HomeMy WebLinkAbout20210423Clearwater to Avista 1-3.pdfAVISTA CORPORATION
RESPONSE TO REQIIEST FOR INFORMATION
RECEIVED
202|April 2j, AM 10:21
IDAHOPUBLIC
UTILITIES COMMISSION
JTJRISDICTION
CASE NO:
REQIJESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: O4/1012021
AW-E-21-01/AW-G-21-01 WTINESS: ElizabethAndrews
Clearwater Paper RESPONDER: Paul Kimball
Production Request DEPARTMENT: Regulatory AffairsCP-001 TELEPHONE: (s09) 49s-4s84
REQUEST:
Please provide, in electonic format with all formulae intact where possible, all workpapers and
other documents used in the development of Avista's Application in this matter.
RESPONSE:
Avista will be providing all case filings and workpapers to Mr. Peterson using the OneDrive
application. If you would like to also receive the documents in this form please provide me with
an email address to receive the files.
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORTVTATTON
IDAHO DATE PREPARED: 0411012021
AVU-E-21-01 / AW-G-21-01 WITNESS: Elizabeth Andrews
Clearwater Paper RESPONDER: Paul Kimball
Production Request DEPARTMENT: Regulatory AffairsCP-002 TELEPHONE: (s09) 495-4584
REQUEST:
Please provide copies of all communications with the Idatro Public Utilities Commission and its
Staffregarding Avista's Application in this matter.
RESPONSE:
The Company has provided all communications with the Commission to date and will continue to
provided them.
Question No. 1: In Response to Staff s Production Request No. 56, Avista stated that the
Company does not apply integration on a per-MWh basis, but instead charge $1.067/kW-month.
The rate used is contained in Sta[PR_056 Attachment A - "Avista 2007 Wind Integration Cost
Summary (PR56).xlsx." Please answer the following questions.
a. Please explain why the Company does not apply integration on a per-MWh basis, but on
a per kW-month basis.
The 2007 Wind Integration study was in $/MWh. However, since then we learned that
the cost is really driven by the size of the project not the energy, therefore we now apply
this on a per kW-month basis as opposed to a per MWh basis. Please refer to an update
version PR56 I sent to Ms. Yin on March 29 (LIVE CALCS VERSION StaflPR_056
Attachment A - Avista 2007 Wind Integration Cost Summary (PR56).xlsx) that
demonstrates the sources and calculations to arrive at the rates we use.
b. Column E of Sta[PR_056 Attachment A - "Avista 2007 Wind Integration Cost
Summary @R56).xlsx." lists different integration charges at different wind penetration
levels. Please explain how the values in Column E were determined.
The values in Column E were taken from the wind study. The study explains how as
pe,netration of wind grows, integration costs rise. Each case has a level of wind
penetration as described and therefore has increased reserve obligations that translate to
higher integration costs.
c. Were the values in Column E calculated in the 2007 Wind Integration Study? If so,
please reference the page numbers.
Yes, but they were published only on a per-MWh basis. To determine the rates,
Attachment A of PR 56 uses the Low Market Prices case Integration Costs on a per-
MWh basis from Table 27 on Page 50 of the Wind Integration Study and "translates"
them to per-kW using the capacity factor for that wind penetration scenario from Table
l0 on page 16.. The Low Market Prices case is used because current market prices more
closely match the Low Market Prices case
d. The note in Cell F7 states that Avista has more than 200 MW of wind on its system
starting n2021. Please provide Avista's current wind penehation level in MW.
Avista's current wind penetration level is 265.75 MW, comprised of its Palouse and
Rattlesnake projects.
e. Please explain why Avista does not use $0.994lkW-mo, the integration charge at the 200
MW penetation level, but use $1.067/kw-month, the integration charge at the 400 MW
penefration level.
Integration costs increase as wind penetration crosses the thresholds studied. Because our
portfolio now contains more than 200 MW of wind, we use the higher incremental cost.
Wlnd lntegratlon Study Results
has morc than 200 MW of wlrd on lts sy$em startlng ln 2021
f. Has this $1.067/kW-month integration charge used in this case? If so, please explain
how and where this number has been used.
Avista does not model integration costs in its power supply cost proforma. We use the
estimate when comparing variable generation resource options as they enter our portfolio
to ensure we are comparing on an "apples to apples" basis with other resource options.
Integration costs are reflected in the case substantially by the use of a de-
optimized S-year historical shaping of our hydro operations. In other words, absent wind
and solar variability our hydro facilities likely would have been able to generate on
average more power across higher value peak periods than they did with wind in our
portfolio. This de-optimization is exactly what the 2007 Wind Integration Study
endeavored to calculate.
g. Please explain why Avista does not use the integration charges approved in Order No.
30500, which is based on the Settlement Stipulation in the 2007 case (AW-E-07-02).
Order 30500 has integration costs based on 2007 market conditions and a period where
Avista had no wind on its systern. Therefore the $2.75lMWh rate was applicable. Since
that time we have added significant wind resources and market prices have changed. The
2007 Wind Integration Study was intended to provide scenarios keeping its work relevant
under various future conditions. Given all of the changes, it could be appropriate to
modifu integration charges for QF facilities; however our preference would be to await
the outcome of our presently VER integration study results.
Prkc Prke Isrntrrld
SEe NCF S/Mwh , $/tw+no S/hr-rno
03231m
2m
:!l.o9a
33.99a 0.9ca
/t00 30.516
1.!1 0.328
2.57t 0.661
3.E81 0.854
6m :10.593 3.98: 0.885 O3r:11
Question No. 2: Line 149 in Mr. Kalich's workpaper "Transmission Expense - Account 565"
includes an adjusfrnent of $92,500 for BPA PTP for Colstrip, Coyote Spring 2, Lancaster. Please
explain what the adjusfrnent is.
This BPA PTP for Colstrip, Coyote Springs 2, Lancaster amount is for the additional 50 MWs
for Coyote Springs 2 which were necessary due to plant enhancements that increased capacity.
However, this additional amount was denied due to constraints in the Tri-Cities area. This
amount will be removed from the pro-forma period when forwarded prices are updated and
before the rate case is finalized.
Question No. 3: Please walk me through the "Conf Gas Contracts MTM" tab in Exhibit No. 9.
Question No. 4: Line77 of Schedule 2 of Exhibit No. 9 contains 'oSurplus AECO to Malin
Transportation".
a. Please explain why it is determined by the difference between the'oConf Fuel Costs" tab
and "Conf Gas Contracts MTM" tab.
b. Please explain why the 2019 acfial ($53,356,000) is significantly greater than the pro
forma amount ($5,0 I 7,000).
Question No.3: Please walk me through the "Conf Gas Contracts MTM" tab in Exhibit No. 9.
Will be addressed on April 6 call
Question No. 4: Lne77 of Schedule 2 of Exhibit No. 9 contains "Surplus AECO to Malin
Transportation".
a. Please explain why it is determined by the difference between the "Conf Fuel Costs" tab
and "Conf Gas Contracts MTM" tab.
Will be addressed on April 6 call.
b. Please explain why the 2019 actual ($53,356,000) is significantly greater than the pro
forma amount ($5,0 I 7,000).
Will be addressed on April 6 call.
Question No. 5: Page l8 of Mr. Kalich states that Avista does not model index contracts since
they do not impact power supply costs. There is only one such contract in this year's filing, the
2021Morgan Stanley Renewable Energy Credit (REC) sale. However, Production Request
Response No. 73 lists six index deals in the following table and states these index deals are
entered into Aurora as index so these contracts are automatically updated when new forward
prices are calculated and input into Aurora.
lndex 277274 Morgan Stanley CapitalGroup lnc.
UortfrWestern Energy
PacifiCorp
euget iound Energy, lnc.
Talen Energy Montana, LLC
277544
lndex 277545
286577 Morgan Stanley CapitalGroup lnc. Morgan Stanley PCC-1 REC deal
tndex
lndex
a. Please reconcile the two statements and explain which deal(s) are considered in this rate
277546
z.tls+l
Nichols
tticttoit
rVi.f',of s
Nichols
Pump index
Pump index
Pump index
Pump index
sale
sale
sale
saleln
ln
dex
J"*
DescriptionDealTyp KEY Counterparty
case.
Nichols pumping (one contract with multiple Colstrip owners shown above as 4
individual keys) is included in the pro forma as a contract as opposed to a term deal. See
line 62 in the pro forma in 'Schedule 2' and under contracts in 'Schedule lC'.
The Morgan Stanley deals are excluded from the pro forma period (see Kalich testimony
page l9line 8) and probably shouldn't have been included in response to PR73.
b. Which deal(s) have impacts on power supply costs?
These have an indirect impact on authorized power supply costs because the Nichols
Pumping contracts enable us to purchase less non-firm Northwestem transmission for
delivering Colstrip output to load.
c. For the deal(s) that do not have impacts on power supply costs, are they included in
annual the PCA filing?
The Morgan REC deals flow through the PCA filing in actuals.
d. By "Morgan Stanley index sale" on Schedule 2 of Mr. Kalich's Exhibit 9, does Avista
refer to "Morgan Stanley-Clearwater REC deaf' or "Morgan Stanley PCC-I REC deal"
or both?
By Morgan Stanley index sale - Avista is referring to both.
e. Are all six deals based on Mid-C prices?
The Nichols Pumping conffact price is discounted $0.50 to reflect the lower value of
power there relative to Mid-C prices.
f. What does'Nichols Pump index sale" mean?
Each Colstrip owner provides a prorated share of the energy needed for cooling water
pumped from an adjacent river at the Colstrip facility. Avista supplies all pumping
power for those utilities at the plant in exchange for index-based payments.
Question No. 6: Schedule 3 of Mr. Kalich's Exhibit 9 includes a note for "Douglas PUD":
Contract has no direct power supply impact. Reflected in beneficial impact on shape of portfolio
hydro operations in Aurora model.
a. Please explain why it has no direct power supply impact.
There is no direct power supply impact but due to the energy exchange at different times,
there is an indirect impact to power supply costs.
b. Please explain what it means by "reflected in beneficial impact on shape of portfolio
hydro operations in Aurora model".
The power we get from Douglas is scheduled for delivery mostly during on-peak hours
with Avista controlling when we acquire the energy. Energy is returned on a flat product
schedule. This exchange benefits customers.
Question No. 7: Schedule 3 of Mr. Kalich's Exhibit 9 includes a note for "Pend Oreille PUD":
Not included in rate period proforma. However, $5000 is included in the pro forma period on
Schedule 2. Please reconcile.
The "not included in rate period pro forma" note on Schedule 3 was included in error. While the
monthly amounts appear to be zero, there is a total of $5,000 included in the annual pro forma
period.
Question No. 8: Response to Question No. I states that "Order 30500 has integration costs
based on2007 market conditions and a period where Avista had no wind on its system.
Therefore the $2.75l\{Wh rate was applicable." Please explain why $2.75 is used in the context
of Order No. 30500. (The order uses three percentages with a cap of $6.50/MWh.)
This was a mistake. The reference to $2.75lMWh reflected the study base case assuming our
then-low level (i.e., zero MW) of wind penetration. And to contrast that base case with the new
case reflecting lower market prices and higher system penetration. We have never needed to
apply the charge to a QF contract, but would use this math were we needing to.
Tier I
Tier 2
Tier 3
Amount of Wind Online
0 to 199 MW
200 to 299 MW
300 MW and above
Integration Charge (cap)
7o/o ($6.504.1Wh)
8% ($O.SoA{Wh)
e% ($0.s04{wh)
Question No. 1: Please answer the following questions regarding "Short-Term Market" under
Account 555.
a. Please explain why there is a significant reduction from its 2019 actual value of 40,814
thousand dollars to its pro forma value of 3,201thousand dollars.
The drop fiorn 2019 reflects reduced load (-48 aMW), greater hydro (+64 aMW), and
more VER ( 1 50 aMW) offset by fewer contract resources (-55 aMW). So the net is tnore
than I 00 aMW of additional energy in the system. This large change brings actual
purchases down greatly along with a commensurate reduction in short-term market
purchases.
Comparison of Project Generation vs. Actual
Modeled GWh
b. Is the pro forma value of 3,201 thousand dollars calculated based on the purchase from
Mid-C Market Resource created under the single-zone method? Yes
c. Does the pro forma value of 3,201thousand dollars match the Company's experience in
reality? If yes, please provide evidence. If not, please explain how to address the issue.
Please see the response to a. above.
2020 m21-2,2
20r9 2019 Case 2o21 Ca*Delta to 2019
Item Actual Proiected Actual aMW
Load g.{t2 I,111 9,346 055 fttt
Clark Fork 2.565 2,771 2.599 I 188 21
17ipokane9551,073 1,051 1,103 16
Mid-C 1,006 1,231 1,273 233 26
Total Hvdro 4.52t's.075 4,923 089 563 u
't.$2 1.220 1.575 nColstrip1,625
cs2 1,891 1,984 1,767 2,120 229 26
Lancaster 1,798 1,707 1,6E5 1 5E6 (24
Kettle Falls 316 312 265 299 17 (2
265 22',1 221 355 90 10Gas Peakers
Total Thermal 5.852 5,849 s,158 5 9
Palouse wind w2 315 370 316 14 2
Rattlesnake Wind 35 37 /169 /t69 *
42 45 qz (5Lind Solar
41 5lTotal VER yt4 350 452
Small Power/C.oqen 560 232 672 26 (/t0
WNP-3 173 (20
(504 e,47 5Other LT Contracts (616)(446)
Other ContracG 49 (384)n6 231 (5i
ST Purchases 1,42 177 1,W2 114 (152
ST Sales Q.t 42 (1,917)(2.796)Q,314 36
fi.5{t01 fi.7401 n.4141 fi.014)(1t61Market Transactions
Station Service (101 m m fil
Total Supply 9.171 I,140 9,345 9,057 14111 (47)
EE@trI
Question No. 2: Please explain whether "Lancaster PPA" includes o'Lancaster Heat Rate
Tracker" (an item included in AVU-E-19-04 for costs associated with difference between
contractual and actual heat rate efficiency) in both the 2019 actual value of 28,141 thousand
dollars and the pro forma value of 28,467 thousand dollars. If not, please explain why the
fracker is not included.
Yes, the Lancaster PPA does include the former line item "Lancaster Heat Rate Tracker". See
also sheet 'Schedule 3' for line item 6 - Lancaster PPA includes contract costs of capital, O&M
and heat rate tracker.
Question No.3: Please define and explain what "BPA Point-to-Point for Colstrip, Coyote
Springs 2 &Lancaster" is under Account 565.
Transmission expense based on contracted capacity at the tariffed rate plus a 3olo escalator
effective October 1,2021. This line item includes the 50 MW contract for Coyote Springs 2 as
well. We will remove 50 MW CS2 proforma expense for final rates as BPA did not award us the
transmission. See also 'Schedule 3' for line item 46.
Question No. 4: Please explain what "WNP-3" under Account 555, "WA WNP3 - reconciling
items (not in ERM/PCA)" under Account 555, and "WNP-3" under Account 565 are. In
addition, please explain why the pro forma value for each one of thern is 0.
WNP-3 is a contract that expired June 30,2019. It was included in the pro forma as 0 since it
was expired and wouldn't occur in the pro forma period, however, the line item was included
because it was in 2019 actuals. See also 'Schedule 3' for line item 44.
Question No. 6: Mr. Kalich's confidential workpaper "Fuel Costing worksheet notes" states
that "we have capacity rights of 69,388 Dth/day from Kingsgate to points south-26,388 of
which we would like to sell at Malin-leaving 43,000 to utilize at the plants." Please explain
how 26,388 Dth/day is determined.
This is Avista's contracted GTN capacity rights - 60,592 dekatherms per day for AECO-
Kingsgate, 43,000 dekatherms per day for Kingsgate to Stanfield, and 26,388 dekatherm per day
for Kingsgate to Malin.
Question No. 7: Mr. Kalich's confidential workpaper "Fuel Costing worksheet notes" states
that o'we buy 8,796 at Kingsgate each day giving us a total of 69,388 Dth/day to nominate." Is
the8,796 Dth/day based on a contract? If not, please explain how the amount is determined.
For the benefit of our customers, to fully utilize our transportation from AECO to Malin, this
intermediary pipeline path is contracted for to complete the path for our rights.
Question No. 8: Please answer the following questions regarding the tab "Conf Aurora Fuel
Output" of Mr. Kalich's Exhibit 9.
a. When the AURORA model dispatches natural gas plants based on natural gas prices,
does the model consider fuel loss on pipelines and transportation costs of each plant?
Yes it does. Both items are reflected in the cost of fuel delivered to the plants.
b. If not, does the model have the capabilities to do that or is it the modeler's decision to not
consider fuel loss on pipelines and transportation costs of each plant in dispatch?
N/A
c. If it is the latter, please explain why the modeler makes that decision.
Costs for losses and transport to plants are based on line items identified in the
transportation tariff (e.g., mileage-based fuel losses) and/or known taxes (i.e.,
Washington -3.873o/o tax on end-use natural gas consumption).
d. When the AURORA model dispatches natural gas plants, does the model consider the
consfiaint ofpipeline capacities below, which is mentioned on the "Conf Fuel Costs" tab?
Aurora dispatches the plant based on the Malin gas price. However, the gas is re-priced
based on lower-cost AECO gas in "Conf Fuel Costs" tab of file "Kalich Exhibit 9,
Schedule l C.xlsc"
GTN capacity(dth/dav)
AE-KG
KG-ST
KG-MA
60,592
43,000
26.388
e. Please explain why Rathdrum_l is dispatched less frequently than Rathdrum_2 during
the pro forma period.
Consistent with how our Rathdrum units are dispatched and as stated in testimony on
page l7 line 4, only one unit is dispatched at a time in order to cover unanticipated
outages. Therefore, in this rate case, we constrained the Rathdrum units to only allow
one to run at a time. This is different from how we modeled it in the last rate and
explained in testimony.
f. Please explain why Northeast_A and Northeast_B are not dispatched during the pro
forma period.
Northeast, even if cost-effective to run relative to market prices, is limited to 100 hours
per year due to regulation by the Spokane Air Pollution Control Board. ln testimony on
page l7 line 4, the Company explains how it holds the units back for emergency or near-
emergency operations. This is different from the last rate case as we allowed the
Northeast units to dispatch up the 100 hour limit.
g. What is Lancaster_DB? What is the difference between Lancaster_DB and Lancaster
and why is the Lancaster_DB dispatched less frequeirtly than Lancaster?
The duct burner has a substantially higher heat rate than the main unit; so, given the
higher heat rate, it dispatches less.
h. Please explain why the Start Fuel Usage by Day is zero for the following plants:
Northeast_B, Northeast_A, Lancaster_DB, Kettle_Falls_CT_CCCTMode,
Coyote_Springs_2_DB, Boulder_Park_l, Boulder_P ark 2, Boulder_Park_3,
Boulder_Park_4, Boulder_Park_5, and Boulder_Park_6.
There was no start fuel associated with these units. For example, the Northeast units
didn't dispatch as the 100 hours were saved for reserve as spoken to in testimony.
Reciprocating engine and duct fire units are quick start and don't require warrn up time;
therefore, no start up fuel is used.
i. ForNortheast B, Kettle_Falls_CT_CCCTMode, and Boulder_Park_5, please explain
why every day in the pro forma period has zero Start Fuel Usage by Day, but the totals in
Line 387 are 90.30641 thousand dekatherm/day, 55.18849 thousand dekatherm/day, and
47.52767 thousand dekatherm/day. How are the grand totals calculated?
The grand totals were hard-coded values from a previous version. This row should have
been removed. However, it should be noted that the grand totals are not used for any of
the calculations, so the inclusion did not change the outcome of the results.
j. It appears for some plants, Start Fuel is higgered once if the plant generates continuously,
such as Lancaster and Coyote_SpringsJ, while for other plants, Start Fuel is higgered
multiple times even if the plant generates continuously, such as Rathdrum_2. Please
explain how each plant's Start Fuel is calculated.
The work paper shows the summarized daily startup costs. For example, Coyote Springs
2 may start and continuously run but only show the one starfup. For Rathdrum, the plant
may start I or 2 times each day and shut off, therefore the data only shows what
happened each day. The hourly Rathdrum data shows how the plant dispatches across the
day. The start fuel is calculated by for each start a fuel quantity is consumed and then
priced at the local price of natural gas. We can provide the hourly data if you'd like to
explore this further.
Question No.9: Please explain why the calculations on the "Conf Fuel Costso'tab of Mr.
Kalich's Exhibit 9 only considers the GTN pipeline, not other pipelines such as the Northwest
pipeline. Also, why do the calculations only consider Kingsgate, Stanfield, and Malin, and not
other ffading hubs such as Sumas.
The Thermal side of the business has rights to pipeline capacity solely on the TransCanada/GTN
pipeline, therefore Thermal only purchases at market points along the Trans Canada/GTN
pipeline: AECO, Kingsgate, Stanfield and Malin.
Question No. 10: The note for Cell Ela @ipe) states that "Kl - use King-Stan capacity, King
segment. S - use King-Stan capaaty, Stan segment. K2 - use King-Malin capacity, King
segmento'. Please confirm that King segment and Stan segment mean the gas is purchased at
Kingsgate and Stanfield, respectively and that the pipeline capacity at each segme,nt is the same,
which is 43,000 dekatherm/day.
That is correct. The King-Stanfield segment can move up to 43,000 (all units are Dth/day) either
through forward or backward haul. Look at January 23,2022 as an example. Boulder Park
requires 2,301 and Lancaster requires 46,043 for a total of 48,343 Dth/day. We forward haul
43,000 from Kingsgate to the plants (cell EUl T) and purchase the remaining 5,343 from
Stanfield and backhaul it to Lancaster and Boulder Park (cells EUlS &EUzl) because the
43,000 forward haul has been exhausted. CS2 requires 51,779 which comes from a combination
of 43,000 (cell EU30) purchased and forward hauled from Stanfield (the 43,000 segment from
Stanfield to CS2 was not utilized by the other plants-known as pipeline segmentation), plus
8,779 of the Kingsgate to Malin 26,388 capacity that we wanted to sell at Malin, but in this case
need for CS2 (cell EU3l ).
Question No. 11: Please answer the following questions related to the Gas Nomination Qty
section on the "Conf Fuel Costs" tab of Mr. Kalich's Exhibit 9.
a. Please confirm that the Stanfield Hub can deliver gas to the north and to the south at the
same capacity level at the same time.
Yes, true. The pipeline has rules for back hauling, none of which are violated in this
modeling.
b. Please explain why there is no surplus amounts sold at Stanfield in Row 33.
c. Surplus gas in the Kingsgate-Stanfield segment is sold (on Row 33) when the demand at
the gas plants is reduced, as is typical in Q2 (cell JB33 for example). There are 56 days in
the test period where surplus gas is sold at Stanfield. When Row 33 is zero, there is no
surplus gas.
Question No. 12: Please explain why a "buy Stan - no burn" scenario is not considered.
A "buy Stan-no burn" scenario is buying gas at Stanfield and selling it at Malin. We have rights
to 26,388 Dth/day between AECO and Malin that is 100% utilized each day, so there is no
additional capacity to move gas from Stanfield to Malin. We would always buy AECO rather
than Stanfield in using the 26,388.
Question No. 13: Please explain why "buy King -burno'on September l, 2021is -15 thousand
dekatherm.
There do not appear to be any negative values in Row 38 in the exhibit as filed nor should they
ever be.
Question No. 14: Please explain what the numbers in the green box on the "Conf Gas Contracts
MTM' represent and how these numbers are calculated.
MTM, or mark-to-market, is the position of the financial trades made for the Thermal side of the
business, with positive values representing expense (out of the money) and negative values
representing revenue (in the money). The detail behind the numbers shaded in green are in
Column O. For example, the deal in Row 5 shows a basis sale of Malin at a price of -$0.5375.
The MTM basis price, based on the prices used in the Case, is -$0.0463. The difference in the
basis is -$0.4912, multiplied by 75,000 Dth, and that deal is $36,843 of expense.
Question No. 15: Under the single-zone method, does the total load in the zone (which includes
the Mid-C Market Load) have to be met by the total resources in the zone (which includes the
Mid-C Market Resource) so that demand is equal to the supply?
No. As explained in testimony on page 9 starting at line 13, the total load just needs to be big
enough to absorb all potential surplus sales from Avista resources when they are lower cost to
operate than the market price of power.
ruRISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
IDAHO DATE PREPARED: 0411412021
AW-E-21-01 / AW-G-21-01 WITNESS: Elizabeth Andrews
Clearwater Paper RESPONDER: Paul Kimball
Production Request DEPARTMENT: Regulatory AffairsCP-003 TELEPHONE: (s09) 49s-4s84
REQUEST:
Please provide copies of all responses to production requests (both formal and informal)
provided to any other party to this proceeding.
RESPONSE:
Please see Avista's response 003C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and exempt from public view and is separately filed under
IDAPA 31.01.01, Rule 067 and233, and Section 9-340D, Idaho Code.
The Company has provided all production requests from all parties to date and will continue to
provide therr. See CP_PR_003 Attachments A-G and CP_PR_003C Confidential Attachments A
& B for the informal responses provided to Staff.