20160818Clearwater 1-3 to AVU.pdf

Peter J. Richardson (ISB No. 3195)
Greg Adams (ISB 7454)
Richardson Adams, PLLC
515 N. 2ih Street
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for the Clearwater Paper Corporation
RECE IVED
20 I G . lh) I 8 PM 3: L+ 4
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE POWER COST )
ADJUSTMENT (PCA) ANNUAL RA TE )
ADJUSTMENT FILING OF A VISTA ~
CORPORATION. )
)
)
)
) _________________ )
CASE NO. AVU-E-16-05
FIRST PRODUCTION REQUEST OF
THE CLEAR WATER 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 their attorney
of record, Peter J. Richardson, hereby requests that Avista Corporation ("Avista") provide the
following with supporting documents, where applicable.
This production request is to be considered as continuing, and A vista 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:
Clearwater Paper Corporation First Production Request -A VU-E-1 6-05 1
[phone]; Fax: [phone] ; [e-mail] and in electronic form to
Marv Lew Allen at [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 include disclosures deemed by A vista to be confidential.
Counsel for Clearwater and Clearwater's expert witness, Don Reading will execute a
confidentiality agreement as necessary to facilitate complete responses.
REQUEST FOR PRODUCTION NO. 1
Please provide, in electronic format with all formulae intact where possible, all workpapers and
other documents used in the development of Avista's Application. Please include the documents
provided on compact disc as part of the filing as listed on page 7 of William Johnson's Direct
Testimony (Electric/Gas Transaction Record, Position Reports, and Forward Market Electric and
Natural Gas Price Curves).
REQUEST FOR PRODUCTION NO. 2
Please provide all discovery responses along with the workpapers and attachments provided to
all other parties.
REQUEST FOR PRODUCTION NO. 3
Please provide copies of all communications with the Idaho Public Utilities Commission and its
Staff regarding A vista's Application in this matter.
DA TED this 18th day of August 2016.
Clearwater Paper First Production Request -A VU-E-16-05 2
Clearwater Paper First Production Request -A VU-E-16-05 3
Richardson Adams, PLLC
e.~~ By~~~~__,,~~~~~~~~~~~
Peter J. Richardson, SB #3195
RICHARDSON ADAMS, PLLC
•
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of August, 2016, a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST of Clearwater Paper Corporation, in
Case No. AVU-E-16-05 was served as indicated below to:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise ID 83720-0074
Kelly 0 . Norwood
Vice President
State and Federal Regulation
A vista Corporation
1411 E. Mission Ave.
Spokane, WA 99220
[e-mail]
David J. Meyer
Vice President and Chief Counsel
For Regulatory and Governmental Affairs
A vista Corporation
1411 E. Mission Ave.
Spokane, WA 99220
[e-mail]
Electronically
[e-mail]
Kandi Walters
Administrative Assistant
Clearwater Paper First Production Request -AVU-E-1 6-05 4
x_ Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Hand Deliver
K_U.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
Hand Deliver
K_U.S. Mail, postage pre-paid
Facsimile
K_ Electronic Mail