20220831Staff 1-4 to Avista.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. II7I4
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 IDAHO
COUNTY LIGHT AND POWER COOPERATIVE
ASSOCIATION FOR APPROVAL OF POWER
PURCHASE AND SALE AGREEMENT
cAsE NO. AVU-E-22-14
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,
Michael Duval, Deputy Attorney General, requests that Avista Corporation provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
SEPTEMBER 21, 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 PRODUCTTON REQUEST
TO AVISTA CORPORATION
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I AUGUST 31,2022
the person preparing the documents. Please also identifu 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: The original 1986 contract at l3 states that the Facility has a 900-
kilowatt nominal rating. However, Exhibit D of the Power Purchase Agreement ("PPA") states
that the nominal rating is 1,010 kilowatts. Please answer the following questions.
a. Please explain what "nominal rating" means and how this rating differs from the
nameplate rating.
b. Please explain why the nominal rating in the original 1986 contract differs from
the nominal rating in the PPA.
c. What was the installed nominal rating when the Facility was first constructed?
d. Has the nominal rating changed since construction? Please explain.
e. Please provide evidence for the current, actual nominal rating.
REQUEST NO. 2: Exhibit D of the PPA also states that the maximum net power
production capacity under ideal conditions is approximately 900 kilowatts. Please answer the
following questions.
a. Please explain how the "maximum net power production capacity under ideal
conditions" is determined.
b. What was the "maximum net power production capacity under ideal conditions"
under the original 1986 contract?
c. If the value was not 900 kilowatts, please explain what has caused the value to
change?
REQUEST NO.3: The PPA defines Operating Year as "each l2-month period from
July 1 through June 30." The original 1986 contract expires on October 30,2022. Please
explain whether Operating Year should have been defined as "each l2-month period from
October 3l through October 30".
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 31,2022
REQUEST NO. 4: Please list all the identified capacity deficiency periods that required
the Company to add resources since 1986 and provide the capacity resources that were actually
added and the dates when they went online.
DATED at Boise, Idaho, this 3 f day of Augnst2022.
Michael
Deputy Attomey General
i:umisc:prodreq/avue22. l4mdyy prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUGUST 31,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3I't DAY OF AUGUST 2A22,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-22-14,
BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
KEVIN HOLLAND MANAGER
WHOLESALE MARKETING &
CONTRACTS
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL:
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
MAX BEACH
ID COI.INTY LIGHT & POWER
COOPERATIVE
PO BOX 300
GRANDEVILLE ID 83530
E-MAIL: [e-mail]
com
dockets@.avistacorp. com
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
5I5 N 27TH ST
BOISE ID 83702
E-MAIL : [e-mail]
Y
CERTIFICATE OF SERVICE