Agenda Date: February 10, 1999 Item Number: Docket: UG-981376 Company Name: Avista Utilities (formerly The Washington Water Power Company) Staff: Mike Parvinen, Revenue Requirements Specialist Recommendation: Issue an order dismissing complaint and order suspending tariff revisions in Docket UG-981376 and allow the temporary rates to become permanent. Discussion: On October 29, 1998, Avista Utilities (Company) filed docket UG-981376 with the purpose of refunding a net $428,000 in prior period gas cost savings. The filing was suspended on November 25, 1998, with rates placed into effect on a temporary basis. Staff raised two concerns at that time: 1) Transactions with its affiliate Avista Energy, 2) Jurisdictional allocation of gas supply costs. Avista Energy: Docket UG-981376 February 10, 1999 Page 1 The Company has entered into many transactions with its subsidiary, Avista Energy. These transactions include pipeline capacity releases, off-system supply purchases and sales, and system supply purchases. Staff has reviewed the transactions for the twelve month period ended June 30, 1998, and found that the transactions appear to be at market rates and are a representation of Avista Energy’s costs. Staff was concerned that Avista Energy could be encroaching on activity that Avista Utilities could and should be doing in the interest of its ratepayers. There is a certain amount of overlap in the functions performed by the Company and Avista Energy. However, Avista Energy’s primary gas function is much more speculative in nature than what a regulated company would be venturing into. The Company has also increased the amount of capacity release revenues and net off-system sales activities since the formation of Avista Energy, indicating that Avista Energy is not taking opportunities from the Company. Staff will need to continue to monitor transactions between the Company and Avista Energy, Avista Energy’s results of operation, and the Company’s level of capacity release/off-system sales. Jurisdictional Gas Cost Allocations: Staff was concerned with the methods employed to assign gas costs to the different jurisdictions. Even though Staff does not agree with the methods used, the Company has demonstrated to Staff’s satisfaction that the end results of the methods used to assign gas supply costs to the various jurisdictions are reasonable. Staff and the Company are continuing to find an allocation method that is agreeable to all jurisdictions involved. Until an agreed upon methodology is found Staff will continue to review all allocations to ensure that the results are reasonable. IV. Summary The outcome of Staff’s review of the above mentioned issues is that there should be no adjustments made to the deferred gas cost accounts and, therefore, the rates placed into effect on November 25, 1998, on a temporary basis are correct and should become permanent. V. Conclusion. Staff recommends that the Commission issue an order dismissing the complaint and order suspending the filing in Docket UG-981376 and allow the temporary rates to go into effect on a permanent basis.