
REQUEST NO. 129: In Kensok's testimony, page 17, line 2-4, he mentioned that the
Enterprise Business Continuity Program "provides the oversight and direction for recovery and
restoration of business systems and facilities in the event of a disaster." Please describe this
program in greater detail and its implementation date.
a. Please provide the documentation for this program.
REQUEST NO. 130: In Kensok's testimony, page 17, line 12-16, he stated that
"Additional communication network engineers and support staff are needed to design and
maintain networks that support the automation of: (1) the electric distribution system,
(2) customer and employee communications, and (3) electric mobile dispatch networks." Please
provide a list of the completed network upgrades, its corresponding completion date and cost to
provide the support for automation.
a. Please provide any analysis (i.e., cost!enefit) to justify these additions.
b. Please provide the number of additional staff needed and justify each staffng
position.
REQUEST NO. 131: Please provide a detailed listing of costs expensed during 2009 for
capital projects not approved. Please separately identify within your response those costs
included within the Company's Idaho rate case filings for electric and natural gas rate increases.
Reference Avista's response to Production Request No. 17, Attchment B, Preliminary Survey
and Investigations (PS&I).
REQUEST NO. 132: To the extent not provided in response to the previous request,
please provide a detailed listing of costs expensed during 2009 for all abandoned projects. Please
separately identify within your response those costs included within the Company's Idaho rate
case filings for electric and natural gas rate increases.
FIFTH PRODUCTION REQUEST
TO AVISTA 9 JUNE 10,2010
REQUEST NO. 133: Please provide, by position and name, a reconcilation of the
compensation reported in the Spokesman-Review and Coeur d Alene Press to the amount paid
each individual in total, by utilty and proposed in Idaho rates. Please include within your
response the detailed nature of each reconcilng item.
REQUEST NO. 134: Please provide a schedule listing projects that can be considered
par of "Smar Grid" investment. For each project provide the description, work order identifying
numbers, in-service dates, and associated costs.
REQUEST NO. 135: For the projects listed in response to the question above, will the
company receive ARR funding? If so, identify the projects and the funding amounts. If not,
please identify any projects where funding was requested.
REQUEST NO. 136: Please provide an itemized listing of all Columbia Grid related
expenses and investments included in this case and account numbers where costs are recorded.
REQUEST NO. 137: Please provide a qualitative and quantitative description of the
benefits derived through Avista's paricipation in Columbia Grid that justifies the expenditures.
REQUEST NO. 138: Please explain why Avista chose to paricipate in Columbia Grid
rather than the Northern Tier Transmission Group.
REQUEST NO. 139: Please describe Avista's expected participation in Columbia Grid
in the future and how expenses might change.
FIFTH PRODUCTION REQUEST
TO AVISTA 10 JUE 10,2010
/ r'"Dated at Boise, Idaho, this () day of June 2010.
~:.d~.
Kris' e A. Sasser
Deputy Attorney General
Technical Staff: Kathy Stockton/#107
Patricia Harms/#108 - 109 & 131 - 133
TJ. Golo/#110 - 130
Terri Carlock/#134 - 139
i:umisc:prodreq/avue_gl O. i ksklsphtctj prod req5.doc
FIFTH PRODUCTION REQUEST
TO AVISTA 11 JUE 10,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF JUE 2010,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA, IN CASE NOS. AVU-E-1O-01_AVU-G-1O-01, BY
E-MAILING AND MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: david.meyer(iavistacorp.com
PETER J RICHARDSON
GREG M ADAMS
RICHARDSON & O'LEARY
515 N 27TH ST
BOISE ID 83702
E-MAIL: peter(irichardsonandoleary.com
greg(irichardsonandoleary .com
DEAN J MILLER
MCDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe(imcdevitt-miler.com
ROWENA PINEDA
ID COMMUNITY ACTION
NETWORK
3450 HILL ROAD
BOISE ID 83703
E-MAIL: Rowena(iidahocan.org
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(ihotmail.com
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmiler(isnakeriverallance.org
KELL YO NORWOOD
VP STATE & FED REG
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: kelly.norwood(iavistacorp.com
HOWARD RAY
CLEARWATER PAPER CORP
803 MILL ROAD
PO BOX 1126
LEWISTON ID 83501-1126
E-MAIL: howard.ray(iclearwaterpaper.com
LARRY CROWLEY
ENERGY STRATEGIES INSTITUTE
5549 S CLIFFS EDGE AVE
BOISE ID 83716
E-MAIL: crowleyla(iaol.com
LEEANNHALL
3518 S EDMUNDS ST
SEATTLE WA 98118
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
POBOX 844
BOISE ID 83701
E-MAIL: botto(iidahoconservation.org
ROB PLUID PRESIDENT
NORTH IDAHO ENERGY LOGS
PO BOX 571
MOYIE SPRINGS ID 83845
E-MAIL: robpluid(igmail.com
CLARK FAIRCHILD
VICE PRESIDENT
NORTH IDAHO ENERGY LOGS
PO BOX 571
MOYIE SPRINGS ID 83845
E-MAIL: energylogs(igmail.com
TOM OXFORD
SECRETARY TREASURER
NORTH IDAHO ENERGY LOGS
E-MAIL: oxford(imeadowcrk.com
(ELECTRONIC SERVICE ONLY)
t~,kt
SECRETARY