200407083rd Request of Avista to Staff.pdf

DAVID J. MEYER, Esq.
, CHIEF COUNSEL
for REGULATORY AND GOVERNMENTAL AFFAIRS
VISTA COROPRA TION
O. BOX 3727
1411 E. MISSION AVE., MSC-
SPOKANE, W A 99220-3727
david.meyer~avistacorp. com
Attorney for A vista Utilities
[phone]
[phone] (FAX)
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLI CA TI 0 N
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-
THIRD PRODUCTION
REQUEST OF A VISTA
CORPORATION
TO IPUC STAFF
Avista Corporation (Avista, Company), by and through its attorney of record, David J.
Meyer, VP, Chief Counsel for Regulatory and Governmental Affairs, requests that IPUC Staff
(Staff) provide the following documents and information on or before July 14th, 2004.
This Production Request is to be considered as continuing in nature and Staff is requested to
provide, by way of supplementary responses, additional documents that it or any person acting on
its behalf may later obtain or become aware of that will augment the documents produced.
In answering each request, please provide the name of the person(s) preparing the answer
along with the title and function such individual holds with your organization and the witness who
can sponsor the answer at the hearing.
For the following responses, please provide all workpapers, diskettes (3.5 in.), CDs and all
underlying formulas intact in Excel 2000 compatible language.
SECOND PRODUCTION REQUEST OF
VISTA TO IPUC STAFF Page
Request No. 14: At page 16, line 15, of Mr. Hessing s direct testimony he writes
, "
Staff
believes that it was extremely risky to lock the price of gas at a traditionally high price in a gas
market with prices falling even though forward electric prices were high." What is the basis for
Mr. Hessing s contention that prices were falling at the time? Please provide all supporting
documentation.
Dated at Spokane, Washington, this ih day of July, 2004.
Dp'\Tld J. Meyer
ChiefCounsel for Regulatory
and Governmental Affairs
A vista Corporation
SECOND PRODUCTION REQUEST OF
VISTA TO IPUC STAFF Page 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have on this 7th day of July, 2004, served the
foregoing upon the following parities, by mailing a copy thereof, property
addressed with postage prepaid to:
Jean 0 Jewell , Secretary
Idaho Public Utilities Commission
Statehouse
Boise, 10 83720-5983
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, 10 83702-0074
Conley Ward
Givens Pursley LLP
601 W. Bannock Street
PO Box 2720
Boise , 1083701-2720
Dennis E. Peseau , Ph.
Utility Resources, Inc.
1500 Liberty Street S. E., Ste. 250
Salem , OR 97302
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, 10 83702
Michael Karp
147 Appaloosa Lane
Bellingham, WA 98229
Charles L. A. Cox
Evans , Keane
111 Main Street
O. Box 659
Kellogg, 10 83837-0659
tty Olsness
Rates Coordinator