20100812Clearwater 1-9 to AVU.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson & O'Leary, PLLC
515 N. 27th Street
P.o. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(ßrichardsonandoleary.com
greg(ßrichardsonandolear.com
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Attorneys for Clearater Paper Corporation
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE POWER COST
ADJUSTMENT (peA) ANNAL RATE
ADJUSTMENT FILING OF A VISTA
CORPORATION
)
) CASE NO. A VU-E-I0-03
)
)) FIRST PRODUCTION REQUEST OF
) CLEARWATER PAPER
) CORPORATION
)
Pursuat to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), Clearater Paper Corporation ("Clearater") hereby requests that Avista
Corporation ("Avista") provide responses to the following with supporting documents, where
applicable, on or before September 2,2010.
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 will augment the responses or documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-IO.03 - PAGE 1
unavailable, a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]; dreading(Ðmindspring.com.
F or each item, please indicate the name of the person( s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
Some of the following requests may include disclosures deemed by A vista to be
confidential. Counsel for Clearater and Clearater's expert witness, Don Reading, have
expressed intent to execute any reasonably necessar confdentiality agreement prior to sending
these Requests for Production, and will do so when A vista provides such an agreement so as not
to delay any of the responses to the following requests.
REQUEST FOR PRODUCTION NO.1
The table on page 3 of the Direct Testimony of Wiliam G. Johnson indicates the "Change in
Retail Loads" contributes $2.9 milion to the net deferral surcharge of $16.4 milion.
(a) Please provide an explanation of how this value was derived, and whether this value is
associated with A vista's Retail Revenue Credit Rate.
(b) Please provide in electronic form the components that are used in deriving this value.
( c) Does this value include transmission expenses?
(d) Please provide a history over the past 5 years of the impact of the "Change in Retal
Loads" on power supply expense fiings and rate changes.
(e) Please explain why A vista believes ratepayers should compensate the Company for
loss ofloads through the PCA, even though fewer kilowatt-hours were demanded by
customers.
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-I0-03 - PAGE 2
REQUEST FOR PRODUCTION NO.2
If the $2.9 milion amount specified in Request NO.1 does not account for Avista's Retail
Revenue Credit Rate, please provide the following:
(a) Please provide the rate impact of Avista's Retail Revenue Credit Rate in this PCA case,
and an explanation of how this value was derived.
(b) Please provide in electronic form the components that are used in deriving this value.
(c) Does this value include transmission expenses?
(d) Please provide a history over the past 5 years of the impact of Avista's Retail
Revenue Credit Rate on power supply expense filings and rate changes.
(e) Please explain why the A vista believes ratepayers should compensate the Company for
loss of loads through the PCA, even though fewer kilowatt-hours were demanded by
customers.
REQUEST FOR PRODUCTION NO.3
Reference IPUC Order No. 31033, at p. 12. In PacifiCorp's 2010 PCA, the Commission stated
that in times of declining loads PacifiCorp's load growth adjustment mechansm "appears to
operate much the same as a decoupling mechanism reimbursing the Company for lost revenue
for reductions in customer usage (sales)."
(a) Is Avista's Retail Revenue Credit Rate operating much the same as a decoupling
mechanism in this PCA case? Please explain.
(b) What power supply cost is the Company recovering with its Retal Revenue Credit Rate
in this case (e.g., gas costs, power purchase costs, retur on rate base, etc.)?
(c) Please explain the rationale for utilizing Avista's Retail Revenue Credit Rate for the
deferral period in this case where loads are declining.
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-I0-03 - PAGE 3
(d) Please cite or provide the Commission order authorizing.Avista to utilize the Retail
Revenue Credit Rate during a deferral period with declining loads.
REQUEST FOR PRODUCTION NO.4
Footnote 3, page 2, of the Direct Testimony of Wiliam G. Johnson states:
The PCA tracks 100% of the variation in Clearater Paper
generation power purchase expense and Clearater Paper retail
revenue related to their generation leveL. Clearwater Paper's
generation during the review period was less than the authorized
level, which results in a PCA deferral in the rebate direction
because the reduction in the power purchase expense exceeded the
reduction in the retail revenue related to the generation leveL.
Please provide in electronic form the data used to calculate the Clearater Paper adjustment of
$19,299 referenced in footnote 3.
REQUEST FOR PRODUCTION NO.5
The Direct Testimony of Wiliam G. Johnson states, on page 4, "Retal loads were 66.4 aMW
below the authorized level due primarily to winter temperatues that were significantly warer
than normaL."
(a) Please provide temperatures and consumption data monthly for July 2009 through June
2010, or other data supporting this assertion.
(b) Please provide normal temperatues for those same months.
(c) Are there any other possible causes of retail loads being 6.1 % lower than authorized
levels durng the deferral period? Please explain.
REQUEST FOR PRODUCTION NO.6
In support of allocating PCA costs on an equal cents per kWh basis, Commission Staff testified
that variable "power supply costs that are captured in the PCA mechansm are directly related to
the variable costs of providing energy. The fixed costs of power supply are not captured in the
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-I0-03 - PAGE 4
PCA." Direct Testimony of Keith Hessing, Commission Staff, Case Nos. AVU-E-04-1and
AVU-G-04-1, at p. 23 (June 21, 2004). But in this case the Direct Testimony of Wiliam G.
Johnson, at page 3, indicates that the Company's fiing includes a request for recovery of 100%
of the Lancaster fixed costs for the deferral period - a quantity of approximately $6 milion.
Does A vista believe it is appropriate to allocate such fixed costs among customer classes on á".~..; .~'." , .; ~ ',"
equal cents per kWh basis rather than as a uniform percentage of revenue basis per customer
class? Please explain.
REQUEST FOR PRODUCTION NO.7
The table on page 3 of the Direct Testimony of Wiliam G. Johnson indicates the "Centralia
Refud Adjustment" reduces the deferral surcharge by $189,607 milion. Please explain the
derivation ofthis value.
REQUEST FOR PRODUCTION NO.8
The Direct Testimony of Wiliam G. Johnson, on p. 3, indicates that the change in market prices
on net power purchase expense is negative $1,795,124. Please explain the derivation of ths
value.
REQUEST FOR PRODUCTION NO.9
Please provide copies of all discovery responses A vista makes to the Idaho Public Utilties
Commission Sta and any other intervenor.
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-1O-03 - PAGE 5
Than you, in advance, for your prompt attention to ths First Request for Production.
Sincerely yours,
tJ
Peter J. Richardson
RICHARDSON & O'LEARY, PLLC
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. A VU-E-l 0-03 - PAGE 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the iil\ay of August, 2010, a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
CORPORATION was served as shown to:
Jean D. Jewell, Secretar
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
.)Hand Delivery_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Scott Woodbur
Deputy Attorney
Idaho Public Utilties Commission
472 West Washington
Boise, Idaho 83702
X Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
David J. Meyer
Vice President and Chief Counsel of
Regulatory and Governental Affairs
A vista Corporation
1411 E. Mission Avenue
Spokane, Washington 99220
_ Hand Delivery
~ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Kelly O. Norwood
Vice President
State and Federal Regulation
A vista Corporation
1411 E. Mission Avenue
Spokane, Washington 99220
_ Hand Delivery
XU.S. Mail, postage pre-paid
Facsimile
_Electronic Mail
BY:~~
Nina uris
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-I0-03 -PAGE 7