20040324Revised 4th Request of Staff to Avista.pdf

IDAHO
PUBLIC UTiliTIES
com mission
Dirk Kempthome, Govemor
o. Box 83720, Boise, Idaho 83720-0074
Paul Kjellander, President
Marsha H. Smith, Commissioner
Dennis S. Hansen, Commissioner
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TO:PARTIES OF RECORD
COMMISSION SECRETARY
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FROM:SCOTT WOODBURY
DATE:MARCH 23 , 2004
SUBJECT:REVISION TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO A VISTA CORPORATION.
The requests in the Fourth Production Request of the Commission Staff to Avista
Corporation were misnumbered. The requests began with Request No. 171 and ended with
Request No. 176. The requests should have been numbered starting with Request No. 173 and
ending with Request No. 178.
Enclosed please find the Revised Fourth Production Request of the Commission
Staff to A vista Corporation.
Thank you for your consideration in this matter.
Scott Woodbury
Deputy Attorney General
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Located at 472 West Washington Street, Boise, Idaho 83702
Telephone: [phone] Facsimile: [phone]
SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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 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 NOS. A VU-04-
A VU -04-
REVISED FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Scott
Woodbury, Deputy Attorney General, requests that Avista Corporation (Avista; Company) provide the
following documents and information on or before MONDAY, APRIL 5, 2004.
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. Reference IDAPA 31.01.01.228.
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.
REVISED FOURTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MARCH 23 , 2004
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. For all responses to the
following requests, please provide all workpapers, diskettes (3.5 in.), CDs and all underlying
formulas intact in Excel 2000 compatible language.
STAFF PRODUCTION REQUEST NOS. 173 - 178 PERTAIN TO POWER SUPPLY
MODELING ISSUES
Request No. 173: Please provide an electronic copy of all input and output files used in the
AURORA system dispatch model for determining power supply costs. Include an electronic copy of any
other linked files or files used for preparing data for input to the AURORA model.
Request No. 174: Please provide a copy of the natural gas forward prices upon which the prices
used in the AURORA model are based. Please cite the source used for the price estimates, the date on
which price data was obtained, the product represented by the prices (e., 12-mo. strip, firm, etc.), the
location associated with the prices (e., Henry Hub, Sumas, etc.) and explain any adjustments made to
reflect price differences between specific plants. Also quantify and describe any adders made to the
commodity price to reflect transportation, taxes, pipeline charges, etc.
Request No. 175: Please provide a copy of the Colstrip fuel prices used in the AURORA modeling.
Please cite the source used for the price estimates.
Request No. 176: Please provide a copy of the Kettle Falls fuel prices used in the AURORA
modeling. Please cite the source used for the price estimates.
Request No. 177: Please identify the source for all hydro data used in the AURORA modeling.
Include a copy of any data and spreadsheets used to determine "normal" hydro conditions for use in the
model, along with a brief description of how "normal" conditions are determined. Please describe how
normal hydro conditions are reflected in the generation for Avista s hydro plants in the AURORA model.
How is "normal" monthly generation determined for other plants in the WECC?
REVISED FOURTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 23, 2004
Request No. 178: Please identify the source for all Avista-specific load data used in the AURORA
modeling. Include a copy of any data and spreadsheets used to determine test year loads for use in the
model. Please provide a description of how test year loads determined in the weather normalization
process are prepared and entered into AURORA to represent hourly system loads. How are "normal"
hourly loads determined for other (non-Avista) loads in the WECC?
Dated at Boise, Idaho , this
d3
day of March 2004.
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/avueO4.avugO4.1 sw4revised
REVISED FOURTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MARCH 23 , 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 23ND DAY OF MARCH 2004
SERVED THE FOREGOING REVISED FOURTH PRODUCTION REQUEST TO
AVISTA CORPORATION, IN CASE NO. AVU-04-l/AVU-04-, BY MAILING A
COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DA VID J. MEYER
SR VP AND GENERAL COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail dmeyer~avistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220-3727
E-mail Kelly.norwood~avistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-mail cew~givenspursley.com
DENNIS E PESEAU, PH. D.
UTILITY RESOURCES INC
1500 LIBERTY ST SE, SUITE 250
SALEM OR 97302
E-mail dpeseau~excite.com
CHARLES L A COX
EV ANS KEANE
111 MAIN STREET
PO BOX 659
KELLOGG ID 83837
E-mail ccox~usamedia.
E-mail don.falkner~avistacorp.com
CERTIFICATE OF SERVICE