20080722Staff to AVU 205-220.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 1895
KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
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 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 NO. A VU-E-08-1
) A VU-G-08-1
)
) ELEVENTH PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO AVISTA 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, AUGUST 5, 2008.
ELEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 1 WLY22,2008
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 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 fies on CD with formulas activated.
REQUEST NO. 205: In reference to the adjustment shown on line 5 of Exhibit No.6,
Schedule 2, p. 1 of2, (W. Johnson), please provide a narrative explanation, along with contract
excerpts, workpapers, spreadsheets or any other documentation supporting the increase in purchased
power costs for the Priest River Project from 2007 actual to 2009 pro forma costs.
REQUEST NO. 206: The workpaper provided in support of the adjustment on line 10 of
Exhibit No.6, Schedule 2, p. 1 of2, Small Power, (W. Johnson) (workpapers p. 17 of Willam
Johnson), shows monthly generation totals and estimated expenses for 2008-2010 for six PURPA
projects. Please provide additional workpapers showing how the expenses for 2008-2010 were
computed or estimated for the Sheep Creek, Jim White, and Hydro Tech projects.
REQUEST NO. 207: In reference to the adjustment shown on line 12 of Exhibit No.6,
Schedule 2, p. 1 of2, (W. Johnson), Spokane-Upriver Power Purchase, please explain why 2009 pro
forma expenses are greater than 2007 actual expenses, given that the power purchase payment rates
shown on p. 21 of Wiliam Johnson's workpapers are the same between July 1, 2004 through
December 31, 2011. Is the difference due to below normal flows in 2007?
REQUEST NO. 208: Please provide an update on the status of the Thompson River cogen
project. Did the project come online as assumed on p. 36 of the workpapers of Wiliam Johnson? If
ELEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 2 WLY22,2008
not, please explain the reasons for the delay and provide a revised estimate of when the project is
expected to become operationaL. Include any support for a revised estimate of an operation date.
Please explain the basis for the monthly generation estimates included on the aforementioned
workpaper.
REQUEST NO. 209: In reference to the PPM Wind Purchase adjustment shown on line 29 of
Exhibit No.6, Schedule 2, p. 1 of2, (W. Johnson), a wind integration cost is shown on page 44 ofthe
confidential workpapers of Wiliam Johnson. Please explain the source for the amount of the wind
integration cost and explain whether it is charged explicitly under the Stateline contract with A vista, by
BPA, or by some other utility. If the cost is not charged explicitly and is instead assumed internal to
A vista's system, please explain why it is not captued in other A vista system operational costs.
REQUEST NO. 210: Please provide documentation and support for the adjustment shown on
line 50 of Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson), Sand Dunes - Warden. Exhibit No.6,
Schedule 2, p. 5 of8, (W. Johnson), states that the contract ended Oct. 2007, yet the amount of the
2007 actual expense has been included as a 2009 pro forma expense. Please reconcile this
inconsistency.
REQUEST NO. 211: Please provide documentation and support for the adjustment shown on
line 51 of Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson), Black Creek Wheeling. Workpapers
show actual 2007 revenue and 2009 normalized revenue, but do not explain the adjustment in
suffcient detail or provide support for it.
REQUEST NO. 212: Please provide an update on the status of the transmission agreement
between Avista and Kootenai Electric for service to Worley. The adjustment is shown on line 56 of
Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson). If a new transmission agreement has been signed,
please provide documentation of the cost to A vista. If no new agreement has yet been signed, please
provide an updated estimate of the cost and cite the source of the estimate.
ELEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 3 WLY22,2008
REQUEST NO. 213: Please provide documentation and support for the adjustment shown on
line 65 of Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson), Peaker (PGE) Capacity Sale.
Workpapers show actual 2007 revenue and 2009 normalized revenue, but do not explain the
adjustment in suffcient detail or provide support for it.
REQUEST NO. 214: Please provide documentation and support for the adjustment shown on
line 72 of Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson), Spokane Energy Services Fee - Peaker
Sale. Workpapers show actual 2007 revenue and 2009 normalized revenue, but do not explain the
adjustment in suffcient detail or provide support for it.
REQUEST NO. 215: Please provide documentation and support for the adjustment shown on
line 67 of Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson), Sovereign/aiser. Workpapers show
actual 2007 revenue and 2009 normalized revenue, but do not explain the adjustment in suffcient
detail or provide support for it. Explain whether any adjustment is due to deviation energy.
REQUEST NO. 216: Please provide documentation and support for the adjustment shown on
line 68 of Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson), Pend Oreile DES & Spinning Reserves.
Workpapers show actual 2007 revenue and 2009 normalized revenue, but do not explain the
adjustment in sufficient detail or provide support for it. Explain whether any adjustment is due to
deviation energy.
REQUEST NO. 217: Please provide documentation and support for the adjustment shown on
line 69 of Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson), Northwestern Load Following.
Workpapers show actual 2007 revenue and 2009 normalized revenue, but do not explain the
adjustment in sufficient detail or provide support for it. Explain whether any adjustment is due to
deviation energy. Why is the 2009 pro forma revenue lower in the months of May, June, and July?
REQUEST NO. 218: In reference to the adjustment shown on line 32 of Exhibit No.6,
Schedule 2, p. 1 of2, and on line 70 of Exhibit No.6, Schedule 2, p. 2 of2, (W. Johnson), please
provide a narrative explanation, along with contract excerpts, workpapers, spreadsheets or any other
ELEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 4 WLY22,2008
documentation explaining the SMUD sale. Discuss the requirements for RECs, pricing for those RECs,
and pricing for the energy provided in the sale.
REQUEST NO. 219: On page 5, lines 13-15 of the direct testimony of Wiliam Johnson, he
discusses the increase in transmission expenses and states "This is primarily due to the purchase of an
additional 125 MW of BP A point-to-point transmission for Coyote Springs 2." On page 13 of his
testimony, however, he states "To meet the transmission requirements of CS2 the Company purchased
an additional 50 MW of firm PTP transmission from BP A, for a total of 272 MW of firm transmission
for CS2." Please reconcile this apparent discrepancy.
REQUEST NO. 220: Please provide electric and natural gas forward prices for 2009 contract
months as reported daily for all settlement dates durng the period June 1, 2008 through the present for
each of the locations included in the forward prices previously provided in the workpapers of Clint
Kalich. Please provide the data in an electronic Excel format. (This is an update to earlier Staff
Request No. 125).
1&Dated at Boise, Idaho, this ~ day of July 2008.
~b;., fl. 5;441A
KriS ne A. Sasser
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/avue~08.ksrps prod reqI I
ELEVENTH PRODUCTION REQUEST
TO A VISTA CORPORATION 5 WLY22,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HA VE THIS 22ND DA Y OF WL Y 2008,
SERVED THE FOREGOING ELEVENTH 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:
DA VID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220
E-MAIL: david.meyer(favistacorp.com
KELLY NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwood(favistacorp.com
CONLEY E WARD
GIVENS PURSLEY LLP
601 W BANNOCK ST (83702)
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(fgivenspursley.com
DENNIS E. PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY STREET SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(fexcite.com
BRAD M. PURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE,ID 83702
E-MAIL: bmpurdy(fhotmail.com
,b~SECRETAR~"
CERTIFICATE OF SERVICE