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Home My WebLink About20110808Clearwater 1-7 to AVU.pdfPeter J. Richadson (ISB No. 3195) Gregory M. Adams (ISB No. 7454) Richardson & O'Lear, PLLC 515 N. 2ih Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~richadsonandolear.con1 greg~chardsonadolear.con1 RECEIVED 2011 AUG -8 PM~: l 7 Attorneys for Clearater 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 NATUR GAS CUSTOMERS IN THE )STATE OF IDAHO ) ) CASE NO. AVU-E-II-01 CASE NO. AVU-G-l1-0l CLEARWATER PAPER CORPORATION'S FIRST REQUESTS FOR PRODUCTION Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilties Commission (the "Commission"), the Clearater Paper Corporation hereby requests that Avista Corporation provide responses to the followig with supporting documents, where applicable. The response to ths production request is due no later than August 29, 2011. This production request is to be considered as continuing, and Avista is requested to provide by way of supplementar responses additional documents that it or any person acting on its behalf may later obtan that will augment the responses or documents produced. Please provide electronic copies, or if unavailable a physical copy, to Mr. Richardson and Mr. Adas at the address noted above, and to Dr. Don Reading at: 6070 Hil Road, Boise, Idao 83703, Tel: (208) 342-1700; Fax: (208) 384-1511; drading~n1indspring.con1. For each item, please indicate the name of the person(s) preparng the answers, along with the job title of such person(s) and the witness at hearing who can sponsor the answer. Some of the following requests may include disclosures deemed by Avista to be confidentiaL. Counsel and the expert witness for the Clearater Paper Corpration are willng to execute any reasonable protective agreement necessar to obta and use such materials according the terms of that agreement. FIRST REQUESTS FOR PRODUCTION OF CLEARWATER PAPER CORPORA nON PAGE 2 REQUEST FOR PRODUCTION NO.1 On page 10 of Patrck Ehrbar's Direct Testimony he states: Upon evaluation of the cost of service results, it was determined that an across the board uniform percentage movement towards unity (e.g., a 50% movement) would cause some schedules to receive a rate decrease, while others would receive an increase twce as large as the overall request. Please provide an electronic copy, with all formula and lins intact, of the cost of servce study referenced above. Please include, also in electronic format where possible, all work papers and other documents used in the development of the cost of service study. REQUEST FOR PRODUCTION NO.2 On page 10 of Patrick Ehrbar's Direct Testimony he states: Application of a unorm percentage across rate Schedules results in a slight movement toward unty for Schedules 1, 11/12,21/22, and 25, and small movement away from unty for the other schedules, none of which r would consider material. In Table 5, on page 11 of Patrck Ehrbar's Direct Testimony indicates Clearater Paper Schedule 25P is the only customer class with a rate of retu at present rates over 1.00 that shows an increae in the rate of retu with the Company's proposed rate increase. Please explai fuly why the Company considers ths not material especially given the fact it is proposing Clearater's rates increase by more than $1.5 milion. REQUEST FOR PRODUCTION NO.3 The Company is adding the following taff languge to the 25P taiff: The anua minimum will also be prorated if base rates change during the 12-month period. The anual minimum is based on 916,667 kWh's per month (11,000,000 kWh's anualy), plus twelve months multiplied by the monthy minimum demand charge for the fist 3,000 kVa of demand. The anual minimum reflected above is based on base revenues only. Any other revenues paid by customers in their biled rates (such as the DSM Tarff Rider Schedule 91) do not factor in to the anual minimum calculation. Please provide a numerical example of a base rate change durng a 12-month perod tht would impact Clearater Paper's bils in the prorated maner suggested in the added languge to the 25P taff. REQUEST FOR PRODUCTION NO.4 Avista's filing proposes that Schedule 25P's over all biled rates should increase is 3.3%. Please FIRST REQUESTS FOR PRODUCTION OF CLEARWATER PAPER CORPORATION PAGE 3 explain fuly why the Company is proposing the ::3,000 kVa rate increase by 4.2% from $12,000 to $12,500; and the ..3,000 kVa rate is increasing by 12.4% - from $4.00 to $4.50 - that is nearly four times the overall increase, while the other rate elements are less than the overal increase. REQUEST FOR PRODUCTION NO.5 On pages 18 and 19 of Clint Kalich's Direct Testimony he states: The Company modeled Clearater Paper's generation and loads in line with our contracts. Clearater's entire load is included in the proforma. Its generation is included as a portolio resource. Generation is represented as 2010 actuals. Please provide Clearwater Paper's the loads and generation used in ths filing along with any supporting documents and work papers. REQUEST FOR PRODUCTION NO.6 Pleas provide an electronic copy, with all. formula and lins intact supporting Exhibit 12 attachéd to Tara Knox's DirectTestmony. Please include, also ineleetonic formatwhere possible, all work paper and other documents used in the development of Exhbit 12. REQUEST FOR PRODUCTION NO.7 Reference the Settlement Stipulation approved in A VU-E-1O-01, at' 8. Has Avistaincluded all fixed costs for the Lancaster Plant in base rates in this filing? Please explain where in the curent filing the fixed costs for the Lancaster Plant appear. Please explain why the Company has requested recovery of $3.15 milion in "Lancaster Fixed Costs" in the power cost adjustment in AVU-E-1I-03. Reference Johnson, DI, p. 3, AVU-E-11-03. Please explain how it is appropriate to request recovery of fixed costs in both cases. Than you for your prompt attention to ths First Requests for Production. Sincerely yours,rßPeter J. Richar on RICHARDSON & O'LEARY, PLLC FIRST REQUESTS FOR PRODUCTION OF CLEARWATER PAPER CORPORA nON PAGE 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 13th day of July, 2011, a tre and correct copy of the within and foregoing CLEARWATER PAPER CORPORATION's FIRST REQUESTS FOR PRODUCTION was served as shown to: Jean D. Jewell, Secretar Idaho Public Utilties Commission 472 West Washington Boise, Idaho 83702 jean. jewellCWpuc.idaho.gov X Hand Delivery __U.S. Mail, postage pre-paid Facsimile Electronic Mail Donald Howell Krs Sasser Idaho Public Utilties Commission 472 West Washington Boise, Idaho 83702 donald.howellCiuc.idaho.goY krsine.sasserCiuc.idaho.gov 1L Hand Delivery __U.S. Mail, postage pre-paid Facsimile Electronic Mail Patrck Ehrbar Manager, Rates & Tariffs A vista Corporation P.O. Box 3727 Spokane, W A 99220 _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile -- Electronic Mail Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise, ID 83702 bmpurdYCWhotmail.com _ Hand Delivery -lU.S. Mail, postage pre-paid Facsimile -- Electronic Mail Dean J. Miler McDevitt & Miler, LLP 420 W. Banock St. Boise, ID 83702 joeWJcdevitt-miler.com _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile X Electronic Mail FIRST REQUESTS FOR PRODUCTION OF CLEARWATER PAPER CORPORATION PAGE 5 Scott Atkison Idaho Forest Products 171 Highway 95 Nort Grangevile, ID 83530 scottidaoforestgroup.com ~ Hand Delivery J u.s. Mail, postage pre-paid Facsimile Electronic Mail fl.~Peter J. FUchardson FIRST REQUESTS FOR PRODUCTION OF CLEARWATER PAPER CORPORATION PAGE 6