20220323Avista to Staff 1-7.pdf

AYISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
ruRISDICTION: IDAHO
CASE NO: AVU-E-22-04
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Staff-001
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0312312022
N/A
Kevin Holland
Power Supply
(s09) 4e5-21e4
REQUEST:
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 lnjection 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 array." Given this, is it likely that the project will sell en€rgy to Avista?
Please explain.
e. What is the difference between Maximum Generation Injection at Point of Common
Coupling used in Case No. AVU-E-22-03 and Maximum Generation Injection at Point of
Interconnection used in this case?f. Page 2 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 132.2 kW listed in the Exhibit A of the
Agreement.
h. Does the actually installed nameplate size match the 132.2 kW listed in Exhibit A?
RESPONSE:
This response is based in part on information provided to Avista by the University.
Attachment 2 to Exhibit D (Interconnection Agreement) defines the Point of Common
Coupling as: "The 2771480Y secondary terminals of the Interconnection Customer's
Interconnection Facilities." The Maximum Generation Injection at Point of Common
Coupling is the maximum amount of energy that may be injected at the Point of Colnmon
Coupling, which is equal to maximum generation capability of the facility (a.k.a nameplate
rating).
a.
b. 100 percent of the output of the facility is expected to serve the University of Idaho's load.
RECEIVED
2022 MAR 23 PM 2:47

IDAHO PUBLIC
UTILITIES COMMISSION
c.
d.
Any energy generated by the facility in excess of the University of Idaho's load will be sold
to Avista.
As noted above, 100 percent of the output of the facility is expected to serve the University
of Idaho's load. It is not likely that University will sell energy from its solar facility to
Avista given that the University's load is in excess of its generation. Although not
expected, it is possible under limited circumstances that there may be some excess energy
that is sold to Avista.
e.The Maximum Generation Injection at the Point of Common Coupling in both this case
and Case No. AVU-E-22-03 is based on the maximum generating capability of the
applicable resource. In this case, the maximum generating capability of the solar resource
is 132 kW. In Case No. AVU-E-22-04, the maximum generating capability of the steam
resource is 825 kW.
In the hypothetical situation that the University of Idaho's load was zero. Then, maximum
Generation Injection at Point of Interconnection would be the generating resource(s) full
output minus losses as measured by the Primary Meter at the Point of Interconnection
between Avista and the University of Idaho.
f.
('E'
T\e 132.32 kW on page2 of the Joint Petition is an error and that number should be 132.2
kw.
The difference between the two figures appears to be due to a difference in rounding in
interconnection losses calculated by the University's contractor that provided these
estimated figures. Additionally, different terminology is used in the FERC Form 556 and
the Power Purchase Agreement (PPA), and it is not apparent that the capacity-related
figures in the power purchase agreement would precisely match those in the FERC Form
556. In any event, the difference is just 0.2 kW, or 200 watts, and appears to be immaterial
to any provisions of the PPA. To the extent that the Commission prefers identical figures
should be used in the PPA's Exhibit A as those used in the FERC Form 556, the University
would be willing to execute such an amendment to the PPA.
h.Yes, based on the University's understanding of the applicable terminology,132.2 kW is a
reasonable estimate ofthe "Nameplate size (rating) - 132.2 kW (AC)" as listed in Exhibit A
of the power purchase agreement. It should be noted that there are diflerent terms used
bearing on this point. The PPA $ l.l7 provides the following definition: "'Nameplate
Capacity Rating' means the maximum generating capacity of the Facility, as determined
by the manufacturer, and expressed in megawatts (MW) or kilowatts (k\M)." This data
request references the following line from Exhibit A: "Nameplate size (rating) - l32.2kW
(AC)." To be clear, however, a PV solar facility consists of solarpanels and inverters, not a
furbine generator, and is unlike a traditional generator that will have a manufacturer's
"nameplate" specifuing a precise rating stamped on the generator. T\e 132.2 kW listed in
Exhibit A is the University's estimate of the equivalent of the 'Nameplate size (rating)" of
the solar facility's capacity in AC provided to Avista. As noted above, due to an apparent
rounding difference between the point where the AC energy is produced at the inverters
and the point of interconnection to Avista's system at the edge of the University's campus,
the amount in the PPA's Exhibit A differs from the maximum power production capacity
of the facility as calculated on FERC's Form 556 by 200 watts.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
ruRISDICTION: IDAHO
CASE NO: AV-IJ-E-Z2-M
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Stafl002
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHoNE: (s09) 495-2194
REQUEST:
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.
RESPONSE:
This response is based on information provided to Avista by the University.
The figures on the Form 556 are correct:
400 watts:0.4 kW
0.4 kW x 368 :147.2kW.
AYISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AYU-E-22-04
IPUC
Production Request
Staff-003
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: (s09) 49s-2194
REQUEST:
Page 6 of the Agreonent states "[t]o the full extent allowed by applicable laws or regulations,
Avista shall own or be entitled to claim fifty percent of the Environmental Attributes associated
with the Net Output delivered to Avista." What are the applicable laws or regulations that the
Agreernent is referring to?
RESPONSE:
This response is based in part on information provided to Avista by the University.
As an initial matter, 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 Qualiling Facility (QF)
that receives a standard avoided cost rate retains all Renewable Enerry Credits (RECs). Order No.
32697 at 45. Where a 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. Id. The Commission's rationale for its allocation of RECs 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. See id.
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 qualiffing facility or
the utility in both this case and Case No. AVU-E-22-04 was based on whether the particular
qualiSing facility would be eligible for standard avoided cost rates. The University's steam
facility at issue in Case No. AVU-E-22-03 is smaller than l0 alvtW and, therefore, would be
eligible for standard avoided cost rates and, therefore, the parties agreed that all RECs associated
with energy delivered and sold to Avista from the steam facility, if any, are to be retained by the
University. In contrast, the solar facility at issue in this case is greater than 100 kW and, therefore,
that facility is not eligible for standard avoided cost rates. Accordingly, in the PPA for the solar
facility, the parties agreed to allocate the RECs associated with energy delivered and sold to Avista
from that facility 50 percent to the University and 50 percort to Avista. Howeve,r, 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: AVU-E-22-04
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Staff-004
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
0312312022
N/A
Kevin Holland
Power Supply
(s09) 49s-21e4
REQUEST:
FERC Form 556 states that the facility is expected to be installed by February 25,2022, and to
begrn operation on February 25,2022. When was this project constructed? When did this project
begin operation and start selling power to Avista?
RESPONSE:
This response is based on information provided to Avista by the University
The solar facility was constructed over ayear ago and commissioning was completed on February
25,2022. Since that time, the facility has been used to serve the University's load but has not
delivered or sold any exrergy to Avista.
AVISTA CORPORATION
RESPONSE TO REQITEST FOR TNFORMATION
ruRISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AI./IJ-E-22-M
IPUC
Production Request
Staff-005
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: (509') 495-2194
REQUEST:
From the first 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?
RESPONSE:
To date, all ofthe energy generated by the facility has been used to serve University load, therefore
no energy generated by the facility has been sold to Avista.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATION
JURISDICTION: IDAHO
CASE NO: AVU-E-22-04
REQUESTER: IPUCTYPE: Production Request
REQUEST NO.: Staff-006
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: (s09) 49s-2194
REQUEST:
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.
RESPONSE
No, Avista does not intend to include the generation from this project in its load and resource
balance.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR TNFORMATTON
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AYU-E-22-04
IPUC
Production Request
Staff-007
DATE PREPARED: 0312312022WITNESS: N/A
RESPONDER: Kevin Holland
DEPARTMENT: Power Supply
TELEPHONE: (509) 49s-2194
REQUEST:
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.
RESPONSE:
a. PowerDex Mid-Columbia Index 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 commitment transactions. The PowerDex Mid-C
index is an index of prices for all transactions within an hour. In this power purchase
agreernent, the PowerDex Mid-C index is used as a proxy for Avista's avoided cost of
energy on an as-available basis.