20110726Staff 1-30 to AVU.pdf

KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE. IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
ioii JUL 26 AM II: 06
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 AVISTA 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-ll-ll
AVU-G-ll-l
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities 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 TUESDAY, AUGUST
16,2011.
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. including 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
FIRST PRODUCTION REQUEST
TO AVISTA 1 JULY 26. 2011
holder and if different the witness who can sponsor the answer at hearng 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.1: Please provide a copy of the trial balance as of December 31, 2010.
REQUEST NO.2: Please provide a copy of the Company Char of Accounts.
REQUEST NO.3: Please provide all documentation related to the proceeds,
underwiter commissions and other expenses associated with any and all debt securities issued
during the years 2010 and 2011 as incured.
REQUEST NO.4: Please provide all documentation related to the expenses, proceeds,
and underwiter commissions associated with the Company's issuance of any and all equity
during 2010 and 2011.
REQUEST NO.5: Please provide any or all underwiting documentation, including
competitive bids from investment banks or broker-dealers associated with any and all Company
debt or equity issuances occurring durng 2010 and 2011 as incured.
REQUEST NO.6: Please provide access to Board of Directors minutes for Avista
Corporation, A vista Utilties, and all affiiates for 2010 and 2011. Please also provide access to
all reports and materials discussed during the board meetings.
REQUEST NO.7: Please provide access to Audit Committee minutes for Avista
Corporation, A vista Utilties, and all affiliates for 2010 and 2011. Please also provide access to
all reports and materials discussed during the committee meetings.
FIRST PRODUCTION REQUEST
TO AVISTA 2 JULY 26,2011
REQUEST NO.8: Please provide access to Compensation Committee minutes for
A vista Corporation, A vista Utilties, and all affiliates for 2010 and 2011. Please also provide
access to all reports and materials discussed during the committee meetings.
REQUEST NO.9: Please provide an analysis of the actual cost of capital at December
31,2010, June 30, 2011 and September 30, 2011, when available. Provide debt amounts and
debt costs, equity amounts and costs, and all account numbers for amounts involved.
REQUEST NO. 10: Please provide a debt schedule showing all long-term and short-
term debt amounts outstanding, stated interest rates, premiums, discounts, unamortized issuance
expenses and effective cost rates at December 31, 2010, June 30, 2011 and September 30, 2011,
when available, for A vista Utilities.
REQUEST NO. 11: Please provide a Schedule of "Property Held for Future Use" at
December 31, 2010, and on a quarerly basis for 2011. List each individual item and provide
cost of property, expected in service date, and the accounts where the property is booked.
REQUEST NO. 12: Please provide a schedule ilustrating all changes to rate base
during 2010 and on a quarterly basis for 2011.
REQUEST NO. 13: Please provide a detailed list with explanation of all cost-cutting
measures undertaken by the Company during 2010 and 2011. Please also provide the
quantifiable results of those measures.
REQUEST NO. 14: Please provide a list showing a summar of all other consultants
and attorneys (internal and external) who performed services for Company or who were paid by
the Company for 2010 and on a quarterly basis for 201 1. For all attorneys, show services
performed, amounts paid, and accounts charged. If services were performed in support of a
docketed federal/state cour or regulatory agency action, please identify the case name, case
number and jurisdiction.
FIRST PRODUCTION REQUEST
TO AVISTA 3 JULY 26, 2011
REQUEST NO. 15: Please provide a schedule of prepaid items as of December 31,
2010 and on a quarterly basis for 2011 showing amounts, vendors, explanations and accounts
used.
REQUEST NO. 16: Please provide the total amounts spent on the following activities
during 2010 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 consultants);
b. Avista Corporation'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;
1. Travel and training for A vista Utilities executives that are also A vista Corporation
executives;
J. Insurance coverage;
k. Overhead items including utilities, propert taxes, security services, and other
corporate headquarers expenses;
1. All other allocated expenses.
REQUEST NO. 17: Please provide copies of all affiiated Company receivables and
payables with Avista Utilities as of December 31, 2010 and June 30, 2011. Show details
including amounts, dates, explanations, and calculations.
REQUEST NO. 18: Please provide the complete calculation of the overhead ratio used
to capitalize labor-related expenses for 2010. Please include all components of the calculation
and their amounts.
FIRST PRODUCTION REQUEST
TO AVISTA 4 JULY 26,2011
REQUEST NO. 19: Please provide copies of the federal and state tax returns for 2009
and 2010 when available.
REQUEST NO. 20: Please provide compensation detail for all management and
offcers of Avista Corp, Avista Utilities, and all affiiates that share employees with Avista
Utilties including salary, incentive pay, bonuses, stock options, and other benefits and taxes for
the years 2010 and on a quarerly basis for 2011 forecasted and actual, when available. Please
also provide any and all compensation studies used to set the compensation levels during the
requested time period.
REQUEST NO. 21: Please show how the compensation for management and offcers of
A vista Corp, A vista Utilities, and all affliates that share employees with A vista Utilties is
allocated to the affiliates in 2010 and 2011. Please explain how the allocation technique was
derived.
REQUEST NO. 22: Please provide copies of all A vista Utilties internal audit reports
and A vista Corporation audit reports that reference A vista Utilties for the years 2009 through
2011.
REQUEST NO. 23: Please provide the percentage amount of the general wage increase
given to employees for each year from 2007-2011 and the date the increases became effective.
REQUEST NO. 24: Please provide all studies (both external and internal) used to
determine the amount of general wage increase given to employees in 2010 and 2011.
REQUEST NO. 25: Please provide Company census data in an Excel spreadsheet
listing each employees title, date of hire, date of termination, date of rehire (if applicable), date
of re-termination (if applicable), and wages earned in 2010.
FIRST PRODUCTION REQUEST
TO AVISTA 5 JULY 26, 2011
REQUEST NO. 26: Mr. Kopczynski states in his Direct Testimony, page 7, that the
Company is using an outside vendor to perform the required Atmospheric Corrosion testing.
Please identify the vendor performing the testing and provide copies of all contracts with that
vendor for testing. Please explain how the $450,000 estimated cost of the testing was derived.
Please also explain why the Company believes it is less expensive to use outside vendors to
perform the testing instead of having the tests performed by Company employees and students,
as has been the practice in the past.
REQUEST NO. 27: Has the Company successfully appealed any property tax
assessments in which refunds were received during the years 2006-2011? If so, please provide
the amounts of the refuds for each year.
REQUEST NO. 28: Ms. Andrews states on page 25 of her Direct Testimony that the
"Company requested from each of its directors, based on their actual experience, the estimated
time spent on utility versus non-utility duties and responsibilties. The responses from the
Directors indicated that approximately 90% of the Directors' time is dedicated to utilty matters,
and approximately 10% to non-utilty." Please provide copies of the Directors' responses.
REQUEST NO. 29: The Company uses 6-year averages to calculate the test year
amounts for both Injuries and Damages and Employee Incentive Payments. When calculating
the 6-year average for Injuries and Damages, the Company excluded the lesser 2010 amounts
and used the average amounts from 2004-2009. When calculating the average amounts for
incentive payments, the Company used the average amounts from 2005-2010, which included
the larger payments made during 2010. Please explain and provide any supporting
documentation showing why the Company uses 2010 amounts in some averages, but not others.
REQUEST NO. 30: Please provide the amount of cash contributions that A vista has
made to the Company's pension plan for the years 2006-2010, and 2011-2012 projected
contributions.
FIRST PRODUCTION REQUEST
TO AVISTA 6 JULY 26, 2011
Dated at Boise, Idaho, this J.c, 71 day of July 2011.
~(Q(L ~4L"-Kris . ne A. Sasser
Deputy Attorney General
Technical Staff: Donn English/I-30
i:umisc:prodreq/avue-ll l.ks prod reql
FIRST PRODUCTION REQUEST
TO AVISTA 7 JULY 26,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF JULY 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO A VISTA CORPORATION, IN CASE NOS.
AVU-E-II-01_AVU-G-II-0I, BY E-MAILING AND MAILING A COPY THEREOF,
POSTAGE PREP AID, TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: david.meyer(favistacorp.com
KELLY 0 NORWOOD
VP STATE & FED REG
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: kelly.norwood(iavistacorp.com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmai1.com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(irichardsonandoleary.com
greg(irichardsonando leary. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(imindspring.com
E-MAIL ONLY:
HOWARD RAY
CLEARWATER PAPER CORP
E-MAIL: howard.ray(iclearaterpaper.com
~~
SECRETARY
CERTIFICATE OF SERVICE