20040819Avista Objection to 6th Request of Potlatch.pdf

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DAVID J. MEYER, Esq.
, CHIEF COUNSEL
for REGULA TORY AND GOVERNMENTAL AFF A1JB.~ fJ,UG \ VISTA CORPORATION
O. BOX 3727
1411 E. MISSION AVE., MSC-
SPOKANE, W A 99220-3727
davi d .1neyer~avistacorp. com
Attorney for A vista Utilities
[phone]
[phone] (FAX)
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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. A VU-O4-. AVU-G-O4-
VISTA CORPORATION'
0 BJECTI ON TO POTLATCH
CORPORATION'S SIXTH
SET OF DISCOVERY
REQUESTS TO A VISTA
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A vista Corporation, by and through its attorney of record, David J. Meyer, VP, Chief
Counsel for Regulatory and Governmental Affairs, hereby objects to Potlatch Corporation s Sixth
Set of Discovery Requests.
Request No. 86:
In Avista s latest quarterly earnings report, Gary Ely states that Avista has entered into a
non-binding letter of intent to purchase Mirant's half interest in Coyote Springs 2.
(a) Please provide a copy of the letter of intent.
(b) Please provide a statement of the purchase price and any tenns and conditions
agreed to by A vista and Mirant that are not included in the letter of intent.
Please provide copies of all studies comparing the cost and benefits of Coyote
Springs 2 to existing or potential alternative resources.
(c)
A VISTA'S OBJECTION TO POTLATCH'
SIXTH SET OF DISCOVERY REQUESTS Page
Response No. 86:
Avista respectfully objects to this request for infonnation. The possible purchase of
Mirant's interest in Coyote Springs 2 is not at issue in these proceedings; A vista has asked for no
rate relief or other regulatory treatment with respect to this potential transaction in this docket.
Should A vista consummate this purchase, any request for associated rate relief will be the subj ect
of future proceedings, which will afford all parties the opportunity for discovery.
Moreover, it should be recognized that only a confidential non-binding letter of intent has
been executed. A definitive purchase and sale agreement has yet to be negotiated and executed.
Unless and until such an agreement is reached, any such purchase remains indefinite.
Request No. 87:
Please explain how A vista proposes to finance the purchase of Mirant' s half of CS2.
Response No. 87:
Please see A vista s response to Request No. 86.
Request No. 88:
Please explain in detail why Avista is purchasing Mirant's half of coyote Springs 2 without
issuing a request for proposal.
Response No. 88:
Please see A vista s response to Request No. 86.
Request No. 89:
Please provide a copy of A visa s latest loads and resources forecast using average water or
its equivalent.
A VISTA'S OBJECTION TO POTLATCH'
SIXTH SET OF DISCOVERY REQUESTS Page 2
Response No. 89:
Please see Avista s response to Request No. 86.
Dated at Spokane, Washington, this 18th day of August, 2004.
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vid J. Meyer
VP and Chief Counsel for Regulatory
and Governmental Affairs
A vista Corporation
A VISTA'S OBJECTION TO POTLATCH'
SIXTH SET OF DISCOVERY REQUESTS Page 3