20160721Clearwater 1-5 to AVU.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27ft Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonandoleary. com
gre g@richardsonandoleary. com
Attorneys for the Clearwater Paper Corporation
IN THE MATTER OF THE
APPLICATION OF AVISTA
CORPORATION FOR THE AUTHORITY
TO INCREASE ITS RATES AND
CHARGES FOR ELECTRIC AND
NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO
FiTC IIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. AW-E.16.03
FIRST PRODUCTION REQUEST OF
THE CLEARWATER PAPER
CORPORATTON
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Clearwater Paper Corporation (Clearwater) by and through their
attorney of record, Peter J. Richardson, hereby requests that the Avista Corporation
("Company") provide the following documents.
This production request is to be considered as 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 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
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
[phone]; Fax: (208) 3 84- I 5 1 I ; [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.
REOUEST FOR PRODUCTION NO. 1
Please provide all discovery responses along with the work papers and attachments
provided to all other parties.
REOUEST FOR PRODUCTION NO. 2
Please provide copies of all material provided to the PUC Staffregarding the Company's
application that were provided other than through formal discovery.
REOUEST FOR PRODUCTION NO. 3
Please provide for the past 10 years (2007 through 2015, at the end ofthe fiscal year) for
each year the following as it relates to the Company's rate of return and capital structure;
a) The actual percentage of equity,
b) The actual percentage ofdebt,
c) The Commission authorized cost of equity approved by the,
a. Washington Utilities and Transpiration Commission,
b. Idaho Public Utilities Commission,
The actual cost of debt,
a. Long-term,
b. Short-term,
c. Weighted Long and Short Term debt,
The overall rate of return approved by the,
a. Washington Utilities and Transpiration Commission,
b. Idaho Public Utilities Commission.
REOUEST FOR PRODUCTION NO. 4
On page 20 of Mark Thies' testimony he states "In April2016 the Company requested an
extension of the expiration date, requesting an additional two years to April 2021" for the
$400 million of revolving credit. Please provide the interest rate, both before and after
First Production Request of the Clearwater Paper Corporation
AVE-E-16-03
Page2
d)
e)
this extension.
REOUEST FOR PRODUCTION NO. 5
On page 35 of Mark Thies' testimony contains footnotes 9 (Moody's Investors Service,
Rating Mythology, December 23,2013) and 10 (Standard and Poor's Key Factors, March
2010). Please provide the complete report of both Moody's and Standard and Poor's
referenced in footnotes 9 and 10.
DATED this 21't day of July,2016
Richardson Adams, PLLC
,, fi,&.&)t*, -
Peter J. Richardson
Clearwater Paper Corporation
First Production Request of the Clearwater Paper Corporation
AVE-E-I6-03
Page 3
CERTIFICATE OF SERVICE
I hereby certiff that on July 21, 2016, copies of the foregoing First Production Request of
the Clearwater Paper Corporation were delivered via U. S. Mail postage prepaid and
electronically as indicated, to:
David J. Meyer, Esq.
Vice President and Chief Counsel for Regulatory Affairs
Avista Corporation
POBox3727
l4l I Mission Avenue
Spokane, WA99220-3727
David.mever@ avistacorp. com
Kelly Norwood
Vice President - State and Federal Regulation
Avista Utilities
POBox3727
Spokane WA99220-3727
Kelly.norwood@avistacorp. com
Avistadockets@avistacom. com
Brandon Karpen
Deputy Attomey General
Idaho Public Utilities Commission
472 W, Washington (837 02)
P0 Box 83720
Boise,ID 83 720-0074
Brandon.karpenpuc@fruc. idaho. gov
Dean J. Miller, Esq.
McDevitt & Miller, LLP
3620F,. Warm Springs
Boise,lD 83716
deanjm i I [e-mail]
First Production Request of the Clearwater Paper Corporation
AVE-E-16-03
Page 4
Larry A. Crowley
The Energy Strategies Institute, Inc.
5549 S. Cliffsedge Avenue
Boise,lD 83716
[e-mail]
Ken Miller
Snake River Alliance
Box l73l
Boise,ID 83701
km i ller@snakeriveral I iance.org
Brad M. Purdy, Attomey at Law
Community Action Partnership Association of ldaho
2019 N. l7e Street
Boise, lD 83702
[e-mail]
Kandi Walters
Adminisfr ative Assi stant
First Production Request of the Clearwater Paper Corporation
AVE-E-16-03
Page 5