20150305Clearwater 1-11 to AVU.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27th Street
Boise,Idatro 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
gre [e-mail]
Attorneys for the Clearwater Paper Corporation
?[:! t'iiR -5 fitl lii, 53
BEFORE THE
IDAHO PUBLIC UTILTTIES COMMISSTON
TN THE MATTER THE APPLICATION OF )
AVISTA CORPORATION FOR A PETITION ) CESP NO. AVU.E.I5.OI
TO MODIFY TERMS AND CONDITTONS OF )
PR9SPECTIVE PURPA AGREEMENTS I TNST PRODUCTION REQUESTS OF1 THE CLEARWATER PAPERI conpoRATIoN
)
)
Pursuant to Rule 225 of the Rules of Procedure of the ldatro Public Utilities Commission
(the "IPUC" or "Commission"), the Clearwater Paper Corporation ("Clearwater") by and
through its attorneys of record, Gregory M. Adams and Peter J. Richardson, hereby requests that
Avista Corporation ("Avista" or the "Company") provide responses to the following requests for
production.
This production request is to be considered as 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 one physical copy and electronic-mail copies of the responses to Mr.
Richardson and Mr. Adams at the addresses noted above. Please provide an additional
CLEARWATER PAPER CORPORATION'S FIRST PRODUCTION REQUEST
AVU-E-15-01
PAGE I
electronic copy, or if unavailable a physical copy, to Dr. Don Reading at:6070 Hill Road, Boise,
Idatro 83703, Tel: [phone];Fax: [phone]; [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 who can sponsor the answer at an evidentiary
hearing.
If some of the following requests include disclosures reasonably deemed by Avista to be
confidential, Clearwater will enter into Avista's standard confidentiality agreement.
REOUEST FOR PRODUCTION NO. 1
Reference the direct testimony of Clint Kalich at page 2:22to3:2 and the Company's Petition at
Prayer for Relief No. l. [s it Avista's intent to limit all PURPA contracts to a five year term or
only " 'IRP Methodology' wind and solar PURPA contracts"?
REOUEST FOR PRODUCTION NO. 2
Reference the direct testimony of Clint Kalich page 3:2 - 3:4 stating, "A term beyond five (5)
years should be an option for the utility in the event a very favorable PURPA opportunity
arises." Please describe the circumstances under which Avista would consider a longer PUPRA
contract.
REOUEST FOR PRODUCTION NO. 3
Please provide copies of all material provided to the Commission Staffregarding the Company's
application that were provided other than through formal discovery, both prior to, and after, the
filing of the Application.
REOUEST FOR PRODUCTION NO.4
Please provide all of the Company's discovery responses to all other parties and any future
discovery responses the Company will provide in this docket.
CLEARWATER PAPER CORPORATION'S FTRST PRODUCTION REQUEST
AVU-E-15-01
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REOUEST FOR PRODUCTION NO. 5
Has the Company investigated the impacts of Avista joining the PacifiCorp-California ISO
energy imbalance market as a potential way to reduce costs associated with intermittent
generation or for any other reasons? If not, why not? Please provide all studies or analyses of the
impacts of Avista joining the PacifiCorp-California ISO energy imbalance market.
REOUEST FOR PRODUCTION NO. 6
Please provide a list of all existing currently operating PURPA projects selling their output to
Avista pursuant to rates set by the ldaho Commission. For each provide the MW rating, on-line
date and year the contract expires.
REOUEST FOR PRODUCTION NO. 7
Please provide a list (confidential information redacted) of all PURPA projects that have
requested a PURPA contract and completed the procedures found in Tariff Schedule 62(1)Ai-
xiv. Include the MW rating, proposed on line date and proposed fuel source.
REOUEST FOR PRODUCTION NO. 8
Please provide a list (confidential information redacted) of all proposed PURPA projects that the
Company has rejected pursuant to Schedule 62(D). Include the MW rating, proposed on line
date and proposed fuel source.
REOUEST FOR PRODUCTION NO. 9
At page 3 lines 15 - 18 of Mr. Kalich's Direct Testimony he states, "Developers have
consistently favored Idaho Power, the utility with the highest calculated avoided cost rates for
PURPA projects ("QFs") that qualit/ for such rates." And at page 4,lines 15 - 18, "Again, this
decision demonstrated rational economic behavior because, while Avista's long-term rates were
much lower than ldaho Power's, Avista's short-term rates were similar to Idaho Power's short-
term rates." Please provide documentation to support these statements. Please provide, by the
fuel type of the QFs the avoided cost offered by ldaho Power and Avista for comparable contract
lengths, both long-term and short-term.
REOUEST FOR PRODUCTION NO. 10
At page 3 of the Petition Avista states, ooThus, as a direct result of the Commission's action
affording one utility interim relief, Avista could be required to enter into a significant number of
PURPA contracts." Has the Company been contacted by any PURPA developers seeking
contracts since the Idaho Public Utilities Commission issued Order No. 33222? If so please
indicate the fuel type, MW size and geographic location of the project.
CLEARWATER PAPER CORPORATION'S FIRST PRODUCTION REQUEST
AVU-E-15-01
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REOUEST FOR PRODUCTION NO. 11
At pages 2 and 3 of the Petition Avista states,'oThe Commission further found that 'there is
sufficient evidence that the predicted influx of high-capacity PURPA contracts could
significantly and detrimentally impact customer rates and system reliability before this matter is
fully resolved' and, therefore, 'action pending resolution of this matter is waranted.' " The
Commission statement was in reference to Idatro Power. Does Avista consider its own situation
equivalent to that of Idaho? Please explain fully why or why not.
try
DATED this / day of March, 2015.
RICHARDSON ADAMS, PLLC
,,,-i-*)L)';r-;
Peter Richardson
Of Attorneys for the Clearwater Paper
Corporation
CLEARWATER PAPER CORPORATION'S FTRST PRODUCTION REQUEST
AVU-E-15-01
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3'd day of March,z}ls,a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
CORPORATION was served by prepaid U.S. Mail and electronic mail to the following
individuals:
Michael G. Andrea
Senior Counsel
Avista Corporation
l41l East Mission Ave. MSC-23
Spokane Washington 99202
Michael. andrea@ avistacorp. com
Clint Kalich
Manager, Resource Planning & Analysis
Avista Corporation
1411 East Mission Ave. MSC-7
Spokane, WA99202
Clint.kalich@avi stacorp. com
Linda Gervais
Manager, Regulatory Policy
141I East Mission Ave. MSC-27
Spokane, WA99202
Linda. gervais@avistacom. com
|.lrp n /\n cu P.\15
CLEARWATER PAPER CORPORATION'S FIRST PRODUCTION REQUEST
AVU-E-15-01
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