2004051812th Request of Staff to Avista.pdf

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
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UTiliTIES COHt11SSfON
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-
TWELFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVIS TACO RPO RA TI 0 N
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 WEDNESDAY,
JUNE 2, 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 IDAPA 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.
TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 18 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.
STAFF PRODUCTION REQUEST NOS. 282 THROUGH NO. 289 PERTAIN TO
ELECTRIC ISSUES
Request No. 282: Please provide a Cost of Service analysis for General Service Schedule
, where Schedule 11 is separated between demand metered customers and non-demand metered
customers. The non-demand metered customers are all those who do not have demand meters.
Include the number of customers who are non-demand metered, and their normalized annual
energy use below and above 3650 kWh/month. Please provide this in Excel 2000 format.
Request No. 283: What is the cost justification for applying the PCA Surcharge on a
uniform percentage basis rather than a uniform cents/kWh basis to each service schedule.
Request No. 284: Has the Company considered Time of Use (TOU) rates for any of their
customers?
Request No. 285: What steps would be required, and what would be the cost to implement
TOU rates for Schedule 25?
Request No. 286: When are the critical peak hours for the system?
Request No. 287: Please provide a load duration curve; include the data table used to
create the curve. Specifically, the curve is a plot of the system peak that occurred over the 8760
hours of the year. Please provide this in Excel 2000 format.
Request No. 288: Please provide a supply cost duration curve; include the data table used
to create the curve. Specifically, this curve is a plot of the variable cost to produce or purchase
energy over the 8760 hours of the year. Please provide this in Excel 2000 format.
TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 18 2004
Request No. 289: Other than energy, what other services, if any, are provided to the
lighting schedules?
Dated at Boise, Idaho, this /~ay of May 2004.
Technical Staff:Dave Schunke
i:umisc:prodreq/avueO4.avugO4.1jhl12
TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 18, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF MAY 2004
SERVED THE FOREGOING TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO VISTA CORPORATION, IN CASE NO. A VU-04-
l/AVU-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
DAVID J. MEYER
SR VP AND GENERAL COUNSEL
VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail dmeyer(illavistacorp.com
KELLY NORWOOD
VICE PRESIDENT STATE & FED. REG.
A VIS T A UTILITIES
PO BOX 3727
SPOKANE W A 99220-3727
E-mail Kelly.norwood(illavistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 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~excite.com
CHARLES L A COX
EV ANS KEANE
111 MAIN STREET
PO BOX 659
KELLOGG ID 83837
E-mail ccox(illusamedia.
BRAD M PURDY
ATTORNEY AT LAW
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