20150702Clearwater 1-7 to AVU.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
zuCHARDSON ADAMS, PLLC
515 N.27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
gre g@richardsonandoleary. com
Attorneys for Clearwater Paper Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. AVU-E-15-05
APPLICATTON OF AVTSTA ) CASE NO. AVU-G-15-01
CORPORATION FOR THE AUTHORITY ) FIRST PRODUCTION REQUEST OF
TO INCREASE ITS RATES AND ) THE CLEARWATER PAPER
CHARGES FOR ELECTRIC AND ) CORPORATION
NATURAL GAS CUSTOMERS IN THE )
STATE OF IDAHO
Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), The Clearwater Paper Corporation (Clearwater) by and through their
attorney of record, Peter J. Richardson, hereby requests that Avista Corporation ("Company")
provide the following documents.
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 one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at:6070 Hill Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone] l; [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 a working electronic copy of Exhibit No. 13, Schedule 3 (the Electric
Cost-of-Service Study) with the formulas intact that is attached to Tara Knox's
testimony.
REOUEST FOR PRODUCTION NO. 2
Please provide all discovery responses along with the workpapers and attachments
provided to all other parties.
REOUEST FOR PRODUCTTON NO. 3
Please provide copies of all material provided to the PUC Staff regarding the Company's
application that were provided other than through formal discovery.
REOUEST FOR PRODUCTION NO. 4
On page l0 of Patrick Ehrbar's testimony he states "The spread of the proposed increase
generally results in the rates of return forthe various electric service schedules moving
approximately one-quarter closer to the overall rate of return (unity)." Please provide an
explanation along with any workpapers and spreadsheets about how the one-quarter moving
to unity was calculated.
REOUEST FOR PRODUCTION NO. 5
Please provide a working electronic copy of Exhibit No. 15, Schedule 3, pages I through
4 with the formulas intact that is attached to Patrick Ehrbar's testimony.
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
AUV-E-l 5-05; AVU-G- I 5-0 I
PAGE 2
REOUEST FOR PRODUCTION NO 6
According to the Multiparty Settlement Stipulation filed with the Washington Utilities
and Transportation Commission in Dockets No. UE-l50204 and UG-l50205
(consolidated) at page 2,5.b (i), in the original filing by Avista there was a coding error
contained in the AURORA model. Please confirm that the error was corrected in the
development of modeled energy prices in the Idaho rate case filing.
REOUEST FOR PRODUCTION NO. 7
The Multiparty Settlement Stipulation filed by Avista with the Washington Utilities and
Transportation Commission indicates the AURORA coding error along with others
agreed to adjustments has cut the Company's original request for a $33.2 million rate
increase in Washington in about half. This would mean the two year proposed increase
in Idaho is significantly higher than the stipulated Washington request. Please explain,
given [daho comprises only about one-third of the Company's total system, why the
Idaho proposed revenue requirement is so much higher than in Washington.
I
DATED thisf,\ay of July. 201 5
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
AUV-E- 1 5-05; AVU-G- I 5-01
PAGE 3
Clearwater Paper Corporation
CERTIFICATE OF SERVICE
I hereby ce,rtify that on JulySnd, 2Ol5,copies of the foregoing First Production Request
of the Clearwater Paper Corporation to Avista Corporation in Docket Nos. AVU-E-15-05 and
AVU-G-15-01 were mailed first class postage prepaid and electronically to:
David J. Meyer, Esq. Kelly Norwood
Vice President and Chief Vice-President - State and
Counsel Reg & Gov Affairs Federal Regulation Affairs
Avista Corporation Avista Corporation
1411 Mission Ave 1411 E. Mission Ave
Spokane, WA99220 Spokane, WA99220
[e-mail] [e-mail]
avi stadockets@ avistacorp. com
Community Action Pannership Snake River Alliance
Brad Purdy, Esq 223 N. 6h St., Ste. 317
2019 N. l7s St. PO Box 1731
Boise, lD 83702 Boise, tD 83702
[e-mail] [e-mail]
Idaho Forest Group Idaho Forest Group
Dean J. Miller Lany Crowley
McDevitt & Miller Energy Strategies Institute
PO Box 2564-83701 5549 South Cliffsedge Ave.
Boise, ID 83702 Boise, ID 83716
joe@,mcdevitt-miller.com [e-mail]
Jean Jewell
Idaho Public Utilities Commission
472W Washington
Boise, ID 83702
i ean j [e-mail]. eov
Nina Curtis
Administrative Assistant
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER
AUV-E- I 5-05; AVU-G- I 5-01
PAGE 4