20150326Staff 1-7 to Clearwater.pdf

DONALD L. HOWELL, II
DAPHNE HUANG
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-03 12t33 4-03 | 8
IDAHO BAR NOS ,336618370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
coMPANy'S PETITION TO MODTFY ) CASE NO. rpC-E-15-01
TERMS AND CONDITIONS OF PURPA )
PURCHASE AGREEMENTS
IN THE MATTER OF AVISTA )
CORPORATTON'S PETITION TO MODIFY ) CASE NO. AVU-E-15-01
TERMS AND CONDITIONS OF PURPA )
PURCHASE AGREEMENTS
)
)
)
)
IN THE MATTER OF ROCKY MOUNTAIN )
POWER COMPANY'S PETITION TO ) CASE NO. PAC-E-15-03
MODIFY TERMS AND CONDITIONS OF )
PURPA PURCHASE AGREEMENTS ) FIRST PRODUCTION REQUEST
) oF THE COMMISSION STAFF TO
) CLEARWATER PAPER
) CORPORATTON
The Staff of the Idaho Public Utilities Commission, by and through its attomeys of
record, Donald L. Howell and Daphne Huang, Deputy Attomeys General, request that
Clearwater Paper Corporation (Clearwater) provide the following documents and information as
soon as possible, by THURSDAY, APRIL 9,2015.r
I Staffis asking for an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO CLEARWATER PAPER 1 MARCH 26,2015
This Production Request is continuing, and the Company 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 documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please explain why Clearwater has never negotiated a2}-year term
for any of its prior PURPA contracts with Avista.
REQUEST NO.2: Has Clearwater ever signed a2}-year fixed price contract for any of
the following for any of its facilities in the U.S.:
a. purchase of electricity;
b. sale of electricity;
c. purchase of natural gas or other non-electric fuels; and
d. purchase of any raw materials used for production, supplies, labor, or transportation.
If the answer to any of the above is o'yes," please describe the general terms of the
contracts.
REQUEST NO. 3: Please describe how Clearwater finances the construction of new
plants or major plant expansions. Specifically discuss whether a contractual 20-year fixed
revenue stream is necessary in order to secure outside financing for major capital projects.
R-EQUEST NO. 4: Does Clearwater have 2}-year contracts at fixed prices for purchase
by customers of any of its products? If not, please explain why Clearwater believes it should be
entitled to 20-year contracts at fixed prices for its PURPA generation.
FIRST PRODUCTION REQUEST
TO CLEARWATER PAPER MARCH 26,2015
REQUEST NO. 5: As a retail customer of Avista, does Clearwater believe retail rates
should increase as a result of the utility signing PURPA contracts instead of generating the
power itself or obtaining it from another source?
REQUEST NO. 6: Please describe in detail each "Qualifying Facility" (QF) or electric
generating unit operating at Clearwater's Lewiston facility including the following information:
a. type of QF;
b. type of fuel used;
c. nameplate output in megawatts (MW);
d. year constructed;
e. date(s) obtained initial and any subsequent certification as a QF; and
f. the amount of energy generated that is either self-generated for Clearwater's own use,
or sold to Avista Corporation under the "Electric Service Agreement" with an "Execution
Date" of April 77,2013, with an "Effective Date" of July 1,2013.
REQUEST NO. 7: Has Clearwater issued any notice or received any notice regarding
the termination of the Electric Service Agreement with the "Execution Date" of April 1I,2013,
pursuant to Section 2 ("Term of Agreement") on page2 of 6?
n rlfb
Dated at Boise, Idaho, this /b taay of March 2015.
Technical Staff: Rick Sterling
Yao Yin
i:umisc:prodreq/ipcel5.l_avuel5.llacel5.3dhdjhrpsyy prod reql clearwater
FIRST PRODUCTION REQUEST
TO CLEARWATER PAPER
Daphne Hfang
Deputy Attorney General
MARCH 26,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY oF MARCH 2015,
SERVED THE FOREGOING FIRST PRODUCTION RE,QUEST OF THE
COMMISSION STAFF TO CLEARWATER PAPER CORPORATION, IN CASE
NOS. IPC-E-Is-OI/PAC-E-I5.03/AVU-E-I5-01, BY MAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail : [e-mail]
dockets@ idahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail : [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK ST
BOISE TD 83702
E-mail : [e-mail]
KELSEY JAE NUNEZ
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 8370I
E-mail: [e-mail]
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTATN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-mail : ted.weston@pacifi corp.com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE TD 83702
E-mail: [e-mail]
gre g@richardsonadams. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE TD 83702
E-mail: [e-mail]
LEIF ELGETHUN
INTERMOLINTAIN ENERGY PARTNERS
LLC
PO BOX 73s4
BOISE ID 83707
E-mail : [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
E.MAIL ONLY:
kmi ller@ snakeriveralliance. org
DANIEL E SOLANDER
YVONNE R HOGLE
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 24OO
SALT LAKE CITY UT 841I1
E-mail: [e-mail]
yvonne.hoele@pacifi corp. com
CERTIFICATE OF SERVICE
DATA REQUEST RESPONSE CENTER C TOM ARKOOSH
E-MAIL ONLY: ARKOOSH LAW [e-mail] PO BOX 2900
BOISE ID 8370I
E-mail : [e-mail]
ERIN CECIL ERIC L OLSEN
ARKOOSH LAW OFFICES RACINE OLSON NYE BUDGE
E-MAIL ONLY & [e-mail] PO BOX l39l
POCATELLO ID 83204-1391
E-mail: [e-mail]
ANTHONY YANKEL RONALD L WILLIAMS
29814 LAKE ROAD WILLIAMS BRADBURY PC
BAY VILLAGE OH 44104 1015 W HAYS ST
E-mail: [e-mail] BOISE ID 83702
E-mail: [e-mail]
IRION SANGER MICHAEL G ANDREA
SANGER LAW PC AVISTA CORPORATION
1117 SW 53RD AVE 1411 E MISSION AVE
PORTLAND OR 972T5 MSC-23
E-mail: [e-mail] SPOKANE WA99202
E-mail : [e-mail]
CLINT KALICH MATT VESPA
AVISTA CORPORATION SIERRA CLUB
I4I I E MISSION AVE 85 SECOND ST 2ND FLOORMSC-23 SAN FRANCISCO CA 94105
SPOKANE WA99202 E-mail: [e-mail]
E-mail : clint.kal [e-mail]
RICHARD MALMGREN FREDERICK J SCHMIDT
SR ASSIST GEN COUNSEL PAMELA S HOWLAND
MICRON TECHNOLOGY INC HOLLAND & HART LLP
8OO S FEDERAL WAY 377 S NEVADA ST
BOISE ID 83716 CARSON CITY NV 89703
E-mail: [e-mail] E-mail: [e-mail]
CERTIFICATE OF SERVICE
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO
I951 S SATURN WAY
STE 1OO
BOISE ID 83702
E-mail : [e-mail]
CAROL HAUGEN
CLEARWATER PAPER CORPORATION
E-MAIL ONLY
Carol. hau gen@clearwaterpaper. com
ANDREW JACKURA
SR VP NORTH AMERICA DEVL
CAMCO CLEAN ENERGY
9360 STATION ST STE 375
LONE TREE CO 80124
E-mail: [e-mail]
CERTIFICATE OF SERVICE