200405281st Request of Coeur Silver Valley to Avista.pdf

CHARLES L.A. COX
EVANS, KEANE
O. Box 659
III Main StreetKellogg, Idaho 83837Phone: ( 2 0 8 ) 784 -1105Fax: ( 2 0 8 ) 783 - 7601
E-Mail: ccox~usamedia.
Idaho State Bar No. 2745
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Attorneys for Coeur Silver Valley, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRI C AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO.
COEUR SILVER VALLEY, INC.' S
FIRST SET OF DISCOVERY
REQUESTS TO AVISTA
CORPORATION
CASE NOS.AVU-E-04-1
AVU-G-04-
YOU WILL PLEASE TAKE NOTICE that Coeur Silver Valley, Inc.
Coeur") requests that Avista Corporation ("A vista") answer the
following discovery requests in accordance with the Idaho Public
Utilities Commission's Rules of Procedure. Coeur requests a
response to these requests within twenty-one days.
REQUEST NO.1: The Company s response to Staff Request
contains in part a "2002 Electric Demand Study"Please answer
the following with respect to that study:a. Most of the data in that Study appears to be
available in an electronic format.Please provide
in electronic format all such data that
presently stored electronically from this study.
Also please produce electronically any other data
included in the response to Staff Request 29 that
may be in electronic format.
COEUR SILVER VALLEY , INC.' S FIRST SET OF DISCOVERY
REQUESTS TO AVISTA CORPORATION
2 .
The first table in the Study is labeled "Demand
12CP.xls Peak Calc CP 12-01-2003"The Total
(100,838) for Schedule 25P Potlatch agrees with
the value on Knox Exhibit 16, Schedule 2 page
line 18, as do many of the other values. Please
explain why the values for Schedule 25 and
Schedule 21-22 all have different values.
The first table in the Study is labeled "Demand
12CP.xls Peak Calc CP 12-01-2003"Please explain
the significance of the values near the top of that
page. Specifically, for January, explain the
meaning of the "estimation error" for Idaho and
Washington as well as how this error is estimated.
Does Idaho's estimation error of 55,586 kW mean that
Idaho's value was estimated 55,586 kW higher than
what was actually measured?
Please reconcile the data from this table for
January 29th with a system peak value of 1,383 MW
with the value found in the response to Staff
Request 173 (C) for the 2002 Hourly Load Data under
the CASSO Data Tab for the 18th hour on January 29,
2002.
Approximately the 4th page of the Study contains a
list of "Estimated non-Coincident Peak with Losses"
f .
values that appear to be what was used to develop
Exhibit 16, Schedule 2 page 31 line 20. Is thatcorrect? What is the significance/use of the values
on the next page under the heading of "1993 Peak
Study non-Coincident Peak" and how are these values
utilized in the cost of service study?
Approximately the 4th page of the Study contains a
list of "Estimated non-Coincident Peak with Losses"
COEUR SILVER VALLEY , INC.' S FIRST SET OF DISCOVERY
REQUESTS TO AVISTA CORPORATION
3 .
values that appear to be what was used to develop
Exhibit 16, Schedule 2 page 31 line 20. How are
these values related to the values above labeled
Estimate 12 Monthly Non-Coincident Peaks"What is
the significance/use of the values labeled "Estimate
12 Monthly Non-Coincident Peaks"
Several sections later in the Study there are tables
for each month that list what appears to be hourly
data for the peak day of each month. What is
contained under the column headings "Sum of IDOl"
Sum of IDll"
, "
Sum of ID21", and Sum of ID31"How
is this data used?
Several sections later in the Study there appear to
be monthly tables listing hourly usage under what
termed "ID25 Summary Report"Are these values at
the customer meter or do they include losses?How
are these values used to calculate the "Estimated
Non-Coincident Peak with Losses" values on the 5th
1 .
page of the Study? Please supply the comparable
hourly data for each month for Coeur Silver Valley
Inc. (electronically if possible)
Under the "ID25 Summary Report" for January 2002
there is listed a Report Total of 24,236,955.
Please reconcile this figure with the figures of
24,190,980 and 22,364,804 found on the first page of
the next section that lists kilowatt hours of each
Schedule 25 customer. In addition, please reconcile
this figure with the figure of 303,707 found for
Schedule 25 on Exhibit 16 Schedule 2 page 31 line
11.
COEUR SILVER VALLEY , INC.' S FIRST SET OF DISCOVERY
REQUESTS TO AVISTA CORPORATION
REQUEST NO.2: On Exhibit 16, Schedule 2 page 21 line 957
there is a direct assignment of Acct 362 Station Equipment to
Schedule 25. Upon what information is this direct assignment
made?
REQUEST NO.3: Given the fact that a direct assignment
made of Acct. 362 costs to Schedule 25, why isn't there a similar
direct assignment made of Primary related Acct. 364 through Acct
367 equipment that goes between the Station Equipment and the
Schedule 25 customers?
REQUEST NO.4: Please provide whatever information the
Company has available so that a direct assignment can be made of
Acct 364-367 costs that are associated with Schedule 25.
REQUEST NO.5: Please provide whatever information the
Company has available so that a direct assignment can be made of
Acct 364-367 costs that are associated with Coeur Silver Valley
Inc.
REQUEST NO.6: Please indicate if any Acct. 366 or 367
(underground) equipment is used to serve any Schedule 25
customer.
REQUEST NO.7: Please provide whatever information the
Company has available so that a direct assignment can be made of
Acct 364-367 costs that are associated with Coeur Silver Valley
Inc.
Dated this 26th day of May, 2004.
EVANS, KEANE
By. arles L. . Cox
Attorney for Coeur
Inc.Silver Valley,
4 .COEUR SILVER VALLEY, INC.' S FIRST SET OF DISCOVERY
REQUESTS TO AVISTA CORPORATION
CERTIFICATE OF SERVICE
I hereby certify that I caused a true and correct copy of the
foregoing COEUR SILVER VALLEY, INC. FIRST SET OF DISCOVERY
REQUESTS TO AVISTA CORPORATION to be e-mailed to the following-
named persons this 26th day of May, 2004:
David J. Meyer
Sr. Vice President and General Counsel
Avista CorporationO. Box 3727
1411 East Mission Ave., MSC-13
Spokane, WA 99220-3727
david. meyer~avistacorp. com
Kelly Norwood
Vice President
Avista Utilities
O. Box 3727
1411 East Mission Ave., MSC-7
Spokane, WA 99220-3727kelly .norwood~avistacorp. com
State & Fed. Reg.
Scot t Woodbury
John Hammond
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington (83702)
. P . O. Box 83 720
Boise, ID 83720-0074
swoodbu~puc. state. id. us
j hammon~puc . state. id. us
Conley E. Ward
Givens Pursley LLP
601 W. Bannock St.
P . O. Box 2 72 0
Boise, ID 83701-2720
cew~givenspursley. com
Denni s E. Peseau, Ph. D
Utility Resources, Inc.
1500 Liberty Street SE,
Salem, OR 97302
dpeseau~exci te . com
Suite 250
COEUR SILVER VALLEY, INC.' S FIRST SET OF DISCOVERY
REQUESTS TO AVISTA CORPORATION
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
bmpurdy~hotmai I . com
Michael Karp
147 Appaloosa Lane
Bellingham, WA 98229
michael~awish. net
6 .COEUR SILVER VALLEY , INC.' S FIRST SET OF DISCOVERY
REQUESTS TO AVISTA CORPORATION
EVANS, KEANE
A LIMITED LIABILITY PARTNERSHIP
KELLOGG OFFICE:ATIORNEYS AT LAW
111 MAIN STREET
O. BOX 659
KELLOGG, IDAHO 83837-0659
[phone]
FACSIMILE [phone]
evanskeane (!Y imbris. net
CHARLES LA. COX
May 26, 2004
Ms. Jean D. Jewell
Idaho Public Utilities
O. Box 83 72 0
Boise, ID 83720-0074
Commi s s ion
Dear Jean:
Re:Avista Corporation
IPUC Case Nos. AVU-E-04-1 and AVU-G-04-1
Enclosed for filing is Coeur Silver Valley,
Notice of Service.
Very truly yours,
--KJ l ,L--.CHARLES L. A . COX
CLAC :
Enc.
BOISE OFFICE:
1405 WEST MAIN STREET
BOISE, IDAHO 83701-0959
[phone]
FACSIMILE [phone]
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CHARLES L. A . COX
EVANS, KEANE
O. Box 65
III Main StreetKellogg, Idaho 83837Phone: ( 2 08 ) 784 -1105Fax: ( 2 0 8 ) 783 - 7601
E-Mail: ccox~usamedia. tv
Idaho State Bar No. 2745
Attorneys for Coeur Silver Valley, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR 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.
NOTICE OF SERVICE
CASE NOS.AVU-E-04-
AVU-G- 04-
TO:JEAN JEWELL
NOTICE IS HEREBY GIVEN that on the 26th day of May, 2004
Charles L.A. Cox of Evans, Keane, served COEUR SILVER VALLEY,
INC. ' S FIRST SET OF DISCOVERY REQUESTS TO AVISTA CORPORATION , by
forwarding a copy thereof , as well as a copy of this Notice of
Service, to:
David J. Meyer
Sr. Vice President and General Counsel
Avista Corporation
O. Box 3 72 7
1411 East Mission Ave., MSC-13Spokane, WA 99220-3727
david. meyer~avistacorp. com
Ke II Y Norwood
Vice President - State & Fed. Reg.
Avista Utilities
O. Box 3 72 7
1411 East Mission Ave., MSC-7
Spokane, WA 99220-3727kelly. norwood~avistacorp. com
NOTICE OF SERVICE
and a copy to:
Scot t Woodbury
John Hammond
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington (83702)
P . O. Box 83 72 0
Boise, ID 83720-0074
swoodbu~puc. state. id. us
jhammon~puc. state. id. us
Conley E. Ward
Givens Pursley LLP
601 W. Bannock St.
P . O. Box 272
Boise, ID 83701-2720
cew~gi venspursley. com
Denni s E. Peseau, Ph. D
Utility Resources, Inc.
1500 Liberty Street SE,
Salem, OR 97302
dpeseau~exci te . com
Suite 250
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
bmpurdy~hotmai I . com
Michael Karp
147 Appaloosa Lane
Bellingham, WA 98229
michael~awish. net
DATED this 26th day of May, 2004.
EVANS, KEANE
By:Ctl ;;;-
2 .NOTICE OF SERVICE