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Home My WebLink About20120322Clearwater 1-10 to Avista.pdfPeter J. Richardson RECEiVED Gregory M. Adams Richardson & O'Leary, PLLC iAR 22 ?$ 15 515 N. 27' Street Ic pu 1W 10 P.O. Box 7218 UTUTS O Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter@richardsonandoleary.com greg(l)richardsonandolearv.com Attorneys for Clearwater Paper Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE COMMISSION'S ) REVIEW OF PURPA QF CONTRACT ) CASE NO. GNR-E-1 1-03 PROVISIONS INCLUDING THE ) SURROGATE AVOIDED RESOURCE ) FIRST PRODUCTION REQUEST OF PLANNING (IRP) METHODOLOGIES FOR ) CLEARWATER PAPER CALCULATING PUBLISHED AVOIDED ) CORPORATION TO AVISTA COST RATES ) Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), Clearwater Paper Corporation hereby requests that Avista (or the "Company") provide responses to the following with supporting documents, where applicable, as soon as possible, but no later than April 11, 2012. 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 one physical copy of your responses to the address above, and electronic copies, if available, to Mr. Richardson and Mr. Adams at the addresses noted above, and one copy to Dr. Reading at 6070 Hill Road, Boise, Idaho 83703. Please provide Dr. Reading's copy in electronic format, if available, to dreadingmindspring.com . Please begin each response on a separate page and provide page numbers on responses longer than one page. 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 a copy of the handout the Company provided at the meeting to present and discuss IRP Models at the Idaho Public Utilities Commission on December 15, 2011. Include all work papers, spreadsheets in electronic format with formulas intact, and model outputs used in producing the handout. REQUEST FOR PRODUCTION NO. 2: For each of the five QF configurations presented in Table 3 of Clint Kalich's Direct Testimony, please provide all work papers, spreadsheets in electronic format with formulas intact, and model outputs used in producing the values found in Table 3. For each of Company's gas-fired generation plants, please provide a list of the annual capacity factor, by year, beginning in 2013 through the end of the 20 year analysis period found in the model runs for each of the five QF configurations. REQUEST FOR PRODUCTION NO. 3: If the Company were to offer a Qualifying Facility (QF) with IRP Methodology contract pricing utilizing the methodology in effect on the date of this request, please state if the assumptions in the calculation would be consistent with the assumptions included in the 2011 IRP filed with the Idaho Public Utilities Commission on August 25, 2011 (AVU-E- 11-04). Please provide the following inputs that would be used in calculating IRP Methodology rates and indicate if the inputs are consistent with the 2011 IRP: (a)Natural gas fuel forecast, (b)Firm load forecast, (c)Resource stack, and (d)Forecast of the year and month of first future peak load deficit. Page 2— FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION TO AVISTA - GNR-E-1 1-03 REQUEST FOR PRODUCTION NO. 4: Reference the Company's Preferred Resource Strategy set forth in the 2011 IRP (Table 1, p. viii), including plans to acquire an 83 MW SCCT in 2018. Please provide the prices the Company would offer a QF that would provide power in the same configuration as the SCCT. In other words, please run the projected output of the 83 MW SCCT through the Company's IRP Methodology as though it were a QF requesting contract pricing. REQUEST FOR PRODUCTION NO. 5: Reference the Company's Preferred Resource Strategy set forth in the 2011 IRP (Table 1, p. viii), including plans to acquire an 83 MW SCCT in 2018. Please provide the assumptions regarding expiring contracts in developing this resource portfolio. Did the Company include the Clearwater Paper QF in its resource portfolio past the time of expiration of the existing contract in 2013? Please explain the impact on Avista's future resource needs under the assumption the Clearwater Paper QF is not available to Avista after expiration of the contract in 2013. REQUEST FOR PRODUCTION NO. 6: According to the Commission's accepted "IRP Methodology' (IPUC Order No. 26576, IPC-E- 95-9) and IPUC Staff Witness Rick Sterling's direct testimony Exhibit 101, "the avoided cost of the QF project is the difference in the present value of the revenue requirements (PVRR) between the base case resource plan and a modified resource plan that includes the QF resource." (Exhibit 101, IPC-E-95-9, R. Sterling, page 14.) Please explain in detail how the Company incorporates the "revenue requirement" as it would in filing for a certificate of public convenience and necessity (i.e. return of and on investment, all taxes, etc.) in the calculation of rates offered to QFs. REQUEST FOR PRODUCTION NO. 7: Reference the Direct Testimony of Clint Kalich, p. 9, stating, "For example, canal hydro operates during the spring and summer months, with no output during the winter. Avista's wind rating is low due to the lack of wind diversity in its portfolio." Please list the wind projects that are in Avista's portfolio and indicate the location, MW nameplate, expected energy output, the date the contract was signed, and the on-line date of each. REQUEST FOR PRODUCTION NO. 8: For each of the five QF configurations presented in Table 4 on page 25 of Clint Kalich's Direct Testimony, please provide all work papers, spreadsheets in electronic format with formulas intact, and model outputs used in producing the values found in lines 8, 9, and 10. In the column titled "Note." please explain fully the source of the noted SAR lines 2, 6, 7, 8, 9, and 10. REQUEST FOR PRODUCTION NO. 9: Page 3— FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION TO AVISTA - GNR-E-1 1-03 Reference the Direct Testimony of Clint Kalich, pp. 13-14, stating: It is often true that utilities are surplus in early years; being so is an essential part of providing reliable utility service. It also is true that QF developers would be affected by these surpluses were they to receive lower early-year payments during surplus years. But this effect is a reflection of true avoided costs. It is not reasonable to hold a utility system short both of capacity and reliability simply to promote QF development. Given the "lumpiness" of utility generation investment, please explain in detail how a QF development would ever, over time, receive compensation equal to what it costs a utility to build a resource if it is denied capacity payments during surplus periods. REQUEST FOR PRODUCTION NO. 10: Assume that an existing QF requested IRP Methodology pricing for the time frame after expiration of its existing contract. Please describe how Avista would treat the expiring contract in the IRP Methodology rate calculations. Would Avista include the output from the existing QF contract in its assumed base case resource plan past the date of expiration of the contract? Please explain the basis for the treatment of the expiring contract. DATED: March 22, 2012 Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY PLLC Page 4— FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION TO AVISTA - GNR-E-1 1-03 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 22nd day of March, 2012, a true and correct copy of the within and foregoing FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION TO AVISTA CORPPORATION was served as shown to: Jean D Jewell, Secretary L Hand Delivery Idaho Public Utilities Commission _U S Mail, postage pre-paid 472 West Washington - Facsimile Boise, Idaho 83702 X . Electronic Mail jean.iewell(puc.idaho.gov Donald Howell X Hand Delivery Kris Sasser U S Mail, postage pre-paid Idaho Public Utilities Commission - Facsimile 472 West Washington X Electronic Mail Boise, Idaho 83702 donald.howell(puc.idaho.gov krisme sasser@puc idaho gov Donovan E. Walker - Hand Delivery Lisa D. 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