20181011Avista to Staff 20-49.pdf

Avista Corp.
1411 East Mission P.O. Box3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
Ahnstfr
Corp,
?iliI l[I I I Ati 9: l2
October I l, 2018
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83720-0074
Attn: Brandon Karpen
Deputy Attorney General
Re: Production Request of Commission Staff in Case No. AVU-E-18-03/AVU-G-18-02
Dear Mr. Karpen,
Enclosed is Avista's response to IPUC Staffs production request in the above referenced
dockets. Included in this mailing are the original and two paper copies of Avista's response to
production request: Staff 20 - 49. Also enclosed on three separate CD's are copies of Avista's
response to the production request. The electronic version of the response was emailed on
I 0/t l/r 8.
Also included on a separate CD are Avista's CONFIDENTIAL responses to PR 20C - 25C,
27C, 28C,30C - 34C, 39C, 40C,, 42C, 43C, 45C - 49C. This response contains TRADE
SBCRET, PROPRIETARY or CONFIDENTIAL information and is separately filed under
IDAPA 31.01.01, Rule 067 and233, and Section 9-340D,Idaho Code. It is being provided
under a sealed separate envelope, marked CONFIDENTIAL.
If there are any questions regarding the enclosed information, please contact Paul Kimball at
[phone] or via e-mail at [e-mail]
Sincerely,
Z-
Paul Kimball
Mgr. Compliance & Discovery
Enclosures
CC (Email):Sierra Club (Ritchie, Boyd)
IPUC (Hanian)
Clearwater (Richardson, Reading, Lewallen, Haugen)
Idaho Conservation League (Otto)
Idaho Forest Group (Miller, Williams, Crowley)
CC (Paper):Clearwater (Richardson)
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-20
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
t0lt0l20t8
N/A
Thomas C Dempsey
GPSS
(s0e) 4es-4e60
REQUEST NO.:
In the event that the Rosebud mine has inadequate or non-existent coal supplies, please describe
Avista's contingency plans for providing fuel to Colstrip. Please identifu any cost-effective
alternatives for fueling the Colstrip plant and include all related studies and planning documents.
RESPONSE:
Please see StaflPR_20C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
AVISTA CORPORATION
RESPONSE TO RBQUEST F'OR INFORMATION
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- I 8-02
Staff
Production Request
Staff-21
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
t0lr0l20r8
N/A
Thomas C Dempsey
GPSS
(s09) 49s-4960
REQUEST NO.:
Regarding alternate fuel supply options for Colstrip
a. Can coal be shipped cost effectively to Colstrip by rail from sources other than the
Rosebud mine? Please explain why or why not.
b. At what expected delivered price of coal does Colstrip cease to be cost effective?
Please specify if the assumptions used to calculate this price are the same as those
used in the 2017 IRP. If not, please identify the changed assumptions and provide
source documentation.
c. Please provide a comparison of the expected delivered coal price from a source
other than Rosebud to the current estimated delivered price from Rosebud.
RESPONSE:
Please see Sta[PR_21C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- l 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-22
DATE PREPARED: l0ll0l20l8WITNESS: N/A
RESPONDER: Thomas C Dempsey
DEPARTMENT: GPSS
TELEPHONE: [phone]
REQUEST NO.:
If coal were delivered from a source other than Rosebud, would improvement of rail line(s) be
necessary? If yes, please provide estimates for the cost of the rail improvements.
RESPONSE:
Please see StaflPR_22C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- l 8-03/AVU-G- l 8-02
staff
Production Request
Staff-23
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
913012018
N/A
Thomas C Dempsey
GPSS
(s09) 49s-4960
REQUEST:
Please provide all risk analyses and studies that Avista has performed to examine the quantitative
or qualitative risk associated with the development of sections F & G of the Rosebud mine. If no
analyses and studies have been conducted, please explain why Avista has not examined that risk.
RESPONSE:
Please see StaflPR_23C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-24
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
1010412018
N/A
Thomas C Dempsey
GPSS
(s09) 49s-4960
REQUEST NO.:
Please provide a cost estimate for expanding into sections F & G of the Rosebud mine
RESPONSE:
Please see Sta[PR_24C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- I 8-02
Staff
Production Request
Staff-25
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
t0t04t20r8
N/A
Thomas C Dempsey
GPSS
(s09) 49s-4960
REQUEST NO.:
Given that the reliability of fuel supplies can affect Avista's ability to serve its customers and the
price of its service, does Avista monitor actions of the United States Department of the Interior, or
the actions of any other federal or state government agencies, that would affect the permitting of
Rosebud mine sections F & G?
a. If so, please provide the findings of that monitoring.
b. If not, please explain why the Company does not monitor this permitting process or
requirements.
RESPONSE:
Please see StafLPR_2sC, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G-1 8-02
Staff
Production Request
Staff-26
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
1010U20t8
N/A
John J. Spanos
Consultant
(s09) 49s-2293
REQUEST:
Please provide any analysis with workpapers that supports a useful life through year 2034 for Unit
3 and year 2036 for Unit 4 at the Colstrip plant.
RESPONSE:
The life spans for Colstrip Unit 3 and Colstrip Unit 4 were based on discussions with Avista
management as well as the life spans utilized by other owners. The2034 and2036life span dates
have been in place since the 2004 Depreciation Study. A 5O-year life span is consistent with the
type of units and the regulations for this type of generating unit.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-27
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
1010912018
N/A
Thomas C Dempsey
GPSS
(s09) 49s-4e60
REQUEST:
Please provide a list of all capital additions for Colstrip Units 3 and 4 (broken out separately) that
the Company will require to continue operation through their current expected useful life (2034
and 2036). Specifically for each capital addition, please provide a detailed description of the
investment, why it is needed, the cost, and any economic justification for each item. Please ensure
that your response includes capital investments for future environmental compliance.
RESPONSE:
Please see Staf{*PR_27C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INF'ORMATION
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-28
DATE PREPARED: 10109/2018WITNESS: N/A
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (509) 49s-2189
REQUEST:
Please provide any analysis with workpapers that the Company has completed to analyze earlier
retirement dates for Units 3 & 4 other than the current planned retirement dates.
RESPONSE:
Please see Staff PR_28C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, md Section 9-340D,Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-29
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
r0lty20r8
N/A
Karen Schuh
Regulatory Affairs
(s}e) 4es-22e3
REQUEST:
For each Colstrip Unit, please provide the total "ORIGINAL COST" values of the Colstrip plant
identified in column 4 of the Gannett Fleming Depreciation Study dated December 31,2016 and
the value for each operating partner.
RESPONSE:
Please see Staff PR_29 Attachment A, as well as the workpapers originally filed in this docket for
details of each Colstrip Unit. Please note that this does not include the balances for plant that are a
part of the Colstrip Transmission assets. The Company does not have the value as of December 31,
2016 for each operating partner.
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-O3/AVU-G- 1 8-02
Staff
Production Request
Staff-30
DATE PREPARED:
WITNESS:
RESPONDE,R:
DEPARTMENT:
TELEPHONE:
t0/t0120t8
N/A
Darrell Soyars
Environmental
(s}e) 49s-2360
REQUEST:
Please provide an update explaining the current non-operational state (non-compliance with
environmental standards) of Colstrip Units 3 and 4. What are the plans to bring the plant back into
compliance and to make Units 3 & 4 operational? Please include:
a. the cause of the shutdown;
b. any investments and capital cost amounts needed to bring the units into emissions
compliance;
c. time needed for the plant to become available for dispatch in order to provide
reliable generation;
d. impacts to operating, dispatch, and insurance costs;
e. the impact to net power costs over the expected time the plant is expected to be
down; and
f. the Company's plan for informing state regulators.
RESPONSE:
Please see Sta[PR_30C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-3 1
DATE PREPARED: 9/3012018WITNESS: N/A
RESPONDER: Thomas C Dempsey
DEPARTMENT: GPSS
TELEPHONE: (s09) 49s-4960
REQUEST:
Please provide a description of the circumstances, the timing, the duration, and the total cost of all
forced outages by unit at Colstrip Units 3 and 4 since 2008. The total costs should specify repair
costs, replacement power costs, and insurance costs.
RESPONSE:
Please see StaflPR_3lC, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-32
DATE PREPARED: 101212018WITNESS: N/A
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHoNE,: (509) 49s-2t89
REQUEST:
Does Avista include the cost of forced outages in its forecast of cost assumptions for Colstrip Units
3 and 4? If so, please provide those cost assumptions. If not, please explain why not.
RESPONSE:
Please see Staff_PR_32C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-33
DATE PREPARED: 913012018WITNESS: N/A
RESPONDER: Thomas C Dempsey
DEPARTMENT: GPSS
TELEPHONE: (s09) 49s-4960
Please identify the date when Avista plans to install the enhanced Mercury controls referenced in
Avista's response to Staff Production Request No. 6.
RESPONSE:
Please see Staff_PR_33C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-34
DATE PREPARED: 10/1112018WITNESS: N/A
RESPONDER: Darrel Soyars
DEPARTMENT: Environmental Affairs
TELEPHONE: [phone]
REQUEST:
Page 7 -4 of Avista's 20 1 7 IRP stated that "Title V operating permit renewal applications are in
process for fColstrip] Units 3 and 4. ..." to comply with the Clean Air Act regulations. Please
provide an update on the status of those applications.
Please see Staff_PR_34C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
RESPONSE:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- 1 8-02
staff
Production Request
Staff-35
DATE PREPARED: l0ll1l20l8WITNESS: N/A
RESPONDER: Darrel Soyars
DEPARTMENT: Environmental Affairs
TELEPHONE: [phone]
REQUEST:
The Billings Gazette reported on August 10,2018, that "Units I and2 typically clear the air
pollution bar test results by relying on a weighted average of pollution test results from all four
units. Results from Unit 3, when performing properly, and Unit l, have pulled Colstrip into
compliance, according to EPA archived data. Units 2 and 4 in past tests haven't cleared the bar
without help."
a) Please confirm or deny that Unit 4 has difficulty passing pollution tests without
Unit 3.
b) Please provide a full explanation of either the confirmation or denial.
c) If confirmed, explain in detail how Avista plans to manage this issue for the
duration of the plant operation.
RESPONSE:
The Billings Gazette article was inaccurate. Due to the age, fuel source and scrubber design; Units
I and2 have a lower Particulate Matter (PM) removal efficiency than Units 3 and 4. The Mercury
Air Toxic Standard (MATS) limitation is an average PM emission rate across all four generating
units. Units 3 and 4 have a higher PM removal efficiency and historically lower the site-wide
average.
a) Deny
b) see above
c) nla
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- I 8-02
Staff
Production Request
Staff-36
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
t0lt1l20t8
N/A
Darrel Soyars
Environmental Affairs
(s09) 49s-2860
REQUEST:
Please provide the current Federal Implementation Plan and State Implementation Plan for each
Colstrip Unit.
RESPONSE:
We assume that the question is referring to the Montana Regional Haze FIP (Federal
Implementation Plan) and SIP (State Implementation Plan) for the Colstrip Units. If so, Montana
Department of Environmental Quality (MDEQ) has issued an excellent summary that is available
at this link: https://deq.rnt.sov/Porlals/l l2lPublic/Air/ProgressReport_DRAFT_7-2017.pdf
Specific to your request; Montana did not submit a Regional Haze Program SIP as required in
2006 and thus EPA issued a FIP on September 18,2012. Portions of this FIP (mostly emission
limitations on Units I and 2) were court remanded back to EPA in May 201 5. EPA has not acted on
the FIP remand to date. Montana intends to assume responsibility for the RegionalHaze Program
by submitting a SIP revision when it is due (-July 31,2021). Units 3 and 4 were not directly
affected by EPA FIP but will be considered in future regional progress reports.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- I 8-02
Staff
Production Request
Staff-37
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
t)ltU20r8
N/A
Darrel Soyars
Environmental Affairs
(s}e) 4es-2860
REQUEST:
Please provide the results of the Federal Implementation Plan progress review that was performed
on Colstrip Units 3 and 4 in September 2017.
RESPONSE:
Pleaserefertohttps://deq.mt.gov/Portals/112lPublic/AiriProeressReporlDRAFT 7-2017.pdf
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- I 8-02
Staff
Production Request
Staff-38
DATE PREPARED: 1010312018
WITNESS: N/A
RESPONDER: Randy Gnaedinger
DEPARTMENT: Transmission Operations
TELEPHONE: (s09) 49s-2047
REQUEST:
Please provide a description of and an update on the status of the third-party interconnection
request for Project #46: 750 MW Wind at Colstrip 500 kV in Montana proposed for September
2018.
RESPONSE:
Project #46 in Avista's generation interconnection queue is a 126 MW wind project southwest of
Othello, WA. Project #46 is still active and has completed all three interconnection studies:
feasibility, system impact, and facilities. Project #46 has a fully executed large generator
interconnection agreement. Avista and the project developer are currently performing to their
respective obligations under the agreement.
Project #47 in Avista's generation interconnection queue has requested interconnection service to
the Colstrip 500 kV Transmission System (CTS) for a 750 MW wind project. Avista is a joint
owner in the CTS with NorthWestern Energy, PacifiCorp, Puget Sound Energy, and Portland
General Electric.
NorthWestern, as the designated CTS operator under the Colstrip Transmission Agreement, is the
lead party in conducting the interconnection study effort, with input from the other CTS owners.
The Project #47 request is still active and has completed all three interconnection studies:
feasibility, system impact, and facilities. The CTS owners are currently drafting a large generator
interconnection agreement for Project #47 .
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-39
DATE PREPARED: 913012018WITNESS: N/A
RESPONDER: Thomas C Dempsey
DEPARTMENT: GPSS
TELEPHoNE: (509) 49s-4960
REQUEST NO.:
Please provide the most recent 5-year projected business plan and capital budget for Colstrip Units
3 and 4.
RESPONSE:
Please see Staff PR_39C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- l 8-02
Staff
Production Request
Staff-40
DATE PREPARED: 10104/2018WITNESS: N/A
RESPONDER: Thomas C Dempsey
DEPARTMENT: GPSS
TELEPHONE: (s09) 49s-4960
REQUEST NO.:
Staff understands that Colstrip units are overhauled every three or four years. Please provide the
planned overhaul schedule and associated costs for Units 3 and 4 from 2018 through2036.
RESPONSE:
Please see Staff PR_40C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
staff
Production Request
Staff-41
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
r0111t2018
N/A
Karen Schuh
Regulatory Affairs
(s09) 49s-2293
REQUEST:
Staff understands that Avista agreed to a 2021 end-of-life date for Colstrip Units 3 and 4 for
depreciation in Washington State. Please provide all analysis that supports 2021 as an economic
end of life date for Units 3 and 4.
RESPONSE:
The total life span of Colstrip Units 3 & 4 proposed in the current depreciation study is 50 years
(i.e., concluding in 2034 and 2036, respectively). This is consistent with the preceding
depreciation study, which also utilized a 50 year total life for these units. Additionally, Avista's
most recent Integrated Resource Plan included both Colstrip units in the preferred resource
strategy over the 2)-year planning horizon. The acceleration of depreciation to a depreciation
schedule through 2027 was an agreement for depreciation and cost recovery purposes only, and
did not establish a shut-down date for the units, as discussed by Mr. Thackston in his supplemental
direct testimony. The settlement was not based on an analysis of survivor curves through 2027,
and such analysis has not been performed and, therefore, is not readily available.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- l 8-03/AVU-G- I 8-02
Staff
Production Request
Staff-42
DATE PREPARED: 0912812018WITNESS: N/A
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 49s-2r89
REQUEST:
Page l2-3 of Avista's 2017 IRP lists the resource options which the Company considered for
replacing Colstrip in the event that plant retires early.
a. Colstrip provides about 246 MW for Avista. Please explain why the tables show
566 - 571 MW resource replacement options.
b. Please explain why this resource list does not include market purchases, power
purchase agreements, or any renewable resources as possible replacement
resources.
RESPONSE:
Please see StafLPR_42C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
Page I of I
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-43
DATE PREPARED: 0912012018WITNESS: N/A
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHONE: (s09) 49s-2189
REQUEST:
Please explain if renewing the Lancaster Power purchase agreement (283 MW) that expires in
2026 could be used to meet load requirements previously served by Colstrip Units 3 and 4 (246
MW) if that plant were retired in2027.
RESPONSE:
Please see Staff PR_43C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-44
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
101r012018
N/A
Darrell Soyars
Environmental
(s09) 49s-2860
REQUEST:
If Colstrip continues operating, please identify the date that SCRs would be required for
compliance with state and/or federal regulations.
RESPONSE:
Avista's most recent Integrated Resource Plan (IRP) identifies the potential need to install
additional pollution controls, possibly an SCR by 2027 . This requirement would result from a
future Reasonable Progress Report as part of the Federal EPA RegionalHaze Program.
AVISTA CORPORATION
RE,SPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- l 8-03/AVU-G- l 8-02
Staff
Production Request
Staff-45
DATE PREPARED: 09120/2018WITNESS: N/A
RESPONDER: James Gall
DEPARTMENT: Energy Resources
TELEPHoNE: (509) 49s-2r89
REQUEST:
Page l2-3 of Avista's 2017 IRP states that regarding Colstrip retirement in 2030 or 2035 that
"Reduced capital spending offsets some of the cost increases prior to shutdown, but not enough to
offset the increase." Please explain why the Company did not model apre-2028 shutdown date
that would let the Company avoid significant SCR expenses.
RESPONSE:
Please see Staff PR_45C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
AYISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- r 8-02
Staff
Production Request
Staff-46
DATE PREPARED: 1010412018WITNESS: N/A
RESPONDER: Thomas C Dempsey
DEPARTMENT: GPSSTELEPHONE: (s09) 49s-4960
REQUEST NO.:
Please provide all presentations made to the Colstrip Owners Meeting Group between June 2017
and September 2018, including, but not limited to, the
"Unit 3 Overhaul Challenge Presentation" from the April 2017 meeting.
RESPONSE:
Please see Staf{_PR_46C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- I 8-03/AVU-G- I 8-02
Staff
Production Request
Staff-47
DATE PREPARED: 1010112018WITNESS: N/A
RESPONDER: Thomas C Dempsey
DEPARTMENT: GPSS
TELEPHONE: [phone]
REQUEST NO.:
Please provide a summary of the discussion on the "Colstrip Maintenance and Contract Status,"
"Real Estate Resolution," and "LP Amina-Boiler Model Preliminary Evaluation" from the June
and July 2017 Colstrip Owners Meeting.
RESPONSE:
Please see Staff PR_47C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.
AVISTA CORPORATION
RESPONSE TO RE,QUEST FOR INFORMATION
JURISDICTION
CASE NO:
RE,QUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 1 8-03/AVU-G- 1 8-02
Staff
Production Request
Staff-48
DATE PREPARED
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
t0t0412018
N/A
Thomas C Dempsey
GPSS
(s}e) 49s-4960
REQUEST NO.:
Please provide a summary of the discussion of the "2 year expenditures associated with the brine
concentrator capital project" from the April 2017 Colstrip Owners meeting. In particular, please
explain the need for the statement that "Going forward, owners will be asked to commit to total
project cost when the projects are multi-year."
RESPONSE:
Please see StaflPR_48C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,ldaho Code.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- l 8-03/AVU-G- I 8-02
Staff
Production Request
Staff-49
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
10109120r8
N/A
James Gall
Energy Resources
(s09) 49s-218e
REQUEST:
In its 2017 IRP modeling, did Avista let PRiSM select the most optimal retirement date for
Colstrip Units 3 and 4 or did the Company hard-code the operating life to a specific date? If the
Company hard-coded the operating life, please explain how that helps select the most
cost-effective resources.
RESPONSE:
Please see Staff PR_49C, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D,Idaho Code.