20230425Clearwater Errata Replacement to 1st PR.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,ldaho 83702
Telephone: [phone]
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 AUTHORITY
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. AVU-E-23-01
ERRATA REPLACEMENT TO 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 attorney 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.
ERRATA REPLACEME,NT TO FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
CORPORATION
IN CASE NO. AVU-E,-23-OI PAGE I
RECEIVED
Tuesday, April 25, 2023 10:21:33 AM
IDAHO PUBLIC
UTILITIES COMMISSION
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- l5 1 1; [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.
REOUEST 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.
REOIIEST F'OR P ODUCTION NO.2
Please provide copies of all communications between Avista and the ldaho Public Utilities
Commission and/or its Staff regarding Avista'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
REQUEST 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 1A9%
RBQUEST FOR PRODUCTION NO. 5:
Pleasea confirm as accurate that in Avista's last Idaho jurisdiction general rate case, (AVU-E-21-
0l) Avista's proposed rates, as originally filed, would have resulted in Clearwater's Rate of Return
ratio of 1.53%. However, the parties settled that case and agreed to the following Stipulation that
was approve by the Commission;
ERRATA REPLACEMENT TO FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
CORPORATION
IN CASE NO. AVU-E-23-OI PAGE 2
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 l,202land September 1,2022 base rate
increases. In addition, Schedules lll12 should receive 25o/o of the overall percentage base
rate change for the September 1,2022 increase. ISTIPULATION AND SETTLEMENT -
AVU.E-21-01, Page 191
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
REOUEST 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 filing to Residential Service
Schedule l, Large General Service Schedules 21122, and Pumping Service Schedules
31132. The remaining revenue should then be applied equally to Schedules lll12, 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. [Miller, 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
REOUEST 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 retum (unity).
[Miller, 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
ERRATA RE,PLACE,MENT TO FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
CORPORATION
IN CASE NO. AVU-E-23-01 PAGE 3
how a "uniform percent of revenue" rate spread moves the "various electric service schedules
closer to ... (unity)."
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.
[Miller, 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 thth day of April2023
Peter J.ISB # 31
RTCHARDSON ADAMS, PLLC
ERRATA REPLACEMENT TO FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
CORPORATION
IN CASE NO. AVU-E-23-OI PAGE 4
I HEREBY CERTIFY that on the 25th day of April2023,a true and correct copy of the
within and foregoing ERRATA REPLACEMENT TO FIRST PRODUCTION REQUEST of the
Clearwater Paper Corporation in Case No. AVU-E -23-01was served, by electronic copy only,
to:
David J. Meyer, Esq
Avista Corporation
david.stacorp.com
Patrick D. Ehrbar
Avista Utilities
patrick. ehrb ar@ avi stacorp. com
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
j an.nori)'uki@puc. idaho. gov
Commission Secretary
Idaho Public Utilities Commission
secr etary @,puc. idaho. sov
Idaho Forest Group, LLC
Andrew P. Moratzka
andrew.moratzka@ stoel. com
Idaho Forest Group
Larry A. Crowley
[e-mail]
Idaho Forest Group
Bradley R. Mullins
[e-mail]
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@idahosonservation. org
ERRATA REPLACEMENT TO FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
CORPORATION
IN CASE NO. AVU-E-23-OI PAGE 5
Idaho Conservation League
Brad Heusinkveld
bheusinkveld@ idahoconservation. org
Idaho Conservation League
F. Diego Rivas
[e-mail]
Peter
rsB # 319s
ERRATA REPLACEMENT TO FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
CORPORATION
IN CASE NO. AVU-E.23-OI PAGE 6