20111206Staff to Avista 1-3.pdf

KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT )
APPLICATION OF AVISTA CORPORATION )
AND STIMSON LUMBER COMPANY FOR )
APPROVAL OF A POWER PURCHASE )AGREEMENT. )
)
)
)
)
CASE NO. AVU-E-11-6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
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 TUESDAY,
DECEMBER 27,2011.
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 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
FIRST PRODUCTION REQUEST
TO AVISTA 1 DECEMBER 6, 2011
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 explain why the definition of "Market Energy Cost" has been
changed from the prior Stimson Lumber contract. Reference § 1.14 of Power Purchase
Agreement between Stimson Lumber Company and A vista Corporation.
REQUEST NO.2: Please explain why the minimum requirement for comprehensive
general liability insurance has been increased from $1 milion per occurence in the prior
contract to $2 milion per occurence in the proposed contract. Reference § 7.1.1 of Power
Purchase Agreement between Stimson Lumber Company and A vista Corporation.
REQUEST NO.3: Please explain why charges for Stimson's use of Avista's Plumer
Substation facilities are specified in the proposed contract but were not specified in the prior
contract. Were payments made for Stimson's use of these facilities in the past under a separate
agreement from the power sales agreement? Reference § 31 of Power Purchase Agreement
between Stimson Lumber Company and A vista Corporation.
r -rl-Dated at Boise, Idaho, this l.- day of December 2011.
~1)a.~JA_,
Kristine A. Sasser
Deputy Attorney General
Techncal Staff: Rick Sterling
i:umisc:prodreq/avuel 1.6ksrpsksrps prod reql ,doc
FIRST PRODUCTION REQUEST
TO AVISTA 2 DECEMBER 6, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF DECEMBER 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO A VISTA, IN CASE NO. AVU-E-II-06, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
STEVE SILKWORTH MGR
A VISTA CORPORATION
1411 E MISSION AVE MSC-7
SPOKANE WA 99202
E-MAIL: steve.silkworthcqavistacorp.com
JEFF WEBBER
VP - MANUFACTURIG
STIMSON LUMBER
520 SW YAMHILL STE 700
PORTLAND OR 97204
E-MAIL: jwebbercqstimsonlumber.com
MICHAEL G ANDREA
A VISTA CORPORATION
1411 E MISSION AVE MSC-23
SPOKANE WA 99202
E-MAIL: Michael.andreacqavistacorp.com
PRESIDENT & CEO
STIMSON LUMBER
STE 700
520 SW YAMHILL
PORTLAND OR 97204
SECRETARY
CERTIFICATE OF SERVICE