20190916Staff 155-167 to Avista.pdf

EDWARD JEWELL
JOHN R HAMMOND JR
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-0 3 | 4 t (208) 33 4-03 s7
IDAHO BAR NO. 104461s470
RECEIVED
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES FOR ELECTRIC
SERVICE IN IDAHO
CASE NO. AVU.E.19-04
SIXTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF 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 MONDAY,
ocToBER 7,2019.
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
SIXTH PRODUCTION REQUEST
TO AVISTA
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I SEPTEMBER 16,2019
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0t.0t.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. 155: Please provide the Coyote Springs 2 combined cycle plant design
operating capacity.
REQUEST NO. 156: Please provide the present, limited operating capacity of Coyote
Springs 2 plant as a result of the GSU transformer de-rating.
REQUEST NO. 157: Please provide the pro forma net power cost adjustment and
corresponding revenue requirement difference with the Coyote Springs 2 plant operating at
reduced capacity as a result of the GSU transformer de-rate using the AURORA model to
calculate proposed base rates. Please provide AURORA model results and updated confidential
and non-confidential schedules that are contained in Mr. Kalich's Exhibit No. 7 workpapers.
REQUEST NO. 158: Please explain the feasibility of continuing to run at reduced
capacity. Specifically, what are the impacts and consequences of continuing to run the Coyote
Springs 2 plant at the current level ofoutput?
REQUEST NO. 159: Please provide all the options available to the Company in
addressing the future issues of the Coyote Springs 2 facility. In addition, based on each option,
please provide the following:
a. Please provide a description of all the activities and analysis the Company plans
to perform to choose the best option;
b. Please describe the criteria and factors that the Company will use to make its
decision while choosing the options; and
c. Please provide a timeline of all the activities, analysis, interim and final decision
points needed to choose the best option.
SIXTH PRODUCTION REQUEST
TO AVISTA 2 SEPTEMBER I6,2019
REQUEST NO. 160: What is the latest date that the Company will have a permanent
solution in place?
REQUEST NO. 161: Regarding the option to reconfigure the facility using three single
phase transformers, please provide the total estimated cost needed to reconfigure the facility if
this option is chosen and an estimate of the time needed to complete re-construction.
REQUEST NO. 162: Please provide reports of any plant investigations or analyses
completed since starting plant construction up to the present regarding GSU transformer failures
at the Coyote Springs 2 plant.
REQUEST NO. 163: For each of the past GSU transformer failures please provide the
following:
a. Date of occurrence;
b. Circumstance of the failure;
c. Date returned to service at full capacity;
d. The amount and value of the lost generation during the outage;
e. The capital cost to return the plant to service;
f. How did the Company receive recovery for the capital cost? Please list any
amounts covered by warranty, recovered from insurance, covered in rates, or
specify other; and
g. How did the Company offset the lost generation and what was the differential cost
of the lost generation?
REQUEST NO. 164: Please provide all Company analyses and reasoning when
procuring each of the capital spare GSU transformers (i.e. GSU #3 and GSU #4).
REQUEST NO. 165: Has the Company or its partners considered alternative GSU
transformer designs/configurations at the Coyote Springs 2 plant prior to the GSU transformer
failure that occurred in 2018? Please provide any reports detailing these proposals.
SIXTH PRODUCTION REQUEST
TO AVISTA 1J SEPTEMBER I6,2019
REQUEST NO. 166: Please provide the monthly data used to generate the Mid-
Columbia Electric Forecast Range graph (as illustrated in Figure 10.14, page 10-21inthe2017
IRP) in Excel format with all working formula intact. Please provide the same data and graph
that was generated for the 2019 IRP.
REQUEST NO. 167: Please provide the average monthly Mid-Columbia electricity
prices generated for each of the Aurora Monte Carlo runs that were used to develop the
Company's 20ll and 2015 Integrated Resource Plans. Please provide the data in Excel format
with all formula intact.
( LPduyof Septemb er 2o I 9 .Dated at Boise, Idaho, this
i:urnisc:prodreq/avuel9.4ejrkmlck prod req6
SIXTH PRODUCTION REQUEST
TO AVISTA
J Hammond Jr.
Attomey General
4 SEPTEMBER 16,20I9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l6th DAY OF SEPTEMBER 2019,
SERVED THE FOREGOING SIXTH 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 BOX3727
SPOKANE W A 99220-3727
E-MAIL: patrick.ehrbar(Oavistacolp.coni
avistadoq@
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-MAIL : ron0r)rvil I i am sbraclburv.corn
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE TD 83702
E-MAIL: peterfOrichardsonadams.conr
NORMAN M SEMANKO
PARSONS BEHLE & LATIMER
8OO W MAIN ST STE 13OO
BOISE ID 83702
E-MAIL: nsemankorOparsonsbehle.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE TD 83702
E-MAIL: botto(!liclahoconscrvation.orts
DAVID J MEYER
VP & CHIEF COLTNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: david.me-r'crrii ar istacorp.corn
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : clrcadingG)rnindsprinq.com
VICKI M BALDWIN
PARSONS BEHLE & LATIMER
201 S MAIN ST STE 18OO
SALT LAKE CITY UT 841I I
E-MAIL: vbaldr.viniizparsonsbehle.corn
BRAD M PURDY
ATTORNEY AT LAW
2019N 17TH ST
BOISE ID 83702
E-MAIL: brnpr"rrcl),(4)hotrnai l.com
CERTIFICATE OF SERVICE
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 83716
E-MAIL : cicanj mil lerrircab I cone.net
ELECTRONIC ONLY
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carol . haugen@clear\,vaterpaper. com
terry.borden1?)clearrvaterpaper. com
mali sa.rnaynard (@c I earwaterpaper.corn
S te phen. chri ss (g) walmiirt. corn
CERTIFICATE OF SERVICE