20230424Clearwater 1-8 to AVU.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,ldaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
Attorneys for Clearwater Paper Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF AVISTA )
CORPORATION FOR THE AUTHORTTY )
TO INCREASE ITS RATES AND )
CHARGES FOR ELECTRIC AND )
NATURAL GAS SERVICE TO ELECTRIC )
AND NATURAL GAS CUSTOMERS IN )
THE STATE OF IDAHO )
CASE NO. IPC-E-23-OI
FIRST PRODUCTION REQUEST OF
CLEARWATER PAPER
CORPORATION
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), Clearwater Paper Corporation by and through its attomey of record, Peter J.
Richardson, hereby requests that Avista Corporation ("Avista" or the "Company") 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: 280 S Silverwood Way, Eagle, Idaho 83616, Tel: [phone]; Fax: (208)
384- I 5 I 1 ; [e-mail].
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-23-01 PAGE I
RECEIVED
Monday, April 24, 2023 3:34:38 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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.
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 in this matter.
REQUEST FOR PRODUCTION NO. 2
Please provide copies of all communications between Avista and the Idaho Public Utilities
Commission and/or its Staff regarding Idaho Power's Application in this matter
REOUEST FOR PRODUCTION NO.3
Please provide copies of all responses to production requests (both formal and informal)
provided to any other party to this proceeding
REOUEST FOR PRODUCTION NO. 4:
Please confirm that the rates Avista proposes in this case will (if approved as filed) result in
Clearwater's Rate of Return ratio of 1 .49o/o
REOUEST FOR PRODUCTION NO. 5:
Pleasea confirm as accurate that in Avista's last ldaho jurisdiction general rate case, (AVU-E-21-
0t) Avista's proposed rates, as originally filed, would have resulted in Clearwater's Rate of
Retum ratio of 1.53%. However, the parties settled that case and agreed to the following
Stipulation that was approve by the Commission;
In recognition, however, that certain rate schedules are generally above their relative cost
of service, the Parties agree that Schedule 25P should receive 25o/o of the overall
percentage base rate changes for the September 1,2021and September 1, 2022 base rute
increases. In addition, Schedules I l/12 should receive 25Yo of the overall percentage base
rate change for the September 1,2022 increase. ISTIPULATION AND SETTLEMENT -
AVU.E-21-01, Page l9l
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO, AVTJ-E-23-OI PAGE 2
Did the Company consider making or offering a similar adjustment to its proposed rates for
Clearwater, or any other customer class, in this general rate case? Please explain why or why not
RR,OTIR,ST FOR PRODUCTION NO. 6:
In the Direct testimony of Company witness Joseph Miller he states onpage 7;
If the Commission were to order a lower revenue requirement than filed for, the
Company proposes to allocate the same increase as the Company's initial hling to
Residential Service Schedule 1, Large General Service Schedules 21122, and Pumping
Service Schedules 31132. The remaining revenue should then be applied equally to
Schedules 1ll12, Schedule 25, Schedule 25P and the Street and Area Lights Schedules as
those schedules are providing significantly more than their relative cost of service as
discussed by Mr. Garbarino. fMiller, Di, p. 7.]
Has the Company done any analysis (sensitivity or otherwise) estimating the impact and rate
design assuming the Commission would decrease the proposed revenue requirement of any given
percentage? Ifso please provide.
REQUEST FOR PRODUCTION NO. 7:
In the Direct testimony of Company witness Joseph Miller he states on page 6;
However, given the relative size of the proposed base revenue increase, Avista is
proposing to spread the revenue increase on a uniform percent ofrevenue basis at the
proposed levels. The spread of the proposed increase still results in the rates of return for
the various electric service schedules moving closer to the overall rate of return (unity).
fMiller, Di, p. 6.]
Please explain why the relative size of the proposed rate increase would support use of a uniform
percent rate increase in class rates schedules rather than lower rate increases for those with that
"are providing significantly more than their relative cost of service. . . ." Please also explain
how a "uniform percent of revenue" rate spread moves the "various electric service schedules
closer to ... (unity)"
FIRST PRODUCTION REQUEST OF CLEARWATER PAPE,R CORPORATION
IN CASE NO. AVU-E-23-OI PAGE 3
REOUEST FOR PRODUCTION NO. 8:
In the Direct testimony of Company witness Joseph Miller he states on page 6;
The Company may propose additional movement toward unity in future proceedings.
fMiller, Di, p. 6.]
Please explain why the Company is delaying a more significant rate spread in moving all
customer classes to rate of return ratios closer to their cost of service.
Dated this 24thth day of April2023
J ISB # 3195
RICHARDSON ADAMS, PLLC
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-23-OI PAGE 4
I HEREBY CERTIFY that on the24th day of April2023, a true and correct copy of the within
and foregoing FIRST PRODUCTION REQUEST of the Clearwater Paper Corporation in Case
No. AVU-E-23-0I was served, by electronic copy only, to:
David J. Meyer, Esq.
Avista Corporation
david. Meyer@avistacorp. com
Patrick D. Ehrbar
Avista Utilities
patrick. [e-mail]
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
j an.noriyuki@puc. idaho. gov
Commission Secretary
Idaho Public Utilities Commission
secretary@puc. idaho. gov
Idaho Forest Group, LLC
Andrew P. Moratzka
andrew.moratzka@stoel. com
Idaho Forest Group
Larry A. Crowley
crowleyla@.aol.com
Idaho Forest Group
Bradley R. Mullins
brmullins@mnanal)'tics. com
Walmart, Inc.
Justina A. Caviglia
j cavi glia@parsonsbehle. com
Walmart, Inc.
Steve W. Chriss
stephen. chriss@walmart. com
Idaho Conservation League
Marie Callaway Kellner
mkellner@idahoconservation. org
Idaho Conservation League
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-23-OI PAGE 5
Brad Heusinkveld
bheusinkveld@idahoconservation. org
Idaho Conservation League
F. Diego Rivas
Peter
ISB # 3l9s
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-E-23-OI PAGE 6