20220323Avista to Staff 1-8.pdf

AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-22-03
IPUC
Production Request
Staff-0O1
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: (s09) 49s-2194
REQUEST:
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 lnjection at Point of Common Coupling is
expected to serve the University of Idaho's load?
d. Please confirm that the ranaining percentage of Maximum Generation Injection at Point of
Common Coupling is expected to be sold to Avista.
e. What is the dif[erence between Maximum Generation Injection at Point of Common
Coupling used in this case and Maximum Generation Injection at Point of Interconnection
used in CaseNo. AVU-E-22-04?
RESPONSE:
a. Attachment 2 to Exhibit D (Interconnection Agreement) defines the Point of Common
Coupling as: o'The secondary terminals of the Interconnection Customer's l3kV/480V
Transformer(s) where the lnterconnection Customer's secondary conductors are
connected." The Maximum Generation Injection at Point of Common Coupling is the
maximum amount of energy that may be injected at the Point of Corlmon Coupling, which
is equal to maximum generation capability of the facility (a.k.a, nameplate rating).
b. The Maximum Generation Injection at the Point of Common Coupling is based on the
maximum generating capability of the facility. Actual generation injected at this point is
determined via a production meter installed at that point.
c. 100 percent of the output of the facility is expected to serve the University of ldatro's load.
Any energy in excess of the University of Idaho's load will be sold to Avista.
d. The Maximum Generation lnjection at the Point of Common Coupling in both this case
and Case No. AVU-E-22-04 is based on the maximum generating capability of the
applicable resource. In this case, the maximum generating capability of the steam resource
is 825 kW. In Case No. AYU-E-22-04, the maximum generating capability of the solar
resource is 132.2 kW.
RECEIVED
2022 MAR 23 PM 2:50
IDAHO PUBLIC
UTILITIES COMMISSION
In the hypothetical situation tlrat the Universify of Idaho's load was zero. Then, modmum
Generation Injection at Point of lnterconnection would be the generating resorno{s) full
output minus losses as measured by the Primary Meter at the Point of Interoonnection
between Avista and the University of ldaho.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-22-03
IPUC
Production Request
Staff-002
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0312312022
N/A
Kevin Holland
Power Supply
(s09) 49s-2re4
REQUEST:
Attachment 2 of the Agreement states "Facilities - (3) 350 kW nontraditional steam backpressure
turbines using biomass as fuel." 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 Atfributes
generated by the Facility." Please explain why this project should be entitled to 100% of
the RECs.
RESPONSE:
The responses below are based in part on information provided to Avista by the University of
Idaho.
a. The steam facility will primarily use steam generated by biomass/wood boilers to produce
electric energy, but aminimal amount of steam produced by supplernental natural gas-fired
boilers may also be used in the production of electric energy. The following is a complete
description of the steam facility and the facility's fuel use: this facility's primary function
has been to provide steam to heat the University of Idaho's campus, and the University has
recently installed three turbine generators to capture and use the steam to produce electric
energy prior to using the steam for heating purposes on the University's campus. The steam
has been, and will continue to be, produced primarily from biomass in a wood boiler, but
supplonental steam is also produced through combustion of natural gas, primarily to meet
the University's peak heating needs in the winter. The biomass-derived steam is more than
sufficient to power the turbine generators at the electric power production capacity of the
three turbine generators. Therefore, under normal operating conditions, the facility would
not rely on the natural gas for purposes of generating electric energy. Each of three turbines
have a maximum limit of l4,4OO pounds per hour of steam, and thus the whole facility can
utilize 43,200 pounds per hour of steam for electric power production purposes (14,400 * 3: 43,200 lb/hr). The capacity of the biomass boiler is 60,000 pounds per hour, and
supplernental firing of the natural gas-produced steam occurs only after the biomass boiler
is operating at capacity or out of service. Thus, under normal operations, the steam capacity
of the turbines (43,200 lb/hr) will be maxed out before the biomass boiler reaches its
capacity (60,000 lb/hr) and before any extra steam produced from the natural gas boilers
beyond that passes through the electric generation and pressure reducing syste,m. Thus,
100% of the relevant energy into the turbines would come from biomass except during
biomass boiler shutdowns, which are expected to occur only during planned maintenance
and emergency outages.
b. The University has not completed an investigation of whether there will be any RECs
associated with the University of Idaho's steam facility. It is possible that the facility may
qualiff for production of RECs under the laws of certain nearby states or in voluntary REC
programs.
c. As an initial matter, as noted above, the parties are not certain that there will be any RECs
associated with the University of Idaho's steam facility. Additionally, it is not anticipated
that the University will deliver and sell much, if any, electric energy to Avista under the
Power Purchase Agreement (PPA) because such deliveries and sale of electric energy to
Avista would occur only when the University's load at its campus is less than the facility's
electrical production.
Under Commission precedent, a Qualiffing Facility (QF) that receive a standard avoided
cost rate retains all RECs. OrderNo. 32697 at45. Where QF is not eligible for an avoided
coat rate, and therefore, the rate is calculated using the IRP Methodology, the RECs are
allocated 50 percent to the QF and 50 percent to the utility. The Commission's rationale for
its allocation ofRECs either to solely the QF (for QFs eligible for the standard avoided cost
rate) or to be shared between the QF and the utility (for QFs that are not eligible for
standard avoided cost rates) is based on whether the SAR methodology or IRP
methodology is used.
In this case, the avoided cost rate is an as-available avoided cost rate and, therefore, neither
the SAR methodology nor the IRP methodology is used to establish the applicable avoided
cost rate. The Commission has not addressed the allocation of RECs under these
circumstances. For consistency, the determination of whether the RECs should be owned
by the QF or the utility in both this case and Case No. AVU-E-22-04 was based on whether
the particular QF would be eligible for standard avoided cost rates. The University's steam
facility at issue in this case is smaller than l0 aMWs and, therefore, would be eligible for
standard avoided cost rates and, therefore, the parties agreed that all RECs associated with
the steam facility, if any, are to be retained by the University. [n contrast, the solar facility
at issue in Case No. AVU-E-22-04 is greater than 100 kW and, therefore, that facility is not
eligible for standard avoided cost rates. Accordingly, in the PPA filed in Case No.
AVU-E-22-04, the parties agreed to allocate the RECs associated with energy delivered to
and purchased by Avista from that facility 50 percent to the University and 50 percent to
Avista. However, the University would retain ownership of RECs associated with energy
that serves the University's own load and is not delivered to or purchased by Avista.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION: IDAHO
CASE NO: AW-E-22-03
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Stafl003
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: (s09) 495-2t94
REQUEST:
When was this project constructed? When did this project come online? Has this project been a
PURPA QF before?
RESPONSE:
This response is based on information provided to Avista by the University.
The preexisting boilers that produce steam have been in service for many years and have been used
for the purpose of heating on the University's campus, but the University has installed the turbine
generators for production of electricity in the past year. As of the date of this response, the facility
has not completed commissioning for production of electric energy with the steam facility.
Commissioning is scheduled to be complete within the next month. The steam facility has not
previously been certified as a Qualiffing Facility with FERC.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-22-03
IPUC
Production Request
Staffi004
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: [phone]
REQUEST:
Please provide the project's FERC Form 556.
RESPONSE:
This response is based on information provided to Avista by the University.
The University of Idaho's steam facility is smaller than I MW and, therefore, is not required to file
a FERC Form 556. See 18 C.F.R. S 292.203(d)(l). However, the University intends to file a Form
556 with FERC for the facility and will serve a copy to the Commission at the time of filing.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-22-03
IPUC
Production Request
Staff:005
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
This response is based on information provided to Avista by the University
The University maintains that the steam facility will be qualified as a topping cycle cogeneration
facility by virtue of the facility's sequential use of thermal energy in the production of electric
energy and a useful thermal heating purpose on the University's campus. The University is still
finalizing the Form 556 that will demonsfrate the qualification criteria in detail and will selve a
copy of the Form 556 on the Commission at the time it is filed with FERC.
AVISTA CORPORATION
RESPONSE TO REQTIEST FOR TNFORMATTON
JURISDICTION: IDAHO
CASE NO: AW-E-22-03
REQUESTER: IPUCTYPE: Production Request
REQUESTNO.: Staff-006
DATE PREPARED: 0312312022WTINESS: N/A
RESPONDER: Kevin Hollaod
DEPARTMENT: Power Supply
TELEPHONE: (509\ 495-2194
REQIJEST:
From February 16,2020,the effective date of the Agreemen! until now, has the project generated
en€rgy that it sold to the Company? If so, what prices has the Company paid to the Seller?
RESPONSE:
No, to datc tlre project has not generated any en€rgy sold to Avista.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AYU-E-22-03
IPUC
Production Request
Staff-007
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
No, Avista does not intend to include the generation from this project in its load and resource
balance.
A\TISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AW-E-22-03
IPUC
Production Request
Staff-008
DATE PREPARED: 0312312022
WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: (s09) 49s-2194
REQUEST:
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.
RESPONSE:
a. PowerDex Mid-Columbia lndex is a commonly used index that provides hourly prices of
electricity traded at the Mid-Columbia trading hub. The prices are derived from reported
trades by participating entities.
b. Avista is not aware of any changes to how PowerDex hourly Mid-C index prices are
determined.
c. The PowerDex Mid-C index price can be either firm or non-firm depending on the
transaction. For example, the index price could be used for WSPP Schedule C firm
transactions or WSPP Schedule B unit contingent transactions. The PowerDex Mid-C
index is an index of prices for all transactions within an hour. In this power purchase
agreement, the PowerDex Mid-C index is used as a proxy for Avista's avoided cost of
energy on an as-available basis.