20121203Clearwater 1-10 to Avista.pdf

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ATTORNEYS AT LAW
Peter Richardson tjTILtTE COMM1SS
Tel: [phone] Fax: [phone]
[e-mail]
P0. Box 7218 Boise, ID $3707 - 515 N. 27th St. Boise, ID 83702
December 3, 2012
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P 0 Box 83720
Boise ID 83720-0074
RE: Case No. AVU-E-12-08
Case No. AVE-G-12-07
Dear Ms. Jewell:
Enclosed please find three (3) copies of the FIRST PRODUCTION
REQUEST OF CLEARWATER PAPER CORPORATION in the above case.
The original has been served on Avista Corporation.
Sincerely,
ma A
Administrative Assistant
end.
Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON & O'LEARY, PLLC
515 N. 274' Street
Boise, Idaho 83702
Telephone [phone]
Fax [phone]
[e-mail]
greg()richardsonando1earv corn
Attorneys for Clearwater Paper Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO AVU-E-12-08
APPLICATION OF AVISTA ) CASE NO AVU-G-12-07
CORPORATION FOR THE AUTHORITY )
TO INCREASE ITS RATES AND ) FIRST PRODUCTION REQUEST OF
CHARGES FOR ELECTRIC AND ) CLEARWATER PAPER
NATURAL GAS SERVICE TO ELECTRIC ) CORPORATION
AND NATURAL GAS CUSTOMERS IN )
THE STATE OF IDAHO )
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), Clearwater Paper Corporation ("Clearwater") by and through its attorney of
record, Peter J Richardson, hereby requests that Avista Corporation ("Avista") provide
responses to the following with supporting documents, where applicable
This production request is to be considered as continuing, and Avista 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 responses or documents produced
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO AVU-E-12-08 AND AVU-G-12-07 - PAGE 1
Please provide an additional electronic copy, or if unavailable, a physical copy, to Dr.
Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel: [phone]; Fax: [phone];
dreadingmindspring.com .
For 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 to be confidential.
Counsel for Clearwater and Clearwater's expert witness, Don Reading, have executed a
confidentiality agreement prior to sending these Requests for Production.
REQUEST FOR PRODUCTION NO.!
Please provide an electronic copy, with all formulae and links intact, of the electric related
portions of Exhibit 12 attached to Tara Knox's direct testimony. Please include, also in
electronic format where possible, all workpapers and other documents used in the development
of the electric portions of Exhibit 12.
REQUEST FOR PRODUCTION NO.2
Please provide an electronic copy, with all formulae intact, of Exhibit 6 attached to William
Johnson's direct testimony. Please include, also in electronic format where possible, all
workpapers and other documents used in the development of Exhibit 6.
REQUEST FOR PRODUCTION NO.3
On page 9 of Patrick Ehrbar's direct testimony he states:
The spread of the proposed increase generally results in the rates of return for the various
electric service schedules moving approximately 15% closer to the overall rate of return
(unity).
Please provide the calculations supporting the calculations for the percentage increase and
resulting relative rates of return for each rate class on page 10 in Tables 4 and 5.
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-l2-08 AND AVU-G-l2-07 - PAGE 2
REQUEST FOR PRODUCTION NO. 4
Please explain the logic used in applying the proposed increase for Clearwater Paper (Schedule
25P) all on the energy rate rather than spreading it between the demand and energy charges, as
shown in Exhibit A, the tariff pages.
REQUEST FOR PRODUCTION NO.5
Please explain the logic used in the increase in the Annual Minimum for Clearwater Paper
(Schedule 25P), as shown in Exhibit A, the tariff pages.
REQUEST FOR PRODUCTION NO.6
On page 15 of Robert Lafferty's direct testimony he states:
Analysis indicated that the combination of the significant drop in project cost and the
substantial tax incentives available for renewable projects completed by December 31,
2012 yielded long-term benefits for customers compared to waiting until tax incentives,
attractive project pricing, and particular attractive wind project sites may no longer be
available to Avista.
Please provide a copy of the analysis that led Avista to the conclusion that the Palouse Wind
Project was in the best long-run interest for its customers. Please include all workpapers,
spreadsheets (in electronic fonn),l and assumptions used in the analysis.
REQUEST FOR PRODUCTION NO. 7
On pages 12 and 13 of Robert Lafferty's direct testimony he states:
Avista's 2009 Integrated Resource Plan (IRP) indicated an approximate need for 50
aMW of qualifying renewable energy credits prior to 2016 in order to meet Washington's
renewable portfolio standard (RPS). In early 2011, the 2011 IRP was well into
development and identified a slightly lower need level of 42 aMW of qualifying
renewable energy credits. In February 2011, Avista decided to issue a request for
proposals (RFP) that would meet the Company's 2016 need for qualifying renewable
energy credits prior to the December 31, 2012 expiration of federal and state tax
incentives and other benefits, and also take advantage of the low equipment and
construction costs that appeared to be available at the time.
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-12-08 AND AVU-G-12-07 -PAGE 3
It appears that the need for the Palouse Wind project is being driven by the need to meet
Washington's renewable portfolio standard (RPS). Please provide all studies and analysis of the
cost advantage of constructing the Palouse Wind project as opposed to simply purchasing
renewable energy credits (REC) in the various markets for said credits. If the Company has not
conducted such a study please explain in detail why such a study was not conducted.
REQUEST FOR PRODUCTION NO. 8
Please provide a detailed list of all RECs purchased and all RECs sold by the Company since the
Washington RPS standards were implemented. Please include, in electronic format, if possible,
the date of the sale or purchase, the number of RECs sold or purchased, the price per REC for
each REC sold or purchased, and identify the counter party for each transaction.
REQUEST FOR PRODUCTION NO. 9
On page 15 of Robert Lafferty's direct testimony, he states:
The need for the type and size of resource provided by the Palouse Wind PPA was
demonstrated in the 2009 Integrated Resources Planning process. (See Exhibit 4,
Schedule 5) The need was also confirmed in the 2011 IRP, which was nearing
completing with the Palouse Wind PPA was executed.
On page 16 of Robert Lafferty's direct testimony, he states:
The Company's energy, capacity and REC needs were used as inputs to the development
of the Preferred Resource Strategy (PRS). The PRS is developed using a proprietary
linear programming model called PRiSM.
On page 8-3 of the Company's 2009 IRP (at Exhibit 4, Schedule 5 of Robert Lafferty's direct
testimony) is a list of the object functions and constraints used as inputs to the PRiSM model
used to conduct the analysis of the Palouse Wind PPA, among other resources. Please provide
the shadow prices fund as a result of the analysis for each of the following identified constraints:
Capacity needs;
Energy needs;
Washington RPS;
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-12-08 AND AVU-G-12-07 - PAGE 4
Resource limitations,
Resource availability; and
Risk tolerance.
REQUEST FOR PRODUCTION NO 10
On page 14 of his direct testimony Mr. Morris states that
These mandates, together with litigation and other claims related to the ownership and
operation of hydroelectric resources, have added, and continue to add, significant costs to
run the utility.
The "requirements" referenced on pages 14 - 16 aside, please identify and document all
litigation costs and "other claims" costs that are embedded in the Company's overall rates and
that are also additionally embedded in the $11.4 million increase in rates
Dated/i/is 3r y of Dece?er 2012.
V Peter'J. Richardsofi ISB # 3195
RICHARDSON & O'LEARY, PLLC
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-12-08 AND AVU-G-12-07 - PAGE 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3rd day of December, 2012, 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, Secretary _ Hand Delivery
Idaho Public Utilities Commission _U.S. Mail, postage pre-paid
472 West Washington - Facsimile
Boise, Idaho 83702 - Electronic Mail
jean.jeweIIcpuc.idaho.gov
Karl Klein j Hand Delivery
Idaho Public Utilities Commission _U S Mail, postage pre-paid
472 West Washington - Facsimile
Boise, ID 83702 Electronic Mail
karl klein(puc idaho gov
David J. Meyer, Vice President - Hand Delivery
Kelly Norwood, Vice President _U.S. Mail, postage pre-paid
Avista Corporation - Facsimile
P.O. Box 3727 X Electronic Mail
Spokane, WA 99220
david. meyer(avistacorp .com
kelly. norwood(avistacorp.com
Larry A. Crowley
The Energies Strategies Institute
5549 Cliffsedge Avenue
Boise, ID 83716
crowlevlaaol. corn
Dean J. Miller
Idaho Forest Group, LLC
McDevitt & Miller, LLP
420W. Bannock St.
Boise, ID 83702
ioe(mcdevitt-miIIer.corn
Benjamin Otto
Idaho Conservation League
P0 Box 844
Boise ID 83701
bottoidahoconservation org
- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
Brad M Purdy
Attorney at Law
2019 N 17" Street
Boise ID 83702
brn pu rdyhotmai I. corn
Ken Miller
Snake River Alliance
P0 Box 1731
Boise ID 83701
kmillersnakeriveraIIilance.orq
- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
Nina M. Curtis