200405109th Request of Staff to Avista.pdf

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
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FUBUC
UIId'I\ES COMMISSlON
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-
NINTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO A VISTA CORPORATION
The Staff of the Idaho Public Utilities Commission (IPUC), by and through its attorney of
record, Scott Woodbury, Deputy Attorney General, requests that Avista Corporation (Avista;
Company) provide the following documents and infonnation on or before MONDAY, MAY 24,
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
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.
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.
NINTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MAY 10 2004
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. 257 THROUGH NO. 260 PERTAIN TO
ADVANCED METER READING (AMR)
Request No. 257: On page 4 of his direct testimony, Mr. Holmes states that Avista
proposed advanced meter reading (AMR) system will be capable of critical peak time-of-use
(CP-TOU) pricing. Please provide any studies or analyses that estimate benefits to Avista s system
from implementing CP- TOU pricing,
Request No. 258: Do the proposed electricity and gas AMR systems share any common or
joint costs? If so, please quantify by account how these costs will be allocated between electricity
and gas customers.
Request No. 259: Please provide copies of all letters and memorandums dated January 1
2003 or later that discuss AMR systems, whether written on paper or in electronic mail, written or
received by A vista employees and officers.
Request No. 260: Is the Company planning to install the same AMR system in
Washington as in Idaho? In the same timeframe? With the same accounting treatment as in Idaho?
If not, please explain.
Dated at Boise, Idaho, this
IP
day of May 2004.
tSl
Scott Woodbury
Deputy Attorney General
Technical Staff:Lynn Anderson
i:umisc:prodreq/avueO4.- avugO4.1sw9
NINTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MAY 10 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF MAY 2004
SERVED THE FOREGOING NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION IN CASE NO, AVU-04-
lIAVU-04-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DAVID 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 VIST A UTILITIES
PO BOX 3727
SPOKANE W A 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.
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-mail bmpurdy~hotmai1.com
MICHAEL KARP
147 APPALOOSA LANE
BELLINGHAM W A 98229
E-mail michael~awish.net
E-mail don.falkner~avistacorp.com
CERTIFICATE OF SERVICE