Avista Corp.
1411 East Mission   P.O. Box 3727
Spokane. Washington  99220-0500
Telephone 509-489-0500
Toll Free   800-727-9170
 


January 25, 1999


Washington Utilities and Transportation Commission
1300 S. Evergreen Park Drive SW
PO Box 47250
Olympia, WA  98504-7250

Attention:  Ms. Carole Washburn, Executive Secretary

RE: Quarterly Year 2000 Status Reports
 Docket No.  U-971835

Avista Corporation wishes to thank the Washington Utilities and Transportation 
Commission for the opportunity to comment on Commission staff’s plan to 
recommend uniform formats for the Year 2000 readiness reporting.

The Company wishes to provide the following comments:

Avista Corporation supports Commission staff’s recommendation to adopt the NERC 
Y2K reporting format.  We agree that, as staff explained, it should provide a 
uniform reporting structure and we have previous experience with the NERC 
format.  

The Y2K Periodic Report Template is understandable, and filling it out should 
be fairly straightforward.  We would, however, ask the Commission staff to 
clarify the type of information they are requesting in paragraph I-A, under the 
“definitions of terms on the report form.”  Depending upon how one reads that 
particular paragraph, it can be interpreted as if the staff was asking for: 1) 
information from the telecommunications companies only, or 2) information form 
all utilities about their individual internal communication systems. 

The Company supports staff’s recommended submission dates for the final Y2K 
Contingency Plans. We do want to emphasize, however, that Avista Corporation 
views our previously submitted contingency plan as a “living document.”  We use 
the term “living document” to illustrate our intention to modify, and thereby 
improve, our contingency plan right up to the date of implementation, should 
that be necessary.  Although we do not foresee major modifications to our plan, 
we will be identifying key personnel to be responsible for the various parts of 
our plan.  That identification process will probably be implemented during the 
third quarter of this year.

If you have any questions, please give me a call at (509) 495-8506.

Jeff Brune,



Y2K Program Manager