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Home My WebLink About20100617Clearwater 1-3 to AVU.pdf~r&:Ql~~ PlATTORNEYS AT LAW Peter Richardson Tel: 208-938-7901 Fax: 208.938-7904 pete rfi r ichardso nan doleary. com P.O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702 16 June 2010 Ms. Jean Jewell Commission Secretary Idaho Public Utilties Commission 472 W. Washington Boise, ID 83702 RE: A VU-E-I0-Ql A VU-G-I0-QL Dear Ms. Jewell: RECE 28lO JUN l 1 AM 8: l 2 We are enclosing an three (3) copies of the FIRST PRODUCTION REQUEST OF THE CLEARWATER PAPER CORPORATION in the above case. Sincerely,~ÚJ~\ Richardson & O'Leary PLLC Peter l. Richardsn (lSB # 3195) Greg Adams (lSB # 7454) Molly O'Leary (lSB # 4996) RICHARDSON &. CYLEARY, PLLC 515 N. 'Q Stree Bose, IÓlho 8302T~K (io $7'01 Fax: (20) 937904 R~-A~t\fr~, t:tjCI i CI) 2010 JUH 17 AM 8: l 2 IDAHO FU:(_i; UTILITIES co)XMišSION Attrneys for the Gearwater Paper Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION OF) ~l ~~g~t~ ) ) ) ) Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilites Commisson (the "Commission'1, Gearwater Paper Corporation ("Clearwater1, by and through its attorney of record, Peter J. Richardson, hereby requests that Avista Corporation (IlAvista11 provide the following information and documents. This producon request is to be considered as continuing, and Avita is hereby reques to provie by way of supplementary responses and additional documents. that it or FIRST PRODUcrlON REQUEST OF CLEARWATER TO AVIST A - 1 any person acting on its behalf may later obtain that wil augment the InformøtiolJ .ãiid documents produced. Please provide one copy of your answer to Mr. Richardson at the addf'e$ rr~ted above and one copy to Dr. Reading at 6070 Hil Road, Boise, Idaho 8303. Please provide Dr. ReadilJg1s copy in electronic format, if available. For each item, please indicate the name of the persolJ(s) preparing the ansers, along with the job title of such person(s) and the witness at hearing who can sponsor the answer. REQUEST FOR PRODUCTION NO.1: On page ISiof Tara Knox's Direc Tesmony she states, Historically, Avista has included transmission costs in the producton pek credit classifcation. It has been done this way largely beuse it is the accepted process in Washington, even though, as the interveners (sic) pointed out, 100% demand is the more universally accepted classification of transmisson cost in other states (including the other investor-owned utilities in Idaho). (p. 18.J (a) Please provide the names of the utilties, both WIthin ldahoandels€Where, that allocte 100% of the costs of transmission to demand as alleged by Ms. Knox in the above- quoted. Direc Testimony. (b) Please identify which lIinterveners" (sic) have "pointed QUt, 100% demand is the more universally accepted classification. of transmission costs in other states (including the other investor-owned utilities in Idaho)." REQUEST FOR PRODUCTION NO.2: The KEMA System Load Research Projec attched to Tara Knox's Direc Tesmony in Secion 2.4.5, pages 2-70 to 2-73, discusses the load characteristcs of Avista1s Extra Large General Service - CP customer class. Please provide all workpapers, data, and models, FIRST PRODUcrlON REQUEST OF ClEARWATER TO AVISTA - eleconic format where possible, that were use in devlopmg the analyss and conclusions of thi seon of the study. REQUEST FQR PROQUCTION NO.3: For the pur of the following request, please refer to Exibit 14, Schedule 3, p. 3 of 3 (P. Ehrbar), for Scheule 25P. Please explain, in detail, the ratinale for the Folowing: a) The 200Á, increase in the demand change for 3,000 kva or less (from $10,00 to $12,0 monthly); b) The increse of 23.08% in the demand charge over 3,00 Kva (from $3.2/kva to $4.00/ kva)¡ c) The jnc~ in the Annual Minimum from $555,6 to $611,990¡ d) The prop dend charge increases of 20% and greater, while the energy charge increase is less than 9%. Please provid all workpapers, data, and models, elecronic format where poible, that were use in deeloping the propo rate increases for this Schedule. DATED this 16th .day of June 2010. RICHARDSON & CYLEARY, PLLC By (/;k Peter Richardson Attorneys for Gearwater'Paper Corporation FIRST PRODUcrlON REQUEST OF CLEARWATER TO A VISTA - 3 CERTIACA TE OF SERVICE I HEREBY CERTIFY that on the 16th day of June, 2010, a trtte.~ndcorr~)~o~v)ofthe within and ,foregoing FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION was served as shown to: Jænc.Ð. fewell, Secretary Idaho Publi~ Utilities Commission 472 West Washington Boise, Idaho 83702 _ HandDelivery LU.s. Mail, postage pre-paid FacsimUe EI~ronic Mail Scott Woodbury Deputy Attorney Idaho Public Utilities Commission 472 West Washington Boise, Idaho 83702 _ Hand Delivery XU.s. Mail, postage pre-paid Facsimile EI~ronic Mail Patrick Ehrbar Manager, Rates&. Tariffs Avista Corporation P.O. Box 3727 Spokane, W A 99220 _ Hand Delivery X U.S. Mail, poge pre-paid Facsimile Elecronic Mail Brad M. Purdy Attorney at Law 2019 N. ITh Street Boise, ID 83702 _ Hand Delivery X U.s. Mail, postage pre-pa.id Facsimile EI~ronic Mail Dean J. Miler McDevitt & Miler, LLP 420 W. Bannock St. Bo:lse, 10 .8302 _ Hand Delivery L u.s. Mail, postage pre-paid _Facsimile Elecronic Mail Scott Atkison Idaho Forest Products 171 Highway 95 North Grangevile, ID 83530 _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile Electronic Mail Larry Crowley Energy Strategies Institute 5549 So. Cliffs Edge Edge Ave Boise, ID 83716 _ Hand Delivery lLU.S. Mail, postage pre-paid Facsimile~lc~\_By:~)~Q'l Nina Curtis FIRST PRODUcrlON REQUEST OF CLEARWATER TO A VISTA - 4