20180620Clearwater 4 to Avista.pdf

Peter J. Richardson ISB # 3 195
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attorneys for Clearwater Paper Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
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IN THE MATTER OF THE
APPLICATION OF AVISTA
CORPORATION, dba AVISTA UTILITIES
REQUESTING AUTHORITY TO REVISE
ITS ELECTRIC AND NATURAL GAS
BOOK DEPRECIATION RATES
cAsE NO. AVU-E-18-03, AVU-G-18-02
SECOND PRODUCTION REQUEST
OF CLEARWATER PAPER
CORPORATION
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Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), Clearwater Paper Corporation (Clearwater) by and through their attorney of
record, Peter J. Richardson, hereby requests that Avista Utilities ("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, tdaho 83703, Tel:
[phone]; Fax: [phone]; [e-mail] and to Carol Haugen at
[e-mail] and Marv Lewallen at marv@,clearwatemaper.com.
I _SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
AVU-E-l 8-03, AVU-G-r 8-02
a
,
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. 4:
The Settlernent Agreement in the Avista/Hydro One merger docket (AVU-E-17-09)
provides, beginning at Paragraph 69, that the depreciation useful life of Colstrip Units 3 and 4,
subject to Commission approval, will terminate on December 31, 2027 .
A.) Does the accelerated depreciation of Colstrip also increase Avista's share of the
Asset Retirernent Obligations (ARO)? Please explain.
B) Does the accelerated depreciation of Colstrip also accelerate Avista's share of the
ARO? Please explain.
C) Please describe the impact of your responses above on the estimate of Idaho's annual
allocated portion of ARO?
D) What will be ldaho's annual share of accelerated depreciation for Colstrip Units 3
and 4 assuming a useful life through December 2027?
DATED this 20th day of June 2018.
AD
Peter ISB # 3195
Attorney for Clearwater Paper Corporation
2 .SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
AVU-E- I 8-03, AVU-G-l 8-02
CERTIFICATE OF SERVICE
I HERBY CERTIFY that on the 20th day of June 2018, a true and correct copy of the within and
foregoing SECOND PRODUCTION REQUEST of Clearwater Paper Corporation to Avista
Utilities in Case Nos. AVU-E-18-03, and AVU-G-18-02 were delivered via electronic mail to
the following:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
[e-mail]. gov
Brandon Karpen
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
brandon. kam en(@puc. idaho. gov
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
botto@idahoconservation. org
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise, Idaho 83701
ron@williamsbradbury. com
Patrick D. Ehrbar
Director of Regulatory Affairs
Avista Corporation
P.O. Box 3727
Spokane, WA 99220-3727
patrick. ehrbar@ avistacorp. com
avi stadockets@ avistacorp. com
David Meyer
Avista Corporation
P.O.Box3727
Spokane, WA 99220-3727
david.meyer@avi stacorp.com
Travis Ritchie
Sierra Club
2l0l Webster St, Suite 1300
Oakland, CA 94612
[e-mail]
Dean J. Miller
3620 E. Warm Springs Ave
Boise, Idaho 83716
deanjmill er@,cableone. net
Lany A. Crowley, Director
The Energy Strategies lnstitute, Inc.
crowleyla(Eaol.com
Walters
Administrative Assistant
3 -SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
AVU-E-l 8-03, AVU-G- r 8-02