20210226Staff 35-60 to Avista.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR ELECTRIC AND NATURAL
GAS SERVICE FOR ELECTRIC AND
NATURAL GAS CUSTOMERS IN THE STATE
OF IDAHO.
CASE NO. AVU-E-?I.OI
AVU-G-21-01
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
Street Address for Express Mail:
1133I W CHINDEN BLVD, BLDG 8, SUITE 201.A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Jr., Deputy Attorney General, requests that Avista Corporation dba Avista
Utilities (ooAvista" or the "Company") provide the following documents and information as soon
as possible, or by FRIDAY, MARCH 19,2021,
This Production Request is continuing, and Avista 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. Avista 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 and if different the
witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY 26,2021
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. 35: Pages 2 through 6 of Ms. Knox's direct testimony describe the
10-year regression analysis used to normalize electric consumption for weather effects. Please
provide, in electronic format, the predictor (CDD, HDD and Trend) and consumption data for the
date range used to construct the regression model.
REQUEST NO.36: In its 2015,2016,2017 and20l9 electric rate cases (AVU-E-l5-05,
AVU-E-16-03, AVU-E-I7-01, and AVU-E-19-04),the Company based its Cost of Service
allocators on a Load Research Study performed by DNV-GL (dated January 22,2015). Were the
Cost of Service allocators for the present case based on the same study? If not, please provide the
information used as a basis for the allocators in the present case.
REQUEST NO. 37: The Company's electric weather normalization models assume there
to be linear relationships between Cooling Degree Days, Heating Degree Days, and Consumption.
Did the Company consider incorporating higher order curvature terms in its models? Please
explain.
REQUEST NO.38: The Company's electric weather normalization adjustments were
obtained by applying selected coefficients (sensitivity factors) from the Company's regression
model to its test year Heating and Cooling Degree days. Did the Company consider using the
whole model, instead of selected coeffrcients, to obtain its adjustments?
REQUEST NO.39: Pages 3 through 5 of Mr. Anderson's direct testimony describe the
10-year regression analysis used to normalize gas consumption for weather effects. Please
provide, in electronic format, the predictor (HDD and Trend) and consumption data for the date
range used to construct the regression model.
REQUEST NO. 40: According to Footnote No. 2 on page 5 of Mr. Anderson's direct
testimony, "Heating degree days that occur during July through September do not impact the
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY 26,20272
natural gas weather normalization adjustment as the seasonal sensitivity factor is zero for summer
months." However, the models on pages 10 through 13 in the accompanying workpapers
(Anderson Revenue Norm WPs.pdf) include factors for the summer months, as well as
interactions between the summer period, Heating Degree Days, and Year. Please explain the
apparent discrepancy between Footnote No. 2 and the workpapers.
REQUEST NO. 41: Please explain why Clearwater Transmission and Renewable Energy
Credits (REC) are netted to zero. Kalich Exhibit No. 9, Schedule 2,page 2.
REQUEST NO. 42: For the natural gas projects listed in Exhibit No. 7, please provide a
workpaper that breaks out the allocation of capital costs by jurisdiction for the years2020 -2023.
Thackston Exhibit No. 7.
REQUEST NO. 43: For the natural gas projects listed in Exhibit No. 11, please provide a
workpaper that breaks out the allocation of capital costs by jurisdiction for the years 2020 -2023.
Rosentrater Exhibit No. 11.
REQUEST NO. 44: For the natural gas projects listed in Exhibit No. 13, please provide a
workpaper that breaks out the allocation of capital costs by jurisdiction for the years 2020-2023.
Kensok Exhibit No. 13.
REQUEST NO. 45: For the natural gas projects listed in Exhibit No. 6, please provide a
workpaper that breaks out the allocation of capital costs by jurisdiction for the years 2020-2023.
Magalsky Exhibit No. 6.
REQUEST NO. 46: For the natural gas projects listed in Exhibit No. 8, please provide a
workpaper that breaks out the allocation of capital costs by jurisdiction for the years 2020-2023.
Kinney Exhibit No. 8.
REQUEST NO. 47: Please explain how the Company validated the single-zone method,
as described in Mr. Kalich's direct testimony, to ensure it can generate reasonable dispatch results
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY 26,2021aJ
REQUEST NO. 48: Please provide evidence using actual data that confirms that the size
of the Mid-C Market Resource (4274 MW) represents the availability of electricity that the
Company can purchase from the electricity market atany given time and that the size of the
Mid-C Market Load (twice Avista's area load in each hour) represents the amount of electricity
that the Company can sell into the market at any given time. Specifically, please provide data
showing the maximum amount that Avista has purchased from and sold into the market at any
time over the last five years.
REQUEST NO. 49: On page 4 of Mr. Kalich's direct testimony, it says, oolnstead of
iterating with modifications to many of the 'out-of-the-box' Model assumptions, thereby driving
calculated prices until they match forwards, we instead input forward prices directly." Please
provide the following:
a) Please list and describe the modifications to model assumptions the Company made to
drive calculated prices until they match forwards.
b) Please explain how using static forward electricity market prices and modeling the
"Market" as a single Mid-C Market Resource and a single Mid-C Market Load can be
more accurate than market prices typically produced in Aurora by modeling the amount
of supply and demand across the entire Western Electricity Coordinating Council
(WECC) region.
c) Please provide any data or evidence that the market forward prices are more accurate
than Aurora calculated market prices without modifications of inputs.
REQUEST NO. 50: As described in Mr. Kalich's direct testimony, please explain why
hydro dispatch depends on the area load shape and does not depend on the amount of load.
REQUEST NO. 51: As described in Mr. Kalich's direct testimony, please explain why
non-hydro resource dispatch is not affected by the size of the Mid-C Market Load.
REQUEST NO. 52: Please provide the actual average monthly market prices at Mid-C
and the average monthly forecasted Mid-C market prices used to generate the Net Power Costs in
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY 26,20214
the Company's original filing in Case No. AVU-E-19-04 for the period of December 1,2019
through November 30, 2020.
REQUEST NO. 53: The direct testimony of Mr. Kalich states that there was an
adjustment to load to account for a large customer being offline for a portion of the test year due to
a fire. Please quantiff the amount of adjustment, identifu the large customer, and provide the
dates it was offline.
REQUEST NO. 54: Section 7.2.2. of the Rattlesnake Flat PPA describes the Sales and
Use Tax Exemption. Please provide the amount of the Sales and Use Tax Exemption adjustments
applied to the contract prices.
REQUEST NO. 55: Please provide the forecasted REC prices in dollars per megawatt-
hour over the remaining contract periods for Rattlesnake Flat and Palouse Wind. Please provide
the data sources and basis for the estimates.
REQUEST NO. 56: Please provide an estimate of the cost to integrate electricity
produced by Rattlesnake Flat and Palouse Wind in dollars per megawatt-hour over the remaining
contract periods for each PPA. Please provide the source and basis for the estimates.
REQUEST NO. 57: Please explain why the tab and the table contained in workpaper
NaturalGas_Elec_Prices_2020_11032020.x1sx, tab "3 Mo Strip Price," table "3-Month Average
Forward Prices" is based on a three-month average while the direct testimony of Mr. Kalich states
that a one-month (from October 7,2020 through October 30,2020) average is used.
REQUEST NO. 58: Please provide the forward prices for natural gas and electricity
based on the latest one-month settlement period for the pro forma period.
REQUEST NO. 59: Please provide the pro forma net power cost adjustment and
corresponding revenue requirement reduction or increase with updates to confidential and non-
confidential schedules contained in Mr. Kalich's Exhibit No. 9 workpapers, for the following
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION
FEBRUARY 26,20215
scenarios using the natural gas forward prices and the electricity forward prices for September 1,
2021, through August 31,2022, based on the most recent one-month settlement period.
a. Include both Palouse Wind and Rattlesnake Flat in base rates.
b. Exclude Palouse Wind from the base rates.
c. Exclude Rattlesnake Flat from the base rates.
d. Exclude both Rattlesnake Flat and Palouse Wind from the base rates.
REQUEST NO. 60: Please provide Tara Knox's workpapers in Excel format with all
formula intact calculating the Load Change Adjustment Rate (LCAR).
Dated at Boise,Idaho, this 2c'fo"t of February 2021.
J Jr
Attorney General
i:umisc/prod req/avue21. l_avug2l. ljhmmmekskyy prod req2
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION
6 FEBRUARY 26,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF FEBRUARY 2021,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-21.01/AVU-G-21-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-mail: patrick.ehrbar@avi stacorp.com
avistadockets@avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail: [e-mail]
,ln,r/rL^-,
SECRETAR*/
CERTIFICATE OF SERVICE