200510051st staff request to Avista.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
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
THOMPSON RIVER CO-GEN, LLC a
Colorado Company,
Complainant,
vs.
VISTA CORPORATION, dba, Avista Utilities,
a Washington Corporation
Respondent
CASE NO. AVU-05-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
VISTA CORPORATION
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 IDAPA 31.01.01.228.
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.
FIRST PRODUCTION REQUEST
TO A VISTA OCTOBER 5 , 2005
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: What purchase price would be offered by Avista if the Thompson River Co-
gen facility is deemed to be greater than 10 aMW and thus not eligible for the published avoided cost
rates? Please provide an explanation of how this price is determined, along with supporting
documentation. Include input and output AURORA files if that is the basis for determination of the
pnce.
Request No.2: Please provide a copy and citation of the "net output" rule ofFERC as
referenced in A vista s Answer to the Thompson River complaint. If the "net output" rule of FERC
were to be adopted by the Commission in this case for purposes of measuring the output of the
Thompson River Co-gen facility, please describe or indicate by way of a sketch exactly where the
point of measurement of the facility s output would be.
Request No.3: Please provide a copy of the draft contract referred to on page 6, item 8 of
A vista s Answer to the Complaint of Thompson River Co-gen that A vista provided to Thompson River
Co-gen in early August 2005. Please mark those sections of the draft contract that A vista understands
Thompson will not accept.
Respectfully submitted this "5 day of October 2005.
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/avueO5.7swrps pr! to Avista
FIRST PRODUCTION REQUEST
TO AVISTA OCTOBER 5 , 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF OCTOBER 2005
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO A VISTA CORPORATION IN CASE NO. A VU-05-
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.
AVIS T A UTILITIES
PO BOX 3727
SPOKANE WA 99220-3727
E-mail Kell y .norwood~avistacorp. com
PETER J. RICHADSON
RICHARDSON & O'LEARY PLLC
515 N 27TH ST
BOISE ID 83702
E-mail peter~richarsonoleary.com
MIKE UD A
DONEY CROWLEY BLUMQUIST
PAYNE & UDA
SUITE 200
DIAMOND BLOCK
HELENAMT 59601
E-mail muda~doneylaw.com
-Jo
SECRETARY
CERTIFICATE OF SERVICE