20060118TRC supp conf response AVU 1st, 2nd.pdf

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Peter 1. Richardson
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Tclephone: [phone]
Fax: [phone]
peter~ri chardsonando I eary. com
Mike Uda (pro hoc vice application pending)
DONEY, CROWLEY, BLUMQUIST, PAYNE & UDA
Suite 200
Diamond Block
Helena, MT 59601
[phone]
[phone]
muda~doneylaw.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.
VISTA CORPORATION, dba, Avista Utilities,
a Washington Corporation
Respondent
CASE NO. A VU-E-O5- 7
THOMPSON RIVER CO-GEN'SUPPLEMENTAL AND
CONFIDENTIAL RESPONSES
TO THE FIRST AND SECOND
PRODUCTION REQUESTS OF
AVISTA
Thompson River Co-G~ LLC
, ("
TRC"), acting by and through counsel, hereby
submit the following answers to A vista'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, KalispelI, MT 59901.
Thompson River Co-Gen, LLCSupplemental Response to Avista s FirstAnd-Seco~duction Requests
Request No. 16: With regard to coal supply, please state with what party the
arrangements exist, and please provide a copy of all documents that set forth the
arrangements.
A copy of said coal supply agreement is attached pursuant and subject to the Protective
Agreement between TRC and A vista.
Thompson River Co-Gen, LLCSupplemental Response to Avista s FirstAncfSec~duction Requests
Request No. 18: If the answer to Production Request 17 is yes, please state with whomthe arrangements exist, and please provide a copy of all documents that set forth such
arrangements.
Response to Request No.J8: A copy of the transmission agreement is attached pursuant
and subj ect to the Protective Agreement between TRC and A vista.
Thompson River Co-Gen, LLCSupplemental Response to Avista s FirstAnd'3e~duction Requests
Request No. 25: Is there common management or operational agreement or arrangement
between Thompson River Lumber and Thompson River Co-Gen? If there is suchagreement or arrangement, please describe the responsibilities of the parties and provide
a copy of those documents that set forth such agreement or arrangement.
Response to Request No. 25: A copy of the lease agreement and the steam sales
agreement are attached pursuant and subject to the Protective Agreement between TRC
and A vista.
Thompson River Co-Gen, LLCSupplemental Response to Avista s FirstAnd;'seCQQd..fr.oduction Requests
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Request No. 26: Please provide a copy of the steam sales agreernent(s) between
Thompson River Co-Gen and Thompson River Lumber.
Response to Request No. 26: A copy of the steam sales agreement was attached pursuant
and subject to the Protective Agreement between TRC and A vista to Response to RequestNo. 25.
RES
y s..UB
llirS 13th DAY OF JANUARY 2006
r& PETER RICHARDSON
I hereby certify that the confidential documents provided in this Supplemental Response
to Avista's First and Second Requests for Production of Documents is exempt ITompublic disclosure pursuant to Idaho Code Section 9-340D and mAPA 31.01.01.067 and
7i7
PETER RICHARDSON
Thompson River Co-Gen, LLCSupplemental Response to Avista s FirstAnd"Se~bduction Requests
CJE:1R'flfIFJrCA TJE OF SJE:RVJIClEY./
I hereby certify that on this 14 ja~ of January 2006, the THOMPSON RlVERCO-GEN'S SUPPLEMENTAL RESPONSES TO THE FIRST AND SECOND PRODUCTION
REQUESTS 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 ( ) FacsimileBoise, Idaho 83702 ( ) Electronic Mailjj ewel1~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
( ? Han~Iivered
~might 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~ght Mail
( )Facsimile
( ) Electronic Mail
Si~oo ft!!
THOMPSON RIVER CO-GEN, LLC
CERTJFICATE OF SERVICE -
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