20120822Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6864
RECEIVED
2012AUG22 PM 2:09
DAht.; UTILITIES COMMISSIO;
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S APPLICATION TO )
ELIMINATE THE ANNUAL COMPLIANCE )
FILING REQUIREMENT FOR ASSET )
RETIREMENT OBLIGATION (ARO) )
ESTABLISHED IN ORDER NO. 29962. )
)
CASE NO. AVU-E-12-05
AVU-G-12-04
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Neil Price, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 32605 on August 1, 2012, in
Case No. AVU-E-12-05 and AVU-G-12-04, submits the following comments.
BACKGROUND
On June 29, 2012, Avista Corporation (hereinafter "Avista" or "Company") submitted an
Application seeking authority to discontinue its annual compliance filing requirement established
in Order No. 29962 to submit all journal entries made under the requirements of Statement of
Financial Accounting Standards (SFAS) 143.1
l Since Order No. 29962 was issued, Generally Accepted Accounting Principles (GAAP) have been codified.
Codification Topic 410 incorporates SFAS 143, Asset Retirement Obligations, into the U.S. GAAP Codification of
Accounting Standards. In this document, Staff will continue to reference the SFAS that originated the requirement.
STAFF COMMENTS 1 AUGUST 22, 2012
Avista states that, pursuant to Commission Order No. 29962, the Company is recording
regulatory assets or liabilities associated with the implementation of SFAS 143. Attached to its
Application, Avista included copies of its 2011 SFAS 143 annual compliance filing.
The Company stated that it removed the Asset Retirement Obligation (ARO) transactions
from its monthly Results of Operations. These transactions are not included in the Company's
earnings or in any rate request in the Company's general rates cases. Avista notes that the journal
entries are routine in nature and that the Company has made the compliance filings for the past
five years.
Avista confirmed that it will continue to maintain the same records regarding the ARO
transactions and would make them available to Staff and any other party upon request.
STAFF ANALYSIS
Staff has reviewed the Company's filing and agrees with the Company's proposal to
discontinue its annual compliance filing. These entries are now routine and do not require annual
reporting. Regulatory oversight will remain unaltered as the entries in the annual compliance
filing will remain accessible to Staff upon request. Confirmation that these transactions are not
included in any rate request can be verified during the Company's general (and other) rate cases.
STAFF RECOMMENDATION
Staff recommends that the annual compliance filing requirement established in Order No.
29962 to submit all journal entries made under the requirements of SFAS 143 be discontinued.
Respectfully submitted this 2 2.'( day of August 2012.
Neil Price
Deputy Attorney General
Technical Staff: Patricia Harms
I :umisc:comments/avue 12. 5_avug I 2.4npph comments
STAFF COMMENTS 2 AUGUST 22, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF AUGUST 2012,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NOS. AVU-E-12-05 & AVU-G-12-04, BY E-MAILING AND MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
KELLY 0 NOR WOOD
VP STATE & FED REG
AVISTA CORPORATION
P0 BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
J%a SECRETARY/
CERTIFICATE OF SERVICE