20070717Staff to AVU 1-3.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
Street Address for Express M~il:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
VISTA CORPORATION TO APPROVE AN
AGREEMENT ALLOCATING SERVICE
TERRITORY WITH NORTHERN LIGHTS, INC. )
PURSUANT TO THE IDAHO ELECTRIC
SUPPLIER STABILIZATION ACT.
IN THE MATTER OF THE APPLICATION OF
VISTA CORPORATION TO APPROVE AN
AGREEMENT ALLOCATING SERVICE
TERRITORY WITH NORTHERN LIGHTS, INC. )
PURSUANT TO THE IDAHO ELECTRIC
SUPPLIER STABILIZATION ACT.
CASE NO. A VU-07-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
VISTA CORPORATION
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
Donald L. Howell, II, Deputy Attorney General, requests that Avista Corporation (Company;
Avista) provide the following documents and information as soon as possible, but no later than
JULY 25, 2007.
FIRST PRODUCTION REQUEST TO
A VISTA CORPORATION JULY 17 2007
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.
The following data requests apply to both applications to approve agreements allocating
territory submitted to the Commission by Avista Utilities and Northern Lights, Inc. and received
June 20 2007. Avista need only respond once for both cases. 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: With the continuing new development in the Sandpoint area, Staff's
concern is about stranded facilities as A vista and other electric suppliers vie for new customers.
Please explain what policies are in place and what planning efforts are employed to assure
Avista s customers and the Commission s Staffthat loss of investment, or stranded investment
does not occur?
REQUEST NO.2: In both cases did Avista and Northern Lights compare exactly how
much it would cost each to provide service to the two new developments, or perform a cost
analysis? If so, please provide those computations.
REQUEST NO.3: In both cases, referring to the areas surrounding each of the new
developments, is A vista aware of any plans for additional developments? Have A vista and
Northern Lights discussed who will provide service to these new customers? If so, please
provide a brief description for each of the planned developments and the factors that determined
who would serve the area.
DATED at Boise, Idaho , this 7f'day of July 2007.
Deputy Attorney General
Technical Staff: Dan Graves
i:umisc:prodreq/avueO7.5 - 6dhdg.doc
FIRST PRODUCTION REQUEST TO
A VISTA CORPORATION JULY 17 2007
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF JULY 2007
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTACORPORATION, IN CASE NOS. AVU-07-05ANDAVU-07-
BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERV AIS
REGULATORY ANALYST
A VISTA CORPORATION
1411 EMISSION AVE
SPOKANE W A 99220
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CERTIFICATE OF SERVICE