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HomeMy WebLinkAbout20040622Stockton Direct.pdfECEfVEO (2::) F" iL. E D r:::J 2DO:1 JUt:i F'r1 I: 4.9 LlWEs Jdt;tii~~SIO.N BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION IN THE MATTER OF THE APPLICATION OF A VISTA CORPORATION FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC AND NA TU RAl GAS SERVICE TO ELECTRIC AND NATURAL GAS CUSTOMERS IN THE STATE OF IDAHO. ) CASE NO. AVU-O4-) AVU-O4- DIRECT TESTIMONY OF KATHY STOCKTON IDAHO PUBLIC UTiliTIES COMMISSION JUNE 21 , 2004 Please state your name and business address? My name is Kathy Stockton.My business address is 472 West Washington Street / Boise / Idaho. By whom are you employed and in what capaci ty? I am employed as a Senior Audi tor by the Idaho Public Utilities Commission. Please describe your educational background and professional experience. I received my B. B. A. degree in Accounting from Boise State University in December 1992.Following graduation I was employed by the Idaho State Tax Commission as a Tax Enforcement Technician.In that capaci ty performed desk audits individual state lncome tax re turns.was promoted to Tax Audi tor and later to Senior Tax Audi tor.In my capacity as audi tor / I performed audi ts on Special Fuel and Motor Fuel Tax returns / International Fuels Tax Agreement Returns and Special Fuel User tax returns.I accepted employment wi the Idaho Public Utilities Commission Staff in July 1995.I attended the National Association of Regulated Utilities Commissioners Annual Regulatory Studies program at Michigan State Uni versi ty.I have conducted numerous audi ts and cases for electric / gas / and water util i ties. I have previously presented testimony before this CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON / K Staff Commission. What is the purpose of your testimony? The purpose of my testimony is to present Commission Staff (Staff) adjustments to the revenue requirement proposed by Avista Corporation (Avista; Company) in Company wi tness Falkner's testimony. propose adjustments to both net operating income and rate base for both gas and electric operations.I will also discuss the Company s Commission Basis Adj ustments and why they are appropriate, as well as Staff's acceptance of the Company s Pro forma Insurance adj ustment. Would you please summarize your testimony in thi s ease? I recommend 12 Staff adj ustments Yes. Electric and 5 Gas) to the Company-proposed test year revenue requirement in the following areas: Electric (1 )Coyote Springs 2 - increases net lncome by $1 72/000; decreases rate base by $1/621 000; and decreases the total revenue requirement by $504/000. (2 )Capital Costs of Small Generation Options - decreases rate base by $ 539 / 000; and decreases the total revenue requirement by $ 7 8/ 000 . CASE NOS. AVU-E- 04 -l/AVU-G- 04-06/21/04 (Di)STOCKTON / K Staff Gas (3 ) (4 ) (5 ) Non-Executive Labor - increases net income by $26, 000; and decreases the total revenue requirement by $41,000. Executive Labor - increases net income by $ 9, 000; and decreases the total revenue requirement by $14, 000. Vegetation Management - increases net income by $288 , 000; and decreases the total revenue requirement by $451,000. (6 )Accounts Receivable Program fees - increases net income by $357,000; and decreases the total revenue requirement by $ 5 5 8 , 0 0 0 . (7 )Corporate Fees and Expenses - increases net income by $ 74 , 000; and decreases the total revenue requirement by $116,000. (1 )Gas Inventory - decreases rate base by 572,000; and decreases the total revenue requirement by $227,000. (2 )Non-Executive Labor - increases net income by $ 6 , 000; and decreases the total revenue requirement by $9,000. (3 )Executi ve Labor - increases net income by $2,000; and decreases the total CASE NOS. AVU-E- 04 -l/AVU-G- 04-06/21/04 STOCKTON, K.Staff (Di) revenue requirement by $3,000. (4 )Accounts Receivable Program fees - increases net income by $ 5 6 , 000; and decreases the total revenue requirement by $ 8 8 , 0 0 0 . (5 )Corporate Fees and Expenses - increases net income by $17 , 000; and decreases the total revenue requirement by $27,000. Did Staff perform an audit in preparing its case? In assessing the Company s Application,Yes. Staff reviewed and audi ted the Company 1 s books and records for the 2002 test year. Does Staff agree with the use of a 2002 test year? Staff accepts the average of monthly average, 2002 test year and agrees with the beginning results of operations. Does Staff accept the allocation method used by the Company? Staff has reviewed the method the Company uses to assigned and allocate common costs and common general plant between services and between jurisdictions. Staff finds the allocation methodology to be sound and acceptable. CASE NOS. AVU-04-1/AVU-04- 06/21/04 (Di)STOCKTON , K. Staf f testimony? Do you have any exhibits that support your Yes. in my testimony: I am sponsoring 12 exhibits discussed Staff Exhibits No. 109 through 115 related to my electric adjustments; and Staff Exhibits No. 116 through 120 related to my gas adjustments. ELECTRIC SECTION Would you please enumerate the Standard Commission Basis Adj ustments to Electric Resul ts of Operations proposed by Avista? The Company adj ustments detailed in Company Exhibi t No. 14, beginning wi th page 4 of 10, by column letter designation are: f . l . J . 1 . Per Results Report Deferred FIT Rate Base Deferred Gain on Office BuildingColstrip 3 AFUDC Elimination Colstrip Common AFUDC Kettle Falls Disallowance MOPS Deferred costs Weatherization & DSM Investment Customer Advances Revenue Adjustment Hydro Relicensing Adjustment Eliminate Franchise Fees Property Tax Uncollectible Expense Regulatory ExpenseInj uries and Damages Federal Income Tax Restate Debt Interest Idaho PCA Nez Perce Settlement Adjustment Remove Mise Tariffs Adjustment CASE NOS. AVU-04-1/AVU-04-06/21/04 STOCKTON , K.Staf f (Di) PGE Monetization Amortization Adjustment Payroll Clearing Adj ustment The Company adjustments begin with the Column b, which starts with the December 2002 Results of Opera t ions Report.The Resul ts of Operations reports are filed monthly, for both gas and electric, with the Commission.The amounts in the report are for the twelve months ended December 31, 2002.The net operating lncome dollar amounts tie back to the Company s general ledger. The Company computes rate base using the average of monthly averages method. Does the Staff accept the Standard Commission Basis Adjustments? Staff has audi ted these adj ustments andYes. finds them acceptable. Please explain the reasonableness of the Company Pro Forma Insurance adjustment and why Staff accepts the Company s adj ustment. The Company s adjustment updates the 2002 lnsurance expense for general liability, directors and officer liability, property and other policies to the actual cost of insurance policies that are in effect for 2004 .Staff has verified that the policy expenses have increased, and that these changes are known and measurable.Staff has verified that the insurance costs CASE NOS. AVU-E- 04 -l/AVU-G- 04-06/21/04 (Di)STOCKTON, K.Staf f that are properly charged to the varlOUS non-utility operations have been excluded from the Company adj ustment Staff accepts this Company adjustment as filed. STAFF ELECTRIC ADJUSTMENTS TO RATE BASE & NET OPERATING INCOME Please explain Staff's adjustment to the Company s Pro Forma Coyote Springs 2 adj ustment. Staff's adj ustment brings the Company adjustment to the actual balance as of April 30 , 2004. This adj ustment incorporates the latest insurance payment received for the transformer.In a confidential response to Staff Production Request No. 268, the Company indicated that addi tional insurance proceeds had been received. Staff included the actual balance as of April 30, 2004 to capture those insurance proceeds.Staff's adjustment includes the effect of this insurance payment on the Company s net plant investment in the Coyote Springs proj ect; in contrast, the Company s filing estimated the net operating income numbers for 2004 and based the rate base numbers on the average of the proj ected plant balances at 12/31/2003 and 12/31/2004.I have verified that the Coyote Springs 2 proj ect was transferred from Avista Power (an un-regulated subsidiary of Avista Corporation) to Avista Utilities at cost.Staff was CASE NOS. AVU-04-1/AVU-04- 06/21/04 (Di)STOCKTON, K. Staf f provided wi th access to the plant records for Coyote Springs 2 during two on-site audits in Spokane.Staf f witness Sterling has reviewed the prudency of this proj ect What is the effect of Staff's adjustment to the Company s Pro Forma Coyote Springs 2 adj ustment? Staff's adj ustment increases Idaho electric net income by $172 000; decreases rate base by $1,621,000; and decreases the total revenue requirement by $504 000 as shown on Staff Exhibit No. 109. Please explain Staff's adjustment to the Company s adj ustment - Capital Costs Small Gen Options. In Order No. 29130 issued August 9, 2002 in Case No. AVU-02-6 the Commission stated: We find that the PCA mechanism is for recovery of variable costs and is not an appropriate vehicle for recovery of capi tal costs. Accordingly, we directthe Company to remove the capi tal costs associated with Kettle Falls Bi-Fuel ($ 5 6 , 598), Devi l' s Gap ($ 96, 743), and Othello ($744,884) from the PCA deferralaccounts together wi th corresponding adjustments to the carrying charges. Order 29130 at 15. The Company proposed to amortize the total of the capi tal costs and the related carrying charge of $921 184 over a 5-year period beginning January 2003, and Commission Staff concurred.Staff also agreed that the CASE NOS. AVU-E- 04 -1/AVU-04-06/21/04 (Di)STOCKTON, K.Staff direct inclusion in rates of any amortized expense would be addressed in a future rate proceeding.Consequently, the Company has asked to include the capital cost amortization expense in rates.The Company has al so asked to earn a return on the unamortized capital cost balance by including it in rate base. Staff finds it reasonable to include the $184 000 in amortized expenses for recovery in this rate case.However , Staff does not find it reasonable to include the $829,000 unamortized balance in rate base. The Company had pursued various proj ects in order to avoid the addi tional high-costs purchases of energy from the wholesale markets during the 2000/2001 energy crlSlS.The proj ects were terminated prior to completion after the energy crlSlS subsided.The proj ects were never completed or beneficial (used and useful) to the customers. Therefore, the Company should not be entitled to earn a return on assets that are not used and useful.Because the plant investment is not used and useful , it does not meet the regulatory requirement for inclusion in rate base.Recovery of the actual capi tal expendi tures wi thout earning a return on the investment is the appropriate regulatory treatment in this case.Staff therefore removes the rate base portion of the Company s pro forma adj ustment CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON , K.Staff What is the effect of Staff's adj ustment to the Company s adjustment - Capital Costs Small Gen Options? Staff's adjustment decreases Idaho electric ra te base by $ 539 , 000; and decreases the total revenue requirement by $78 000 as shown on Staff Exhibit No. 110. Please explain Staff's adj ustment to the Company s Pro Forma Labor Non-Executive and Executive adj ustments. Traditionally, ratemaking principles have allowed for the inclusion of known and measurable changes to test year expenses.Wages and salaries in the test year are usually adjusted to reflect pay changes in the current level of expense and better match the expenses on a going-forward basis.The Company has included two adjustments that reflect known and measurable changes to the test period union and non-union wages and salaries, as well as known and measurable changes to the executive salaries.The test period expenses for wages and salaries is restated with the increases in wage and salaries for 2002 , 2003, and 2004 , as if they were in place during the entire pro forma test year.When the Company filed its case, the amount of the increase for 2004 was estimated to be 3.5% for both union and non-union employees. response to Staff Production Request 245, the actual CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON, K.Staff salary increase in 2004 for non-union employees was 2. and not the 3.5% used in calculating the Company Pro Forma Labor adjustments for Executive and Non-executive labor. Staff's adj ustments replace the estimate used by the Company with the actual salary increases for 2002 , 2003, and 2004.Staff's adj ustment not only updates the non- union budgeted 3.5% salary increase to the actual 2. increase, but also updated the Pro Forma Labor Executive adjustment for changes in salaries and staffing that resulted from the retirement of several key executives and the subsequent hiring of replacements for those posi tions. What is the effect of Staff's adj ustment to the Company s Pro Forma Labor Non-Executive adjustment? Staff's adj ustment increases Idaho electric net operating income by $26,000, and decreases the total revenue requirement by $41 000 as shown on Staff Exhibit No. 111. What is the effect of Staff's adjustment to the Company s Pro Forma Labor - Executive adj ustment? Staff's adjustment increases Idaho electric net operating income by $9,000 and decreases the total revenue requirement by $14 000 as shown on Staff Exhibit No. 112. Please explain Staff's adj ustment to the Company s Pro Forma Vegetation Management adj ustment. CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON, K Staff Staff's adj ustment reflects replacing the Company s requested vegetation management expenses wi th an average of the actual amounts expended for vegetation management during the years 1998 through 2003.It is appropriate to use actual dollars, as these amounts are known and measurable, rather than an estimate based on a budget.The budgeted number is just that - a budgeted number, an estimate.Because the Company has some flexibili ty in the budgeting process, and because it is not known what the company will actually expend for vegetation management, it is more appropriate to look at what has taken place in the past.The past expenses are known and measurable.The vegetation management budget has been reduced in many years based on the Company cash flow and earnings resul ts.There is no reason to believe it will be different in the future. In the prior electric rate case (AVU-98-11) Staff found that the five-year average of the actual amounts booked for tree-trimming costs (vegetation management) was $1 205,893.The five year average similar to that used in the last rate case lS $1 217 048.The average of the actual amounts booked for vegetation management for the years 1998 through 2003 is $1,322 464. Staff notes that the amount recorded in 2002 was abnormally low at $550,255.The amounts expended by year CASE NOS. AVU-04-1/AVU-04- 06/21/04 (Di)STOCKTON , K. Staf f tend to fluctuate because of the nature of the program. Staff is aware that the vegetation management program expendi tures are not the same from year to year, as integrated vegetation management includes specific treatments for each tree-trimming circuit, and each circuit is different in size, and the requirements for each circuit are different.The integrated management approach does not take a one size fits all approach, thus the fluctuation in expenditures from year to year. Staff proposes to adj ust the Company s Pro Forma Vegetation Management adjustment to reflect the average amount actually expensed during the six-year period from 1998 through 2003.Staff asserts that a SlX- year average is reasonable, given the fluctuation in the amounts actually expended from year to year.The last electric rate case used a 1997 test year.The six-year average reflects the activity in vegetation management from the last rate case through the end of 2003.This slx-year average allows the Staff to use known and measurable expenses In calculating an appropriate amount for future recovery in rates.The average reflects the variability in the amount expended from year to year due to the cyclical nature of the vegetation management program , and recognlzes that the amount recorded in the test year is abnormally low in comparison to other years. CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON, K.Staff What is the effect of Staff's adj ustment to the Company s Pro Forma Vegetation Management adj ustment? Staff's adjustment increases Idaho electric net operating income by $288,000; and decreases the total revenue requirement by $451,000 as shown on Staff Exhibit No. 113. Please explain Staff's Account Receivable Program Fees adjustment. This adjustment removes the fees associated wi th the Company s Accounts Receivable Sale Program.The Accounts Receivable Sale Program was initiated in 1988 when the Company entered into a five-year agreement to sell $30 million of its accounts receivable.At that time, the effect of the program was to reduce the Company s need for financing and provide the Company wi a source of funds at a much lower effective cost.This arrangement was a true sale of assets because the accounts receivable were sold wi thout recourse to the Company.The Company previously agreed in a letter to Staff that the sale of the accounts receivable and all costs associated wi th the program would not be included or recovered through the Company s cost of capital.Since 1988, the Company has expanded the limit to sell up to $125 million of the Company s accounts receivables. In Production Request 261 , the Staff asked CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON , K.Staff the Company to "explain and quantify the benefi ts of the Accounts Receivable Sale program for the ratepayer.The Company stated , in response to Production Request 261: The Accounts Receivable Sale program is a cost effective approach of funding the cost of carrying customer receivables on the Company s balance sheet. The al ternati ve to factoring accountsreceivable would be a working capi tal addi tion to rate base at the Company authorized rate of return. While the response does not specifically explain the benefits of the program for the ratepayer , it does state that the program is like a working capital addition to rate base, or a substitute for such a program. Why have you proposed disallowing the fees associated wi th the Accounts Receivable Sale Program? I have calculated a negative cash working capi tal for the Company.Because the Company asserts that the Accounts Receivable Sale Program is a substitute for a working capi tal requirement and the Company does not have a working capi tal requirement, I have removed the fees associated wi th the Accounts Receivable Program. What is the effect of Staff's Accounts Receivable Program fees adj ustment? Staff's adj ustment increases Idaho electric net operating income by $357 000 and decreases the total revenue requirement by $558,000 as shown on Staff Exhibit CASE NOS. AVU-E- 04 -l/AVU-G- 04-06/21/04 (Di)STOCKTON, K Staff No. 114. Please explain working capi tal. Working capi tal is the amount of capi tal needed to run the business between the time expenses are disbursed to provide the services paid for by consumers and the revenues from those services are received. Working capital includes prepayments, inventories, and cash working capi tal.Cash working capi tal is the average amount of capital (cash) that is supplied by the investors over and above the investment in plant and other rate base items that is required to fill the gap between the time when expendi tures are made to provide services and the time collections are received for these services. Historically this Commission has used the balance sheet method for determining cash working capi tal for large utilities. What is the balance sheet method for determining cash working capi tal? The balance sheet method of cash working capital evaluates the need for cash working capital by identifying whether investors , usually shareholders, are providing the working capi tal or whether it is being provided from some other source.Using the balance sheet method I have calculated a negative cash working capi tal for Avista Corporation.At the corporate level , the cash CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON , K.Staff working capital requirement is a negative $139,799 million.This negative amount indicates that shareholders were not the source of working capi tal , and subsequently no return to the shareholders should be allowed.The Company does not readily maintain the information necessary to perform a working capital analysis at the Avista Utilities level , let alone for Avista Utilities, Electric Operations, at the Idaho Jurisdictional level. Therefore , Avista Corp data must be used to calculate cash working capi tal. Did the Company request a return on cash working capi tal? No, the Company did not request a return on cash working capi tal, nor did they request a return on materials and supplies (inventory), and prepayments. Has the Commission authorized negative cash working capi tal? Historically, the Commission has not recognized negative cash working capital , finding that the cash working capital allowance in those cases should zero.In Case No. SOU-94-1 the Commission stated, Because the Commission has never recognized negative cash working capital, we find that the working capital allowance in this case should be zero.Order No. 25785 at CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON , K.Staff Consequently, to the extent the Accounts Receivable Sale Program is a substitutes for working capital, the program fees too should not be allowed recovery. Please explain Staff's Corporate Fees and Expenses adj ustment Staff's Corporate Fees and Expenses adjustment allocates 50% of the amounts recorded in FERC account 930., Corporate Fees and Expenses, Electric Operations, for the Idaho jurisdiction , to affiliates to reflect the benefit received by the other affiliates from these activities.In Staff Production Request 112, the Staff inquired of the Company how the Board of Directors fees and other expenses were allocated to Avista Utilities and to the other subsidiaries.The request specifically asked the Company to: identify expenses associated wi bond issuances , analyst fees, rating agencies, Board of Directors ' fees, and shareholder expenses and how they are allocated to Avista Corp. and its subsidiaries, including the utility and Idaho Gas and Electric Operations. The Company s response did not identify the expenses specifically.The response further stated: Other costs related to Avista s debt and equity financing activities, such as Board of Director fees, rating agency fees and other shareholder costs, are CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON , K.Staff generally recorded to FERC account 930. Miscellaneous General Expenses. Theseaccount 930 costs are primarily assigned the common-to-all utility code ' 7' which spreads those expenses initially to both electric and gas operations, and then to all state jurisdictions, through application of the ' Four Factor Did the Company s response provide the amount of or indicate that the other subsidiaries were allocated any port ion of these expenses? The Company did not provide Staff withNo. any information showing the subsidiaries ' portion of these expenses prior to being allocated to the utility operations using the common-to-all utility code.This utility code does not include the subsidiaries in the allocation process.Therefore , due to the nature of the allocation method, any apportionment to the subsidiaries must be done prior to the expenses being allocated to utility operations through the current allocation process. The Board of Directors of Avista Corporation responsible for all subsidiaries including Avista Utilities.Because the other subsidiaries are included in the required SEC filings, and the Annual Report to Shareholders, among other things, the other subsidiaries benefit from these activities, and therefore should bear some of the costs.Therefore, the Staff adjustment asslgns 50% of these activities to the other affiliated CASE NOS. AVU-04-1/AVU-04- 06/21/04 (Di)STOCKTON , K.Staff subsidiaries. Did you allocate 50% of the total in the 930.2 account to the other subsidiaries? No, I allocated 50% of sub-account 930. Corporate Fees and Expenses to the other subsidiaries, slnce this was the sub-account used by the Company for Board of Directors ' fees, shareholder expenses, and other corporate expenses. How did you determine that 50% was the appropriate allocation percentage? Absent any further information from the Company, I used the 50% allocation based on what other utility companies in Idaho use to allocate a portion of the Board of Directors fees and other related expenses to affiliates.In Case No. IPC-E- 03 -13, Staff wi tness Leckie recommended that the cost of the Document Management System be allocated equally between the ratepayers and the shareholders, because that is the same allocation percentage (50%) that IDACORP uses to allocate Board of Director fees.Moreover , Order No. 29505 from that case states: The Commission finds that including the entire cost of the Shareowners Document Management System in rate base would be unfair to ratepayers. Because the system benefits IDACORP in its administrative responsibilities much like the fees paid to its Board of Directors, we find that it should be allocated the CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON , K.Staff same as the Board of Director s fees inthis case. Therefore, only one-half the cost of the system should be included in Idaho Power s rate base. Similarly, Intermountain Gas Company s utility operations is allocated 50% of the Board of Directors fees and other similar expenses , with the remaining 50% allocated to other affiliates. What is the effect of Staff's Corporate Fees and Expenses adj ustment? Staff's adjustment increases Idaho electric net operating income $74,000; and decreases the total revenue requirement by $116,000 as shown on Staff Exhibit No. 115. Do you have addi tional adj ustments for Electric Operations? No I do not. GAS SECTION Would you please enumerate the Standard Commission Basis Adjustments to Gas Results of Operations proposed by Avista? The Company adjustments as detailed in Company Exhibi t No. 15, beginning wi th page 4 of 8, by column letter designation are: c . Per Resul ts Report Deferred FIT Rate Base Deferred Gain on Office BuildingGas Inventory CASE NOS. AVU-E- 04 -l/AVU-G- 04-06/21/04 (Di)STOCKTON, K.Staff f . l . Weatherization & DSM Investment Customer Advances Eliminate Franchise Fees Property Tax Uncollectible Expense Regulatory Expense AdjustmentInj uries and Damages Federal Income Tax Restate Debt InterestPayroll Clearing Adj ustment J . 1 . The Company adjustments begin with the Column b, which starts with the December 2002 Results of Operations Report.The Results of Operations reports are filed monthly, for both gas and electric, with the Commission.The amounts in the report are for the twelve months ended December 31 , 2002.The net operating lncome dollar amounts tie back to the Company s general ledger. The Company computes rate base using the average of monthly averages method. Does the Staff accept the Standard Commission Basis Adj ustments? Staff has audited these adjustments and with the exception of the Gas Inventory adjustment, Staff finds them acceptable. " Q.Please explain the reasonableness of the Company Pro Forma Insurance Adjustment and why Staff accepts the Company s adj ustment. The Company s adjustment updates the 2002 lnsurance expense for general liabili ty, directors and CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON, K.Staff officer liability, property and other policies to the actual cost of insurance policies that are in effect for 2004 .Staff has verified that the policy expenses have increased, and that these changes are known and measurable.Staff has verified that the insurance costs that are properly charge to the various non-utility operations have been excluded from the Company adj ustment Staff accepts this adjustment as filed by Avista. STAFF GAS ADJUSTMENTS TO RATE BASE & NET OPERATING INCOME Please explain Staff's adjustment to the Company s Gas Inventory Pro Forma adj ustment This adjustment removes the Company s Pro Forma Gas Inventory adj ustment from rate base.Al though the Company has been including a gas inventory adj ustment since 1984 , Staff has not identified a rationale to justify continuing its current inclusion in rate base. Gas inventory is normally considered part of working capi tal.Working capi tal includes inventories, prepayments , minimum and compensating bank balances, and" cash working capi tal.Typically three kinds of inventories are included in working capi tal:fuel stocks, construction material in inventory, and materials and supplies held for operating and maintenance purposes. Working capital is generally allowed in recognition that a CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON , K.Staff company pays some of its expenses before it recel ves revenue, and to the extent shareholders supply that money, they should earn a return on it.However , as described previously in my testimony, Staff identified a negative cash working capital for Avista Corporation so cash working capi tal is not an appropriate rate base addi tion. Therefore, including gas inventory in rate base for this case also is not appropriate.As previously discussed, the Commission has not historically recognized negative cash working capi tal cash working capi tal zero. What adj ustment? and had consequently found that the allowance in those cases should be the effect of Staff's Gas Inventory Staff's Gas Inventory adj ustment decreases Idaho gas rate base by $1,572 000; and decreases the total revenue requirement by $227 000 as shown on Staff Exhibit No. 116. Please explain Staff's adj ustment to the Company s Executive and Non-Executive Labor Pro Forma adj ustments. As previously stated in the electric section ratemaking principles have traditionally allowed for the inclusion of known and measurable changes to test year expenses.Wages and salaries in the test year are usually CASE NOS. AVU-E- 04 -l/AVU-G- 04-06/21/04 (Di)STOCKTON , K.Staf f adjusted to reflect pay changes in the current level of expense and better match the expenses on a going-forward basis.As previously discussed, Staff's adj ustments replace the estimate used by the Company wi th the actual salary increases for 2002, 2003, and 2004.Staff' adjustment not only updates the non-union budgeted 3. salary increase to the actual 2.9% increase, but also updated the Pro Forma Labor - Executive adjustment for changes in salaries and staffing that resulted from the retirement of several key executives and the subsequent hiring of replacements for those positions. What is the effect of Staff's adj ustment to the Company s Pro Forma Labor Non-Executive adj ustment? Staff's adjustment increases Idaho gas net operating income by $6,000; and decreases the total revenue requirement by $9,000 as shown on Staff Exhibit No. 117. What is the effect of Staff's adj ustment to the Company s Pro Forma Labor Executive adj ustment? Staff's adj ustment increases Idaho gas net operating income by $2 000; and decreases the total revenue requirement by $3,000 as shown on Staff Exhibit No. 118. Please explain Staff's adj ustment to the Accounts Receivable Sale Program Fees? CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON, K.Staff As stated in the electric section of my testimony, this adj ustment removes the fees associated wi th the Company s Accounts Receivable Sale Program.The Company has equated the fees associated with this program wi th working capi tal.As I stated previously, Avista Corporation has a negative cash working capital making a working capitol aqjustment or expenditures associated with working capi tal inappropriate in this case.As previously discussed, the Commission has not historically recognized negative cash working capital and has found that the cash working capi tal allowance in those cases should be zero. therefore, Staff has simply removed these fees in this case. What is the effect of Staff's Accounts Receivable Program fees adjustment? Staff's adjustment increases Idaho gas net operating incom~ by $56,000; and decreases the total revenue requirement by $88,000 as shown on Staff Exhibit No. 119. Please explain Staff's Corporate Fees and Expenses adj ustment As I stated in the electric section, Staff' Corporate Fees and Expenses adjustment allocates 50% of the amounts recorded in the corresponding natural gas FERC account 1930.27, Corporate Fees and Expenses, Gas CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON , K.Staff Operations, for the Idaho jurisdiction to the other subsidiaries for the same reasons enumerated. What is the effect of Staff's Corporate Fees and Expenses adjustment? Staff's adj ustment increases Idaho gas net operating income by $17 000; and decreases the total revenue requirement by $27 000 as shown on Staff Exhibit No. 120. Do you have additional adjustments for Gas Operations? No, I do not. Does this conclude your direct testimony? Yes, it does. CASE NOS. AVU-04-1/AVU-04-06/21/04 (Di)STOCKTON, K Staff AVISTA UTILITIES ELECTRIC PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) Line No. A vista Utilities. Electric Operations Coyote Springs 2 Adjustment Net Adjustment Idaho COYOTE SPRINGS 2 Company Adjustment Idaho Staff Adjustment IdahoDESCRIPTION REVENUES Total General Business Interdepartmental Sales Sales For Resale Total Sales of Electricity Other Revenue Total Electric Revenue EXPENSES Production and Transmission Operating Expenses Purchased Power Depreciation and Amortization Taxes Total Production & Transmission 535 681 296 122 (174) (94) 268 629 949 Distribution Operating Expenses Depreciation Taxes Total Distribution (32) (32) (29) (29) 16 Customer Accounting17 Customer Service & Information18 Marketing Administrative & General19 Operating Expenses20 Depreciation21 Taxes22 Total Admin. & General23 Total Electric Expenses 24 Operating Income before FIT 917 652 265 917)652)265 021)(928) 896 ($1 724)$172 Federal Income Taxes25 Current Accrual26 Deferred Income Taxes 35. 27 NET OPERATING INCOME RATE BASE PLANT IN SERVICE28 Intangible29 Production30 Transmission31 Distribution32 General33 Total Plant in Service 34 ACCUMULATED DEPRECIATION 35 ACCUM. PROVISION FOR AMORTIZATION36 Total Accum. Depreciation & Amort.37 GAIN ON SALE OF BUILDING 38 DEFERRED TAXES 096 772 519 324) 519 096 629 291 534 805) (95) (95)629 534 (502) $36 965 (413) $35,34439 TOTAL RATE BASE (~1 621) ($504)40 Revenue Requirement Increase (Decrease) Exhibit No. 109 Case No. A VU-04- A VU -04- K. Stockton, Staff 6/21/04 AVISTA UTILITIES ELECTRIC PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) Avista Utilities. Electric Operations CAPITAL COSTS OF SMALL GENERATION OPTIONSCapital Costs of Small Generation Options AdjustmentLine Company Adjustment Staff Adjustment Net AdjustmentNo. DESCRIPTION Idaho Idaho Idaho REVENUES To~al General Business Interdepartmental Sales Sales For Resale Total Sales of Electricity Other Revenue Total Electric Revenue EXPENSES Production and Transmission Operating Expenses Purchased Power Depreciation and Amortization Taxes Total Production & Transmission 184 184 184 184 Distribution Operating Expenses Depreciation Taxes Total Distribution 16 Customer Accounting17 Customer Service & Information18 Marketing Administrative & General19 Operating Expenses20 Depreciation21 Taxes22 " Total Admin. & General23 Total Electric Expenses 24 Operating Income before FIT 184 184 (184)(184) Federal Income Taxes25 Current Accrual26 Deferred Income Taxes 35. (64) $120 (64) $12027 NET OPERATING INCOME RATE BASE PLANT IN SERVICE28 Intangible29 Production30 Transmission31 Distribution32 General33 Total Plant in Service 34 ACCUMULATED DEPRECIATION 35 ACCUM. PROVISION FOR AMORTIZATION36 Total Accum. Depreciation & Amort.37 GAIN ON SALE OF BUILDING 38 DEFERRED TAXES 829 (829) 829 (829) (290) $539 290 39 TOTAL RATE BASE ($539) $7840 Revenue Requirement Increase (Decrease) Exhibit No. 110 Case No. A VU-04- A VU -04- K. Stockton, Staff 6/21/04 Line No. Avista Utilities - Electric Operations Non-Executive Labor Adjustment DESCRIPTION REVENUES Total General Business Interdepartmental Sales Sales For Resale Total Sales of Electricity Other Revenue Total Electric Revenue EXPENSES Production and Transmission Operating Expenses Purchased Power Depreciation and Amortization Taxes Total Production & Transmission Distribution Operating Expenses Depreciation Taxes Total Distribution 16 Customer Accounting17 Customer Service & Information18 Marketing Administrative & General19 Operating Expenses20 Depreciation21 Taxes22 Total Admin. & General23 Total Electric Expenses 24 Operating Income before FIT Federal Income Taxes25 Current Accrual26 Deferred Income Taxes 27 NET OPERATING INCOME RATE BASE PLANT IN SERVICE28 Intangible29 Production30 Transmission31 Distribution32 General33 Total Plant in Service 34 ACCUMULATED DEPRECIATION 35 ACCUM. PROVISION FOR AMORTIZATION36 Total Accum. Depreciation & Amort.37 GAIN ON SALE OF BUILDING 38 DEFERRED TAXES 39 TOTAL RATE BASE 40 Revenue Requirement Increase (Decrease) AVISTA UTILITIES ELECTRIC PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) NON-EXECUTIVE LABOR ADJUSTMENT Company Adjustment Idaho Staff Adjustment Idaho 390 378 35. 390 378 272 270 (11) 260 259 140 133 273 254 273 254 084 044 084)044) (379)(365) $705 $679 Net Adjustment Idaho (12) (12) (2) (1 ) (7) (1 ) (19) (19) (40) $26 $41 Exhibit No. 111 Case No. A VU-O4- A VU -O4- K. Stockton, Staff 6/21/04 Line No. Avista Utilities - Electric Operations Executive Labor Adjustment DESCRIPTION REVENUES Total General Business Interdepartmental Sales Sales For Resale Total Sales of Electricity Other Revenue Total Electric Revenue EXPENSES Production and Transmission Operating Expenses Purchased Power Depreciation and Amortization Taxes Total Production & Transmission Distribution Operating Expenses Depreciation Taxes Total Distribution 16 Customer Accounting17 Customer Service & Information18 Marketing Administrative & General19 Operating Expenses20 Depreciation21 Taxes22 Total Admin. & General23 Total Electric Expenses 24 Operating Income before FIT Federal Income Taxes25 Current Accrual26 Deferred Income Taxes 27 NET OPERATING INCOME RATE BASE PLANT IN SERVICE28 Intangible29 Production30 Transmission31 Distribution32 General33 Total Plant in Service 34 ACCUMULATED DEPRECIATION 35 ACCUM. PROVISION FOR AMORTIZATION36 Total Accum. Depreciation & Amort. 37 GAIN ON SALE OF BUILDING 38 DEFERRED TAXES 39 TOTAL RATE BASE 40 Revenue Requirement Increase (Decrease) AVISTA UTILITIES ELECTRIC PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) EXECUTIVE LABOR ADJUSTMENT Company Adjustment Idaho Staff Adjustment Idaho 35. (17) (17) (23)(9) (8)(3) $15 Net Adjustment Idaho (17) (17) (14) ($14) Exhibit No. 112 Case No. A VU-04- A VU -04- K. Stockton, Staff 6/21/04 Line No. A vista Utilities - Electric Operations Vegetation Management Adjustment DESCRIPTION REVENUES Total General Business Interdepartmental Sales Sales For Resale Total Sales of Electricity Other Revenue Total Electric Revenue EXPENSES Production and Transmission Operating Expenses Purchased Power Depreciation and Amortization Taxes Total Production & Transmission Distribution Operating Expenses Depreciation Taxes Total Distribution 16 Customer Accounting17 Customer Service & Information18 Marketing Administrative & General19 Operating Expenses20 Depreciation21 Taxes22 Total Admin. & General23 Total Electric Expenses 24 Operating Income before FIT Federal Income Taxes25 Current Accrual26 Deferred Income Taxes 27 NET OPERATING INCOME RATE BASE PLANT IN SERVICE28 Intangible29 Production30 Transmission31 Distribution32 General33 Total Plant in Service 34 ACCUMULATED DEPRECIATION 35 ACCUM. PROVISION FOR AMORTIZATION36 Total Accum. Depreciation & Amort.37 GAIN ON SALE OF BUILDING 38 DEFERRED TAXES 39 TOTAL RATE BASE 40 Revenue Requirement Increase (Decrease) AVISTA UTILITIES ELECTRIC PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) VEGETATION MANAGEMENT ADJUSTMENT Company Adjustment Idaho Staff Adjustment Idaho Net Adjustment Idaho 150 155 150 155 070 617 (8) 057 609 (448) (453) 35. 207 764 443 207)(764)443 (422)(267)155 $785 ($497)$288 Exhibit No. 113 Case No. A VU-04- A VU -04- K. Stockton, Staff 6/21/04 AVISTA UTILITIES ELECTRIC PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) A vista Utilities - Electric Operations Accounts Receivable Fees Adjustment Line No. ACCOUNTS RECEIVABLE FEES Company Adjustment Idaho Staff Adjustment Idaho Net Adjustment IdahoDESCRIPTION REVENUES Total General Business Interdepartmental Sales Sales For Resale Total Sales of Electricity Other Revenue Total Electric Revenue EXPENSES Production and Transmission Operating Expenses Purchased Power Depreciation and Amortization Taxes Total Production & Transmission Distribution Operating Expenses Depreciation Taxes Total Distribution 16 Customer Accounting17 Customer Service & Information18 Marketing (556)556 Administrative & General19 Operating Expenses20 Depreciation21 Taxes22 Total Admin. & General23 Total Electric Expenses 24 Operating Income before FIT 550 550 550 550 193 193 $357 $357 Federal Income Taxes25 Current Accrual26 Deferred Income Taxes 35. 27 NET OPERATING INCOME RATE BASE PLANT IN SERVICE28 Intangible29 Production30 Transmission31 Distribution32 General33 Total Plant in Service 34 ACCUMULATED DEPRECIATION 35 ACCUM. PROVISION FOR AMORTIZATION36 Total Accum. Depreciation & Amort.37 GAIN ON SALE OF BUILDING 38 DEFERRED TAXES 39 TO!AL RATE BASE 40 Revenue Requirement Increase (Decrease)$558 Exhibit No. 114 Case No. A VU-04- A VU -O4- K. Stockton, Staff 6/21/04 AVISTA UTILITIES ELECTRIC PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) Avista Utilities - Electric Operations Corporate Fees and Expenses Adjustment Line No. CORPORATE FEES AND EXPENSES Company Adjustment Idaho Staff Adjustment IdahoDESCRIPTION REVENUES Total General Business Interdepartmental Sales Sales For Resale Total Sales of Electricity Other Revenue Total Electric Revenue EXPENSES Production and Transmission Operating Expenses Purchased Power Depreciation and Amortization Taxes Total Production & Transmission Distribution Operating Expenses Depreciation Taxes Total Distribution 16 Customer Accounting17 Customer Service & Information18 Marketing Administrative & General19 Operating Expenses20 Depreciation21 Taxes22 Total Admin. & General23 Total Electric Expenses 24 Operating Income before FIT (115) (115) 114 114 $74 Federal Income Taxes25 Current Accrual26 Deferred Income Taxes 35. 27 NET OPERATING INCOME RATE BASE PLANT IN SERVICE28 Intangible29 Production30 Transmission31 Distribution32 General33 Total Plant in Service 34 ACCUMULATED DEPRECIATION 35 ACCUM. PROVISION FOR AMORTIZATION36 Total Accum. Depreciation & Amort.37 GAIN ON SALE OF BUILDING 38 DEFERRED TAXES 39 TOTAL RATE BASE 40 Revenue Requirement Increase (Decrease) Net Adjustment Idaho (115) (115) (114) 114 $74 $116 Exhibit No. 115 Case No. A VU-04- A VU-04- K. Stockton, Staff 6/21/04 Line No. Avista Utilities - Gas Operations Gas Inventory Adjustment Description REVENUES Total General Business Total Transportation Other Revenues Total Gas Revenues EXPENSES Exploration & Development Production City Gate Purchases Purchased Gas Expense Net Nat. Gas Storage Trans Total Production Underground Storage Operating Expenses Depreciation Taxes Total Underground Storage Distribution Operating Expenses Depreciation Taxes Total Distribution 18 Customer Accounting19 Customer Service & Information20 Sales Administrative and General21 Operating Expenses22 Depreciation23 Taxes24 Total Admin. & General25 Total Gas Expense 26 Operating Income before FIT Federal Income Taxes27 Current Accrual28 Deferred FIT29 Amort ITC 30 NET OPERATING INCOME RATE BASE PLANT IN SERVICE Underground Storage Distribution Plant General Plant Total Plant in Service ACCUMULATED DEPRECIATION35 Underground Storage36 Distribution Plant37 General Plant38 Total Accum. Depreciation 39 DEFERRED TAXES 40 GAS INVENTORY41 GAIN ON SALE OF BUILDING 42 TOTAL RATE BASE 43 Revenue Requirement Increase (Decrease) AVISTA UTILITIES GAS PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) GAS INVENTORY ADJUSTMENT Company Adjustment Idaho Staff Adjustment Idaho 35. 572 572 Net Adjustment Idaho 572) ($1 572) ($227) Exhibit No. 116 Case No. A VU-04- A VU -04- K. Stockton, Staff 6/21/04 Line No. Avista Utilities - Gas Operations Non-Executive Labor Adjustment Description REVENUES Total General Business Total Transportation Other Revenues Total Gas Revenues EXPENSES Exploration & Development Production City Gate Purchases Purchased Gas Expense Net Nat. Gas Storage Trans Total Production Underground Storage Operating Expenses Depreciation Taxes Total Underground Storage Distribution Operating Expenses Depreciation Taxes Total Distribution 18 Customer Accounting19 Customer Service & Information20 Sales Administrative and General21 Operating Expenses22 Depreciation23 Taxes24 Total Admin. & General25 Total Gas Expense 26 Operating Income before FIT Federal Income Taxes27 Current Accrual (at 35%)28 Amort ITC29 Deferred FIT 30 NET OPERATING INCOME RATE BASE PLANT IN SERVICE Underground Storage Distribution Plant General Plant Total Plant in Service ACCUMULATED DEPRECIATION35 Underground Storage36 Distribution Plant37 General Plant38 Total Accum. Depreciation 39 DEFERRED TAXES 40 GAS INVENTORY41 GAIN ON SALE OF BUILDING 42 TOTAL RATE BASE 43 Revenue Requirement Increase (Decrease) AVISTA UTILITIES GAS PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) NON-EXECUTIVE LABOR ADJUSTMENT Company Adjustment Idaho Staff Adjustment Idaho 111 111 (3) 108 108 268 258 (268)(258) (94)(90) ($174)($168) Net Adjustment Idaho (4) (1 ) (1 ) (4) (4) (10) ($9) Exhibit No. 117 Case No. A VU-O4- A VU -04- K. Stockton, Staff 6/21/04 Line No. Avista Utilities - Gas Operations Executive Labor Adjustment Description REVENUES Total General Business Total Transportation Other Revenues Total Gas Revenues EXPENSES Exploration & Development Production City Gate Purchases " Purchased Gas Expense Net Nat. Gas Storage Trans Total Production Underground Storage Operating Expenses Depreciation Taxes Total Underground Storage Distribution Operating Expenses Depreciation Taxes Total Distribution 18 Customer Accounting19 Customer Service & Information20 Sales Administrative and General21 Operating Expenses22 Depreciation23 Taxes24 Total Admin. & General25 Total Gas Expense 26 Operating Income before FIT Federal Income Taxes27 Current Accrual (at 35%)28 Amort ITC 29 ": Deferred FIT 30 NET OPERATING INCOME RATE BASE PLANT IN SERVICE Underground Storage Distribution Plant General Plant Total Plant in Service ACCUMULATED DEPRECIATION35 Underground Storage36 Distribution Plant37 General Plant38 Total Accum. Depreciation 39 DEFERRED TAXES 40 GAS INVENTORY41 GAIN ON SALE OF BUILDING 42 TOTAL RATE BASE 43 Revenue Requirement Increase (Decrease) AVISTA UTILITIES GAS PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) EXECUTIVE LABOR ADJUSTMENT Company Adjustment Idaho Staff Adjustment Idaho (1) (1) (13)(10) (5)(4) Net Adjustment Idaho (3) (3) (3) ($3) Exhibit No. 118 Case No. A VU-04- A VU -04- K. Stockton, Staff 6/21/04 AVISTA UTILITIES GAS PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) Line No. Avista Utilities - Gas Operations Accounts Receivable Fees Adjustment Staff Adjustment IdahoDESCRIPTION REVENUES Total General Business Total Transportation Other Revenues Total Gas Revenues EXPENSES Exploration & Development Production City Gate Purchases Purchased Gas Expense Net Nat. Gas Storage Trans Total Production Underground Storage10 Operating Expenses11 i Depreciation12 Taxes13 Total Underground Storage Distribution Operating Expenses Depreciation Taxes Total Distribution 18 Customer Accounting19 Customer Service & Information20 Sales Administrative and General21 Operating Expenses22 Depreciation23 Taxes24 Total Admin. & General25 Total Gas Expense 26 Operating Income before FIT Federal Income Taxes27 Current Accrual28 Deferred FIT29 Amort ITC 30 NET OPERATING INCOME RATE BASE PLANT IN SERVICE Underground Storage Distribution Plant General Plant Total Plant in Service ACCUMULATED DEPRECIATION35 Underground Storage36 Distribution Plant37 General Plant38 Total Accum. Depreciation 39 DEFERRED TAXES 40 GAS INVENTORY41 GAIN ON SALE OF BUILDING 42 TOTAL RATE BASE 43 Revenue Requirement Increase (Decrease) ACCOUNTS RECEIVABLE FEES ADJUSTMENT Company Adjustment Idaho (87) 35% $56 Net Adjustment Idaho (87) $56 $88 Exhibit No. 119 Case No. A VU-O4- A VU -04- K. Stockton, Staff 6/21/04 Avista Utilities - Gas Operations Corporate Fees and Expenses Adjustment LineNo. Description REVENUES Total General Business Total Transportation Other Revenues Total Gas Revenues EXPENSES Exploration & Development Production City Gate Purchases Purchased Gas Expense Net Nat. Gas Storage Trans Total Production Underground Storage Operating Expenses Depreciation Taxes Total Underground Storage Distribution Operating Expenses Depreciation Taxes Total Distribution 18 Customer Accounting19 Customer Service & Information20 Sales Administrative and General21 Operating Expenses22 Depreciation23 Taxes24 Total Admin. & General25 Total Gas Expense 26 Operating Income before FIT Federal Income Taxes27 Current Accrual (at 35%)28 Amort ITC29 Deferred FIT 30 NET OPERATING INCOME RATE BASE PLANT IN SERVICE Underground Storage Distribution Plant General Plant Total Plant in Service ACCUMULATED DEPRECIATION35 Underground Storage36 Distribution Plant37 General Plant38 Total Accum. Depreciation 39 DEFERRED TAXES 40 GAS INVENTORY41 GAIN ON SALE OF BUILDING 42 TOTAL RATE BASE 43 Revenue Requirement Increase (Decrease) AVISTA UTILITIES GAS PRO FORMA ADJUSTMENTS IDAHO PUBLIC UTILITIES COMMISSION STAFF TWELVE MONTHS ENDED DECEMBER 31 2002 (OOO'S OF DOLLARS) CORPORATE FEES AND EXPENSES ADJUSTMENT Company Adjustment Idaho Staff Adjustment Idaho (26) (26) $17 Net Adjustment Idaho (26) (26) (26) ($27) Exhibit No. 120 Case No. A VU-04- A VU -04- K. Stockton, Staff 6/21/04 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF JUNE 2004 SERVED THE FOREGOING DIRECT TESTIMONY OF KATHY STOCKTON, IN CASE NO. AVU-04-l/AVU-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE FOLLOWING: DAVID J. MEYER SR VP AND GENERAL COUNSEL VISTA CORPORATION PO BOX 3727 SPOKANE WA 99220-3727 KELLY NORWOOD VICE PRESIDENT STATE & FED. REG. AVIS T A UTILITIES PO BOX 3727 SPOKANE WA 99220-3727 CONLEY E WARD GIVENS PURSLEY LLP PO BOX 2720 BOISE ID 83701-2720 DENNIS E PESEAU, PH. D. UTILITY RESOURCES INC 1500 LIBERTY ST SE, SUITE 250 SALEM OR 97302 CHARLES L A COX EV ANS KEANE 111 MAIN STREET PO BOX 659 KELLOGG ID 83837 BRAD M PURDY ATTORNEY AT LAW 2019 N 17TH ST BOISE ID 83702 CERTIFICATE OF SERVICE