20070627Staff to Avista 1-3.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
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
VISTA CORPORATION FOR AN ORDER
REVISING A VISTA CORPORATION'S
OBLIGATIONS TO ENTER INTO CONTRACTS)
TO PURCHASE ENERGY GENERATED BY
WIND-POWERED SMALL POWER GENERATION FACILITIES.
CASE NO. A VU-07-
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 Avista Corporation (Avista; Company) provide the
following documents and information on or before WEDNESDAY, JULY 18, 2007.
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.
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 JUNE 27 2007
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: Please provide an estimate of the cost to purchase state-of-the-art wind forecasting
services as referenced in the Company s Petition. Please provide a detailed description of how each
QF's share of the on-going cost of the wind forecasting services will be determined. For what length
oftime would QFs be required to make a contribution for the cost of forecasting services? How would
costs be allocated amongst QFs that are built at different points in time?
Request No.2: Among other things, the Company s Petition seeks a Commission Order
Clarifying that the cap on entitlement to published avoided cost rates shall be raised to 10 aMW only
until Avista s total wind portfolio from all sources totals 400 MW." Please clarify whether the
Company s proposal as stated in its Petition is intended to mean that the Company will recompute its
wind integration cost when its total wind portfolio from all sources totals 400 MW or whether it is
intended to mean that a new cap on entitlement to published avoided cost rates would be restored at
that time.
Request No.3: Please explain how the proposed "mechanical availability guarantee" will be
computed during periods of time when there is not enough wind blowing for wind turbines to generate.
Respectfully submitted this 'n. day of June 2007.
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Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/avueO7.2swrps
FIRST PRODUCTION REQUEST
TO A VISTA JUNE 27 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF JUNE 2007 SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF,
IN CASE NO. AVU-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID
TO THE FOLLOWING:
R BLAIR STRONG
PAINE HAMBLEN LLP
717 W SPRAGUE AVE SUITE 1200
SPOKANE WA 99201-3505
CLINT KALICH
MANAGER OF RESOURCE PLANNING
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
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SECRETARY
CERTIFICATE OF SERVICE