200406072nd Request of Coeur Silver Valley to Avista.pdf

CHARLES L. A . COX
EVANS, KEANE
O. Box 6 5 9
111 Main StreetKellogg, Idaho 83837
Phone: ( 2 0 8 ) 784 - 1105
Fax: ( 2 0 8 ) 7 8 3 - 7 6 0 1
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.
CA"SE NOS.AVU-O4-
AVU-O4-
INTERVENOR COEUR SILVER
VALLEY, INC.' S SECOND SET
OF DISCOVERY REQUESTS TO
AVISTA CORPORATION
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
Coeur requests aUtilities Commission s Rules of Procedure.
response to these requests within twenty-one
days.
Definitions and Instructions
The interrogatories and document requests are governed by
the following definitions and instructions:
DEFINITIONS
You,
" "
your" or "A vista " means or pertains to the
named respondent in this matter and includes, without
limitation, Avista, its officers, directors, employees,
agents, attorneys, corporate subsidiaries andaffiliates.
2 .Persons " means any and all natural persons,
corporations, businesses, firms, companies,
partnerships, unincorporated associations, governmental
or public agencies, joint ventures and all other
INTERVENOR COEUR SILVER VALLEY INC.' S SECOND SET OF
DISCOVERY REQUESTS TO AVISTA CORPORATION
3 .
entities, including, without limitation, all employees,
representatives, consultants and agents of any of theforegoing.
Documents " means any and all written, electronic or
graphic matter, of any kind or description, however
created, produced, reproduced or stored, whether sent
or received, or whether originals, copies or drafts,
including, but not limited to, every side of every page
of all letters, papers, books, correspondence,
bulletins, circulars, instructions, telegrams, cables,
telex messages, facsimiles, memoranda, notes,
notations, work papers, transcripts, minutes, reports,
recordings of notes or meetings, conferences,
interviews or telephone or other conversations,
affidavits, statements, summaries, opinions, studies,
analyses, evaluations, work sheets, contracts,
agreements, journals, statistical records, desk or
pocket calendars, appointment books, diaries, lists,
tabulations, advertisements, sketches, drawings, blue
prints, catalogs, audio or video records, photographs,
computer printouts, e-mail transmissions, data
processing input and output, deeds, microfilm, all
other records kept by electronic, photographic or
electrical means, and things similar to any of the
foregoing however denominated.
4 .Relating to " or "Relate (s) to " means directly or
indirectly mentioning, consisting of, evidencing,
describing, referring to, pertaining to, being
connected with, or reflecting upon the stated subject
matter.
5 .The words "any" and "all" shall be considered to
inc 1 ude each and every.
6 .The singular of any word shall include the plural and
the plural of any word shall include the singular.
7 .The word "expert" as used herein includes any person
who will be offering expert testimony on behalf of
Avista or who has been consulted or relied upon by any
person who assisted in the preparation of the responses
to these interrogatories and document production
requests or who will be offering testimony on behalf of
Avista in this matter.
2 .INTERVENOR COEUR SILVER VALLEY INC.' S SECOND SET OF
DISCOVERY REQUESTS TO AVISTA CORPORATION
INSTRUCTIONS
In answering these interrogatories and document
requests,
you are required to furnish all information that
is available to
you, or subject to your reasonable inquiry, including the
information in the possession of you, your attorneys or other
persons directly, or indirectly employed by, or connected with,
you or your attorneys, and anyone else other wise
subj ect to your
control. I answering each interrogatory and document request:
A. Identify by title, heading or caption, date, sender,
recipient, location and custodian, each document relied upon,
reviewed or which forms a basis for the response given or which
corroborates or relates to the response given or the
subj ect
what is given in response to these discovery requests.
B. State whether the information furnished is within the
personal knowledge of the person responding and, if not, the
name, if known, of each person to whom the information is a
matter of personal knowledge.
C. Identify each person who assisted or participated in
preparing and/ or supplying any of the information given in
response to or relied upon in preparing responses to thesediscovery requests.
D. Where a discovery request calls for a response in
multiple parts, each part should be separated in the response so
that the response is clearly understandable and complete.
E. Where the name or identity of a person is requested,
state the full name, business address, and any telephone numbers
of each person.F. If any of your responses require the production of
documents, label the documents to indicate the discovery request
to which you are responding.
G. If you obj ect to the production of any document called
for in these document requests, for each such document state the
following: (1) the reasons for the obj ection and any facts
supporting the objection; (2) give a description of each document
including, without limitation, the date, sender, recipient (s) ,
persons to whom copies have been furnished, mob titles of each of
the persons, subj ect matter of the document, number of pages of
the document, the number (s) of the request to which such document
is responsive and the identity of the person in whose custody the
document is presently located.
3 .INTERVENOR COEUR SILVER VALLEY INC.' S SECOND SET OF
DISCOVERY REQUESTS TO AVISTA CORPORATION
H. If any document is withheld under claim of privilege or
work product, furnish a list identifying each document for which
the privilege or work product is claimed, together with the
following information for each such document: date, sender,
recipient (s), persons to whom copies were furnished, job titles
of each of those persons, subj ect matter of the document, number
of pages of the document, the basis on which the privileges or
work product is claimed, the paragraph (s) of these requests to
which the document responds, the person in whose custody the
document is presently located, and whether any matter that is not
privileged or is not work product is discussed or mentioned in
each document.I. If any document requested was, but is no longer in the
possession or subj ect to the control of Avista, or is n longer in
existence, state whether it: (1) is missing or lost; (2) has been
destroyed; (3) has been transferred voluntarily or involuntarily
to others and state the identity of the persons to whom
it has
been transferred; (4) has otherwise been disposed of, or in each
instance explain the circumstances surrounding such disposition,
state the date or approximate date thereof and the identity
the person with knowledge of such circumstances; (5) identify the
documents that are missing, lost, destroyed, transferred or
otherwise disposed of, by author, date, subj ect matter,
addressee (s), and the number of pages.J. If you do not clearly understand, or have any questions
about, these definitions, instructions, interrogatories or
requests, contact counsel for Coeur promptly for clarification.
K. These discovery requests are continuing in nature and
require supplemental responses upon the discovery or receipt of
new or additional information.
REQUEST NO.8: Please provide a cost-of service analysis,
including all new work papers and changed allocation factors that
address the following changes for Schedule 25:a. Schedule 25 has the cost of 15 substations (Acct. 361
and 362) directly assigned in whole or in part. For
each of these substations please list the name of the
Schedule 25 customer supplied as well as the miles of
primary and/or secondary line that is supplied by the
directly assigned piece of each substation.
Please list the circuit miles of primary line out
4 .INTERVENOR COEUR SILVER VALLEY INC.' S SECOND SET OF
DISCOVERY REQUESTS TO AVISTA CORPORATION
each "directly assigned" substation or portion of the
substation that serves a Schedule 25 customer in whole
or in part. Please indicate how many and what type of
other customers may be also served of that line going
to the Schedule 25 customer. Please use the ratio of
the miles of primary line utilized by Schedule
customers (in whole or shared) to the total primary
line circuit miles to develop an allocation factor for
Accounts 364 and 365.
Please directly assign any underground plant (Acct. 367
& 368) that serves Schedule 25 and Coeur Mining and,
please remove the allocation of this plant such that
only plant that is actually used by these customers
assigned/ allocated to them.
REQUEST NO.9: Please provide a cost-of-service analysis,
including all new work papers and changed allocation factors that
address the following changes for Schedule 25 and using one of
the "open" columns to treat Coeur Mines as a separate customer
(similar to potlatch)
5 .
Schedule 25 has the cost of 15 substations (Acct. 361
and 362) directly assigned in whole or in part. It
believed that three of these substations are directly
related to Coeur Mining. For each of these substations
please list the name of the Schedule 25 customer
supplied as well as the miles of primary and/or
secondary line that is supplied by the directly
assigned piece of each substation.
Please list the circuit miles of primary line out
each "directly assigned" substation or portion of the
substation that serves a Schedule 25 customer or Coeur
Mining in whole or in part. Please indicate how many
and what type of other customers may be also served
INTERVENOR COEUR SILVER VALLEY INC.' S SECOND SET OF
DISCOVERY REQUESTS TO AVISTA CORPORATION
that line going to the Schedule 25 customer. Please
use the ratio of the miles of primary line utilized by
Schedule 25 customers (in whole or shared) to the total
primary line circuit miles to develop an allocation
factor for Accounts 364 and 365.
Please directly assign any underground plant (Acct. 367
& 368) that serves Schedule 25 and Coeur Mining and,
please remove the allocation of this plant such that
only plant that is actually used by these customers
assigned/allocated to them.
REQUEST NO. 10: If there is any underground primary plant
serving any Schedule 25 customer, please give the distance of the
circuit (s) in miles.
Dated this 3rd day of June, 2004.
EVANS, KEANE
....'..-
By: (" C---:7
Charles L./ 0
Attorney ~c0f Coeur Silver Valley
6 .INTERVENOR COEUR SILVER VALLEY INC.' S SECOND SET OF
DISCOVERY REQUESTS TO AVISTA CORPORATION
CERTIFICATE OF SERVICE
I hereby certify that I have this 3rd day of June, 2004,
served the foregoing INTERVENOR COEUR SILVER VALLEY, INC.' S
SECOND SET OF DISCOVERY REQUESTS TO AVISTA CORPORATION upon all
parties of record in this proceedings by e-mail to:
David J. Meyer
Sr. Vice President and General Counsel
Avista Corporation
O. Box 3 727
1411 East Mission Ave., MSC-Spokane, WA 99220-3727
david. meyer~avistacorp. com
Kelly Norwood
Vice President - State & Fed. Reg.
Avista Utilities
O. Box 3 72 7
1411 East Mission Ave., MSC-
Spokane, WA 99220-3727kelly. norwood~avistacorp. com
Scot t Woodbury
John Hammond
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington (83702)
P . O. Box 83 72 0Boise, ID 83720-0074
swoodbu~puc. state. id. us
j hammon~puc . state. id.
Conley E. Ward
Givens Pursley LLP
601 W. Bannock St.
P . O. Box 2 72 0
Boise, ID 83701-2720
cew~gi venspursley . com
Dennis E. Peseau, Ph. D.
Utility Resources, Inc.
1500 Liberty Street SE,
Salem , OR 97302
dpeseau~exci te . com
Suite 250
7 .INTERVENOR COEUR SILVER VALLEY INC.' S SECOND SET OF
DISCOVERY REQUESTS TO AVISTA CORPORATION
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
bmpurdy~hotmai 1 . com
8 .INTERVENOR COEUR SILVER VALLEY INC.' S SECOND SET OF
DISCOVERY REQUESTS TO AVISTA CORPORATION