200302241st Request of Staff.pdf

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SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
POTLATCH CORPORATION
Complainant
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
CASE NO. A VU-02-
VISTA UTILITIES
Respondent.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that Avista Corporation (Avista; Company)
provide the following documents and information on or before MONDAY, MARCH 17, 2003.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name
location and phone number of the record holder. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementary responses, additional documents that it or any person acting on
its behalf may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST TO
A VISTA UTILITIES FEBRUARY 24, 2003
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
For each item, please indicate the name of the person(s) preparing the answers, along with
the job title of such person(s) and the witness who can sponsor the answer at hearing.
Request No.1: Staff understands that Avista made an offer on or about February 14, 2003
to purchase generation from Potlatch. Please provide a copy of Avista s offer. Also please
provide a written description of how the rate was determined, along with the complete data and
analysis upon which the offer is based.
Request No.2: What would be the rate offered to Potlatch if the rate was based on use of
the avoided cost methodology for projects larger than 10 MW as described in the Settlement
Stipulation in Case No. IPC-95-9? Please provide the AURORA input data files (AURORA
project file and MDB file) and the output file used to determine the rate. Also provide a copy of
any analysis done outside of the AURORA model to compute the avoided cost rate.
Request No.3: Please provide analysis showing the avoided cost rate determined using
the following assumptions:
a. assuming the Coyote Springs II project is already built and available for dispatch
and
b. assuming the Coyote Springs II project has not been built and is not available for
dispatch.
Dated at Boise, Idaho, this
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Scott W 0 dbury
Deputy Attorney General
Technical Staff: Rick Sterling
SW :RPS:i :umisc/prodreq/avueOZ.Sswrps
FIRST PRODUCTION REQUEST TO
A VISTA UTILITIES FEBRUARY 24, 2003
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF FEBRUARY 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO A VISTA UTILITIES IN CASE NO. A VU-02-, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
KELLY NORWOOD
VICE PRESIDENT
A VISTA CORPORATION
PO BOX 3727
SPOKANE, W A 99220
DAVID MEYER, ESQ.
SENIOR VP AND GENERAL COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE, W A 99220
R BLAIR STRONG
PAINE HAMBLEN COFFIN BROOKE
& MILLER LLP
717 W SPRAGUE AVE, STE 1200
SPOKANE W A 99201
CONLEY WARD
GIVENS PURSLEY
PO BOX 2720
BOISE ID 83701-2720
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SEC TARY
CERTIFICATE OF SERVICE