20190821Avista to Staff Supplemental 87-148.pdf

Avista Corp.
141 1 East Mission P .O . Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
Afr'tnsrfr
RECEIVED
i0l9 AUE 2l All 9: 2l
August 20,2019 i I r Ji?ittt'fslif* l8r' *
Idaho Public Utilities Commission
472W. Washington St.
Boise,lD 83702-0074
Attn: Edward Jewell
Deputy Attorney General
Re: Production Request of the Commission Staff in Case Nos. AVU-E-19-04
Dear Mr. Jewell,
Enclosed are Avista's responses to IPUC Staffs production requests in the above referenced
dockets. Included in this mailing are the original and two poper copies of Avista's responses to
production requests: Staff 87 Supplemental, 110-143 & 145-148. Also enclosed on three separate
CD's are copies of Avista's responses to the production requests. The electronic versions of the
responses were emailed on 08120119.
Also included both on paper and on a separate CD are Avista's CONFIDENTIAL responses to PR
111C, 112C,115C, 116C, ll7c, LL8c, 125C,126C,127C,128C,129C,130C & 143C. This
response contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and
is separately filed under IDAPA 31.01.01, Rule 067 and233, and Section 9-340D,Idaho Code. It
is being provided under a sealed separate envelope, marked CONFIDENTIAL.
If there are any questions regarding the enclosed information, please contact Paul Kimball at (509)
495-4584 or via e-mail at [e-mail].
Manager of Compliance & Discovery
Enclosures
CC (Email):IPUC (Hanian)
Idaho Forest Group (Miller, Williams, Crowley)
Corp.
Sincerely,.,/
Paul
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-87 Supplemental
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: Scott Kinney
DEPARTMENT: Power SupplyTELEPHoNE: (509) 49s-4494
REQUEST:
Please provide a detailed description of software, upgrades, and equipment needed for
participation in the Energy Imbalance Market. Please describe the Capital Investment Project/s
where all EIM related software/systems, upgrades, and equipment are included.
SUPPLEMENTAL RESPONSE:
No costs associated with EIM are included in this case. The costs originally included have shifted
to2020. Avista's Supplemental response "Staff-DR-067 Supplemental 1 Revised" filed on
August 15 , 2019 included the updated capital transfers to plant for 2079 , which excluded the EIM
capital projects shifted to 2020.
RESPONSE:
Please see Avista's response 87C, 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.
In the fall of 2018 Avista worked with Utilicast (an EIM consultanQ to develop a technology road
map, metering and controls assessment, EIM project plan, and estimated costs for Avista to
participate in the Western Energy Imbalance Market (EIM). See attached reports titled "Avista -
Technology Assessment - Summary Report - final" and "Avista - Metering Assessment -
Summary Report - Final" included as Staff PR_087C Confidential Attachments A-C. The
technology plan describes the different software applications that Avista needs to acquire or
modiff in order to successfully participate in the EIM. Avista is currently working with Utilicast
to develop request for proposals (RFP) for each of the required software applications. Avista plans
to initiate all of the RFPs and possibly select some vendors by the end of 2019. Upon selection of
all vendors and applications in early 2020, Avista plans to create an EIM technology summary
document to describe all selected applications and update associated schedule and costs. The
metering assessment evaluated the required metering upgrades and replacements, generation
control upgrades, and the associated network requirements at Avista's generation facilities and
transmission substation interconnection points.
The preliminary cost estimates produced in the technology and metering assessments were further
evaluated in the first quarter of 2019 based on additional preliminary project designs and a better
assessment of required labor. This updated evaluation and data was used to create the attached
program charter document "Energy Imbalance Market Program Initiation Chaner_Final
05.17.19." All EIM project requirements, descriptions, and associated cost estimates are included
in the attached documents.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-l l0
DATE PREPARED: 0811612019WITNESS: Clint Kalich
RESPONDER: Liz Andrews
DEPARTMENT: Regulatory Affairs
TELEPHONE: (s09) 495-8601
REQUEST:
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 Washinglon-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 ldaho base rates and actual Net Power Cost (NPC) 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.
RESPONSE:
a. Yes, the Company's intent is to exclude the cost of the project in Idaho base rates and
actual Net Power Cost (NPC) in the Power Cost Adjustment (PCA). This PPA is dedicated
to WA Solar select customers only. The value of the power and the cost of integration is
charged to a 555 account at a system level, and revenues are charged to a system 447. Solar
Select amounts are adjusted out within actual amounts so that both 555 and 447 are
excluded. On a net system basis, specific solar select amounts net to $0 so that neither the
WA (ERM) or ID (PCA) are impacted - this is done so that no customers are impacted
except direct WA Solar Select Customers.
b. - d. The costs associated with the Company's Adams Neilson Solar Project is excluded
from actual 2018 test period Results of Operations (ROO) and excluded from the Pro
Forma Power Supply Adjustment 3.01 (see Andrews workpaper Adjustment 3.01, excel
file "Kalich WPS Exhibit No. 7
"Adjustment".
Schedules I 2C", tab "Schedule 3" column
During discussions with Staff it came to the Company's attention that Kalich Adjustment
workpapers had inadvertently included the Neilson net power costs in account 456 (Other
electric revenue) rather than account 447 - system *2020 Pro Forma" column. Although
this has no effect on the pro forma power supply adjustment (3.01) proposed to be included
in base rates (only Idaho's share of the actual column, net of the adjustment column is
included), the system *2020 Pro Forma" column net expenses and net revenues are used for
the PCA base (Kalich Exhibit No. 7, Schedule 6) and then allocated to Idaho.
Therefore, although the Nielson 555 expenses was correctly included in system amounts
within the PCA proposed base, this error inadvertently caused the 447 system revenues
account to be understated by the Nielson revenues amount within the PCA proposed base.
Without the offsetting44T Nielson revenues, the impact of the Nielson PPA did not net to
$0 as intended. Attached as Staff DR_l l0 - Attachment A is a revised Kalich workpaper
and Kalich Exhibit No. 7, Schedule 6, correcting the accounts and the PCA base schedule.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-l 1 I
DATE PREPARED: 0812012019
WITNESS: Clint Kalich
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: (509) 49s-8515
REQUEST:
Please provide a copy of the Purchased Power Agreement (PPA) for Adams Neilson.
RESPONSE:
Please see Avista's response 11lC, 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,ldaho Code.
Please see the attached file Staff PR 1l lC Confidential Attachment A.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-1 12
DATE PREPARED: 0812012019WITNESS: Clint Kalich
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 49s-2189
REQUEST:
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 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.
RESPONSE:
Please see Avista's response ll2c, 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 results of the power cost study of removing the impacts of Palouse Wind and Rattlesnake Flats
Wind are included in StaflPR_l l2C Confidential Attachment A. Net system power costs of
removing both projects decrease by $11.854 million ($4.103 million [daho share) without the
Palouse Wind PPA (see StaflPR_l25) and Rattlesnake Flat PPA (see Staff PR_l l8), decreasing
the Company's proposed Idaho allocated net revenue requirementby $4.126 million.
The output Aurora files are included as StaflPR_l12C Confidential Attachment B. If necessary
the change set to view changes in Aurora are also included using the confidential attachment
Staff PR_l12C Confidential Attachment C -
AVA 201 9_ID_GRc_Changeset_Wind_Sensitivies.csf
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-l 1 3
DATE PREPARED: 08109/2019WITNESS: Clint Kalich
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 495-2189
REQUEST:
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.
RESPONSE:
Please see Avista's response 113C, 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.
Please see Staff PR 1 13C.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 19-04
IPUC
Production Request
Staff-l l4
DATE PREPARED: 0812012019WITNESS: Clint Kalich
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Please refer to StafLPR_1 13C for the yearly non-levelized contract price of the Rattlesnake Wind
PPA.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff- I l5
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0810912019
Clint Kalich
James Gall
Energy Resources
(509) 49s-2189
REQUEST:
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 10-21: 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 -2017IRP, 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
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 10.74, page l0-21 in the 2017 IRP) for each of
the carbon futures.
RESPONSE:
Please see Avista's response 115C, 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,ldaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-1 16
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: [phone]
REQUEST:
Please provide the data used to generate the Stanfield Natural Gas Distributions graph (as
illustrated in figure 10.10, page 10-14 in the 2017IRP) in Excel format with all working formula
intact.
RESPONSE:
Please see Avista's response ll6C, 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,ldaho Code.
Please refer to StafLPR_116C Confidential Attachment A for the data used to generate the
Stanfield Natural Gas Distribution graph illustrated in figure 10.10 on page l0-14 in the 2017 IRP.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-l I 7
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
08t20t20t9
Clint Kalich
James Gall
Energy Resources
(s09) 49s-2189
REQUEST:
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.
RESPONSE:
Please see Avista's response ll7c, 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,ldaho Code.
The lognormal distributions used for the 2017 IRP natural gas prices are based on historical
coefficients of variationl of the change in natural gas prices from month to month. Each monthly
period is randomly drawn for each of the 500 iterations using the distribution and the forecasted
monthly change in prices. The attached file "Staff PR_l l7C Confidential Attachment A" includes
the formulas intact for the analysis, although each of the 500 iterations drawn use VBA code to
record its precise result (which is included in the workbook).
' Standard deviation divided by the mean.
Page I of I
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-l I 8
DATE PREPARED: 0812012019WITNESS: Clint Kalich
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 495-2189
REQUEST:
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.
RESPONSE:
Please see Avista's response 118C, 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 results of the power cost study removing the effect of Rattlesnake Wind PPA are included in
StaflPR_l18C Confidential Attachment A. System power costs increase by $152,000 ($53,000
Idaho share) without the Rattlesnake Flat PPA, increasins the Company's proposed Idaho
allocated electric revenue requirement by $53,000.
The output Aurora files are included as StaflPR_I18C Confidential Attachment B. If necessary
the change set to view changes in Aurora are also included using the confidential attachment
StaflPR_l l2C Confidential Attachment C -
AVA_20 I 9_lD_GRc_Changeset_Wind_Sensitivies.csf
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-l I 9
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
08120120t9
Scott Kinney
John Lyons
Energy Resources
(s09) 4es-8s1s
REQUEST:
PageT of Mr. Kinney's Direct Testimony states that "Avista signed two Power Purchase
Agreements (PPA) for20 MW of solar starting in December of 2018 (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?
RESPONSE:
a. The costs of the Adams-Neilson solar PPA are being paid for by the participants in the
Company's voluntary Solar Select program. See Avista's response to Sta[PR_l10.
The costs associated with the Rattlesnake Flat PPA have been pro formed into Avista'
Power Supply adjustment 3.01 as discussed by Mr. Kalich, effective in December 2020.
The impact on this case of including the pro forma net power supply costs associated with
Rattlesnake Flats reduces the proposed revenue requirement by approximately $53,000.
See Avista's response to StaflPR_l l8C.
b. The RECs for the Adams-Neilson solar PPA will be retired on behalf of the participants in
the voluntary Solar Select program for the duration of that program. The RECs produced
by the Rattlesnake Flat PPA will be managed the same way that RECs from the Palouse
Wind PPA are managed. Surplus RECs will either be sold for the benefit of all customers
based on their share of costs and benefits or used for renewable compliance programs in
the State of Washington and ldaho customers will be compensated for their pro rata based
on the average value of the sales of similar RECs by Avista.
c. RECS will be assigned/allocated based on the pro rata costs and benefits under the
Company's Production and Transmission Ratio.
For Rattlesnake Flat, as discussed by Mr. Kinney in his direct testimony starting at page
13, the Company's 2017 Electric IRP identified a need for additional generation resources
beginning in2026 with the expiration of the Lancaster PPA. The Company also uses short
Page I of2
d. The Adams-Nelson Solar PPA is not being requested to be included in Idaho rates for the
duration of the Washington-only Solar Select Program.
term market transactions when economical to replace the dispatch of owned or contracted
for resources. 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, and
the RFP indicated that the Company would consider the acquisition of additional
renewable resources if the resources had lower long-term costs than electric energy market
altematives. Supported indicators at that time included the following: the expiring
Production Tax Credit (PTC) was lowering prices as compared to price quotes after 2020;
other market indicators, such as pricing and developer activity; competing renewable
RFPs; and further advancing renewable technology and competition for least cost
resources.
Specifically, the Company had four main drivers for determining that a new resource was
necessary. First, the expiring PTC was lowering prices as compared to price quotes after
2020 because the PTC is scheduled to be reduced or expire in2020. The Investment Tax
Credit (ITC) is scheduled to do the same in 2022. There is a strong likelihood that the
pricing of additional renewable generation will increase given the decrease and/or
expiration of the PTC and ITC. At the time of the 2018 RFP, many developers had
projects ready to be completed by the end of 2020 that they were offering competitive
pricing to potentially interested parties. Second, other market indicators, such as pricing
and developer activity, also indicated this was an opportune time for issuing an RFP for
additional renewable energy. Developer activity along with industry market insights
provided Avista personnel opportunities to observe and analyze changes in renewable
energy technology and pricing. Indicative and actual pricing for renewables in the
Western United States suggested that renewable resources were competitive in the
wholesale market at the time the 2018 RPF was issued. Indicative pricing provided to
Avista at the time showed falling prices for renewables. Third, competing RFPs indicated
that the timing was good for obtaining additional renewable generation. At the time, other
utilities in the Northwest were actively pursuing renewable resources. Portland General
Electric had issued an RFP, and Puget Sound Energy issued an RFP in June 2018 to
replace the 272 MW expected deficiency from the closure of Colstrip Units 1 and 2 by
2022, as well as 671,000 renewable energy credits beginning in2023 and increasing after
that. This demand for additional resources could create increased competition for
preferred products based on location and ability to site utility-scale projects. Lastl)r, with
the advances of machine technologies and the sun-setting of tax credits, pricing for
renewables had never been lower. Pricing may have been expected to increase if available
tax opportunities were not fully captured before reduction or expiration. See Kinney
testimony for further detail at pages 12 - 18 of his direct testimony.
Page 2 of 2
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-120
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 495-8515
REQUEST:
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 RIP 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.
RESPONSE:
As explained in Mr. Kinney's testimony, the four indicators supporting the release of the RFP for
renewables in 2018 included the expiration of the Production Tax Credit and Investment Tax
Credit, other market indicators including pricing and developer activity, competing RFPs, and
further advancing renewable technology and competition for least cost resources. The Company
did not have any renewable projects or sites in development at the time of this RFP. Also, the
Company's transmission interconnection queue showed that several renewable projects had
finished or were close to finishing the transmission interconnection process so they were well
positioned to take advantage of the expiring tax credits. Prior to the Company issuing its RFP,
both Puget Sound Energy and Portland General Electric had active renewable RFPs which
provided an opportunity for competitive bidding between the developers.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-121
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: (509) 49s-8s1s
REQUEST:
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.
RESPONSE:
No, the Rattlesnake Wind PPA is not a "must-run" resource. The PPA allows for uncompensated
curtailment if the system operator declares a reliability event. The Company may also request
Rattlesnake Flat to curtail generation from the project during non-reliability events in exchange for
the normal PPA rate grossed up to account for the loss of the Production Tax Credit for the amount
of generation curtailed. The decision to curtail the Rattlesnake Wind PPA will be an economic
decision based on market prices and other resources available at that time.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-122
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: [phone]
REQUEST:
Please explain iflhow Avista intends to pass costs and/or benefits of any form of Liquidated
Damages, for Output Shortfall on to customers. Rattlesnake Wind PPA, Section 5.3, 6.6 and
24.12.
RESPONSE:
Any answers at this point in time would be speculative because the response would depend upon
the circumstances and nature of the costs or benefits of liquidated damages, or output shortfall, at
the time of the possible event. The Company would strive to equitably handle the situation after
seeking input from Staff.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff- 123
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0812012019
Scott Kinney
John Lyons
Energy Resources
(s09) 49s-8s l s
REQUEST:
Please explain the current need for Palouse Wind in the Company's system.
RESPONSE:
The Palouse Wind PPA has been part of the Company's resource mix since the project started
commercial operation in December 2012. This resource provides energy and RECs that are used
or monetized for the benefit of customers like any of our generating resources.
As discussed in Mr. Kasich's direct testimony starting at page 74, at the time of the contract
execution, the Palouse Wind purchase was one of, if not the lowest priced, wind resource projects
in the Northwest. The purchase price also compared favorably to the Idaho avoided cost rates at
the time. The 2O-year (2013-2032) levelized cost of Palouse Wind was $63.61/MWh. By
comparison, Avista's Idaho avoided cost rate (effective 813012011), including the wind integration
deduction, for the same period was $67.4IlMWh. The Palouse Wind contract was and remains a
prudent acquisition as a cost-effective, prudent and long term resource acquisition.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-124
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: [phone]s
REQUEST:
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?
RESPONSE:
The Company's first energy deficit of 2026 in the 2017 IRP considers energy from Palouse Wind,
but assigns zero capacity credit to that resource.
a. Palouse Wind contributed 40 aMW of energy and no capacity.
b. The first capacity deficit in the 2017 IRP would remain at2026 without Palouse Wind
because it provided no additional capacity. The energy deficit would have begun in2027
without Palouse Wind.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-125
DATE PREPARED: 0812012019WITNESS: Clint Kalich
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (509) 49s-2189
REQUEST:
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.
RESPONSE:
Please see Avista's response 125C, 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 results of the power cost study removing the effect of Palouse Wind PPA are included in
StaflPR_l25C Confidential Attachment A. System power costs decrease by $12.006 million
($4.155 million Idaho share) without the Palouse Wind PPA, decreasins the Company's Idaho
allocated electric revenue requirement by $4.179 million.
The output Aurora files are included as Staff PR_I25C Confidential Attachment B. If necessary
the change set to view changes in Aurora are also included using the confidential attachment
StaflPR_l12C Conf,rdential Attachment C -
AVA 20 1 9_ID_GRc_Changeset_Wind_Sensitivies.csf.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-126
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: (509) 49s-851s
REQUEST:
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.
RESPONSE:
Please see Avista's response 126C, 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,ldaho Code.
Please refer to StaflPR_l26C Confidential Attachment A for the historic monthly generation of
Palouse Wind and the expected monthly generation through the end of the PPA, which is based on
average historic generation.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-127
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 49s-8515
REQUEST:
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.
RESPONSE:
Please see Avista's response 727C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and exempt from public view and is separately filed under
IDAPA 31.01.01, Rule 067 arfi233,and Section 9-340D,ldaho Code.
Please refer to StaflPR_l27C Confrdential Attachment A for the historic monthly Mid-C prices,
forward Mid-C prices, and forecasted Mid-C market prices through the end of the Palouse Wind
PPA in 1213112042. The forward prices have relatively few trades out past six months. The
forecasted prices are from the draft IRP models.
Page I of I
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-I9-04
IPUC
Production Request
Staff-128
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0812012019
Scott Kinney
John Lyons
Energy Resources
(s09) 49s-8sls
REQUEST:
Please provide a copy of the Palouse Wind PPA.
RESPONSE:
Please see Avista's response 128C, 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.
Please refer to StaflPR_l28C Confidential Attachments A through D for a copy of the Palouse
Wind PPA plus the three amendments to the PPA.
Page I of I
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-129
DATE PREPARED: 0812012019WITNESS: Clint Kalich
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Please see Avista's response 129C, 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.
Please refer to StaflPR_I29C Confidential Attachment A for the 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 3 1,2019.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-130
DATE PREPARED: 0810912019WITNESS: Clint Kalich
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: [phone]
REQUEST:
Page I 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.
RESPONSE:
Please see Avista's response 130C, 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.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO: AVU-E-19-04
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Staff-l3l
DATE PREPARED: 0811412019WITNESSES: Rosentrater/Kinney
RESPONDER: Jeff Schlect
DEPARTMENT: Transmission Services
TELEPHONE: [phone]
REQUEST:
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);
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 area (identify Company
owned transmission); and
f. Alternative transmission capacity identified as "Mitigation alternatives"
considered in Kinney Exhibit-5 Schedules 4C (page 186 of 207) - Conhdential.
RESPONSE:
(a) thru (e): The following maps are provided to illustrate the requested information:
Figure I - Rattlesnake Flat Comprehensive Map
- Blue lines represent existing Avista I l5kV transmission lines
- Red line represents existing Grant County PUD 1 l5kV transmission line
- Push-pin icons represent existing and new (Neilson) switching stations and substations
- Yellow dotted line represents developer's transmission line from the project to the point of
interconnection
Figure 2 - Rattlesnake Flat Developer Site Plan
Detailed site plan providing geographic locations of the wind project (with expected turbine
locations), developer's transmission line, point of interconnection at Neilson Station, and general
project boundary.
Figure 3 - Rattlesnake Flat Project Diagram
One-line diagram, which can be viewed with Figure 1, depicting existing facilities, Network
Upgrades, Transmission Provider Interconnection Facilities, and Interconnection Customer
Interconnection Facilities.
Page I of5
(0: Altemative transmission capacity identified as "Mitigation alternatives" considered in
Kinney Exhibit-5 Schedules 4C (page 186 of 207) - Confidential Alternative
The Generation Integration and Transmission Service Studyfor Avista Load Serving Entity, dated
August 28,2018 ("Study"), does not describe mitigation altematives for the interconnection of any
resource on the Avista Transmission System, but describes mitigation alternatives that may be
necessary to fully integrate resources with respectto Transmission Service, or in scheduling and
delivering the full output of a resource to the Company's major load centers. The new and
upgraded transmission facilities (Interconnection Facilities and Network Upgrades) referenced in
this Production Request are required to provide Interconnection Service for the Rattlesnake Flat
wind project. These facilities are required for the reliable interconnection of the Rattlesnake Flat
project regardless of to whom the output of the project might ultimately be delivered.
Interconnection Service does not in and of itself entail the ability to provide Transmission Service,
as noted in each interconnection study report. With respect to Transmission Service, depending
upon where the output of a resource is to be delivered, there may or may not be additional facilities
or requirements necessary.
With respect to Transmission Service to the Company's bundled retail native load customers from
a resource located in the Othello/Lind area [Section III(b) of the Study], Avista's transmission
group described an issue that would arise "without (1) the Saddle Mountain Station or (2) making
other transmission iurangements. .." (emphasis added). Note that the Company is constructing the
Saddle Mountain Station project for other reliability and load-service requirements, independent
of the interconnection of any resource. The Saddle Mountain Station project is not necessary to
provide Interconnection Service to the Rattlesnake Flat project. Only those upgraded facilities
identified in the Project 49 Facilities Study are specifically necessary to provide Interconnection
Service for Rattlesnake Flat. In order to provide a long-term contractual transmission path from
the Rattlesnake Flat project to the Company's load centers, however, either the Saddle Mountain
Station project needs to be completed or alternative iurangements would have to be made across
third-party systems. The Study identified three mitigation alternatives that would be necessary for
Rattlesnake Flat integration to the Company's load centers only for an interim period if/when the
Saddle Mountain Station is not yet placed in-service.
These potential mitigation alternatives are expressly unrelated to what is required to interconnect
the Rattlesnake Flat project. In other words, the Rattlesnake Flat project will be able to reliably
generate at full output upon completion of its defined Interconnection Facilities and Network
Upgrades without completion of any other project, including the Saddle Mountain Station project.
Where Rattlesnake Flat output is to be scheduled and delivered, however, may create issues with
respect to Transmission Service, which is what the Study addressed.
Page 2 of5
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff- 132
DATE PREPARED: 0811512019WITNESS: Heather Rosentrater
RESPONDER: Randy Gnaedinger
DEPARTMENT: Transmission Services
TELEPHONE: [phone]
REQUEST:
If Rattlesnake Wind does not exist, what specific network system upgrades or other investments
included in the $12,911,000 cost (Rosenstrater, Di, p. 20) attributed to the project would not be
needed? Please provide a detailed list with associated costs.
RESPONSE:
The original filed case estimated $ 12,91 I ,000 to transfer to plant in 2019 for the Rattlesnake Wind
interconnection project. An updated estimate for 2019 transfers to plant was provided in response
to PR-067. Current expected 2019 transfers to plant are also provided, incorporating actual costs
for some completed upgrades. Table I includes a project that was a planned upgrade by the
Company due to asset condition - the Lind-Warden l15 kV Transmission Line rebuild project
would need to be completed regardless of Rattlesnake Flat project integration. Table 2 outlines
those 2019 completed projects that are directly attributable to the Rattlesnake Flat interconnection.
Table 3 shows the project total amount.
Table 1-ect Transfers Planned without Rattlesnake Flat
* - represents an actual cost
Table 2 -ect Transfers Attributable to Rattlesnake Flat
* - represents an actual cost
Table 3 - Total2019 Transfers to Plant
Description ER Filed Case PR-067 Current Expected
Lind-Warden 115
kV line rebuild
2604 $8,795,000 $8,204,697 * $8,998,578
Description ER Filed Case PR-067 Current Expected
2618 $4,116,000 $2,775,000Lind-Neilson 115
kV line rebuild
s2,775,000
2618Neilson 115 kV
station property
$468,000 * $468,000
Lind Station
Capacity Upgrades
2618 $930, I 06
Sub Total $4,116,000 $3,243,000 $4,173,106
Filed Case PR-067 Current Expected
Total $ 12,91 1 ,000 $11,447,697 $13,171,684
The Company included ldaho's share of $11,447,697 in Staff PR_067. Since preparing that
updated pro forma capital adjustment, it was determined that the project costs that will transfer to
plant in 2019 is $13,171,684, which is$7,723,987 more than the Company included in the updated
pro forma capital adjustment. Idaho's share is approximately $600,000. The Company will
update the pro formal capital adjustment in September, including actual transfers to plant through
August 31,2019. This revised amount will be included in that update.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-1 33
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0811912019
Scott Kinney
Steve Silkworth
Power Supply
(s09) 49s-8093
REQUEST:
Please provide the PPA contract price impact when the costs in the above Production Request are
included.
RESPONSE:
With respect to the cost of Network Upgrades associated with Interconnection Service for the
Rattlesnake Flat project (which are not directly assignable to the Interconnection Customer), no
such costs would presumably have an impact upon the actual PPA contract price. When
evaluating multiple resource alternatives under an RFP process, such costs would appropriately be
added to a proposed PPA contract price to properly evaluate the resource relative to other
altematives. Only those costs that are directly assignable to the Interconnection Customer would
presumably have an impact upon the PPA contract price, since the Interconnection Customer
would presumably seek to recover such costs in its PPA pricing.
For purposes of this response, the Company has calculated the overall imputed pricing impact to
the Company's retail native load customers associated with an expected 2019 transfer to plant
figure of $4,173,106 (see response to Staff-132). The pricing impact associated with this
transmission investment is $0.84/MWh. Expected Network Upgrade costs were included as an
adder in evaluating the Rattlesnake Flat project in the Company's RFP, still, Rattlesnake Flat was
more than l0% less expensive than the second place bidder.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
DATE PREPARED: 0811512019WITNESS: Heather Rosentrater
RESPONDER: John Gross
DEPARTMENT: System Planning
TELEPHONE: (s09) 495-4591
REQUEST:
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.
RESPONSE:
Required Network Upgrades are identified during the System Impact Study phase of the Large
Generator Interconnection Process. The schedule and cost of Network Upgrades become further
defined during the Facilities Study phase of the process (and further refined as a project moves to
design and construction). The project component descriptions below are taken from the Project 49
(Rattlesnake Flat) Facilities Study Report. Additional narrative is provided to explain the specific
need/benefit identified in the System Impact Study. The costs provided are current expected 2019
transfer to plant amounts, consistent with the amounts provided in the response to Staff-132.
Those portions of the project that are expected to be placed in-service in2020 are noted.
Transmission Provider Interconnection Facilities (Direct Assigned to Customer)
7.4.2: Collector Substation - engineering, design, procurement and installation of protection
and control
The collector substation is the station constructed by the Ratllesnake Wind project developer
to collect the windfarmfeeders to a single pointfor transformation to I 15 kV. Avista requires
specific protection and control schemes to coordinate with the Avista-owned lerminal at
Neilson Station that connects to the I I 5 kV generator tie line.
2020 Cost
7.6.2: Point of Interconnection Substation (Smart Road) - engineering, design, procurement
and construction for one ( I ) line position, Y, of two (2) I I 5 kV breakers, metering, protection
and control
The Neilson Station (previously referued to as Smart Road) is configured as a three lerminal
ring bus. One of the three line positions is specific to interconnecting the I l5 kV generator
lead line. A three-terminal ring bus allows the generalor and generator lead line to be
operationally disconnecledfrom the Avista system while maintaining service to other
customers. Onelhird of the overall cost of the Neilson Stationwill be directly assigned to the
Rattlesnake Flat project. The total 2019 transfer to plant amount of $468,000 only reJlects the
cost of the station property. The remainder is a 2020 cost.
$ r 56,000
Sabtotal Dbect Assigned Costs - Expected 2019 Transfers to Plant $ 156,000
Transmission Provider Network Upgrades
7.1.1: Rebuild 4.5 miles of 115 kV transmission with Optical Ground Wire (OPGW) from
Smart Road to Lind - permitting, engineering, design, procurement and construction
The existing Lind-llashtucna I l5 kV Transmission Line is constructed with 4/0 ACSR
conductor which does not have adequate capacity for the 144 MW wind proiect to be
s 2,775,000
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-1 34
connected to it. The transmission linefrom Neilson Station to Lind Station must be upgraded
to accommodqte the output of the project. The upgrade consists of a rebuild with Avista's
standard I l5 kV conductor (795 ACSS) to provide the necessary capacity.
7.2.1: Rebuild 22 miles of I 15 kV transmission with OPGW from Lind-Warden - permitting,
engineering, design, procurement and construction
The existing Lind-l{arden I 15 kV Transmission Line is constructed with primarily 7#8 copper
conductor which does not hwe adequate capacity for with the 144 MW wind project to be
connected at the Neilson Station. The normal operating condition of the Company's
Transmission System requires all output from the wind project, minus the amount consumed
by local area load, to Jlow on the Lind-Warden I I5 kV Transmission Line. This line must be
upgraded to reliably interconnect the project. The upgrade consists ofa rebuild ofthe
transmission line with Avista's standqrd I l5 kV conductor (795 ACSS) to provide the
necessary capacity.
$ 8,998,578
7.3.1: Lind Substation capacity upgrades I l5 kV substation - engineering, design,
procurement and installation ofprotection and control
Upgrades to the transmission line relay packages are necessqry at the Lind Stationfor the
Neilson and Warden terminals. The new relay packages allow for necessary relay
coordination and foult detection with the wind project connected to the transmission system.
Installation of modern era relays also allows for the required islanding detection system to
trip the wind project when an islanding condition occurs.
2020 Cost
7.6.1: Point of Interconnection I l5 kV Substation (Smart Road) - engineering, design,
procurement and construction of(2) line positions, protection and conffol
The Neilson Station (previously referred to as Smqrt Road) is configured as a three terminol
ring bus. Two of the three line positions are necessary to interconnecl with the existing Lind -
Washtucna I l5 kV Transmission Line, resulting in a Lind-Neilson line and a
Neilson-Washtucna line. The station is a necessary means of connecting the wind project to
the Avista trqnsmission system. Two-thirds of the overall cost of the Neilson Station will be
will be attributable to Network Upgrades. The 2019 transfer to plant amount of $468,000 onll
reJlects the cost of the station property. The remainder is a 2020 cost.
$ 312,000
7.7.22 Warden Substation capacity upgrades - engineering, design, procurement and
installation of protection and control
Replacement of transmission line terminal equipment to meet or exceed the capacity of the
transmission line conductor is necessary to obtain any increase in capocityfrom a
transmission line rebuild. The Lind terminal at l(arden Station requires equipment
replacement to meet or exceed the capacity of the new 795 ACSS conductor installed with the
Lind-I{arden I l5 kV Transmission Line rebuild.
2020 Cost
7.7.4: Lind substation capacity upgrades - engineering, design, procurement and installation
of protection and control
Replacemenl of transmission line terminal equipment lo meet or exceed the copacity of the
transmission line conductor is necessary to obtain any increase in capacityfrom a
transmission line rebuild. Both the Neilson and Warden terminals at Lind Station require
equipment replacement to meet or exceed the capacity of the new 795 ACSS conductor
installed.for the Lind-I{arden and Lind-Neilson I 15 kV Transmission Line rebuilds.
$ 930,r06
7.8.2: Construct Communications Path(s) for Operation of the (POI) 115 kV Smart Road
switching station - engineering, design, licensing, land acquisition, building construction, and
installation
The new Neilson Station requires integralion into the Avista communication netvvork to
provide the abiliry b operate the station and receiye lelemetry from the wind project.
2020 Cost
Subtotal Network Upgrades - Expected 2019 Transfers to Plant $ 13,015,684
Figure I (a copy of Figure 5 from the Project 49 System Impact Study Report) provides an
illustrative representation of the need for the applicable Network Upgrades. The figure depicts the
transmission line percent loading of applicable facility ratings when Project 49 (Rattlesnake Flat)
is connected to the system prior to any Network Upgrades. All Network Upgrades must be
in-service prior to the project commencing operation.
Figure l: Project 49 Transmission System Performance
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TOTAL_ EXPECTED 2OI9 TRANSFERS TO PLANT
Interconnection Customer Direct Assigned Facilities $ r 56,000
Network Upgrades $ 13,015,684
TOTAL $ 13,171,684
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-135
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0811612019
Heather Rosentrater
Jeff Schlect
Transmission Services
(s0e) 4es-48s1
REQUEST:
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.
RESPONSE:
a. The Company evaluated the different alternatives and the economic tradeoffs such as wheeling
costs versus Company capital investment and other such tradeoffs as follows:
The interconnection of any large generation resource with the Company's transmission system
must follow the Large Generator Interconnection Process established by the Federal Energy
Regulatory Commission, which includes a three-step study process. During the Feasibility Study
and System Impact Study phases, the Company may evaluate different system configurations to
reliably interconnect a proposed generator. The Facilities Study phase primarily incorporates
detailed design, cost estimates and schedule milestones for a given project scope that has been
identified in the System Impact Study phase.
This process, by definition, only addresses the ability of the Company's transmission system to
reliably accommodate the interconnection and operation of a resource; it does not specifically
address Transmission Service, which would be the ability of the Company's transmission system
to accommodate the delivery of the resource's output to a given point or points of delivery. In this
context, when studying Interconnection Service, there is no such thing as an alternative wheeling
arangement or economic tradeoff between capital investment and another option. In situations
when there are multiple plans of service that provide for reliable Interconnection Service (i.e.
multiple options for capital investment, whether on the Company's system or a neighboring
system), the Company must assess the reliability performance level and capital cost of each option.
This would be a basic economic assessment of two or more capital investment options, not of a
capital investment option versus another type of alternative. When assessing the interconnection
of a generation resource, a Transmission Provider is simply assessing whether or not the existing
system can reliably accommodate the interconnection. If not, the study process determines what
new or upgraded facilities are needed to accommodate the interconnection.
Further economic assessment, such as alternative transmission paths, providing firm versus
conditional firm transmission capacity, resource redispatch options, etc. may come into play when
Page I of8
studying Transmission Service, but not Interconnection Service. For example, in its response to
Staff-I33(f), the Company discusses a report (the Generation Integration and Transmission
Service Studyfor Avista Load Serving Entity) that assessed alternative means of providing interim
Transmission Service for the full output of the Rattlesnake Flat project.
b. The Company's justification for selecting the preferred alternative is as follows:
The Company's preferred plan of service to provide Interconnection Service to the Rattlesnake
Flat 144 MW wind project was determined to be the lowest cost alternative that met all
performance and reliability requirements. The Rattlesnake Wind project was proposed by three
different developers over a period of seven years from 201 1 to 2017 . These projects were studied
under generation interconnection queue positions #33, #43, and #49. Each request proposed
different sized projects, ranging from 400 MW down to 144 MW. (See
Staf IPR_ 1 3 5 -Attachments A-D. )
Over the course of these studies, the two primary altematives for interconnecting the Rattlesnake
Flat project were to rebuild Lind Station, for a point of interconnection at Lind Station, or to
construct a new station at a point of interconnection on the Lind-Washtucna line. During the
applicable study phases, project alternatives that included a Lind Station rebuild were estimated to
cost from $21-$22 million. The project alternative to construct a new station on the
Lind-Washtucna line (the current Neilson Station, originally referred to as Smart Station) was
estimated to cost $17.3 million. The upgrade to the Lind-Warden l15 kV Transmission Line,
already in the Company's plan under the asset condition driver, was required for either alternative.
c.The workpapers used to evaluate and ultimately select the alternative is as follows
The Company is providing the completed study reports for each of these projects.
Project #33 Feasibility Study Report (400 MW request, studied at various levels) -
StaflPR_l 35 Attachment A.
Project #43 Feasibility Study Report (150 MW request) - StaflPR_135 Attachment B.
Project #43 System Impact Study Report (150 MW request) - StaflPR_l35 Attachment C.
Project #49 System Impact Study Report (144 MW request) - StaflPR_l35 Attachment D.
In the course of these studies multiple construction alternatives to provide Interconnection Service
are often conceptually outlined and reviewed but are rejected due either to insufficient system
performance or prohibitive cost; such conceptual alternatives are not usually documented. Project
documentation included in a Feasibility Study or System Impact Study report is normally focused
on the selected alternative. In the case of Rattlesnake Flat, however, a review of the multiple
studies for a wind resource to be connected at or near the Company's Lind Station illustrates the
iterative nature of these types of studies. The following seven diagrams, which are excerpts from
the attached reports, with accompanying notes, provide an overall summary of the ultimate
selection of the final project.
Page 2 of8
Proiect #33 Feasibilitv Study - March 29,2013
Resource: 62 MW, Estimated Project Cost: $500,000
Lind115 kV Substation
Ch.ngo of
O{.rmrahlp
Add breaker position at Lind Station LGIR T33
-
Existing
Propeed
ll5kVro
Warden rc
115 kV to
tYashtrna 115 kv to
Rltarlll.'t3 kv
115 kY to
Xarengo
Note: The initial Rattlesnake Flat interconnection request of 400 MW was received in February,
2011. The Company is required to perform studies to provide Interconnection Service at the level
requested by the customer. In this case, however, the Company voluntarily performed feasibility
studies at varying generation levels to provide an indication of the generation thresholds that
would require progressively greater levels of magnitude in transmission construction costs. Per
studies in this time frame a resource limited to 62 MW could conceivably be integrated with the
existing conductor on the Lind-Warden I 15 kV Transmission Line.
Resource: 250 MW, Estimated Project Cost: $600,000 + planned 2016 projects
115 kV to
EgrDoro
I
Lindl'l 5 kV Swilching Station
WardenllS kV Station
Ctu.g. ol
Ot116hh
LG'N '33ffi
lt6rvb
Warht!@ ltS kV lo
RtLeilh',3 hv
Othello 1'15 kV Swltchlng Statlon
fislvbUn.eo
Add brcaker posilixr at Und Stalion
Upgrsde Cuc1ll Swildler al Roxboro
ll3 kVtc
Effton (SPA,
-E(EtrtO
-
PEFed
-
Asu Prc004 &rF d PeFcr
Note: Following this study the Company installed 20 MVar of shunt capacitors at Lind to provide
operational support during peak summer conditions.
Page 3 of8
c
@
Resource: 400 MW, Estimated Project Cost: $67.7 million
llSkVlo
Marango tl5 kV to
RirrYllleRebuild Lind subslation to breaker and a
half configuration
1t5 kVto
Washtuna
Re-conductor the 21.71 miles Lind -
Warden 1 15 kV transmission line to
minimum ol 330 MVA
lnstall 2 250 MVA 1 15/230 kV
transformers at Lind, and construct
approximately 66 miles of minimum 440
ilA/A 230 kV transmission line from Lind
to Wanapum
Add breaker position at Wanapum
LGIR f33re
Change ot
OwnoEhip
-
Exlsling
Propoe€d
- -- -- - Re-@nductored 1'15 kV
'lt3 kv ro
Wardan Substation
230 kV to
Wanapum
13 kV
1 15230 kV
250 MvA r 2
#
Note: This study provided an early indication that total generation output in excess of
150-200MW in the Big Bend area would require significant 230 kV construction.
Page 4 of8
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@
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@
@
Proiect #43 Feasibilitv Studv - April 10,2015
Resource: 150 MW, Option 1 Estimated Project Cost: $20.7 million
rdr Gip
R =O 12#x.o t8t82B: ODt16
R=Cg5
x = 0476B=0OaS
R .0 0G56x.0ffiE8.0681t
(mb55 at
6
-o()u: o 05IA:o.mt xI
-00r28:OO7819
:O.o(E[5 sfi6
9 i!
i
R :0-3cLf
X:O.O59l
S =O,6il
,.^t3 16MB
735 AC39iru
CMF oaoffil+Lind Starion lJ-)
ld
s:
00t4t5
0 csu
0_0 r252
nrnallal
o lrv 00 wa
1 t5aa 5 lV
Z=9 5at15445p
2-g 5*LGIR *i3 Rattl.sn k. Flet Option #l
(i) n"oriu r-i,,0 srrri.
'2 I Orsrom c$*uairn iEu&s a 16 rle t 15 h/ trBmbsbn ine" f m RatdesrEleto tE ffi L,rds-tatho
a3-r Rebuild Lind - Waden 115 kV laEb >201 llvA srmsmtng.' Rebuit, Llno - ottrehas I 15 lil lhe b >204 i/ryA s[yxEf ,ilir{
rRqdA*Fd*
-PrwdclfurFrdfb
Page 5 of8
Resource: 150 MW, Option 2 Estimated Project Cost: $60.5 million
Lind Station
-
Fmgand Au6h F*ifr!6
-
tto[ca6 CGsmr fadtocs@
Rorboro
73 t ltAlsR. 0.06587
X ; 0 .CO?7E-00916 DeviIs Gap
€)
13 kv
Washtucna o Hiller Statione19.@ UiLr
tt - 0Ol3A
X = 0 0l,16l
B = 0Ol22t o
Shawnee
70 2 Mts
R - 0og3gg
Ralson 5 MIh6
R = 0 t{}sflB
X - 0 COl547
B =0frla8i
x = 0 32649
B =004i1
@ LGIF ,{3 Reflt*nata Flal Orrtrm *2
11 MibR=0Olf'616
X - 0 065@4B=00m9
o
o
o
o
o
@
ConsfiuEr n€w l-llbr St tirn
Ch.rEc otOvnaltip
Rebuild Urd Ra/ston 1 15 kV *gment lo a
minimum smmgr ratng or 2gt MVA
Customer construcxon modeled as 1t.mile
Iransiision lne willl sumrer ratiflq 2OS iJVA
90 IIA/A
I I v!4.5
Zsg 516
90 $r'A
t15/3a5kV
z-9,5r,RGbuiH to minilM 205 MVA summer mting
Lird - Oevil's G.p 115 kV
Urd-Shawnee l15lV
Rattle sneke Ooen Lhd - Waro€r)'l15 kV lire al Llnd
Closein Lind - Oevl'r Gap 1 15 hV
Cbsenn Lind - Shaerc 1 15 kV
76 MW
38 Tlrbimes
76 MW
38 Turbiun6
lnEtall capacitcr bank at Rotboro Station
I
Note: This study recognized that any integration directly into Lind Station would require a major
rebuild of Lind. Alternative approaches to avoid an immediate rebuild of Lind began to be
reviewed.
Page 6 of8
Proiect #43 Svstem Impact Studv - October 30. 2015
Option 1: 150 MW, $22.017 million
O.Yf! G+
8 3 drbiR.0 0073
X = O Oa5lr2
l0.t iaBR. 0.qla56
X ' 0.05t58
Otr[o 33 R " 0.00961
X = 0 0tsl2
B - 0 r,OC53
Rorbo.o
29nt-R'0m5,x = 0 01573
A .0 0@27
o
3h.ilE
Olhollo -r2 ila.r
t58 inr'A Sffi R.l.
Chng. dOrrfrattlp Und StationoR , 0 009937 Urld
X i 0 (8319
g = 0 0@7s7
@ R.krl.o
o
@
Proieci #43
Rebuild Lad Stsli,on
l56.3MVA
Ir54a5W
Z-9 5ia
Customsr construc{on includ€s a '1 1 5 kV tranEmissirn Ine lrom
Raile$ake to th€ new Lind Statim
RGDuild Lhd . Wardm 1t5 kV lne b >a)4 MVA smmr mting
R€Ouild Werdm - O$etoSS 1t5 kV f l lino to >204 MVA summs raling
Retuild othelo - orlellrss t 15 kv lirle to >a)4 MVA $mms r8ling
Cmdete the Bfflon - Oths$o I l StV Tmnsmission Lim r€Ouild
-
PEPE .d Avig F.{atil6
-AF..dCrffiF&lliE
ffitiltI
Note: Advancing to the System Impact Study for Project #43,no further study of the more costly
Option 2 was considered.
Page 7 of8
Proiect #49 Svstem Im Studv - Mav 4.2017
144 MW, $17,343,500
Lind Station Ritzville
CI @
10.9 mtes
R : 0 t!0tr4
X :0.05S17B:0 mg6?
10.gniles
R : 0 0Ce55
x : 0-osr6'lB:000S0
16I mil6
R = 0.0703SX:0 10850
I
Wudan Rorborc
o Marongo
t3 kv 21 I mil€
R = 0 88310X: 0 l3l?ls;0.lit5so
4 mllBR=flm34?
x . 0 02306
B :0.m3.4
b.lhh
f1)
Smsrt Statlon
t{ .l r{e6
R: 0.061 n
X = 0.0m83g = 0 0t056
10.4 mk6
R : 0 0L1.6x ' 0m3a{B=00OAl
Warhffi Chlngc ol
Owimhlp
R.0 m213X:0.0Is4A=0flm
r 5s icr'A
1 riE4.5 w
R=O.qlzl3
X:0 0?g0a LGIR '40R:0m564
X = 0.g)687
B=0m6Ba o
@
o
0
Consruct 6 new Btalion: Smaft Staton
Rcbuild Lind - Smarl 1 15 kV 3sgm.nl to a minimum
rummrr roling of 314lWA
151 t VA
3i 14 63 ta/
R:O.m593S
x:0.06{758
R.build Lind - Wrrd.n 115 kV lin. to smcr rdirB of
314 MVA
Project #49 facililres using dala supplied bry deyeloper
Project#il9 14lMw
-
PropoHl Avils Facl{x'r
-
PDped D€ydops Fadlili*
Note: This study ultimately settled on a new point of interconnection on the Lind-Washtucna line,
avoiding the cost and construction logistics of an immediate rebuild of the Lind Station.
Page 8 of8
@
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff- 136
DATE PREPARED: 0811512019WITNESS: Jason Thackston
RESPONDER: Crystal Lewis
DEPARTMENT: GPSS
TELEPHONE: (509) 49s-2331
REQUEST:
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.
RESPONSE:
The Little Falls Powerhouse Redevelopment Program is a collection of individual projects that are
focused on upgrading and modernizing the equipment and ancillary systems associated with the
generating units to increase reliability. The structured program focused on preparing the plant and
systems for the generating unit upgrades by replacing the less reliable units and systems first. For
this production request, this response will focus on the Unit 4 Upgrade project which is the project
that will be completed in 2019 and that is shown as the Capital Addition in Table No. 1 of the
Thackston Testimony for the Little Falls Powerhouse Redevelopment for the estimated amount of
$9,047,000.
Project Contracts:
The following table summarizes the major project contracts for professional service providers,
miscellaneous contractors, major equipment procurements, suppliers, vendors, and fabricators for
the Unit 4 Upgrade project. Many of these agreements were set in place at the beginning of the
Program to procure the major equipment and materials for all four of the generator units to be
upgraded. Unit 4 is the last of these units to be upgraded. The costs identified in the table below are
specifically for the Unit 4 project. The project contracts listed are very voluminous as many of
these documents contain the agreements for the entire Program for years of procurements,
materials, and services for the different Unit upgrades. Due to the significant amount of
documentation, the contracts themselves are not included in this request. However, if a specific
agreement is requested, this production request can be supplemented.
Additionally, the table below includes only the major equipment, materials, suppliers, and services
used on the Unit 4 Upgrade project. The project work was performed by Avista's Electrical crews,
Mechanical/Structural crews, Relay techs, multiple engineering groups in conjunction with the
project team. Therefore, the total project costs for labor, engineering, overhead, transportation, and
other miscellaneous costs are not included in the amount below.
Design/Engineering:
Cimrs Design R-39124 WA #4 $ 400,000
Fabricators/Supplier/Vendors (Major):
GE/ABB - Field Poles R-39010 $ 700,000
GE/Alstom - Generators F.-39417 $ 1,800,000
Hudson Bay - Ducting Insulation R-41671 WA #9 $ 59,000
Page I of4
Fabricators/Supplier/Vendors (Major)z cont.
Hydro Tech -
Re-Babbitt Generator and Turbine
Bearings, Wear Sleeves
R-39833 $ 132,000
Jetco - Eccentric Pins, Pole Keys, Gen
Shaft Mach, Head Covers, Brake Hub
R-40688 WA #13, #14, & #t5 $ 75,ooo
L&S - Governors R-39769 $ 220,000
NWS&P - Sandblast & Paint R-41385 WA#4 &#6 $ 95,000
Voith - Turbine Shaft & Runner
Assembly
R-39423 $ 1,080,000
Wagstaff - Wicket Gates & Disks,
Distributor Body, Sole Plate
R-39215 WA #13
R-41765 WA #1
$ 540,000
$ 5,105,000
Organization Chart (Project):
The Organization Chart depicts the hierarchy of the Project Sponsor, Project Steering Committee
and the Project Team Members for the Little Falls Powerhouse Redevelopment Program,
including the Unit 4 Upgrade project. The Project Team is responsible for the daily coordination of
activities and work performed on the project and escalates concerns regarding scope, schedule,
budget and risks to the Project Steering Committee and Project Sponsor accordingly.
Project Schedules:
The Unit 4 Upgrade project schedule is provided in a snapshot below showing the Completion
Dates identified in the Baseline Schedule with a data date of 1012018 and the updated Project
Schedule with a data date of 512019.
Baseline Project Schedule dated l0ll2ll8:
Tmlc l.Iame Start
296
297
298
j commercial operation {GoC ends s/30/19 6pm)
Notify/Coord i nate Operations
TTPI tn-Service/Used and Useful Notification
wcdEr2ule Fri sl?BlLe
wed 8/2vD rhu slazlLe
rhvslzzlLe FnslzilLe
This shows the original Unit 4 completion of work when the generator is released to the Operations
group for commercial operation and production on the dates shown as early as 8121ll9 to 8123119.
Page 2 of 4
Oirects - GPSS
Prciect Sponsor
Proiect sterinS Cmmitte
Jacob Reidt
& Constt &
Alexis Alexender
Maintenance
Bob weisb€ck
and Ma,ntenance
Prciect Mensger
Lewis
Brian
Opentlons
Xevin Powell
Ioren Davidson
Jeff vogel - Relay shop
Bmd McNamra - Electriel Shop
Enginering
(ristine Newhou* - Controls
Glen Famr- Electriel
PJ Hensheid - MedBniol
v Finish v
Updated Project Schedule dated 5l22ll9:
Task Name ! Start v Finish
thuehelLe
ThuelLe/Le
Ftie!2o/Le
296 . Comm€rcia! Operation (GOC ends g/3O/19 6pm!
Notify/Coord i nate Operations
TTP/ ln-ServicelUsed and Useful Notification
tionglziltg
Fr. e/?a/E
Mon 9/23/19
?97
298
This shows the updated/revised Unit 4 completion of work when the generator is released to the
Operations group for commercial operation and production on the dates shown as early as9119l19
to 9123119. The project experienced a delay in delivery of critical materials from a fabricator that
resulted in a negative impact to the project completion dates. To mitigate this delay of one month
in the completion dates for Unit 4, the project team has made arrangements and taken additional
steps to compress the unit commissioning from two weeks down to one week with anticipation of
releasing the unit to Operations before the revised 9ll9ll9 date above.
Project Status Reports:
Monthly Project Status Reports are provided to the Project Sponsor and Steering Committee for
each active project under the Program. The report provides a summary table of the project's
approved budget, accrued spend, estimate at completion, as well as showing the current status of
the scope, schedule, and budget. Project Milestones are identified with planned and actual
completion dates as well as bullet points for project accomplishments to date, upcoming activities,
and any risk or mitigation strategies. The Project Monthly Reports for the Unit 4 Upgrade Project
are provided as Staff PR_l36-Attachment A.
Action ltems/Lists:
The project schedule was developed using a Work Breakdown Structure, identifying each type of
work and each step to perform the work with the appropriate resources throughout the duration of
the construction project. This project schedule acts as the action items list for work to be
performed on the project. Additionally, weekly construction meetings are held on-site with the
Project Team members to discuss past, current, and future activities to determine if any
coordination or preparation is necessary. Any additional steps of coordination or communication
are identified by the team at that time and are then managed by the responsible team member.
Project Change Orders/Additional Work:
The following change orders have been executed on the Unit 4 Upgrade project during the
construction phase while performing disassembly and assembly of the unit. These changes and
additional work were identified by the project team as existing equipment was inspected and
unforeseen conditions were discovered.
Changes &
Additional Work Description
Vendor/
Fabricator Amount
co l0
Generator Stator
Halves
Provides credit to Avista for on-site Operator support during
extended shifts for generator splicing work performed by
Alstom and extends the warranty period ofthe splicing work
performed.
Alstom $ (4,560)
credit
wA6
Operating Shaft
Reconditioning
Change order to perform reconditioning of the operating
shaft including turning, grinding, and polishing ofthe center
journals due to wear during operation.
Eastside
Electric
$ 6,995
Page 3 of4
v
Changes &
Additional Work Description
Vendor/
Fabricator Amount
wA 15
Head Covers
Machining and
Drilling
Change order to perform specialized milling, machining,
drilling and tapping of 3 sections of the head covers to
provide for proper final fit and operational clearance.
Jetco $ 2,985
wA6
Sand blasting &
Paint
Change order to have the lead containing paint removed and
properly disposed of from the operating shaft and packing
gland and new paint applied.
Northwest
Sandblast
& Paint
$ 1,320
WAI
Design &
Manufacture
Sole Plate
Change Order to provide design and fabrication of a new
sole plate as the existing plate was unusable due to
significant corrosion. It could not be rehabilitated due to
being cast and grouted into the plant floor.
Wagstaff $ 30,386
co7&8
Wicket Gates
Change orders to remove contracted work tasks determined
to be unnecessary upon inspection of existing equipment.
Wagstaff $ (9,660)
credit
TOTAL s 27,466
Pro Forma Capital Amount:
In the original filed case, the Company included $9,047,000 for the system 2019 transfer-to-plant
amount. The Company updated the pro formed system amount to $8,760,038 with Staff PR_067,
since a planned portion of the work was removed from the project. Since providing that update,
due to the wicket gate delay, the forecasted costs have been estimated to be more in line with the
original estimate of $9,047,000. Therefore, the pro formed amount is understated by
approximately $287,000 (system) or approximately $100,000 for Idaho.
Page 4 of 4
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-I9-04
IPUC
Production Request
Staff- 137
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
08109t2019
Elizabeth Andrews
Jeanne Pluth
Regulatory Affairs
(s09) 4es-2204
REQUEST:
In Thackston DI (page 7), for the Long Lake Plant Upgrades please provide the revenue
requirement based on the corrected capital addition amount.
RESPONSE:
The revenue requirement for the Long Lake Plant Upgrades after updating for actual
transfers-to-plant through May 31,2019 and updated forecasted amounts for the remainder of
2019 is $31,730. Please see StaflDR_l37-Attachemnt A for calculation of the revenue
requirement amount.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO: AVU-E-19-04
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Staff-l38
DATE PREPARED: 0810912019
WITNESS: Elizabeth Andrews
RESPONDER: Jeanne Pluth
DEPARTMENT: Regulatory Affairs
TELEPHONE: (509) 49s-2204
REQUEST:
In Thackston DI (page 8), for the Generation DC Supplied System Upgrade please provide the
revenue requirement based on the corrected capital addition amount.
RESPONSE:
The revenue requirement for the Generation DC Supplied System Upgrade after updating for
actual transfers-to-plant through May 31,2019 and updated forecasted amounts for the remainder
of 2019 is $7,588. Please see Staff DR_l38-Attachemnt A for calculation of the revenue
requirement amount.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff- 1 39
DATE PREPARED
WITNE,SS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0812012019
Jason Thackston
Terri Echegoyen
GPSS
(s09) 49s-2199
REQUEST:
In Thackston DI (page 9), please explain the basis for deferring the Cabinet Gorge HED Service
Station Replacement project until2020 relative to other capital projects.
RESPONSE:
The Cabinet Gorge HED Service Station Replacement project was deferred because it relies on the
successful completion of other Cabinet Gorge projects. In order to properly determine the load
requirements of the plant that will ultimately need to be fed from the Station Service, the Controls
Upgrade projects for Units 2,3, and 4 will need to be executed. The schedule for the Controls
Upgrade project was pushed out due to resource and other constraints associated with the plant's
highest priority project, the Gantry Crane Rehabilitation.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-140
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: Scott Kinney
DEPARTMENT: Power Supply
TELEPHONE: [phone]
REQUEST:
For the Resource Metering, Telemetry, and Controls Upgrade capital project referenced in
Thackston Schedule l,page 80 and 8l please provide copies of the results, specifications, and
report from the metering engineer.
RESPONSE:
The Metering, Telemetry, and Controls Upgrade capital projects are based on a report developed
by Utilicast (Avista - Metering Assessment - Summary Report - Final) which was previously
provided in StaflPR_87C. As discussed during the recent staff visit, costs associated with this
capital project and business case have recently been moved to an EIM business case and the
associated costs for EIM metering, telemetry, and control work has been removed from this GRC
and will be incorporated into future rate filings.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-141
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: Scott Kinney
DEPARTMENT: Power Supply
TELEPHONE: [phone]
REQUEST:
For the Resource Metering, Telemetry, and Controls Upgrade capital project referenced in
Thackston Schedule 1, 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.
RESPONSE:
Please see response to StafLPR_I40
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-l42
DATE PREPARED: 0812012019WITNESS: Scott Kinney
RESPONDER: Scott Kinney
DEPARTMENT: Power Supply
TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Please see response to StafLPR_l40
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-143
DATE PREPARED: 0811312019WITNESS: Heather Rosentrater
RESPONDER: Zachary Curry
DEPARTMENT: Substation
TELEPHONE: (509) 49s-8922
REQUEST:
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 to 2026.
Rosentrater Schedule 3 at 92.
RESPONSE:
Please see Avista's response 143C, 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.
Please see Staff PR l43C Confidential Attachment A.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 19-04
IPUC
Production Request
Staff-145
DATE PREPARED: 0810812019WITNESS: Heather Rosentrater
RESPONDER: Neil Thorson
DEPARTMENT: Operations Analyics
TELEPHONE: [phone]
REQUEST:
Please provide the workpapers used to calculate historic averages for the Storms Transmission
Capital Investment Business Case. Rosentrater Schedule 3 at 63.
RESPONSE:
Storms Transmission Capital is contained within the Electric Storm Business Case. The total for
this Business Case has been at $3 million for the last several years. The primary reason for the lack
of update to this case is that storm activity is highly unpredictable by nature, and that this is a 'shall
respond' type of activity. As storms occur, they are funded at whatever level is needed. The split
between Transmission and Distribution has been typically 1/3 Transmission and2l3 Distribution.
In 2019 the split was adjusted to 116 Transmission and 5/6 Distribution. This was seen as an
oversight, such that the Budget was redistributed manually to 1/2 Transmission and ll2
Distribution. (Once the 'official' budget is finalized, only off-system manual adjustments are
allowed). StaflPR_I45 Attachment A shows the actual activity over the last several years, with
notations of anomalous data in2014 and 2017. The numbers shown are system numbers.
Page I of I
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-146
DATE PREPARED: 0812012019
WITNESS: Heather Rosentrater
RESPONDER: Landen Grant
DEPARTMENT: Asset Maintenance
TELEPHONE: [phone]s1
REQUEST:
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 14-15). Please explain when the installations are scheduled to occur.
RESPONSE:
The scope of the LED Change-Out program is only lights on Tariff Schedule 042. When the
program is completed, over 28,000 streetlights system-wide will be converted to LED. Avista
standards include just four LED fixtures, three of which are cobrahead style and one decorative
style. The three cobrahead styles comes in various wattages (60W, 107W, and 241W), while the
decorative is only 40W. This small number of fixtures simplifies the supply chain and inventory.
LED installs began in Idaho back in 2016 and are expected to continue past 2023, but at a low
annual rate because conversions from high pressure sodium (HPS) fixtures to LED fixtures are
being performed on a'oburn-out" only basis. For 2019, it is estimated that a total of just 800
streetlights will be converted to LED in Idaho. See Staff PR_l46 Attachment A for the number of
streetlights converted in Idaho from 2016-2019.
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-l47
DATE PREPARED: 0812012019WITNESS: Heather Rosentrater
RESPONDER: Landen Grant
DEPARTMENT: Asset Maintenance
TELEPHONE: (s09) 49s-2ssr
REQUEST:
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.
RESPONSE:
The scope of the LED Change-Out program is only for streetlights under Schedule 042. On aper
fixture basis the energy savings from high pressure sodium (HPS) to LED is as follows:
Below is a table showing the total estimated annual energy savings (MW*hrs) for schedule 042
lights in Idaho:
HPS Wattage (actual)LED Wattage (actual)Enerry Savings
l35W cobrahead 60w 75W
235W cobrahead 123W I 12W
435W cobrahead 24tW l94W
l35W decorative 55W 80w
2016 2017 2018 2019 (thru July)
Total Estimate MW*hr savings 1843.28 2134.7 984.16 120.13
Page I of I
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-19-04
IPUC
Production Request
Staff-148
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
08t20/2019
Heather Rosentrater
Landen Grant
Asset Maintenance
(s0e) 4es-2ss1
REQUEST:
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.
b. If not available in the format described, please provide the Company's net benefit
analysis for the LED Change Out Program.
RESPONSE:
a.-b.
The scope of the LED Change-Out program is only for streetlights under Schedule 042
See Staff PR_148 Attachment A - 2013 Streetlight Asset Management Plan.pdf for analysis
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