20210107Staff 20-34 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
I1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-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
UPDATE AND ESTABLISH ITS CAPACITY
DEFICIENCY PERIOD TO BE USED FOR
AVOIDED COST CALCULATIONS
CASE NO. AVU-E.20.11
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than THURSDAY, JANUARY 28,
2021.
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
SECOND PRODUCTION REQUEST
TO AVISTA JANUARY 7,2021
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the person preparing the documents. Please also identify the name, job title, location, and
telephone number 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.
REQUEST NO. 20: Please explain the purpose of "Planning Margins" of JVo for
sufirmer and 167o for winter and explain whether the purpose captures "Regulation," "Operating
Reserve," and "Frequency Response Requirement." Also, please explain any overlap between
"Regulation," "Operating Reserve," and "Frequency Response Requirement" and the Planning
Margins.
REQUEST NO.21: Please provide the latest load and obligation forecast that the
Company has developed.
REQUEST NO.22: Please explain the causes in the difference between the latest load
and obligation forecast and the load and obligation forecast in the Compliance Filing. In the
explanation, please include how the latest load and obligation forecast reflects impacts of the
pandemic.
REQUEST NO.23: In "Staft_PR_OOlC Confidential Attachment 1," the note for "Net
Borderline In" states it represents imports from third parties to cover borderline loads in Avista's
Control Area, and it does not include resources on Avista's system. Please confirm that
borderline loads are not the Company's obligation to meet. Also, please explain why "Net
Borderline [n" should be included in Avista's Load and Resource Balance.
REQUEST NO. 24: In response to Staff s Production Request No. 13, the Company
states that there is a 10 MW operating reserve credit in its example of a 100 MW turbine. Using
the Company's example, please provide evidence that if a 100 MW turbine could produce 90
MW for the peak hour in an average water year, including the 10 MW as operating reserve credit
in the capacity Load and Resource Balance is reasonable and can be relied upon during peak.
SECOND PRODUCTION REQUEST
TO AVISTA 2 JANUARY'7,2021
REQUEST NO. 25: Response to Staff s Production Request No. l5 states that the
Company considers the amount of its expected share of available market resources to determine
the appropriate level of resource planning margins to include in the Load and Resource Balance.
Please answer the following questions.
a. How much of the planning margin is for market reliance capacity? Please provide the
amount in MW by year and by percentage of the planning margin.
b. In determining the expected share of available market resources, is transmission
capacity I constraint considered? Please explain.
c. What is the proportion of market reliance relative to the Company's import
transmission capacity?
REQUEST NO. 26: 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 updates that have occurred since the Compliance Filing
REQUEST NO. 27: In "Staff PR_001C Confidential Attachment 1," the note for
"Other Load in BA" states that this is the third-party load in Avista's control area. Please
explain why this load is not excluded from the total obligation after being used to calculate
operating reseryes.
REQUEST NO. 28: Please explain "Pend Oreille Load" in the Load and Resource
Balance? Please explain why Pend Oreille Load is included in the Company's Obligation.
REQUEST NO. 29: Please define "Capacity Services" in the Load and Resource
Balance.
REQUEST NO.30: Is Avista obligated to provide ancillary services to balance load for
cooperatives or municipalities within its balancing area at OATT rates? If so, which category
within the load and resource balance are these ancillary services included?
SECOND PRODUCTION REQUEST
TO AVISTA JANUARY 7,2021J
REQUEST NO. 31: Why is a regulation value of l6 MW constant throughout the
planning horizon?
REQUEST NO. 32: Response to Staff s Production Request No. 5 states that operating
reserves are three percent of balancing area load plus three percent of on-line balancing area
generation. Please explain the calculation for "on-line balancing area generation," given the
calculation in the Excel Spreadsheet, "Staff PR 001C Confidential Attachment I."
REQUEST NO. 33: Response to Staff s Production Request No. 6 states that, "The
Frequency Response Requirement is included in the operating margin requirement section of the
Load and Resource Balance." However, operating reserves only include three percent of
balancing area load plus three percent of on-line balancing area generation, without the
Frequency Response Requirement in the formula for calculating operating reserves in Excel
spreadsheet, "Staff PR_001C Confidential Attachment 1." Please explain the discrepancy.
REQUEST NO. 34: Why is the planning margin only applied to Peak Native Load and
Net Clearwater Load, and not other loads in the total obligation?
DATED at Boise, Idaho, thiJ/^ day of Janu ary 2021
Deputy Attorney General
i:umisc:prodreq/avue20.1 ldhyy prod req 2
SECOND PRODUCTION REQUEST
TO AVISTA JANUARY 7,20214
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF JANUARY 202I,
SERVED T}IE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, rN CASE NO. AVU-E-z}-tt,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
POBOX3727
SPoKANE WA99220-3727
E-MAIL: michael.andrea @ avistacorp.com
avistadockets @ avistacorp.com
SHAWN BONFIELD
SR MGR/REGULATORY POLICY
AVISTA CORPORATION
POBOX3727
SPOKANE WA99220-3727
E-MAIL: shawn.bonfield avlstacorp.com
SECRETAR
CERTIFICATE OF SERVICE