20040812Supp. 1st Response of Staff to Potlatch.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
EGEIVED
J I ~-~tLLtJ (iJ
.,--,.
L.,
7Dfn ' f\. t'):UtlIM,b ,~ PH 3:83
(.1"- I'
~ :~:~
C c~ i ,H ~ I C" IILI I IL.J 'i""'
'("'
fiJ'-"- /, JI.;;.) '
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
FIRST PRODUCTION REQUEST
OF POTLATCH CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, hereby responds to Potlatch Corporation s (Potlatch;
Company) First Request for Production to the Idaho Public Utilities Commission Staff filed
June 28, 2004.
Regarding Potlatch's Production Request Nos. 2 and 3, Staff provides the following
responses. A telephonic conference has been arranged for 8/13/04 between Potlatch counsel Conley
Ward and Staff witness Terri Carlock with respect to the remaining outstanding Potlatch production
requests.
REQUEST NO.2: Page 5 at 1 to 3: Please describe Ms. Carlock's understanding of the
three standards.
RESPONSE NO.2: A) The Financial Integrity or Credit Maintenance Standard requires that
a company have the opportunity to earn a return sufficient to allow that company to meet or exceed
STAFF RESPONSE TO THE FIRST
PRODUCTION REQUEST OF POTLATCH AUGUST 12, 2004
the credit maintenance rating criteria so the company is financially viable and able to maintain the
existing credit rating. If the company is not financially viable or of investment quality the overall
return from all entities must be sufficient to begin to improve its credit quality. B) The Capital
Attraction Standard requires that a company have the opportunity to earn a return sufficient to allow
that company to meet or exceed the coverage and rating requirements to attract capital at reasonable
rates. Reasonable rates are dependent on the existing rating for the company. C) The Comparable
Earnings Standard requires that a company be allowed to earn a return comparable to that being
earned by other companies with similar risks. Similar returns for similar risks is one factor that
allows a company to retain and attract shareholders. D) When a company is involved in more than
one operation or entity then each operation or entity must share these responsibilities.
REQUEST NO.3: Page 5 at 8 to 12: Please explain how Ms. Carlock considered the
standards in her analysis.
RESPONSE NO.3: The standards were considered to make sure that my recommended
return on equity and overall rate of return will allow A vista the opportunity to earn a return that will
allow coverages and rating criteria to be within the range established by rating agencies to maintain
or improve A vista s credit ratings. This would also allow A vista to attract capital. I also detennined
that my recommendations were also in the range of those returns earned by other companies of
comparable risk.
Dated at Boise, Idaho, this
/'"
Clay of August 2004.
Scott oodbury
Deputy Attorney General
Technical Staff: Terri Carlock
i:umisc:prodreq/response/avueO4.1 avugO4.1sw staff response 1 to pot #s 2 and 3
STAFF RESPONSE TO THE FIRST
PRODUCTION REQUEST OF POTLATCH AUGUST 12, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF AUGUST 2004
SERVED THE FOREGOING STAFF RESPONSE TO THE FIRST PRODUCTION
REQUEST OF POTLATCH CORPORATION, IN CASE NO. AVU-04-l/AVU-04-
BY E-MAILING A COpy THEREOF AND BY MAILING A COpy THEREOF
POST AGE PREP AID 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.
VISTA 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 LIBERTY ST SE, SUITE 250
SALEM OR 97302
E-mail dpeseau~excite.com
CHARLES L A COX
EV ANS KEANE
III 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~hotmail.com
:J),
SECRETARY
CERTIFICATE OF SERVICE