20230216Staff to AVU1-34.pdf

CHRIS BURDIN i D
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION c A
PO BOX 83720
BOISE,IDAHO 83720-0074 ',¾(208)334-0314
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.AVU-E-23-01AVISTACORPORATIONFORTHE)AVU-G-23-01AUTHORITYTOINCREASEITSRATESAND)CHARGES FOR ELECTRIC AND NATURAL )FIRST PRODUCTIONGASSERVICETOELECTRICANDNATURAL)REQUESTOF THEGASCUSTOMERSINTHESTATEOFIDAHO.)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy Attorney General,requests that Avista Corporation dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and informationas soon as
possible,but no later than THURSDAY,MARCH 9,2023.
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 or informationproduced.
Please provide answers to each question;supporting workpapersthat provide detail or are
the source of information used in calculations;and the name,job title,and telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTIONREQUEST
TO AVISTA CORPORATION 1 FEBRUARY 16,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUESTNO.1:Please provide copies of the monthlytrial balances from January
2021 throughthe most current month available.Please supplement your response when
additional months become available throughout2023.
REQUESTNO.2:Please provide a copy of the Company Chart of Accounts.
REQUESTNO.3:Please provide a list of all external attorneys who performed services
for the Company or who were paid by the Company for services during 2021 and 2022.Please
list the amounts paid,accounts charged,and date of payment.Please also provide a brief
summary of the services performed.If services were performed in support of a docketed
federal/state court or regulatory action,please identify the case name,case number,and
jurisdiction.For each expense,please illustrate how the charge was allocated to the Company's
jurisdictions.
REQUESTNO.4:Please provide the total amount that the Company spent on the
followingactivities for 2021 and 2022,and show how the Company allocated the amounts
between the Avista Utilities operating division and the rest of the Company and its subsidiaries.
a.Internal auditing expenses
b.The Company's annual report
c.Deloitte &Touche and Deloitte Consulting
d.Rating agencies
e.All software or informationsystem-related issues
f.Board of Directors compensation,travel expenses,and meeting expenses
g.Corporate or chartered aircraft
h.Travel and training for all shared executives of Avista Utilities and affiliates
i.Insurance coverage
j.Overhead items includingutilities,property taxes,security services,and other
corporate headquarter expenses
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 FEBRUARY 16,2023
k.All other allocated expenses.
REQUESTNO.5:Please provide a copy of all regulatory orders relating to Avista
Utilities or its subsidiaries issued by state agencies in Oregon,Washington,Alaska,or the
Federal Energy Regulatory Commission (FERC)in 2021 through 2023 to date.
REQUESTNO.6:Please summarize all of the Company's environmental cleanup costs
during 2021 and 2022.Please show all account numbers and the amount booked to each
subaccount.
REQUESTNO.7:Please provide access to all employee newsletters issued in 2021 and
2022.
REQUESTNO.8:Please provide a matrix identifying the major capital expenditure
approval levels that includes the dollar level of authorization by employee title,division,and
company.Please include within your response the dollar level at which the individual capital
expendituresrequire approval by the Company's Board of Directors ("Board of Directors").
REQUESTNO.9:Please provide an analysis of any sales of land and/or plant for the
years 2021 through 2023 to date,if any.Please show gains,losses,and supporting
documentation includingaccounting entries for removal of items from rate base.
REQUESTNO.10:Please provide the details of any planned sales of land and/or plant
for the remainder of 2023 through 2024.Please include within your response the estimated date
of these sales and planned accounting treatment.
REQUESTNO.11:Please provide a list of "out-of-period adjustments"and
"extraordinary items"for the years 2021 through 2023 to date.
FIRST PRODUCTIONREQUEST
TO AVISTA CORPORATION 3 FEBRUARY 16,2023
REQUESTNO.12:Please provide a schedule showing injuries and damages claims
over $1,000 for the years 2016 through 2023 to date.Please include within your response the
description of each item,the amount for each item,and the account charged.
REQUESTNO.13:Please provide the details of all advertising expenses recorded
above the line includingaccount and subaccounts where posted,dates posted,vendor names,
explanations,and amounts posted during 2021 and 2022.
REQUESTNO.14:Please provide copies of all advertisements used during 2021 and
2022 and correlate the advertisement with the specific detail provided in the Company's
response to Request No.13.
REQUESTNO.15:Please provide copies of all billinginserts for 2021 and 2022.
Please indicate the states where they were sent.Please also provide a schedule showing the
amount and account numbers charged for all costs to produce,print,and distribute the inserts.
REQUESTNO.16:Please prepare a schedule for plant in service that includes project
name and description,and the dollar amount of each project closed to plant in service in excess
of $2 million from 2021 through 2023 to date.
REQUESTNO.17:Please provide copies of the cost/benefit analysis,internal rates of
return,or similar analysis for each capital project included in the Company's response to Request
No.16.
REQUESTNO.18:Please provide all documents the Company used to demonstrate the
benefits realized by the Company for each capital project included in the Company's response to
Request No.16.
REQUESTNO.19:Please provide copies of the monthly,quarterly,and annual
comparison of operating and capital budget to actuals expendituresfor 2020 through 2023 to
date.Please include within your response a narrative explanation for budget variations.This
FIRST PRODUCTIONREQUEST
TO AVISTA CORPORATION 4 FEBRUARY 16,2023
should include,but not be limited to,written operating and capital budget variance reports and
explanations used by Company officers and managers to monitor and control budgets under their
responsibility.Please supplement your response as additional information becomes available
throughout 2023.
REQUESTNO.20:Please provide copies of all Audit Reports issued by the
Company's internal auditors for all audits completed during 2021 through 2023 to date.
REQUESTNO.21:Please provide a copy of each adjusting journal entry proposed by
the Company's independentauditors in the two most recent audits of the Company.Please
include within your response the documentation supporting these adjustments,and the
documentation supporting any items that the Company decided not to adjust that are not reflected
in the Company's financial records and/or financial statements.
REQUESTNO.22:Please provide a list of all leased items from 2021 through2023 to
date.Please separate capital leases from operating leases and show the dates,terms,amounts,
and accounts used for each lease.
REQUESTNO.23:Please provide a schedule of prepaid items for 2021 through2023
to date showing amounts posted,vendor names,explanations,and accounts to which these items
were booked.Please include within your response any significant changes to prepaid items
occurring or planned to occur in 2023 and 2024.
REQUESTNO.24:For each officer of the Company,please provide the total dollar
amount of remuneration for 2019 through 2022.Please separate by year,salary,incentive pay,
options,benefits,and other.For each officer,please provide the percentages of his or her total
remunerationthat is allocated to other subsidiaries each year along with the basis for that
allocation.
REQUESTNO.25:Please provide the followingmonthlydirect labor related
information as recorded for 2020 through 2022.Information,where applicable,should be listed
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 5 FEBRUARY 16,2023
by O&M expense,other expense,construction and other account groups (listed by functional
categories,i.e.,generation,transmission,distribution,customer,A&G,etc.).Please provide the
information on a system-wide basis,and on an Idaho electric and Idaho gas jurisdiction basis.
The response should include wages and salaries for each employee category (officer,exempt,
non-exempt,and union),paid time-off,overtime,bonuses,incentive pay,and overheads for
pension,benefits,and payrolltaxes.Please also include average and year-end number of
employees by employee category.Include part-time and temporary employees as full-time
equivalents.
REQUESTNO.26:Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years.Please provide any additional workforce
reduction programs planned for 2022 through2023.
REQUESTNO.27:Please summarize all benefit and retirement plans provided to any
classification of Company employees.Please also include any changes that have occurred to the
benefits/accruals during the past five years.
REQUESTNO.28:Please provide the amount of SupplementalExecutive Retirement
Plan expense,if any,which is included in the test year.
REQUESTNO.29:Please provide copies of the Company's pension and actuarial
reports for the years 2020 through 2022.Also,please provide any actuarial calculations and
documentation that shows the development of FAS 87 expenses (ASC 715 Compensation -
Retirement Benefits as codified),Company contributions,balances,and assumptions.
REQUESTNO.30:Please provide access to the Board of Directors'meeting minutes
for each meeting in 2021 through 2023 to date.
REQUESTNO.31:Please provide copies of the Board of Directors'materials
distributed for/at meetings from 2021 through2023 to date.Please also include the same for the
Compensation Committee.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 6 FEBRUARY 16,2023
REQUESTNO.32:To the extent not previously included in the Company's response to
Request No.31,please provide access to copies of all studies used to determine employee
compensation,includingexecutive compensation,and explanations of how the Company applied
them in the years 2020 through2023 to date.
REQUESTNO.33:Please provide the fixed costs associated with the use of the
Company-owned aircraft,such as pilot salaries,hangar fees,etc.Please provide the total dollar
amount posted in 2021 and 2022 at the system level,the account(s)posted,and how those costs
were allocated or assigned to the Idaho electric and gas operations.
REQUESTNO.34:Please provide the variable costs associated with the use of the
Company-owned aircraft.Please provide dollar amounts posted in 2021,2022 and 2023 to date,
at the system level,the account(s)posted,and how those costs were allocated or assigned to the
Idaho electric and gas operations.
DATED at Boise,Idaho,this 16th day of February 2023.
Chris Burdin '
Deputy AttorneyGeneral
i:umise:prodreq/avue23.l_avug23.lcbde prod req l
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 7 FEBRUARY 16,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF FEBRUARY 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NOS.AVU-E-23-
01/AVU-G-23-01,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727E-mail:[e-mail] E-mail:[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE