Agenda Date: January 24, 2001 Item Number: 2A Docket: UE-002066 Company: Avista Corporation Staff: Merton Lott, Energy Coordinator Roland C. Martin, Energy Regulatory Consultant Recommendation: Grant Avista Corporation’s request for an accounting order Docket No. UE-002066. Discussion: On December 26, 2000, Avista Corporation (“Avista” or “Company”) filed a request to defer as regulatory assets or liabilities offsets to the accounting entries that will be required under Financial Accounting Standards Numbers 133 and 138 (FAS 133/138) related to certain derivative and hedging activities as they apply to resource acquisitions for the Company’s retail electric and natural gas customers. The Financial Accounting Standards Board (FASB) issued FAS 133 in June 1998, and amended it with FAS - 138 in June 2000. All companies are required to carry all derivatives and certain embedded derivatives on their balance sheet at fair market value, sometimes referred to as mark-to-market. These requirements represent a change in accounting for Avista with respect to certain contracts for the sale or purchase of power, (currently all electric), for financial reporting beginning January 1, 2001. Avista’s review of their power contracts identified a few contracts that would require accounting under FAS 133/138. The application of these requirements to Avista’s 2000 results would have created large liabilities (in excess of $100,000,000) and corresponding reductions to their 2000 earnings. These liabilities and earnings would ultimately be reversed when the contracts were actually fulfilled and the power delivered or received. The net impact of the new accounting requirements is that earnings in the long run would not be affected nor would Avista’s cash flow, but on a quarter by quarter basis income could fluctuate substantially. Avista’s proposal in this proceeding is to create regulatory assets and liabilities that would offset the assets and liabilities created by valuing the implied derivatives at market. The intent of the proposal is to continue the treatment of long term sales and purchase contracts as they have been in the past. In this fashion, expenses would continue to be recognized for a period at the embedded prices contained in the contract rather than restating the costs of these contracts at market prices. Staff believes that the historic pricing contained within these contracts is consistent with the regulatory treatment authorized by this Commission. Avista’s petition also addresses the situations where a contract is settled for cash in advance of normal delivery of power. In these cases, the resulting gain or loss on the transaction would be available for Commission consideration in the determination of rates. The petition does not limit the Commissions authority to review the prudence of the original contract, or actions, or lack of action, by the Company with respect to settling the contract prior to completion. Conclusion and Recommendation: Staff believes that for ratemaking purposes the revaluing of derivatives or implied derivatives to market value related to contracts for the purchase or sale of power (gas or electric) is not consistent with Commission policy. Staff concludes that Avista’s petition for accounting treatment as outlined in their petition is reasonable. Therefore, Staff recommends that the Commission issue an accounting order consistent with Avista’s petition.