20150722Staff 37-73 to AVU.pdf

KARL T. KLEIN
BRANDON KARPEN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]t334-03s7
IDAHO BAR NOS. 515617956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVTSTA CORPORATION DBA AVISTA ) CASE NO. AVU-E-15-05
UTILITIES FOR AUTHORTTY TO TNCREASE ) AVU-G-15-01
ITS RATES AND CHARGES FOR ELECTRIC )
AND NATURAL GAS SERVICE IN IDAHO. ) SECOND PRODUCTION
) REQUEST OF THE
) coMMrssroN STAFF To
) AVISTA CORPORATTON
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, and no later
than WEDNESDAY, AUGUST 12,2015.
This Production Request is 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 answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
SECOND PRODUCTION REQUEST
TO AVISTA JULY 22,2015
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 37: With respect to the Northwest Power Pool (NWPP) cost increase
(See Cox DI pg. 4, line 18), please answer the following questions:
l. What caused the annual increases from the current contributions, and how are they
determined?
2. Did the amounts change with the recently signed 2015 agreement? Please explain.
3. Do Company operators obtain NERC certification credits via the NWPP training? If
so, what are the estimated savings to the Company for taking advantage of this
service?
4. Did Company staff participate in the NWPP Energy Emergency Plan (EEP) training
(May 13,2015)? If so, did this training compliment or replace any Company-
sponsored emergency response training?
5. Are any of the cost increases associated with the Market Assessment and
Coordination Committee (MC) Initiative? Please explain.
6. Does the Company intend to explore Energy Imbalance Market (EIM) opportunities
via other means (i.e., join the Califomia/PacifiCorp EIM)? Please explain.
7. Please explain whether the Company has utilized the NWPP reserves, including the
frequency, specific times, and quantities over the past 5 years.
8. Please explain whether the Company plans to utilize the NWPP reserves, including
the frequency specific times, and quantities for the next three years.
REQUEST NO.38: Please provide a copy of the North Western Energy Colstrip
transmission operation and maintenance plans (See Cox DI, pg. 5, line 9). Does the Company
agree with the current approach to operating and maintaining of these lines? Does the Company
plan to re-assess any ownership rights? Please explain.
REQUEST NO.39: With respect to the ColumbiaGrid participation and cost increases
(See Cox DI, pg. 6, line 7), please answer the following:
1. What caused the annual increases from the current contributions, and how are they
determined?
SECOND PRODUCTION REQUEST
TO AVISTA JULY 22,2015
Please describe how ColumbiaGrid implements data improvements to the
Transmission Expansion Planning Poliry Committee (TEPPC) Common Case and
Base Case in the regional analyses. For example NTTG conducts a "round trip"
analysis approach of PCM - Power Flow - PCM. Does ColumbiaGrid perform a
similar analysis? If not, why not?
Are these regional planning data and modeling improvements provided to TEPPC to
improve the TEPPC Common Case and WECC Base Cases? If not, what do
ColumbiaGrid members need to do so that these improvements are effectively
shared?
Please describe how the other regions implement improvements to the TEPPC
Common Case and WECC base cases in their regional analyses. Are these
improvements provided to WECC for use in future base cases? If not, are
ColumbiaGrid interface members communicating on how all of the regions need to
effectively share these improvements so that everyone can have access to better data?
How will the resulting regional and interregional plans evaluate reliability
challenges? And, will WECC be asked to contribute anything to these efforts?
Please clarify whether the benefits of the transmission projects are included in the
ColumbiaGrid analysis, or whether the analysis only evaluates a difference in cost.
How does ColumbiaGrid quantifu the benefits? Please explain.
How can the current ColumbiaGrid members ensure the regional and interregional
FERC Order 1000 processes will produce a least-cost, least-risk interregional plan
that also provides the highest benefits? Will the resulting interregional plan result in
a cost-allocation framework that is also suitable for investment and ownership rights?
Please explain.
REQUEST NO. 40: Please provide a copy of the current ColumbiaGrid Planning and
Expansion Functional Agreement (PEFA) contract and explain what is causing the expense
increases. (See Cox DI, pg. 6,line22)
REQUEST NO.41: Please provide a copy of the Amended and Restated FERC Order
1000 Functional Agreement (See Cox DI, pg. 7, line l0), along with a list of participants and the
duration of the agreement.
REQUEST NO.42: Please provide copies of the Company's Critical Infrastructure
Protection (CIP) planning documents (See Cox DI, pg. 7,line l9). How does the Company
SECOND PRODUCTION REQUEST
TO AVISTA
2.
J.
4.
5.
6.
7.
JULY 22,2015
comply with the third-party certification of the physical security assessment (i.e., CIP 014-02)?
What are the costs associated with the third-party certification?
REQUEST NO. 43: Please describe how the Company protects its generators from
cyber-attacks or tampering, including out-of-phase conditions. Does the Company utilize
specific hardware to address generator vulnerabilities (e.g., Cooper Power Systems' iGR-933
Rotating Equipment Isolation Device, or Schweitzer Engineering Laboratories 75lA feeder
protection relay)? Please describe in detail the hardware the Company uses for this purpose (i.e.,
model number, serial number, year, cost). Did the Company obtain the hardware through a
proposal process or through another process? Please explain how the Company evaluated the
benefits and costs among the hardware options available at the time of purchase.
REQUEST NO.44: Please describe Peak's services to the Company (See Cox DI, pg. 9,
line 4), and respond to the following:
l. Does the Company utilize additional services from Peak including the Advanced
Applications or the Enhanced Curtailment Calculator?
2. Please compare the Company's costs under the previous funding framework (i.e.,
under Section 215) andthe newly adopted Alternative Funding Agreement.
3. Please provide a copy of the Company's current agreement with Peak.
4. Please describe the Company's input to the current Peak Section 21 review.
REQUEST NO. 45: Please describe WECC's services to the Company (See Cox DI, pg.
10, line 3). Does the Company utilize additional services from WECC, including the TEPPC
common base case development, WREGIS, or others? Please describe the Company's input to
the current WECC Section 4.9 review. Please compare the pre-bifunction costs/services to the
post-bifunction costs/services.
REQUEST NO.46: Please provide a copy of the Company's method for differentiating
between distribution and transmission components (See Cox DI, pg. 1 1, line 20). How do the
newly developed Bulk Electric System (BES) definitions and policies change the Company's
definitions of transmission vs. distribution components? Do these changes impact the
SECOND PRODUCTION REQUEST
TO AVISTA JULY 22,2015
Company's reliability analysis (i.e., contingency or path rating analysis) and Transmission
Revenue Adjustment? Please explain.
REQUEST NO.47: Please provide a copy of the Parallel Operation Agreement with
BPA (See Cox DI, pg.23,line 21). What would the value of the capacity be to the Company if it
were to withdraw from this agreement? Does the parallel support provided by the Company
assist BPA in complying with NERC reliability requirements? If so, which NERC reliability
requirements? Please provide the Company's cost/benefit analysis for providing this service to
BPA.
REQUEST NO. 48: Regarding the termination of the 150 MW Point to Point Contract
(See Cox DI, pg. 25,line 3), please provide a copy of the original contract and all
correspondence and notifications associated with the contract termination. When did the
Company know the Lancaster Generation Station would be integrated into its transmission
system? What is the cost associated with the nine-month delay in contract termination? Where
are these costs booked?
REQUEST NO. 49: Regarding the transmission capital projects described in Cox DI,
pg.28,line I I and pg. 30 through p9.37, please provide the following:
1. The 2012 and2013 budgeted amounts as compared to the amounts actually booked
and included in test year revenue requirement;
2. a description of the method(s) used to develop individual program budgets;
3. the differences in program costs and priorities over the past 5 years;
4. an explanation on whether any of the capital investments address contingency
requirements and, if so, which ones;
5. an explanation of whether the Company is pursuing any joint-ownership agreements
that may result in reliability improvements and/or reduced capital expenses;
6. a description of how the Company analyzes project costs and benefits;
7. results of transmission system project costs and benefits analysis;
8. the specific locations of the proposed investments in the transmission system;
9. a description of the Company's SCADA system;
10. copies of the supporting studies that document the necessity for the capital
investments;
SECOND PRODUCTION REQUEST
TO AVISTA JULY 22,2015
1 1. a description of the Company's efforts to increase reliability and transmission
capacity through operation enhancements or controls (e.g., frequency response, etc.);
and
12. a description of the Company's optimized Transmission Asset Management Program.
REQUEST NO. 50: Regarding the distribution system capital projects for Idaho
described in Cox DI, pg. 3J,line 17, please provide the following:
1. The 2012 and2013 budgeted amounts as compared to the amounts actually booked
and included in test year revenue requirement;
2. a description of the method(s) used to develop individual program budgets;
3. the differences in program costs and priorities over the past five years;
4. the specific locations of the proposed investments in the distribution system;
5. circuit locations, performance data, reliability index(es) data, and available
information on asset management/optimization;
6. a description of how the Company analyzes project costs and benefits;
7 . results of distribution system project costs and benefits analysis;
8. a description of the Company's voltage and other power-quality monitoring
equipment, including locations within circuits located within Idaho;
9. copies of the supporting studies that document the necessity for the capital
investments;
10. a description of the Company's efforts to increase reliability and distribution capacity
through operation enhancements or controls including voltage support, frequency
response, and the Company's ability to rotate outages among circuits;
1 1. a description of key program elements such as meters, cyber security, outage
detection/response, and
12. a description of the Company's optimized Distribution Asset Management Program.
REQUEST NO. 51: Please describe the Company's situational awareness of the
transmission system beyond the Company's Balancing Authority Area. If the Company does not
participate in Peak RC's Advanced Applications program for Real Time Contingency Analysis
training for Operators, does it plan to in the future? If so, please provide the costs to the
Company to obtain situational awareness over the past three years and projected into the future.
Please explain how the Company evaluates the benefits and costs of the available programs used
to maintain situational awareness.
SECOND PRODUCTION REQUEST
TO AVISTA JULY 22,2015
REQUEST NO. 52: Please provide a copy of the current cost allocations (i.e.,
percentages and dollar amounts) among the states within which the Company operates. Please
also provide this same information from 2009.
REQUEST NO. 53: What are the anticipated impacts due to the proposed re-opening of
the Columbia Treaty (See Kinney DI, pg. 6, line 9, footnote 1)?
REQUEST NO. 54: Please explain how the Company evaluates the risks associated
with transmission market purchases and a sale, including which risks the Company has identified
and how the Company is exposed to changes within the markets. What is the Company's risk-
tolerance policy, how is it measured, and how does the Company demonstrate it conforms to the
current policy?
REQUEST NO. 55: Please explain how the Company analyzes the market risks due to
short-, medium-, and long-term wholesale transactions (See Kinney DI, pg. 7, line 21). How
does the Company ensure the risk policies are complied with?
REQUEST NO. 56: Please explain how the Company evaluates the potential benefits
and risks associated with an Energy Imbalance Market (See Kinney DI, pg. 7,line 21). Please
provide the specific calculations and assumptions.
REQUEST NO. 57: Please explain how the Company evaluates the possibility,
potential benefits, and risks associated with participating in an Independent System Organization
(ISO, See Kinney DI, pg. 7, line 21). Please provide specific calculations and assumptions if a
cost benefit analysis has been developed.
REQUEST NO. 58: Please describe the financial and programmatic impacts of the
Company's cyber-security requirements due to expanding reliability requirements (See Kensok
DI, pg. 5, line 17).
SECOND PRODUCTION REQUEST
TO AVISTA JULY 22,2015
REQUEST NO.59: Please:
1. Describe the Company's utility-scale, of Balancing Authority Area-scale emergency
planning and response training activities.
Explain whether the Company participated in the Northwest Power Pool Energy
Emergency Plan (EEP) training on May 13,2015. If so, did this training compliment
or replace any Company-planned emergency response training? If the Company did
not participate, please provide the Company's reasons for not participating and a
describe the Company's regional-scale emergency response exercise and trainino
efforts.
Explain whether the Company plans to participate in, or observe the GridEx III
emergency response exercise planned for November 2016. If so, please list the staff
who will participate, and their roles within the Company and with GridEx III. If not,
please provide the Company's reasons for not participating and describe the
Company's national-scale emergency response exercise and training efforts.
REQUEST NO. 60: What is the sensor technology (e.g., phase-angle measurement
units) and associated data network management and protection utilized by the Company (See
Kensok DI, pg. 6, line 3)? Does the Company employ similar tools to manage the natural gas
distribution system needs? Please explain how the Company evaluates the benefits and costs
among the options available, what these costs have been over the past three years, and what the
projected costs are.
REQUEST NO. 61: Please describe the scope and type of the Company's investments
to increase customers' energy-management options (See Kensok DI, pg. 6, line 14). Please
explain how the Company analyzes the benefits it receives from these investments.
REQUEST NO. 62: Please describe the Company's review of system evaluations over
time, and in light of the current CIP 4 requirements (See Kensok, pg. 5,line24).
REQUEST NO. 63: Please describe any CIP 4-related services provided to the
Company by Peak (See Kensok DI, pg. 5,line24).
SECOND PRODUCTION REQUEST
TO AVISTA
2.
3.
JULY 22,2015
REQUEST NO. 64: Please provide the make, serial number, and cost of the meters
currently being installed by the Company. Please explain whether any of the proposed IT
updates are associated with metering equipment deployment or use (See Kensok DI, pg. 19, line
26). Please list the benefits and all associated assumptions for the costs vs. benefits for meter
installation (e.g., meter reading efficiencies or other benefits; associated IT upgrades or other
costs). Please describe how the Company uses the installed meters in its demand response,
energy efficiency, and demand-side management programs. Does the Company perceive and/or
assess any reliability benefits? Please explain.
REQUEST NO. 65: Please provide in an electronic Excel format electric and natural
gas forward prices for January 2016 to December 2017, contract months as reported daily for all
settlement dates during the period from July 1,2014, through the present for AECO, Malin,
Spokane, Rockies, Stanfield, Sumas, Henry Hub, and S. Califomia.
REQUEST NO. 66: Please list and describe any natural gas purchase contracts that
have already been executed for delivery of natural gas to Coyote Springs 2, orLancaster during
any months of the pro forma period. List the date of the purchase, the quantity of natural gas, the
scheduled delivery dates, and the price for the purchase in $/MMBtu.
REQUEST NO. 67: Please provide the monthly generation of the Palouse wind project
for 2013 and2014 calendar years. Please indicate the percentage each month of generation in
peak load hours.
REQUEST NO. 68: Please provide the monthly amounts paid by the Company for the
Palouse wind project in the 2013 and2014 calendar years.
REQUEST NO. 69: Please provide an itemized listing of the capital investment made
by the Company for interconnection, substation, transmission and distribution facilities required
to receive generation from the Palouse wind project.
SECOND PRODUCTION REQUEST
TO AVISTA JULY 22,20T5
REQUEST NO. 70: Please provide the total test year and any proforma revenue
requirement for the Company to purchase and receive energy from the Palouse wind project.
REQUEST NO. 71: Please provide an itemized listing of annual expenses and capital
investments associated with the current Clark Fork River Hydroelectric FERC license.
REQUEST NO. 72: Please explain how current and proposed expense and capital
investment compare to the estimated relicensing costs when the relicense was originally
approved.
REQUEST NO. 73: What is the annual test year and proforma revenue requirement
associated with maintaining the Clark Fork River FERC hydro electric generating license?
Dated at Boise, Idaho, this 77DA aayof July 2015.
Technical Staff: Johanna BelU37-64
Yao Yin/65-66
Randy Lobbl6T-73
i : umisc: prodreq/avue I 5. 5_avug I 5. I dhdjhjbyy prod req2
SECOND PRODUCTION REQUEST
TO AVISTA
{J I ru*-
Karl T. Klein
Deputy Attorney General
10 JULY 22,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY oF JULY 2015,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AYISTA CORPORATION, IN CASE NOS.
AVU-E.15-05/AVU-G.I5-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
KELLY NORWOOD
VP _ STATE & FED REG
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83702
E-mail : j [e-mail]
CLEARWATER PAPER CORP
C/O PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE TD 83702
E-mail : peter@richardsonadams. com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail: [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES
INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 83716
E-mail: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 8370I
E-mail: [e-mail]
kmiller@ snakeriveralliance. org
CERTIFICATE OF SERVICE