20170922Avista to Sierra Club 3-1, 3-13.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club - 3-1 TELEPHONE: [phone]
REQUEST: Please identify and itemize the "Pollution Control Taxes" referenced in the document "SC_PR_1-3C Confidential Attachment C - 2017 Business Plan.pdf", provided in response to Sierra Club Data Request 1-3. RESPONSE: The Pollution Control Taxes referenced are taxes collected by the state of Montana for the total tons of emissions of the following pollutants: total of SO2, NOx, PM10, & VOC. The combined
total emissions is multiplied by the emission tax rate. The total for budget purposes is based on
anticipated run-hours and generation levels. The Company does not have an itemized account of the Pollution Control Taxes.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Clint Kalich
REQUESTER: Sierra Club RESPONDER: James Gall TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: Sierra Club: 3-2 TELEPHONE: [phone]
REQUEST: Please describe Avista corporation's current expectations regarding future greenhouse gas regulations, emissions restrictions, and/or pricing for resource planning purposes. Please provide any available supporting documentation such as board presentations, board minutes, financial
statements, or white papers describing these expectations. RESPONSE:
Avista’s current expectations for future greenhouse gas regulations for resource planning are
described in the 2017 Electric Integrated Resource Plan, provided as SC_PR_3-2 – Attachment A (provided in electronic format only), at pages 10-25 and 10-26.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: State & Federal Regulation REQUEST NO.: Sierra Club-3-3 TELEPHONE: [phone]
REQUEST: What is the status of Avista's "cost/benefit analysis associated with joining the CAISO EIM" described on Page 6-6 of its 2017 IRP? Please provide this analysis and supporting workpapers if and when available.
RESPONSE: Objection: Avista objects to this data request on the ground that it is beyond the scope of this
case, inasmuch as there are no costs associated with joining the CAISO EIM included within the
Company’s case.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: State & Federal Regulation REQUEST NO.: Sierra Club-3-4 TELEPHONE: [phone]
REQUEST: In Appendix G of Avista's 2017 IRP, the company estimates integration costs for Montana wind as $4.40/kW-yr. a. Please confirm that these are the intended units for this assumption. If not, please identify the correct units.
b. Please provide underlying workpapers, analysis, or references supporting this assumption. RESPONSE: Objection: Avista objects to this data request on the ground that it is beyond the scope of this case, inasmuch as there are no costs associated with integration costs for Montana wind included within the Company’s case.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: State & Federal Regulation REQUEST NO.: Sierra Club-3-5 TELEPHONE: [phone]
REQUEST: Please provide any analyses of the price, availability, technical feasibility, and integration costs associated with using Montana wind resources to serve Avista's electricity customers prepared by or for Avista, or relied upon by the company in developing its resource plans.
RESPONSE: Objection: Avista objects to this data request on the ground that it is beyond the scope of this
case, inasmuch as there are no costs associated with Montana wind integration costs included
within the Company’s case.
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AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club - 3-6 TELEPHONE: [phone]
REQUEST: Reference Avista’s response to SC 1-3, Confidential Attachment E, page 33 of 38. a. What is the construction and operation status of [confidential] (“Project ID 10022111”)? If
it has not been completed, when (month and year) does Avista anticipate it will be completed? b. Please provide the dollar amount, if any, from Project ID 10022111 that Avista included in
its rate base request in this proceeding AVU-E-17-01?
c. On what date does Avista anticipate Project ID 10022111 was or will be “used and useful”?
d. The project description states: [confidential] What is the status of the [confidential]
referenced in this project authorization? e. On what date did the [confidential] referenced by this document come into effect? If that date has not yet occurred, what date does Avista anticipate they will come into effect?
f. Please provide all memos, reports, emails, or other documents prepared by, reviewed by, or made available to Avista that support the conclusion that [confidential]. g. Please provide all memos, reports, emails, or other documents prepared by, reviewed by, or
made available to Avista between 2015 and today that discuss any changes to the referenced [confidential] and/or the referenced [confidential]. h. Please provide a narrative description of what Avista understands its regulatory obligations
are today that necessitate the installation of Project ID 10022111, including but not limited
to compliance deadlines and applicable emissions limits. RESPONSE: a. Project ID 10022111 has been completed and is in service.
b. This project was completed in June of 2016, included and approved in Avista’ prior 2016 GRC (Case No. AVU-E-16-03), and is therefore currently included in base rates as of January 1, 2017. Therefore this project is not included in the Company’s current base
request in this proceeding. The total cost from Talen for this project is $1,993,516. This
total does not include any overheads incurred by Avista. c. 6/30/2016
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d. The Regional Haze Program set a national goal of eliminating man-made visibility
degradation in Class I areas by the year 2064. States are expected to take actions to make “reasonable progress” to maintain the proper glide-path of pollutant reductions to achieve the 2064 goal. On September 18, 2012, the EPA finalized the Regional Haze federal implementation plan (FIP) for Montana which included both emission limitations and
pollution controls for Colstrip Units 1 & 2. Anticipating that Colstrip Units 3 & 4 could be ordered to install Selective Catalytic Reduction (SCR) during the 2017 review period, the Colstrip Owners’ proactively installed the Smart Burn technology to reduce the formation of Nitrous Oxides (NOx) in
combustion zone for two major benefits: Make proactive and verifiable NOx reductions and Optimize the size, scope and ammonia use of any future SCR installation. Colstrip Units 3 & 4 are currently being evaluated as part of the State of Montana Regional
Haze 5-Year Progress Report (please see: https://deq.mt.gov/Portals/112/Public/Air/ProgressReport_DRAFT_7-2017.pdf) for more information. e. See answer to “d”
f. The following attachments are provided:
• SC_PR_3-6 Attachment A – PPL - PPL response letter to EPA dated Jan. 31, 2011 to request for information (Nov. 5, 2010) for additional Reasonable Progress information for Colstrip Units 3 & 4.
• SC_PR_3-6 Attachment B –Executive - NOx Control supplement to Attachment 2 of PPL.pdf . This attachment includes additional information in regards to NOx provided by PPL.
• SC_PR_3-6 Attachment C –Earth J -Earth Justice, Montana Environmental
Information Center, Sierra Club and National Parks Conservation Association
comment letter to EPA dated August 22, 2011
• SC_PR_3-6 Attachment D –Regional Haze - Colstrip Owners presentation to EPA dated Nov. 1, 2011
• SC_PR_3-6 Attachment E –Federal Reg - EPA issued the Federal Implementation Plan (FIP) for Montana dated Sept. 18, 2012
• SC_PR_3-6 Attachment E –EPA - EPA issued general principles for next review period for reasonable progress reports
The Company is in the process of searching for additional material and will supplement this response with relevant information if and when available. g. See “f”
h. See answer to “d”

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club - 3-7 TELEPHONE: [phone]
REQUEST: Reference Avista’s response to SC 1-3, Confidential Attachment G, page 50 of 74. a. What is the construction and operation status of the (“Project ID 10023705”)? If it has not
been completed, when (month and year) does Avista anticipate it will be completed? b. Please provide the dollar amount, if any, from Project ID 10023705 that Avista included in its rate base request in this proceeding AVU-E-17-01?

c. On what date does Avista anticipate Project ID 10023705 was or will be “used and useful”? d. Please provide a narrative description of what Avista understands its regulatory obligations
are today that necessitate the installation of Project ID 10023705, including but not limited
to compliance deadlines and applicable emissions limits. e. Please provide all memos, reports, emails, or other documents prepared by, reviewed by, or made available to Avista that support the conclusion that any regulation, statute, or other
requirement requires the installation of Project ID 10023705.
RESPONSE: a. Project ID 10023705 has been completed and is in service.
b. The total project costs billed from Talen are $1,047,417. This total does not include any overheads incurred by Avista. c. 6/30/17. d. See the Company’s response to SC_PR_3-6 (d).
e. See the Company’s response to SC_PR_3-6 (d).
f. See Avista’s response to SC_PR_3-6 (f) g. See Avista’s response to SC_PR_3-6 (f) h. See the Company’s response to SC_PR_3-6 (d).
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AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club - 3-8 TELEPHONE: [phone]
REQUEST: Reference Avista’s response to SC 1-3, Confidential Attachment G, page 48 of 74. a. What is the construction and operation status of the (“Project ID 10023703”)? If it has not
been completed, when (month and year) does Avista anticipate it will be completed? b. Please provide the dollar amount, if any, from Project ID 10023703 that Avista included in its rate base request in this proceeding AVU-E-17-01?

c. On what date does Avista anticipate Project ID 10023703 was or will be “used and useful”? d. Does Avista anticipate that Project ID 10023703 has or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not? e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?
RESPONSE: a. Project ID 10023703 has been completed and is in service.
b. The total cost billed from Talen for this project is $487,735. This total does not include any overheads incurred by Avista. c. 6/30/2017. d. It is Avista’s belief that the project does not require a PSD permit, because it is regular
ongoing maintenance.
e. The currently assessed probable retirement years for Avista’s investment in Colstrip Unit 3 and Colstrip Unit 4 are 2034 and 2036, respectively. The depreciation rates approved by the Idaho Public Utilities Commission (IPUC) and utilized by the Company are established through periodic depreciation studies, which the Company undertakes approximately
every five years. The depreciation study examines, for each studied FERC account, the
existing level of plant investment in service, the estimated remaining life span of each given asset category, and the expected salvage costs.1
1 As stated in the Company’s most recent completed depreciation study, “The life span estimates for power generating stations were the result of considering experienced life spans of similar generating units, the age of surviving units, general operating characteristics of the units, major refurbishing, and discussions with management personnel concerning the probable long-term outlook for the units. Final decisions as to date of retirement will be determined by management on a unit by unit basis.” (See SC_PR_2-5 Attachment A, page 35 of 616.)
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Based upon these factors, a depreciation accrual rate (on the straight-line basis) is established such that the plant investment in service as of the date of the depreciation study would be completely depreciated by the end of the expected remaining life (in the case of Colstrip Units 3 & 4, 2034 and 2036, respectively). Because depreciation rates must be
approved by the IPUC, depreciation rates are not updated on a continuous basis as time moves closer to the expected end of life; rather, the rates are updated periodically in connection with a formal depreciation study. Each subsequent depreciation study will again synchronize the current depreciation rates with the expected remaining asset lives for each studied FERC account.
Regarding the specific project referenced in this production request, the effective remaining useful life varies depending upon which FERC account or accounts to which the investment is recorded. The referenced projects in requests SC 3-8 through SC 3-13 address projects associated with both Colstrip Units 3 and 4 and both plant accounts 3120
and 3140 (FERC plant accounts 312 and 314). In the Company’s most recently completed depreciation study (which was provided as SC_PR_2-5 Attachment A, see page 47 of 616 therein), the composite remaining lives upon which the depreciation rates for these accounts were established were approximately 21.5 years and 19.4 years, for accounts 312
and 314, respectively, for Colstrip Unit 3, and were approximately 23.3 years and 20.9
years, for accounts 312 and 314, respectively for Colstrip Unit 4.2 The Company is currently in the process of finalizing a new depreciation study and the preliminary results suggest composite remaining lives for these accounts of approximately 16.3 years and 14.9 years (Colstrip Unit 3, accounts 312 and 314, respectively) and 18.2 years and 15.6 years
(Colstrip Unit 4, accounts 312 and 314, respectively).3
f. Avista does not have this information.
2 As the referenced depreciation study was performed as of 12/31/2010, this represents estimated useful lives for Colstrip Unit 3 ending mid-way through 2032 (FERC plant account 312) and mid-way through 2030 (FERC plant account 314); and estimated useful lives for Colstrip Unit 4 ending mid-way through 2034 (FERC plant account 312) and mid-way through 2031 (FERC plant account 314). 3 This represents estimated useful lives ending during 2033 and 2031, respectively, for plant accounts 312 and 314 in Colstrip Unit 3 and useful lives ending during 2035 and 2032, respectively for plant accounts 312 and 314 in Colstrip Unit 4. These are consistent with the previous depreciation study and the expected retirement years of 2034 and 2036 for Colstrip Units 3 and 4, respectively.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club - 3-9 TELEPHONE: [phone]
REQUEST: Reference Avista’s response to SC 1-3, Confidential Attachment G, page 43 of 74. a. What is the construction and operation status of the (“Project ID 10022113”)? If it has not
been completed, when (month and year) does Avista anticipate it will be completed? b. Please provide the dollar amount, if any, from Project ID 10022113 that Avista included in its rate base request in this proceeding AVU-E-17-01?

c. On what date does Avista anticipate Project ID 10022113 was or will be “used and useful”? d. Does Avista anticipate that Project ID 10022113 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not? e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?
RESPONSE: a. Project ID 10022113 has been completed and is in service.
b. This project was completed in June of 2016, included and approved in Avista’ prior 2016 GRC (Case No. AVU-E-16-03), and is therefore currently included in base rates as of January 1, 2017. Therefore this project is not included in the Company’s current base request in this proceeding. The total cost billed from Talen for this project is $648,987.
This total does not include any overheads incurred by Avista.
c. 6/30/2016. d. It is Avista’s belief that the project does not require a PSD permit, because it is regular ongoing maintenance. e. See Avista’s response to SC_PR_3-8 (e)
f. Avista does not have this information.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club - 3-10 TELEPHONE: [phone]
REQUEST: Reference Avista’s response to SC 1-3, Confidential Attachment G, page 2 of 74. a. What is the construction and operation status of the (“Project ID 10019068”)? If it has not
been completed, when (month and year) does Avista anticipate it will be completed? b. Please provide the dollar amount, if any, from Project ID 10019068 that Avista included in its rate base request in this proceeding AVU-E-17-01?

c. On what date does Avista anticipate Project ID 10019068 was or will be “used and useful”? d. Does Avista anticipate that Project ID 10019068 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not? e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?
RESPONSE: a. Project ID 10019068 has been completed and is in service.
b. The total cost from Talen for this project is $133,244. This total does not include any overheads incurred by Avista. c. 6/30/17. d. It is Avista’s belief that the project does not require a PSD permit, because it is regular
ongoing maintenance.
e. See Avista’s response to SC_PR_3-8 (e) f. Avista does not have this information.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club - 3-11 TELEPHONE: [phone]
REQUEST: Reference Avista’s response to SC 1-3, Confidential Attachment G, page 3 of 74. a. What is the construction and operation status of the (“Project ID 10019069”)? If it has not
been completed, when (month and year) does Avista anticipate it will be completed? b. Please provide the dollar amount, if any, from Project ID 10019069 that Avista included in its rate base request in this proceeding AVU-E-17-01?

c. On what date does Avista anticipate Project ID 10019069 was or will be “used and useful”? d. Does Avista anticipate that Project ID 10019069 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not? e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?
RESPONSE: a. Project ID 10019069 has been completed and is in service. b. The total cost from Talen for this project is $132,992. This total does not include any overheads incurred by Avista. c. 6/30/17.
d. It is Avista’s belief that the project does not require a PSD permit, because it is regular
ongoing maintenance. e. See Avista’s response to SC_PR_3-8 (e) f. Avista does not have this information.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club - 3-12 TELEPHONE: [phone]
REQUEST: Reference Avista’s response to SC 1-3, Confidential Attachment G, page 6 of 74. a. What is the construction and operation status of the (“Project ID 10022077”)? If it has not
been completed, when (month and year) does Avista anticipate it will be completed? b. Please provide the dollar amount, if any, from Project ID 10022077 that Avista included in its rate base request in this proceeding AVU-E-17-01?

c. On what date does Avista anticipate Project ID 10022077 was or will be “used and useful”? d. Does Avista anticipate that Project ID 10022077 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not? e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?
RESPONSE: a. Project ID 10022111 has been completed and is in service. b. This project was completed in June of 2016, included and approved in Avista’ prior 2016 GRC (Case No. AVU-E-16-03), and is therefore currently included in base rates as of January 1, 2017. Therefore this project is not included in the Company’s current base
request in this proceeding. The total cost from Talen for this project is $344,287. This total
does not include any overheads incurred by Avista. c. 6/30/16. d. It is Avista’s belief that the project does not require a PSD permit, because it is regular ongoing maintenance.
e. See Avista’s response to SC_PR_3-8 (e)
f. Avista does not have this information.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 09/22/2017 CASE NO: AVU-E-17-01/AVU-G-17-01 WITNESS: Scott Kinney
REQUESTER: Sierra Club RESPONDER: Thomas Dempsey TYPE: Production Request DEPARTMENT: Thermal Operations REQUEST NO.: Sierra Club – 3-13 TELEPHONE: [phone]
REQUEST: Reference Avista’s response to SC 1-3, Confidential Attachment G, page 7 of 74. a. What is the construction and operation status of the (“Project ID 10022078”)? If it has not
been completed, when (month and year) does Avista anticipate it will be completed? b. Please provide the dollar amount, if any, from Project ID 10022078 that Avista included in its rate base request in this proceeding AVU-E-17-01?

c. On what date does Avista anticipate Project ID 10022078 was or will be “used and useful”? d. Does Avista anticipate that Project ID 10022078 does or will require a prevention of
significant deterioration (“PSD”) permit under the Clean Air Act’s New Source Review
program? If not, why not? e. What is the estimated useful life of this project?
f. How long has the component that is being replaced been in operation?
RESPONSE: a. Project ID 10022078 has been completed and is in service.
b. This project was completed in June of 2016, included and approved in Avista’ prior 2016 GRC (Case No. AVU-E-16-03), and is therefore currently included in base rates as of January 1, 2017. Therefore this project is not included in the Company’s current base request in this proceeding. The total cost from Talen for this project is $346,706. This total
does not include any overheads incurred by Avista.
c. 6/30/16. d. It is Avista’s belief that the project does not require a PSD permit, because it is regular ongoing maintenance. e. See Avista’s response to SC_PR_3-8 (e)
f. Avista does not have this information.