20190730Staff 110-148 to Avista.pdf

EDWARD JEWELL
JOHN R HAMMOND JR
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t4t (208) 334-03s7
IDAHO BAR NO. 104461 5470
RECEIVED
?fi19 iUL 3il Pll tr: 55
, , ii:ii;i,l.,itsioH
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES FOR ELECTRIC
SERVICE IN IDAHO.
CASE NO. AVU-E.19.04
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAF'F TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
John R. Hammond Jr., Deputy Attomey General, request that Avista Corporation (Company)
provide the following documents and information as soon as possible, or by TUESDAY,
AUGUST 20,2019.
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
FOURTH PRODUCTION REQUEST
TO AVISTA
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I JULY 30,2OI9
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0r.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. 110: In response to Staff Production Request No. 70, the Company
explained that the Company did not conduct an Adams Neilson Solar Project (Adams Neilson)
cost-benefit analysis for Idaho customers because it was a Washington-only project. Please
respond to the following:
a. Please confirm or deny that the Company's intent is to exclude the cost of the
project in Idaho base rates and actual Net Power Cost Q.{PC) in the Power Cost
Adjustment (PCA). Please explain.
b. If the Company's intent is to exclude the cost of Adams Neilson in base rates,
please explain how the Company has removed NPC associated with Adams
Neilson out of base rates including any adjustments that Company made to the
Company's AURORA model run establishing NPC in this case.
c. Please explain how the cost of Adams Neilson is removed from base rates in
Schedule 6, Exhibit No. 7, of Clint Kalich's Confidential"2018 Idaho Power
Supply Adjustment (Apr 2019)" Confidential Workpapers.
d. If the Company's intent is to exclude actual NPC associated with Adams Neilson
and given the method that the Company plans to use to remove the cost of Adams
Neilson from base rates, please explain how actual NPC will be adjusted or
removed in the Company's PCA. Include all workpapers with operational
formulas.
REQUEST NO. 111: Please provide a copy of the Purchased Power Agreement (PPA)
for Adams Neilson.
REQUEST NO. 112: Please provide pro forma net power cost adjustments and the
corresponding revenue requirement reduction if Palouse Wind Project (Palouse Wind) and
Rattlesnake Flats Wind Farm (Rattlesnake Wind), in combination are taken out of the AURORA
FOURTH PRODUCTION REQUEST
TO AVISTA 2 JULY 3O,2OI9
model to calculate proposed base rates. Please provide AURORA model results and updated
confidential and non-confidential schedules in Mr. Kalich's Exhibit No. 7.
REQUEST NO. 113: Please describe the method and calculations used to develop the
levelized contract price for the Rattlesnake Wind PPA. Please include all assumptions and a
description of each assumption used in the calculations.
REQUEST NO. 114: For Rattlesnake Wind, please provide the yearly non-levelized
contract price over the life of the PPA. Include all data, assumptions and a description of each
assumption used in the calculations in Excel format with all working formulas intact.
REQUEST NO. 115: Regarding Rattlesnake Wind, please provide the following data
and information (in Excel format with all working calculations intact) from the Company's 2017
IRP AURORA runs that generated electricity market prices (See 2017 IRP page l0-21: 500
Monte Carlo runs that generated electricity market prices) for each of the three CO2 cases
(Expected, social cost of carbon, and the benchmarking case excluding a cost of carbon - 2017
IRP, page l0-20):
a. For the period that Rattlesnake Wind will be in operation during the 2017 IRP
planning timeframe, please provide the percentage of market prices generated
from the 500 Monte Carlo simulation runs that are LESS than the non-levelized
contract price for each year for each ofthe carbon futures.
b. For the period that Rattlesnake Wind will be in operation during the 2017 IRP
planning timeframe, please provide the average annual market prices generated
from the 500 Monte Carlo simulation runs that are LESS than the non-levelized
contract price for each year for each ofthe carbon futures.
c. For the period that Rattlesnake Wind will be in operation during the 2017 IRP
planning timeframe, please provide the percentage of market prices generated
from the 500 Monte Carlo simulation runs that are GREATER than the non-
levelized contract price for each year for each ofthe carbon futures.
d. For the period that Rattlesnake Wind will be in operation during the 2017 IRP
planning timeframe, please provide the average annual market prices generated
FOURTH PRODUCTION REQUEST
TO AVISTA J JULY 30,2019
from the 500 Monte Carlo simulation runs that are GREATER than the non-
levelized contract price for each year for each ofthe carbon futures.
e. Please provide the data used to generate the Mid-Columbia Electric Price Forecast
Range graph (as illustrated in figure 10.14, page 10-21in the 2017 IRP) for each
of the carbon futures.
REQUEST NO. 116: Please provide the data used to generate the Stanfield Natural Gas
Distributions graph (as illustrated in f,rgure 10.10, page 10-14 in the 2017 IRP) in Excel format
with all working formula intact.
REQUEST NO. 117: Please provide the statistical parameters for the lognormal
distribution(s) used to model natural gas prices in the Monte Carlo simulations that determined
electricity prices in the 2017 IRP (see pages 10-12 through l0-14). Please explain how these
distributions were derived and why these parameters and distributions are appropriate.
REQUEST NO. 118: Please provide the pro forma net power cost adjustment and
corresponding revenue requirement reduction if Rattlesnake Wind is taken out of the AURORA
model to calculate proposed base rates. Please provide AURORA model results and updated
confidential and non-confidential schedules contained in Mr. Kalich's Exhibit No. 7 workpapers.
REQUEST NO. 119: PageT of Mr. Kinney's Direct Testimony states that "Avista
signed two Power Purchase Agreements (PPA) for 20 MW of solar starting in December of 201 8
(Adams-Neilson) and 145 MW of wind starting in late 2020 (Rattlesnake Flat)." For each of
these two projects, please answer the following questions:
a. Please explain when and how Avista plans to recover the associated costs?
b. Please explain how the RECs will be utilized?
c. Please explain how the RECs will be assigned/allocated?
d. Please explain why the proposed recovery treatment is reasonable for Idaho
customers?
FOURTH PRODUCTION REQUEST
TO AVISTA 4 JULY 3O,2OI9
REQUEST NO. 120: Page 13 of Mr. Kinney's Direct Testimony states that "Several
changes in the market and price for renewable generation prompted Avista to issue an RFP for
additional renewable resources without a self-build option". Please explain why the RFP did not
consider a self-build option? Please provide evidence to support your answer.
REQUEST NO. 121: According to the Rattlesnake Wind PPA the Company and the
developer have allowed curtailment under certain circumstances. Are there any situations that
the Company can or will curtail generation from Rattlesnake Wind due to market prices or the
Company's own generation resources being less expensive? Does the Company consider this a
"must-run" resource? Please explain.
REQUEST NO. 122: Please explain if/how Avista intends to pass costs and/or benef,rts
of any form of Liquidated Damages, for Output Shortfall on to customers. Rattlesnake Wind
PPA, Section 5.3, 6.6 and24.12.
REQUEST NO. 123: Please explain the current need for Palouse Wind in the
Company's system.
REQUEST NO. 124: Does the Company's first capacity and energy deficit year of 2026
in the 2017 IRP consider capacity and energy contribution from Palouse Wind? Please explain.
Also answer the following:
a. If it does, how much is the contribution from Palouse Wind?
b. What would the first capacity and energy deficit years be if Palouse Wind
contribution is not considered?
REQUEST NO. 125: Please provide the pro forma net power cost adjustment and
corresponding revenue requirement reduction if Palouse Wind is taken out of the AURORA
model to calculate proposed base rates. Please provide AURORA model results and updated
confidential and non-confidential schedules contained in Mr. Kalich's Exhibit No. 7 workpapers.
FOURTH PRODUCTION REQUEST
TO AVISTA 5 JULY 30,2019
REQUEST NO. 126: Please provide historic monthly generation of Palouse Wind from
the start of operation through the most recent full month of operation. Please also provide the
expected monthly generation of Palouse Wind from the most recent full month of operation to
the end of the PPA.
REQUEST NO. 127: Please provide historic monthly mid-C market prices from the
start of operation of Palouse Wind through the most recent full month of operation and the
expected monthly mid-C market prices from the most recent full month of operation to the end of
the PPA.
REQUEST NO. 128: Please provide a copy of the Palouse Wind PPA.
REQUEST NO. 129: Please provide natural gas forward prices of all hubs used in
AURORA for January 2020 through December 2020 contract months on settlement dates from
July 1 ,2019 to July 31,2019.
REQUEST NO. 130: Page 1 of Mr. Kalich's Schedule 2C, Exhibit No. 7 lists dispatch
model results. Please provide the following:
a. Are the generation amounts of Palouse Wind based on historical data? Please
explain how the numbers were derived or calculated and provide workpapers with
all formulas intact.
b. The generation amount of Rattlesnake Wind in December in the dispatch model
results is 4 gigawatt hours lower than that listed in the original PPA included in
Mr. Kinney's Schedule 4C of Exhibit No. 5. Please reconcile the difference.
REQUEST NO. 131: Please provide a comprehensive map with legend detailing
Rattlesnake Wind including:
a. The wind farm project;
b. Rattlesnake Wind interconnection point;
c. The transmission customer's interconnection (paid by the developer);
FOURTH PRODUCTION REQUEST
TO AVISTA 6 JULY 30,2079
d. All network upgrades, including new required transmission upgrades, substation
upgrades, etc. included in the $12,91 1,000 cost (Rosenstrater, Di, p.20) attributed
to Rattlesnake Wind;
e. The existing transmission system in the surrounding arca (identify Company
owned transmission); and
f. Alternative transmission capacity identified as "Mitigation alternatives"
considered in Kinney Exhibit-5 Schedules 4C (page 186 of 207) - Confidential.
REQUEST NO. 132: If Rattlesnake Wind does not exist, what specific network system
upgrades or other investments included in the $12,91 1,000 cost (Rosenstrater, Di, p.20)
attributed to the project would not be needed? Please provide a detailed list with associated
costs.
REQUEST NO. 133: Please provide the PPA contract price impact when the costs in
the above Production Request are included.
REQUEST NO. 134: For each of the Company identified upgrades identified in the
previous request, please provide a description of the upgrade and explain the specific
need/benefits, timing of the need, and an itemized breakdown of each upgrade cost.
REQUEST NO. 135: Regarding the interconnection from the Company's existing
system to Rattlesnake Wind interconnection point, please provide the following:
a. Explain how the Company evaluated the different alternatives and the economic
tradeoffs such as wheeling costs versus Company capital investment and other
such tradeoffs.
b. The Company's justification for selecting the preferred alternative.
c. The workpapers used to evaluate and ultimately select the alternative.
FOURTH PRODUCTION REQUEST
TO AVISTA 7 JULY 3O,2OI9
REQUEST NO. 136: Please provide a copy of the project contract(s), construction
organization charts, construction schedules (baseline vs. actual), project status reports, action
item lists, and change orders for the plant investment project listed as Little Falls Powerhouse
Redevelopment - $9,047,000.
REQUEST NO. 137: In Thackston DI (page 7),for the Long Lake Plant Upgrades
please provide the revenue requirement based on the corrected capital addition amount.
REQUEST NO. 138: In Thackston DI (page 8), for the Generation DC Supplied System
Upgrade please provide the revenue requirement based on the corrected capital addition amount.
REQUEST NO. 139: In Thackston DI (page 9), please explain the basis for deferring
the Cabinet Gorge HED Service Station Replacement project until 2020 relative to other capital
projects.
REQUEST NO. 140: For the Resource Metering, Telemetry, and Controls Upgrade
capital project referenced in Thackston Schedule 1, page 80 and 81 please provide copies ofthe
results, specifications, and report from the metering engineer.
REQUEST NO. 141: For the Resource Metering, Telemetry, and Controls Upgrade
capital project referenced in Thackston Schedule l, pages 80 and 81, please provide copies ofthe
final report laying out actual costs to make the Avista generation fleet metering, controls and
telemetry in compliance with CAISO standards.
REQUEST NO. 142: For the Resource Metering, Telemetry, and Controls Upgrade
capital project referenced in Thackston Schedule 1, pages 80 and 81, please provide the
Company's analysis to prioritize the metering upgrade at generating plants based on plants that
are currently being used to fulfill merchant positions in California and those plants that could be
used to supply potential non-EIM market services in the near future.
FOURTH PRODUCTION REQUEST
TO AVISTA 8 JULY 3O,2OI9
REQUEST NO. 143: Please provide a list of substations included in the Business Case
Narrative for the New Distribution Station Capacity Program. Please provide the location,
description, and high level cost breakdown for the distribution substations that were built from
January 2017 through the current month, and include the projected date of construction for new
substations to2026. Rosentrater Schedule 3 at92.
REQUEST NO. 144: Please provide a list of substations included in the Business Case
Narrative for the Substation Rebuilds Program. Please detail the proposed work to be performed
with dates, and include descriptions and cost estimates. Rosentrater Schedule 3 at 66.
REQUEST NO. 145: Please provide the workpapers used to calculate historic averages
for the Storms Transmission Capital Investment Business Case. Rosentrater Schedule 3 at 63.
REQUEST NO. 146: Please identify the number of street lights, by rate schedule and by
fixture and size, that are expected to be affected by the LED Change Out Program discussed in
Ms. Heather Rosentrater's direct testimony (pages l4-15). Please explain when the installations
are scheduled to occur.
REQUEST NO. 147: Please quantify the kWh savings by rate schedule, per light by
fixture and size (i.e., per unit savings) and in aggregate, for the LED Change Out Program.
REQUEST NO. 148: Please quantify the expected annual dollar net savings by rate
schedule for the LED Change Out Program, detailing the change in annualized fixed costs
(capital investment and fixed O&M) and offsetting annual variable cost (fuel, incremental O&M)
savings.
a. Please list all assumptions made in annualizing costs, including but not limited to:
federal and state income tax rates, tax incentives, depreciation assumptions, book
and tax lives, property taxes and salvage values. Please provide workpapers, in
Excel, formulae intact. If available, please provide these results by rate schedule
on a per unit basis, by fixture and size, and on an aggregate basis.
FOURTH PRODUCTION REQUEST
TO AVISTA 9 JULY 3O,2OI9
b. If not available in the format described, please provide the Company's net benefit
analysis for the LED Change Out Program.
Dated at Boise, Idaho, this 3oLau,of July 2019.
Jr
Attorney General
i:umisc:prodreq/avue I 9.4ejyyrk prod req4
FOURTH PRODUCTION REQUEST
TO AVISTA 10 JULY 3O,2OI9
I HEREBY CERTIFY THAT I HAVE THIS 30th DAY OF JULY 2019,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-19-04,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
E-MAIL: Iratrick.chrbar(0tavistacorp.conr
a vi stad ockets (4ayi61qEalp.qa m
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL: ron(n)w.illiams bradburv.corn
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: peter(4)richardsonadams.com
NORMAN M SEMANKO
PARSONS BEHLE & LATIMER
8OO W MAIN ST STE I3OO
BOISE ID 83702
E-MAIL: usemanko/3)parsonsbehle.corn
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL : botto(lliidahoconservation.org
DAVID J MEYER
VP & CHIEF COLTNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E_MAIL : clavid.mcyerl;Aavi stacorp.cotn
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 83716
E-MAIL: dcanjmiller(g)cableonc.net
VICKI M BALDWIN
PARSONS BEHLE & LATIMER
201 S MAIN ST STE 18OO
SALT LAKE CITY UT 84I1I
E-MAIL: vbald cotn
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: brnpLrrcly(rDhotmail.com
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : clreadin g(lDrnindspring.com
ELECTRONIC ONLY
crou I e.r, I al4)ao l. corn
carol.haugen(J)clearruraterrraper.corn
terry. borden(g)c I e arr.vatcr rrapcr. c om
nrali sa.maynard @clearr,vaterpaper. corn
Sterrhen. chri ssG)weilmarrl. com
CERTIFICATE OF SERVICE