20060118TRC 2nd supp conf response Avista 2nd.pdf

Peter 1. Richardson
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
petercaJri chardsonando I eary. com
Mike U da (pro hoc vice application pending)
DONEY, CROWLEY, BLUMQUIST, PAYNE & UDA
Suite 200
Diamond Block
Helena, MT 59601
[phone]
[phone]
mudacaJdonevlaw.com
Attorneys for Complainant Thompson River Co-Gen, LLC
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
THOMPSON RIVER CO-GEN, LLC a
Colorado Company,
Complainant,
vs.
A VISTA CORPORATION, dba, Avista Utilities,
a Washington Corporation
Respondent
CASE NO. A VU-O5- 7
THOMPSON RIVER CO-GEN'
SECOND SUPPLEMENTAL
AND CONFIDENTIAL
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
VISTA
Thompson River Co-Gen, LLC
, ("
TRC"), acting by and through counsel, hereby
submit the following answers to Avista s Discovery Request. Peter Richardson, Michael
Uda, Mike Underwood and Mark Thompson prepared these answers. Mr. Underwood'
telephone number is [phone], and Mr. Thompson s telephone number is (406)
490-1109. The record holder in this instance is Mr. Underwood, and the records are
located at TRC's offices located at 8 1st Street E., Suite 205, Kalispell, MT 59901.
Thompson River Co-Gen, LLC
Second Supplemental Response to Avista
.. Secood. Production Request
Request No. 31: If the answer to Production Request NO. 30 is yes, please provide an
electronic Excel (or other 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 to Request NO. 31: Pursuant and subject to the Protective Agreement between
TRC and Avista, copies ofTRC's bills from NorthWestern are attached and an Excel file
containing the requested information has been e-mailed to Mr. Blair Strong, counsel for
A vista for his dissemination pursuant to the protective agreement in place between the
TRC and Avista.
Thompson River Co-Gen, LLC
Second Supplemental Response to Avista
.. SecOAGProduction Request
Zd::~IIS
16th DAY OF JANUARY 2006
ER RIC :.\SON
I hereby certify that the confidential documents provided in this Second Supplemental
Response to Avista s Second Request for Production of Documents is exempt from
public disclosure pursuant to Idaho Code Section 9-340D and IDAPA 31.01.01.067 and
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~~
PETER RI HARDSON
Thompson River Co-Gen LLC
Second Supplemental Response to Avista
,. Sec-Gnd"production Request
CERTIFICATE OF SERVICE
I hereby certify that on this 16th day of January 2006, the THOMPSON RIVER
CO-GEN'S SECOND SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF A VISTA was sent to the following parties as shown:
Jean Jewell (~. Mail, Postage PrepaidCommission Secretary ( ) Hand DeliveredIdaho Public Utilities Commission
( )
Overnight Mail472 West Washington
( )
Facsimile
Boise, Idaho 83702 ( ) Electronic Mail
11 ewell~puc.state.id. us
Scott Woodbury
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
swoodbury~puc.state.id. us
~. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
David J. Meyer
Vice President, Chief Counsel for
Regulatory & Governmental Affairs
A vista Corporation
PO Box 3727
Spokane W A 99220-3727
( ) U.S. Mail, Postage Prepaid
( )
Hand Delivered
~vernight Mail
( )
Facsimile
Electronic Mail
Kelly O. Norwood
Vice President, State & Federal Regulation
A vista Corporation
PO Box 3727
Spokane W A 99220
( ) U.S. Mail, Postage Prepaid
( )
Hand Delivered
~Overnight Mail
( ) Facsimile
~lectronic Mail
Signed
Peter Ric ardson
THOMPSON RIVER CO-GEN, LLC
CERTIFICATE OF SERVICE -
..-.