20100421Staff 1-9 to AVU.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
1~\~ ~PR 2. \ ~tA \0: 33
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF A VISTA CORPORATION DBA A VISTA )
UTILITIES FOR THE AUTHORITY TO )
INCREASE ITS RATES AND CHARGES FOR )
ELECTRIC AND NATURAL GAS SERVICE )
IN IDAHO. )
)
)
)
CASE NO. AVU-E-I0-l
AVU-G-I0-l
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that A vista Corporation (Company;
Avista) provide the following documents and information on or before WEDNESDAY,
MAY 12,2010.
FIRST PRODUCTION REQUEST
TO AVISTA 1 APRIL 21, 2010
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 wil 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 IDAPA
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.1: Please provide a copy of the BorisMetrics study referred to on page
10, lines 14 - 18, ofthe Direct Testimony of Clint Kalich.
REQUEST NO.2: Please explain why the 1929-1978 historical record is used for the
Clark Fork hydro studies discussed on page 12 of the Direct Testimony of Clint Kalich. Explain
why hydro data for the 1979-2009 period is not used in the studies.
REQUEST NO.3: Please provide a copy of the Lancaster PPA discussed on page 4,
line 10, through page 5, line 4 of the Direct Testimony of Richard Storro.
REQUEST NO.4: Please explain how costs associated with the purchase of 5.7 aMW
ofRECs per year from 2012 through 2015 are allocated between Idaho and Washington.
Reference Storro p. 9, lines 6-8.
REQUEST NO.5: On page 11, lines 7-14 of the Direct Testimony of Wiliam Johnson,
he discusses the purchase of 250 MW of point-to-point transmission for the Lancaster plant.
Does A vista have any future plans to build transmission to directly connect the Lancaster plant to
its system? If so, please discuss.
FIRST PRODUCTION REQUEST
TO AVISTA 2 APRIL 21, 2010
REQUEST NO.6: Please provide a copy of any reports, studies or other analysis
demonstrating the cost-effectiveness of the following generation capital projects:
a. Noxon Units 2 and 3 upgrades,
b. Kettle Falls capital projects,
c. Colstrip capital additions,
d. Nine Mile upgrade,
e. Coyote Springs 2 capital projects,
f. Boulder Park control network replacement, and
g. any other generation capital projects that individually exceeded $1 milion.
In those instances in which justification for a paricular capital project was not based solely on
economics, please describe any non-economic benefits and quantify those benefits to the extent
possible.
REQUEST NO.7: Please provide electric and natural gas forward prices for October
2010 - September 2011 contract months as reported daily for all settlement dates during the
period January 1,2009 through the present for each of the locations included in the forward
prices previously provided in the workpapers of Clint Kalich. Please provide the data in an
electronic Excel format.
REQUEST NO.8: Please list and describe any gas purchase contracts that have already
been executed for delivery of gas to Coyote Springs 2 or Lancaster during any months of the pro
forma period. List the date of the purchase, the quantity of gas, the scheduled delivery dates, and
the price for the purchase in $/MMBtu.
REQUEST NO.9: For the pro forma period, please compare the Company's July 2009
monthly load forecast as used in this rate case fiing to the Company's monthly load forecasts
made in each of the previous two years. Please discuss changes in the forecasts due to economic
conditions or other significant events. Please also discuss, for Avista's service territory, the
Company's expectations about the timing and pace of recovery from the current recession and
FIRST PRODUCTION REQUEST
TO AVISTA 3 APRIL 21, 2010
accompanying rebound in load. Finally, compare the load forecasts for the past two years to the
Company's actual weather-normalized loads during the same time period.
Dated at Boise, Idaho, this ;LIS! day of ApriL.
~,a.~.
Kri ne A. Sasser
Deputy Attorney General
Technical Staff: Rick Sterling/l-9
i:umisc:prodreq/avue~IO.lksrps prod reql.doc
FIRST PRODUCTION REQUEST
TO AVISTA 4 APRIL 21, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF APRIL 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA, IN CASE NOS. AVU-E-IO-01_AVU-G-IO-01, BY
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DA VID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: david.meyer(favistacom.com
PETER J RICHARDSON
GREG M ADAMS
RICHARDSON & O'LEARY
515 N 27TH ST
BOISE ID 83702
E-MAIL: peter(frichardsonandoleary.com
greg(frichardsonandoleary .com
DEAN J MILLER
MCDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL:joe(fmcdevitt-miler.com
ROWENA PINEDA
ID COMMUNITY ACTION
NETWORK
3450 HILL ROAD
BOISE ID 83703
E-MAIL: Rowena(fidahocan.org
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
KELL YO NORWOOD
VP STATE & FED REG
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: kelly.norwood(favistacom.com
HOWARD RAY
CLEARWATER PAPER CORP
803 MILL ROAD
PO BOX 1126
LEWISTON ID 83501-1126
E-MAIL: howard.ray(fclearatemaper.com
LARRY CROWLEY
ENERGY STRATEGIES INSTITUTE
5549 S CLIFFS EDGE AVE
BOISE ID 83716
E-MAIL: crowleyla(faol.com
LEEANNHALL
3518 S EDMUNDS ST
SEATTLE WA 98118
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
POBOX 844
BOISE ID 83701
E-MAIL: botto(fidahoconservation.org
JJI~ ß. ~ .k'ocSECRETARY
CERTIFICATE OF SERVICE