20231012Staff 5-7to AVU.pdf

MICHAEL DUVAL DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074
[phone]IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
. ;: r· t= 1 VEO : \ •- V •- i
2023 OCT I 2 AH 11: 5 I
' '' '. '(', ,-,usuc ',, !. !. , f1: �. �-:·-'r'o• 1·1�1 1S'"'10N... ,J '�' n I f\-1 0 v ..
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO UPDATE AND ESTABLISH ITS CAPACITY DEFICIENCY PERIOD TO BE USED FOR A VOIDED COST CALCULATIONS;
) ) CASE NO. AVU-E-23-12
) ) SECOND PRODUCTION ) REQUEST OF THE ) COMMISSION STAFF
) TO AVISTA CORPORATION ___________________)
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that A vista Corporation ("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY, OCTOBER 19, 2023.1
This Production Request is to be considered as continuing, and the Company 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
1 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney at [phone].
SECOND PRODUCTION REQUEST TO AVISTA CORPORATION OCTOBER 12, 2023
the person preparing the documents. Please also identify 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 with formulas intact and enabled.
REQUEST NO. 5: Response to Staff Production Request No. 1 states "Avista conducted
comparative analysis of the WRAP L&R methodology to its previous methodology to ensure the
resulting planning margin used in the new WRAP methodology did not result in a material
change to the capacity position." Company Response to Staffs Production Request No. 1
(emphasis added). The Company continued, [t]herefore, at the time of the change, Avista used
its own calculated PRM to not materially change the position using the new methodology."
Company Response to Staffs Production Request No. 1 (emphasis added). In addition, the
Company provided capacity positions determined under the two different methods in the
response. Staff calculated the difference between the two capacity positions determined under
the two methods and discovered that the capacity positions under the traditional method are
greater than those under the WRAP method by the following amounts.
Capacity Position in January Capacity Position in January
Year under WRAP Method (MW) under Traditional Method (MW)
2024 224 318
2025 214 308
2026 122 215
2027 150 233
2028 140 224
2029 113 186
2030 99 172
2031 76 148
2032 53 126
2033 35 107
2034 (52) {8)
2035 {76) {32)
2036 {166) (125)
2037 {196) (155)
2038 (227) {186)
2039 {261) (219)
2040 {297) (256)
2041 (405) (343)
2042 (730) {670)
2043 {790} {725)
2044 (842) (777)
2045 {896) {830)
SECOND PRODUCTION REQUEST TO AVISTA CORPORATION 2
Capacity Difference in January (MW)
94
94
93
83
83
73
73
72
72
72
43
43
41
41
42
42
42
62
60
66
66
66
OCTOBER 12, 2023
Please respond to the following:
a.Please explain why the capacity positions determined under the two methods are
significantly different;
b.Please explain why capacity positions determined under the traditional method are
consistently higher than capacity positions determined under the WRAP method;
and
c.Given the significant difference, please justify the Planning Reserve Margins
("PRMs") used in this filing (22% for winter and 13% for summer).
REQUEST NO. 6: Response to Staff Production Request No. 1 states Avista would not
use the Western Resource Adequacy Program ("WRAP") PRM for planning until the WRAP
program becomes binding. Please respond to the following:
a.What are the WRAP PRM values?
b.When will the WRAP program become binding based on the latest information?
c.Does WRAP provide different PRM values to different utility participants based
on each participant's system peaks or the same PRM values to different utility
participants based on the regional peak?
REQUEST NO. 7: Between the capacity positions determined under the traditional
method and the capacity positions determined under the WRAP method, please explain which
result is more accurate and why? In the response, please include the following perspectives
discussed in Response to Staff Production Request No. 1 (c):
a.PRM;
b.Operation reserves; and
c.Qualifying Capacity Credit (thermal units, storage hydro, wind, and run-of-river).
DATED at Boise, Idaho, this / 7-1aay of October 2023.
i:umisc:prodreq/A VU-E-23-12 PR #2
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 3
Deputy Attorney General
OCTOBER 12, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12th DAY OF OCTOBER 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-E-23-12,
BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
MICHAEL G.ANDREA SHAWN BONFIELD
SENIOR COUNSEL SR.MANAGER,REGULATORY POLICY
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE