20040510Response of Avista to Potlatch.pdf

Avista Corp.
1411 East Mission POBox3727
Spokane. Washington 99220-3727
Telephone 5O9-48!I-0500
Toll Free 800-727-9170
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May 7, 2004
Conley E. Ward
GIVENS PURSLEY LLP
601 W. Bannock Street
PO Box 2720
Boise, ill 83701-2720
Re:First Production Request of Potlatch Corporation
in Case Nos. A VU-04-01 and A VU-04-
Mr. Ward
I have attached one copy of Avista s response to Potlatch Data Request No. (s) 2, 4 , 7
7(C), 8, 10, 10(C), 11 , 12, and 12(C).
If you have any questions, please call me at [phone] or Don Falkner at (509) 495-
4326.
Mike Fink
Rate Analyst
Enclosures
S. Woodbury (IPDC)
D. Peseau
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
Potlatch
Data Request
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
4/27/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please explain why A vista Power initially purchased Coyote Springs 2, rather than A vista
Corporation.
RESPONSE:
Coyote Springs 2 was offered for sale by Enron North America in late 1999 through early 2000.
A vista Power, LLC was in the business at that time of acquiring and developing new power
generation projects. A vista Power negotiated a letter of intent to purchase the project from
Enron North America Corp. in March 2000. The purchase was finalized in July 2000.
During the period when Enron North America Corp made Coyote Springs 2 available to the
market, A vista Corporation was performing initial screening and investigation of potential
combined cycle combustion turbine generation sites and options in the region. A vista
Corporation was planning to conduct an all-resource RFP in summer 2000 that would evaluate
proposals for power supply and power generation projects from the market as well as company
cost-based generation build options. The timing of the offer of Coyote Springs 2 in the market
by Enron North America Corp. pre-dated Avista Corporation s RFP process.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
Potlatch
Data Request
DATE PREPARED:
WITNESS:
RES PO ND ER:
DEPARTMENT:
TELEPHONE:
4/2712004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please provide a statement of A vista Power s total purchase price for Coyote Springs 2 and a
breakdown of Avista Power s purchase price by asset categoies, i., how much was for land
equipment, licenses, etc.
RESPONSE:
The requested materials are being provided with Avista s data response to Potlatch, number4(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information and
are separately filed under IDAPA 31.01.01 , Rule 067 , and Section 9-340D, Idaho Code.
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
Potlatch
Data Request
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
5/612004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please provide copies of all documents related to any transaction or correspondence between
A vista Power or A vista Corporation or any of its subsidiaries or affiliates, on the one hand, and
UM2 Co-Investment LP , on the other, during the period January 1 , 1999 to the present.
RESPONSE:
The requested materials are being provided with A vista s data response to Potlatch, number
3(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information and
are separately filed under IDAPA 31.01.01 , Rule 067, and Section 9-340D, Idaho Code.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
Potlatch
Data Request
DATE PREP ARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
4/27/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please provide a statement of the consideration A vista Power received for the transfer of
ownership or control of Coyote Springs 2 and a breakdown of such consideration by asset
categories, i.e., how much was for land, equipment, licenses, etc.
RESPONSE:
The requested materials are being provided with A vista s data response to Potlatch, number
7(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information and
are separately filed under IDAPA 31.01.01 , Rule 067 , and Section 9-340D, Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
Potlatch
Data Request
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
4/27/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please provide a statement of the total amount A vista Power had spent on Coyote Springs 2 at
the time of such transfer, and a breakdown of such amount by asset categories , i., how much
was for land, equipment, licenses, etc.
RESPONSE:
The requested information is provided with Avista s data response to Potlatch, number 7(C).
The materials provided contain TRADE SECRET or CONFIDENTIAL information and are
separately filed under IDAPA 31.01.01 , Rule 067 , and Section 9-340D , Idaho Code.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
Potlatch
Data Request
DATE PREPARED:
WITNESS:
RES PONDER:
DEP ARTMENT:
TELEPHONE:
4/2712004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please provide a statement of the total amount A vista Corporation or any of its subsidiaries or
affiliates had spent on Coyote Springs 2 at the time of such transfer to Mirant, and a breakdown
of such amount by asset categories, i., how much was for land, equipment, licenses, etc.
RESPONSE:
The requested materials are being provided with A vista s data response to Potlatch, number
lO(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information
and are separately filed under IDAPA 31.01.01 , Rule 067, and Section 9-340D, Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
Potlatch
Data Request
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
412712004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please provide a statement of the consideration A vista Corporation and/or its affiliates and
subsidiaries received for the transfer of ownership or control of a portion of Coyote Springs 2 to
Mirant, and a breakdown of such consideration by asset categories, i., how much was for land
equipment, licenses, etc.
RESPONSE:
The requested information is provided with Avista s data response to Potlatch, number lO(C) and
number 9(C). In addition, please see Exhibit #6, Schedule #11 of witness Robert Lafferty s Pre-
filed Direct Testimony. The materials provided contain TRADE SECRET or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01 , Rule 067 , and
Section 9-340D, Idaho Code.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
Potlatch
Data Request
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
5/312004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please provide a statement of the earliest construction cost estimate for Coyote Spring 2, broken
down by cost categories, together with a corresponding statement of the final cost for each
category and for the plant as a whole.
RESPONSE:
The requested materials are being provided with Avista s data response to Potlatch, number
12(C). The materials provided contain TRADE SECRET or CONFIDENTIAL information
and are separately filed under IDAPA 31.01.01 , Rule 067, and Section 9-340D, Idaho Code.
The materials provided contain TRADE SECRET or CONFIDENTIAL information and are
separately filed under IDAPA 31.01.01, Rule 067 , and Section 9-340D, Idaho Code.