20220316Staff 1-7 to Avista.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. II2O2
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION
OF AVISTA CORPORATION AND REGENTS
OF THE UNIVERSITY OF IDAHO FOR
APPROVAL OF POWER PURCHASE
AGREEMENT (SOLAR)
cAsE NO. AVU-E-22-04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Riley Newton, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than WEDNESDAY, APRIL 612021.
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
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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1 MARCH 16,2022
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: Exhibit A of the Agreement states that Maximum Generation
Injection at Point of Interconnection is 132.2 kW (AC). Please answer the following questions.
a. What does "Maximum Generation Injection at Point of Interconnection" mean?
b. What percentage of Maximum Generation Injection at Point of Interconnection is
expected to serve the University of Idaho's load?
c. Please confirm that the remaining percentage of Maximum Generation Injection
at Point of Interconnection is expected to be sold to Avista.
d. FERC Form 556 states "[t]he array is connected to the primary 480V switchgear
for the building and does not have battery storage since the building electrical
load exceeds the total output of the anay." Given this, is it likely that the project
will sell energy to Avista? Please explain.
e. What is the difference between Maximum Generation Injection at Point of
Common Coupling used in Case No. AYU-E-22-03 and Maximum Generation
Injection at Point of Interconnection used in this case?
f. Page2 of the Joint Petition states that the project is 132.32 kW. Please confirm
that it should have been 132.2kW.
g. Section 7(g) of FERC Form 556 shows that the maximum net power production
capacity is 132.0 kW. Please reconcile this value and the 132.2kW listed in the
Exhibit A of the Agreement.
h. Does the actually installed nameplate size match the 132.2 kW listed in Exhibit A?
REQUEST NO.2: FERC Form 556 states that the facility consists of a solar array with
368 PV modules (400 W DC each), and the maximum gross power production capacity is 147.2
KW (DC). Please confirm that the 400 Watts for each module should have been 0.4 Watts.
REQUEST NO.3: Page 6 of the Agreement states "[t]o the full extent allowed by
applicable laws or regulations, Avista shall own or be entitled to claim fifty percent of the
FIRST PRODUCTION REQUEST
TO AVTSTA CORPORATION 2 MARCH 16,2022
Environmental Attributes associated with the Net Output delivered to Avista." What are the
applicable laws or regulations that the Agreement is referring to?
REQUEST NO. 4: FERC Form 556 states that the facility is expected to be installed by
February 25,2022, and to begin operation on February 25,2022. When was this project
constructed? When did this project begin operation and start selling power to Avista?
REQUEST NO. 5: From the frst operation date until now, has the project generated
energy and sold it to the Company? If so, what prices has the Company paid to the Seller?
REQUEST NO. 6: Is this project included (or going to be included) in Avista's load and
resource balance? If so, please explain why a project that generates non-firm energy should be
included in the load and resource balance.
REQUEST NO. 7: Please answer the following questions 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 methodology since Order No. 33048? If
so, what has changed?
c. Is the PowerDex still a reasonable representation of firm or non-firm market
prices today? Please explain.
DATED at Boise, Idaho, this [6S au, of March
ewton
Deputy Attomey General
i:umisc:prodreq/av ue22.4myy prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION J MARCH 16,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l6th DAY OF MARCH 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO rDAHO POWER COMPAIYY, IN CASE NO. AVU-E-22-04,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
KEVIN HOLLAND MANAGER
WHOLESALE MARKETING &
CONTRACTS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL : kevin. [e-mail]
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 BOX3727
SPOKANE W499220-3727
E-mail: [e-mail]
EDITH PACILLO SENIOR
ASSOCATE GENERAL COUNSEL
OFFICE OF GENERAL COUNSEL
322E FRONT ST 324D
BOISE ID 83702
E-MAIL : [e-mail]
[e-mail]
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CERTIFICATE OF SERVICE