20210126Avista to Staff 20-34.pdf

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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-2O-I I
Staff
Production Request
Staft-020
DATE PREPARED: l/1912021WITNESS: John Lyons
RESPONDER: James Gall
DEPARTMENT: Energy ResourcesTELEPHONE: (509) 49s-2189
REQUEST:
Please explain the purpose of "Plaruring Margins" of 7%o for summer and 16%o for winter and
explain whether the purpose captures "Regulation," o'Operating Reserve," and "Frequency
Response Requirement." Also, please explain any overlap between "Regulation," "Operating
Reserve," and'oFrequency Response Requirement" and the Planning Margins.
RESPONSE:
For Load and Resource (L&R) planning Avista's load forecast assumes the average historical
coldest/trottest day for each month and resources assume expected generation during the average
historical coldest/hottest day for each month. Given the use of averages when more extreme
possibilities are likely, Avista includes a planning margin to increase the amount of resources to
cover load in the event loads are higher due to extreme weather or resources have forced outages.
Further, Avista's reliability planning method does not include Regulation, Operating Reserves, or
Frequency Response Requirements within the planning margin. These are separate calculations.
These calculations are separate because they are known operating requirements to run the system.
The only overlap between these different requirements is that Frequency Response Reserves can
also be counted as Operating Reserves ifthey meet the NERC requirements forboth. Avista counts
Frequency Response as Operating Reserves.
RECEIVED
2021January 26, AM 8:00
IDAHO PUBLIC
UTILITIES COMMISSION
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-20-11
Staff
Production Request
Staff-O21
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
U19t2021
John Lyons
John Lyons
Energy Resources
(s0e) 4es-8s1s
REQUEST:
Please provide the latest load and obligation forecast that the Company has developed.
RESPONSE:
Please see Avista's response 021C, which contains TRADE SECRET, PROPRIETARy orCONFIDENTIAL information and exempt from public view and is separately filed under
IDAPA 31.01.01, Rule 067 and233, and Section g-34}D,Idaho Code.
Please see Staff PR-021C Confidential Attachment A for the Company's most current load and
obligation forecast. This forecast was used to develop the recently filed draft 2021Electnc IRp.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-20-11
Staff
Production Request
Staff-O21C
DATE PREPARED: lll9l202lWITNESS: John Lyons
RESPONDER: John Lyons
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 49s-8s1s
REQUEST:
Please provide the latest load and obligation forecast that the Company has developed.
RESPONSE:
Please see Avista's response 021C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and exernpt 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_021C Confidential Attachment A for the Company's most current load and
obligation forecast. This forecast was used to develop the recently filed draft 2021Electrtc IRP.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2o-11
Staff
Production Request
Staff-022
DATE PREPARED: lll9l202lWITNESS: John Lyons
RESPONDER: John Lyons
DEPARTMENT: Energy ResourcesTELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
The latest load and obligation forecast uses the current load forecast, any updated contract or
resource information that is retrieved from our Nucleus database, and most notably a change from
a 14 percent to a 16 percent winter planning margin (October through April). Other minor changes
are corrections made for small data or equation issues that are listed on the Updates tab of
Staff PR 021 Confidential Attachment A.
As stated in the draft202l Electric IRP, the IRP forecast was developed assuming the service area
economy is structured under normal economic conditions and we would not be able to make any
significant adjustments, if any are needed, until the end of pandemic and any subsequent
restructuring of the economy in the service area becomes clear. The load forecast was completed
in early August 2020, so it does include Avista's actual load and customer data from the initial
stages of the pandernic up to the end of July 2020.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-20-11
Staff
Production Request
Staff-023
DATE PREPARED: lll9l202lWITNESS: John Lyons
RESPONDER: James Gall
DEPARTMENT: Energy ResourcesTELEPHoNE: (s09) 49s-2189
REQUEST:
In "Staff PR_001C Confidential Attachment 1," the note for "Net Borderline In" states it
represents imports from third parties to coverborderline loads in Avista's Control Area, and it does
not include resources on Avista's systern. Please confirm that borderline loads are not the
Company's obligation to meet. Also, please explain why "Net Borderline In" should be included
in Avista's Load and Resource Balance.
RESPONSE:
Avista instantaneously meets two types of load: 1) Avista native load (its customers) and 2) other
load within the Balancing Authority (BA). Non-Avista loads (often times termed as "borderline
loads") are included in the load and resource (L&R) report because Avista must provide operating
reserves and balancing services for these loads. Within the L&R, the operating reserves are
calculated with these loads, but the loads are met with an equal borderline resource to zero out the
effect to the L&R.
Extra background:
In operations, Avista serves all load within its BA instantaneously. Some of this load is for
non-Avista customers, such as Pend Oreille PUD. The third-party loads schedule power to Avista
to cover this load each hour and Avista serves the intra hour variability for a fee. If the amount of
power scheduled by the third party for the hour differs from actual load in the hour, the difference
is paid for by the third-party using market prices plus penalties.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION: IDAHO
CASE NO: AW-E-20-11
REQUESTER: StaffTYPE: Production Request
REQUEST NO.: Staff-024
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
Ut9l202t
John Lyons
James Gall
Energy Resources
(s}e) 49s-218e
REQUEST:
In response to StafPs Production Request No. 13, the Company states that there is a l0 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 capacitv Load and
Resource Balance is reasonable and can be relied upon during peak.
RESPONSE:
Avista's response to Staff Production Request No. 13 was illushative to explain the concept of
operating reserves. The Avista example of the 100 MW turbine assumes the hydro resource has a
storage reservoir and if the average energy over the course of the period created 90 aMW of
energy, the hydro plant could theoretically generate 100 MW using the storage for a short period of
time. Because of the plant's capability to instantaneously increase generation, the capability
between operations of 90 MW and capability of 100 MW can count toward operating reserves.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2O-11
Staff
Production Request
Staff-025
DATE PREPARED: lll9l202lWITNESS: John Lyons
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: [phone]
REQUEST:
Response to StafPs Production RequestNo. 15 states thatthe 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?
RESPONSE:
a) Avista's planning margin is used to cover above average peak load and/or resource
unavailability. In these events, utilities could either rely on the wholesale market or acquire
additional capacity above their peak load forecast (i.e. planning margin). Avista uses a 16
percent planning margin to ensure sufficient resources for this level of security. Assuming
the 16 percent planning margin also means the Company relies on 330 MW of market
power to meet its 5 percent Loss of Load Probability (LOLP) metric). If Avista reduced its
available market power assumption below 330 MW, the planning margin would need to
increase to some level above 16 percent to compensate for the reduction in available
market power.
b) Avista does not consider transmission as a constraint in resource adequacy planning at this
time. The transmission system from the Mid-C market to Avista's system is not congested
because it is counter to the energy flow from eastern resources to load centers in westem
Washington and Oregon.
c) Avista is uniquely located near a market hub and is connected to several larger utilities
including BPA. Avista's total transmission import capability is more than double Avista's
peak load.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-20-11
Staff
Production Request
Staff-026
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
Ut9l202t
John Lyons
John Lyons
Energy Resources
(s0e) 4es-8sls
REQUEST:
Does the contract information (e.9., 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.
RESPONSE:
Yes, the contract information is up to date. The negotiations with the successful bidders in the
2020 Renewable RFP are still in process. If new contracts are signed, they will be incorporated
into the L&R at that time.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATTON
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-20-11
Staff
Production Request
Staff-027
DATE PREPARED: lll9l202lWITNESS: John Lyons
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: [phone]
REQUEST:
In "Staff PR_001C Confidential Auachment 1," the note for o'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 reserves.
RESPONSE:
Since these loads are netted out with resources in the "Rights" portion of the load and resource
position (L&R); the choice to leave this load in the "Obligation" is a preference by the utility to
develop an L&R using a Balancing Authority point of view because it represents how the utility
actually operates its power system. Avista could remove third-party loads from the L&R and the
net position would be the same, so long as it capfures the extra reserve requirements these loads
and resources require.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION: IDAHO
CASE NO: AVU-E-20-11
REQUESTER: StaffTYPE: Production Request
REQUEST NO.: Staff-028
DATE PREPARED: lll9l202lWITNESS: John Lyons
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 495-2189
REQUEST:
Please explain "Pend Oreille Load" in the Load and Resource Balance? Please explain why Pend
Oreille Load is included in the Company's Obligation.
RESPONSE:
Avista currently provides balancing area services to Pend Oreille PUD. Pend Oreille PUD has
loads and resources Avista must provide operating reserves and load balancing services for as part
of the arrangement with the PUD. Pend Oreille PUD compensates Avista for this service and this
revenue lowers Avista's power supply cost. Given the load and resource balance is estimating the
total requirsments of the utility as discussed in prior production requests, this load and its
associated resources are included.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-20-11
Staff
Production Request
Staffi029
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
Ut9l202t
John Lyons
James Gall
Energy Resources
(s09) 49s-218e
REQUEST:
Please define "Capacity Seryices" in the Load and Resource Balance.
RESPONSE:
Avista occasionally sells capacity products or "services" to third parties outside its Balancing
Authority. These services are typically referred to as dynamic capacity or regulation services. In
this case, the third party is able to make instantaneous calls for power to either follow the third
party's load(s) or resource(s) requiring the flexibility. This line item could be used to account for
the sale of excess capacity or other capacity related products in the future.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION: IDAHO
CASE NO: AW-E-20-11
REQUESTER: StaffTYPE: Production Request
REQUEST NO.: Staff-030
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
U19l202t
James Gall
John Lyons
Energy Resources
(s0e) 4es-2t8e
REQUEST:
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?
RESPONSE:
Yes, Avista is obligated to provide ancillary services to all non-Avista loads within its balancing
authority at OATT rates. The effect on the load and resource balance are included within the
operating reserves and regulation line items.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-20-11
Staff
Production Request
Staff-O31
DATE PREPARED: lll9l202lWITNESS: John Lyons
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: [phone]
REQUEST:
Why is a regulation value of l6 MW constant throughout the planning horizon?
RESPONSE:
Avista must balance the load variance within the peak hour period. The peak load for a single hour
is actually the average load over the course of the hour. The actual load within the hour varies. The
16 MW labeled as o'regulation" represents the average of the maximum instantaneous load
variance within a typical historical peak hour. Avista must be able to flex its system
instantaneously within the hour to meet this higher load. Avista has chosen not to change this value
over time since it is a variance based on historical operations and the Company does not have
evidence this variation will increase or decrease over time.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-20-11
Staff
Production Request
Staff-032
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
Ut9l202t
John Lyons
John Lyons
Energy Resources
(s0e) 4e5-8s1s
REQUEST:
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 1."
RESPONSE:
The online balancing area calculations are made in the Operating Reserves row (Row 21) of the
lhr Peak and 18hr Peak tabs by multiplying the 3 percent load operating and 3 percent generation
operating reserves targets in rows 10 and l1 of the thr Peak and 18hr Peak tabs.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-20-11
Staff
Production Request
Staff-033
DATE PREPARED: lll9l202lWITNESS: John Lyons
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 495-851s
REQUEST:
Response to StafPs 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 balancingareaload plus three percent of
on-line balancing area generation, without the Frequency Response Requiranent in the formula
for calculating operating reserves in Excel spreadsheet, "StaLPR 001C Confidential Attachment
1." Please explain the discrepancy.
RESPONSE:
Staff is correct. Operating reserves must total three percent of on-line balancing area generation
and three percent of load. When meeting this operating reserve requirement, a portion must meet
the Frequency Reponses Requirement and the remaining must meet the requirement for the
amount of time necessary to sync to the grid requirement (non-spin reserves).
Note:
In the past, the requirement was half from spinning reserves and the other half was from
non-spinning reserues.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-20-11
Staff
Production Request
StaffiO34
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
Ut9l202t
John Lyons
James Gall
Energy Resources
(s09) 4es-2t89
REQUEST:
Why is the planning margin only applied to Peak Native Load and Net Clearwater Load, and not
other loads in the total obligation?
RESPONSE:
Avista does not plan to meet non-Avista native load future load obligations. All third-party load
within the Balancing Authority must also provide sufficient generation to meet its load for each
hour. Given the third-party loads bring their own generation each hour (including the peak hour),
Avista does not need to plan for any potential variation in the future.