200305161st Request of Avista to Potlatch.pdf

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]
RECEIVED
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2003 Mil Y I 6 AM 8: ~ 1
Ut\hG PUBLIC
UTILITiES COMMISSION
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
POTLATCH CORPORATION,
Complainant
CASE NO. A VU-02-
Res ondent
FIRST DISCOVERY REQUESTS
OF A VISTA CORPORATION TO
POTLATCH CORPORATION
A VISTA UTILITIES
TO:COMPLAINANT, POTLATCH CORPORATION;
AND TO:CONLEY WARD, YOUR ATTORNEY OF RECORD.
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
Avista Corporation ("A vista ), by and through its attorneys of record, Paine, Hamblen, Coffin
Brooke & Miller LLP, hereby requests that Potlatch Corporation answer to the following
interrogatories and respond to the following requests for production.
In responding to the discovery requests, furnish such information as is available to you
not merely that which you know of your own personal knowledge. This means that you are to
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION -
furnish information that is available to you or is in the possession of your attorney or consultant
or otherwise subject to your control or in your custody. Identify each document that forms a
basis for the response given or which corroborates or relates to the response given. Identify each
person who assisted or participated in preparing and/or supplying any of the information in
response to or relied upon in preparing responses to these discovery requests, the discovery
request, or part thereof, that they assisted or participated in preparing, and provide the full name
business address, and any telephone number of such person.
For purposes of these discovery requests
, "
documents" means any and all written
electronic or graphic matter, of any kind or description, however created, produced, reproduced
or stored, whether sent or received, or whether originals, copies or drafts. Where your responses
require the production of documents, label the documents to indicate the discovery request to
which the document pertains.
These discovery requests are continuing in nature and you are required to immediately
supplement your answers upon acquiring any additional responsive information following
service of your answers to the interrogatories or responses to the requests for production.
Please produce and deliver all responses to discovery requests to R. Blair Strong, Paine
Hamblen, Coffin, Brooke & Miller LLP, 717 West Sprague Avenue, Suite 1200, Spokane
Washington 99201-3505, phone number 509-455-6000. If you have any questions respecting
the discovery requests, please contract immediately R. Blair Strong, at the address and phone
number listed above.
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 2
INTERROGATORIES and PRODUCTION REQUESTS
REQUEST NO.
With respect to the four generating facilities from which Potlatch desires to sell power to
Avista Corporation, please provide copies of the self certifications, or the applications and
corresponding orders of the Federal Energy Regulatory Commission ("FERC"), and any
amendments or changes to such self-certifications or FERC orders, for each of the generation
facilities located at Lewiston that are qualifying facilities pursuant to the Public Utility
Regulatory Policies Act of 1978 ("PURP A"
REQUEST NO.
With respect to the four generating facilities from which Potlatch desires to sell power to
A vista Corporation please provide the present heat rate and generating capability of each of
Potlatch's four generation facilities located at Lewiston, Idaho.
REQUEST NO.
With respect to the four generating facilities from which Potlatch desires to sell power to
Avista Corporation, please set forth the variable operating costs of each of Potlatch's generation
facilities located at Lewiston, Idaho.
REQUEST NO.
With respect to the four generating facilities from which Potlatch desires to sell power to
A vista Corporation, please provide for each generation facility, separately, the type of fuels
consumed by each of Potlatch's generation facilities at Lewiston, Idaho.
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 3
REQUEST NO.
With respect to the four generating facilities from which Potlatch desires to sell power to
Avista Corporation, please provide the variable fuel costs of operating each of Potlatch'
generation facilities located at Lewiston, Idaho.
REQUEST NO.
With respect to the four generating facilities from which Potlatch desires to sell power to
A vista Corporation, please indicate how Potlatch proposes to determine the cost of operating
each such facilities for purposes of determining when such generator will operate to supply
electric power during the term of a power sale contract to A vista.
REQUEST NO.
Please explain how Potlatch presently measures or meters the electric output and station
service of each of the four generation facilities located at Lewiston, and how Potlatch proposes to
measure the electric output and station service of each such facility for purposes of a power sale
contract to A vista.
REQUEST NO.
With respect to Dr. Peseau s prepared direct testimony, page 7, lines 5 -6, please define
what is meant by "base load resource " and how Potlatch's generating resources fit within such
definition.
REQUEST NO.
With respect to Dr. Peseau s prepared direct testimony, page 7, lines 5 -6, please provide
all documents, including but not necessarily limited to correspondence, that addresses Potlatch'
plans for increasing or decreasing net load on A vista and plans for increasing or decreasing
generation at its facilities at Lewiston, Idaho.
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 4
REQUEST NO. 10.
With respect to Dr. Peseau s prepared direct testimony, page 11 , lines 17-, please
identify all consultants and their contact information that Potlatch has hired or retained since
January 1 , 2000 to evaluate the sale of power from Potlatch's generation facilities located at
Lewiston, Idaho.
REQUEST NO. 11.
With respect to Dr. Peseau s prepared direct testimony, page 17, lines 10-, please
indicate how Potlatch proposes to measure station service for each of the four qualifying
generating facilities for the purposes of a power sale contract to A vista. Please provide all
schematic or line diagrams or other documents that illustrate how Potlatch presently measures
the electric output and station service of each of its four generation facilities located at Lewiston
and how Potlatch proposes to measure the electric output and station service of each such facility
for purposes of a power sale
REQUEST NO. 12.
With respect to Dr. Peseau s prepared direct testimony, page 17, lines 21-23 and page 18
lines 5-, please explain if Potlatch has any intention of changing its manufacturing facilities at
Lewiston, Idaho in a manner that would increase or decrease its net electric load on A vista
during the next five years. If your answer is yes, provide written estimates of the magnitude and
timing of such changes.
REQUEST NO. 13.
With respect to Dr. Peseau s prepared direct testimony, page 17, lines 21-23 and page 18
lines 5-, do Potlatch's facilities at Lewiston, Idaho have the electrical capability to have a net
load in excess of 50 megawatts of electric energy? (Net load means all on site electrical load less
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 5
electrical generation on site.) If, the answer is yes, please indicate what changes have been made
to Potlatch's manufacturing facilities that would allow net loads to exceed 50 megawatts.
REQUEST NO. 14.
With respect to Dr. Peseau s prepared direct testimony, page 17 , lines 15-23 and page 18
lines 1-, please provide a listing of all generator shutdowns, closures and reductions in
generation by each of its four generation plans for the past five years and each generators
expected shutdowns, closures and reductions in generation expected for the next five years.
REQUEST NO. 15.
With respect to Dr. Peseau s prepared direct testimony, page 17, lines 15-23 and page 18
lines 1-, please provide for calendar year 2002 a listing of gross generation and generation net
of station service by hour for each of Potlatch's generation facilities located at Lewiston, Idaho.
For each generation unit indicate the specific number of megawatt hours generated and how the
specific number was determined.
REQUEST NO. 16.
With respect to Dr. Peseau s prepared direct testimony, page 17, lines 15-23 and page 18
lines 1-, for calendar year 2002, please itemize the amount of fuel, categorized by type of fuel
utilized by Potlatch to generate electric power at Lewiston, Idaho and the amount of electric
power generated by each of Potlatch's four generators resulting from the use of each type of fuel.
Please indicate how the amount of electric power generated by each of the four generators
resulting from each type of fuel was measured, calculated or estimated.
REQUEST NO. 17
With respect to Dr. Peseau s prepared direct testimony, page 18, lines 5 -, please
explain upon what basis Dr. Peseau concluded that; "(I) t is common knowledge that, without
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 6
Potlatch's generation, Avista would have to upgrade its transmission system in order to provide
reliable service to the LewistoniClarkston valley," Provide a copy of all documents upon which
Dr. Peseau arrived is making this statement.
REQUEST NO. 18.
With respect to Dr. Peseau s prepared direct testimony, page 18 , lines 19-, and page
, lines 1 - 6, please explain how Dr. Peseau determined the additional savings from line losses
and avoidance of internal expenditures to replace the system stability provided by Potlatch
generation to be roughly equivalent to a ten percent (10%) increase in the avoided cost rates.
Provide a copy of all documents upon which Dr. Peseau relied in making this determination.
REQUEST NO. 19.
With respect to Dr. Peseau s prepared direct testimony, page 19, lines 9-, does Potlatch
presently have any plans to operate its manufacturing facilities at Lewiston, Idaho without
simultaneously operating its generation facilities? If yes, please explain.
REQUEST NO. 20.
With respect to Dr. Peseau s prepared direct testimony, page 19, lines 9-, is Potlatch
presently able to operate its manufacturing facilities at Lewiston, Idaho for extended periods of
time without operating its generation facilities? If the answer is yes, please explain under what
circumstances and for what period of time Potlatch could operate its manufacturing facilities
without operating its generation facilities. If the answer is no, please explain what changes
would have to be made to its facilities to accommodate operation of its manufacturing facilities
without operating its generation facilities.
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 7
REQUEST NO. 21.
With respect to Dr. Peseau s prepared direct testimony, page 19, lines 9-, please list
when, under what circumstances, and for what duration, in the past ten years, Potlatch has
operated its manufacturing facilities without simultaneously operating its generation facilities.
REQUEST NO. 22.
With respect to Dr. Peseau s prepared direct testimony, page 19, lines 9-, please
provide copies of all requests for proposals, requests for qualifications, and similar documents
soliciting the purchase of the electric output of its generators in Lewiston, Idaho issued by
Potlatch since January 1 , 2000.
REQUEST NO. 23.
With respect to Dr. Peseau s prepared direct testimony, page 19, lines 9-, please
provide copies of all offers or proposals to purchase power generated by Potlatch's generators at
Lewiston, Idaho or similar documents received by Potlatch since January 1 , 2000. If offers or
proposals were oral, please provide a summary of the offer indicating the offered price, period of
delivery, and quantity and quality of power.
REQUEST NO. 24.
Has Dr. Peseau utilized the Henwood Prosym , or similar, software package? If the
answer is yes please provide a copy ofthe most recent study conducted by Dr. Peseau.
REQUEST NO. 25.
Has Dr. Peseau utilized the EPIS AURORATM, or similar, software package? If the
answer is yes, please provide a copy of the most recent study conducted by Dr. Peseau.
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 8
REQUEST NO. 26.
With respect to Dr. Peseau s prepared direct testimony, exhibit 1 , page 3 please state for
what purposes and for whom the optimal capacity expansion model was utilized.
REQUEST NO. 27.
With respect to Dr. Peseau s prepared direct testimony, exhibit 1 , page 3; provide a copy
of the most recent study conducted by Dr. Peseau that utilized the optimal capacity expansion
model.
REQUEST NO. 28.
With respect to Dr. Peseau s prepared direct testimony, exhibit 1, page 3; provide a copy
of the most recent reserve and reliability study that Dr. Peseau conducted for the Northwest
Power Planning Council.
REQUEST NO. 29.
With respect to Dr. Peseau s prepared direct testimony, page 19, lines 9-, please
provide Potlatch's most recent estimate, if any, of market prices for electric power to be
purchased and/or sold at wholesale in the Northwest United States through 2009, for example at
the Mid Columbia point of delivery.
REQUEST NO. 30.
With respect to Dr. Peseau s prepared direct testimony, page 19, lines 9-, please
describe how Potlatch arrived at its estimate, if any, of expected levels of prices for electric
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 9
power to be purchased and sold at wholesale in the Northwest United States through
2009.
DATED this 14th day of May, 2003.
Paine, Hamblen, Coffin, Brooke & Miller LLP
~~~
R. Blair Strong
Attorneys for A vista Corporation
FIRST PRODUCTION REQUEST
OF AVISTA CORPORATION -
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th 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
Boise, Idaho 83720-0074
Conley Ward
Givens Pursley LLP
277 North 6th Street, Suite 200
O. Box 2720
Boise, Idaho 83701
XXXX S. Mail
Hand Delivery
Facsimile
Overnight Mail
Electronic Mail
XXXX S. Mail
Hand Delivery
XXXX Facsimile
Overnight Mail
XXXX Electronic Mail
Mr. Scott D. Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
XXXX u.S. Mail
Hand Delivery
XXXX Facsimile
Overnight Mail
XXXX Electronic Mai
(JI.
fCIY R. BLAIR STRONG
00115241
FIRST PRODUCTION REQUEST
OF A VISTA CORPORATION - 11
Sent By: PAINE HAMBLEN 14j 509 838 0007 May-16-0310:13AMj Page 1/5
PAINE, HAMBLEN, COFFIN, BROOKE & MILLER LLP
717 West Sprague Avenue, Suite 1200
Spokane, Washington 99101-3505
[phone]
Fax: (SO9) 838-0007
FACSIMILE MESSAGE. . PLEASE DELIVER PROMPTLY
Name:
Organization:
Fax:
Phone:
Scott Woodbury
Idaho Public Utilities Conunission
208.334-3762
208-334-0320
Name:
Organization:
ax:
Phone:
Conley Ward
Givens Pursley
208-388-1300
208.388-1200
Date:May 16,2003
Subject:Potlatch Corporation v, A vista Corporation
IPUC Docket No. A VU-O2-
11150-03086
Pages:
Please see attached. Hard copy to fo11ow via regular mail.
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Sent By: PAINE HAMBLEN 14j 509 838 0007 May-16-10:13AMj Page 2/5
THE LAW OFFICi:: OF
PAINE, HAMBLEN, COFFIN, BROOKE &MILLERLLP
R. Blair Strong
Partner
717 WEST SPRAGUE A VENlIt:
~tJ)TE 1200
:;POKANJ::, WASHINGTON 99101.3505
[phone]
FAX: [phone]
www,vai1\chambl~L).cnm
May 16,2003
Mr. Conley Ward
Givens Pursley LLP
277 North 61h Street, Suite 200
O. Box 2720
Boise, ID 83701
Re:
Via Email, Facsimile and Regular Mail
Potlatch Corporation v. Avista Corporation
TPUC Docket No. A VU-O2-
Dear Mr .J.V.am:-
(' "'-
Enclosed please fink' an original plus one copy of the Amendment to Hrst Discovery
Requests of A vista Corporation to Potlatch Corporation. Our original request inadvertently left out
the response deadline, therefore we are amending the discovery requests to request responses by May
30, 2003. No other changes have been made to the First Discovery Requests.
Tfyou have difficulties with the requested time frame, please give me a ring.
V cry truly yours
PAINE, HAMBLEN, COFFIN
BROOKE & MILLER LLP
.'-"'").;"'" ./;~
't:L#
R. Blair Strong
Enclosure
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Sent By: PAINE HAMBLEN 14 509 838 0007 May-16-0310:13AMj Page 3/5
DA VID 1. MEYER
SENIOR VICE PRESIDENT AND GENERAL COUNSEL
A VIST A 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]
FACSLMILE: [phone]
ATTORNEYS FOR A VISTA CORPORATION
BEFORE THE IDAHO PUBLIC UTI LlTIES COMMISSION
POTLATCH CORPORATION,
Complainant
CASE NO, A V U-O2-
Respondent
AMENDMENT TO FIRST
DISCOVERY REQUESTS OF
A VTST A CORPORATION TO
POTLATCH CORPORATION
A VISTA UTTLTTIES
TO: COMPLAINANT, POTLATCH CORPORATION;
AND TO:CONI..EY WARD, YOUR ATTORNEY OF RECORD,
Please take notice of the fol1owing amendment to the First Discovery Requests or
Avista Corporation to Potlatch Corporation: POTLA TCH IS REQUESTED TO
PROVIDE RESPONSES TO THE FIRST DISCOVERY REQUESTS WITHIN
FOURTEEN (14) DAYS, WHICH WILL BE ON I'RlDAY, MAY 30 , 2003,
AMENDMENT TO FiRST PRODUCTION REQUEST
OF A VISr A CORPORATION -
Sent By: PAINE HAMBLEN 14 509 838 0007 May-16-03 10:14AMj Page 4/5
This amendment is submitted in order to assure that the responses to the discovery
requests will be received in a timely marmer in order to allow preparation for the heating,
which is scheduled to commence on June 16. 2003. All other contents of the First
Discovery Requests of A vista Corporation to Potlatch Corporation are unchanged by this
amendment.
DATED this 16th day of May, 2003,
Paine, Hamblen, CoffIn. Brooke & Miller LLP
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R, Blair Sttong
Attorneys for A vista Corporation
AMENDMENT TO FIRST PRODUCTION REQUEST
OF AVISTA CORPORATTON - 2
Sent By: PAINE HAMBLEN 14;GO9 636 0007;May-10-0310:14AM;Page GIG
CERTIFICATE OF SERVICE
. 1 HEREBY CERTIFY that on the 16th day of May, 2003 , 1 caused to be served
a true and correct copy of the foregoing by the method indicated below, and c,ddre~~~c1 to
the following:
M~. Jean Jewel1. Secretary
Idaho Public Ulilities Commission
472 West Washington Street
Bui~c, IdwlU 83720-0074
Conley Ward
Givens Pursley LLP
277 Noah 6th Stn~et, Suite 200
P .0, Box 2720
Doisc, Iduho 83701
XXXX S. Mail
Hand Delivery
Fac!:imile
Overnight Mail
Electronic Mail
x.XXX S. Mail
Hand Delivery
XXXX .Facsimile
Overnight Mail
XXXX Electronic Mail
Mr. Scott D. Woodbury
Dcpuly AuulIJt:y Ocucntl
Idaho Public Utilities Conul1ission
472 West Washington Street
Boise, Idaho 83720 0074
XXXX US. M;.Iil
Hand Delivery
XXXX Facsimile
Ovemi ght Mail
XXXX flc\.:L1uuk Mal
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/5 ?a-Gl
R. BLAIR STRONG
00115562
AMENDMENT TO FIRST PROm JCTTON RRQ( JEST
OF AVISTA CORPORATION - 3