20210701Staff 1-8 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION' S 2O2I ELECTRIC
INTEGRATED RESOURCE PLAII
CASE NO. AVU.E.2I-04
FIRST 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, JULY 22,2021.
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 behall 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
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
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FIRST PRODUCTION REQUEST
TO AVISTA 1 ruLY 1,2021
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. 1: Table 1.1 in the202l Electric IRP shows the Preferred Resource
Strategy ("PRS") exiting Colstrip in2021. Please respond to the following:
a. Please explain why exiting Colstrip in202l was included in the PRS when the
Company has not shown that retiring Colstrip in that time frame is a possibility.
b. Please explain how including an earlier exit date for Colstrip in the PRS impacts
the portfolio cost and resource selections.
REQUEST NO. 2: The202l Electric IRP, page 2-18, states, "Loads and resources are
divided using the Production-Transportation (PT) ratio and resources must be selected to meet
individual state requirements." Please respond to the following:
a. Why it is appropriate to allocate based on the PT ratio for each of the following
attributes: (l) individual state loads; (2) individual state resources; (3) individual
state costs; (4) individual state benefits; and (5) any other attributes that use the
PT ratio in the 2021 IRP.
b. What other ratios or methods besides the PT ratio has the Company considered to
allocate load and resource requirements, costs, benefits, and other attributes?
c. Are there any advantages and disadvantages for using these other ratios or
methodologies in accurately determining resource requirements in the IRP.
REQUEST NO.3: PageT-2 of the Company's 2021Electric IRP describes the
difference between the E3 method and the Company's method for determining reserves. Please
provide a comparison of the different components of reserves for the two methods using year
2025 winter and summer as shown in Figure 7.1 as an example.
REQUEST NO. 4: Please provide a copy of the E3 study documenting the method and
results for the amount of reserves referenced on page 7.2 of the Company's 2021 IRP.
FIRST PRODUCTION REQUEST
TO AVISTA 2 ruLY 1,2021
REQUEST NO. 5: PageT-7 of the Company's 2021Electric IRP states that the Loss Of
Load Probability analysis assumes the Company could acquire up to 500 Megawatts ("MW")
from the market in non-regionally stressed hours and 330 MW in regionally stressed hours
recognizing that the market is not unlimited. Please explain:
a. How the Company determined that 500 MW is reasonable during non-regionally
stressed hours. Please include any evidence that supports this assumption.
b. How the Company determined that 330 MW is reasonable during regionally
stressed hours. Please include any evidence that supports this assumption.
c. Why the Company increased this amount from 250MW in previous IRPs to 330
MW. Please include any evidence that supports this assumption.
REQUEST NO. 6: In the 2021 Electric IRP, page 7-7, states, "Avista revised its market
reliance in this IRP up to 330 MW from 250 MW used in the previous IRPs. The change is
informed by regional work discussed in other parts of this report indicating that higher market
reliance is possible under a regional capacity planning effort." Please respond to the following:
a. What are the necessary and sufficient set of milestones included in the
implementation timeline of the regional capacity planning effort that will provide
increased market reliance to the Company?
b. When will the regional capacity planning effort provide increased market
reliance?
c. How the price of the additional 80 MW of market reliance is determined.
d. Has the Company in the last ten years had market constraints that prevented the
Company from purchasing more than 250 MW from the market?
REQUEST NO. 7: Please provide workpapers supporting Figure 7.1 on page 7-3 of the
2021Electric IRP.
REQUEST NO.8: Please provide workpapers supporting Figure 7.5 onpageT-6 of the
2021Electric IRP.
FIRST PRODUCTION REQUEST
TO AVISTA J JULY I,2O2I
DATED at Boise, Idaho, this Lb day of July 2021.
Deputy Attorney General
i:umisc:prodreq/avue2l.4dhme prod req I
FIRST PRODUCTION REQUEST
TO AVISTA 4 ruLY 1,202t
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l't DAY OF ruLY 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF Trm COMnflSSION
sTAf,'r' TO AVISTA CORPORATION, IN CASE NO. AVU-E-21-04, By E-MAILING
A COPY THEREOF, TO THE FOLLOMNG:
SHAWN BONFIELD
DAVID J MEYER
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
davi d. meyer@avi stacorp. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE