20210809Clearwater 1-6 to Avista.pdf

'i.-rr Ii 'i L.-,Peter J.. Richardson
ISB No.3l95
Richardson Adams, PLLC
515 N. 271h Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
Attorneys for the Clearwater Paper Corporation
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE POWER COST
ADJUSTMENT (PCA) ANNUAL RATE
ADJUSTMENT FILING OF AVISTA
CORPORATION
CASE NO. AVU-E-21-09
FIRST PRODUCTION REQUEST
CLEARWATER PAPER
CORPORATION
Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), Clearwater Paper Corporation ("Clearwater") by and through its attorney of
record, Peter J. Richardson, hereby requests that Avista Corporation ("Avista") ("Company")
provide responses to the following with supporting documents, where applicable.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplemental 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, tdaho 83703,
dread i n gfrD.rn i nclsnri ns,. corn.
For each item, please indicate the name of the person(s) preparing the answer(s), along
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with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REQUEST FOR PRODUCTION NO. l:
Please provide copies of all of the company's responses to data requests from the IPUC
Staff (or any other party) in this matter. Please include responses to informal as well as formal
requests and oral as well as written requests.
REQUEST FOR PRODUCTION NO. 2:
Company witness Annette Brandon on pages l0 and I I of her Direct Testimony states;
Lower natural gas prices and increased revenuefrom natural gas-fired
generation resulted in the largest increase ($4.27 million) of any of the items
when compared to authorized. Coyote Springs 2 was downfrom March * June
2021 in order to replace the three-phase transformer that suffered afailure in
2018. This longer maintenance period was required to reconfigure the generattng
stationfrom one three-phase transformer to three single-phase
transformers. This longer than normal maintenance period was not considered tn
the initial power supply authorized. In total, natural gas-fired plants generated 64
aMW less than authorized, resulting in $4,3 million (ldaho allocation) of
increased power supply expense at the Mid-Columbia ("Mid-C") electricity
trading hub to replace the lower than normal level of natural gas generation.
Please provide the work papers used to calculate the$4.27 million increase, including the input
assumptions including ("Mid-C" prices, natural gas prices, normal maintenance period, etc.).
Please also include the normal maintenance period and the reason why three single-phase
transformers were needed to replace the three-phase transformer.
REQUEST FOR PRODUCTTON NO.3:
Company witness Annette Brandon on page 3 of her Direct Testimony states;
As one can imagine, nltmerolts variables affect short-term power supply. As such,
we employ the Energt Resources Risk Policy (" Risk Policy") to recognize and
actively manage the interaction and dynamics among these variables by
establishing processes for future load and obligation esttmation, resource
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estimation, and management of the expected net surplus or deficit short-term
position.
Please provide the Energy Resources Risk Policy used by Avista uses to manage it power supply
resources.
REQUEST FOR PRODUCTION NO.4:
Company witness Annette Brandon on page 6 of her Direct Testimony states;
The Company employs a Power Supply Hedge Requirements Report tool (PSHRR).
The PSHRR is an analytical tool to guide power supply hedging decisions in the
short-term forward period. It provides a process to systematically reduce open
positions with forward transactions by buying for expected shortages and selling
expected surpluses. An "open" pos[tionfor this purpose is theforecasted monthly
Jinancial positton that is not covered by .fixed price phystcal or financial
transactions, i.e., the surplus or deJicit that is subject to price risk. The plun
provides guidance, but may not befollowed rigidly when management judgment or
market conditions warrant other actions, no action, or simply a delay in acting.
Please provide Power Supply Hedge Requirements Report too (PSHRR) used by Avista uses in
its hedging program and the criteria it uses when it deviates from the guidance of the PSHRR .
REQUEST FOR PRODUCTION NO.5:
Company witness Kaylene Schultz on pages 4 and 5 of her Direct Testimony states;
The $446,075 credtt.for Renewable Energy Credit Retirement benefits is to credit
Idaho customers.for benefits related to the renewable energ/ credits retired to
meet ll/ashington's renewable portfolio standards. The RECs used to meet
Washington RPS are tracked 100% in the PCA. The credit is based on the ldaho
allocation of RECs that were retired to meet Washtngton RPS (WA I-937) that
would have been otherwise sold.
Please provide the work papers used to calculate $446,A75, Renewable Energy Credit Retirement
benefits including the input assumptions including the volume and prices of the RECs retired.
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REQUEST FOR PRODUCTTON NO.6:
Company witness Annette Brandon on page 6 of her Direct Testimony states;
The PCA includes a load change adjustment to reflect the change in power
production and transmission expense recovered through base retail revenues,
related to changes in retail load. The LCAR calculation is based on the energl
classiJied production and transmission costs included in the Company's general
rate case. The LCAR revenue adjustmentfor July 2020 through June 2021 was
$22.00/MWh.
Please provide the work papers used to calculate LCAR of $22.00/MWh, including the input
assumptions of production and transmission costs included in the Company's general rate case.
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DA fi of 202t
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICEcy
I HEREBY CERTIFY that on the dt'day of August 2021, a true and correct copy of the within
and foregoing FIRST PRODUCTION REQUEST OF THE CLEARWATER PAPER
CORPORATION TO AVISTA CORPORATION in Docket No. AVU-E-21-O9 was served
electronically to:
David Meyer
Vice President and Chief Counsel
For Regulatory and Government Affairs
Avista Corporation
david. meyer@av istacom.com
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
jan. nori y uki6?p uc. idaho. gov
Commission Secretary
Idaho Public Utilities Commission
secretary6Dpuc. idaho. gov
Patrick D. Ehrbar
Director Regulatory Affairs
Avista Utilities
patri ck. ehrbar@avi stacorp.com
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RICHARDSON ADAMS, PLLC
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