20220607Staff 1-11 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:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION
OF AVISTA CORPORATION AND FORI)
HYDRO LIMITED PARTNERSHIP FOR
APPROVAL OF POWER PURCHASE AND
SALE AGREEMENT
CASE NO. AVU.E-22-07
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 Attomey General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than TUESDAY, JUNE 2112022.r
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
I Stuff i, requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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I JUNE 7,2022
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: Please explain why the contract term is for only one-year
REQUEST NO. 2: The original 1985 contract stated the nameplate capacity was 1,500
kilowatts ("kW"), but the renewal contract states the nameplate capacity is 1,499 kW. Please
respond to the following.
a. Please reconcile the two numbers.
b. What was the installed nameplate capacity when the Facility was first constructed?
c. Has the nameplate capacity changed since construction? Please explain.
REQUEST NO.3: Please respond to the following regarding the Facility's Designated
Network Resource ("DNR") status.
a. Will the Facility lose its DNR status and become incapable of selling power to the
Company after the current 1985 contract expires on June 30,2022? Please explain.
b. Please confirm that DNR status can be only requested after a power purchase
agreement is executed.
c. Have the parties in this case requested the DNR status? Please explain.
d. If so, please provide an approximate date when the DNR status will be granted.
REQUEST NO. 4: Assuming the Agreement is not approved before July 1, 2022,for
the period between July l, 2022 and the Commission's approval (the lapse contract period), what
rate does the Company propose to pay the Seller for the energy delivered? Please provide
justification for the proposed rate. Also, does the Seller plan to sell energy to the Company
during the lapse contract period?
REQUEST NO. 5: Please respond to the following regarding the avoided cost rates in
the original, 1985 contract.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 JTINE 7,2022
a. Did the avoided cost rates contained in the original 1985 contract include avoided
cost of capacity? Please explain.
b. Please provide the Order number that determined the avoided cost rates contained in
the original 1985 contract.
REQUEST NO. 6: Please list all the identified capacity deficiency periods that required
the Company to add resources since 1985 and provide the capacity resources that were actually
added and the dates when they went online.
REQUEST NO. 7: The proposed avoided cost rates contained in the Agreement are
based on the rates from GNR-E-22-01, which became effective on June 1,2022. However, the
Agreement was executed on May 11,2022. Please explain why the parties did not use the
published avoided cost rates effective on May 11,2022.
REQUEST NO.8: Section 1.23 (the definition of Surplus Energy) states that the
monthly generation estimates for the purpose of the 90/110 rule are specified in Section 6.3.
However, the estimates are not provided in Section 6.3. Please provide the monthly generation
estimates.
REQUEST NO. 9: Section 6.2 states that "[t]he maximum annual amount of electric
power that Avista is obligated to purchase hereunder shall be 5000 megawatt-hours ("MWh") in
any Operating Year which is a non-Leap Year, or 5000 MWhs in any Operating Year which is a
Leap Year." Please respond to the following.
a. How is the 5000 MWhs determined?
b. Why is the maximum annual amount of a non-Leap Year the same as the maximum
annual amount of a Leap Year?
c. What is the relationship between the 5000 MWhs and the sum of the monthly
generation estimates provided in Request No. 8?
d. What is the relationship between the 5000 MWhs and the ll0% of the sum of the
monthly generation estimates provided in Request No. 8?
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 JLINE 7,2022
REQUEST NO. 10: Section 6.3.1 states that Project Developer shall provide monthly
generation estimates for both the initial year and each subsequent year. However, the Agreement
term in this case is only one-year. Please explain why Project Developer shall provide monthly
generation estimates for "each subsequent yeaf'.
REQUEST NO. l1: Section 6.3.2 allows the Seller to provide updates to the monthly
generation estimates at least one-month in advance. However, Section 6.3.5 requires the Seller
to use a different timeframe. Please reconcile the two timeframes and explain which one should
be used.
}bDATED at Boise, Idatro, this day ofJune 2022.
Deputy Attorney
i:umisc:prodreq/avue22.7dhyy prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 JUNE 7,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF JUNE 2022, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMMISSION
STAFF TO AVISTA CORPORATION, IN CASE NO. AW-E-22-07, By E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
KEVIN HOLLAND
WHOLESALE MARKETING MANAGER
AVISTA CORPORATION
PO BO){ 3727
SPOKANE WA99220-3727
E-mail : [e-mail]
dockets@ avi stacorp. com
BRENDA J FORD PRESIDENT
FORD HYDRO,INC
PO BOX 1432
LEWISTON, ID 8350I
MICHAEL G. ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
PO BO){ 3727
SPOKANE WA99220-3727
E-mail : [e-mail]
-L,42-\sECRErxRT
CERTIFICATE OF SERVICE