20121116Staff 58-79 to Avista.pdf

KARL T. KLEIN
WELDON B. STUTZMAN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0318
IDAHO BAR NOS. 5 156/3283

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7017 PflY I PH 124
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 AVISTA
UTILITIES FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
ELECTRIC AND NATURAL GAS SERVICE
IN IDAHO.
CASE NO. AVU-E-12-08
AVU-G-12-07
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities requests that Avista Corporation (Company;
Avista) provide the following documents and information as soon as possible, by FRIDAY,
DECEMBER 7, 2012.
This Production Request is to be considered as continuing, and Avista is requested to
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will 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
FOURTH PRODUCTION REQUEST
TO AVISTA 1 NOVEMBER 16, 2012
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. 58: The following requests pertain to the Canada to Northern
California (CNC) Transmission Project:
a.Why did Avista originally enter into a CNC Stage 1 Project Development Agreement
(i.e., for $537,000), and what were the additional planning expenditures (i.e., for
$221,000)? See Kinney, pg. 10, line 23 and pg. 11, lines 1-6.
b.Were the additional planning expenditures for the CNC project part of an agreement
or obligation? Please explain. See Kinney, pg. 11, lines 5-6.
c.Why is Avista amortizing the CNC Stage 1 Project Development Agreement costs
over a three-year period starting in 2012? See Kinney, pg. 11, lines 6-11.
d.If the Idaho share of the amortized amount of $253,000 is $88,000 for each of the
three years, why is the test year expense listed as $127,000, and why is the pro forma
amount $253,000? See Kinney, pg. 11, lines 8-11, Table 1, and Exhibit 9.
e.Why did Avista receive a refund from the Stage I Project Development Agreement?
See Kinney Workpaper G, line 5, Column 9.
REQUEST NO. 59: Please explain why training and travel expenses for the
ColumbiaGrid OASIS staff are increasing by $8,550 over the test year amount of $450. See
Kinney pg. 7, lines 22, 23 and pg. 8, lines 1-6.
REQUEST NO. 60: Avista Utilities' 2011 Electric Service Reliability Report provided
to the Washington Public Utility and Transmission Commission identified Colville as an area of
concern because it has the lowest reliability ratings of Washington's operating areas. The
following requests seek to obtain similar information on Avista's analysis of Idaho's distribution
reliabilities and associated reliability improvements investment. See Kinney testimony, System
Distribution Reliability Improve Worst Feeders (Kinney Table 4 and pg. 38, lines 10-27).
a. Please describe the process the Company uses to select areas of concern for Idaho.
FOURTH PRODUCTION REQUEST
TO AVISTA 2 NOVEMBER 16, 2012
b.Does the Company identify areas of concern for each of its distribution offices? If so,
please describe the individual areas of concern of each distribution office in Idaho.
c.What metrics or criteria does the company use to measure circuit reliability?
d.Does the Company have a goal or target timeframe to improve the reliability of
underperforming circuits?
e.What have the reliability target values been over the past 3 years (i.e., the specific 5-
year averages with the major event day removed, plus 2 standard deviations)?
f.Please describe the work plans and budgets developed to improve Idaho's operating
areas and include a list of the feeders, feeders' abbreviations, office codes, towns or
cities, and counties for each substation located in Idaho.
g.Please provide a 5-year history of the reliability performance data for Idaho organized
by distribution office and by circuit number.
REQUEST NO. 61: Regarding the power factor penalties incurred by Avista due to
reactive power violations at interconnections to BPA (Kinney pg. 8, lines 10-23 and pg. 9, lines
1-3):
a.What is the BPA-required reactive power threshold?
b.Are there any potential reductions to power factor penalties at BPA interconnections
attributable to transmission capital projects scheduled for 2012 or 2013? See Kinney
pg. 29, Table 3 and pg. 42, Table 5. Please explain.
REQUEST NO. 62: Please explain in greater detail how the BPA/Avista Parallel
Capacity revenue is computed based on the services provided by Avista. See Kinney Table 2,
pg. 14 and pg. 24, lines 5-17. Has BPA previously provided this revenue to Avista? Does
Avista expect similar revenues from BPA in the future?
REQUEST NO. 63: Please provide the schedule of self-reported and NERC/WECC
audits over the past three years, and state what the anticipated audit schedule will be for the
different Avista services and responsibilities in the future. Please also provide copies of the self-
reported and NERC/WECC audit results received within the past three years. See Kinney pg. 36,
Table 4 and pg. 49, Table 6 and associated capital investment testimony.
FOURTH PRODUCTION REQUEST
TO AVISTA 3 NOVEMBER 16, 2012
REQUEST NO. 64: Has Avista incurred any NERC/WECC fines for non-compliance,
either via self-reported or NERC/WECC audits? Do any identified standard violations or actual
standard violations directly relate to the Reliability Compliance projects? Please explain. See
Kinney pg. 36, Table 4 and pg. 49, Table 6 and associated capital investment testimony.
REQUEST NO. 65: Please completely describe the Atmospheric Testing Program.
Please include all plans, timelines, budgets, and deliverables. Also, please provide a cost-vs-
actual breakdown of Idaho's 2011 cost for the program ($390,000), and describe each cost
category as it relates to the overall program.
REQUEST NO. 66: Please provide a description and supporting documentation
showing how Avista selected the lowest cost vendor for its Customer Service Information
System Replacement Project.
REQUEST NO. 67: Please provide a description and supporting documentation
showing how Avista selected the lowest cost vendor for its Enterprise Asset Management
Support System Replacement Project.
REQUEST NO. 68: Please describe and justify the $13,800,000 ($4,300,000 +
$9,500,000) HVAC Renovation Project. Please include the financial analysis used to determine
the size and scope of the project and to ensure the project is least-cost. This should include a
detailed description, cost (budget vs actual), and timing of specific 2012 and 2013 capital project
amounts proposed to be pro formed in this filing. If vendors were used, please explain how
Avista selected them and summarize the results.
REQUEST NO. 69: Please provide the square footage amount and proportion of floor
space associated with non-regulated business units that are being supported by the HVAC
Renovation Project.
FOURTH PRODUCTION REQUEST
TO AVISTA 4 NOVEMBER 16, 2012
REQUEST NO. 70: Please describe and justify the Dollar Road Land Purchase and
Facility Expansion Project, including the financial analysis used to determine the size and scope
of the project to ensure it is least-cost. Include any comparisons of different alternatives for both
the 6,000 sq. ft. storage facility and for the 12,900 sq. ft. 6-bay fleet facility. If vendors were
selected to perform the work, please explain how they were selected and summarize the results.
REQUEST NO. 71: Please explain how the Company plans to allocate the cost of the
CNG filling station at the Dollar Road facility between regulated and non-regulated business
now and in the future. Please provide the cost allocation being used in this filing.
REQUEST NO. 72: Please describe and justify the following projects and how the
Company ensures they are completed at least-cost. This should include a detailed description,
cost (budget vs actual), and timing of specific 2012 and 2013 capital project amounts proposed to
be pro formed in this filing. If vendors are used, please explain how the Company selected them
and summarize the results. Projects include:
a)Jackson Prairie Storage Project;
b)Gas Reinforce Minor Blanket;
c)Replace Deteriorated Pipe;
d)Regulator Station Reliability Projects;
e)Natural Gas Replacement Street/Highways;
f)Cathodic Protection Projects;
g)Gas Distribution Non-Revenue Blanket;
h)Isolated Steel Replacement;
i)Overbuilt Pipe Replacement Blanket;
j)Gas Telemetry;
k)Replacement 6" PE;
1) Old Hwy 95 Relocation;
m)Klamath Falls Lateral; and
n)Reinforce Chase Rd Gate Station in Post Falls.
REQUEST NO. 73: Please provide the line item detail of the Structures and
Improvements by project for 2010, 2011, 2012, and 2013. Please include both budgeted and
actual costs to date for each project.
FOURTH PRODUCTION REQUEST
TO AVISTA 5 NOVEMBER 16, 2012
REQUEST NO. 74: Please provide the line item detail of the Transportation Equipment
by project for 2010, 2011, 2012, and 2013. Please include both budgeted and actual costs to date
for each project.
REQUEST NO. 75: Please provide a description and supporting documentation
showing how Avista selected the lowest cost vendor for its Next Generation Radio Project.
Please include all expenses to date.
REQUEST NO. 76: Please provide a description and supporting documentation
showing how Avista selected the lowest cost vendor for its Moducom Replacement. Please
include all expenses to date.
REQUEST NO. 77: Please describe any synergy or overlap of the Moducom project
and Next Generation Radio project.
REQUEST NO. 78: Please provide the square footage amount and proportion of floor
space associated with non-regulated business units that are being supported Long Term Campus
Re-Structuring Plan.
REQUEST NO. 79: Please provide the line item detail of all expenses for Long Term
Campus Re-Structuring Plan. Include budget for all separate projects and actual costs to date.
Dated at Boise, Idaho, this ' day of November 2012.
Karl T. Alein
Deputy Attorney General
Technical Staff: Johanna Bell/58-64
Mike Louis/65-72
Joe Terry/73-79
i:umisc:prodreq/avuel2.8_avugl2.7kkjbmljt prod req4
FOURTH PRODUCTION REQUEST
TO AVISTA 6 NOVEMBER 16, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16 ' DAY OF NOVEMBER 2012,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-12-08
& AVU-G-12-07, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
DAVID J MEYER KELLY 0 NOR WOOD
VP & CHIEF COUNSEL VP STATE & FED REG
AVISTA CORPORATION AVISTA CORPORATION
P0 BOX 3727 P0 BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-MAIL: [e-mail] E-MAIL: [e-mail]
DEAN J MILLER LARRY A CR0 WLEY
McDEVITT & MILLER LLP THE ENERGY STRATEGIES
P0 BOX 2564 INSTITUTE INC
BOISE ID 83702 5549 S CLIFFSEDGE AVE
E-MAIL: joeCmcdevitt-mi11er.com BOISE ID 83716
E-MAIL: [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
515 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
gregCrichardsonandoleary.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading2limindspring.com
ELECTRONIC SERVICE ONLY:
Howard Ray
Clearwater Paper Corporation
[e-mail]
'J.
SECRETfRY
CERTIFICATE OF SERVICE