20210319Avista to Staff 35-60 - Redacted.pdf

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION -i a ::1 * ; ! 1.+j\--ii..-Li U i4i.;#
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2l -01 / AVU-G-21-01
IPUC
Production Request
Staff-035
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
031171202r. ,', : !?F** , fl ala aA a *l
Tara Knox,..; rii:; i i ffl ld: l+ i
TaraKnox ir,,,.". 1Regulatory A&irs, "''*":':":J6'ps'
(s0e) 4es-432s
REQUEST:
Pages 2 through 6 of Ms. Knox's direct testimony describe the l0-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.
RESPONSE:
Please see StaflPR_035_Attachment A which is the Excel file containing the data that was
imported into the EViews program where the regressions were performed. Please see
StaflPR_035_Attachment B which is the EViews Workfile used to perform the electric
regressions.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION: IDAHO DATE PREPARED: 0311712021
CASE NO: AW-E-21-01 / AW-G-21-01 WITNESS: Tara Knox
REQUESTER: IPUC RESPONDER: Tara KnoxTYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-036 TELEPHONE: (509\ 49s-432s
REQUEST:
In its 2015, 2016, 2017 and 2019 electric rate cases (AVU-E-15-05, AVU-E-16-03,
AVU-E-17-01, 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.
RESPONSE:
As in prior cases, the demand allocators in the cost of service sfudy are indirectly based on the
DNV-GL load study completed for the 2015 General Rate Case (2015 Load Study). The demand
allocation factors are developed in the cost of service work paper file named "Demand l2CP
l2.20l9.xlsm". The 2019 system coincident peak estimation process utilizes average daily load
shapes from the 2015 Load Study to assign estimates of peak day loads to the peak hours. The
peak day load estimates are derived from 2019 billing information, weather statistics, and weather
sensitivity. The relationships of monthly average hourly load to class non-coincident peak loads
from the 2015 Load Study are multiplied by 2019 monthly average hourly loads (by class) to
estimate 2019 non-coincident peak demand.
The 2015 Load Study information is not used for the extra-large general service and lighting
service Schedules 25,25P, and 4l - 49. Actual 2019 hourly data is developed for the extra-large
general service classes, negating the need to estimate their dernand. Similarly, the lighting class
dernands are assumed based on 2019 recorded consumption and the 2019 hours of darkness.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATION
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: 0311712021
AVLI-E-21-01 / AVU-G-21-01 WITNESS: Tara KnoxIPUC RESPONDER: Tara Knox
Production Request DEPARTMENT: Regulatory AffairsStaff-037 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
No higher order terms were tested with the 2018 dataset electric regressions. However, two sets of
regressions were performed, differentiated by whether Cooling Degree Days were segregated into
shoulder and summer seasonality. The selected results do not segregate Cooling Degree Days by
season resulting in one sensitivity factor applied to all cooling adjustments.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION: IDAHO DATE PREPARED: 031171202t
CASE NO: AW-E-21-01 / AW-G-21-01 WITNESS: Tara Knox
REQUESTER: IPUC RESPONDER: Tara KnoxTYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-038 TELEPHONE: [phone]
REQUEST:
The Company's electric weather normalization adjustrnents 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
coefficients, to obtain its adjustrnents?
RESPONSE:
No, the purpose of the weather normalization is to adjust loads for weather. If the predicted model
were compared to booked usage it would eliminate other usage changes not associated with
weather (such as energy efficiency) that should be reflected in the test year.
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATION
IDAHO DATE PREPARED: 0311712021
AVU-E-21-01 / AVU-G-21-01 WITNESS: Joel AndersonIPUC RESPONDER: Joel Anderson
Production Request DEPARTMENT: Regulatory AffairsStaff-039 TELEPHONE: [phone]
REQUEST:
Pages 3 through 5 of Mr. Anderson's direct testimony describe the lO-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.
RESPONSE:
Please see StaflPR_039 Attachment A which is the Excel file containing the data that was
imported into the EViews progrilm where the regressions were performed. Please see
StaflPR_039 Attachment B which is the EViews Workfile used to perform the electric
regressions.
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 0311512021
AVU-E-21-01 / AVU-G-21-01 WITNESS: ElizabethAndrewsIPUC RESPONDER: Joel Anderson
Production Request DEPARTMENT: Regulatory AffairsStaff-040 TELEPHONE: [phone]
REQUEST:
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 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 surlmer 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.
RESPONSE:
Footnote No. 2 on Page 5 of Anderson testimony was inadvertently included in testimony. The
associated sentence on line 2 and 3 of page 5 of Anderson testimony should read as follows, "The
adjustment to normal required the decrease of 235 heating degree-days from January through
Decernber" with no footnote. This updated language is supported by Page 15 in (Anderson
Revenue Norm WPs.pdf).
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 1 -0 1/AVLr-G -21-0t
IPUC
Production Request
Staff - 041
DATE PREPARED: 0311712021WITNESS: Clint Kalich
RESPONDER: Clint Kalich
DEPARTMENT: Power Supply
TELEPHONE: [phone]s32
REQUEST:
Please explain why Clearwater Transmission and Renewable Energy Credits (REC) are netted to
zero. Kalich Exhibit No. 9, Schedule 2, page 2.
RESPONSE:
As explained on page 20 (beginning at line 1) of my direct testimony, the Clearwater
self-generation contract results in no net power expense, but it does result in the Company's 10olo
share of the REC revenues offset by the Company's 10% share of associated transmission expense
(net revenue from RECs sold), both of which are directly assigned to the Idaho jurisdiction.
As per the Clearwater contract approved in Case No. AVU-E-18-13, actual values for the
Company's 10% share of the net revenue from REC sales are intended to flow through the PCA
subject to the 90/10 sharing. Therefore, any test year net REC proceeds must be pro formed to $0
in order to exclude them from retail ratemaking and establishment of the PCA base.
The following excerpt from CaseNo. AVU-E-18-13 Joint Petition ofAvista and ClearwaterPaper
(pages 7 and 8) outlines the approved treatment of the RECs net of associated transmission
expense.
(g) Under the terms of the REC deal with the Third Party, 100% of the total REC
value from RECs associated with Clearwater's Generation will be directly assigned
to the Idaho jurisdiction. Of the total REC proceeds from RECs associated with
Clearwater's Generation, Clearwater will receive 90o/o of the net revenue from
RECs sold to the Third Party; the remaining llYo of the net revenue from RECs
sold to the Third Party will flow through the PCA to all Idaho customers at the
90%ll0% sharing. T}rre9}% net benefit to Clearwater from such REC sales will be
separately credited directly to Clearwater through a monthly bill credit. T\e l0o/o
net benefit from such REC sales for all Idaho customers will be excluded from
retail ratemaking for base retail rates, and would flow through the PCA subject to
the90%ll0% sharing.
Page 1 of1
AYISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: 0311912021
AW-E-21-01 / AVU-G-21-01 WITNESS: K. Schultz/J. ThackstonIPUC RESPONDER: Kaylene Schultz
Production Request DEPARTMENT: RegulatoryAffairsStaff-042 TELEPHONE: [phone]
REQUEST:
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 years 2020 -2023. Thackston Exhibit No. 7.
RESPONSE:
Thackston Exhibit No. 7 does not sponsor any natural gas capital projects.
The Company has updated Pro Forma Adjustment 3.08 - 2020 Pro Forma EOP to reflect actual
2020 transfers to plant, including retirements, for both electric and natural gas. The Company has
also updated Pro Forma Adjustment 3.09 - 2021Pro Forma EOP to reflect variances between final
2020 expected transfer to plant amounts and 2020 year-end CWIP (as described in Company
Witness Ms. Schultz's testimony) for both electric and natural gas. The cascading effect of
updating Pro Forma Adjustments 3.08 - 3.09 can be seen in Pro Forma Adjusbnents 3.10, 22.01,
and22.02. Please see Staff-PR-O43 for more information.
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 031191202r
AW-E-21-01 / AVU-G-2l-01 WITNESS: K. Schultz,/H. RosentraterIPUC RESPONDER: Kaylene Schultz
Production Request DEPARTMENT: Regulatory AffairsStaff-043 TELEPHONE: (509) 49s-2482
REQUEST:
For the natural gas projects listed in Exhibit No. 1 1, please provide a workpaper that breaks out the
allocation of capital costs by jurisdiction for the years 2020 -2023. Rosentrater Exhibit No. I I .
RESPONSE:
The Company has updated Pro Forma Adjustrnent 3.08 - 2020 Pro Forma EOP to reflect actual
2020 transfers to plant, including retirements, for both electric and natural gas. The Company has
also updated Pro Forma Adjustment 3.09 - 2021Pro Forma EOP to reflect variances between final
2020 expected transfer to plant amounts and 2020 year-end CWIP (as described in Company
Witness Ms. Schultz's testimony) for both electric and natural gas. The cascading effect of
updating Pro Forma Adjustments 3.08 - 3.09 can be seen in Pro Forma Adjustrnents 3.10, 22.01,
and22.02. Please see Staff PR_043 Attachment A fortheupdated adjustments. Boththe "Eleckic
SUM 2020-2021 Update" and *Nat. Gas SUM 2020-2021 Update" tabs show the variance
between adjustments from the Company's original filing and this 2020-2021update.
Staff PR_043 Attachment B contains the electric and natural gas transfers to plant detail for years
2020-2023, which is the basis for the monthly plant additions inputs in Sta[PR_043 Attachment
(see tabs "Summary-Cost-E" and ooSummary-Cost-G"). In Sta[PR_043 Attachment B, on the*CAP 2020-2023 Plant Additions" tab, the user can filter Column A - ooID Witness" for the
desired Company witness. Specifically, monthly Idaho natural gas transfer to plant balances can be
see in Column AO through Column BA; the associated year is listed by project in Column J.
The Company intends to update Pro Forma Adjustments 3.09 - 3.10, 22.01 -22.02 with Q1 actual
2021 transfers to plant and a re-forecast of April - Decernber 2021 when available. The system
re-forecast is expected to be available in late Apil 2021, with the jurisdiction reallocation
available to update this response the first two weeks of May.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: 0311912021
AVU-E-21-01 / AVU-G-21-01 WITNESS: K. Schultz./J. KensokIPUC RESPONDER: Kaylene Schultz
Production Request DEPARTMENT: Regulatory AffairsStaft-044 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Please see Staff-PR-043 for the 2020-2023 natural gas project detail sponsored by Company
witness Mr. Kensok.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: 0311912021
AW-E-21-01 / AVU-G-21-01 WITNESS: K. Schultz/K. MagalskyIPUC RESPONDER: Kaylene Schultz
Production Request DEPARTMENT: Regulatory AffairsStaff-045 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Please see Staff-PR-O43 for the 2020-2023 natural gas project detail sponsored by Company
witness Mr. Magalsky.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: 0311912021
AVU-E-21-01 /AVU-G-21-01 WITNESS: K. Schultz/S. KinneyIPUC RESPONDER: Kaylene Schultz
Production Request DEPARTMENT: Regulatory AffairsStaff-046 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Please see Staff-PR-043 for the 2020-2023 natural gas project detail sponsored by Company
witness Mr. Kinney.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION: IDAHO
CASE NO.: AVU-E-2l-01/AVU-G-21-01
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Staff- 047
DATE PREPARED: 0311712021WITNESS: Clint Kalich
RESPONDER: Clint Kalich
DEPARTMENT: Power Supply
TELEPHONE: (s09) 49s-4s32
REQUEST:
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.
RESPONSE:
The Company validated the results of the single-zone method by reviewing the overall dispatch
against historical operations and how plants performed in individual periods. The single-zone
method, sometimes also called the input-pricing method, is greatly simplified from how Aurora
normally would calculate dispatch. This is because the majority of the math Aurora normally
performs, i.e., developing market prices, is not needed.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 1 -0 l /AVU-G -21 -0t
IPUC
Production Request
Staff - 048
DATE PREPARED: 03117 12021WITNESS: Clint Kalich
RESPONDER: Clint Kalich
DEPARTMENT: Power SupplyTELEPHONE: [phone]
REQUEST:
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 at any 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.
RESPONSE:
There is no evidence to confirm Mid-C market availability. The market must exceed the possible
maximum sale and/orbuy needed in each hour. This is the same as in past filings. In the
multi-zonal WECC model Avista and the Mid-C market were contained together in the northwest
market "bubble," meaning there were no market liquidity limits. Were Avista to introduce such
limits based on historical transaction levels, the result would be higher filed rates because the
market would not be as available to optimize our portfolio.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 1 -0 1 /AW-G -21 -0t
IPUC
Production Request
Staff - 049
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0311712021
Clint Kalich
Clint Kalich
Power Supply
(s0e) 4es-4s32
REQUEST:
On page 4 of Mr. Kalich's direct testimony, it says, "Instead 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 elecricity 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.
RESPONSE:
The Company made no assumption changes to drive prices to equal forwards because forward
prices were directly input into the model making this step unnecessary. While Aurora would in the
past been relied upon to determine the intra-month hourly price shape applied to monthly on- and
off-peak prices, in this case we use actual test-year hourly shapes, as described in testimony.
In past cases we essentially drove market prices to equal forwards. We were required to greatly
modifr assumptions affecting loads and dispatch to where we would substantially achieve prices
equal to forward prices. Over time this effort became more difficult to the point where Avista
became uncomfortable with the assumptions having to be made. Besides having to make these
large changes relative to cases further in history where smaller changes were necessary, the effort
was very time consuming and difficult to achieve. It also made updating prices during a case
difficult. Given that the goal of previous cases was to modiff input assumptions in Aurora to
achieve prices equal to the forward prices, by definition inputting actual forward prices is more
accurate.
Inputting market forward prices is by definition more accurate than iterating with Aurora in an
attempt to closely match forward prices.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION: IDAHO
CASE NO.: AVU-E-21-01/AVU-c-2r-01
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Staff- 050
DATE PREPARED: 03117 /2021WITNESS: Clint Kalich
RESPONDER: Clint Kalich
DEPARTMENT: Power Supply
TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Since hydro dispatch is tied to Avista's load shape, hydro runs to maximize its value relative to our
load by reducing peaks. Further, the dispatch is compared to ensure energy dispatch reflects our
5-year average hydro operations. Lastly, dispatch is not affected by the size of the Mid-C market
load so long as that load is large enough to "consume" all surplus Company generation, which it is.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 I -01/AVLr-G -21-01
IPUC
Production Request
Staff- 051
DATE PREPARED: 03117 12021WITNESS: Clint Kalich
RESPONDER: Clint Kalich
DEPARTMENT: Power SupplyTELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Dispatch is not affected by the size ofthe Mid-C market load so long as that load is large enough toooconsume" all surplus Company generation, which it is.
Page 1 of1
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 l -0 I /AW-c -2t -01
IPUC
Production Request
Staff- 052
DATE PREPARED: 0311712021WITNESS: Clint Kalich
RESPONDER: Clint Kalich
DEPARTMENT: Power SupplyTELEPHONE: [phone]
REQUEST:
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 the Company's original
filing in Case No. AVU'E-19-04 for the period of Decemb er 1,2019 through November 30,2020.
RESPONSE:
Please see Avista's response 052C, which contain TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
Staff PR_052C Confidential Attachment A - *2020 Mid-C Actual Prices (PR52C).xlsx provides
actual Mid-C prices for 2019 and2020. Staff PR_052C Confidential Attachment B - 2018 Idaho
Power Supply Adjustment (Apr 2019) (PR52C).xlsx is from our original filing in the
AVU-E- I 9-04 case. Please refer to tab "Mid-C Price Comparison" for the filed values in that case.
Page I ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 1 -0 1 /AW-G -2t -01
IPUC
Production Request
Staff - 053
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
031t712021
Clint Kalich
Lori Hermanson/Tara Knox
Power Supply/Regulatory Affairs
(sOe\ 4e s -4658(s0e) 4e s -432s
REQUEST:
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 quantif,i the amount of
adjustment, identifu the large customer, and provide the dates it was offline.
RESPONSE:
Please see Avista's response 053C, which contain TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
Please refer to Kalich electronic work paper'Native Load Table_2020 weather adj.xlsx", sheet
'weather correction' (starting in cell C68) which includes the large customer adjustment in the
amount of 6,994,487 k to being grossed for line losses.
The retail revenue side of this adjustment is included in the Knox Revenue Normalization
workpapers. The sales adjustment is shown on workpaper reference page REV-4 of AVU-E-2l
Knox REV workpapers. Please see Staff PR 053C Attachment A CONFIDENTIAL that
contains support for the 2019 Schedule 21 Adjustment,2019 Schedule 25 iustment for actual
billed, and 2019 Schedule 25 Adjustment for Expected monthly values resulting in the Net
Increase/(decrease) in overall load values that were provided to Mr. Kalich.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: 0311712021
AW-E-21-01 / AW-G-21-01 WITNESS: Clint KalichIPUC RESPONDER: Annette Brandon
Production Request DEPARTMENT: Power SupplyStaff-054 TELEPHONE: (509\ 495-4324
REQUEST:
Section 7.2.2 of the Rattlesnake Flat PPA describes Sales and Use Tax Exemption. Please provide
the amount of the Sales and Use Tax Exemption adjusfinents applied to the contract prices.
RESPONSE:
The agreed upon exemption amount for the Sales and Use Tax exemption was based on a
negotiated rate of $1.25lMW.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 0311712021
CASE NO: AVU-E-21-01 / AVU-G-21-01 WITNESS: Clint Kalich
REQUESTER: IPUC RESPONDER: Annette BrandonTYPE: Production Request DEPARTMENT: Power Supply
REQUEST NO.: Staff-055 TELEPHONE: [phone]
REQUEST:
Please provide the forecasted REC prices in dollars per megawaff-hour over the remaining contract
period for Rattlesnake Flat and Palouse Wind. Please provide the data sources and the basis for the
estimates.
RESPONSE:
The best estimate for the value of Renewable Energy Credits (REC) for the forward time period is
$7.50 based on abroker quote from Karbone. This suggests the average pricing for RECs couldbe
$7.50, however the price will most likely be higher for a larger transaction amount or further out
into the future. RECs are a dynamic market and the price is volatile depending on supply and
demand. Because we cannot sell our RECs as WA compliant and the Company has not had a need
to purchase any, we don't have any acfual transactions to verifr current or future prices. As such,
$6-$8 is a reasonable assumption. However, the amount could vary based on how large a purchase
or how far into the future you need to secure, etc.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-2 I -0 I /AW-G -21 -01
IPUC
Production Request
Staff - 056
DATE PREPARED: 03117 12021WITNESS: Clint Kalich
RESPONDER: Clint Kalich
DEPARTMENT: Power SupplyTELEPHONE: [phone]
RE,QUEST:
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.
RESPONSE:
The cost to integrate the wind projects is based on our 2007 wind integration study. T\e2007
study is a single value and therefore is applied to each year. The Company will perform a new
study this year, but continues to rely on the 2007 work until such time as a new study is available.
We do not apply integration on a per-MWh basis, but instead charge $1.067/kw-month. The rate
used is contained in StaflPR_056 Attachment A - "Avista 2007 Wind lntegration Cost Summary
(PR56).xlsx." Our 2007 Wind Integration Study is available on our website at the following
location:
https://www.myavista.coml-lmelia/myavista/content-documents/about-us/our-company/irp-docu
ments/archive/avi stawindintegrationstudy. pdf
Page 1 ofl
1TAVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 I -0 I /AVU-G -2t -01
IPUC
Production Request
Staff- 057
DATE PREPARED: 0311712021WITNESS: Clint Kalich
RESPONDER: Lori Hermanson
DEPARTMENT: Power Supply
TELEPHONE: [phone]
REQUEST:
Please explain why the tab and the table contained in workpaper NaturalGas_Elec_Prices 2020_
ll032020.xlsx, 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 thata one-month (from
October 1,2020 through October 30,2020) average is used.
RESPONSE:
In Kalich workpaper'NaturalGas_Elec_Prices]020_11032020.x1sx" the tab"3 Mo Price" was a
labeling error and should have been updated to "l Mo Price Strip." In addition, the table "3-Month
Average Forward Prices" was a labeling error that should have been updated to "l-Month Average
Forward Prices." You'll see from the query copied into that same sheet that the actual period
queried was October I - October 30,2020 as stated in Mr. Kalich's direct testimony.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 1 -0 t/AW-G -21 -01
IPUC
Production Request
Staff - 058
DATE PREPARED: 03/17 /202rWITNESS: Clint Kalich
RESPONDER: Lori Hermanson
DEPARTMENT: Power Supply
TELEPHONE: (s09) 495-4658
REQUEST:
Please provide the forward prices for natural gas and electricity based on the latest one-month
settlement period for the pro forma period.
RESPONSE:
The first set of prices below reflect forward electric and natural gas prices for the period January
28 - February 26,2021. The originally filed values are shown in the second set of columns.
Price $/dth (updated)Price $/dth (as filed)
Basin AECO Malin
Mid-C
off
Mid.C
On AECO Malin
Mid-c Mid-c
On
Sep-21 2.21 2.93 33.85 55.91 2.08 2.87 27.78 45.33
Oct-21 2.32 2.88 27.01 33.35 2.15 2.84 25.85 32.67
Nov-21 2.42 3.31 27.30 33.74 2.31 3.t2 30.25 36.98
Dec-21 2.52 3.68 34.46 44.34 2.4t 3.46 39.82 49.49
Jrn-22 2.s8 3.73 32.40 42.02 2.48 3.59 34.78 44.96
Feb-22 2.56 3.58 28.88 36.t9 2.48 3.45 30.88 38.45
lslar-22 2.36 3.0s 23.46 28.02 2.33 2.91 26.76 32.31
Apr-22 1.89 2.33 13.08 19.83 1.8s 2.28 t3.92 20.37
Iu{ay-22 1.78 2.27 6.22 t4.63 1.74 2.21 10.36 19.66
Jw-22 1.73 2.30 r0.27 18.32 1.72 2.24 8.74 20.t4
Jttl-22 1.80 2.49 2t.21 42.94 1.77 2.37 24.54 44.44
Atrs-22 1 .81 2.5r 33.42 56.34 t.77 2.39 28.39 49.19
Avq 2.t6 2.92 24.30 35.47 2.09 2.8t 25.17 36.17
Page I ofl
A\TISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-2 I -0 I /AVU-G -2t -01
IPUC
Production Request
Staff- 059
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
031t71202r
Clint Kalich
Lori Hermanson
Power Supply
(s0e) 4es-46s8
REQUEST:
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 scenarios using the natural gas forward
prices and the electricity forward prices for September l,2l2l,through August 3l,2022,based on
the most recent one-month settlement period.
a.
b.
c.
d.
lnclude both Palouse Wind and Rattlesnake Flat in base rates.
Exclude Palouse Wind from the base rates.
Exclude Rattlesnake Flat from the base rates.
Exclude both Rattlesnake Flat and Palouse Wind from the base rates.
RESPONSE:
See Staff PR_059 Attachment A - Comparative Summary of Wind Cases (PR59).xlsx for the
results of the 4 scenarios above with the as filed forwards and the updated forwards for the period
of ll28l2l-2126121.
Page 1 ofl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: 0311712021
AW-E-21-01 / AVU-G-21-01 WITNESS: Tara KnoxIPUC RESPONDER: Tara Knox
Production Request DEPARTMENT: Regulatory AffairsStaff-060 TELEPHONE: (s09) 49s-432s
REQUEST:
Please provide Tara Knox's workpapers in Excel format with all formula intact calculating the
Load Change Adjustment Rate (LCAR).
RESPONSE:
Electronic versions of the printouts provided in my LCAR workpapers were included in either Ms.
Andrews or my native format work papers in the Company's initial filing. The following table
indicates the location of associated electronic format files.
Annotated versions of Results of Operations are provided here as Staf{_PR_060_Attachment A
and Staff PR 060 Attachment B.
Native work File Name Tab Name
Reference
folder Sub-FolderNo.if icable
Annotated Version
LCAR-8
LCAR-9
LCAR-10
LCAR.11
LCAR-12
LCAR-1:}
tcAR-14
tcAR-15
rcAR-16
LCAR-17
LCAR.18
LCAR.19
LCAR-20
LCAR-21
LCAR-22
LCAR-23
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. AndrewsWorkpapers
4. Elizabeth M. Andrews Workpapers
16. Tara L Knox Workpapers
16. Tara L. Knox workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. Andrews Workpapers
16. Tara L Knox Workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. Andrews workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M, Andrews workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. Andrews Workpapers
4. Elizabeth M. Andrews Workpapers
16. Tara L. Knox workpapers
15. Tara L. Knox Workpapers
16. Tara L. Knox Workpapers
2019 lD Electric RR Model-09.01.2021
2019 lD Electric RR Model-09.01.2021
124-2019.12_Avista Electric Pull
Functionalization lD 2019
Functionalization lD 2019
124-2019.12_Avista Electric Pull
12A-2019.12_Avista Electric Pull
124-2019.12_Avista Electric Pull
Functionalization lD 2019
124-2019.12_Avista Electric Pull
12E-2019.12_Avista Electric Pull
12E-2019.12_Avista Electric Pull
12E-2019.12_Avista Electric Pull
1) lD Pro Forma Plant Adi - SUMMARY
1) lD Pro Forma Plant Adj - SUMMARY
1) lD Pro Forma Plant Adi - SUMMARY
1) lD Pro Forma Plant Adj - SUMMARY
1) lD Pro Forma Plant Adi - SUMMARY
1) lD Pro Forma Plant Adi - SUMMARY
Functionalization lD 201!)
Functionalization lD 20()
lDElec COS Base Case AVU-E-21-01
lDElec COS Base Case AVU-E-21-01
PCA LCAR Calc-21-22
PCA LCAR Calc-21-22
E-OPS
454 Revenue
456 Revenue
E-PLT
E-PLT
E-PLT
lntangible
E.APL
E.PtT
E-PLT
E.PLT
E-CAP SUMMARY
E-CAP SUMMARY
E-CAP SUMMARY
E.CAP SUMMARY
E.CAP SUMMARY
E-CAP SUMMARY
ADFIT
lD Retail Load
SUMCOST
Sumcost Exhibits
Lm Results of Operations - 2019
ECOS workpapers native
ECOS workpapers native
Lm Results of Operations - 2019
Lm Results of Operations - 2019
1.00 Results of Operations - 2019
ECOS workpapers native
1.00 Results of Operations - 2019
1.00 Results of Operations - 2019
1.00 Results of Operations - 2019
1.00 Results of Operations - 2019
3.08-3.10 22.01-22.02 PF - Capital Additions
[e-mail] 27.01-22.02 PF - Capital Additions
[e-mail] Z2.OL-22.02 PF - Capital Additions
3.08-3.10 22.01-22.02 PF - Capital Additions
3.0&3.10 22.01-22.02 PF - Capital Additions
3.08-3.LO 22.0L-22.02 PF - Capital Additions
ECOS workpapers native
ECO5 workpapers native
ECOS workpapers native
LCAR.1
Attachment A
15. Tara L. Knox
LCAR.2
ECOS native
LCAR.7
Attachment A
Attachment A
Attachment A
Attachment A
Attachment B
Attachment B
Attachment B
LCAR-4
LCAR-5
LCAR.5