20210528Clearwater 8 to Avista.pdf

Peter J. Richardson tSB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone : [phone]
Fax: [phone]
peter@,richardsonandoleary. com
gre g@richardsonandolear)¡. com
Attorneys for Clearwater Paper Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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-21.01
THIRD 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 Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel: [phone]; Fax: (208) 384- l5 I I ;
THIRD PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-2I-OI AVU.G-21-OI - PAGE I
RECEIVED
2021May 28, PM 1:11
IDAHO PUBLIC
UTILITIES COMMISSION
[e-mail] and in electronic form to [e-mail];
mal i sa. maynardldc 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.
REOI]EST F'OR P DUCTION NO. 8
For, the Company's proposed Rate Year I (RYl) the total proposed increased revenue
requirement is $24.8 million, and the total proposed increased revenue requirement is $8.7 million
for Rate Year 2 (RY2) equaling $33.5 million for the two year period. The total available tax
credit used to offset RYI's increased revenue requirement equals $24.8 million. Please describe
in narrative format how the Company proposes to return the unused portion of the tax credit to its
ratepayers in the event the Commission orders a combined (RYl and RY2) increased revenue
requirement of less than the $24.8 million tax credit? V/ould your answer differ if the Commission
ordered a zero increase in revenue requirement, and if so how? Would your answer differ if the
Commission ordered a decreased revenue requirement, and if so, how?
Dated this of 2021(
P ISB # 319s
RICHARDSON ADAMS, PLLC
THIRD PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-21-01. AVU-G-21-01 * PAGE 2
I HEREBY CERTIFY that on the 28tr' day of May, 2021 , a true and correct copy of the within
and foregoing THIRD 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.nori)¡uki@puc. idaho. eov
David J. Meyer
Vice President and Chief Counsel
for Regulatory and Governmental
Affairs
Avista Corporation
Dav i d. m e),er@avi stacorp. com
Benjamin Otto
Idaho Conservation League
botto@ idahoconservation. org
Brad Purdy
Attorney atLaw
[e-mail]
Norman M. Semanko
Parsons Behle & Latimer
nsemanko@parsonsbehle. com
Steven W. Chriss
Director, Energy Strategies, Walmart Inc
Stephen.chriss@wal mart.com
John Hammond
Deputy Attorney General
Idaho Public Utilities Commission
uc.idaho.sov
Patrick Ehrbar
Avista Corporation
Patrick. ehrbar@avistacorp. com
dockets@avistacorp. com
Diane Gibson-Webb
Idaho Conservation League
deibson-webb@idahoconservation. org
Larry A. Crowley, Director
The Energy Strategies Institute, Inc.
[e-mail]
Vicki Baldwin
Parsons Behle & Latimer
vbaldwin@parsonsbehle. com
Ron Williams
ron@williamsbradbury. com
Peter Richardson
ISB # 3195
THIRD PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
TN CASE NO. AVU-E-2T.OI AVU-G-2I.OI - PAGE 3