20080701Staff to AVU 178-189.pdf

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SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSIUN
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys 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 NO. AVU-E-08-1
) A VU-G-08-1
)
) SEVENTH PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO A VISTA CORPORATION
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Avista Corporation (Company;
Avista) provide the following documents and information on or before TUESDAY, JULY 15,
2008.
SEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 1 JULY 1,2008
This Production Request is to be considered as continuing, and A vista is requested to
provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil 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 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
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the wrtten copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 178: Please provide a list showing all purchases of natural gas made to
date intended for use in 2009 for electrc production. For each purchase, show the quantity, the
purchase price per MMBtu, the date of the purchase, and the delivery date.
REQUEST NO. 179: Please provide copies of all 2008 monthly variance analysis
reports completed to date showing how actual monthly loads in 2008 compare to forecasted
loads. Please provide a brief narative to explain the variance in each month or season. Please
identify any sectors whose load is growing faster or slower than expected and discuss reasons for
the changes in expected growth rate.
REQUEST NO. 180: On what date was the 2009 load forecast used in AURORA
modeling rus prepared? When will the next 2009 load forecast be prepared and available?
REQUEST NO. 181: Does the Company have any indications or analysis available at
this point to make a judgment about whether the new 2009 load forecast will be higher or lower
than the 2009 load forecast used in AURORA modeling rus? If so, please provide any analysis
and discuss expected differences between the new 2009 forecast and the old 2009 forecast.
SEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 2 JULY 1,2008
Discuss any changes in assumptions with regard to DSM activity, retail price increases and
elasticity, major changes in economic activity, and major changes in large customer loads.
REQUEST NO. 182: What assumptions were made about normal weather in the 2009
load forecast used in AURORA modeling rus? Discuss the effect in any new load forecasts if a
25-year rollng average of weather conditions is used instead.
REQUEST NO. 183: Please provide IPUC Staff with copies of Avista's responses to the
following Washington Utility and Transportation Commission Staff Data Requests:
Request No. 36
Request No. 37
Request No. 38
Request No. 40
Request No. 41
Request No. 42
Request No. 43
Request No. 44
Request No. 45
Request No. 53
Request No. 55
Request No. 57
Request No. 58
Request No. 59
Request No. 60
Request No. 61
Request No. 62
Request No. 63
Request No. 64
REQUEST NO. 184: As referenced in Company witness Morris's testimony, please
provide a copy of the results of Avista's 4th Quarer 2007 Customer Satisfaction Surey.
REQUEST NO. 185: The char included in Avista's response to Staff Production
Request No.118, shows a considerable decline in the number of accounts enrolled in the Winter
Payment Plan from 2006 to 2008. To what does A vista attibute this decline?
SEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 3 JULY 1,2008
REQUEST NO. 186: In Avista's response to Staff Production Request No. 65, the
Company witness stated a weekly report was generated for all new opens and that this report was
used for monitoring when customers may be eligible to move from one rate to another. Please
provide an actual copy of the report with details of how it is read and interpreted.
REQUEST NO. 187: In 2007, how many actual physical connections of service for both
gas and electric meters were performed by A vista service personnel during regular working
hours? Please provide this information by customers with: (1) gas only; (2) electric only; and
(3) combined gas and electric.
REQUEST NO. 188: Please provide the total number of residential and small
commercial customers who receive a monthly bil for both natual gas and electric usage on one
statement.
REQUEST NO. 189: Please describe the process by which costs associated with
abandoned projects are recorded. Please include within your response the total costs recorded in
2007 by account and a detailed spreadsheet (in Excel format) identifying the project number,
project description, expenditure type, vendor description, transaction description, transaction
amount, date posted, document/transaction number, and total amount posted.
'QDated at Boise, Idaho, this I day of July 2008.
~a..~
Kri me A. Sasser
Deputy Attorney General
Technical Staff: Rick Sterling
Kathy Stockton
Marilyn Parker
Patricia Hars
i:umisc:prodreq/avue~08.ksrpsmpkisph prod req7
SEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 4 JULY 1, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1 ST DAY OF JULY 2008, SERVED
THE FOREGOING SEVENTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA CORPORATION, IN CASE NOS. AVU-E-08-01 & AVU-G-08-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
AVISTA CORPORATION
POBOX 3727
SPOKANE WA 99220
E-MAIL: david.meyer(iavistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwood(iavistacorp.com
CONLEYE WARD
GIVENS PURSLEY LLP
601 W BANNOCK ST (83702)
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(igivenspursley.com
DENNIS E. PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY STREET SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(iexcite.com
BRAD M. PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE,ID 83702
E-MAIL: bmpurdy(ihotmail.com
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SECRETARY ~
CERTIFICATE OF SERVICE