production requests & r.pdf

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SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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UTILITiES COhHiSSiON
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE SUBMISSION OF
THE SCHEDULE 66 PCA STATUS REPORT
OF A VISTA CORPORATION AND
APPLICATION FOR CONTINUATION OF A
SCHEDULE 66 POWER COST ADJUSTMENT(PCA) SURCHARGE.
CASE NO. A VU-03-
FIRST 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
Scott Woodbury, Deputy Attorney General, requests that Avista Corporation (Avista; Company)
provide the following documents and information on or before WEDNESDAY
SEPTEMBER 10, 2003.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number ofthe person preparing the document, and the name
location and phone number of the record holder. Reference IDAPA 31.01.01.228.
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.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA AUGUST 29, 2003
Request No.1: Please describe the decisions and decision points inherent in the
Company s purchase and subsequent fixing of the price of27 658 MMBtu/day of gas purchased
on March 13, 2001. Please discuss these transactions as they relate to the Company s Risk
Policy.
Request No.2: Please describe the decisions and decision points inherent in the
Company s purchase and subsequent fixing of the price of20 000 MMBtu/day of gas purchased
on March 22, 2001. Please discuss these transactions as they relate to the Company s Risk
Policy.
Request No.3: Even though much of both of these purchases have subsequently been
unwound, please describe the unwinding process and reference the associated deal tickets and
Risk Policy guidelines. Please quantify the loss associated with unwinding these purchases and
provide detail on the loss associated with each deal ticket. Please provide the same information
on any gains associated with unwinding the deals.
Request No.4: Did the Company purchase gas at a fixed price for the Company s gas
customers approximately 3 years in advance in the spring of2001? Ifnot, why not? If the
Company did, what was the justification? How does this decision differ from the decision to
purchase gas 3 years in advance for electric generation?
Request No.5: Please provide a breakdown of the $23 383 629 increase in power supply
costs identified on page 3, line 15 of the Company s Application. Please break the costs into the
following categories:
Fuel Costs
Purchased Power Costs
Non-Firm Sales Revenue
Other
Request No.6: Please provide the calculations and supporting documentation to justify
the statement that "Hydro generation was approximately 12.9 aMW below the authorized level
which would account for approximately $2.1 million of increased expense.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA AUGUST 29 , 2003
Request No.7: Please provide a copy of the insurance claims associated with damaged
transformers at the Coyote Springs power plant. Are there any other areas in which the Company
could have filed a claim? Please explain.
Request No.8: Please provide a breakdown of the compensation received as a result of
the Coyote Springs Insurance claims and categorize the compensation amounts to reflect account
numbers for all capital or expense items booked.
Request No.9: How much does the Company expect to defer in above normal power
supply costs in the July 2003 through June 2004 period? Please break this estimate into the
components shown on page 3 of the Company s Application. Please break the category titled
Net Increase in Power Supply Costs" into the components listed in Request No.5 above.
Dated at Boise, Idaho, this d.
~y
of August 2003.
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Technical Staff: Keith Hessing
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FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO AVISTA AUGUST 29, 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF AUGUST 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO A VISTA CORPORATION IN CASE NO. A VU-03-, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID 1. MEYER
SR VP AND GENERAL COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
KELLY NORWOOD
VICE PRESIDENT
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
MAILED TO:
kell y.norwood(fYavistacorp. com
CONLEY WARD
GIVENS PURSLEY, LLP
PO BOX 2720
BOISE ID 83701
RALPH DAVISSON
POTLATCH CORPORATION
601 W RIVERSIDE AVE
SUITE 1100
SPOKANE WA 99201
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CRETARY
CERTIFICATE OF SERVICE