990219.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO  83720-0074
[phone]
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 APPLICATION OF THE WASHINGTON WATER POWER COMPANY (NOW AVISTA CORPORATION DBA AVISTA UTILITIES — WASHINGTON WATER POWER DIVISION) FOR AN ORDER APPROVING INCREASED RATES AND CHARGES FOR ELECTRIC SERVICE IN THE STATE OF IDAHO.
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CASE NO. WWP-E-98-11
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA UTILITIES — WASHINGTON WATER POWER DIVISION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests that Avista Corporation dba Avista Utilities - Washington Water Power Division (Avista; Company) provide the following documents and information on or before FRIDAY, MARCH 12, 1999.
This Production Request is to be considered as continuing, and Avista 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.
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.
In Request Nos. 31 through 44, please note all line numbers refer to Norwood power supply adjustments as shown in Company Exhibit No. 6 and the adjustment index to the Norwood work papers.
Request No. 31:The adjustment shown on line 13, small power, uses the weighted average secondary price as calculated in the power supply model to estimate contract payments. Isn’t the weighted price as calculated in the model inaccurate for this use due to the effect of excess purchase and secondary sales that occur in the model in the same month?
Request No. 32:On line 13, small power, the workpapers show an adjustment for John Day and Jim Ford Creeks.  Why are normalized expenses higher in March and April when actual 97 generation is higher than the historic averages?
Request No. 33:On line 28, why was there no contract for Black Creek hydro in the test year?  What is the likelihood that a contract will continue?
Request No. 34:On line 29, why did Avista only purchase 103 Avg. MW in the test year rather than 115 MW as contracted?
Request No. 35:On line 65, why were no WSCC dues paid in the test year?
Request No. 36:On line 67, please provide an explanation of Oasis expense using work papers.
Request No. 37:On line 95, what was the 1999 rate for this agreement?
Request No. 38:On line 97, the Modesto contract is for firm capacity June through September.  Why are no revenues shown for June?
Request No. 39:On line 110, why is adjusted revenue lower than test year revenue?
Request No. 40: On line 118, why are revenues lower when average 93-97 peak demand is greater than actual 1997 and rate of $1.147 kW/mo appears to have been in effect since 1994?
Request No. 41: On line 122, why did scheduling revenues end?
Request No. 42:Please explain the nature of the adjustment shown on line 125.
Request No. 43:On lines 38 and 126, was there any expense and revenue respectively for October through December of 1998?  If so, what was it?
Request No. 44:Ps 222 and Ps 226 show line incremental fuel costs for Colstrip and Centralia.  Please explain the line loss component.
Request No. 45:In the Company’s Schedule 51; Line Extension, Conversion and Relocation Schedule for Idaho, “Basic Cost” is the cost of the service circuit, secondary circuit, transformer and primary circuit computed from the rates listed in the schedule.  The rates for these components as specified in sections 5 and 7 of the schedule consist of fixed and variable costs for overhead and underground circuits, and costs for overhead and padmount transformers.  For each of these costs as specified in Schedule 51, state the year in which they were derived, and state the corresponding cost for the same items in 1997.  For each total fixed or variable cost, include a cost breakdown of the items making up the total.
Request No. 46:If the “Basic Cost” elements in sections 5 and 7 of Schedule 51 have changed since they were first established in the tariff, does the Company anticipate requesting to update them in the foreseeable future?  Does the Company anticipate changing the maximum customer allowances and refunds as specified in the tariff?
DATED at Boise, Idaho, this              day of February 1999.
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Scott Woodbury
Deputy Attorney General
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