20030515Avista Response No. 5 & 5C.pdf

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Avista Corp.
1411 East Mission PO Box 3727
Spokane. Washington 99220-3727
Telephone [phone]
Toll Free 800-727-9170
RECEIVED r LEO rJ ~~''V'STA.
2003 Mf\Y 14 . AM 10: 03
Corp.
May 12, 2003
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UTILITIES COt1tiiSSION
VIA OVERNIGHT DELIVERY
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
PO Box 83720
Boise, Idaho 83720-0074
RE:Case No. A VU-02-08 (Potlatch Corporation v. Avista Utilities)
Ms. Jewell :
Please find enclosed three (3) copies of Avista s responses to Staff Production Request No.(s) 5
and 5C (Confidential).
If you have any questions, please call me at [phone].
Mike
Rate Analyst
Enclosures
cc:Blair Strong
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 13th day of May 2003, I caused to be served a true
and correct copy of the foregoing by the method indicated below, and addressed to the following:
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
PO Box 83720
Boise, Idaho 83720-0074
US Mail
Hand Delivery
Facsimile
Overnight Mail
Electronic Mail
Conley Ward
Givens Pursley LLP
277 North 6th Street, Suite 200
PO Box 2720
Boise, Idaho 83701
US Mail
Hand Delivery
Facsimile
Overnight Mail
Electronic Mail
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
REQUEST NO.
DATE PREPARED: 05/1312003
WITNESS:
RESPONDER: Clint Kalich
DEPT./JOB TITLE: Energy Resources/Manager of
Resource Planning & Analysis
[phone]TELEPHONE:
JURISDICTION: Idaho
CASE NO: A VU-02-
REQUESTER: IPUCTYPE: Data Request
REQUEST:
Please provide the monthly forward prices that have been quoted to A vista on a daily basis
during the period from April 1 , 2003 through May 9,2003 for delivery months beginning March
2003 and ending February 2008.
RESPONSE:
The file entitled "Forward Curves 1-2002 thru 5-2003.xls," which is attached to Avista
CONFIDENTIAL Data Response Number 5C, contains all forward price curve data for the
forward months March 2003 through February 2008 recorded during the period January 2002
through May 9, 2003. The data represent an historical record of the Company s "forward
curves" for each traded day for Mid-Columbia electricity. Because broker quote data is available
on a monthly basis for only a few months out, and quarterly data is available for only a few
quarters out, the Company interpolates between available data points using historical market
information to create monthly forward curves.
The worksheet entitled "Sheet 2" contains average 7x24 monthly prices over the period. More
detailed on- and off-peak prices are available in "Sheet I." "Chart I" contains a graphic of the
average March 2003 through February 2008 forward curve price for each trading day beginning
on January 2 , 2002 (the first trading day of the year) and ending on May 9 , 2003. The Chart
explains that the lowest average value for the period was recorded on January 7 , 2002 at $23.
per MWh. The highest value, $43.35 per MWh, was recorded on February 25 2003. On May 9
2003 , the last requested forward curve day, the average price was $37.59 per MWh for the period
May 2003 through February 2008. The May 9 average does not include March or April 2003
since trading stops in months that have past.
DAVID J. MEYER
SENIOR VICE PRESIDENT AND GENERAL COUNSEL
A VISTA CORPORATION
O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
FACSIMILE: [phone]
R. BLAIR STRONG
PAINE, HAMBLEN, COFFIN, BROOKE & MILLER LLP
717 WEST SPRAGUE AVENUE, SUITE 1200
SPOKANE, WASHINGTON 99201-3505
TELEPHONE: [phone]
FACSIMILE: [phone]
ATTORNEYS FOR A VISTA CORPORATION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. A VU-02-
POTLATCH CORPORATION,
Complainant
Respondent
ATTORNEY'S CERTIFICATE
AND CLAIM OF
CONFIDENTIALITY RELATING
TO AVISTA'S STAFF
PRODUCTION REQUEST NO.
AVISTA UTILITIES
, R. Blair Strong, represent A vista Corporation. I make this certification and claim of
confidentiality pursuant to IDAP A 31.01.01.067 and 31.01.01.233.
I am an attorney and have been requested by Avista Corporation to appear on its
behalf in this proceeding.
In response to Staff Production Requests No.5 A vista is disclosing pursuant to
the Protective Agreement Between Avista Corporation and Idaho Public Utilities Commission
Staff monthly forward prices that have been quoted to A vista on a daily basis during the period
ATTORNEY'S CERTIFICATE -
from April 1 , 2003 through May 9, 2003 for delivery months ending February 2008, which are
contained on a computer diskette ("Confidential Diskette
I am advised by the Company that contained within the Confidential Diskette are
historic forward projections by Avista of future electric power prices for the forward months
through February 2008.From such projections, it would be possible to derive Avista
methodology used to derive its projections of future power prices ("forward price curves ). Such
would be extremely useful to competitive buyers and sellers of electric power in western North
America who also develop their own proprietary forward price curves upon which, in part they
base their buying and selling decisions. Based on this information, I am of the opinion that the
compilation in the responses is a "Trade Secret" as defined by Idaho Code Sections 9-340D and
48-801 and, therefore is protected by law from public disclosure.
The Company herein asserts that the forward price curve information contained
on the Confidential Diskette are proprietary and confidential information and should be protected
from public inspection, examination and copying, and should be utilized only in accordance with
the terms of the PROTECTIVE AGREEMENT BETWEEN A VISTA CORPORATION AND
IDAHO PUBLIC UTILITIES COMMISSION STAFF, entered on February 21 2003.
RESPECTFULLY SUBMITTED this 12th day of May, 2003.
Paine, Hamblen, Coffin, Brooke & Miller LLP
R. Blair Strong
Attorneys for A vista Corporation
ATTORNEY'S CERTIFICATE - 2