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Home My WebLink About20051222Avista 2nd requests of TRCG.pdfAvista Corp. 1411 East Mission POBox3727 Spokane. Washington 99220-3727 Telephone 509-489-0500 Toll Free 800-727-9170 , - .- Ii ~~\'V'STA. - .: ';;; , ) 0- - '. ,-:. Ie;:Corp. December 20, 2006 I; if-! !!i i;:Oj"/.F inr,,-hi Via Electronic and UPS Mr. Peter J. Richardson Richardson & O'Leary PLLC 515 N 27th Street Boise, ID 83702 RE:In the Matter of Thompson River Co-Gen, LLC v. Avista Corporation Docket No. A VU-O5- Dear Mr. Richardson: Enclosed please find Avista s Second Production Requests to Thompson River Co-Gen LLC in the above-referenced matter. Please provide a copy of your responses via "overnight delivery" to this office, with paper and electronic copies to Mike Fink. Additionally, please be advised that appropriate A vista employees and counsel will execute a confidentially agreement in order to review materials that Thompson River Co-Gen expressed a willingness to provide on a confidential basis in response to the First Production Requests. Thank you for your attention to this matter. If you have any questions, please do not hesitate to call Mr. R. Blair Strong in this matter. Sincerely yours 7ka; Kelly O. Norwood , State & Federal Regulation A vista Corporation Enclosures David J. Meyer VP and Chief Counsel for Regulatory & Governmental Affairs A vista Corporation 1411 E. Mission Avenue, MSC- PO Box 3727 Spokane; W A 99220-3727 (509) 495-4316 ,:C:::.!\I . ';-. . ~; ' , '-. L., DB !', i\JbLiCt: i! :(~ (' (i:": "'" JU!!110. j , BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION THOMPSON RIVER CO-GEN, a Colorado Company, Complainant vs. AVISTA CORPORATION, a Washington Corporation Respondent. CASE NO. A VU-05- SECOND PRODUCTION REQUESTS OF A VISTA CORPORATION TO THOMPSON RIVER CO-GEN TO: TO: COMPLAINANT, THOMPSON RIVER CO-GEN, and Your attorney, Peter J. Richardson A vista Corporation, requests that Complainant, Thompson River Co-Gen, provide the following documents and information no later than January 6 2006. These Second Production Requests are subject to the same Definitions and General Instructions set forth in the First Production Requests of A vista Corporation. Please provide the responses to these Production Requests to: Mr. David J. Meyer VP and Chief Counsel for Regulatory & Governmental Affairs A vista CogJoration 1411 E. MIssion Avenue, MSC- PO Box 3727 Spokane, W A 99220-3727 (509) 495-4316 (509) 495-4361 (FAX) david. mever(ipa vistacorp. com SECOND PRODUCTION REQUESTS OF A VISTA CORPORATION Mr. Mike Fink State & Federal Regulation A vista CogJoration 1411 E. MIssion Avenue, MSC- PO Box 3727 Spokane, W A 99220-3727 (509) 495-4706 (509) 495-8058 (FAX) mike. fink(W,avistacorp. com PRODUCTION REQUESTS These Production Requests are numbered following the sequence started in the First Production Requests. REQUEST FOR PRODUCTION NO. 29: With respect to your response to Production Request No., it appears that Thompson River Co-Gen only provided data for April, 2005. Please provide an electronic Excel (or other common commercially available) spreadsheet in machine readable format showing the amount of power, expressed in kilowatt-hours, delivered by Thompson River Co-Gen to the NorthWestern Energy transmission system as measured by the metering equipment located at the point of interconnection between the Project common electrical bus and the transmission system owned and operated by NorthWestern Energy for each hour of each day beginning with the first day on which the Project began to generate power and continuing through today. If such data can not be provided, please explain why. RESPONSE: REQUEST FOR PRODUCTION NO. 30: Does the data provided by Thompson River Co-Gen in response to Production Request No.6 include the electric load of the Thompson River Lumber Company? RESPONSE: REQUEST FOR PRODUCTION NO. 31 : If the answer to Production Request No. 30 is yes, please provide an electronic Excel (or other common commercially available) spreadsheet in machine readable format showing the amount of power, expressed in kilowatt-hours broken out by amount of power delivered to the Project and amount of power delivered to Thompson River Lumber, from the Project common electrical bus, when the Project is not generating power for each hour of each day beginning with the first day on which the Project began to generate power and continuing through today. RESPONSE: REQUEST FOR PRODUCTION NO. 32: With respect to your response to Production Request No., please provide an electronic Excel (or other common commercially available) spreadsheet in machine readable format showing the amount of power, expressed in kilowatt- hours, delivered from the Project to the Project common electrical bus net of Project load, when SECOND PRODUCTION REQUESTS OF A VISTA CORPORATION the Project is generating power, for each hour of each day beginning when the first day on which the Project began to generate power and continuing through today. (For clarification, Project load for purposes of the Production Requests excludes the electric load of Thompson River Lumber Company.) If this data is not available in the form requested, please provide whatever other net output or gross output data regarding project output that may be available in an electronic Excel (or other common commercially available) spreadsheet in machine readable format. RESPONSE: REQUEST FOR PRODUCTION NO. 33 : With respect to the response to Production Request No., please explain if NorthWestern Energy separately meters the flow of power to Thompson River Co-Gen and to Thompson Lumber Company? RESPONSE: REQUEST FOR PRODUCTION NO. 34:: Does NorthWestern Energy separately bill Thompson River Co-Gen for power used when the Project is not generating power? RESPONSE: REQUEST FOR PRODUCTION NO. 35: If the answer to Production Request No. 34 is yes, please explain how the bill to Thompson River Co-Gen is determined. RESPONSE: REQUEST FOR PRODUCTION NO. 36 : As a supplement to Production Request No. 11 , please provide an electronic Excel (or other common commercially available) spreadsheet in machine readable format showing the amount of power, expressed in kilowatt- hours, delivered to Thompson River Lumber Company as measured by the metering equipment located at the point of interconnection between the Project common electrical bus and the Thompson River Lumber Company for each hour of each day beginning with the first day on which the Project began to generate power continuing through today. Ifhourly data is not SECOND PRODUCTION REQUESTS OF A VISTA CORPORATION available, please provide that data which is available and responsive in electronic Excel (or other common commercially available) spreadsheet in machine readable format. RESPONSE: REQUEST FOR PRODUCTION NO. 37 : In the event that transmission is not available due to a line outage at Thompson River Co-Gen s proposed primary point of delivery to A vista at Burke, Idaho, please state if Thompson River Co-Gen is willing to deliver power to Avista to an alternative point of delivery in the state of Idaho at Thompson River Co-Gen s sole cost? RESPONSE: REQUEST FOR PRODUCTION NO. 38 : On what date did Thompson River Co-Gen and/or NorthWestern Energy make the determination that its long-term contract with NorthWestern Energy terminated? RESPONSE: REQUEST FOR PRODUCTION NO. 39: Please state the effective date of the termination of Thompson River Co-Gen long-term contract with NorthWestern Energy, and explain how that date was determined. RESPONSE: REQUEST FOR PRODUCTION NO. 40 : What is the maximum amount of firm energy deliverable from Thompson River Co-Gen to A vista under any transmission agreement that may be in place between NorthWestern Energy and Thompson River Co-Gen? RESPONSE: REQUEST FOR PRODUCTION NO. 41 : Please explain if the capacity limit under the transmission agreement for firm power from response to Production Request No. 39 above, is SECOND PRODUCTION REQUESTS OF A VISTA CORPORATION sufficient to provide for the delivery of dynamically delivered Project power to Avista on a firm basis during all hours. In your explanation, please explain how the full dynamic range of power deliveries will be accommodated under the firm transmission agreements in place between NorthWestern and Thompson River Co-Gen. RESPONSE: Respectfully submitted this 20th day of December, 2005 A VISTA CORPORATION /dlf )~ w=I By Kello/o. Norwood Vice President, State & Federal Regulation SECOND PRODUCTION REQUESTS OF A VISTA CORPORATION CERTIFICATE OF SERVICE I HEREBY CERTIFY (swear or affirm) that I have this day of, served the foregoing SECOND PRODUCTION REQUESTS OF A VISTA CORPORATION TO THOMPSON RIVER CO-GEN upon all parties of record in this proceeding, by mailing a copy thereof properly addressed with postage prepaid, to: Jean Jewell u.s. Mail, Postage Prepaid CommissIOn Secretary Hand Delivered Idaho Public Utilities Commission (X)Overnight Mail 1-172 West Washington Facsimile Boise, ID 83702 (X)Electronic Mail Email: iiewell~puc.state.id. Scott Woodbury u.s. Mail, Postage Prepaid Idaho Public Utilities Commission Hand Delivered 472 West Washington (X)Overnight Mail Boise, ID 83702 Facsimile Email: swoodbury(W,puc.state.id.(X)Electronic Mail Peter J. Richardson u.s. Mail, Postage Prepaid Richardson & O'Leary PLLC Hand Delivered 515 N. 27th Street (X)Overnight Mail Boise, ID 83702 Facsimile Email: peter(iprichardsonanddolearv.com (X)Electronic Mail Mike Uda S. Mail, Postage Prepaid Doney, Crowley, Bloomquist, Payne Hand Delivered &UdaP.(X)Overnight Mail 44 West 6th Avenue, Suite 200 Facsimile Helena, MT 59601 (X)Electronic Mail Email: muda(W,donevlaw.com SECOND PRODUCTION REQUESTS OF A VISTA CORPORATION