20121207Staff 101-136 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. 5156/3283
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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
SEVENTH 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 28, 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
SEVENTH PRODUCTION REQUEST
TO AVISTA 1 DECEMBER 7, 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. 101: Please provide cost of service summary results for the following
two scenarios:
a.Using the Load Factor methodology proposed in Case No. AVU-E-11-01 instead of
the traditional Peak Credit methodology used in this filing.
b.Use the load factor methodology from a) and use the weighted 1 2CP methodology for
transmission proposed in Case No. AVU-E-1 1-01 instead of the 12CP methodology
used in this filing.
REQUEST NO. 102: Compare the differences in results between the filed method and
the results of Request No. 101a. and bib.
REQUEST NO. 103: Please provide a description and method of calculation for
allocation basis/reference number 16 in Report ID G-OTX- 1 2A in the Gas Results of Operations
Report for the test year (12 months ending 6/30/20 12).
REQUEST NO. 104: Please provide a description and method of calculation for
allocation basis/reference "JP" in the Gas Results of Operations Report for the test year (12
months ending 6/30/2012). Please verify the date of the data used to develop the allocation
versus the date published in the report.
REQUEST NO. 105: Please provide the Oregon Gas Results of Operation report for
twelve months ending June 30, 2012.
REQUEST NO. 106: Given that Idaho has no RPS requirement, does Avista plan to use
100% of the RECs produced by the Palouse Wind project to satisfy RPS requirements in
Washington? Does Avista believe that Idaho is entitled to a share of the Palouse Wind project
SEVENTH PRODUCTION REQUEST
TO AVISTA 2 DECEMBER 7, 2012
RECs even though Idaho has no RPS requirement? Does Avista plan to sell Idaho's share of the
RECs and credit the revenue to Idaho, or alternatively, to impute revenue to Idaho equal to the
value of Idaho's share of the RECs if it chooses to use all of the project's RECs to satisfy
Washington RPS requirements?
REQUEST NO. 107: Given that Idaho has no RPS requirement and that Avista's 2011
IRP does not show a need for new energy resources to meet load until 2018 (Lafferty, Direct, p.
15 and Exhibit 4, Schedule 1), please explain how Idaho ratepayers specifically benefit from the
Palouse Wind PPA. To the extent possible, please quantify any identified benefits for Idaho
ratepayers.
REQUEST NO. 108: Please compare on a monthly basis for 2013 the cost of purchases
under the Palouse Wind PPA to the expected cost of market alternatives as indicated by internal
price forecasts, broker quotes or forward prices. If the cost of market alternatives is less than the
cost of purchases under the Palouse Wind PPA, does Avista believe that Idaho ratepayers should
be responsible for the higher cost of the Palouse Wind PPA? Please explain.
REQUEST NO. 109: If the Idaho Commission ultimately decides not to allow recovery
of above-market costs of the Palouse Wind PPA until the Company can demonstrate a need by
Idaho ratepayers, how will Avista attempt to recover the costs of the PPA (e.g., assign all costs
and benefits of the PPA to Washington, resell Idaho's share of the project output and associated
RECs, something else)?
REQUEST NO. 110: Please provide schedules showing the Electric Operation and
Maintenance (O&M) accounts by month, and the administrative and general (A&G) accounts by
month for the period, July 1, 2011 through December 31, 2012, in excel format with the
following headings:
a)Er
b)Ferc Acct
c)Service
d)Voucher Number
e)Organization Desc
SEVENTH PRODUCTION REQUEST
3 DECEMBER 7, 2012 TOAVISTA
Accounting Period
g) Subledger Transaction Id
h) Expenditure Organization
i) Pm Number
j) Project Number
k) Stock Number
1) Vehicle Number
m) Ticket Number
n) Jurisdiction
o) Journal Name
p) Transaction Desc
q) Ava Jet
r) Expenditure Category
s) Invoice Number
t) Report Category
u) Summary Exp Category
v) Accounting Year
w) Task Number
x) FERC
y) Expenditure Type
z) Source Id
aa) Transaction Amount
bb) Electric Amt SUM
cc) Gas North Amt SUM
dd) Not Assigned Amt SUM
ee) Project Desc
ff) Company
gg) Statind
hh) Vendor Number
ii) Employee Number
jj) Gas South Amt SUM
kk) Job Title
11) Vendor Name
REQUEST NO. 111: Please provide schedules showing the Gas Operation and
Maintenance (O&M) accounts by month, and the administrative and general (A&G) accounts by
month for the period, July 1, 2011 through December 31, 2012, in excel format with the
following headings:
SEVENTH PRODUCTION REQUEST
TO AVISTA 4 DECEMBER 7, 2012
a)
b)
c)
d)
e)
0
g)
h)
i) Pm Number
j) Project Number
k) Stock Number
1) Vehicle Number
m) Ticket Number
n) Jurisdiction
o) Journal Name
p) Transaction Desc
q) Ava Jet
r) Expenditure Category
s) Invoice Number
t) Report Category
u) Summary Exp Category
v) Accounting Year
w) Task Number
x) FERC
y) Expenditure Type
z) Source Id
aa) Transaction Amount
bb) Electric Amt SUM
cc) Gas North Amt SUM
dd) Not Assigned Amt SUM
ee) Project Desc
ff) Company
gg) Statind
hh) Vendor Number
ii) Employee Number
jj) Gas South Amt SUM
kk) Job Title
Il) Vendor Name
REQUEST NO. 112: Please provide by month for 2011 and 2012 the totals for the
following projects. Include budgeted and actual to date:
SEVENTH PRODUCTION REQUEST
TO AVISTA 5 DECEMBER 7, 2012
Er
Ferc Acct
Service
Voucher Number
Organization Desc
Accounting Period
Subledger Transaction Id
Expenditure Organization
a.Failed Electric Plant
b.Transmission Minor Rebuilds
c.IT Technology Refresh Blanket
d.IT Technology Expansion Blanket
e.Electric Distribution Minor Blanket
f.Wood Pole Management
g.PCB Related Distribution Rebuilds
REQUEST NO. 113: Please provide a schedule of lobbying and/or political action
committee expenses associated with or allocated to Avista Gas and Electric Operations for the
test period (the twelve months ending June 30, 2012). Please describe the nature of the
expenses, the payee, amounts paid, accounts posted, transaction/voucher number, date paid, and
cross-reference where the expense was removed from the Company's filing.
REQUEST NO. 114: Please identify any extraordinary expenses, revenues, gains or
losses for the years 2011 and 2012 to date that were directly assigned or allocated to Avista Gas
and/or Electric Operations. Please describe the circumstances, identify dates of relevant events,
amounts, transaction/voucher number, date of transaction, and accounts posted including how
and where items were amortized. If any of these costs were included in the Company's filing
please identify where they were included.
REQUEST NO. 115: Please provide a detailed schedule of any land and/or plant sales
(including allocations of system wide amounts) for Avista Electric and Gas Operations in 2011
and 2012 to date. Please include in your response the date of sale, description of the sale, the
account numbers posted, transaction/voucher number, and dollar amounts posted and how they
were included in the Company's filing. If they were not included in the Company's filing, please
describe why not.
REQUEST NO. 116: Please provide a detailed schedule of any land and plant sales
planned for Avista Electric and Gas Operations. Please include in your response the
anticipated/estimated date of sale, description of the sale, the account numbers to be posted and
estimated dollar amounts to be posted.
SEVENTH PRODUCTION REQUEST
TO AVISTA 6 DECEMBER 7, 2012
REQUEST NO. 117: Please provide a detailed schedule of any insurance settlements,
refunds, legal settlements and the like that occurred during 2011 and 2012 to date. Please
include within your response the nature/reason for the funds received or awarded, the date of the
award, the account numbers posted, transaction/voucher number, dollar amounts posted and how
they were included in the Company's filing. If they were not included in the Company's filing,
please describe why not.
REQUEST NO. 118: Please provide a detailed schedule of any insurance settlements,
refunds, legal settlements and the like that have not occurred but are pending or likely to occur.
Please include within your response the nature/reason for the funds to be received or awarded,
the potential date of the award, the account numbers to be posted, and approximate dollar
amounts to be posted.
REQUEST NO. 119: Please provide a detailed schedule of any judgments, penalties,
fines and the like that occurred during 2011 and 2012 to date. Please include within your
response the nature/reason for the judgment, the date of the judgment, transaction/voucher
number, the account numbers posted, dollar amounts posted and how they were included in the
Company's filing.
REQUEST NO. 120: Please provide a schedule of expenses associated with Board of
Directors' meetings, travel and payments during the test year (12 months ended June 30, 2012).
Please include the accounts to which the amounts were posted and illustrate the allocations of the
amounts between utility and non-utility operations and the ultimate allocation to Idaho's utility
operations that were incorporated into the Company's filing.
REQUEST NO. 121: Please describe the process by which costs associated with
abandoned projects are recorded. Please include within your response the total costs recorded in
the test year (12 months ended June 30, 2012) by account and a detailed spreadsheet (in Excel
format) identifying the project number, project description, expenditure type, vendor description,
transaction description, transaction amount, date posted, document/transaction number, and total
SEVENTH PRODUCTION REQUEST
TO AVISTA 7 DECEMBER 7, 2012
amount posted. If any of these costs were included in the Company's filing please identify
where they were included.
REQUEST NO. 122: To the extent not provided in response to the previous request,
please provide a detailed listing of costs expensed during the test period (12 months ended June
30, 2012) 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.
REQUEST NO. 123: In Order No. 29602, the Commission accepted Staff's
adjustments removing non-recurring extraordinary legal expense as reasonable and appropriate.
Specifically Staff removed legal expenses related to subsidiary activities, and extraordinary and
non-recurring events such as the bankruptcy proceedings of Enron Corporation and the FERC
investigation into electricity trading practices. Please provide a listing of all legal expenses
included in the rate case filings, both gas and electric, for subsidiary activities, extraordinary
events, and non-recurring events. Please identify in your response the account and
subaccount to which the expenses were posted, the nature of the events/activities and the
corresponding amounts allocated to Idaho contained in the Company's filing.
REQUEST NO. 124: Please identify the FERC account and subaccount to which any
expenses were written off, the transaction/voucher numbers, date posted, amount posted,
transaction description and the corresponding amounts allocated to Idaho contained within the
Company's general rate case.
REQUEST NO. 125: Please list all attorneys (internal and external) who performed
services for the Company or who were paid by the Company during the test period (12 months
ended June 30, 2012). Please identify the 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. Please include
within your response how the amounts were allocated to Idaho Electric and Natural Gas
Operations.
SEVENTH PRODUCTION REQUEST
TO AVISTA 8 DECEMBER 7, 2012
REQUEST NO. 126: Please list all consultants who performed services for Avista
Utilities for the years 2011 and 2012 to date. Please include within your response the services
performed, amounts paid, the accounts charged, the allocation factor and amount allocated to the
Idaho jurisdiction.
REQUEST NO. 127: Please provide a schedule of prepaid items as of December 31,
2011 and on a quarterly basis for 2012 showing amounts, vendors, explanations and accounts
used.
REQUEST NO. 128: Please provide the total amounts spent on the following activities
during the test period (12 months ending June 30, 2012) and show how the amounts were
allocated between regulated and non-regulated operations:
a.Internal auditing expenses (by employees and others);
b.Avista Corporation's annual report;
c.Avista's filings with the SEC;
d.External audits and consulting;
e.Overhead items including utilities, property taxes, security services, and other
corporate headquarters' expenses.
REQUEST NO. 129: Please identify all instances in which the Company successfully
appealed a property tax assessment in which refunds were received during the years 2011-2012.
Please provide within your response the amounts of the refunds for each year and how they were
incorporated into the Company's filing.
REQUEST NO. 130: Please list all pending legal cases and describe their status
including the issue, estimates of liability and possible ramifications to the Company.
REQUEST NO. 131: Please provide a copy of the Company's policy for bad debt write-
offs and collection of past due amounts.
REQUEST NO. 132: Please provide a schedule of the Company's bad debt amounts for
2011 and 2012 to date.
SEVENTH PRODUCTION REQUEST
TO AVISTA 9 DECEMBER 7, 2012
REQUEST NO. 133: Please provide a copy of each adjusting journal entry proposed by
the Company's independent auditors in the two (2) most recent audits of the Company. Please
include within your response the documentation supporting these adjustments and documentation
supporting any items that were "passed upon" and not reflected in the Company's financial
records or financial statements.
REQUEST NO. 134: Please provide copies of the employee newsletters issued during
2011 and 2012.
REQUEST NO. 135: Please list any costs included in the test year (12 months ended
June 30, 2012) related to sporting or entertainment events, including but not limited to season
tickets or sky boxes. Provide the accounts where these costs are booked and if above the line
and not already removed in this filing, please include any and all explanations as to the business
purpose of those expenses.
REQUEST NO. 136: Please provide copies of all affiliated Company receivables and
payables with Avista Utilities as of December 31, 2011 and June 30, 2012. Please provide
details of the transactions including amounts, dates, explanations, and calculations.
Dated at Boise, Idaho, this 3 41,day of December 2012.
V
Karl T. Klein
Deputy Attorney General
Technical Staff: Keith Hessing/101-102
Mike Louis/103-105
Rick Sterling/ i 06-109
Kathy Stockton/i 10-ill
Joe Terry/1 12
Patricia Harms/i 13-136
i:umisc:prodreq/avuel2.8avugl 2.7kkkhmlrpsklsjtph prod req7
SEVENTH PRODUCTION REQUEST
TO AVISTA 10 DECEMBER 7, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF DECEMBER 2012,
SERVED THE FOREGOING SEVENTH 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
VP & CHIEF COUNSEL
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
P0 BOX 2564
BOISE ID 83702
E-MAIL: joe(mcdevitt-mil1er.com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
515 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
greg(2irichardsonandoleary.com
ELECTRONIC SERVICE ONLY:
Howard Ray
Clearwater Paper Corporation
[e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019N 17TH ST.
BOISE ID 83702
E-mail: [e-mail]
KELLY 0 NOR WOOD
VP STATE & FED REG
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
LARRY A CR0 WLEY
THE ENERGY STRATEGIES
INSTITUTE INC
55495 CLIFFSEDGE AVE
BOISE ID 83716
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadingc2imindspring.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710N. 6TH ST
BOISE ID 83702
E-mail: botto(idahoconservation.org
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-mail: kmiller(snakeriveralliance.org
SECRETARY
CERTIFICATE OF SERVICE