20210310Staff 61-95 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-21-01
AVU-G-21-01
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
: ': ;; ''.'' ;- I Y :6 *'
:-.! :i : -1 fl"f ln. q ?,. .--, .,;;.ii lU ftti {U' vc-
' i : '- _g:
"':f
i ;l_'a
j. *tfir\!
Street Address for Express Mail:
I133I W CHINDEN BLVD, BLDG 8, SUITE 2OT.A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Jr., Deputy Attomey General, requests that Avista Corporation dba Avista
Utilities ("Avista" or the "Company") provide the following documents and information as soon
as possible, or by WEDNESDAY, MARCH 31,2021.
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.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH IO,2O2I1
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. 61: Please provide the monthly historic Mid-C weighted-average market
prices, weighted by the number of on-peak and off-peak hours beginning December 2012 through
February 2021 in the same format as provided in response to Staff Production Request No. 127 in
Case No. AVU-E-19-04 with all formula intact (file name: StaflPR_I27C_Confidential
Attachment A.xlsx; tab: Historic Mid C Prices).
REQUEST NO. 62: Please provide the latest monthly forward Mid-C weighted average
market prices, weighted by the number of on-peak and off-peak hours beginning March202l
through December 2045 in the same format as provided in response to Staff Production Request
No. 127 in Case No. AVU-E-19-04 with all formula intact (file name:
StaffPR_|27C_Confidential Attachment A.xlsx; tab: Forward Mid C Prices).
REQUEST NO. 63: Please provide the2020 and202l IRP monthly forecasted Mid-C
weighted average market prices, weighted by the number of on-peak and off-peak hours over the
IRP-planning horizon in the same format as provided in response to Staff Production Request No.
127 in Case No. AVU-E-19-04 with all formula intact (file name: StaflPR_127C_Con{rdential
Attachment A.xlsx; tab: Draft IRP Mid C Prices).
REQUEST NO. 64: Please provide historic monthly generation of Palouse Wind from
the start of operation through the most recent fulI month of operation. Please also provide the
expected monthly generation of Palouse Wind from the most recent fullmonth of operation to the
end of the PPA term. Please provide the data in the same format as provided in response to Staff
Production Request No. 126 in Case No. AVU-E-19-04 with all formula intact (file name:
StaffPR_ I 26C _Confidential Attachment A.xlsx; tab : Palouse Wind).
REQUEST NO. 65: Have the contract prices for Palouse Wind changed from the
prices provided in the contract in response to Staff Production Request No. 128 in Case No.
AVU-E-19-A4? ff so, please provide an update to the pricing in Excel format.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH IO,2O2I2
REQUEST NO. 66: Please provide the average monthly Mid-C electricity prices
generated for all 500 Aurora Monte Carlo simulation runs for each month across the full planning
horizon for the 2020 IRP and202l IRP. Please provide the information in the same format as
provided in response to Staff Production Request No. 166 in Case No. AVU-E-19-04 with all
formula intact (file name : StaflPR_l 66C_Confidential Attachment A.xlsx).
REQUEST NO. 67: Please provide the average Mid-C electricity prices for the 500
iterations generated from the Company's Aurora Monte Carlo simulation runs for each hour across
the full planning horizon for the 2020 and 2021 IRP. Please provide the information in the same
format as provided in response to Staff Production Request No.115 in Case No. AVU-E-19-04
with all formula intact (file name: StaflPR_ll5C_Confidential Attachment A.xlsx).
REQUEST NO. 68: Please provide the percentage of the 500 Mid-C prices generated
from the Company's Aurora Monte Carlo simulation runs that are greater than or equal to the
Rattlesnake Contract Price (provide the comparisons to contract prices with and without the Sales
and Use Tax Exemption adjustments) for each hour across the full planning horizons for the2020
IRP and the 2021IRP. Please provide the information in the same format as provided in response
to Staff Production Request No.l15 in Case No. AVU-E-19-04 with all formula intact (file name:
StaffPR_l 1 5 C_Supplemental Attachment A - 20 17 IRP prices above rattlesnake
flats_Results.xlsx).
REQUEST NO. 69: Please provide the yearly difference in cost to the Company for
generation from the Rattlesnake Wind Project between the Mid-C Market price and the
Rattlesnake Contract price for each of the Company's 500 Aurora Monte Carlo simulation runs.
Please provide the differences using contract prices with and without the Sales and Use Tax
Exemption adjustments for both the2020 and202l IRP. Please provide the information in
the same format as provided in response to Staff Production Request No.115 in Case No.
AVU-E-19-04 with all formula intact (file name: StaflPR_l15C_Supplemental Attachment B -
Rattlesnake Margin by Iteration.xlsx).
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH IO,2O2IaJ
REQUEST NO. 70: Mr. Kalich's direct testimony states that in the past, Avista ran the
entire 8O-year hydro record through the Model, averaging the results. The Company now
dispatches resources using median monthly water levels derived from the 8O-year water record
under the single-zone method. Please answer the following:
a. Please describe the causal relationship between the hydro conditions used as an input
into the Model and the resulting Net Power Cost ("NPC"). For example, as hydro
conditions improve, does the resulting NPC decrease linearly or non-linearly? Are
there any discontinuities, asymptotes, or convergences in the results?
b. Has the Company analyzed and compared the two different treatments under the
single-zone method in terms of the result difference? If so, please provide the results
ofthe analysis and explain causes for any differences.
REQUEST NO. 71: Please reconcile Mr. Kalich's Exhibit No. 9, Schedule 2 and Ms.
Elizabeth Andrew's lD 2021Copy of Comp Summary of Wind Cases (with actuals), specifically
for the following items:
a. Account 555 actuals
b. Account 557 actuals
c. Account numbers for MT Invasive Species
d. Account 447 actuals
e. Account 456 actuals
REQUEST NO. 72: Please explain why Mr. Kalich's Exhibit No. 9, Schedule 2 does not
include the "Palouse Feather" line item, which is intended to capture the payment Avista makes to
Palouse Wind for the curtailed hours beyond the 50 hours in each rolling 2-year period allowed in
the contract. If the item is incorporated in the "Palouse Wind" line item, please break out Palouse
Feather from the 2019 actual and pro forma amounts and include workpapers that show how these
numbers are determined.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH IO,2O2I4
REQUEST NO. 73: There are several projects that use market index for pricing such as
Priest Rapids. Please answer the following questions.
a. Please list all the projects that use market index for pricing.
b. Please provide workpapers that calculate the pro forma numbers for each project using
the latest forward electricity prices in Response to Production Request No. 59.
c. Please confirm that the Response to Production Request No. 59 reflects updates of the
pro forma numbers for these projects.
REQUEST NO. 74: Please provide Avista's utility dividend payment policy. Identifu the
amounts of net income and actual dividend payments over the last five years.
REQUEST NO. 75: Please provide copies of all credit reports covering Avista issued by
Standard & Poor's, Moody's, Fitch, or any other credit rating agency over the last three years.
REQUEST NO. 76: Referencing witness Kinney's testimony on page 4, please provide
the Company's evidence that EIM participants are less likely to conduct bi-lateral transactions
close to the operating hour.
REQUEST NO. 77: Referencing witness Kinney's testimony on pages 4 and 5 of the
factors that led to the Company's decision to enter the EIM, how much weight was given to the
Company's clean energy goals and the Washington renewable regulations?
REQUEST NO. 78: How does the Company plan to ensure the Idaho ratepayers are not
going to pay for increased costs that result from Washington laws, rules, and initiatives?
REQUEST NO. 79: Please include a detailed breakdown of costs related to failed
infrastructure technology assets. Please identiff if failures are due to manufacturing defects,
human elror, and/or malicious actors. Please describe any other means for cost recovery pursued,
such as insurance reimbursements, and support why an increase to ratebase is the proper means of
recovery for these types of losses. Technology Failed Assets, Kensok Schedule l, page 12.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH IO,2O2I5
REQUEST NO. 80: Please provide a list of technology assets and the supporting
calculations that were used to determine the capital investment included in the Data Center
Compute and Storage Systems business case. Kensok at Schedule l,page 37.
REQUEST NO. 81: Please describe how the projects and investments included in the
Digital Grid Network business case, are different from several other business cases that ask for
technology investments to manage network technologies and optimize communications and
operations. Please include a detailed list of projects, cost estimates or cost breakdown, and
descriptions of projects included in the Digital Grid Network business case. Kensok, Schedule I
at 44.
REQUEST NO. 82: Please describe how the requested investment in the Endpoint
Compute and Productivity Systems business case is different from several other business cases
that ask for similar investments for real time data and communications and automated business
processes investments, and for replacing technology assets that have reached end of life. Kensok,
Schedule I at 55-63.
REQUEST NO. 83: Please provide a list of technology assets and the calculations that
were used to determine the capital funds request included in the Endpoint Compute and
Productivity Systems business case. Kensok at Schedule 1, page 58.
REQUEST NO. 84: Please provide descriptions, cost estimates, and timelines for projects
included in the Enterprise & Control Network Infrastructure business case.
REQUEST NO. 85: Please provide descriptions, cost estimates, and timelines for projects
included in the Enterprise Communications Systems business case. Kensok, Schedule I at75.
REQUEST NO. 86: Please describe the equipment, systems, and projects included in the
Environmental Control and Monitoring Systems capital investments business case. Kensok,
Schedule I at92.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH IO,2O2I6
REQUEST NO. 87: Please describe the significant increase in proposed investments for
the Atlas business case and provide a list and description of projects, cost estimates, and
timeframes for completion.
REQUEST NO. 88: Please provide descriptions, cost estimates, and timelines for projects
included in Outage Management Systems and Advanced Distribution Management. Kensok,
Schedule I at 155. Please describe how projects and technology investments for outage
management and electric and gas real time editing are separate from outage management and edit
tools included in business cases for Atlas and Energy Delivery Modemization.
REQUEST NO. 89: Please provide a list of Commercial off the Shelf Solutions that the
Company already has, and a list of those the Company intends to acquire as part of the Energy
Delivery Operational Efficiency business case. Kensok, Schedule 1 at 163.
REQUEST NO. 90: Please provide a cost breakdown for capital costs included in the
Energy Delivery Operational Efficiency business case. Kensok, Schedule I at 162.
REQUEST NO. 91: Please provide a cost breakdown for capital costs included in the
Energy Delivery Modemization & Operational Efficiency business case. Kensok, Schedule 1 at
t67.
REQUEST NO. 92: Please provide the project charter of costs, schedule, deliverables,
and benefits for projects included in the Energy Delivery Modernization & Operational Efficiency
business case. Kensok, Schedule I at 167.
REQUEST NO. 93: Please provide a detailed list and description of projects and cost
estimates included in the Enterprise Security ISflT Capital Project business case. Kensok
Schedule I at223.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION
MARCH IO,2O217
REQUEST NO. 94: Please provide a detailed list and description of security related
projects, timeframes, and cost estimates included in the Generation, Substation, and Gas Location
Security business case. Kensok at Schedule l,page234.
REQUEST NO. 95: Please describe how the projects, systems, and investments included
in the Enterprise Security business case are different from security projects and investments
included in Facilities and Storage Locations, and Generation, Substation & Gas Location Security
business cases. Kensok Direct at27-28.
Dated at Boise, Idaho, this 1Oft day of March202l.
John Jr
General
i:umisc/prod req/avue2l.l_avug2l. ljh prod req3
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION
8 MARCH IO,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IOTH DAY OF MARCH 2021,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
coMMrssroN STAFF To AVISTA CORPORATION, IN CASE NOS.
AVU-E-21-OI/AVU-G-21-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BO)( 3727
SPOKANE WA99220-3727
E-mail : patrick.ehrbar@avistacorp. com
avi stadockets @av i stacorp. com
BENJAMIN J OTTO
DAINEE GIBSON-WEBB
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-mail : [e-mail]
dgibson-webb@idahoconservation. org
VICKI M. BALDWIN
PARSON BEHLE & LATIMER
201 SOUTH MAIN STREET SUITE 18OO
SALT LAKE CITY UT 84I I I
E-mail: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W499220-3727
E-mail : david.meyer@avistacorp. com
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO WEST MAIN STREET SUITE I3OO
BOISE ID 83702
E-mail : [e-mail]
Electronic Service Only:
STEVE W CHRISS
DIRECTOR ENERGY SERVICES
WALMART INC
E-mail: [e-mail]
SECRE
CERTIFICATE OF SERVICE