20140807Clearwater 4-7 to Avista.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,Idatro 83702
Telephone : [phone]
Fax: [phone]
Peter@richardson*dol.*n. "o*gre e@richardsonandolear.v. com
Attorneys for Clearwater Paper Corporation
IN THE MATTER OF THE POWER COST
ADruSTMENT (PCA) ANNUAL RATE
ADJUSTMENT FILING OF AVISTA
CORPORATION
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. AVU-E-14-06
SECOND PRODUCTTON REQUEST
OF CLEARWATER PAPER
CORPORATION
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 docurnents produced.
SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
TN CASE NO. AVU.E-I4.06 _ PAGE I
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];
[e-mail] and in electronic form to [e-mail].
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, will execute a
confidentiality agreement as necessary to facilitate complete responses.
REOUEST FOR PRODUCTION NO. 4
Page three of William Johnson's direct testimony states, "Colstrip Unit 4 was unavailable due to
a forced outage from July 1,2013 until January 22,2014."
A. Please explain and document the circumstances causing the "forced outage."
B. Please detail all efforts undertaken to correct the "forced outage."
C. Was the event(s) causing the forced outage insured against? If so, please provide all
documentation related to the insurance (policies, notices, claims etc.). If not, please explain why
no insurance was secured against such events.
D. Please explain and justifr why Avista's PCA mechanism should cover power supply
expenses associated with a forced outage of a coal fired power plant? Provide copies of all
Commission's orders relied upon.
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SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
TN CASE NO. AVU-E-14-06 _ PAGE 2
REOUEST FOR PRODUCTION NO.5
Please provide, in electronic format with all formulae intact where possible, all workpapers and
other documents used to calculate the $4,082,573 "Change due to Colstrip Generation and Fuel
Expense" from the table on page 4 of Mr. Johnson's testimony.
REOUEST FOR PRODUCTION NO. 6
Mr. Williams states on page three of his direct testimony: "Given that the power purchase rate
was lower than retail rates, when the Clearwater purchase contract ended on June 30, 2013 and
Clearwater chose to use its generation to reduce purchases from Avista, the result was an
increase in PCA surcharge deferrals."
A. Please provide, in electronic format with all formulae intact where possible, all
workpapers and other documents used to calculate the $2,320,289 change due to the purchase
contract for Clearwater Paper.
B. Has Avista performed any studies relating to the base rate impact of the change in the
purchase contract? If so, please provide. If not, does Avista believe there is any impact? Please
explain fully.
REOUEST FOR PRODUCTION NO. 7.
Mr. Williams states on page three of his direct testimony that: "Palouse Wind is currently
included in the authorized level of power supply expense (i.e. is not included in base rates)."
A. Do the payments to Palouse Wind include a capacity component? If not, please explain
why not? [f so, please document.
B. [f payments to Palouse do include a capacity component, please explain the
collecting the costs associated with that project on a kWh basis.
for
SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
TN CASE NO. AVU-E.14-06 - PAGE 3
B # 3195
RDSON ADAMS, PLLC
I HEREBY CERTIFY that on the 7th day of August, 2014, a true and conect copy of the within
and foregoing FIRST PRODUCTION REQUEST of Clearwater Paper Corporation in Case No.
AVU-E-I4-06 will be served by HAND DELIVERY, to:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, tdaho 83702
And on August 6 via electronic mail and U.S. Mail, postage prepaid to:
Kelly O. Norwood
Vice President
State and Federal Regulation
Avista Corporation
141I E. Mission Ave.
Spokane, WA 99220
Kelly. norwood@ avistacorp. com
David J. Meyer
Vice President and Chief Counsel
for Regulatory and Governmental
Affairs
Avista Corporation
1411 E. Mission Ave.
Spokane, WA99220
David. meyer@ avistacorp. com
SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
TN CASE NO. AVU-E-14-06 _ PAGE 4