20130109Staff 182-199 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
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
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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
ELEVENTH 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
WEDNESDAY, JANUARY 30, 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
ELEVENTH PRODUCTION REQUEST
TO AVISTA 1 JANUARY 9, 2013
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 182: Please explain which, if any, of the reliability compliance,
reliability improvements, or reliability replacement projects resulted in increased transmission
capacity. Please list the line segments and provide the location and additional capacity acquired
as a result of the 2011 and 2012 transmission investments. See Kinney pg. 29-35, Table 3 and
Table 5.
REQUEST NO. 183: Please provide a copy of the new general funding agreement for
ColumbiaGrid. See Kinney pg. 5, lines 8-15.
REQUEST NO. 184: Referencing Kinney's work papers, please provide all actual
transmission sales (Account 456) from July 2012 to present.
REQUEST NO. 185: Please provide a schedule showing the dollar amount and gallons
of fuel used by year for the Avista Fleet during the last 5 years (2008 —2012).
REQUEST NO. 186: Please provide a list of the Major O&M projects for the last five
years (2008 —2012). For each project, please include a description, length of project, completion
date, estimated cost and final cost.
REQUEST NO. 187: Please update the response to Production Request No. 36 and
provide the property tax payments through December 31, 2012. Please include within your
response the account number and amount for the property taxes paid during the test year (twelve
months ended June 30, 2012) and the calendar year (twelve months ended December 31, 2012)
and the amount allocated to Idaho Electric and Idaho Natural Gas.
ELEVENTH PRODUCTION REQUEST
TO AVISTA 2 JANUARY 9, 2013
REQUEST NO. 188: Please identify all the regulatory case costs included in the
Company's filing. Please identify in your response the type of case (Washington 2012 general
rate case, Idaho 2011 general rate case as examples), accounts posted, payee, transaction
description, dates posted, method of assigning costs to the various jurisdictions, and the dollar
amount included in the Idaho Electric case and the Idaho Natural Gas case.
REQUEST NO. 189: Please refer to the Company's response to Production Request
No. 130, Attachment A, page 6 of 8 discussion of Harbor Oil Inc., Site. Please identify the dates,
accounts and amounts to which the remedial investigation and feasibility study were expensed.
Please include within your response the method used to assign the costs and the dollar amount
included in the Idaho Electric case and the Idaho Natural Gas case.
REQUEST NO. 190: Please refer to the Company's response to Production Request
No. 128, item b and c. In that response the Company identified the third-party costs associated
with Avista Corporation's annual report and SEC filings. Please identify the internal costs
associated with those activities. If the internal costs associated with these activities are not
separately tracked, please state so in your response.
REQUEST NO. 191: Please expand the Company's response to Production Request No.
128, item b and c to include the underlying accounting detail (similar to the Company's
confidential response to Production Request No. 125) organized to total $147,203 and $72,371,
respectively. Please also provide the allocation of each of these amounts to Idaho Electric and
Idaho Natural Gas as contained in the Company's filing.
REQUEST NO. 192: According to the most recent information obtained from Avista in
2010, Avista employed the vendor Kubra to process credit card, debit card and online bank
account payments from Avista customers. Has Avista changed vendors? If so, what is the name
of the current vendor?
ELEVENTH PRODUCTION REQUEST
TO AVISTA 3 JANUARY 9, 2013
REQUEST NO. 193: In CY 2010, the fee that a customer was required to pay to the
vendor to have a payment processed to pay the Avista utility bill was $4.25. Has that dollar
amount changed recently? If so, what is the current fee?
REQUEST NO. 194: For CY 2011 and 2012, please provide the following information
regarding payment transactions conducted by Idaho customers: (a) total number of payments
received using any transaction method; (b) total number of credit card payments received; (c)
total number of debit card payments received; (d) total number of checks (either electronic or
paper) received; (e) total number of checks-by-phone received; (f) total number of one-time
online authorized withdrawals from customers" bank accounts initiated by the customer; and
(g) total number of authorized monthly withdrawals from customers' bank accounts initiated by
Avista (automatic payment).
REQUEST NO. 195: For CY 2010, 2011 and 2012, please provide the following
information for all Idaho accounts: (a) by month and year, the total number of accounts with
deposits; (b) by month and year, the total dollar amount associated with those deposits; (c) by
year, the average annual percentage of accounts with deposits.
REQUEST NO. 196: For CY 2010, 2011 and 2012, please provide the following
information for Idaho residential accounts: (a) the monthly and annual total number of accounts
with deposits; (b) the average annual percentage of accounts with deposits; and (c) the deposit
dollar amount on accounts.
REQUEST NO. 197: For CY 2010, 2011 and 2012 by month and year, please provide
the following information: (a) the total number of residential accounts with payment
arrangements, and (b) the total number of payment arrangements made on those residential
accounts.
REQUEST NO. 198: For CY 2010, 2011 and by month and year, please provide the
following information: (a) the total number of residential accounts with payment arrangements
ELEVENTH PRODUCTION REQUEST
TO AVISTA 4 JANUARY 9, 2013
that defaulted, and (b) the total number of payment arrangements made on those residential
accounts that defaulted.
REQUEST NO. 199: For October through February of 2010 and 2011 and October
2011 through December 2011 by month, please provide the number of Idaho accounts that
signed up for Moratorium protection. Of these accounts, how many received LIHEAP
assistance?
Dated at Boise, Idaho, this day of January 2013.
. 1
Karl T. Klein
Deputy Attorney General
Technical Staff: Johanna Bell/i 82-184
Joe Terry/185-186
Patricia Harms/ i 87-19 1
Marilyn Parker/192-199
i:umisc:prodreq/avuel2.8avugl2.7kkjbjtphmp prod reql 1
ELEVENTH PRODUCTION REQUEST
TO AVISTA 5 JANUARY 9, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF JANUARY 2013,
SERVED THE FOREGOING ELEVENTH 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
5549 S CLIFFSEDGE AVE
BOISE ID 83716
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(2i,mindspring.corn
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N. 6TH ST
BOISE ID 83702
E-MAIL: botto(idahoconservation.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
BOISE ID 83702
E-MAIL: [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
gregQa
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]
do 1 a03
SECRETARY
CERTIFICATE OF SERVICE