20210524Clearwater 4-7 to Avista.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
5 l5 N. 27th Street
Boise, Idaho 83702
Telephone : [phone]
Fax: [phone]
peter@richardsonandoleary. com
Attorneys for Clearwater Paper Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
.com
IN THE MATTER OF THE
APPLICATION OF AVISTA
CORPORATION TO INCREASE ITS
RATES AND CHARGES FOR ELECTRIC
AND NATURAL GAAS SERVICE TO
ELECTRIC AND NATURAL GAS
CUSTOMERS IN THE STATE OF IDAHO
CASE NO. AVU-E-21-01
CASE NO. AVU.G.21.O1
SECOND PRODUCTION REQUEST
OF CLEARWATER PAPER
CORPORATION
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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 attomey 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.
Please provide an additional electronic copy, or if unavailable, a physical copy, to Dr.
Don Readingat:6070 Hill Road, Boise, Idaho 83703, Tel: [phone]:. Fax: (208) 384-l5l l;
SECOND PRODUCTION REQUEST OF CLEARWATE,R PAPER CORPORATION
IN CASE NO. AVU-E,-2|-OI AVU-G-21.0I - PAGE I
RECEIVED
2021May 24, PM 2:14
IDAHO PUBLIC
UTILITIES COMMISSION
[e-mail] and in electronic form to [e-mail]; and
mal i sa. maynard@,c learwaterpaper. 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 (Peter Richardson and Greg Adams) Clearwater's expert witness, Dr.
Don Reading, as well as counsel's legal assistant (Grace Hansen) have executed the
confidentiality agreement in order to facilitate complete responses.
REOUEST FOR PRODUCTION NO.4
Company witness Miller in his Direct Testimony was asked if the Commission were to order a
revenue requirement lower than the Company's request how would they propose to spread the
revenue request. He answered on page 8 of his direct testimony:
lf the Commission were to order a lower revenue requirement, the Company
proposes to allocate the same increase as the Company's initialfiling to Residential
Service Schedule I. The Company also proposes that Large General Service
Schedules 2l/22, Extra Large General Service Schedule 25, Pumping Service
Schedules 3l/32 and Street and Area Lights Schedules continue to receive an equal
percentage of'revenue increase. Any remaining revenue should then be applied
equally to Schedules ll/12 qnd Schedule 25P as those schedules are providing
signfficantly more than their relative cost ol'service as discussed by Ms. Knox.
During Rate Year I (RY I ) the revenue requirement was set to be offset with the tax credit.
If the revenue requirement is less that proposed by Avista how will the tax credit benefit ratepayers
be spread for the benefit of Avista's ratepayers?
SE,COND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-21-OI AVU-G-2I -O I - PAGE 2
REOUEST FOR PRODUCTION NO. 5
lf the Commission were to order a two-year revenue requirement that is less than the tax credit
how does the Company propose the tax credit would be returned to rate payers in Rate Year 2
(RY2X
REOUEST FOR PRODUCTION NO. 6
During Rate Year I (RYl) for Clearwater (Schedule 25P) the Company is proposing to not change
any ofthe demand charges but"The revenue increasefor the schedule is proposed to be recovered
through qn increase of 0.520 cents per klVh to the energy charge." fDirect Testimony Joseph
Miller, p. 16.] Please explain in detail the rational of fixing Clearwater's demand charges at current
rates and applying the increased revenue requirement all on energy charges.
UEST FOR PRODUCTI
During Rate Year 2 (RY2) for Clearwater (Schedule 25P) the Company is
proposing ". . the present minimum demand charge of 814,000 be increased by $2,500, to
816,500 per month. Further, the Company is proposing to increase the volumetric demand charge
for the 3,000 55,000 kVA blockfrom $5.00/kVA to 55.50/kt/A. The remaining revenue change
.for the schedule is proposed to be recovered through a percentage decrease of'approximately 0.4%
applied to the single energy block rate, a decrease of 0.017 cents per kwh." [Direct Testimony, a
Joseph Miller, pg. 16, 17.] Please explain in detail the rational of increasing Clearwater's demand
charges and reducing the per kWh energy charge for RY2.
rhi th da¡çof y 202r.
J.ISB # 3195
RICHARDSON ADAMS, PLLC
SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU.E.2I-OI AVU-G-2I-OI - PAGE 3
I HEREBY CERTIFY that on the24th day of May,202l, a true and correct copy of the within
and foregoing SECOND PRODUCTION REQUEST of Clearwater Paper Corporation in Case
No. AVU-E-21-01, AVU-G-21-01 was served, pursuant to Commission Order No. 34602, by
electronic copy only, to:
JanNorkyuki
Commission Secretary
Idaho Public Utilities Commission
Jan. norivuki@puc. idaho. gov
David J. Meyer
Vice President and Chief Counsel
for Regulatory and Governmental
Affairs
Avista Corporation
Dav id. meyer@avi stacorp.com
Benjamin Otto
Idaho Conservation League
botto
Brad Purdy
Attorney atLaw
bmpurdy(@hotmail.com
Norman M. Semanko
Parsons Behle & Latimer
[e-mail]
Steven W. Chriss
Director, Energy Strategies, Walmart Inc
S tephen. c hri s s (Ðwalmart. c om
John Hammond
Deputy Attorney General
ldaho Public Utilities Commission
j ohn. hammond@puc. idaho. gov
Patrick Ehrbar
Avista Corporation
Patrick. ehrb ar @av istac o rp. c om
dockets @avistacorp. com
Diane Gibson-Webb
Idaho Conservation League
deibson-webb@idahoconservation. org
Lany A. Crowley, Director
The Energy Strategies lnstitute, Inc.
crowle)[e-mail]
Vicki Baldwin
Parsons Behle & Latimer
vbaldwin@parsonsbehle. com
Ron Williams
Williams Bradbury
ron(Øwi I I iamsbradbury. c om
Peter Richardson
ISB # 319s
SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-2T-OI AVU-G-2I.OI - PAGE 4