20031009Reply Comments.pdf

Kelly O. Norwood
Vice-President, State and Federal Regulation
1411 E. Mission Avenue
P. O. Box 3727
Spokane, Washington 99220
Phone: [phone], Fax: [phone]
RECEIVED (1)FILED
Zan3 OCT -9 AtffO: 32
IUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTll.lTIES 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
REPLY COMMENTS OF
A VISTA CORPORATION
CASE NO. A VU-03-
I. INTRODUCTION
A vista Corporation doing business as A vista Utilities (hereinafter A vista or Company), at
1411 East Mission Avenue, Spokane, Washington, respectfully files its Reply Comments in the
above-entitled matter.
II. BACKGROUND
On August 11, 2003, Avista filed its Power Cost Adjustment (PCA) Schedule 66 Status
Report with the Idaho Public Utilities Commission (Commission) and an Application requesting
approved recovery of excess power costs deferred through June 30, 2003 and further continuation
of the 19.4% ($23.6 million) PCA surcharge. The Staff of the Commission submitted its comments
on September 30, 2003.
REPLY COMMENTS OF A VISTA PAGE 1
III. REPLY COMMENTS
In comments dated September 30, 2003, Commission Staff has recommended disallowance
of approximately $5.9 million of deferred costs associated with certain natural gas costs for thermal
generation. A vista does not agree with Staff's recommendation. The transactions related to the costs
at issue were entered into in the spring of 2001, at a time when wholesale electric prices were at
unprecedented highs, federal regulators were continuing to refuse to intervene, and A vista was facing
the worst hydroelectric conditions in its history. The Company believes that a careful review of the
information available at the time the transactions were entered into will show that the decisions were
reasonable given the circumstances at the time.
The Company requests the opportunity to fully respond to Commission Staff's
recommendations through evidentiary hearings. However, following discussions with Staff, A vista
and Staff agree that it would be administratively efficient for the Company to respond to Staff's
recommendations in its upcoming general rate case, which A vista plans to file in the first quarter of
2004. If evidentiary hearings were to proceed in this case, they would likely overlap the general rate
case proceedings.
In its comments, Staff recommended that the "existing PCA rates be continued until the next
PCA regardless of the final decision reached in this case." Approval of continuation of the existing
surcharge rates by the Commission until the next PCA (through October 11, 2004) would allow
adequate opportunity for the issues in this case to be addressed in the general rate case. A vista would
REPLY COMMENTS OF A VISTA PAGE 2
fully respond to the issues raised by Staff in this case, in its pre-filed testimony in the general rate
case, to be filed no later than March 31 , 2004.
IV. REQUEST
A vista respectfully requests that the matters identified in the Staff's comments filed in this
case be addressed instead in A vista s upcoming electric general rate case to be filed no later than
March 31 , 2004. The Company also requests that the Commission approve the continuation of the
existing 19.4% surcharge through October 2004.
Dated at Spokane, Washington this 8th day of October 2003.
AVISTA CORPORATION
rJ?
( -
BY t'. iHtlfcc
Kelly O. orwood
Vice-President, State and Federal Regulation
I If the Commission does not accept the proposal to address the issues raised by Staff in the context of the next
electric general rate case, then Avista requests the opportunity to fully present its case by means of evidentiary
hearings in this case. Modified Procedure would no longer be appropriate.
REPLY COMMENTS OF A VISTA PAGE 3