20250224Clearwater Paper to AVU 1-6.pdf

RECEIVEC
Monday, February 24, 202E
IDAHO PUBLIC
I Peter J. Richardson UTILITIES COMMISSION
515 N. 271" Street
2 Boise, Idaho 8702
3 (208) 9387901
[phone]
4 eter a)richardsdonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
s IN THE MATTER OF THE APPLICATION CASE Nos.: AVU-E-25-01, AVU-G-25-01
9 OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
10 AND CHARGES FOR ELECTRIC AND FIRST PRODUCTION REQUEST OF
I I NATURAL GAS SERVICE TO ELECTRIC CLEARWATER PAPER CORPORATION
AND NATURAL GAS CUSTOMERS IN THE TO AVISTA CORPORATION
12 STATE OF IDAHO
13
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities
14
15 Commission (the "Commission"), Clearwater Paper Corporation by and through its attorney of
16 record, Peter J. Richardson, hereby requests that Avista Corporation ("Avista" or the
17 "Company") provide responses to the following with supporting documents, where applicable.
18 This Production Request is to be considered as continuing, and Avista is
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requested to provide by way of supplementary responses additional documentation that it or any
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21 person acting on its behalf may later obtain that will augment the responses or documents
22 previously produced.
23 Please provide an additional electronic copy, or if unavailable, a physical copy, to
24 Dr. Reading at; 280 S. Silverwood Way, Eagle, Idaho 83616 dread-i-n a�)mnd— rn�,.com .
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28 FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION TO AVISTA CORPORATION
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I For each response, please indicate the name of the person(s)preparing the same
2 along with the job title of such person(s) and the name of the witness at hearing who can sponsor
3
the answer.
4
5
REQUEST FOR PRODUCTION NO. 1:
6 Please provide copies of all communications between Avista and the Idaho Public
7 Utilities Commission(including its Staff, consultants and/or Commissioners) regarding any
8 aspect Avista's current rate case as well as any aspect of Avista's anticipated or possible future
9
rate cases.
10
I REQUEST FOR PRODUCTION NO. 2:
12 Please provide copies of all responses to production requests (whether formal or informal
13 provided to any other party to this proceeding.
14 REQUEST FOR PRODUCTION N0. 3:
15
At page 7 of his direct prefiled testimony, Mr. Miller states:
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17 However, given the size of the proposed base revenue increase, Avista is proposing t
spread the revenue increase on a uniform percent of revenue basis at the proposed levels
18 The spread of the proposed increase still results in the rates of return for the various electric
service schedules moving closer to the overall rate of return (unity) for most schedules.
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20 Please explain, and document, Avista's policy regarding the relationship between the magnitud
21 of a revenue increase and rate spread recommendations in general and also specifically explain
22 how that policy is being implemented for this particular rate case.
23
24
RIB:( tjEST FOR PRODUCTION NO. 4:
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Parenthetical in original.
28 FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION TO AVISTA CORPORATION
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I At what level of a rate increase would Avista find it appropriate to move customer classe.
2 closer to the overall rate of return (unity). Please provide narrative of the company's policy o
3
this issue and, if available, copies of the company's written policy on this issue. Please identify
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5 the individuals in the Company who made the decision as to the company's recommends
6 movement, or lack thereof, toward unity for the various service schedules.
7 REQUEST FOR PRODUCTION NO. 5:
8 On page 7 of Mr. Miller's prefiled direct testimony he provides "Table No. 5—Present
9
Proposed Relative Rates of Return" that is based on a uniform 14.0% increase in base rates for th
to
I first year's proposed rate increase. There appears to be no similar table showing the relative rate
12 of return based on the second year's proposed rate increase of 5.0%. Please provide the Company'.
13 calculations of the relative rates of return based on the second year's proposed rate increase—using
14 the assumption that the first year's proposed rate increase has been adopted as filed in the
15
Company's application.
16
17 REQUEST FOR PRODUCTION NO. 6:
18 Exhibit No. 14, Schedule 3,Page 1 at line 601 indicates that Avista has invested$3,207,13
19 in distribution plant to serve Clearwater Paper Corporation. Please verify said investment amoun
20 and identify the distribution facilities being used to provide service to Clearwater Pape
21
Corporation.
22
23
24 Dated this 241h day of February 2025.
2s
26
Peter J. Richardson ISB # 3195
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28 FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION TO AVISTA CORPORATION
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1
I HEREBY CERTIFY that on the 241h day of February 2025, a true and correct copy of the
2 within and foregoing FIRST PRODUCTION REQUEST OF THE CLEARWATER PAPER
3 CORPORATION TO AVISTA CORPORATION was served, pursuant to Commission Order
No. 34602, by electronic copy only, to:
4
Monica Barrios-Sanchez
5 Commission Secretary
6 Idaho Public Utilities Commission
Monica.barriossanche puc.idaho.gov
7 — -- -
8 Secretary
Idaho Public Utilities Commission
9 secretary puc.idaho.gov
10 Adam Triplett
Deputy Attorney General
l l Idaho Public Utilities Commission
12 adam.triplettC&puc.idaho.gov
13 David J. Meyer, Esq.
14 Vice President and Chief Counsel
for Regulatory& Governmental Affairs
15 Avista Corporation
David.m-er4avistacorp.com
16 avistadockets(i0vistacorp.com
17 Patrick D. Ehrbar
18 Director of Regulatory Affairs
Avista Corporation
19 Pat.ehrbar(a.�avistacorp.com
20 �l o
21 By
Peter J. Richardson ISB # 3195
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28 FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION TO AVISTA CORPORATION
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