20080605Staff to AVU 123-135.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
i";:; J
2906 JUri - 5 lt'i 3: l 3
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF A VISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO.
)
) CASE NO. A VU-E-08-1
) A VU.,G-08-1
)
) FOURTH PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TOAVISTACORPORATION
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Avista Corporation (Company;
Avista) provide the following documents and information on or before THURSDAY, JUNE 19,
2008.
FOURTH PRODUCTION REQUEST
TO A VISTA CORPORATION 1 JUE 5, 2008
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. 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
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 123: Please provide meter reading, biling, and other fixed monthly
customer cost for electric and natural gas customers. Show each category separately.
REQUEST NO. 124: For the Company, what economy is realized with service to a
customer taking both electric and natural gas service? In other words, how might each of the
costs listed above be changed by serving a customer with both electricity and natural gas?
REQUEST NO. 125: Please provide electric and natural gas forward prices for 2009
contract months as reported daily for all settlement dates durng the period Januar 1,2007
through the present for each of the locations included in the forward price data previously
provided in the workpapers of Clint Kalich. Please provide the data in an electronic Excel
format. Please include any analysis used to prepare, adjust or modify the data for use in
AURORA. Please cite the source for the price data and discuss any adjustments or assumptions
made by A vista in preparing the data.
REQUEST NO. 126: Why were natual gas price monthly forwards from October 1,
2007 through December 31, 2007 used to derive the pro forma period natural gas prices used in
the AURORA analysis (as opposed to using some other source or period of time)?
FOURTH PRODUCTION REQUEST
TO A VISTA CORPORATION 2 JUE 5, 2008
REQUEST NO. 127: In the direct testimony of Clint Kalich at page 9, lines 6-8, he
states "Natual gas prices are modified to ensure prices across the Western Interconnect are
consistent with changes made to the Northwest." Please explain how the natual gas prices are
modified.
REQUEST NO. 128: Please explain why 50 years of hydro data were used for Avista's
AURORA power supply modeling, rather than 70 years of hydro data. Provide a comparson of
the power generation and power cost results obtaned using 70 water years in a format similar to
that used in Kalich's Exhibit NO.5.
REQUEST NO. 129: Please provide the weather normalized 2007 and 2008 Avista
system monthly actual loads, and the 2009 pro forma system load as used in AURORA.
REQUEST NO. 130: Please identify any specific changes made to transmission
capacities assumed in AURORA.
REQUEST NO. 131: Please provide AURORA sumar output showing results if the
"Avista Hydro Adjustment" is excluded. Provide the output in a format similar to that used in
Kalich's Exhibit NO.5.
REQUEST NO. 132: Please provide AURORA sumar output showing results if a
2007 weather normalized system load is used rather than the 2009 pro forma system load.
Provide the output in a format similar to that used in Kalich's Exhibit NO.5.
REQUEST NO. 133: Please provide copies of the Priest Rapids contract that became
effective after October 31,2005 and Wanapum contract that wil become effective November 1,
2009.
FOURTH PRODUCTION REQUEST
TO A VISTA CORPORATION 3 JUNE 5, 2008
The following production requests are in reference to the Clark Fork PM&E adjustment,
referenced by Company witness Andrews testimony beginning on page 25.
REQUEST NO. 134: Please provide the account transaction detail for account 253890,
the Idaho jurisdiction subaccount for the Clark Fork PM&E expenses, by year, for the years 2005
through 2007, and for 2008 to date. Please provide the account transaction detail in an Excel
spreadsheet format, including all subaccounts. Provide the name of the vendor, voucher number,
expenditure type, transaction description, and jurisdictions that the transaction is spread to.
Please provide a print out as well as an electronic copy of the Excel spreadsheet with formulas
activated.
REQUEST NO. 135: Please provide the estimate of the total Idaho jursdictional
amount of the Clark Fork PM&E expenses for 2008 and for 2009 by category.
Dated at Boise, Idaho, this "50 day of June 2008.
K'ii p, a S:41/1me A. Sasser
Deputy Attorney General
Technical Staff: Dave Schune
Rick Sterling
Kathy Stockton
i:umisc:prodreq/avueJÛ8.swdesrpskls prod req4
FOURTH PRODUCTION REQUEST
TO A VISTA CORPORATION 4 JUE 5, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF JUE 2008, SERVED
THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-08-01 & AVU-G-08-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
AVISTA CORPORATION
POBOX 3727
SPOKANE WA 99220
E-MAIL: david.meyeraYavistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwoodaYavistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
601 W BANNOCK ST (83702)
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cewaYgivenspursley.com
DENNIS E. PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY STREET SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseauaYexcite.com
BRAD M. PURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE,ID 83702
E-MAIL: bmpurdyaYhotmail.com
~;i~-SECRETARY
CERTIFICATE OF SERVICE