20121220Staff 147-159 to Avista.pdf

LC 20 P7q I:51
ir_- PUMB- JTIUTI
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
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
F.11 lrofftzly~
NINTH 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 THURSDAY,
JANUARY 10, 2013.
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
NINTH PRODUCTION REQUEST
TO AVISTA 1 DECEMBER 20, 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. 147: Please provide a schedule showing all vehicle retirements since
January 2011.
a.Please include the vehicle description, book value of the vehicle, date of retirement
and method of disposal.
b.If the vehicle was sold at auction, please also provide the sales price for each vehicle.
c.If the vehicle was donated, please also provide the cost basis used for the donation.
REQUEST NO. 148: Please provide copies of the overhead memos from January 2012
to present.
REQUEST NO. 149: Please provide a description and associated details of the cost
savings to date for the HVAC renovation. Please quantify the savings and reference the location
in the general rate case where the savings are shown.
REQUEST NO. 150: Referencing the confidential memo provided at the onsite audit
from Ryan Beam about the Post Falls Headgate Project, please provide the economic analysis for
performing all the other tasks at this time as opposed to waiting.
REQUEST NO. 151: Please explain the method(s) Avista used to jurisdictionally
allocate the following capital expenditure projects, explaining why each service level and
jurisdiction received the allocation percentages used in this rate case:
a.Dollar Road Land Purchase and Facility Expansion Project. Also, please explain why
this project is allocated 72.38% of the total cost to electric when this project is
described to be primarily needed for natural gas.
b.Gas Distribution Non-revenue Blanket;
c.Electric Distribution Minor Blanket;
NINTH PRODUCTION REQUEST
TO AVISTA 2 DECEMBER 20, 2012
d.Wood Pole Management; and
e.Jackson Prairie Storage.
REQUEST NO. 152: Please provide the portion of costs (capital - 2.5m, O&M, and
other costs) required for the CNG filling station included in the Dollar Road Land Purchase and
Facility Expansion Project.
REQUEST NO. 153: Please provide a forecast for the percent of total volume of CNG
projected to be sold to the public at the Dollar Road CNG facility for the test year and for
proforma 2012 and 2013.
REQUEST NO. 154: Please explain the discrepancy in the allocation percentages used
to allocate General Plant Common System, Transportation Common System, and Software AN
Common reflected in Andrew's Capital Expense allocation workpapers and the 4-factor
allocation percentages contained in Andrew's workpapers Part 2 (August 2012).
REQUEST NO. 155: Please provide a map of Avista's natural gas transportation and
distribution system showing all mains and laterals for Idaho, Washington, and Oregon.
REQUEST NO. 156: Please provide the number and dollar amount of SO2 and
renewable energy credits included in the Company's revenue requirement for this rate case.
REQUEST NO. 157: Please refer to the direct testimony of Mr. Morris, page 25 and 26,
where he discusses the Performance Excellence Initiative.
a.Provide the total cost to Avista of this initiative by year, to-date. Specifically include
the total dollar amount included in the test period on a total system and Idaho-only
basis.
b.Please explain whether any costs indentified in (a) have been removed and the total
dollar amount removed from this or previous rate cases.
NINTH PRODUCTION REQUEST
TO AVISTA 3 DECEMBER 20, 2012
c. Please quantify total cost savings from the initiative included in the test period (actual
results and/or pro formed into the case) and identify where these costs are accounted
for.
REQUEST NO. 158: Please provide all documents/reports prepared by Avista and
Booz & Co. related to the Performance Excellence Initiative.
REQUEST NO. 159: To the extent not previously provided, please provide the
following regarding the consultant retained to independently look at opportunities for Avista to
work more efficiently:
a.Engagement letter regarding all work performed from inception of engagement to
date;
b.Contract(s) for all services performed from inception of engagement to date;
c.All draft and final reports/studies produced by the consultant;
d.A listing of all efforts and process changes undertaken as a result of any
recommendations made, stating with specificity what was undertaken and when
implementation occurred. Please include within your response the cost and/or
savings associated with these changes by FERC account;
e.Any follow up studies or reports prepared that analyze or describe/summarize the
results of changes/process improvements undertaken;
f.Total cost for the consultant charged to electric operations, gas operations, and non-
utility operations by month by FERC account for the period since inception of the
engagement to date; and
g.Rate treatment currently, or previously, being requested or previously afforded such
consultant costs.
NINTH PRODUCTION REQUEST
TO AVISTA 4 DECEMBER 20, 2012
Dated at Boise, Idaho, this 2O'- day of December 2012.
4110 19
Karl T. Klein
Deputy Attorney General
Technical Staff: Joe Terry/147-150
Mike Louis/151-156
Patricia Harms/ i 57-159
i:umisc:prodreq/avuel2.8avugl2.7kkjtmlph prod req9
NINTH PRODUCTION REQUEST
TO AVISTA 5 DECEMBER 20, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF DECEMBER 2012,
SERVED THE FOREGOING NINTH 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]
ELECTRONIC SERVICE ONLY:
PAUL KIMBALL
AVISTA CORPORATION
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: dreadingmindspring.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710N. 6TH ST
BOISE ID 83702
E-MAIL: bottoidahoconservation.org
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: kmi11ersnakerivera11iance.org
KELLY 0 NOR WOOD
VP STATE & FED REG
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: ioeCmcdevitt-mi11er.com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
greg(2irichardsonando1eary.com
ELECTRONIC SERVICE ONLY:
HOWARD RAY
CLEAR WATER PAPER CORPORATION
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019N 17TH ST.
BOISE ID 83702
E-MAIL: [e-mail]
SECRETAY
CERTIFICATE OF SERVICE