200407133rd Response of Staff to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLI CA TI 0 N
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. A VU-O4-
A VU -O4-
COMMISSION STAFF
RESPONSE TO THE
THIRD PRODUCTION
REQUEST OF A VISTA
CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, hereby responds to Avista Corporation s (Avista;
Company) Third Request for Production to the Idaho Public Utilities Commission Staff filed
July 8, 2004.
Request No. 14: At page 16, line 15, of Mr. Hessing s direct testimony he writes
, "
Staff
believes that it was extremely risky to lock the price of gas at a traditionally high price in a gas
market with prices falling even though forward electric prices were high." What is the basis for Mr.
Hessing s contention that prices were falling at the time? Please provide all supporting
documentation.
ST AFF RESPONSE TO THE THIRD
PRODUCTION REQUEST OF A VISTA JULY 13 2004
Response No. 14: Staff concluded that gas prices were falling based on historical spot
market price information contained in Staff Exhibit No. 139, Pages 23 , 24 and 25.
Dated at Boise, Idaho, this rJ, day of July 2004,
Scott Woodbury
Deputy Attorney General
Technical Staff: Keith Hessing
i:umisc:prodreq/response/avueO4.1 avugO4.1sw staff response 3 to av
STAFF RESPONSE TO THE THIRD
PRODUCTION REQUEST OF A VISTA JULY 13 2004
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF JULY 2004
SERVED THE FOREGOING COMMISSION STAFF RESPONSE TO THE
THIRD PRODUCTION REQUEST OF A VISTA CORPORATION, IN CASE
NO. A VU-04-l/A VU-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~avistacorp.com
KELLY NORWOOD
VICE PRESIDENT STATE & FED. REG.
AVIS T A UTILITIES
PO BOX 3727
SPOKANE WA 99220-3727
E-mail Kelly.norwood~avistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-mail cew~givenspursley.com
DENNIS E PESEAU, PH. D.
UTILITY RESOURCES INC
1500 LillERTY 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~usamedia.
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-mail bmpurdy~hotmai1.com
CERTIFICATE OF SERVICE