20230710Staff 1-7 to AVU.pdf

CHRIS BURDIN
DEPUTYATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-ABOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA'S 2023 )CASE NO.AVU-E-23-05ELECTRICINTEGRATEDRESOURCEPLAN.)
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Avista Corporation dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and informationas soon as
possible,but no later than MONDAY,JULY 31,2023.
This Production Request is to be considered as continuing,and Avista is requested to
provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTIONREQUEST
TO AVISTA CORPORATION 1 JULY 10,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:In the 2023 Electric IRP,page 4-2,it states,"Avista also is using the
WRAP's methodology for resource capacity accounting,also known as Qualifying Capacity
Credit (QCC)."Please respond to the following:
a.Please explain why it is appropriate to use Western Resource Adequacy
Program's ("WRAP")QCCs for the Company's resources when the WRAP
QCCs are based on regional resources;
b.Please explain how the Company verified that the WRAP QCC values used in the
2023 IRP are equivalent resource capacity values for the Company's system and
resources;and
c.Please explain how the Company plans to verify that the WRAP QCC values are
equivalent to Company system resource QCC values in future IRPs.
REQUESTNO.2:In the 2023 Electric IRP,page 4-4,it states,"The Northwest
Planning and Conservation Council (NPCC)is also evaluating the creation of new resource
adequacy metrics beyond traditional Loss of Load Probability Expectation (LOLE)."Please
respond to the following:
a.Please explain the new resource adequacy metrics the NPCC are evaluating;and
b.Please explain what resource adequacy metrics the Company is considering using
in future IRPs.
REQUESTNO.3:Please explain the Company's plan for using the WRAP Planning
Reserve Margin ("PRM")as the Company's PRM in future IRPs.If the Company plans to use
the WRAP PRM in future IRPs,please explain how the Company plans to verify the WRAP
PRM is appropriate to use as the Company's PRM in future IRPs.
REQUESTNO.4:Please provide an update on the status and timeline of AMI meter
installs in the Idaho service territory.Please make note of any delays.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 JULY 10,2023
REQUESTNO.5:The 2023 Electric IRP at 4-3 states that in the WRAP forward
showing program the QCC of Company's portfolio must be adequate to meet peak demand less
demand response ("DR")programs.Later,page 5-16 states that a primary factor in the cost-
effectiveness of modeled DR programs is the QCC value of the resource in the WRAP.Please
answer the followingquestions related to the Company's DR programs.
a.Please explain if the Company is modeling the value of DR resources as a peak demand
reduction or by claiming the QCC of the DR resource;
b.Please describe the rational and provide any workpapers or documents supporting the
assumption that a 6-hour load reduction is needed to receive 100%value of the QCC
value for a DR resource;
c.For any Idaho DR programs selected by the 2023 IRP,please provide the program's
modeled start date and the anticipated QCC for the forecasted years;
d.Please explain how the QCC value for DR programs will be determined and updated;
e.Please provide an estimated timeline for when the Company expects to know details of
the WRAP's QCC for demand response resources;and
f.If the Company were to claim the QCC of DR resources in the WRAP,please explain
how the cost-effectiveness calculations will account for the additional benefit.If
possible,please provide example workpapers detailing how the benefit is accounted for
in the cost-effectiveness calculation of a DR program in Excel format with equations
intact and enabled.
REQUESTNO.6:Please provide the followingworkpapers listed in the 2023 IRP
Appendix F.
a.Avista DR potential inputs and levelized cost;
b.Final Avista Electric Measure List;and
c.Avista 2022 Electric CPA Summary and IRP Inputs v3
REQUESTNO.7:Please provide workpapers supporting the Idaho avoided costs given in the
2023 IRP on page 9-29 in Excel format with equations intact and enabled.
FIRST PRODUCTIONREQUEST
TO AVISTA CORPORATION 3 JULY 10,2023
DATED at Boise,Idaho,this day of July 2023.
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/avue23.5cbme prod req l
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 JULY 10,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF JULY 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NO.AVU-E-23-05,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYERDIROFREGULATORYAFFAIRSVP&CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727E-mail:[e-mail] E-mail:[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE