20180613Avista to Sierra Club 1-8.pdf

JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORP.
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED:
AVU.E- I 8-03/AVU-G- 1 8-02 WITNES S :
Siena Club RESPONDER:
Production Request DEPT:
SC _ 1-I TELEPHONE:
EMAIL:
REC E I VED
oercerf)j1siiJii l3 Atl l0: l2
N/A ri:tr-lC
Paul Kimbr11,- " ,1:Il5sf t,f .
Regulatory Affairs
(s0e) 4es-4s84
paul.kimball@avistacorp. com
REQUEST:
Provide electronic copies ofall data requests and responses received from or sent to other parties in
this proceeding. If electronic copies are not available, please contact counsel for Sierra Club to
coordinate response. This is an ongoing request.
RESPONSE:
To date Avista has not had any other data requests however, Avista will continue to provide copies
of data requests, along with corresponding data responses, from all parties to this proceeding as they
are completed.
Page I of I
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORP.
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED:
AVU-E- 1 8-03/AVU-G- 1 8-02 WITNESS :
Sierra Club RESPONDER:
Production Request DEPT:
SC _ 1-2 TELEPHONE:
EMAIL:
RTSEIVEI)
06t0612018:ii rii:, lI BH l0: lZN/A {_!r } u r, ui {
Paul Kimball ,1 ' ,i,: , .;iii-li:l
Regulatory Affaiis' fl I r :ii iii ISS ICI:l
(s09) 49s-4s84
paul.kimball@avistacorp. com
REQUEST:
Provide all confidential testimony and exhibits included in Avista's application.
RESPONSE:
Avista has not filed any testimony in this docket.
Page I of I
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Sierra Club
Production Request
sc - 1-3
R[CriVEI)
DATE PREPARED: 0610612018WITNESS: N/A i*i*.j:lii 13 ,{l{ l0: 12RESPONDER: Thomas Dempgey
DEPARTMENT: Mgr. Thelryra!,-Ops-;",1.it-i1)
TELEPHONE: tSOgl +gs-qg6O:'i .:ir'1fF"ll$sl0H
REQUEST:
When does the currently applicable coal supply agreement for Colstrip Units 3 and 4 terminate?
Provide a narrative description of the status of any negotiations or discussions regarding the
extension of any currently applicable coal supply contract(s) for Colstrip Units 3 and 4. Provide
any documents prepared by or for Avista summarizing these negotiations or discussions
RESPONSE:
Please see Avista's response 1-3C, 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 current coal supply agreement for Colstrip Units 3 & 4 expires December 31,2019
The plant ownership group and WECO have engaged a number of times over previous years to
negotiate a new coal supply agreement for Colstrip Units 3 & 4, but a final agreement has not yet
been achieved. The plant ownership group is currently evaluating several issues, including areas
to be mined and duration of the term of any new agreement. The owners expect to continue to
work with WECO to determine the best course of action.
Avista objects to the request for further information summarizing the negotiations or discussions
to the extent that it seeks information that is subject to attorney-client, attorney work product, or
similar privilege. Without waiving the foregoing objection, Avista provides the following
response:
SC_PR_I-3C Confidential Attachment A -*20150618 Operations Council.pptx" is a presentation
prepared by Thomas Dempsey and given to Avista's Operations Council on June 18,2015.
SC_PR_l-3C Confidential Attachment B - *20160919 RMC Meeting.pptx" is a presentation
prepared by Thomas Dempsey and given to Avista's Risk Management Committee on September
19,2016.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- 1 8-02
Sierra Club
Production Request
sc - 1-4
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
o6to6t2dfrc I l\,/ED
N/A, .,
ir,J*',ti sul,{,fl..gtt Io: I 2
Mgr. Thgrrnal Offt.ii;
(509)' 495-4960 ) i'i l,r ! l:;$ I O F,l
REQUEST:
By what date does Avista and/or the Rosebud mine owner expect that the Rosebud mine's
currently permitted coal reserves will be exhausted?
RESPONSE:
We cannot speak for the Rosebud mine owner regarding its estimate of when the permitted
reserves will be exhausted. Avista expects that the currently permitted reserves will be adequate
for the current contract as well as adequate for the terms being considered for an extension of the
existing contract or a new contract.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- r 8-02
Sierra Club
Production Request
sc - l-5
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
RT C I IVEt)
06106120t8N/A l0ll] .jtj[.,t t3 fiffi l0: t3
Thomas Dempsey
Mgr.
(s0e)
Thermal Ops .i ,,,,,,,.,,495-4960 ' r'';"'
REQUEST:
Does Avista anticipate that all of the currently permitted coal supply at the Rosebud mine will be
economically feasible to extract? If not, when does Avista expect the currently permitted coal
reserve to become uneconomic for use at Colstrip Units 3 and 4? Please explain who bears the risk
(i.e. Avista or Westmoreland) for any potential increase in coal extraction costs in the event the
mine's permitted reserves become more expensive to extract.
RESPONSE:
Avista does anticipate that all of the currently permitted coal reserves will be economically
feasible to extract; however, economic feasibility depends heavily on unknown factors, such as
wholesale market prices.
The current contract construct is a o'cost plus" contract that does not require the ownership group to
purchase uneconomic coal, with the exception of a circumstance where we (Avista) would be
required to supply coal to meet its minimum obligation. So, for example, if one of the other
owners wanted the unit online and their share of generation was below the minimum load allowed
on the unit, the other owners would be required to supply their proportionate share of fuel (ao'minimum take" obligation) so as to meet the total unit minimum output. Since the current coal
supply agreement is a "cost-plus" construct, the owners bear the risk of coal extraction cost
increases. If all owners agree, the owners do have the ability to shut down the units when they are
not economic and, under such circumstances, no owner would have a "minimum take" obligation
to the mine.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- I 8-02
Sierra Club
Production Request
sc - l-6
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
r i: n trlvED
06/06120lg r'\ '|-- rJ r
N/A ruffi,rlili l3 frt"l lo: l3r nomas uempsey
Mgr. Therm4l Qps", r, -, ;*l.l#
(509) 495'i4960: ::' r':-r ;,,1 ful i S $ I 0 i'l
REQUEST:
Provide Avista's understanding of the status of any efforts by the Rosebud mine owner to obtain
permits to expand the Rosebud mine. Please provide a narrative description of the impact on
available coal supply of any such efforts and the expected timing of any required development.
Provide any documents prepared by or for Avista summarizing these permitting and/or expansion
efforts.
RESPONSE:
It is Avista's understanding that the mine owner is currently in a permitting process for Area F
and Area G of the Rosebud Mine. Permitting of these areas would result in a significant increase
in permitted coal. Avista does have an expectation that Area F will be permitted in late 2018 or
2019 but these processes are uncertain and depend on unknown agency timelines, etc. Avista
does not have a reasonable time estimate for Area G at this time. Please see Attachments A and B
provided in the Company's response to SC - 1-3.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION: IDAHO
CASE NO: AVU-E-I8-03/AVU-G-18-02
REQUESTER: Sierra ClubTYPE: Production Request
REQUEST NO.: SC - 1-7
Flf:Cf lVE[)
DATE PREPARED: 0610612018WITNESS: N/A i0tt -iii;; tl f,H l0: I 3RESPONDER: Thomas Dempsey
DEPARTMENT: Mgr. Thermal.Opi _., I :,.tlr-l,ig.,^,
TELEPHONE: [phone]'0 ' ' -' ';rrr'j'irdlrui
REQUEST:
Please describe how a bankruptcy by Westmoreland Coal Company could impact the coal supply
to Colstrip Units 3 and 4. Provide any documents prepared by or for Avista that address any
contingency plans in the event of a Westmoreland Coal Company bankruptcy.
RESPONSE:
Avista does not have sufficient information to know all of the various potential impacts that a
Westmoreland Coal Company bankruptcy could have to the coal supply to Colstrip Units 3 and 4.
Any response to this request would, therefore, be speculative. Avista does not have any
documents responsive to this request.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- l 8-03/AVU-G- l 8-02
Sierra Club
Production Request
sc - 1-8
P.E f, =.IVED
DATE PREPARED: 0610612018
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
tilt$v${ l3 Al{ l0: lt+
Thomas
Mgr,ON(s0e)
REQUEST:
Has Avista or any of the Colstrip Unit 3 and 4 co-owners explored the potential of Colstrip Units 3
and 4 to receive coal from a supplier other than the Rosebud mine? If yes, please describe the cost
and feasibility of such alternative supplies. Provide any documents prepared by or for Avista
addressing such potential alternative coal supplies.
RESPONSE:
Avista has not prepared any documents addressing such potential alternative coal supplies.
Alternate supplies were considered by the Mine Operating Committee a number of years ago when
evaluation of long term fuel supply options was initiated. Alternative options were ultimately
determined to be unfeasible for a number of reasons such as large transportation costs associated
with rail supply and also because the Title V air permit allows only for Rosebud seam coal to be
used:
From the Title V Operating Permit: A.15. In accordance with the
conditional certification of Colstrip Units #3 and #4 made pursuant to
Section 70-810 (L), Revised Code of Montana (R.C.M) 1947 of the Major
Facility Siting Act (MFSA), Talen shall utilize only coal from the Rosebud
seam within Units #3 and #4 (Boord of Health and Environmental Sciences
(BHES) Findings of Fact and Conclusions of Low signed on November 21,
1975; this requirement is "State-Only").