20100323Kensok Di.pdf

DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL OF
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P . 0 . BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727TELEPHONE: [phone]
FACSIMILE: [phone]
r ': ~,'; :.~ i' J
Hit J 23 n: is
BEFORE THE IDAHO PULIC UTILITIES COMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRI C AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO
CASE NO. AVU-E-10-01
CASE NO. AVU-G-10-01
DIRECT TESTIMONY OF
JAMES M. KENSOK
FOR AVISTA CORPORATION
(ELECTRIC AND NATURAL GAS)
1 I. INODUCTION
2 Q.Please state your name, emloyer and business
3 address.
4 A.My name is James M. Kensok.I am employed by
5 Avista Corporation as the Vice-President and Chief
6 Information Officer (CIO). My business address is 1411 E.
7 Mission Avenue, Spokane, Washington.
8 Q.Mr.Kensok,please provide inform tion
9 pertaining to your educational background and professional
10 exprience.
11 A.I am a graduate of Eastern Washington University
12 wi th a Bachelor of Arts Degree in Business Administration,
13 majoring in Management Information Systems.I have
14 experience through direct application and management of
15 Information Services over the course of my 31 year
16 information technology career.I joined the Company in
17 June of 1996.Over the past 14 years, I have spent
18 approximately one year in Avista's Internal Audi t
19 Department as an Information Systems Auditor with
20 involvement in performing internal information systems
21 compliance and technology audits. I have been in the
22 Information Services Department for approximately 13 years
23 in a variety of management roles directing and leading
Kensok, Di 1
Avista Corporation
1 information technology and systems; planning, operations,
2 system analysis, network advancement, telecommunications,
3 information security,applications deve 1 opmen t,
4 outsourcing agreements, contract negotiations, technical
5 support, cost management, data management and strategic
6 development.I was appointed Vice-President and CiO in
7 January of 2007.
.8 Q.What is the scope of your testimny?
9 A.My testimony will describe the increase in costs
10 associated with Avista's information technology, and the
11 proposed pro forma adjustments included in this filing.
12 These costs increases include additional expenses for
13 supporting applications utilized by the Company,
14 additional required security and compliance requirements,
15 and addi tional dollars required for hosting fees,
16 application fees, software maintenance and license fees.
17 Q.Please provide som background regarding
18 Avista's Informtion Services (IS) Departmnt's operating
19 needs.
20 A.Avista has been, and continues to be, focused on
21 utilizing cost-effective information and operating
22 technology to meet business and customer needs.
23 Maintaining appropriate levels of information and
Kensok, Di 2
Avista Corporation
1 operating technology funding is increasingly important,
2 and Avista and its customers rely more and more on
3 computer systems and technology to meet day-to-day
4 business operations.
5 Computer hardware, software, networks and related
6 tools are becoming more indispensable, and more complex,
7 as the business environment and customer expectations
8 grow, and more information and transactions flow on-line.
9 There continues to be exponential growth in the use of
10 Avista networks for customers transacting on-line and for
11 Avista to manage its delivery system and mobile workforce.
12 For example, electronic bill presentment and electronic
13 payment provides convenience for customers to understand
14 their bill and remit payment electronically, as well as
15 access extensive information from the Company related to
16 areas such as energy efficiency and safety.As Mr.
17 Kopczynski explains in his testimony, our automated voice
18 response call system now handles 47.3% of incoming calls
19 from our customers.Mobile dispatch of service crews
20 involves wireless technology in Company field vehicles,
21 and provides improved customer service for construction
22 locates and service work, at lower cost.wi thout these
23 technologies,Avista could not meet customer and
Kensok, Di 3
Avista Corporation
1 regulatory expectations, nor achieve many of the cost
2 savings we have accomplished through the use of
3 technology.
4 Q.What is causing an increase in costs related to
5 Informtion System?
6 A.One factor driving an increase in is costs is
7 the life of the systems themselves.Unlike other utility
8 equipment which may have useful lives of 30 to 50 years or
9 longer, is hardware and software is relatively short-
10 lived, and must be enhanced or replaced more frequently
11 than other utility tools and equipment.In addition,
12 among ,other things, increasing requirements related to
13 reliability and security related to our operations and
14 communications have required significant ongoing
15 investment in our is hardware, software and staff.
16 As an example,Avista is implementing a new
17 compliance application necessary for meeting the North
18 American Electric Reliabili ty Corporation (NERC)
19 requirements.Currently, the activity for documenting
20 Avista's controls for NERC compliance is done manually
21 which is very labor intensive.By implementing the
22 compliance application, the required documentation is
23 easily accessible for updating and for auditing.To
Kensok, Di 4
Avista Corporation
1 continue to operate manually would require the addition of
2 1-2 staff positions.
3 The need for additional development and support of
4 Avista's outage management and construction design
5 applications is growing.The value of these applications
6 is measured in efficiency through improved customer
7 response time for outage restoration.Further, it
8 provides the customer with real-time access via the
9 telephone or Web on estimated restoration times.The
10 construction design system is a tool used by Avista
11 engineers to design electric and natural gas
12 infrastructure.The tool reduces the amount of time the
13 design engineer spends in the field, as most all of the
14 existing facility and geographic information they need is
15 contained wi thin the application.As a result, they are
16 able to design construction jobs more quickly and
17 accurately for the customer, which reduces the overall
18 cost of the project and on-going support.These systems
19 are expanding, and as a result require additional hours
20 for maintenance and support.
21 Q.As is requiremnts change over, time, is there
22 also opportunity to reduce costs associated with these
23 tools?
Kensok, Di 5
Avista Corporation
1 A.Yes. In 2009, Avista worked to reduce the
2 overall technology expenditures by nearly one-million
3 dollars. This was done through a focus on reducing many
4 costs: from as little as a $111 reduction for OATI (open,
5 access transmission information system) web hosting fees,
6 to as high as a $179,872 reduction through a renegotiated
7 AT&T contract.Table 1 below summarizes the cost
8 reductions in is of nearly $1 million.
9 Table 1
Communication Infrastructure
Data Storage
services (helpdesk, web hosting, ass management, etc.)
General Offce Technology (softare, printer, fax, keyboards,
etc.)
Operating Systems (Unux, UNIX, Virtual Server, etc.)
Total Reductions:
$437,791
$74,282
$380,124
$36,00
$37,306
$965,503
10
11 In addition, to these cost reductions in 2009 that
12 will carry forward to 2010, we have also identified other
13 reductions in the 2011 pro forma period (October 1, 2010 -
14 September 30, 2011).Telecommunications maintenance &
15 repair is anticipated to bé reduced by approximately
16 $115,000 in 2011,and professional services are
17 anticipated to be lower by $87,000. These reductions were
Kensok, Di 6
Avista Corporation
1 included in the development of the pro forma adjustment
2 for the 2009 test period.
3 While Avista diligently works to reduce technology
4 costs resulting in significant reductions, there are net
5 cost increases of $4,437,375 related to operations in
6 2010, and an additional $657,000 for 2011.
7 Q.Please sumrize the 2010 pro form cost
8 increases?
9 A.Table 2 below summarizes the net increase in is
10 costs for the year 2010, which continue into the 2011 pro
11 forma rate year.
12 Table 2
2010 Net Operating Cost Increases
Description Amount
$ 380,205
$ 232,512
$ 908,545
$1,427,356
$1,488.757
..
TOTAL 4.4U.J75
Information Technology Operations
General Expenses
Software/Hardware Operating and License Fees
Professional Services - Customer and Operating Applications
Professional Services - Network Engineering/Support - Security & Compliance Support
13
14 Q.Please explain the increase in costs associated
15 with Informtion Technology Operations of $380,205 shown
16 in Table 2.
17 A. Avista has experienced significant increases in
18 property lease costs for mountaintop communication
Kensok, Di 7
Avista Corporation
1 facili ties.For the year 2010, the lease for the Mt.
2 Spokane communication facilities has increased from
3 approximately $5,000 per year to approximately $73,759 per
4 year. Other mountaintop facilities are also experiencing
5 increases in lease costs totaling approximately $10,548
6 per year. These facilities are the core communication
7 si tes for all network traffic that support the electric
8 distribution system, protection and relay circuits, field
9 communication devices,and mobile communications for
10 natural gas and electric crews.Without these
11 communication sites, Avista would not be able to dispatch
12 service work, provide a safe working environment for the
13 crews, and operate the electric and gas infrastructure.
14 Costs from communication network providers such as
15 Century tel , Frontier, Verizon, etc. will also increase in
16 2010. The increase in costs are related to constraints in
17 network capacity and general vendor cost increases. The
18 network capacity, or volume of data a network can move in
19 a timely manner, is constrained. It is constrained due to
20 an increase in volume related to the number of customers
21 contacting Avista via the internet for customer self-
22 service. This provides the customer a channel to transact
23 business, (bill payment, energy efficiency information,
Kensok, Di 8
Avista Corporation
1 rebates, etc.) with Avista when it is convenient for them
2 and reduces calls to the call center.
3 Increases are also due to greater usage of mobile
4 communications.Avista utilizes mobile communications to
5 improve efficiency when serving customers.For example,
6 rather than driving back to the office for work
7 assignments, a field-based employee is given service work
8 via their mobile laptop or cell phone.Avista's claims
9 representatives use mobile communication to work with
10 various agencies and Avista staff when processing a claim.
11 Prior to this, the claims representative had to take
12 pictures and notes at the scene and then return to the
13 office to re-enter those notes manually.Now, they send
14 them via their cell phone.This reduces time for claims
15 processing and improves the efficiency of the claims
16 representative.
17 In order to preserve these tools that enhance
18 customer service and cost-efficiency, it is reasonable and
19 appropriate that the increased costs associated with these
20 tools be passed on to customers, who benefit directly from
21 these tools.
22 Q.Please explain the cost increases related to
23 General Expenses of $232,512 in Table 2 above.
Kensok, Di 9
Avista Corporation
1 A.There has been a significant increase in the
2 use of customer-focused technology,i. e. ,Web and
3 automated telephone transactions, outage management and
4 restoration information, etc., and an increase in staff to
5 support the technology.Avista's customers have quickly
6 adopted the Company's new voice-based technology system
7 that allows for making credit arrangements via the
8 telephone, which reduces calls to the call center.Mr.
9 Kopczynski explains the significant cost reductions
10 related to call center staff,resul ting from this
11 technology, which have been passed on to customers.
12 Avista must ensure that there is adequately-trained
13 staff with proper tools to operate and maintain this
14 technology. For 2010, this requires increased staff,
15 training and tools totaling $232,512. These costs include
16 $116,558 for software development tools for application
17 programming, computer monitors, and personal communication
18 devices for on-call support and web content management, as
19 well as productivity tools such as program debugging
20 software.These systems also require additional
21 technology training costs in 2010 of $115,954.With a
22 lack of training, these applications and others will not
23 be properly maintained, will not be effective in serving
Kensok, Di 10
Avista Corporation
1 customers and preserving the cost savings they have
2 created.
3 Q.Please explain the change in costs associated
4 with Software/Hardware Operating and License Fees of
5 $908,545 in Table 2 above.
6 A.In order to meet customer needs, Avista employs
7 numerous applications from more than 85 application and
8 hardware vendors. These applications and hardware vendors
9 (Avaya, Hewlett-Packard-hardware, Wonderware, etc. ) are
10 expected to increase the software/hardware maintenance
11 fees by $908,545 in 2010. These applications and hardware
12 are necessary to support Avista' s customers calling in to
13 check on system outages (Avaya) , and have an Avista
14 service person dispatched to check for natural gas leaks,
15 read meters, and to protect their information, etc.
16 In addition,these applications and associated
17 hardware are utilized for operating Avista's generation
18 and distribution systems.For example,Wonderware
19 software is used to operate Avista's power plants and the
20 Hewlett-Packard hardware is used to host the computers
21 that manage the electric and natural gas infrastructure.
22 Without 85-plus primary applications, Avista would
23 not be able to operate its natural gas and electric
Kensok, Di 11
Avista Corporation
1 infrastructure and power plants, and would not be able to
2 serve its customers.
3 Q.Please explain the change in costs associated
4 wi th Professional Services Customr and ÇPrating
5 Applications of $1,427,356 shown in Table 2.
6 A.This area includes cost changes involving four
7 different components.Each component is explained
8 separately below.
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New Positions Already Filled ($134,340) - There is an
increase of 1.31 positions contracted with Hewlett-
Packard for 2010. The purpose of the new positions
is to support the need for report writing and web
application development.
The one full-time report writing position is needed
to mine data and write reports that lead to improved
efficiency across the Company. For example, in order
to determine the main causes of electric distribution
system outages, data are mined and correlated to the
root, cause of the outage. This position produces
reports for managing crew over-time, crew efficiency,
customer transaction efficiency, resul ting in
improved employee efficiency and asset management.
The purpose of the partial FTE (.31 FTE) is to assist
in the on-going maintenance and support of Avista's
Intranet site web technology based platform
(SharePoint) . This is a site that is designed to
improve efficiency for communicating across the
Company. All of the business unit performance
metrics are managed on the internal web-site. The
employee self-service applications for Human
Resources and Payroll are accessed through the
internal web-site. Through employee self-service,
Avista gains efficiency in productivity and reduces
Kensok, Di 12
Avista Corporation
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costs of printing
communications.
and mailing internal
New Positions To Be Added in 2010 ($324,738) - Avista
will be contracting with Hewlett-Packard in the third
quarter of 2010 for two positions to support a new
distribution automation application. The annualized
cost for these positions is $324,738. The purpose of
the application is to automate the management of the
electric distribution system. With automation,
Avista has the opportunity to reduce line losses andimprove efficiency in the electric distribution
system. With a reduction in line losses ahd improved
load balancing, the overall efficiency of the
electric system improves. With these improvements,
costs are optimized through reduced line loss of
electricity, and system reliability is improved for
Avista customers.
Hewlett-Packard Annual Cost Adjustmnt ($77,972)
Avista's outsource agreement with Hewlett-Packard has
a contractual obligation for increases in labor rates
associated with all application labor-based Operating
Agreements. The increase is based on the ConsumerPrice Index as of May 2nd of the current contract
year. The annualized increase for 2010 is estimated
to be $77,972. Infrastructure labor as compared to
application labor (Le., networks, desktop support,
etc.) is also subject to adjustment on an annual
basis. The infrastructure adjustment is included in
the overall total in the Professional Services
Network Engineering Support section.
Application Development Services ($890,306)
Staffing and support of applications for the meter
shop are necessary to accurately reflect meter
inventory and meter data accuracy. The addition of
mul tiple meter platforms requires additional staffing
and IS applications to address meter inventory and
meter read data accuracy. The meter data must be
validated through error checking software to ensure
that the customer is properly billed. There is alsoincreased work load associated with integration
technology. The increase in workload is related to
integrating additional customer transactions, such as
Kensok, Di 13
Avista Corporation
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open/close/transfer and outage information tied tomobile dispatching. These is applications provide
the platform for Avista and its customers to be more
efficient in managing outages, bill payments and
opening, closing and transferring accounts.
8 Q.Please explain the changes in costs associated
9 wi th Professional Services - Network Engineering/Support &
10 Security & Comliance Support of $1,488,757 in Table 2
11 above.
12 A.There are two components to this item.The
13 first is related to security and compliance support with a
14 total increase in costs of $906,239.Securi ty and
15 compliance for customer data and Avista's natural gas and
16 electric infrastructure is mandatory.
17 By way of background, the vulnerability of electric
" 18 utili ty operations to accidental or malicious disruption
19 has been the subject of significant concern for several
20 years. These concerns were intensified, first after the
21 widespread blackout in the western United States in 1997,
22 and then after the tragic events of September 11, 2001,
23 and the unprecedented blackout in 2003 in the Northeast
24 and portions of the Midwest. These events spurred the
25 Federal Energy Regulatory Commission (FERC) to develop
26 actionable mandates for enhancing security over bulk
Kensok, Di 14
Avista Corporation
1 electricity operations. These mandates apply to all users,
2 owners, and operators of the bulk power system and
3 primarily involve generation and transmission
4 infrastructure. In addition to this governmental mandate
5 for increased security, the rapid evolution of information
6 technologies in the intervening years and the widespread
7 adoption of the internet as the defacto medium of choice
8 for data communications, including Voice over Internet
9 Protocol communications, have added another layer of
10 urgency to this need for mitigating vulnerabilities
11 inherent in the design, constrüction and operations of the
12 country's bulk electric system.
13 In the wake of 9/11 and the 2003 blackout, the
14 Critical Infrastructure Protection (CIP)Standards
15 mandated were issued by NERC to protect the electric
16 system.The ~cyber security" requirements contained
17 within these Critical Infrastructure Protection mandates
18 specifically require the utilities to ensure secure
19 operations of the information and communication' technology
20 components hardware, software and networks that
21 support the operation of the nation's bulk electricity
22 system.Unlike previous NERC-driven reliabili ty
23 improvement efforts,these mandates are not merely
Kensok, Di 15
Avista Corporation
1 suggested actions, but instead, include penalties for non-
2 compliance.
3 Therefore, Avista has a legal obligation to secure
4 its data networks beyond protecting customer information.
5 Avista must now not only provide secure access to its
6 customer and business information, it now must provide, by
7 law, secure access to its bulk electric system.This
8 requires Avista to engineer,implement and maintain
9 addi tional new network security.In order to meet these
10 new security requirements, Avista must add additional
11 staff and systems.
12 Avista added one security position and will add a
13 second security position to focus on meeting new network
14 securi ty compliance requirements from NERC. The purpose of
15 these two staff positions is to design and implement
16 systems and processes necessary to ensure that Avista is
17 able to comply with NERC's mandated set of Cyber Security
18 Critical Infrastructure Protection communication network
19 standards.
20 In addition to protecting Avista customer information
21 and electric/gas and operating applications, Avista must
22 be prepared to recover from a maj or disaster affecting the
23 business operations. Therefore, Avista has implemented an
Kensok, Di 16
Avista Corporation
1 Enterprise Business Continui ty program.This program
2 provides the oversight and direction for recovery and
3 restoration of business systems and facilities in the
4 event of a disaster.As such, Avista has dedicated new
5 staff to manage and operate the program.
6 Q.What is the second component of the increase in
7 costs associated with Professional Services Network
8 Engineering/Support & Security & COmpliance Support in
9 Table 2 above?
10 A.The second component is related to network
11 engineering and support with a total increase in còsts of
12 $582,518.Addi tional communication network engineers and
13 support staff are needed to design and maintain networks
14 that support the automation of:(1 )the electric
15 distribution system,(2 )customer and employee
16 communications, and (3) electric mobile dispatch networks.
17 With the expansion of these networks, Avista has added and
18 will add new staffing. The following is an explanation of
19 how each network supports Avista's customers, employees
20 and distribution operations:
21
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1.The Electric distribution system network enhances the
control, reliability and efficiency of the electrictransmission and distribution system. Traditionally,
this system has been managed with an industry
Kensok, Di 17
Avista Corporation
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standard network known as Supervisory Control and
Data Acquisition (SCADA) network.
2.The customer and employee communication network is
used for transmitting voice, data and video for day-
to-day business operations to and from Avista
customers and employees. This network has grown and
changed significantly in its complexity to engineer
and manage. The growth and complexity is related to
increased on-line automated customer transactions on
both the Web and the telephone. Through the
automation of many customer transactions and access
to data that customers request on a regular basis,
Avista has been able to minimize the number of staff
in the call center that assist customers withtransactions. These transactions include: self-service functionali ty for customers to
open/close/transfer their account; report a poweroutage; view current outages and restoration
estimates; sign up for various programs such as
comfort level billing and automatic payment service;
view their past 24 months of electric and natural gas
usage; and use of tools to understand options for
energy efficiency.
3.The electric mobile dispatch network is used for
dispatching electric service crews. Avista is
broadening the use of the gas mobile dispatch ~etwork
from gas only to include electric service work. The
success that Avista continues to experience through
improved customer satisfaction is related to on-time
service work, staffing efficiency and reduced drive
time.
Q.How is the distribution automation network
36 different than the SCAA network?
37 A.The network the electricSCADAmanages
38 transmission and distribution system where communication
39 devices signal utility system operators as to the
Kensok, Di 18
Avista Corporation
1 condi tion or health of the electric system. When there is
2 a fault in the electric system, the system operator is
3 notified via the SCADA data network of the fault. The
4 current SCADA network does not provide comprehensive data
5 analytics that are necessary for improving efficiency in
6 the electric distribution system.With improved
7 efficiency, Avista can reduce line losses resulting in
8 higher distribution system reliability, and efficiency,
9 which increases customer satisfaction. In order to capture
10 the efficiency and improved reliability, Avista has
11 started to implement a new distribution automation network
12 that complements the existing SCADA network.
13 Wi th the opportunity to reduce line losses in the
14 electric distribution system,more comprehensi ve
15 analytical data is required than what the SCADA network
16 has been providing.In order to obtain more analytical
17 data, additional sensing devices have been added to the
18 electric distribution system.These additional sensing
19 devices require a ~distribution automation network" to
20 move the data from the sensing devices back to a location
21 where an engineer can analyze the data.Through
22 analytics, the engineer is then able to tune the electric
23 infrastructure to reduce line losses and more efficiently
Kensok, Di 19
Avista Corporation
1 balance the electric load.Wi th a reduction of line
2 losses and improved load balancing, the overall efficiency
3 of the electric system improves, which reduces costs
4 related to loss of electricity and improves reliability
5 for Avista customers.
6 Q.What are the changes in costs for the 2011
7 portion of the pro form period that have been included in
8 this case?
9 A.The increases in information technology costs
10 for the 2011 portion of the pro forma period are shown in
11 Table 3 below:
12 Table 3
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2011 Operating Cost Increases
Description Amount
Professional services and network maintenance/growth costs $ 208,231
Professional services and application softare maintenance $ 448,544
TOTAL $ 656.n5
18
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20 Professional Services and Network Maintenance/Growth
21 ($208,231)Avista expects increases in network
22 maintenance and repair fees in 2011 of $208,231.For
23 each new critical piece of network usage hardware that
Kensok, Di 20
Avista Corporation
1 is added in 2010, Avista has an increase in maintenance
2 fees the following year. Avista pays a maintenance fee
3 to ensure that it meets system availability requirements
4 for customers and employees.In addition, as 'I
5 mentioned earlier, there continues to be exponential
6 growth in the use of Avista networks for customers
7 transacting on-line and for Avista to manage its meters
8 and mobile workforce. As a result, the capacity of the
9 network must be expanded each year. The expansion costs
10 are related to increased costs with the
11 telecommunication providers.
12 Professional Services and Application Software
13 Maintenance ($448,544)Avista expects one new
14 application in 2011 that requires a recurring
15 maintenance fee of $174,140.The Company expects
16 increases of approximately $274,404 in labor expense in
17 2011. The additional labor is necessary to provide
18 development and support services for Meter Data
19 Management System; this captures meter reads on a
20 defined frequency and is used for customer billing,
21 usage-presentment and demand-management by the customer.
22 Wi thout the labor to manage the new application for
23 meter data management, the application is' at risk for
Kensok, Di 21
Avista Corporation
1 poor performance or failure.Should the application
2 fail or perform poorly, the meter reads that are
3 captured by the application will be lost, limiting
4 Avista's ability to bill customers and the customers'
5 abili ty to know their usage of power.
6 Q.Does that conclude your pre-filed direct
7 testimny?
8 A. Yes.
Kensok, Di 22
Avista Corporation
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL OF
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
FACSIMILE: [phone]
DAVID.MEYER~AVISTACORP. COM
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO
CASE NO. AVU-E-10-01
CASE NO. AVU-G-10-01
EXHIBIT NO. 10
JAMES M. KENS OK
FOR AVISTA CORPORATION
(ELECTRIC AND NATURAL GAS)
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No Exhibit Material
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