20181029Clearwater 4-6 to Avista.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N.271h Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attorneys for Clearwater Paper Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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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 Idaho 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, Idaho 83703, Tel:
[phone]; Fax: [phone]; [e-mail] and to Carol Haugen at
carol.hau gen@clearwaterpaper. com and Marv Lewallen at marv@lewallen. com.
I SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
AVU-E- I 8-03, AVU-G- I 8-02
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 Settlement Agreement in the Avista/Hydro One merger docket (AVU-E-l7-09)
provides, beginning atParagraphT2 that the depreciation useful life of Colstrip Units 3 and 4,
subject to Commission approval, will terminate on Decernber 31, 2027.
A.) Does the accelerated depreciation of Colstrip also increase Avista's share of the
Asset Retirement 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 ldaho's annual
allocated portion of ARO?
D) What will be Idaho's annual share of accelerated depreciation for Colstrip Units 3
and 4 assuming a useful life through December 2027?
REQUEST FOR PRODUCTION NO. 5:
Avista's Application in this Docket states, "Consistent with Order No. 29962 in Case Nos.
AVU-E-05-09 and AVU-G-}5-03 (consolidated), Avista shall recover costs associated with asset
retirement obligations ("AROs") through depreciation expense based on Commission-approved
depreciation rates. " fApplication, AVU-18-03, p. 8.]
2 -SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
AVU-E-l 8-03, AVU-G- I 8-02
In Response to Clearwater's First Request for Production, PR02, the Company provided a
Workpaper spreadsheet titled; 'Clearw'ater PR02 - Attachment 9 Workpapers - Depreciation
Study Summary - Attachment A, B I -2, and Summary WPs. On tabs, 'Att B I l23l l6 Depr_Chg-
ex trans', and'Wkpr-stdy Bal (ex. Trnsptn)'in column L Row 38 is the value Soh,that is the
'Proposed Study Rate' for Colstrip Units 3 & 4 ARO [3 I 7. I Asset Retirement Obligation].
A.) Please provide all documents, reports, studies, electronic copies of the workpapers
and spreadsheets used in support of the 5olo Proposed Study Rate.
B) Has the Commission approved the 5% ARO Proposed Study Rate in any past
depreciation Dockets? If so please provide the Case Number and the Commission's Final Order
Number in the Docket.
REOUEST FOR PRODUCTION NO. 6:
Avista's 2017 l0-K states,
"ln addition to an increase to our ARO, it is expected that there will be significant
compliance costs at Colstrip in the future, both operating and capital costs, due to
a series of incremental infrastructure improvements which are separate from the
ARO. LVe cannot reasonably estimate the.future compliance costs; however, we
will update our ARO and compltance cost estimates as data becomes
available.[Avista 20 ] 7 I 0-K, p. 75J
Even though the final compliance costs are known at this time, please provide a list the items that
these expected significant compliance cost would include and provide an explanation of each.
3 -SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
AVU-E- I 8-03, AVU-G- I 8-02
DATED this 29th day of October 2018.
RICHARDSON ADAMS, PLLC
Richardson, ISB # 3195
Attorney for Clearwater Paper Corporation
4 -SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
AVU-E- l 8-03, AVU-G-l 8-02
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of October 201 8, a true and correct copy of the within
and foregoing SECOND PRODUCTION REQUEST OF Clearwater Paper Corporation in Case
Nos. AVU-E-18-03 and AVU-G-18-02 was served to the following via electronic mail and U.S.
Mail, postage prepaid to:
Diane Hanian (HAND DELIVERED)
Idaho Public Utilities Commission
472 W . Washington Street
Boise, Idaho 83702
diane.holt@puc. idaho. gov
Brandon Karpen
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702
brandon. karpen@puc. idaho. gov
Patrick D. Ehrbar
Avista Corporation
POBox3727
Spokane, WA 99220
patrick. ehrbar@ avi stacorp. com
David J. Meyer
Avista Corporation
PO Box3727
Spokane, WA 99220
.com
Benjamin Otto
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
botto@idahoconservation. org
Travis Ritchie
Sierra Club
2l0l Webster St, Suite 1300
Oakland, CA 94612
travis.ritchie@sierraclub. ors
Dean J. Miller
3620 E. Warm Springs Ave
Boise, Idaho 83716
deanjmiller@cableone. net
Ronald L. Williams
Williams Bradbury, PC
PO Box 388
Boise, Idaho 83701
ron@williamsbradburlz. com
Lany A. Crowley
The Energy Strategies lnstitute, Inc.
[e-mail]
Kandi Walters
Administrative Assistant
5 -SECOND PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
AVU-E-l 8-03, AVU-G- I 8-02