2004051411th Request of Staff to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTACORPORATIONFOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO.
CASE NOS. A VU-04-
A VU -04-
ELEVENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission (IPUC), by and through its attorney of
record, Scott Woodbury, Deputy Attorney General, requests that A vista Corporation (A vista;
Company) provide the following documents and information on or before FRIDAY,
MAY 28, 2004.
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.
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.
ELEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 14, 2004
For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.
CDs and all underlying formulas intact in Excel 2000 compatible language.
ST AFF PRODUCTION REQUEST NOS. 265 THROUGH NO. 281 PERTAIN TO
ELECTRIC ISSUES
Request No. 265: To the extent not provided in response to Staff Request No. 243 , please
provide a copy of any operations and maintenance agreements between A vista, Mirant, and PGE
for operation of the Coyote Springs II (CS II) plant. What recourse does A vista have against PGE
in the event PGE negligently operates the plant causing losses or forgone gains to A vista?
Request No. 266: On page 16, lines 13-20 of Robert Lafferty s testimony, he discusses
options considered by Avista for sale of portions or all of the CS II project and states that three
proposals were received. Please describe the process followed by the Company to solicit proposals
for purchase of all or portions of the plant. Did the Company issue a Request For Proposals (RFP)?
If so, please provide a copy. Does A vista believe that a fair and reasonable price was obtained
given that only three proposals were received and considered?
Request No. 267: The direct testimony of Robert Lafferty includes an Exhibit No.
Schedule 10 that appears to be an analysis of estimated revenue requirement impacts of three of the
proposals considered in the RFP. The analysis appears to have been done subsequent to a decision
being made by A vista to select the CS II proposal. There appears to be no narrative discussion of
Schedule 10 in Mr. Lafferty s testimony. Please discuss the purpose of the analysis shown in
Schedule 10 and any conclusions Avista reached based on the results of that analysis.
Request No. 268: How much did Avista pay for its share of the first failed GSU
transformer at CS II? How much did A vista pay for its share of the costs to clean up the site due to
the oil spill? How much of Avista s share of these costs is being sought for recovery in this rate
case? If additional costs are awarded through insurance claims, how does the Company propose
that those proceeds be treated for ratemaking purposes?
ELEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MAY 14, 2004
Request No. 269: Has Avista performed any analysis or computations to determine the
cost impact of the delayed commercial operation date of the CS II plant (i., inability to generate
between August 2002 and July 2003)? How many MWh would the plant have produced given
market conditions during the period and what was the estimated value of those MWhs? How much
higher were Avista s net power supply costs during this period as a result ofCS II's unavailability?
Request No. 270: Has a spare GSU transformer been procured for the CS II project? If so
what was the cost? Is recovery of the cost of the spare GSU transformer sought in this rate case?
Request No. 271: With regard to the second, most recent, failure of the GSU transformer
at CS II for which repairs are now underway, has a cause of failure been determined? What is the
expected cost of repair? Is any insurance recovery expected for the cost of the repair?
Request No. 272: Robert Lafferty s testimony at page 6, lines 23-26 and at page 63, lines
15-19 refers to project costs for Boulder Park being higher than expected due in part to the fast
track design and construction approach. According to Don Falkner s testimony at page 22, lines
10-, the Boulder Park project became commercially operational in May 2002. However, in 2001
materials presented to the Company s Board of Directors, Boulder Park was anticipated to be
operational September 1 , 2001. Please reconcile why the project's operational date was delayed
despite Avista incurring higher project costs with the intent of bringing the project's generation on-
line more quickly during the period of high power prices.
Request No. 273: On page 6, lines 22-23 and on page 63, line 14 of Robert Lafferty
testimony, he states in referring to the Boulder Park project"
. . .
that the Company reasonably
managed project costs given the circumstances." Please elaborate on what is referred to as "given
the circumstances.
Request No. 274: Were the two natural gas fired reciprocating engines planned for the
Spokane Industrial Park ever purchased? If so, were they ever installed? If they were purchased
but never installed, does A vista still own the units or have they been sold?
ELEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MAY 14, 2004
Request No. 275: Referring to Robert Lafferty s confidential Exhibit No., Schedule 35
page 1 of 4, please explain what is represented and how the amounts were calculated in the two
columns on the far right hand side of the page labeled 6/4/01 Value and 6/11/01 Value.
Request No. 276: Please provide a copy of the Municipal Development Agreement
between Washington Water Power (Avista) and the City of Rathdrum dated April 22, 1993. Also
provide a copy of any and all amendments to the original agreement. Please state why A vista
believes that payments made to Rathdrum under the agreement should be allowed for ratemaking
purposes.
Request No. 277: Robert Lafferty s Exhibit No., Schedule 36, page 11 of 11 (Kalich'
4/8/02 economic analysis of the Kettle Falls CT) shows the project generating 12.1 GWh in 2004
and 14.2 GWh in 2005. However, Kalich's Exhibit No. 11 shows the Kettle Falls CT generating
only 1.0 GWh. Please explain why this difference is so large. Please revise Schedule 36, page 11
using operation consistent with Kalich Exhibit No. 11.
Request No. 278: Has the loss of load in the aluminum industry, specifically that non-
system load at Kaiser Mead, restricted A vista s ability to make off-system sales or purchases due to
changes in transmission capacity? If so, have these changes in transmission capacity been reflected
in A vista s AURORA modeling?
Request No. 279: Please provide a copy of the cogeneration contract referred to on page
, lines 18-19 of Robert Lafferty s testimony. How much was paid under the contract?
Request No. 280: Referring to William Johnson s Exhibit No. 10, Schedule 1 , page 1 of2
lines 42-, please explain why the adjustment is positive for Boulder Park gas while the
adjustment is negative for Rathdrum gas, Kettle Falls CT gas and Northeast gas. Was the actual
operation of the Boulder Park project in 2002 less than anticipated? If so, please explain why.
ELEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 14, 2004
Request No. 281: What was the price for energy and capacity in the three and one-half
year power purchase contract (7/1/2000-12/31/2003) from Centralia referred to on page 7, lines 8-
16 of Robert Lafferty s testimony?
Dated at Boise, Idaho, this
/,
day of May 2004.
~8. woJ
Scott Woodbury
Deputy Attorney General
Technical Staff:Rick Sterling
i:umisc:prodreq/avueO4.1 avugO4,lswll
ELEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MAY 14, 2004
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF MAY 2004
SERVED THE FOREGOING ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-04-
1/AVU-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
DAVID 1. MEYER
SR VP AND GENERAL COUNSEL
VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail dmeyer(illavistacorp.com
KELLY NORWOOD
VICE PRESIDENT STATE & FED. REG.
AVIS T A UTILITIES
PO BOX 3727
SPOKANE WA 99220-3727
E- mail Kelly .norwood(illavistacorp. com
CONLEY E WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ill 83701-2720
E-mail cew(illgivenspursley.com
DENNIS E PESEAU, PH. D.
UTILITY RESOURCES INC
1500 LIBERTY ST SE, SUITE 250
SALEM OR 97302
E-mail dpeseau(illexcite.com
CHARLES L A COX
EV ANS KEANE
111 MAIN STREET
PO BOX 659
KELLOGG ID 83837
E-mail ccox(illusamedia. tv
BRAD M PURDY
ATTORNEY AT LA W
2019 N 17TH ST
BOISE ID 83702
E-mail bmpurdy(illhotmail.com
MICHAEL KARP
147 APPALOOSA LANE
BELLINGHAM W 98229
E-mail michael(illawish.net
E-mail don.falkner(illavistacorp.com
SECRETARY
CERTIFICATE OF SERVICE