20150529Staff 1-5 to AVU.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEYS GENERAL .T, .
IDAHO PUBLIC UTILITIES COMMISSION ii: i Ii I " ,... T !,i';' ?. n ,PO BOX 83720 ', i; ,,: !
BOISE, IDAHO 83720-0074 ''; ir ;1-(2os)334-0312 i't"tt':''':-''
-,
IDAHO BAR NO. 3366 . '-.i
Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTTLITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION )
oF AVISTA CORPORATTON AND ) CASE NO. AVU-E-15-06
CLEARWATER PAPER CORPORATION FOR )
APPROVAL OF AMENDMENT NO. 1 TO THE ) FrRST PRODUCTTON
ELECTRIC SERVICE AGREEMENT. ) REQUEST OF THE) coMMrssroN STAFF To
) AVTSTA CORPORATION
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Donald L. Howell, Deputy Attorney General, request that Avista Corporation (Company; Avista)
provide the following documents and information as soon as possible, by FRIDAY,
JUNE 19,2015.
This Production Request is continuing, and the Company 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 documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.01.0r.228.
FIRST PRODUCTION REQUEST
TO AVISTA MAY 29,2015
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a summary showing Clearwater's approximate
monthly generation and load for each of the past l0 years.
REQUEST NO.2: Please describe the circumstances under which Avista expects
Clearwater to generate Incremental Energy. Please be as specific as possible and give examples
if necessary.
REQUEST NO.3: Please clarify the difference between Excess Energy and
Incremental Energy.
REQUEST NO. 4: Please provide a summary showing the amounts by month of Excess
Energy generated by Clearwater since the inception of the current Agreement in June 2013.
REQUEST NO. 5: Please provide data showing the frequency and duration of
generation outages at Clearwater since the inception of the current Agreement in June 2013.
DATED at Boise, Idaho, tni, 21fu Ourof May 2015.
Technical Staff: Rick Sterling (1-5)
i : umisc:prodreq/avue I 5.6dhrps prod req I avista
FIRST PRODUCTION REQUEST
TO AVISTA
Deputy Attorney General
MAY 29,2015
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF MAY 2015, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-15-06, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE W A 99220-3727
PETER RICHARDSON
RICHARDSON ADAMS PLLC
505 N 27TH STREET
BOISE ID 83702
MICHAEL S GADD
SR VP & GEN COUNSEL
CLEARWATER PAPER CORP
60I W RIVERSIDE AVE STE I lOO
SPOKANE WA 99201
CERTIFICATE OF SERVICE