200406292nd Request of Avista to Staff.pdf

DAVID 1. MEYER, Esq.
, CHIEF COUNSEL
for REGULA TORY AND GOVERNMENTAL AFFAIRS
VISTA COROPRA TION
O. BOX 3727
1411 E. MISSION AVE., MSC-
SPOKANE, WA 99220-3727
david .1neyer~avistacorp. com
Attorney for A vista Utilities
[phone]
[phone] (FAX)
ECEJVED
II
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200ft JUy; 29 AM 8: 51
iLl JiG PUBLiC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF A VISTA 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.
CASE NOS. AVU-04-
A VU -04-
SECOND PRODUCTION
REQUEST OF AVISTA
CORPORATION
TO IPUC STAFF
Avista Corporation (Avista, Company), by and through its attorney of record, David J.
Meyer, VP, Chief Counsel for Regulatory and Governmental Affairs, requests that IPUC Staff
(Staff) provide the following documents and information on or before July 7th, 2004.
This Production Request is to be considered as continuing in nature and Staff is requested to
provide, by way of supplementary responses, additional documents that it or any person acting on
its behalf may later obtain or become aware of that will augment the documents produced.
In answering each request, please provide the name of the person(s) preparing the answer
along with the title and function such individual holds with your organization and the witness who
can sponsor the answer at the hearing.
For the following responses, please provide all workpapers, diskettes (3.5 in.), CDs and all
underlying formulas intact in Excel 2000 compatible language.
SECOND PRODUCTION REQUEST OF
AVISTA TO IPUC STAFF Page
Request No. 10: At page 7, line 13 of Mr. Hessings direct testimony he writes
, "
Staff
concluded that appropriate safeguards were not in place or followed to protect customers when the
regulated utility does business with its affiliate ? Please provide copies of the statute, order, rule or
guideline upon which Mr. Hessing was basing his statement regarding "appropriate safeguards.
Request No. 11: At page 7, line 15 of Mr. Hessing s direct testimony he writes
, "
Safeguards
could include a proper Code of Conduct or a requirement for lower-of-cost-or market pricing.
What statute, order, rule or guideline was Mr. Hessing relying on that requires Avista Utilities have
a Code of Conduct in place covering natural gas purchases or financial transactions with its affiliate
Avista Energy for fuel supply for electric generation? Please provide a copy of all relevant
documents.
Request No. 12: At page 7, line 15 of Mr. Hessing s direct testimony he writes
, "
Safeguards
could include a proper Code of Conduct or a requirement for lower-of-cost-or market pricing.
What statute, order, rule or guideline was Mr. Hessing relying on which requires A vista Utilities to
receive a price for physical or financial natural gas transactions at the lower of cost or market when
securing fuel supply for electric generation from its affiliate A vista Energy? Please provide a copy
of all relevant documents.
Request No. 13: At page 16, line 2, of Mr. Hessing s direct testimony he writes
, "
It is Staffs
position that the Company violated both the intent and the written requirements of its own Energy
Resources Risk Policy." What portions of, or wording from, the Company s Risk Policy did Mr.
Hessing rely upon to support his conclusion that A vista violated the written requirements of its own
Energy Resources Risk Policy?
Dated at Spokane, Washington, this 28th day of June, 2004.
~ Ly
ChiefCounsel for Regulatory
and Governmental Affairs
A vista Corporation
SECOND PRODUCTION REQUEST OF
AVISTA TO IPUC STAFF Page 2