20040601Responses of Avista to Staff.pdf

Avista Corp.
1411 East Mission POBox3727
Spokane, Washington 99220-3727
Telephone [phone]
Toll Free 800-727-9170
' '. ,.... ~ '-
'V'STA~
Corp.
F~'ILED
~fI'"" lt 1M LUCii.vUl'1 f~tl : tt....
May 28, 2004
iG I:;UBLiC
UTILlrlES COf~ir"1iSSION
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ill 83720-0074
Attn: Scott Woodbury
Deputy Attorney General
Re:Production Request of the Commission Staff
in Case Nos. A VU-04-01 and A VU-04-
Mr. Woodbury,
I have attached an original and three copies of A vista s response to Staff Data Request
No(s). 268, 268(C), 269, 270, 270(C), 271 , 271(C), 272, 273, 274, 275, 276, 277, 278
279, 279(C), 280, 281 , and 281(C).
If you have any questions, please call me at [phone].
~relY'
Mike Pi
Rate Analyst
Enclosures
Enclosures
Copy: C. Ward (Potlatch)
D. Peseau (Utility Resources, Inc)
A. Yankel (Yankel & Assoc., Inc)
7~ti
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
IPUC
Data Request
Staff - 268
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
5/26/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
How much did A vista 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?
RESPONSE:
The cost for the first GSU transformer was included in the fixed-price EPC contract with
NEPCO. The cost for the NEPCO EPC contract is shown on Confidential Exhibit No.
Schedule No. 15 rev. 1 , page 2, and line 25.
The amounts that A vista paid for its share of transformer clean up costs is being provided with
A vista s data response to Staff, Request No. 252(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
VU - E-04-0 1 / A VU -04-0 1
IPUC
Data Request
269
DATE PREPARED:
WITNES S
RESPONDER:
D EP AR TMENT:
TELEPHONE:
5/24/2004
Bob Lafferty
Bill Johnson
Power Supply
[phone]
REQUEST:
Has Avista performed any analysis or computations to determine the cost impact of the
delayed commercial operation date of the CS II plant (i.e., 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 of CS II's unavailability?
RESPONSE:
Yes. The estimated lost operating margin of the Coyote Springs 2 (CS2) plant, based on
daily electricity and natural gas prices, during the period August 15, 2002 through June 30, 2003
is $2,487 278 (system number). The estimated number of MWh the plant would have produced
during the period was 590 162.
It is difficult to know how much higher Avista s power supply were as a result of CS2
unavailability because the decisions Avista would have made regarding gas and/or electricity
purchases and sales would have been different had the plant been available. The estimates
provided above are based on a hypothetical daily dispatch and may not necessary reflect the
actual change in power supply expense.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
AVU-O4-01 / AVU-O4-
IPUC
Data Request
Staff - 270
DATE PREPARED:
WITNES S
RES PO ND ER:
DEP ARTMENT:
TELEPHONE:
5/26/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
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?
RESPONSE:
Yes, a spare transformer has been procured for Coyote Springs 2. The cost recovery of the spare
transformer is not part of this general rate case filing.
The cost of the transformer is being provided with A vista s data response to Staff, Request No.
270(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-
IPUC
Data Request
Staff - 271
DATE PREPARED:
WITNES S
RES PO ND ER :
D EP AR TMENT:
TELEPHONE:
5/26/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
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?
RESPONSE:
The data requested is being provided with Avista s data response to Staff, Request No. 271(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
AVU-O4-01 / AVU-O4-
IPUC
Data Request
Staff - 272
DATE PREPARED:
WITNES S
RESPONDER:
D EP AR TMENT:
TELEPHONE:
5/26/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
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 A vista incurring higher project costs with the intent of bringing the project's generation
on-line more quickly during the period of high power prices.
RESPONSE:
In addition to the description provided in the Pre-filed Direct Testimony of Robert Lafferty,
please also see response to Staff Data Request Nos. 248, 248(C), and 249 for information
concerning Boulder Park project time line delays and higher than anticipated construction costs.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
IPUC
Data Request
Staff - 273
DATE PREPARED:
WITNES S
RESPONDER:
DEPARTMENT:
TELEPHONE:
5/26/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
On page 6, lines 22-23 and on page 63 , line 14 of Robert Lafferty s 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.
RESPONSE:
In addition to the description provided in the Pre-filed Direct Testimony of Robert Lafferty,
please also see response to Staff Data Request Nos. 248, 248(C), and 249 for information
concerning Boulder Park project time line delays and higher than anticipated construction costs.
The circumstances surrounding the construction of the Boulder Park project generally stemmed
from the fast track design-build approach that the Company chose in order to bring small
generation on line as quickly as practical in order to mitigate the high prices and volatility in the
electric power market during the energy crisis. The fact that Boulder Park was the first
reciprocating engine-generator project that the Company had permitted, designed, constructed
and commissioned, when combined with the fast track design-build approach, contributed to
circumstances under which the Company managed this project.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
IPUC
Data Request
Staff - 274
DATE PREPARED:
WITNES S
RESPONDER:
DEPARTMENT:
TELEPHONE:
5/26/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Were the two natural gas fired reciprocating engines planned for the Spokane Industrial Park
ever purchased? If so, were they ever installed? IT they were purchased but never installed, does
A vista still own the units or have they been sold?
RESPONSE:
Yes, the two natural gas fired reciprocating engines for Spokane Industrial Park were purchased
but were not installed. The Company is continuing to evaluate the units for installation, but is
also offering these units for sale.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO:
Idaho
A VU-04-01 / A VU-04-
IPUC
Data Request
275
DATE PREPARED:
WITNES S
RESPONDER:
D EP AR TMENT:
TELEPHONE:
5/20/2004
Bob Lafferty
Bill Johnson
Power Supply
[phone]
REQUEST:
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.
RESPONSE:
The two columns labeled 6/4/01 Value and 6/11/01 Value represent the net present value
(NPV) of the projects on those two dates. The NPV was calculated by first determining the
operating margin of the projects by running the Prosym dispatch simulation model using the
forward electric and natural gas prices on those two dates. The resulting operating margin was
then incorporated into a revenue requirements worksheet that included the capital costs of the
projects and related fixed operation and maintenance costs. The NPV represents the net benefit
of the projects over their expected lives. These two columns show that as the forward price of
electricity declined during the early June 2001 period the net benefit of the projects decreased.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO:
Idaho
A VU-O4-01 / A VU-04-
IPUC
Data Request
276
DATE PREPARED:
WITNES S
RESPONDER:
DEPARTMENT:
TELEPHONE:
5/26/2004
Bill Johnson
Bill Johnson
Power Supply
[phone]
REQUEST:
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.
RESPONSE:
A copy of the Municipal Development Agreement between Washington Water Power
(Avista) and the City of Rathdrum dated April 22, 1993 and all amendments to the original
agreement are attached.
The payments to the City of Rathdrum (City) were required for the development of the
Rathdrum project. The development of the Rathdrum project was expected to require upgrading,
expansion and/or use of City services. The payments to the City provided compensation for
actions the City may have been required to undertake which were necessary for the development
of the project. Under the agreement no less than ninety percent of the payments made by the
Company were to be used for the construction, installation, maintenance or repair of streets and
roads, water systems and sewer systems within the City.
.. ,., "," ,",," h LV P-f'S 3- '-17/(5
MUNICIPAL DEVELOPMENT AGREEMENT
Il~CE:/IhJ.rc:oWW
4P/i 1 .
this
;, ~
day of April, 1993 , by and
Wa ter -Power Company, a Washington
do business in the state of Idaho ("WWP"
an Idaho municipal corporation (" City"
) .
THI S AGREEMENT datedbetween The Washington
corporation authorized to
and the City of Rathdrum
T N 'E S E T H
WHEREAS:
A. WWP is the owner of, or holds an option to purchase,
certain real property consisting of approximately 40 acres located
in section 32 , Township 52 North, Range 4 West, Boise Meridian
Kootenai County, Idaho, and more particularly described on Exhibit
"A", and generally depicted on the site plan Exhibit "B", both
attached hereto and by this reference incorporated herein (the"proj ect Site"
B. WWP proposes to construct and operate an electrical
generating facility on the Project site (the "Project"
C. The proj ect site is part of a larger parcel, consistingof approximately 82.44 acres located at the northeast corner of the
intersection of Meyer and Boekel Roads in Kootenai County, Idaho
(the "Property". At a meeting of the City Council held on January
, 1993 , the City approved the application of WWP for annexation
of the Property into the City, including the Project Site , with a
Comprehensive Plan and Zoning designation of Industrial as defined
in the City I S Zoning Code.
D. Under the current system of taxation, the City willrecei ve nominal revenues from the proj ect by way of real
personal property taxes , due to the fact that the proj ect will be
centrally assessed by the Idaho State Tax Commission , with the taxrevenues from such assessment being divided among the various
taxing districts in Kootenai County as a whole , in accordance with
Idaho Code S63-707.E. The development of the proj ect as proposed may require
upgrading, expansion and/ or use of City services , such as roads,water and sewer services , and police and fire protectionaddi tion to improvements provided by WWP, for which the City may
not be adequately compensated by additional property tax revenues
available to it from the Property, or from its regularly assessed
hookup and capitalization fees.
MUNICIPAL DEVELOPMENT AGREEMENT -
F. By this Agreement , the parties desire to provide for
payments to the City as compensation for additional City services
and other actions the City may prudently take which may be required
by the development of the Project , on the terms and conditions set
forth herein.
NOW, THEREFORE in consideration for the annexation and
industrial zoning of the Property, and in consideration for the
mutual covenants , conditions and agreements contained herein, the
parties agree as follows:
Sl. Term. The term of this Agreement shall be for a period
of twenty (20) years from the Commencement Date , unless soonerterminated as provided for herein.
S2. Payments. (a) Commencing January 31, 1994 , or January
31 of the year in which substantial completion of the proj ect
referred to in recital B above is anticipated , whichever is later
(the "Commencement Date"), WWP agrees to make annual payments to
the City as follows:
Year 1 through 5Year through 10
Year 11 through
Year 16 through 20
$195 000.00 per year
$190 000.00 per year
$175,000.00 per year
$160 000.00 per year
(b) Except as otherwise provided herein, such payments shall
remain fixed throughout the term of this Agreement , and shall not
be modified for inflation , interest or other similar factors.
S3. Property Tax Revenues. (a) The payments provided forunder S2 above shall constitute the liability of WWP to the City,
for real and personal property taxes whether paid pursuant to this
Agreement or otherwise. In the event that the assessment taxationor distribution of the property taxes attributable to WWP,
including the Project , are changed at any time during the term of
this Agreement , such that the City receives more property taxrevenues from WWP, whether from the proj ect or otherwise, the
amount of the payments to the city under S2 above shall be reduced
by an amount equal to the increased amount received by the City by
virtue of such change.
(b) Notwithstanding the foregoing, in the event that there
a change in the applicable law , such that the real and personal
property taxes payable to the City exceed the payments provided for
in S2 , above , WWP shall pay the new amount , and this Agreement
shall be of no further force or effect.
S4. Use of Funds. City shall use not less than ninetypercent (90%) of the payments made by WWP pursuant to this
Agreement for the construction , installation maintenance or repair
MUNICIPAL DEVELOPMENT AGREEMENT -
of streets and roads , water systems and sewer systems wi thin thecity.
ss.follows:Authority.City represents and warrants to WWP
(a) This Agreement has been duly authorized , executed
and delivered by city;
(b) City has the power and authority to execute , deliver
and perform this Agreement;
(c) This Agreement constitutes the legal, valid and
binding obligation of City, enforceable against it in accordance
with its terms; and
(d) Neither the execution , delivery or performance by
City of this Agreement , nor compliance with the terms thereof,
conflicts or will conflict with or will result in a breach or
violation of any of the terms conditions or provision of any Idaholawconstitutional provision governmental rule or regulation, or
any order, writ , injunction or decree of any court or governmentalauthori ty.
S6. continued Effect. This Agreement shall be binding upon
the parties hereto , and shall continue in full force and effect forso long as WWP (either itself or as agent for an owner of theProject or Project Site), or its subsidiary, affiliate
successor by merger, continues to operate the Project. The partiesspecif ically acknowledge and agree that this Agreement shall not be
binding upon a successor to WWP in the event of foreclosure
repossession or other involuntary transfer of the proj ect and/ or
Project site to or for the benefit of any creditor or creditors of
WWP , its subsidiary, affiliate , or successor by merger.
S7. Termination of Project. , for any reason and at any
time during the term of this Agreement , either ( 1) the proj ect is
not constructed or (2) the proj ect is terminated after
construction whether or not operation has commenced , or (3) the
Project is not operated after construction due to regulatory or
similar events beyond the control of WWP (other than mere lack of
need for power produced by the Project), this Agreement may be
terminated at the sole option of WWP upon the giving of written
notice to City to that effect. Upon such termination, WWP shall be
required to make the next two (2) annual installments. Thereafter
neither WWP nor any subsidiary, affiliate or successor shall have
any further liability for any payments under this Agreement.
MUNICIPAL DEVELOPMENT AGREEMENT - 3
IN WITNESS WHEREOF, the parties have executed this Agreement
the day and year first above written.
THE WASHINGTON WATER
POWER COMP ANY ATTEST:
'---~');-
Its: SR.. \J. j)~"tf.S RESou.R,cLf
CITY OF ATTEST:
\11150\01700\118
MUNICIPAL DEVELOPMENT AGREEMENT -
w?- PSQCS - ,-\cn 8 - 01
RiP
Washington Water Power
July 26, 1995
Ms. Judy Hollenbeck
City Clerk
City of Rathdrum
O. Box 67
Rathdrum, Idaho 83858
Dear Judy;
Enclosed is a copy of the executed Amendment to the Municipal Development Agreement
between WWP and the City of Rathdrum.
As you know, this amendment changes the payment schedule and provides for an advance of
000,000 to the City, which has already been forwarded under separate cover. According to
the new payment schedule, WWP' s next payment of $50,000 will be due before January 31
1997.
Please file this amendment with your copy of the Original Agreement.
Dana C. Zentz
Project Development Manager
cc:Mary Trudel
Janet Robnett
Tim Carlberg
The Washington Water Power Company P.O. Box 3727 Spokane, Washington 99220 [phone]/1-800-727-9170
SERVING EASTERN WASHINGTON AND NORTHERN IDAHO WITH ELECTRICITY AND NATURAL GAS
"i-
.. '
AMENDMENT TO MUNICIPAL
DEVELOPMENT AGREEMENT
THIS AMENDMENT to that certain Municipal Development Agreement
dated April 22, 1993 , by and between The Washington Water Power
Company, a Washington corporation authorized to do business in thestate of Idaho ("WWP"
),
and the City of Rathdrum an Idahomunicipal corporation ("Ci ty"
) .
IN CONSIDERATION FOR the mutual covenants, conditions and
agreements contained herein, the parties hereto agree that theMunicipal Development Agreement ref erred to above, a true copy of
which is attached hereto as Exhibit "A" and by this reference
incorporated herein, shall be amended as follows:
51. payment Schedule. The payment schedule provided forunder S2 of the Municipal Development Agreement is hereby amended
to provide for payments as follows:
On or before July 1 , 1995, WWP shall pay to City thesum of $1,000 000.00. There shall be no payment on
January 31 , 1996. Thereafter , annual payments shall be
resumed commencing January 31 , 1997 , and on or before
January 31 of each year thereafter for the balance of the
term of the Municipal Development Agreement and this
Addendum, as follows:
1/31/97 through 1/31/06 $ 50,000.per year
1/31/07 $155 240.(one time)
1/31/08 $175 000.(one time)
1/31/09 through 1/31/13 $160,000.per year
52. Termina tion of Proj ect. In the event the proj ect
terminated under any of the conditions set forth in S7 of the
Municipal Development Agreement , city shall reimburse to WWP thatamount by which the payments made pursuant to S 1, above , exceed the
amount which would have been paid to ci ty under the schedule
provided under S 2 of the Municipal Development Agreement , in the
absence of this Amendment.
53. continued Effect. Except as expressly modified
provided for herein , all other terms , covenants , conditions and
agreements set forth in the Municipal Devel opment Agreement shall
remain in full force and effect.
AMENDMENT TO MUNICIPAL DEVELOPMENT AGREEMENT - 1
DATED this ~l~day of June , 1995.
CXTY OP RATHDRUH:
Its: Mayor
THE WASHINGTON WATER
POWER COMPANY
\111S~O17~122
ATTEST:
C-/
AMENDMENT TO MUNICIPAL DEVELOPMENT AGREEMENT - 2
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-04-01 / A VU-04-
IPUC
Data Request
Staff - 277
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
OS/26/2004
Lafferty
Kalich
Energy Resources
[phone]
REQUEST:
Robert Lafferty s Exhibit No., Schedule 36, page 11 of 11 (Kalich's 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.
RESPONSE:
A gas plant's dispatch is dependent on the margin its operation will generate. In the 2002
analysis, the average implied market heat rate (calculated as the average of the monthly
electricity prices divided by natural gas price times 1000) was 9,238 Btu/kWh, with Q3 prices
averaging nearly 12 000 Btu/kWh. These figures were above the plant's then-estimated heat rate
of 8,845 Btu/kWh by enough to cover variable operation costs in many hours. The plant was
forecast to operate at a 14.6% capacity factor and generate 12.1 GWh of electricity.
The implied market heat rate since April 2002 has fallen below conditions present when the
analysis was completed. The power supply model, using prices current at the time of our filing,
dispatches gas-fired resources on an implied market heat rate of around 8 600 Btu/kWh, which is
below the plant's final estimated heat rate of 8,750 Btu/kWh. Bec~use the plant can generate
positive margins only when the market implied heat rate exceeds 8,750 Btu/kWh by enough to
cover variable O&M costs, there are very few hours where the plant is expected to run during the
2004/05 period.
The April 2002 analysis is a 25-year life-cycle evaluation of the plant; the proforma period
represents only one year of operations. The Company cannot revise a life-cycle analysis when
information is available for only one of the 25 years.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO:
Idaho
A VU-04-01 / A VU-04-
IPUC
Data Request
278
DATE PREPARED:
WITNES S
RESPONDER:
DEP AR TMENT:
TELEPHONE:
5/26/2004
Dick StOITO
Bill Johnson
Power Supply
[phone]
REQUEST:
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
Avista s AURORA modeling?
RESPONSE:
No. The loss of the Kaiser Mead load has not restricted Avista s ability to make off-
system purchases or sales. No changes have been reflected in the AURORA modeling.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
IPUC
Data Request
Staff - 279
DATE PREPARED:
WITNESS:
RES PONDER:
DEPARTMENT:
TELEPHONE:
5/26/2004
Lafferty
Lafferty
Energy Resources
[phone]
REQUEST:
Please provide a copy of the cogeneration contract referred to on page 60, lines 18-19 of Robert
Lafferty s testimony. How much was paid under the contract?
RESPONSE:
The requested materials are being provided with Avista s data response to Staff, Request No.
279(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-04-01 / A VU-04-
IPUC
Data Request
280
DATE PREPARED:
WITNES S
RESPONDER:
DEP ARTMENT:
TELEPHONE:
5/26/2004
Bill Johnson
Bill Johnson
Power Supply
[phone]
REQUEST:
Referring to William Johnson s Exhibit No. 10, Schedule 1 , page 1 of 2, 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.
RESPONSE:
The adjustment is positive for Boulder Park because the plant generates more in the
proforma (38,191 MWh) than it generated in the 2002 test year (8 537 MWh). One reason for
this is that the plant didn t began commercial operation until May 2002 (there was some test
generation in March and April 2002), while the proforma includes generation for an entire
twelve-month period. The plant ran based on economics in the 2002 test year.
The three other plants, Rathdrum, Kettle Falls CT and Northeast all generated more in the
2002 test year than they generate in the proforma, creating a negati ve adjustment for fuel
expense for those plants.
VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQ UES TER:
TYPE:
REQUEST NO.
Idaho
A VU-O4-01 / A VU-O4-
IPUC
Data Request
281
DATE PREPARED:
WITNESS:
RESPOND ER:
DEPARTMENT:
TELEPHONE:
5/20/2004
Bob Lafferty
Bill Johnson
Power Supply
[phone]
REQUEST:
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?
RESPONSE:
Please see response 281(C), which contains TRADE SECRET or CONFIDENTIAL
information, are exempt from public view, and are separately filed under IDAPA 31.01.01 , Rule
067, and Section 9-340D, Idaho Code.
CO NFID E NTIAL
ATTACHMENTS