20201203Staff 1-19 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL og .y:IDAHO PUBLIC UTILITIES COMMISSION "
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )CORPORATION'S COMPLIANCE FILING TO )CASE NO.AVU-E-20-11UPDATEANDESTABLISHITSCAPACITY)DEFICIENCY PERIOD TO BE USED FOR )AVOIDED COST CALCULATIONS )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy AttorneyGeneral,requests that Avista Corporation provide the following
documents and information as soon as possible,but no later than THURSDAY,DECEMBER
24,2020.
This Production Request is to be considered as continuing,and Avista Corporation 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 or information
produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephone number of
FIRST PRODUCTION REQUEST
TO AVISTA 1 DECEMBER 3,2020
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUESTNO.1:Please provide workpapers,with formulas intact,for all calculations
used in Figures 1 -3 of the Company's Application.
REQUESTNO.2:Please explain how the capacity contribution of Energy Efficiency
(EE)is included in the Load and Resource Balance.Please answer each of the following:
a.Which category (or categories)in the Load and Resource Balance is the capacity
contribution of EE included?
b.Please explain if the capacity contribution of Energy Efficiency (EE)includes both
existing and forecasted EE.
c.If included,please provide the amount of existing EE and forecasted EE separately
for each year over the IRP planning horizon.
d.Please explain how existing EE and forecasted EE are determined and the sources of
the data.
e.Are existing EE and forecasted EE assumed to continue throughout the IRP planning
horizon once included in the Load and Resource Balance and are the levels of
capacity contribution expected to change over time?Please explain.
REQUESTNO.3:Is the Company planning Demand Response (DR)to meet customer
load?Also,please answer the following:
a.Has the Company included DR in the Load and Resource Balance?
b.Which category (or categories)in the Load and Resource Balance is the capacity
contribution of DR included?
c.Please explain if the capacity contribution of DR includes both existing and
forecasted DR.
d.If included,please provide the amount of existing DR and forecasted DR separately
for each year over the IRP planning horizon.
FIRST PRODUCTION REQUEST
2 DECEMBER 3,2020TOAVISTA
e.Please explain how existing DR and forecasted DR are determinedand the sources of
the data.
f.Are existing DR and forecasted DR assumed to continue throughout the IRP planning
horizon once included in the Load and Resource Balance and are the levels of
capacity contribution expected to change over time?Please explain.
REQUESTNO.4:Does the Company have interruptible load contracts included in the
Load and Resource Balance?Also,please provide the following:
a.Explain how interruptible load contracts are included in the Load and Resource
Balance.
b.Provide the amount of capacity contribution in each year.
c.Explain if interruptible load contracts are assumed to be renewed in the Load and
Resource Balance after contract expiration.
d.Please explain whether their values should be considered for load when calculating
planning margin.
REQUESTNO.5:Please define and differentiate "Regulation,""Operating Reserves,"
and "Planning Margin."In addition,please explain how the items that the reserve/margin
percentages apply to are chosen.
REQUESTNO.6:Page 7-2 of the 2020 IRP states that there is a 24-megawatt
Frequency Response Requirement.Please provide the following:
a.Please explain how the 24 megawatts is determined and why it is needed for the
system.
b.Please explain how the Frequency Response Requirement is included in the Load and
Resource Balance.
REQUESTNO.7:Are the load and obligation amounts included in the Application the
latest information available?If not,please provide the latest load and obligation data and explain
causes for any differences from the amounts included in the Application.
FIRST PRODUCTION REQUEST
TO AVISTA 3 DECEMBER 3,2020
REQUESTNO.8:Please explain how peak hour capacity amounts are determined for
PURPA contracts and non-PURPA contracts for different types of resources (i.e.wind,solar,
etc.).
REQUESTNO.9:Please answer the followingregarding to Customer-Owned
Generation as mentioned on pages 4-10 of the 2020 IRP.
a.Has the Company included Customer-Owned Generationin the Load and Resource
Balance?
b.Which category (categories)in the Load and Resource Balance is the capacity
contribution of Customer-Owned Generation included?
c.Please explain if the capacity contribution of Customer-Owned Generationincludes
both existing and forecasted Customer-Owned Generation.
d.If included,please provide the amount of existing Customer-Owned Generationand
forecasted Customer-Owned Generation separately for each year over the IRP
planning horizon.
e.Please explain how existing Customer-Owned Generationand forecasted Customer-
Owned Generation is determined and the sources of the data.
f.Are existing Customer-Owned Generationand forecasted Customer-Owned
Generation assumed to continue throughout the IRP planning horizon once included
in the Load and Resource Balance and are the levels of capacity contribution
expected to change over time?Please explain.
REQUESTNO.10:Please define "Power Deal Purchases"and explain whether it only
includes committed power purchases,or both committed power purchases and forecasted
purchases.If it includes forecasted purchases,please explain how the values are determined.
REQUESTNO.11:Please define "Net Borderline In"and explain whether it only
includes committed values,or both committed values and forecasted values.If it includes
forecasted values,please explain how the values are determined.
FIRST PRODUCTIONREQUEST
TO AVISTA 4 DECEMBER 3,2020
REQUESTNO.12:Please defme "small power"and explain whether it only includes
committed values,or both committed values and forecasted values.If it includes forecasted
values,please explain how the values are determined.
REQUESTNO.13:Please define "Operating Reserve Credit-Hydro"and explain
whether it only includes committed values,or both committed values and forecasted values.If it
includes forecasted values,please explain how the values are determined.
REQUESTNO.14:Please define "Market Reliance"in the Load and Resource Balance
and explain why the value is zero.
REQUESTNO.15:Please explain whether transmission capacity and market
availabilityare included in the Load and Resource Balance.If not,please explain why.If so,
please explain how it is determined and where it is included in the Load and Resource Balance.
REQUESTNO.16:Page 4-8 of the 2020 IRP states that the IRP assumes renewal of
PURPA contracts after their current contract term ends.Please explain why PURPA contracts
are assumed to be renewed after expiration for purposes of determining the deficit date and
provide rationale and/or evidence to support the answer.
REQUESTNO.17:Please explain how non-PURPA energy/capacitycontracts are
included the Load and Resource Balance (whichcategory or categories).Please explain when
and if they are assumed to be renewed.
REQUESTNO.18:When are Colstrip units 3 and 4 reflected to be removed in the
Load and Resource Balance for determining the deficit date?Has the Company included
replacement resources in the Load and Resource Balance if Colstrip units 3 and 4 are to be
closed early?
FIRST PRODUCTION REQUEST
5 DECEMBER 3,2020TOAVISTA
REQUESTNO.19:Does the contract information (e.g.contract execution,contract
renewal,and contract termination)included in the Load and Resource Balance reflect the latest
information?If not,please provide the latest information.
DATED at Boise,Idaho,this day of December 2020.
Dayn Hardi
Deputy AttorneyGeneral
i:umisc:prodreq/avue20.1 Idhyy prod req l
FIRST PRODUCTION REQUEST
6 DECEMBER 3,2020TOAVISTA
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3 DAY OF DECEMBER 2020,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NO.AVU-E-20-11,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL G ANDREA SHAWN BONFIELD
SENIOR COUNSEL SR MGR/REGULATORY POLICY
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-MAIL:michael.andrea avistacorp.com E-MAIL:shawn.bonfield avistacorp.com
avistadockets avistacorp.coin
SECRETAR/
CERTIFICATE OF SERVICE