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Home My WebLink About20250213Staff 1-18 to AVU.pdf RECEIVED Thursday, February 13, 2025 3:52:57 PM IDAHO PUBLIC UTILITIES COMMISSION MICHAEL DUVAL DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 IDAHO BAR NO. 11714 Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF AVISTA ) CORPORATION'S FILING TO UPDATE AND ) CASE NO.AVU-E-25-02 ESTABLISH ITS CAPACITY DEFICIENCY ) PERIOD TO BE USED FOR AVOIDED COST ) CALCULATIONS ) REDACTED FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA CORPORATION, DB/A AVISTA UTILITIES Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Michael Duval, Deputy Attorney General, requests that Avista Corporation, d/b/a Avista Utilities ("Company")provide the following documents and information as soon as possible, but no later than THURSDAY,MARCH 6, 2025. 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 or information produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations, and the name,job title, and telephone number of the person preparing the documents. Please also identify the name,job title, location, and telephone number of the record holder. REDACTED FIRST PRODUCTION REQUEST TO AVISTA CORPORATION D/B/A AVISTA UTILITIES 1 FEBRUARY 13, 2025 In addition to the written copies provided as response to the requests,please provide all Excel spreadsheets and electronic files with formulas intact and enabled. REQUEST NO. 1: Please provide the monthly capacity positions for 2025. REQUEST NO. 2: Table I of the Compliance Filing shows that Colstrip Units 3 and 4 will exit in 2025 and Northeast will exit in 2029. Please explain whether these exits have regulatory certainties such as a signed contract or a Commission approval. Please also provide the exit dates based on their useful lives. REQUEST NO. 3: Prior Commission orders such as Order No. 33958 required the Company to use the latest information for determining capacity deficiency periods. Please respond to the following: a. Is the load forecast used in the Compliance Filing the latest load forecast? i. If not, please provide the latest load forecast and explain the difference between the latest and the proposed load forecast. b. Is the contract information used for determining capacity deficiency periods the latest contract information? i. If not, please provide the latest contract information and explain the difference between the latest contract information and the proposed contract information. REQUEST NO. 4: Are Public Utility Regulatory Policies Act("PURPA") contracts assumed to be renewed in the Load and Resource Balance? Please explain and justify the decision. REQUEST NO. 5: Please explain why the values in Table 2 of the Compliance Filing do not match the table on the Tab "Position Summary" of confidential file "AVU-E-25_2025 Capacity Deficiency Application-Confidential 1-29-25.xlsm". Also,please explain which table is correct. REDACTED FIRST PRODUCTION REQUEST TO AvisTA CORPORATION D/B/A AVISTA uTiLiTiEs 2 FEBRUARY 13, 2025 REQUEST NO. 6: Please define and explain the following resources that are included in Tab "System—LW' of confidential file "AVU-E-25_2025 Capacity Deficiency Application- Confidential 1-29-25.xlsm" and why their values are- Juris Purch Palouse Wind Juris Purch Rattlesnake Flat Juris Purch Kettle Falls Juris Purch Chelan PUD Juris Purch Chelan PUD Canadian Entitlement Juris Purch Columbia Basin Hydro Juris Purch Clearwater Wind REQUEST NO. 7: Please define "Jurisdictional Transfer" and explain why its capacity is m. REQUEST NO. 8: Please explain how the values of"Short Term Market Purchases" are determined and why they are not used in calculating Net Position. Also,please explain if the values are subject to a 330 MW market limitation. REQUEST NO. 9: Please define "Embedded EE" and"Selected EE". Please explain the difference between the two and also explain why their values are_- REQUEST NO. 10: Please explain what`Electrification"represents and why its values are■. REQUEST NO. 11: For the line item"Reserves +Regulation+Maintenance Adjustment", please define "Reserves", "Regulation" and"Maintenance Adjustment" and explain how their values are determined. Also, please explain the difference between"Reserves" and"Regulation." REDACTED FIRST PRODUCTION REQUEST TO AvisTA CORPORATION D/B/A AVISTA UTiLiTiEs 3 FEBRUARY 13, 2025 REQUEST NO. 12: Please explain why the Planning Reserve Margin("PRM") for winter is determined by a reliability study, while the PRM for summer is determined by the single largest contingency resource compared to expected load. Also,please explain the rationale behind the method for summer PRM. Lastly,please explain if the reliability study that determines PRM uses the Qualifying Capacity Contribution("QCCs") in 2030 derived from the short-term Western Resource Adequacy Program ("WRAP") QCCs. REQUEST NO. 13: Page 6 states that Avista conducts a reliability study with the resources chosen within the Preferred Resource Strategy for 2030, and the results show the system is below the 5% Loss of Load Probability ("LOLP") threshold. Please explain if it is possible for the LOLP to be above 5% if the PRM is selected using the 5% LOLP threshold and resources are selected based on the PRM. If so, please explain how that would occur. REQUEST NO. 14: Page 5 of the Compliance Filing states that using the WRAP values creates a consistency of resource assumptions in other resource adequacy settings. Please explain what are"other resource adequacy settings" and why the consistency of resource assumptions is important. REQUEST NO. 15: Please provide examples showing how WRAP short-term QCCs are converted to long-term QCCs. REQUEST NO. 16: Page 6 of the Compliance Filing states that if Avista used the prior methodology approved in past orders for resource capacity contribution, the resulting capacity need would be the same. Please provide the following: a. Please explain how the prior methodology determined resource capacity contribution and provide examples for each technology type. b. Please explain how WRAP method determines short-term QCCs and provide examples for each technology type. c. Please explain how Avista determined long-term QCCs and provide examples for each technology type. REDACTED FIRST PRODUCTION REQUEST TO AVISTA CORPORATION DB/A AVISTA UTILiTIEs 4 FEBRUARY 13, 2025 REQUEST NO. 17: Page 6 of the Compliance Filing states that Avista uses the resource adequacy study to calculate its resource deficit. Please explain the method used in the resource adequacy study and provide a copy of the study. Also, please explain the relationship between the deficit amount determined in the resource adequacy study and the deficit amount determined by the Load and Resource Balance. REQUEST NO. 18: Page 5 of the Compliance Filing states that the PRM is determined by summing the QCCs of all existing and"required"resources to determine the 5% LOLP result and then dividing it by the expected peak load. In reference to Table 3 of the Compliance Filing, does the "required"resource mean the 50-MW resource? Please explain whether the 50-MW resource is determined based on the 5%LOLP target under both Method 1 and/or Method 2. DATED at Boise, Idaho, this 13th day of February 2025. Michael Duval Deputy Attorney General I:\Utility\UMISC\PRDREQ\AVU-E-25-02 PR#l.docx REDACTED FIRST PRODUCTION REQUEST TO AvisTA CORPORATION DiBiA AVISTA UTILITIES 5 FEBRUARY 13, 2025 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF FEBRUARY 2025, SERVED THE FOREGOING REDACTED FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA CORPORATION,DB/A AVISTA UTILITIES , IN CASE NO. AVU-E-25-02, BY &MAILING A COPY THEREOF TO THE FOLLOWING: DAVID J MEYER SHAWN BONFIELD VP & CHIEF COUNSEL SR MGR REGULATORY POLICY AVISTA CORPORATION AVISTA CORPORATION PO BOX 3727 PO BOX 3727 SPOKANE WA 99220-3727 SPOKANE WA 99220-3727 E-mail: david.me ergavistacorp.com E-mail: shawn.bonfieldgavistacorp.com avi stadockets(cry avistacorp.com PATRICIA JORDAN,,,,SECRETARY CERTIFICATE OF SERVICE