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Home My WebLink About200510051st staff request to Thompson River.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff 1 ' . ' LI L ; ;~. (';,. , c ""' ,..,r;r""" " - "-4 ?: fJj l; J .1;1 '- ." L~~ r,~j F ~i ~:~ I~: ! \,(". Or'lfl1oSIOr.'. l~. ILJ BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION THOMPSON RIVER CO-GEN, LLC a Colorado Company, Complainant, vs. VISTA CORPORATION, dba, Avista Utilities a Washington Corporation, Respondent CASE NO. A VU-05- 7 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO THOMPSON RIVER CO-GEN The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that A vista Corporation (A vista; Company) provide the following documents and information on or before WEDNESDAY, OCTOBER 26, 2005. The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name location and phone number of the record holder. Reference IDAP A 31.01.01.228. FIRST PRODUCTION REQUEST TO THOMPSON RIVER OCTOBER 5, 2005 This Production Request is to be considered as continuing, and A vista is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced. Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. Request No.1: Does Thompson River Co-gen have any currently effective agreements with any party for the purchase and sale of electrical energy output from the Thompson River Co-gen facility? If so, please provide a copy of such agreements. Request No.2: Has Thompson River Co-gen ever had any agreements in the past with any party for the purchase and sale of electrical energy output from the Thompson River Co-gen facility? If so, please provide a copy of such agreements along with documentation that such agreements have been canceled, expired, or otherwise terminated. Request No.3: If the answer to Request No.2 is affirmative, please explain why past power purchase/sales agreements have been canceled or terminated. Do the prior contract purchaser(s) have a right of first refusal or any contract rights regarding future output of Thompson River Co-gen? Request No.4: Please provide a copy of all agreements that Thompson River Co-gen has with NorthWestern Energy that will be necessary in order for Thompson River Co-gen to sell electrical energy to A vista. Request No.5: Please provide a copy of any agreements Thompson River Co-gen has for the sale of electrical energy and/or steam to the Thompson River lumber mill. If no such written agreement exists, please describe the terms of and electrical power and/or steam sales between the two facilities. FIRST PRODUCTION REQUEST TO THOMPSON RIVER OCTOBER 5, 2005 Request No.6: Is there any common ownership of the Thompson River Co-gen facility and the Thompson River lumber mill? If so, please describe. Request No.7: Are there any facilities used in common by both the Thompson River Co-gen facility and the Thompson River lumber mill? If so, please describe. Request No.8: Please provide a complete history of the gross monthly generation produced by the Thompson River Co-gen facility from the time when the facility first became operational until the present. Request No.9: Please provide a complete historical breakdown of the gross monthly electrical energy production by the Thompson River Co-gen facility into the categories of a) electrical energy sales to Thompson River Lumber Company; b) electrical generation used internally by the Thompson River Co-gen facility; c) electrical energy sales to NorthWestern Energy; d) transmission losses incurred in delivery from the facility to NorthWestern Energy. Request No. 10: If the Thompson River Co-gen facility has the capability to generate more than 10 aMW on a monthly basis, please describe how Thompson River Co-gen intends to limit its generation under a contract with Avista to no more than 10 aMW on a monthly basis. Request No. 11: Does Thompson River Co-gen intend to sell any electrical energy to NorthWestern Energy after a power sales agreement with Avista becomes effective? Request No. 12: Please provide a copy of the draft contract that Thompson River Co- gen prepared and offered to A vista in response to A vista s August 2005 draft contract. Please mark those sections of the draft contract that Thompson understands A vista will not accept. Request No. 13: In reference to the October 5, 2005 article in the newspaper Missoulian please discuss whether the Thompson River Co-gen plant is currently operating. If the plant is currently not operating, please explain why, and when or if the plant is expected to FIRST PRODUCTION REQUEST TO THOMPSON RIVER OCTOBER 5 , 2005 again become operational. What actions must be taken before the plant can again become operational? Request No. 14: Has the Thompson River Co-gen plant been able to meet all federal and state air quality standards since if has been operational? Please discuss any standards that are not currently being met, any past or outstanding fines for failure to meet all standards, and all corrective actions that have been or will be taken in the future in order to meet all required standards. Respectfully submitted this 5 b.day of October 2005, cot oodbury Deputy Attorney General Technical Staff: Rick Sterling i:umisc:prodreq/avueO5.7swrps prl to Thompson River FIRST PRODUCTION REQUEST TO THOMPSON RIVER OCTOBER 5, 2005 CERTIFICA TE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF OCTOBER 2005 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO THOMPSON RIVER CO-GEN, IN CASE NO. AVU-05-, BY MAILING A COpy THEREOF POSTAGE PREPAID, TO THE FOLLOWING: DAVID J. MEYER SR VP AND GENERAL COUNSEL VISTA CORPORATION PO BOX 3727 SPOKANE W A 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 PETER J. RICHADSON RICHARDSON & O'LEARY PLLC 515 N 27TH ST BOISE ID 83702 E-mail peter~ri charsono leary. com MIKE UDA DONEY CROWLEY BLUMQUIST PAYNE & UDA SUITE 200 DIAMOND BLOCK HELENAMT 59601 E-mail muda~doneylaw.com b 1 SECRET AR Y CERTIFICATE OF SERVICE