2004051310th 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
HECEiVED
II t"n1L~
2034 fiA Y 13 PM 2:
Hi ,,) PUBLIC
UTiL(riES COr1t~1IsstnN
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA 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-
TENTH 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 A vista Corporation (A vista;
Company) provide the following documents and information on or before THURSDAY,
MAY 20, 2004. Staff notes that this is an expedited request and would appreciate the
Company s cooperation. Please notify Staff if the Company is unable to meet this deadline.
Staff is attempting to coordinate the receipt of information with Staff's in-house draft
deadline for Staff testimony.
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.
TENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 13 2004
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.
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.
ST AFF PRODUCTION REQUEST NOS. 261 THROUGH NO. 264 PERTAIN TO
ACCOUNTING ISSUES
Request No. 261: Please explain and quantify the benefits of the Accounts Receivable Sale
program for the ratepayer?
Request No. 262: What expenses for the Plymouth LNG facility are included in the
Company s filing? Please identify, on a system basis and an Idaho jurisdictional basis, and by
FERC account, all expenses associated with the Plymouth LNG facility. Specifically include
capacity and deliverability expenses.
Request No. 263: What amounts for the Plymouth LNG facility are included in rate base in
the Company s filing, other than Company Adjustment E, Gas Inventory Adjustment. Please
identify, on a system basis and an Idaho jurisdictional basis, and by FERC account, all amounts
included in rate base associated with the Plymouth LNG facility.
Request No. 264: Please provide a schedule showing any injections or withdrawals to the
Plymouth LNG facility since January 1 , 1989. Please provide the information by month and year
showing the amount injected and amount withdrawn.
TENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA MAY 13 2004
Dated at Boise, Idaho, this -fI"/3 day of May 2004.
Scott Woodbury
Deputy Attorney General
Technical Staff:Kathy Stockton
i:umisc:prodreq/avueO4.avugO4.1swlO
TENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO A VISTA MAY 13 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF MAY 2004
SERVED THE FOREGOING TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO VISTA CORPORATION, IN CASE NO. A VU-04-
l/AVU-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
DAVID J. MEYER
SR VP AND GENERAL COUNSEL
VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-mail dmeyer~avistacorp. com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
AVIS T A 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(fYexcite.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 98229
E-mail michael~awish.net
E-mail don.falkner~avistacorp.com
::D, \.(0cL
CERTIFICATE OF SERVICE