20220318Staff 1-18 to Avista.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. II2O2
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].ti'ilflH lB PH l:30
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Street Address for Express Mail:
I 1331 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 COMPLIANCE FILING TO
UPDATE AND ESTABLISH ITS CAPACITY
DEFICIENCY PERIOD TO BE USED FOR
AVOIDED COST CALCULATIONS
cAsE NO. AVU-E-22-02
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,
Riley Newton, Deputy Attomey General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than FRIDAY, APRIL 8r2021.
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 identiff the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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I MARCH 18,2022
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: Please identiff the pros and cons of filing the biannual capacity
deficit date case when the IRP is submitted versus after the IRP is acknowledged?
REQUEST NO.2: Are the load and obligation amounts included in the load and
existing resource balance (L&R) for all scenarios the latest information available? If not, please
provide the latest load and obligation data and explain the causes for any differences to the
amounts included in the filing.
REQUEST NO. 3: Please confirm that PURPA contracts are assumed to renew in the
L&R for all scenarios.
REQUEST NO. 4: Does the contract information (e.g. contract execution, contract
renewal, and contract termination) included in the L&R for all scenarios reflect the latest
information? If not, please provide the latest information.
REQUEST NO.5: Are the University of Idaho's solar and steam PURPA projects
included in the L&R? If so, please provide the capacity contribution amount and explain the
method, with calculations, for determining the capacity contribution for each contract. Please
provide all workpapers in Excel format with formula intact.
REQUEST NO. 6: Table I of the Application shows the first deficit occurs on
November 1,2026, for the *2021Electric IRP" scenario with a deficit amount of 247 MW.
However, the corresponding excel file "1_PRiSM_7.0_GUROBI_120720_IRP_PRS_wCheIan"
shows that the first deficit occurs in the winter of 2023 with a deficit amount of 4 MW and that
the second deficit occurs in the year of 2027 with a deficit amount of 247 MW. Please answer
the following questions.
a. Please explain why the first deficit year is not2023.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MARCH 18,2022
b. Why does the excel file show that the 247-MW deficit occurs in2027 instead of
2026 as described in the Application?
REQUEST NO. 7: Page 4 of the Application states that each scenario does not change
the year of the annual deficit. However, Table I shows two first deficit years of 2026 and2027.
Please reconcile what is stated in the Application versus what is reflected in Table l.
REQUEST NO. 8: Please define "Colstrip Losses Adjustments" and explain why this
amount lasts for the entire planning horizon and explain how the amount is determined.
REQUEST NO. 9: Please define "Embedded EE (added back)" and "Selected EE."
What is the difference between the two? How is each determined? Why does the Company add
back Embedded EE to the Baseline Load Forecast to derive "Load Forecast w/o EE", and then
adjust it with Selected EE?
REQUEST NO. 10: Please answer the following regarding the planning margin.
a. Please define planning margin and explain its specific purpose.
b. Please explain why resources used to meet the planning margin requirements are
kept separate from the resources used to meet operating reserves, regulation
reserves, and frequency response requirements. In other words, why does the
planning margin not already include operating reserves, regulation reserves, and
frequency response requirements. In the explanation, please provide the reasons
why the resources used for these reserves and the resources used for the planning
margin cannot be shared.
REQUEST NO. 11: The format and categories included in the L&R in Case No. AVU-
E-20-l I are different than in this case. Please answer the following questions.
a. What does Baseline Load Forecast include? Does it include Peak Native Load,
Net Clearwater Load, Pend Oreille Load, Other Load in Balancing Area, Power
Deal Sales, and Capacity Services listed in Case No. AVU-E-20-1 1? Please
explain.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 MARCH 18,2022
b. In Case No. AVU-E-20-ll,the sum of Pend Oreille Load and Other Load in
Balancing Area is equal to Net Borderline In. However, Net Borderline In is
removed in this case. Does it mean Pend Oreille Load and Other Load in
Balancing Area are not included in the Baseline Load Forecast? Please explain.
c. In Case No. AVU-E-2}-ll, Operating Reserves are calculated as the sum of 3
percent of generation and 3 percent of load, where the load includes Peak Native
Load, Net Clearwater Load, Pend Oreille Load, and Other Load in Balancing
Area, while generation is calculated as the load plus Power Deal Sales minus
Power Deal Purchases and Net Borderline In. Please answer the following:
l. Does the Company use the same method to calculate Operating Reserves
in this case?
2. If so, why are Power Deal Sales and Capacity Services not considered as
part of the load?
3. Why is generation calculated as the load plus Power Deal Sales minus
Power Deal Purchases and Net Borderline In?
4. If the Company uses a different method to calculate Operating Reserves in
this case, please provide a comparison between the two methods and
explain why the two methods are mathematically equivalent.
5. If not equivalent, please explain the difference and why the Company
changed its method.
d. What is the amount of "Regulation" in the L&R? Please explain how the amount
is determined.
e. In Case No. AVU-E-2}-ll, planning margin is calculated based on the sum of
Peak Native Load and Net Clearwater Load. Has the calculation method changed
in this case? If so, please describe and explain the reasons for the change.
f. Is "Power Deal Purchases" in Case No. AVU-E-2O-11 the same as "PURPA
Contracts" in this case?
REQUEST NO. 12: What does "Long Term Sales" represent and include? Why does it
only last unt1l2023?
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 MARCH 18,2022
REQUEST NO. 13: Why is Adams Nielson Solar zero MW in winter?
REQUEST NO. 14: Why does Kettle Falls CT's contribution to winter peak only last
tntil2023, while its contribution to srrnmer peak lasts for the entire planning horizon?
REQUEST NO. 15: What does'Northeast A&B" represent?
REQUEST NO. 16: Please define "Winter Peak" in context to determining the deficit
date
REQUEST NO. 17: Please defure "Summer Peak" in context to determining the deficit
date
REQUEST NO. 18: Page 4 of the Application states that the PRiSM model does not
have the capability to show the month of the deficiency. How does the Company plan to develop
IRP-based avoided cost rates, which use higher-resolution data (i.e. monthly data and/or hourly
data)?
DATED at Boise, Idaho, this lffr^V of March 2022.
Riley N
Deputy General
i:umisc:prodreq/avue22.2myy prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 5 MARCH 18,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I8d' DAY OF MARCH 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-22-02,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
SHAWN BONFIELD
SR MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
MICHAEL G ANDREA
SENIOR COI.INSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W499220-3727
E-MAIL: [e-mail]
ARY
CERTIFICATE OF SERVICE