20220316Staff 1-8 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
I133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TTIE MATTER OF THE JOINT PETITION
OF AVISTA CORPORATION AND REGENTS
OF THE UNIVERSITY OF IDAHO FOR
APPROVAL OF POWER PURCHASE
AGREEMENT (STEAM)
CASE NO. AVU.E-22.03
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 WEDNESDAY, APRIL 6,
2022.
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 behalf, 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
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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1 MARCH 16,2022
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
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: Attachment 2 of the Agreement states that Maximum Generation
Injection at Point of Common Coupling is 825 kW. Please respond to the following:
a. How is "Maximum Generation Injection at Point of Common Coupling" defined by
the parties?
b. How is the value determined?
c. What percentage of Maximum Generation Injection at Point of Common Coupling is
expected to serve the University of Idaho's load?
d. Please confirm that the remaining percentage of Maximum Generation Injection at
Point of Common Coupling is expected to be sold to Avista.
e. What is the difference between Maximum Generation Injection at Point of Common
Coupling used in this case and Maximum Generation Injection at Point of
Interconnection used in Case No. AVU-E-22-04?
REQUEST NO.2: Attachment 2 of the Agreement states "Facilities - (3) 350 kW non-
traditional steam backpressure turbines using biomass as fueI." Please respond to the following:
a. Please confirm the statement means all three 350-kW turbines use biomass as fuel,
and no other types of fuel is used. If not, please provide details of fuel sources.
b. Will the project receive any Renewable Energy Credits ("RECs")?
c. Page 6 of the Agreement states "Seller shall retain and own all Environmental
Attributes generated by the Facility." Please explain why this project should be
entitled to 100% of the RECs.
REQUEST NO. 3: When was this project constructed? When did this project come
online? Has this project been a PURPA QF before?
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MARCH 16,2022
REQUEST NO. 4: Please provide the project's FERC Form 556.
REQUEST NO. 5: l8 CFR S 292.205 describes PURPA criteria for qualiffing
cogeneration facilities. Which criteria apply to this project? Has the project met its
corresponding criteria? If so, please provide evidence to support the answer.
REQUEST NO. 6: From February 16,2020, the effective date of the Agreement, until
now, has the project generated energy that it sold to the Company? [f so, what prices has the
Company paid to the Seller?
REQUEST NO. 7: Is this project included (or going to be included) in Avista's load and
resource balance? If so, please explain why a cogeneration project that generates non-firm
energy should be included in the load and resource balance.
REQUEST NO. 8: Please respond to the following regarding the PowerDex hourly
Mid-C index price:
a. Please explain what the PowerDex prices represent and how they are determined.
b. Has PowerDex changed the calculation method since Order No. 33048? If so, what
has changed?
c. Does PowerDex accurately represent firm or non-firm market prices today? Please
explain.
DATED at Boise, Idaho, ,n rl[\ay of Marc h2022.
i:umisc:prodreq/avue22.3dhyy prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3
Deputy Attorney General
MARCH 16,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l6fl' DAY OF MARCH 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
C0MMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-22-03,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
KEVIN HOLLAND MANAGER
WHOLESALE MARKETING &
CONTRACTS
AVISTA CORPORATION
POBOX3727
SPoKANE WA99220-3727
E-MAIL: kevin.holland@.avistacorp.com
dockets@ avi stacorp.com
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH ST
BOISE ID 83702
E-MAIL : [e-mail]
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-mail: [e-mail]
EDITH PACILLO SENIOR
ASSOCATE GENERAL COI.]NSEL
OFFICE OF GENERAL COUNSEL
3228 FRONT ST 324D
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
J, n*,.t
SECRET,ARZ
CERTIFICATE OF SERVICE