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Home My WebLink About20100615Staff 140-146 to AVU.pdfDONALD L. HOWELL, II DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NO. 3366 Di:l"~r= rJ,,,,,\..l_, zOin JUN \5 PM 2: 1;5 KRISTINE A. SASSER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0357 BARNO. 6618 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5918 Attorneys for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF A VISTA CORPORATION DBA A VISTA ) UTILITIES FOR THE AUTHORITY TO ) INCREASE ITS RATES AND CHARGES FOR ) ELECTRIC AND NATURAL GAS SERVICE )IN IDAHO. ) ) ) ) CASE NO. AVU-E-I0-l AVU-G-I0-l SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO A VISTA CORPORATION The Staff of the Idaho Public Utilities 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 6, 2010. SIXTH PRODUCTION REQUEST TO AVISTA 1 JUE 15,2010 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 written copies provided as response to the questions, please provide all Excel and electronic fies on CD with formulas activated. REQUEST NO. 140: Please provide a summar by month, from the beginning of the contract through the curent month, of the MWhs received by A vista under the Stateline contract. What is the basis for the modeled monthly MWh shown on P43 of Johnson's workpapers? REQUEST NO. 141: Wind integration costs have been included in the proforma expense calculation for the Stateline wind purchase. Are wind integration costs specifically quantified and paid under the Stateline contract or paid to another utilty? If not, does A vista believe that wind integration costs associated with the Stateline contract are not already captured as ancilary services costs that are booked to various accounts? Does A vista believe that wind integration costs are curently not being recovered in base rates or through the PCA? REQUEST NO. 142: Does A vista intend to renew its load following contract with NorthWestern? If so, when? If Avista expects to renew the contract, please provide an estimate of the monthly revenues A vista would expect to receive under a renewed contract. Please provide calculations showing how the estimate was made. REQUEST NO. 143: Does Avista expect to renew its contract with the Colvile Indian Tribe for its 4.5% share of the Wells project? Ifso, when? SIXTH PRODUCTION REQUEST TO AVISTA 2 JUNE 15,2010 REQUEST NO. 144: Avista has included a proforma expense of approximately $4.5 milion per year for PTP transmission wheeling from the Lancaster plant. In its response to Staff Production Request No.5, Avista states that the preliminar cost estimate to interconnect A vista's system to BPA's system at the Lancaster plant is $3 milion. A vista also estimates that interconnection of this type could potentially be completed within two years. Given that the approximate cost to interconnect A vista's and BP A's systems is only $3 milion, yet A vista is paying BPA $4.5 milion anually for PTP transmission, can the interconnection of the two transmission systems be expedited? What are the obstacles to interconnecting the two systems as soon as possible? REQUEST NO. 145: Avista has included a proforma adjustment of $777,796 to pay BPA for reserves required for Lancaster. If the Avista and BPA transmission systems are interconnected at the Lancaster substation in the future, wil the Lancaster plant then be considered located in A vista's control area instead of BP A's? If so, wil the cost assumed for BP A reserves associated with Lancaster then go away? REQUEST NO. 146: Please explain why the deviation energy portion of the Kaiser DES sales were over $413,000 in the test year, but are assumed to be zero for the proforma period. Are there ongoing operations at Kaiser that would lead to an expectation of significant deviation energy in the future? Dated at Boise, Idaho, this I SIt day of June 2010. ~,,~a., ~MKri ~ A. Sasser c Deputy Attorney General Technical Staff: Rick Sterling/#140 - 146 i:umisc:prodreq/avue~10.lksrps prod req6.doc SIXTH PRODUCTION REQUEST TO AVISTA 3 JUE 15,2010 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF JUNE 2010, SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA, IN CASE NOS. AVU-E-l 0-01_AVU-G-l 0-01, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: DAVID J MEYER VP & CHIEF COUNSEL A VISTA CORPORATION PO BOX 3727 SPOKANE WA 99220-3727 E-MAIL: david.meyer(iavistacorp.com PETER J RICHARDSON GREG M ADAMS RICHARDSON & O'LEARY 515 N 27TH ST BOISE ID 83702 E-MAIL: peter(irichardsonandolear.com greg(irichardsonandoleary.com DEAN J MILLER MCDEVITT & MILLER LLP PO BOX 2564 BOISE ID 83701 E-MAIL: joe(imcdevitt-miler.com ROWENA PINEDA ID COMMUNITY ACTION NETWORK 3450 HILL ROAD BOISE ID 83703 E-MAIL: Rowena(iidahocan.org BRAD M PURDY ATTORNEY AT LAW 2019 N 17TH ST BOISE ID 83702 E-MAIL: bmpurdy(ihotmaiL.cotn KEN MILLER SNAKE RIVER ALLIANCE PO BOX 1731 BOISE ID 83701 E-MAIL: kmiler(isnakeriverallance.org KELL YO NORWOOD VP STATE & FED REG AVISTA CORPORATION PO BOX 3727 SPOKANE WA 99220-3727 E-MAIL: kelly.norwood(iavistacorp.com HOWARD RAY CLEARWATER PAPER CORP 803 MILL ROAD PO BOX 1126 LEWISTON ID 83501-1126 E-MAIL: howard.ray(iclearaterpaper.com LARRY CROWLEY ENERGY STRATEGIES INSTITUTE 5549 S CLIFFS EDGE AVE BOISE ID 83716 E-MAIL: crowleyla(iaoL.com LEEANNHALL 3518 S EDMUNDS ST SEATTLE WA 98118 BENJAMIN J OTTO ID CONSERVATION LEAGUE POBOX 844 BOISE ID 83701 E-MAIL: botto(iidahoconservation.org ROB PLUID PRESIDENT NORTH IDAHO ENERGY LOGS PO BOX 571 MOYIE SPRIGS ID 83845 E-MAIL: robpluid(igmaiL.com CLARK FAIRCHILD VICE PRESIDENT NORTH IDAHO ENERGY LOGS PO BOX 571 MOYIE SPRINGS ID 83845 E-MAIL: energylogs(igmaiL.com TOM OXFORD SECRETARY TREASURER NORTH IDAHO ENERGY LOGS E-MAIL: oxford(imeadowcrk.com (ELECTRONIC SERVICE ONLY)