20190610Rosentrater Exhibit 8 Sechedule 2.pdf

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Exhibit No. 8
Case No. AVU-E-'!9-04
H. Rosentrater, Avista
Schedule 2,Page 1 ol 128
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Avista Utilities
Electric Transmission lnfrastructure Plan
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Aaron Tremayne - Transmission Photographs
Brett Agee - Technical Support
Bruce Howard - Environmenta! Affairs
Bryan Hyde - Transmission Photos & Air Breaks
Damon Fisher - Transmission General lnformation and Expertise
Dave James - Editing, General Transmission Expertise
Debi Olson - Transmission Mapping
Erin McClatchey - FERC/NERC/WSCC Reliability Standards & Compliance
Garth Brandon - Transmission Operations
Heather Rosentrater - Leadership, Guidance, Editing, and lnspiration
Jeff Schlect - Transmission Services, Editing
Jeff Smith - Editing, Data Checking
Jeremiah Webster - Editing and Guidance
Jim Corder - Editing
John Gilrein - Transformers
Josh DiLuciano - Support, Guidance and Direction
Justin Dick - Substations
Ken Sweigart - Primary Author & Contributor, Transmission Engineering
Lamont Miles - Budgeting and Decision Making Processes
larry La Bolle - Editing and Regulatory lnformation
laura Vickers - Capital Planning Group Coordinator, Guidance & Direction
Marc Schaffner - Solar Programs
Mark Gabert - Ground lnspections
Mike Faulkenberry - Guidance and Editing
Mike Magruder - Transmission Expertise, Leadership & Guidance
Pat Clevenger - Transmission Design, Aerial lnspections, Fire Retardant
Rendall Farley - Expertise and Editing
Rich Hydzik - Transmission Operations & Regulations
Rip Divis - Transmission Operations and Training
Robert Follini- Pre-Schedule and RealTime Operations
Rodney Pickett - Asset Management Data
Rubal Gill - Budget and Actua! Expenditures
Sharon Vore - System Forester, Vegetation Management
Lisa La Bolle - Chief Author & Editor, Research, Drafting, Figures & Graphics, Production
Special thanks to Mike Magruder and Ken Sweigart, who are the heart and soul of this report,
ond to Heather Rosentrdter, without whose vision this project would never have hoppened.
Tua,Nxs & AcnNowLEDGEMENTS o
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Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 2 of 128
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Thanks & Acknowledgements
Electric Tronsmission ot the Crossroads.............. ...................1
Avista I nvestment Selection Process
Conclusion
lntroduction
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Overview of the U.S. Transmission System
The Electric System..
lndustry Chollenges.
Trends in Tronsmission Reliobility
National Historic lnvestment in Electric Transmission
Avista's Transmission System
Avista's Electric System Reliability
Avisto Historic Transmission lnvestments
Overview of Electric Transmission Regulation
Avista Currently Planned Transmission lnvestments 2018 - 2022
Avista Transmission Capital Progroms by lnvestment Driver .
Avisto Tronsmission Operations & Maintenance lnvestments
Avista Transmission Organization Functions
Appendix A: Avista Capital Project Details...
Appendix l: Key Transmission Operations Positions ................
Appendix J: Transmission System Equipment
Appendix Z: Transmission Glossary of Terms.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 3 of 1 28
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85Appendix C: The National Transmission Grid
Appendix E: NERC Corrective Action Events ....... 88
Appendix G: Changing Weather Patterns...... ...... 91
Appendix H: How The Grid Controls Time............
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TeeLE or FIcURES
Figure 1. lnfrastructure lnvestment Demands
Figure 2. National & Avista lransmisslon Cost Per Customer
Figure 3. Total Planned Capikl Expenditures by lnvestment Driver
Figure 4. Total Planned Capitallransmlssion Expenditures 2018-2022
Figure 5. Average Planned O&M Transmission Expenditures 2018-2022.
Figure 6. Basic Structure of the Electic Sysfem
Figure 8. Number of NERC Mandatory Sfandards
Figure 9. National Planned Iransmission
Figure 10. U.S. Iransmlssion Structure Age and Construction Drivers
Figure 11. Top Concerns of U{tlity Executives
Figure 12. National Residential Cost per kWh
Figure 15. Avista Transmission Lrne A7e...............
Figure 16. The Average Number & Duration of Avista Electric System Outages
Figure lT.Iransmrssion Outage Causes 2002 - Present
Figure 20. The Basic Levels of Regulation Affecting the Avista lransmrssion System..........
Figure 21. Planned lransmlssion Capital Expenditures by lnvestment Driver 2018 -2022.............
Figure 23. Program Percentage of Transmission O&trl Expenditures 2018 - 2022...
Figure 24. Yearly Average Expected Iransmisslon O&lrl Expenditures 2018 - 2022...........
Figure 25. Avista Aeial lnspection O&M Actuals & Budgefs
Figure 26. Avista Ground lnspection O&M Actuals & Budgets.....
Figure 27. Avista Fire Retardant Expenditures Budgets & Actuals
Figure 29. Avista Historic Vegetation Management Expenditures
Figure 30. Avista Unplanned Capital Transmission Expenditures.
Figure Sl.Iransmrsslon Weather-Related Outages 2003 - Present..............,,............
TaeLE oF TABLES
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Table 2. Planned Capital Expenditures Based on Cusfomer Requesfs
Table 3. Planned Capital Expenditures for lrlandatory & Compliance.
Table 4. Planned Capital Expenditures Based on Performance & Capacity....
Table 5. Planned Capital Expenditures Based on Asset Condition....................
Table 6. Planned Capital Expenditures Expected for Failed Plant & Operations....
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2, Page 4 of 128
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Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 5 of 128
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Avista Utilities serves approximately 370,000 electric customers in Washington and ldaho over an
extensive electric transmission system that is designed, built, operated and maintained by the
Company. This infrastructure system consists of approximately 2,200 miles of high voltage transmission
lines crossing 30,000 square miles and bringing electric power to over L.6 million people in Washington
and Northern ldaho. Avista must continually make new investments in this system in order to continue
providing our customers with safe and reliable electric service, at a reasonable cost, with service levels
that meet our customer's expectations for quality and satisfaction, and that meet stringent national,
regional, state, and local regulatory requirements.
The purpose of this report is to provide a comprehensive overview of Avista's transmission system and
associated programs, as well describe the need for capital investment, operations, and maintenance
funding for our transmission system. But more importantly, the goal is to explain the many forces that
are driving these needs. We believe this visibility provides meaningful context for better understanding
these many demands and how Avista is attempting to balance complex and competing needs.
EIEcrnIc TRANSMISSIoN AT THE CnOSSnOADS
Our nation's electric utilities are facing times of unprecedented challenge when it comes to the forces
driving the need for new investment in ourtransmission infrastructure, and Avista is no different. This
growing demand for new investment has overwhelmed our ability to
fund all of our high-priority needs for electric transmission, which
are out of proportion to the investment requirements of our other
infrastructure. Drivers for new investment include:
the myriad and expanding federal regulations governing
nearly every aspect of our transmission business. Priority
among these, as of late, are the requirements to meet more
restrictive transmission operations and planning standards,
both of which drive the need for new investment. These
requirements are accompanied by the threat of financial penalties for noncompliance.
and it will continue to increase year-over-year for at least the next two decades. This need is
the result of the dramatic increase in construction of new electric infrastructure during the
economic boom that followed the end of World War ll. Because these assets are now at or near
the end of their useful lives, a substantial boost in new investment is required compared with
previous years just to properly maintain existing systems.
to private parties for such needs as the integration of new variable energy resources,
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 6 ol 128
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particularly wind and solar. These interconnections require significant capital investment to
extend or reinforce our transmission system in order to provide for these non-traditional uses
of our system.
Though primarily focused at the distribution level, these changes in our energy delivery
business model are expected to impact the investments we make in transmission and create
uncertainty about future cost recovery for them.
consuming and expensive due in part to increasing environmental and property requirements.
Landowners, public and private, seek more compensation for rights-of-way and access
agreements than in the past. Local, state, and federal permitting requirements cover issues
such as endangered species, historical and cultural resources, water quality, wildlife and more.
Permitting can extend over several years and typically includes conditions that constrain how
utilities construct or maintain these assets as well as requirements for site restoration.
increasing digitization, distributed generation, energy storage, and other technologies that
require adapting and upgrading the existing system. Customers are requiring new services,
increased levels of reliability, flexibility, and choice that are beyond the experience of
traditional power companies. These demands not only create uncertainty, but add cost.
When it comes to the impact for our customers, who must ultimately
pay for these requirements and investments, an exacerbating factor is
our relatively stagnant load growth due to declining use per customer.
This translates into nearly flat revenues, which means that new capital
investments must be covered by higher customer rates. Historically,
annual increases in customer loads produced new revenues that were
often sufficient to cover the costs for new investment and inflation
without the need to increase customer rates.
This report intends to demonstrate the way Avista is responding to the challenges facing the industry.
ln order to do this most effectively, the Company has developed strategies and methodologies to meet
competing financial needs through formalized decision-making processes as described below.
AVISTE. INVESTT,TENT SEI-EC'TION PROCESS
Engineering Roundtable
How do Avista's Transmission Planning, System Operations
and Engineering business units evaluate and prioritize
proposed transmission projects? Several steps are involved in
determining which projects should be considered for funding.
Upgrading Sunset Substation
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
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Schedule 2, Page 7 of 128
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Stagnant Load Grow,th
. Tronsmission Plonning
o Distribution Plonning
o Transmission Design
o Substotion Design. System Protection
o Distribution Design
. System Operotions
r Asset Monogement
o Com mu n icotions E ngi n eeri ng
o Transmission Servicest Generotion Engineering
Business Units
Represented in the
Engineering
Roundtable
lnitially, projects are developed through planning studies, engineering and asset management
analyses, and scheduled upgrades or replacements identified in the operations districts and within
engineering groups. These projects undergo internal review by multiple stakeholders who help ensure
all system needs and alternatives have been identified and
addressed. lf proposed projects are initially approved, they go
through a formal review process
referred to as the "Engineering
Roundtable." The purpose of the
Engineering Roundtable (ERT) is to
provide an actionable roadmap that
identifies a nd prioritizes projects
that will benefit Avista and our
customers. Each proposed project
includes clear justification and
alternatives analysis to achieve
positive regulatory outcomes. The
ERT seeks to enhance efficiency and
effectiveness of capital spending
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and resource allocation while acknowledging and validating internal
customer needs and providing clear communication, visibility, and transparency as decisions are made.
The Engineering Roundtable serves as a communication and review committee for projects requiring
Transmission, Substation, or Protection engineering support. The Committee is responsible to track
project requests, prioritize them, and establish committed construction package dates and required in-
service dates for projects that are consistent with the Company's vision and corporate strategies.
Representatives from eleven business units participate in the ERT process.
Dry Creek 230/1L5 transmission auto transformer making its way to
Each business unit proposing a
project is required to fill out a
form explaining the problem,
the primary business driver,
alternatives considered, and
the justification for the
approach recommended.
During the review, the
potential benefits of any cross-
Dry Creek Substation business unit synergies that could
better optimize project benefits
and scope are also identified and evaluated. The primary output of this process is a list that serves as a
roadmap of projects that are scoped at a high level and sequenced by year for at least a ten-year time
horizon. lt is then communicated across the organization so that each department can plan ahead for
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 8 of 1 28
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the work that they will be responsible to execute. Once a project has passed this phase of evaluation, it
moves to the Capital Planning Group for final review.
Capital Planning Group
The Engineering Roundtable creates a prioritized list of needed investments for electric transmission.
Business cases are completed for the projects on this list and submitted to the Capital Planning Group
(CPG), a group of Avista Directors that represent capital intensive areas of the Company. Committee
members are directors from a variety of business units to add a depth of perspective, though their role
is to consider capital decisions from the perspective of overallCompany operations and strategic goals.
The CPG reviews the submitted Business Cases from various departments and prioritizes funding to
meet the upcoming five year capital spending guidance set by senior management and approved by
the Finance Committee of the Board of Directors. The CPG meets monthly to review the status of the
capital projects and programs, evaluate changes
requested, and approve or decline new Business
Cases. They also monitor the overall current year
capital budget. This group develops and
recommends a 5-year capital expenditure plan by
investment driver to the Company's officers. The
CPG is responsible for reviewing, approving,
deferring, or denying capital requests, and for
appraising productivity and strategic proposals.
lnitial expenditure requests may need to be modified based on the timing of equipment, permits,
available crews, priorities of projects, etc. The CPG approves or declines these changes based on
managing a total budget amount. Therefore, as changes occur throughout the project, project funding
may change, or one project may be funded while another is
removed or delayed to allow higher priority projects to be
funded. This is done while remaining within the total approved
capital spending amount. This group reprioritizes as needed to
ensure that the highest priority projects are identified and
funded.
Avista's Capital Planning Group evaluates aspects such as the
project description, alternatives, cost and other financial
assessments, risk, justification, resource requirements, and how Hot springs - Noxon #2: Replacing
the project fits into the Company's overall strategies. They provid s old wood structures with steel
a comprehensive and strategic perspective that helps ensure that the right projects are funded
adequately at the right time.
Ultimately the individual investments selected to be included in Avista's Transmission lnfrastructure
Plan represent a portfolio of projects and funding levels intended to optimize:
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 9 of 1 28
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Purpose
People &
Resources
1) The overall demond for tronsmission investment,
2) The specific requirements of the projects ond programs proposed for funding, and the potential
consequences ossocioted with deferring needed investments, ond
3) A bolance among the needs and priorities of all investment requests ocross the enterprise ond
the Compony's investment plonning principles.l
The result demonstrates a reasonable balance among
competing needs required to maintain the performance of
Avista's systems, as well as prudent management of the
overall enterprise in the best interest of customers.
External factors such as new regulatory or legislative
requirements may drive changes in the plan. The projects in
the Company's portfolio are continuously reviewed for
changes in assumptions, constraints, project delays,
accelerations, weather impacts, outage coordination,
system operations, performance,
permitting/licensing/agency approvals, safety, and customer-driven needs that arise. The portfolio will
be continually updated throughout the year to remain as accurate as possible.
AvISTA's TRANSMISSIoN I ruvEsrrraENTs
lncreasing Capital lnvestments for lnfrastructure Needs
ln recent years, Avista has experienced an increasing demand for new and upgraded infrastructure
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National Avemge md Avista Actual Tmmmission
Capital Spending Cost Per Customer
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Avista Actual
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Figure L. Infrastructure Investment Demands
Source of Notionol Doto: FERC Form 7'1
investment. The pattern of investments
made by the Company during this period
bear a resemblance to that of the
industry, though Avista's investments
have increased at a slower pace, as shown
by the trend line in Figure 1 (with
exceptions in the mid-2000s as will be
discussed later in this report). This
similarity should not be a surprise since
we are all responding to the same
investment drivers: the demand to replace
an increasing amount of infrastructure
that has reached the end of its useful life,
ever increasing regulatory compliance
1 ln setting its overall infrastructure spending limits, the Company considers a range of factors referred as "key planning principles" as shown in the bubble
diagram.
2 Note that compiled FERC Form 1 data is cunently only available through 2015 - they are typically a year or two behind in providing lhis data to the
public. https//openei.org/datasets/dataseUferc-form-1 -electric-utility-cost-energy-sales-peak-demand-and-customer-counldata-1 994-201 5
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 10 ol 128
0bjectives
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requirements, and the need for reliability and technology investments necessary to build the
integrated energy services grid of the future. Avista's investments in electric transmission also reflect
the Company's adoption of new asset
management-based approaches for
assessing infrastructu re needs and
developing strategies and programs to
optimize the lifecycle value of our
system.
ln the early 2000s, Avista was required
to execute major upgrades in the
transmission system to replace lines
built in the 1950s and to mitigate
congestion issues in the Northwest (as
described in detail beginning on page
Figure 2. National & Avista Transmission Cost Per Customer 31) WhiCh puShed spending above the
source of Nationol Doto: FERC Form 13 national average for that time period.
Since the completion of those projects, our annual capital costs expressed on a per-customer basis are
generally in line with, though below, that of the national electric utility industry, as shown in Figure 2.
When considering the Company's Transmission, Distribution, and Generation infrastructure
investments measured across the entirety of our business, Avista's historical capital cost per customer
has varied, sometimes substantially, based on the intensity of our historic levels of investment and the
number of customers we served at the time. However, the Company's spending tends to be very much
in line with that of other utilities across the nation.
Failed Plant &Classification of lnfrastructure Need by
lnvestment Drivers
Operations
As a way to create more clarity around the
particular needs being addressed with each
capitolinvestment as well as simplifying the
organization and understanding of our overall
project plans, the Company has organized the
infrastructure investments described in this
report by the classification of need or
"lnvestment Driver." a Figure 3. Total Planned Capital Expenditures by Investment Drivers
3 Note that compiled FERC Form 1 data is currently only available through 2015 - they are lypically a year or two behind in providing this data to the
public. https//openei.org/datasets/dataseUferc-form-1-electric-utility-cost-energy-sales-peakdemand-and-customer-counldata-1994-2015
a Avista's Distribution asset class has a sixth investment driver, Customer Service Quality & Reliability. This driver is not applicable to the Transmission
system, as Transmission does not typically directly impact customers. lt is also planned and operated to maintain continuity of service to customers at all
times, including during forced outage contingencies.
5 The Failed Plant & Operations budget is split between Distribution & Transmission. This chart reflects 18.71% of the total, as that has been the
percentage of the budget actually used by Transmission over lhe past five years.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 11 of 128
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Mandatory & Compliance
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The need for investments associated with each investment driver is briefly defined below, and in
greater detail later in this report. Details about the projects in each category can be found in Appendix
A, beginning on page 58.
L. Customer Requested - This category is primarily related to connecting new facilities for large
transmission-direct customers or to enhance their service as requested. This category was used,
for example, to provide for expenses related to the requested interconnection of Avista's new
solar project, which is owned by an independent solar developer that requested
interconnection.
2. Customer Service Quality & Reliability - This category is for expenses related to meeting our
customers' expectations for quality of service and electric system reliability. Transmission does
not have any dollars set aside under this category, as it does not typically directly impact
customers - very few of our customers receive direct transmission service.
3. Mandatory & Compliance - The Company makes a
large number of business decisions as a direct
result of compliance with laws, mandatory
standards, safety codes, contracts, and
agreements. Examples include transmission
reinforcement projects or control equipment
required by NERC to preserve the reliability of the
interconnected grid. These decisions are primarily
driven by external requirements that are largely
beyond the Company's control.
4. Performance & Capacity - Programs in this category ensure that
our assets satisfy business needs and meet performance
standards, typically defined by Company experts or in line with
industry standards. Some examples include adding new
substations or transmission lines to meet customer growth or to
provide redundancy to reduce the potential for outages.
5. Asset Condition - All assets have a defined useful service life.
This category provides funding to replace equipment as needed
so it can continue to function effectively. lt may include
replacing parts as they wear out or when items can no longer
meet their required purpose, as systems become obsolete and
replacement parts are no longer available, to remedy safety or
environmental issues, or if the condition of an asset is such that it is no longer optimizing its
own performance or customer value. The Company also replaces critical equipment to mitigate
the risk of failure.
6. Failed Plant & Operations - This category sets aside funds to replace failed equipment and
support ongoing utility operations. Often these expenditures are the result of storm damage.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 12 ot 128
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All of Avista's capital expenditures are categorized into one of these
Drivers, though not all of the investment driver categories are
represented for each asset class. For example, electric distribution
investments encompass all six categories; however, investments
planned for electric transmission during the upcoming five year
planning cycle do not include any projects in the category of Customer
Service Quality and Reliability. This is fairly common, since very few of
our customers receive direct transmission service. ln addition,
investments in electric transmission related directly to service
reliability for all customers are generally driven by mandatory
compliance requirements so can be found in the "Mandatory &
Compliance" Driver. Note that not all of the investment drivers will be
Iransmrssion work at Noxon used in all of Avista's primary asset categories in every budgeting
cycle, yet they remain an efficient and effective way of categorizing
expenditures in a clear and transparent fashion that promotes better understanding of how the
Company makes business decisions.
Overview of Currently Planned lnvestments in Electric Transmission 2018 -2022
Pla nned Ca pital I nvestme nts
Over the current five-year planning horizon, Avista expects to spend approximately 5364 million for
transmission capital investments. The planned annual investments for this period ranges from a low of
about S0S million (in 2020)to
a high of 581 million (in
2O2U, with an annualaverage
of 572.7 million. Avista's
programs for electric
transmission investments are
summarized by investment
driver, discussed in more
detail later in this report.
Note that some projects may
resolve issues under more
than one category. While
projects are categorized by a
principal investment driver, a
project that resolves multiple Figure 4. Total planned Capital rransmission Expenditures 201.g-2022
issues may be prioritized
differently than it would be if under a single investment driver category.
Exhibit No. 8
Case No. AVU-E-I9-04
H. Rosentrater, Avista
Schedule 2, Page 'l 3 of 128
Electric Tralsmission Capital Infrastructure lnvestments
by Year & Investment Driver
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Madatwy & Customet Requested Perlormonce &Complbne Coqclty
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Asset Condition Foiled Plont &
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F 2021 .2022
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oP I a n ne d lVl a i nte n a nce Expe n d itu re s
Over the next five years Avista plans to invest approximately S1.2 million annually in operations and
maintenance programs designed to sustain its electric transmission system. Unexpected expenses are
Elccnic Transmission Planncd O&\{ Expenditurcs
Average per Year 2018-2022
Foundations
Aerlal P.trols
Ground
lnspecdons
Flre
Reterdant
V6getation
Manatement
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Figure 5. Average Planned O&M Transmission Expenditures
always a possibility, but the Company has
routine maintenance programs in place to
insure that those occurrences are as few
as possible. Programs such as aerial and
ground patrols to identify potential
problems, fire retardant to protect poles
from wildfire, foundation work to maintain
the integrity of the structures, and
vegetation management around lines and
on access roads all help prevent outages.
Each of these programs play a role in
ensuring reliable service.
CoNctusroN
The year-over-year growth in the level of our prior period investments is not unusual compared with
our peers across the utility industry. Our capital investments on a per
customer basis are reasonably consistent with the industry, though our
overall transmission spending pattern has trended below the industry
average.
Avista's transmission i nfrastructu re progra ms a re thoughtful ly developed,
analyzed, optimized, adjusted, and re-analyzed as appropriate to ensure
that we deliver cost effective value for our customers and meet all legal
and mandatory requirements. This report also demonstrates that the level
of our investments is somewhat
conservative as a result of our
need to balance transmission
priorities with our other
infrastructure demand, and the
re
impact of these investments on our customers and our level
of service.
t
o
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 14 ot 128
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$J,i
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Avista Utilities serves approximately 1.6 million electric and
natural gas customers over 30,000 square miles, primarily in
Eastern Washington and Northern ldaho, over 2,2OO miles of
high-voltage transmission lines and associated equipment.
Avista must continually invest in its electric transmission
system in order to provide the reliability our customers
expect and deserve, at an affordable price, and that meets
the requirements of numerous laws and regulations.
Though all of Avista's assets play
a role providing the electricity
that ultimately reaches
consumers, in this report we have
confined our discussion
specifically to tra nsmission
facilities. Transmission is the
physical energy delivery system
that moves electricity from
generation facilities to the
substations where the voltage is
stepped down to the distribution
level so it can be delivered to
customers. We have also included
several operations and
maintenance (O&M) proBrams
such as Vegetation Management that play a key role in
helping us provide safe and reliable service.
This report provides a summary overview of the Company's
recent historic, current, and planned infrastructure
investments in our electric transmission system for the period
2OLB - 2022. Collectively these investments allow Avista to
effectively respond to customer requests for new service or service enhancements, meet its regulatory
and other mandatory obligations, replace equipment that is damaged or fails, support electric
operations, address system performance and capacity issues, and replace infrastructure at the end of
its useful life based on asset condition. Moreover, the investments described in the plan are based on
what we know about our business today, including a range of precision in future cost estimates,
applicable laws, regulatory requirements, and the capabilities of current technologies.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 15 ol 128
o Provide a comprehensive
summary of the need for
capital investment ond the
plo n for i m ple me ntation;
o Explain factors driving
Avista's need for increosed
investment;
. Simplify the understonding
of the types of needs, or
"investment drivers"
shaping our investment
plan;
o Provide visibility into why
each capitol project and
progrom is necessary to
meet our electric
tronsmission system needs,
and
o Provide a plotform for
co nti n u o u s co I I a bo roti o n
with our customers, Energy
and Policy Stoff,
Commissioners, and o ronge
of other Stakeholders.
INrnooUCTIoN
o
Report Key
Objectives:
I
AvTsM ^A.ccoUNTABILITY ro CusroMERs
Prudent lnvestment - Avista demonstrates that the overall need, evaluations of alternatives, and
the planned timing of implementation for each investment is carefully considered and in our
customers' best interest. This report explains that the investments made to uphold the current
reliability of the electric transmission system are conservative and cost effective for customers. Many
of the investments are required in order to be in compliance with the federal, regional, state, and local
entities that oversee our transmission operations. We believe this report demonstrates that our
investments are needed and necessary in the timeframes planned in order to prudently serve our
customers. lt also notes identified and vetted needs for investment that are not fully funded in the
current planning cycle in an effort to balance other priority investment needs.
Managing Our Costs - With the increasing levels of investments made by the Company in recent
years, we have worked to mitigate the cost impact by moving to our present level of investment more
gradually over a period of several years. This effort often requires Avista to fund programs at less than
an optimum level during ramp up. The Company's efforts to manage the impact of these increasing
infrastructure needs has allowed us to hold the annual increases in our customers' electric bill to a
reasonable average of L.9% over the past eight years. This keeps Avista's electric bills below the
national average, below the average for ldaho since 2013, and below the average for electric
customers in the state of Washington.6
Providing Reliable Electric Service -Avista is focused on maintaining a high degree of reliability
as an important aspect of the quality of our service, particularly as our society becomes ever more
reliant upon electronic technologies. Essentially, every utility has to define what "acceptable service
reliability" is for its customers, striking a complex balance between customer's expectations, the
investments that are needed to meet them, and overall system performance. ldeally, this mix creates
the highest level of reliability performance that customers are willing to pay for in their rates. The
expectations of customers can vary substantially from utility to utility, and there is a range of reliability
levels that customers deem to be acceptable. Even within a utility's service territory, the reliability
performance that is acceptable to customers can vary substantially by region. ln Avista's experience,
our customers are accustomed to the level of service reliability they have experienced in the area in
which they live, and generally believe that to be reasonable for their locale. Avista's customer
satisfaction surveys support this conclusion. ln 2016 customers indicated94% satisfaction with the
overall service they receive from the Company. The number of complaints is also quite low, with only
ten complaints filed in 2016.7 Because it is expensive to achieve incremental levels of system reliability,
and because these investments must be sustained over a period of many years before the benefit is
realized, it is important to ensure that we are investing only the amount of money it takes to achieve
an acceptable level of performance.
6 The 1.9% includes all aspects of electric service. Statewide and national customer cost comparison information based on Edison Electric lnstitute
lnvestor-Owned Utilities. Study available at https://www.myavista.com/aboutus/our-rates-and-tariffs/aboutrates
7 Nine complaints were filed with the Company, one with the Commission directly. Washington Utilities and Transportation Commission, 151958-AVA-
Comments-8-21-17
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 16 of 128
o
o
o
o
o
Tne Elecrnrc SYsrenr
The North American electrical grid is a highly complex and diverse system. lt includes varied
organizational structures and operating models (including multinational ownership), interdependent
functions and systems, and multi-level authorities, responsibilities, and regulations. lt is made up of
generating facilities such as coal-fired and nuclear power plants, solar panels, wind turbines, natural
gas-fired power plants, and hydroelectric dams. Transmission lines of various sizes carry the generated
energy to substations. A complex distribution network takes the energy from the substations to the
ultimate customer. An example is shown in the diagram below.s
Figure 6. Basic Structure ofthe Electric System
When electricity is generated, typically at voltage levels similar to primary distribution customers, it is
sent to a "step up" transformer in a substation outside the power plant where it is increased in voltage
to allow it to travel more efficiently over long distances via transmission lines. At the distribution
substation, the transmission line feeds a "step down" transformer that reduces the voltage before it
enters the distribution system and goes on to the customer.
As electric current flows through a line, the resistance of the wires causes some of the energy to be
dissipated in the form of heat (think of an electric space heater). This loss of energy is called active
power line loss. By increasing the voltage on the line, typically to 110 kV or above, the required amount
of electric current to transfer the same amount of energy is proportionally reduced, thus reducing line
loss.e lncreasing the diameter of the electric conductor also serves to reduce the amount of resistance
and associated losses. Thus, high voltage transmission lines allow utilities to maximize the amount of
energy that is ultimately delivered to the end user.
8 Diagram cou(esy of University of ldaho, "Principles of Sustainability." Chapter 6, http://www.webpages.uidaho.edu/sustainability/chapters/ch06/ch06-
p3a.asp
e ln the United States, the fraction of electricity lost in transit is about 6% for lines at 230 kV and below. Losses are reduced as voltage is increased. Lines
at 345 kV typically suffer 4% losses, 500 kV lines are down to about 1 .3% losses, and 765 kV and above are under 1 %. However, new line and equipment
designs are reducing these losses. https//www.dallasnews.com/business/health-care/201 0/1 0/1 1 /ElectricityJostin-transmission-shows-up-3566
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 17 of 128
Ovznvtgw oF THE U.S. TnartsrutsstoN Sysrgru
ooooE
60
ENE
Transrnission Lines
765, 500,145,210 and t t skv
Transmission
fustomer
138 kV 0r 230 kV
Distribution
Lines
Subtransmission
(ustomer
26kv and 59kv
fiimary Customer
t;kv and +kv
GeneratingStation Generalor
SteqUp
Transformer
Substation
StepDown
Trans{ormer
5econdary
l20Vand
Custorner
240V
o
While electric reliability metrics
of outage frequency and
duration are measured at the
distribution level of our system,
the integrity and performance
of our transmission system also
plays a vital role in providing
reliable service to Avista
customers. Most transmission is
Gererating Station
Generating Station
SubtraMission
Customet26kV and 69l(/
Primary Customer13kV and 4kV
Secondary Cu$omeI12OV and 24OV
Secondary Custmel12()V ild 2zl()V
O
o
configured to be loop-fed, substation
which means that the lf an outage occurs on the top transmission tine, cusfomers can stillbe serued from the
electricity can be provided to a second line (a redundant or looped feed system). Without the second transmlsslon /rne,
. ..-- r--_ thetopline customers wouldbewithoutserviceuntilthelinewasrepaired.otstnouUon suDsrailon Trom
more than one direction (as shown in the illustration). ln this configuration, a transmission outage will
be isolated by substation equipment, the power will be rerouted to a different transmission line and on
to customers. Thus the outage will have little or no effect on distribution facilities and customers.
However, the reality of a modern electric system reflects a number of scenarios where transmission
level reliability could directly affect distribution level reliability
For example, some small rural substations have a single
transmission feed and cannot be backed up by nearby
distribution feeders or a second substation. This is called a
radially fed substation (such as that shown in Figure 6 on the
previous page). ln this configuration, an outage to the
transmission line can put the entire substation and its
associated distribution system out of service.
lNpusrRv CnallgNGEs
The utility industry has never faced the onslaught of challenges it is dealing with today. Even as
demand and cash flow shrink, utilities must weigh significant capital investments in transmission and
distribution lines in order to maintain reliability, update outmoded systems, and address 2Lst-century
concerns like cybersecurity. ln addition, utilities must manage:
transformers, reactors, ca pacitors,
conductors, poles and structures are well past
their expected lifespan.l0 The U.S.
Department of Energy (DOE) estimates that, nationwide, T0% of transformers are 25 years old or
older, 60% of circuit breakers are more than 30 years old, and 70% of transmission lines are 25
10 For more information about the primary equipment used in lhe kansmission system, please see Appendix J (page 97).
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page'18 of 128
63%7ff/o
ffi/o4V/o
7@/o88%
Transformer > 25 years old
Circr,rit Breakers > !l0years old
Transmission Lines > 25 years old
Avista Nation
O
o years old or older and approaching the end of their useful life. This critical situation continues to
build, driven by a lack of investment in transmission infrastructure, which declined 44% between
1980 and 1999.11
) Low and Shifting Demand is reducing sales and revenues. The20L7 Annual Energy Outlook from
Edison Electric lnstitute projects a decrease in load growth for the next several years, as can be seen
in Figure 7. EEI projects total electricity sales to rise 0.7% annually, with the residential sector
U.S. Electricity Demand (Load) Growth 1950-2040
14
12
10
6
4
2
0
-2
1950 1960 1970 19E0 1990 2000 2010
-3-year
moving avcrag€
-Trendlinc
2020 2030 2040
projected to grow by 0.3% per year, the
industrial sector to grow by L.1% per
year, and the commercial sector
expected to decline by 0.3% per year.12
EEI attributes this slow growth to energy
efficiency and a move toward less
electricity-intensive industries. Th is
situation sharply reduces earnings
growth for utilities.
For utilities like Avista, the load mix is
also shifting. The State of Washington
legalized growing marijuana, which is a
o
Fiqure 7. u.S. Electricity Demand Growth13 highly power intensive operation
requiring 24-hour lighting, heating, air conditioning and ventilation systems. As an example of the
impact, Denver's 362 marijuana growing facilities consumed more than
2% of the entire city's electrical usage. City planners estimate that a
5,000 square foot indoor facility consumes approximately 29,000 kWh
of electricity as compared to a local household which would consume
about 630 kwh.14 Data centers have similar high-energy usage profiles.
As an example, when Microsoft located a data center in Quincy,
Washington in 2007 they requested that Grant County Public Utility
District provide a substation capable of 48 million watts, about enough
power to serve 29,000 American homes, according to an analysis done
by the Electric Power Research lnstitute. A large data center can use as much electricity as a small
town, with a power density L00 times more than a typical large commercial customer.ls
11 'Transmission & Distribution lnfrastructure," A Hanis & Company, Summer 2014,
http://www.harriswilliams.com/sites/defaulUfiles/industry_reports/ep_td_white_paper_06_10_14_final.pdf. For information on the specific equipment
referred to, please see Appendix J 'Transmission System Equipment" beginning on page 97 or the Glossary in Appendix Z beginning on page 103.
12 Edison Electric lnstitute 2017 Annual Energy Outlook, https://www.eia.gov/outlooks/aeo/ and the Energy lnformation Administration,
https:i/www.eia.gov/todayinenergy/detai l. php?id=26672
13 Data for this chart from the EEI 2017 Annual Energy Outlook: https://www.eia.gov/outlooks/aeo/
1a Melanie Sevcenko, "Pot is Power Hungry: Why the Madjuana lndustry's Energy Footprint is Growing," The Guardian, February 27 ,2016,
https//www.theguardian.com/us-news/201 6/feb/27lmarijuana-industry-huge-energy-footprint
15 James Glanz, "Data Barns in a Farm Town, Gobbling Power & Flexing Muscle," The New York Times, September 23,2012,
http//www.nytim es.coml2012l09l24ltechnology/data-centers-in-rural-washington-state-gobble-power,html and "Facts and Stats of World's Largest Data
Centers," Storage Servers, July 17,2013, https://storageservers.wordpress.com/2013/07/17lfacts-and-stats-of-worldsJargestdata-centers/
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 19 of 128
o
) Regulatory pressure is focused on retail energy prices, green technologies and more customer
control. A 2015 PriceWaterhouseCooper Power and Utilities Survey indicated that uncertainty in
regulatory policies and regulations are the primary risk facing utilities.16 According to the survey,
allowed return on equity (ROE) has been
consistently dropping throughout the
industry since the 1980s, although the
need for capital investment is increasing,
creating tremendous tension. Though
regulators maintain close scrutiny over
rates they are "freely encouraging the
development of renewables and greater
customer access to the grid, distribution
channels, and equipment through
emerging technologies."lT These
technologies require expensive
investments and infrastructure. ln addition,
as will be discussed in later sections, national and regional regulations and requirements are
increasing in number, each requiring Avista to respond in the way we operate and do business.
Today's federal operating standards presume that the nation's transmission infrastructure is
sufficiently robust at this time, allowing it to comply with the ever more restrictive operations
standards and additional uses put forth by the Federal Energy
Regulatory Commission (FERC). That is simply not the case.
According to the American Society of Civil Engineer's 20L7
lnfrastructure Report Card, much of the U.S. energy system was
constructed in the 1950s and 1960s and more than 640,000
miles of aging high-voltage transmission lines in the lower 48
states' power grids are at full capacity.
ln addition to feeling its age, the integrated grid, designed to
accommodate very steady, very stable traditional resources, is
now required to integrate non-traditional and often
unpredictable resources, smart grid technology and emerging
technologies such as energy storage, electric cars and
distributed systems. At the same time, the grid is facing cyber
threats never imagined back in the L950s and L960s when most
of the system was built.
16 PriceWaterhouseCooper (PWC) 'Global Power & Utilities Survey, 2015: Key Challenges", https://www.pwc.com/gx/en/industries/energy-utilities-
mining/power-utilities/global-power-and-utilities-survey/key-challenges.html
17 Earl Simpkins, Leslie Hoard, Suva Chakraborty, Daniel Wilderotter, "Utilities Preparing for Growth: Navigating Disruption By Linking Capabilities,"
November 20, 2015, https//www.strategyand.pwc.com/reports/utilities-preparing-forgrowth
18 Herman K. Trabish, "US Utilities Are Beginning to Remake the Nation's Grid," UtilityDive, July 15, 2014, https://www.utilitydive.com/news/us-utilities-are-
beginning-to-remake-the-nations-grid/285916/ based on data from the Edison Electric lnstitute.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 20 of 128
Number ofNERC Mandatory Standards Subject to Enforcement
35
25
!
{20
6
o
10
5
0
2W 2m8 2m9 2010 2011 2012 2A13 2014 2015 2015 2017
Figure 8. Number of NERC Mandatory Standards
o
o
The U.S. Power Grid bv the
Numbers
o Technology dates back to 7950s -
1970s
c Over 7,000 power plonts
o Over 5 million miles of transmission &
distribution lines
o 68-73% of oll major outages ore
weother related. More blockouts thon any other
developed nation (today having 285%
more outoges than occurred in 7984)t Avemge price l2d/kwh. 3,3N utilities
o 750 million customers
o Valued at 5876 billionls
o
/
\-
o
o
According to a variety of studies across the United States, the viability of the century old bulk power
grid has been declining and is "nearing the end of its useful life." They note that depreciation is
exceeding new investment, even with all of the large projects being built nationwide. Further, they
state that: "Legislative and regulatory barriers based upon environmental and sustainability concerns
constrain, even prevent, the siting, construction and operation of new grid facilities." 1e The cost of
new infrastructure is increasing and any significant new construction means higher rates to consumers
in an increasingly competitive environment. Utilities face significant risk of not recovering all their
costs, much less an adequate return, for new infrastructure investment.20
Utilities are pulled to economize and pushed to innovate, dealing with decreasing revenues and, at the
same time, expensive and revolutionary new technologies such as distributed generation, battery
storage technology, customer-requested technologies, and integrating intermittent renewable
resources.2l
Federal Transmission Standards: Operations
Avista has been hit particularly hard by tightening federal standards governing our transmission
operations. The primary impact has been a significant loss in the operational flexibility once relied
upon to ensure stability of the grid during unusual
operating conditions, usuary invorving rine or *"*i::j!ffi;1";*','.;::,',.#,y,.,'::!#:*::;r1trrfn'*
substation outages. As an example, by judiciously
using its past operating flexibility based on the
standard operating practices of the time, the
Company was able to take short-term remedial
actions to manage through unexpected outages,
thereby avoiding making expensive investments in
transmission infrastructure to mitigate infrequent
system outages. Consequently, the more restrictive
operating requirements mandated by federal
standards now necessitate construction of new
infrastructure or rebuilding existing infrastructure to
mitigate the potential for loss of customer service.
The tightening of the operating standards has simply
outpaced Avista's ability to make the significant
capital investments needed to reasonably comply.
"Reasonably comply" here means without bearing
5%
Figure 9. National Planned Transmission
Additions lndicating the lmpact of Federal Regulations
Regarding Reliability and Renewable Resource lntegration22
1e Ead Simpkins, Leslie Hoard, Suva Chakraborty, Daniel Wilderotter, "Utilities Preparing for Grov(h: Navigating Disruption By Linking Capabilities,"
November20,2015, https//www.strategyand.pwc.com/reports/utilities-preparing-for-growth
20 lbid.
21 "Electric Utilities Are Facing Unprecedented Challenges," Seeking Alpha, January 18, 2016, httpsJ/seekingalpha.com/article/38'16936-electric-utilities-
facing-unprecedented-challenges and Tom Flaherty, Norbert Schwieters and Steve Jennings, "21 07 Power and Utilities Trends,'
https://www.strategyand.pwc.com/trend/2017-power-and-utilities-industry-trends
22 Data for this chart from "Transmission & Distribution lnfrastructure," http://www.haniswilliams.com/sites/defaulUfiles/industry_reports/final%20TD.pdf
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2,Page21 of 128
Renewable lntetration
35%
Reliability
35%
o
Other
lntegratlon
2s%
undue additional stress and risk to equipment, or having to operate in an emergency mode in order to
avoid a violation and sufferthe significant resultingfinancial penalties. As a result of this mismatch in
system capability and operating restrictions, the Company must develop and undertake relatively
short-term, urgent investment strategies which, while prudently serving the immediate need to be
compliant, may not provide the optimum long-term solutions from a facility planning perspective or a
customer rate basis.
Federal Transmission Standards: Planning
Electric utilities must also comply with more stringent federal transmission
planning requirements, which, like the FERC operating standards, also
come with attached penalties for noncompliance. These planning
standards rely on conventionalforecasts of load growth and modeling of
the electric system. They focus on the type of transmission system
improvements needed to operate in accordance with the federal
operations standards a decade or more into the future. Though the
planning standards do not stipulate what investments must be made, they
do require the Company to prove it has timely completed the required
studies, and to demonstrate that it is making reasonable progress making
the transmission investments identified in the planning studies.
Because the focus of planning is to create an adequate and robust system
for the future (from a holistic system perspective) it is necessarily disconnected from today's
operational limitations and the current critical needs of the system. ln an idealworld, the operating
limitations of today's system would be remedied in the long-term infrastructure plan developed by
sufficient planning. However, that does not address the needs of providing compliant load service
today. lt's not that this disconnect is a bad thing; however, it requires the Company to rationalize
sometimes incongruent and competing needs and to make certain it provides the capitalfunding
necessary to achieve compliance in both current operations and future planning. Though the Company
is making great strides in better rationalizing these competing needs through formalized processes
such as the Engineering Roundtable (discussed earlier), it still has not been able to provide the capital
required to adequately fund the needs identified by each function.
Growing Need for Investment Based on Asset Condition
lrrespective of the investments needed to plan for and operate our electric transmission system in
compliance with federal standards, the Company and the industry in general face the growing need for
reinvestment in transmission based upon the replacement of assetsthat have reached the end of their
useful life. Much of the nation'stransmission system was constructed before 1970, with an expected
23 Herman K. Trabish, "US Utilities Are Beginning to Remake the Nation's Grid," UtilityDive, July 15, 2014, https//www.utilitydive.com/news/us-utilities-are-
beginning-to-remake{he-nations-grid/285916/ based on data from the Edison Electric lnstitute.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 22of 128
o
o
o
o
o
service life of 50 years.2a Approximat ely 63% of Avista's electric
transmission lines are more than 50 years old; 88% are over 25
years old. ln addition, these lines were built to provide traditional
utility service: moving energy from the power plant to the
substation, without consideration to the integration of
intermittent resources, the development of the energy open
market, or the issues created by increasing regulation. These
matters are driving required transmission investment nationwide,
as shown in Figure 10.
This pattern of growth in the need for new investment reflects the
significant expansion of the electric system during the economic
boom following the end of World War ll. During this period, which
continued as late as the early L980s, the annual plant additions to
the system dwarfed those investments made before the war. So
while the industry and Avista have for many years been replacing
end-of-life transmission and other infrastructure, we have entered
a period where the amount of material that must be replaced is
Current Transmission lnfrastructure Age
Relativeto Useful Life
Transmission lnf rastructure
(asa%ofTotal)
At End 5%
Near End
Planned Transmission Miles by Driver
(asa%ofTotal)
lntegradon ol
New 6enention
Renewables 27%
E@nomics/
Con8estion 1596
within
70%
Regulatory/
Reliability 58%
o
increasing each year, and it will continue to do so for the next Figure 10. U.S. Transmission Structure
two decades at least. while some of these asset condition Age and construction Drivers2s
investments may serve the needs of transmission planning and operations, they tend to be separate
and distinct, and as such, represent another significant competing driver for limited the capital
required to fund priority needs across the business.26
Third-Party Transmission Requirements and Growing Uncertainties
Today's electric utility is also under federal obligation to provide transmission interconnections and
related investments required to serve the needs of non-utility, non-customer, private business
interests. While it is assumed that these private transmission users will pay for the investments they
require over the term of their contracts, this concept presumes that they remain in business long
enough to do so. lt also supposes that the transmission rates for these users, which are established by
Federal Energy Regulatory Commission, fairly allocate the costs between Avista's customers and these
third-party users. But even more importantly, the requirement to make the investments needed to
provide these interconnections (and associated capacity) competes directly with the utility's primary
capital needs to support operations, planning, asset replacements, failed plant, and its own customer
base in an increasingly constrained capital environment.
2a American Society of Civil Engineers, "2017 lnfrastructure Report Card," https//www.infrastructurereportcard.org/cat-item/energy/
25 This data is from "Transmission & Distribution lnfrastructure", http://www.harriswilliams.com/sites/defaulUfiles/industry_reports/final%20TD.pdf
26 For more information about national grid condition, see Meagan Clark, 'Aging US Power Grid Blacks Out More Than Any Other Developed Nation," July
17 ,2014,lntemational Business Times, http://www.ibtimes.com/aging-us-power-g rid-blacks-out-more-any-other-developed-nation-1631086 and Steve
Brachmann, 'America's Aging Electrical Grid Could Benefit from Smart Grid Tech," April 4, 2016, http//www.ipwatchdog.com l2016l04l04laging-electrical-
grid-smart-gridtech/id=67934/ and Tara Dodrill, "Study: US Power Grid Has More Blackouts Than ENTIRE Developed World,"
http://www.offthegridnews.com/grid{hreats/study-us-powergrid-has-more-blackouts-than-entire-developed-world/
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 23 ot 128
New Technology
Another dynamic facing electric utilities today is the uncertainty generated by the emerging business
model, which is focused on decentralizing traditional utility function in order to create a new
integrated grid-services platform of the future. While for some time now the thinking has been that
the promotion of new technologies like distributed
resources might help offset the need for pending
grid reinforcements, the nascent reality is that
customers, armed with a range of new
technologies, are desiring new services and
flexibility that go well beyond any notion of
maintaining the conventional grid with just a few
tweaks here and there.27 While our Company has
been a pioneer of sorts and a promoter of the
development of these ideas, these concepts create
uncertainty about the long-term used and
usefulness of the infrastructure investments we
make today. This is the case because the assets
that comprise the transmission and distribution system generally have very long lives. As customers
continue to exercise greater choice in how they meet their personal energy needs, and laws and rules
continue to adapt to support that, it places increasing degrees of uncertainty around long-term
usefulness as well as the potential for stranding today's investments.
Top Conce,ms of Utility Executives
Aging lnfrastructure
AgingWorklorce
Cunent Regulatory Model
Stagnant [oad Growth
Federal Emission Standards
PhFicel & Cyber Grid Sec1lrity
Distributed EnerBy Resources
Coal Plant Retirements
Grid Reliability
Smart Grid Deployment
Re rnwable Portf olio Standards
Energy Efficiency Mandates
47%
39i!o
38%
28%
25%
24%
zJ%
7L%
9Yo
0%ZWn 4M 6096 8096 100%
Figure 11. Top Concerns of Utility Executives2s
27 "Smart Power Grid" graphic courtesy of John Toon, Georgia lnstitute of Technology, https//phys.org/news/2014-02-lessons-biggestblackouts-
history.html
28 "State of The Elechic Utility Survey Results" UtilityDlVE (Survey of over 400 U.S. Electric Utility Executives) - https://www.slideshare.neUwyakab/utility-
2015
2e Elisa Wood,'Avista to Test Economic Model for Utility Microgrids," September 30, 2016, https//microgridknowledge.com/utility-microgrids-avista/ and
"Spokane Microgrid Diskibuted Generation and Slorage," http://mindworks.shoutwiki.com/wiki/Spokane_Microgrid_Distributed_Generation_and_Storage
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 24 oI 128
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Grid
Avista is actively engaged in addressing
these industry changes, including
collaborating with regulators and
customers to provide the services they are
demanding. Examples include a recently
redesigned website and an outage phone
app. Avista is also developing additional
renewable resources to add to the
traditional resource portfolio, teaming up
with the University of ldaho and
Washington State University to develop a
microgrid in downtown Spokane,2s and
creating a groundbreaking urban renewal
project in Spokane to pilot a variety of
Traditional
Crcnrrationm
-
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potential utility assets, including smart meters, distributed generation, and battery storage.30 At the
same time, the Company is pragmatically managing and balancing its existing and foundational assets
in a way that meets traditional needs.
Avista is faced with the same questions the entire utility industry is dealing with today: does it make
sense to pursue strategies such as the development of new high-voltage power lines that may
reinforce an outdated paradigm of electricity delivery, or should scarce dollars be spent on new but
emerging technology such as distributed generation? Uncertainty exists all around us: the potential for
increased renewable portfolio standards, growing environmental issues surrounding renewable energy
resources,3l changing customer behaviors and expectations, new technologies such as automation,
smart grid, smart meters, the internet-of-things,32 automation, electric vehicles, distributed grid,33
pressure on coal, etc. The list is extensive and expensive, making this an agonizing quandary as so
much is at stake. Since no crystal ball is available, Avista has developed strategies and plans the
Company believes are rational, measured, thoughtful, and conscientious in doing what is right for the
long-term health of the Company and its customers. We will discuss these approaches in the following
pages.
TnEruos IN TRANSMISSION REUABILITY
The North American electric grid is one of the most impressive and complex engineering feats of the
modern era. lt has been called the world's largest machine, comprising over 5,800 power plants,
70,000 substations3a, six million miles of distribution lines,3s and 640,000 miles of high voltage
transmission power lines3s serving nearly 300 million customers in the United States,37 and all
managed byover 3,200 organizations.38lt is made up of three primarygrids: Eastern, Western, and
Texas. lt is estimated thatthe value of this machine is in the range of S1.5 to $2 trillion, with a
30 "Spokane's Urbanova Set to Drive lnnovation and Economic Development for Cities of the Future,' October 3, 2016,
http://www.uetechnologies.com/news/83-spokane-s-urbanova-set-to-drive-innovation-and-economic-development-for-cities-otthe-future and Jeff St. John,
"How Spokane ls Building a Sma( City From the Grid Out, With Transactive Energy lncluded,'November 14,2016,
https://www.greentechmedia.com/squared/read/how-spokane-is-building-a-smart-city-from-the-ground-up-with{ransactive-en#gs.p65vyBM
31 For more information: Union of Concemed Scientists, "Environmental lmpacts of Renewable Energy Technologies," https://www,ucsusa.org/clean-
energy/renewable-energy/environmental-impacts#.Wl-lXWckumQ
32 The lnternelof-Things is the concept of putting computing devices into everyday objects, such as cellphones, cars, washing machines, lamps, etc.,
allowing connection of any device with an on and off switch to the lnternet and/or to each other.
33 lt is interesting to note that there are ripple effects to the utility from dishibuted grid. For example, a study by Black and Veatch found that a utility may
have to add 17% of more transformers to their system to allow for this technology. See: "Disruptive Technologies and the Future of the Utility Business
Model," https//www.slideshare.neUblackveatch/disruptive{echnologies-and-the-future-of-the-utility-business-model. New technologies do not come
without cost.il A. Harris Williams, 'Transmission & Distribution lnfrastructure," 2010, page 7,
hftp//www.harriswilliams.com/sites/default/files/industry_reports/final%20TD.pdf
35 lbid. Page 2.
36 James McBride, "Modernizing the U.S. Energy Grid," January 26,2016, Council on Foreign Relations, https//www.cfr.org/backgrounder/modernizing-
us-energy-grid
38 While investor-owned utilities make up only 6% of the number of electricity providers, they serve 68% of electric customers,
https//www.infrastructurereportcard.org/wp-contenUuploadsi20l 7/01 /Energy-Final.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 25 of 128
replacement cost approaching SS trillion.3s This energy delivery system is the bridge between
electricity generation and consumption. lt transmits power generated from a variety of sources and
moves it to end users every minute of every day. lt is a living entity, constantly changing, with different
sources of electricity being generated, bought, sold, and manipulated to instantly satisfy the demands
of the users. Most of the time it operates invisibly in the background while providing the essential
services that underpin American society. This system is the essential foundation of life-enabling, life-
sustaining infrastructure. lt is considered "uniquely critical"ao by the White House due to enabling and
supporting other vital infrastructure sectors, including oil and natural gas, water, transportation,
communications, and the financial sector.
Originally constructed to serve local customers, the U.S. grid now moves energy nationally across an
aging system. The grid was neither originally engineered to meet today's demand, nor increasingly
severe weather events.al lt is currently operating at or near full capacity. According to the American
United States Outages Affecting >1 Million People Per Hour
-- a a o oo oo o o aa aa a aa-aaaaoaaoa aa
9." *,r&*,"t p& g&
"4" "de"4t S,",4" Bf B* ^p* ^pf ^p& ^ptr +*^p* gr. 4f"s""dfl"stds."s""*""dP"$I"$,.
o Weather Related a Avoidable
Society of Civil Engineers in their 20L7 lnfrastructure Report Card,a2 the energy sector in the United
States faces serious challenges due to aging infrastructure. There are also resiliency issues related to
severe weather events, which they believe pose a threat to both public safety and the national
economy. Their studies show that between 2003 and 20L2, weather-related outages coupled with
aging infrastructure are estimated to have cost the U.S. economy an inflation-adjusted annual average
of S18 billion to S33 billion. Their analysis indicates that in 2015, Americans experienced a reported
3,571 total outages with an average duration of 49
minutes. Backing up these findings is a report to the
White House prepared by the President's Council of
Economic Advisors, which states that extreme
weather is currently "the number one cause of power
outages in the United States, causing an astonishing
87% of outages affecting more than 50,000 people."a3
3s Joshua D. Rhodes, 'The Outdated US Electric Grid is Going to Cost $5 Trillion to Replace," March 16, 2017, Business lnsider,
httpJ/www.businessinsider.com/replacing-us-electrical-grid-cost-2017-3
a0 "Presidential Policy Directive - Critical lnfrastructure Security and Resilience," February 12,2013, https//obamawhitehouse.archives.gov/the-press-
otlicel2013l02l12lpresidential-policy-directive-critical-infrastructure-security-and-resil
a1 For more information regarding increasing numbers of severe weather events, please see Appendix G on page 91.
a2 "American Society of Civil Engineers, 2017 lnfrastructure Report Card: Energy", https://www.infrastructurereportcard.org/wp-
contenUu ploads/2017 101 lEnergy -Final. pdf
a3 "Economic Beneflts of lncreasing Electric Grid Resilience to Weather Outages," President's Council of Economic Advisers, the U.S. Department of
Energy's Office of Eleckicity Delivery and Energy Reliability and the White House Office of Science and Technology, 2013,
https//energy.gov/sites/prod/flles/2013l08l2lGrido/o20Resiliency%20Report_FlNAL.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 26 of 128
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'A robwst ehcd,cfuawsilussww grvd l,s essev*LaL
to achrtt/vvt4 the isww o{ aw ewrgg f,ttwre that t
beLi.cve vtast of us share.'
- FERC Chairman Jon Wellinghofl,20lO
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Noting that the U.S. grid is an "aging and complex patchwork system," the American Society of Civil
Engineers states: "Without greater attention to aging equipment, capacity bottlenecks, and increased
demand, as well as increasing storm and climate impacts, Americans will likely experience longer and
more frequent power interruptions." Their Report Card estimates the cumulative investment gap
between 2016 and 2025 to be 5L77 billion, while at the same time "utilities face considerable pressure
to cover maintenance and system
upgrade costs through regulator-
capped rate increases, and thus
struggle to justify more reliable
lines or make long-term
investments."aa Another study,
this one performed by the Brattle
Group and commissioned by the
Edison Electric lnstitute, suggested
that approximately 5298 billion in
new transmission will be required
over the period 2010 to 2030 to
replace aging infrastructure and
meet increasing demands on the
grid.as
lnternational Electricity Grid Reliability
O = 1000 lWh/tr Consumption
Cuslomcr oulrgr mhul6s prr yoar
280
240
200
160
120
80
40
0
. Littuania Portucal
Austalia
Hmgrryo o llef, lealand
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Slor?nia O tinhnd
Grm[,llcthcrlardi o
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5,000 15,000 25,000 35,000 45,000
t0P per capila (llS[]
Galvin Po,,rer lnstitute, Council ol Iuropean Energy Regulators,
55,000 65,000
SouG& The Blattle 0l0up,
Chin, Southe, Pouer Gdd Efr
Urtai Cilrr
According to federal data, the u.s. electric grid loses lnternational Electricitv Grid Reliabilitv.6
power 285% more often now than it did in 1984 when data collection on blackouts began.aT That is
estimated to cost American businesses as much as S1SS billion per year.as According to experts this is
primarily due to aging infrastructure, including reliance on technologies developed in the L960s and
1970s.4e Analysis indicates that at least25% of America's power assets are of an age in which condition
is a concern.s0 According to the Edison Electric lnstitute:
"Tronsmission investments provide on orroy of benefits thot include: providing relioble electricity service to
customers, relieving congestion, facilitoting robust wholesale morket competition, enobling o diverse and
changing energy portfolio ond mitigating domage ond limiting customer outdges during odverse conditions.
aa'American Society of Civil Engineers, 2017 lnfrastructure Report Card: Energy", https://www.infrastructurereportcard.org/wp-
contenUu ploads/2017 I 01 lEnergy -Fi n al. pdf
a5'Transforming America's Power lndustry: The lnvestment Challenge 2010-2030," The Brattle Group, November 2008, page 5,
http//www.eei.org/ourissues/finance/Documentsffransforming_Americas_Power_lndustry_Exec_Summary.pdf
a6 Source of this graphic: http//www.investmentu.com larlicleldelaill44T9S/chart-cybersecurity-united-states-electricitygrid#.WbqQRWckuUk
lnteresting note: China is now the #1 consumer of electricity in the world and has been since 2009. Global Energy Statistical Yearbook 2017:
https://yearbook.enerdata.net/totalenergy/world-consumption-statistics.html
a7 Megan Clark, 'Aging US Power Grid Blacks Out More Than Any Other Developed Nation," July 2014, http//www.ibtimes.com/aging-us-power-grid-
blacks-outmore-any-other-developed-nation-1 631 086
a8 Massoud Amin,'Asset Management, ROl, Risks, Resilience, and Security," Session 1, June 2017, lnstitute of Electrical and Electronics Engineers
(IEEE), http//resourcecenter.smartgrid.ieee.org/sg/producUeducation/SGTUT0005
ae Megan Clark, 'Aging US Power Grid Blacks Out More Than Any Other Developed Nation," July 2014, httpJ/www.ibtimes.com/aging-us-power-grid-
blacks-outmore-any-other-developed-nation-1 631 086
50 Massoud Amin, "How To Save Aging Assets," 2015, http//www.midwesterngovernors.org/EnergyStorage/Meeting/HowToSaveAgingAssets.pdf
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2,Page27 of 128
o
lrtritsd SlaLr
New tronsmission investments olso deploy advanced monitoring systems ond other new technologies
designed to ensure o more flexible ond resilient grid. At the some time, all transmission projects support
locol systems in order to maintain the poromount objective of providing relioble electricity service to
customers. A robust tronsmission system is needed to provide the flexibility that will enable the modern
electric system to operote. Although much transmission hos been built to enhonce reliobility and meet
customer needs, continued investment and development will be needed to provide thot flexibility."sl
The Need for a Robust Transmission Grid
The public policy benefits of transmission investment are becoming increasingly clear. There are
numerous advantages of a robust transmission system, which have been recognized by Congress,s2 the
Administration,s3 and the Federal Energy Regulatory Commission (FERC).s4 People are dependent upon
electricity for almost every aspect of their daily lives and people cannot imagine modern life without it!
l.Y r The electrical transmission grid is an integral component of
?s I have repeatedly stressed, this nation should this system and must constantly change and grow to meet
have policies that encourage needed investment increasing demands, new generation resources, and
in transmission projects. The new construction of
transmission lines is often the lowest-cost way to ennanceo rellaolllty regulatlon ano requlremenTs'
improve the delivery of electricity service. By
buitding needed transmission, our electrical FERC continues to articulate public policy reasons for
service can maintain retiabitity at tevets that are additional investment in transmission infrastructure. With
the envy of the world, while simultaneously the issuance of Order No. 1000, the Commission stated
improving consumer access to lower cost power
generation - all while permitting more efflcient that "additional' and potentially significant' investment in
and costeffective renewabte resources to new transmission facilities will be required in the future to
compete on an equal basis with traditional meet reliability needs" and that "it must act promptly to
sources of power." establish the rules and processes necessary to allow public- FERC commissioner Philip Moeller utility transmission providers to ensure planning of and
sr 'Transmission Prolects: At A Glance," Edison Electric lnstitute, December 2016,
http://www.eei.org/issuesandpolicy/transmission/Documenls/Trans_ProjectJxecutivesummary.pdf
52 H.R.6 Energy Policy Act of 2005, Public Law No: 109-58 (08/08/2005), https://www.congress.gov/bill/109th-congress/house-bill/6 sets forth an energy
research and development program to promote stability and reliability in the American interconnected system with tax incentives, loan programs,
additional authority for the Deparlment of Energy, etc.
53 U.S. Department of the lnterior, October 5, 201 1, "Obama Administration Announces Job-Creating Grid Modernization Pilot Projects" from Ken Salazar,
Secretary of the lnterior: "Transmission is a vital component of our nation's energy portfolio, and.,.serve as impo(ant links across our country to increase
our power grid's capacity and reliability...This is the kind of critical infrastructure we should be working together to advance in order to create jobs and
move our nation toward energy independence." Department of Energy, June 13,2011, "Energy Secretary Chu Announces Five Million Smart Meters
lnstalled Nationwide as Part of Grid Modernization Effort, https//energy.gov/articles/energy-secretary-chu-announces-flve-million-smart-meters-installed-
nationwide-partgrid. Energy Secretary Steven Chu: "To compete in the global economy, we need a modern electricity grid....An upgraded electricity gdd
will give consumers choices and promote energy savings, increase energy efficiency, and foster the growth of renewable energy resources."il Testimony of Chairman Jon Wellinghoff, Federal Energy Regulatory Commission, Before the Energy and Environment Subcommittee 0f the Committee
on Energy and Commerce, United States House of Representatives, Oversight Hearing for the Federal Energy Regulatory Commission, March 23,2010,
https//www.ferc.gov/CalendarFiles/20100323141517-Wellinghoff-3-23-10.pdf quotes Chairman Wellinghoff: "A robust electric transmission grid is
essential to achieving the vision of an energy future that I believe most of us share." Federal Energy Regulatory Commissioner Philip Moeller, quoted on
May 19, 201 1: 'As I have repeatedly stressed, this nation should have policies that encourage needed investment in transmission projects. The new
construction of transmission lines is often the lowest-cost way to improve the delivery of electricity service. By building needed transmission, our electrical
service can maintain reliability at levels that are the envy of the world, while simultaneously improving consumer access to lower cost power generation -
all while permitting more efficient and cost-effective renewable resources to compete on an equal basis with traditional sources of power."
httpsJ/www.ferc.gov/EventCalendar/Files/201 105191 15137-E-9-Moeller.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 28 of 128
o
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investment in the right transmission facilities as the industry moves forward the many challenges it
faces."ss FERC is responsible for promoting a strong nationaltransmission infrastructure, and
establishes rules to support electric reliability and lower costs to consumers by reducing transmission
congestion.s6
The U.S. Congress is paying increasing attention to the resilience and security of the grid as well. Last
July, the U.S. House of Representatives passed legislation designed to strengthen the U.S. electric grid,
recognizing that the grid is critical to all Americans and that it is right out in the open, visible to citizens
every day and thus vulnerable to a wide variety of
"A retiabte and resilient electricat grid is critical not only to threats' Every U'S' President since 1990 has
our nationaland economic security, but alsotothe acknowledged that U.S. infrastructure risks are high.
everyday lives of American families." Finally Congress is taking action, creating a bill that
-u s Secretaryof Enersv Rick Perry offers the necessary funding to increase the resiliency
of the grid and to provide a comprehensive, national
plan to protect it.s7 This bill is currently being discussed in the Senate. Regardless of the final outcome,
it is apparent that the energy business and, in particular the grid, is under increasing scrutiny and
evaluation, and that will likely bring changes to electric utilities across the nation.
N^aNor.IA.L H ISTORIC I NvESTU ENT IN ELECTRI c TRANSM I ssloN
As mentioned earlier, the bulk of Avista and the nation's energy delivery systems were constructed in
the period after World War ll and generally into the 1970s and 1980ss8 when economic growth and
expansion fueled the demand for new energy infrastructure.se Nationwide, utility investment generally
slowed during the 1990s. This slowdown was attributed to several factors, particularly the uncertainty
around disaggregation of vertically-integrated utilities and concerns of how new plant investment
might be treated under the then-impending federal utility deregulation. Another driver of reduced
spending was the opportunity to take advantage
of the robust capacity in distribution,
transmission, and generation resources built up
in prior decades. By the late 1990s, however,
the country's utility industry recognized the
need for increased investment to keep pace
with customer growth, to replace or rebuild
aging facilities, and to meet increasing customer
and regulatory expectations for greater
power quality and system reliability.Using a helicopter to rebuild the 60 year old Benewah - Moscow Line
55 United States of America Federal Regulatory Commission 18 CFR Part 35, May 17,2012, i, pages 9 and 10.
so FERC Transmission lnvestment: https://www.ferc.gov/induskies/electric/indus-acUtrans-invest.asp
57 "House Bill to Protect, Strengthen U.S. Electric Grid is lmportant First Step," July 21, 2017, https//www.prnewswire.com/news-releases/house-bill-to-
protectstrengthen-us-electric-grid-is-importantfirststep-300492357.htm1 and H.R.2507 - 21st Century Power Grid Act, 115th Congress,
https://www.congress.gov/bill/1 I 5th-congress/house-bill/2507/text
58 This cycle of utility investment ended as early as the '1960s for some utilities and through the early 1980s for others, including Avista.
ss "Powering a Generation: Power History #3," http:i/americanhistory.si.edu/powering/pasUh2main.htm.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
O
Schedule 2, Page 29 of 128
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For utilities like Avista that waited to invest in their assets throughout much of the 1990s due to
industry uncertainty, the need for capital investment is even greater. The need for utilities to continue
investing in new and upgraded facilities is fully supported by Congress' directive to incentivize
improvement and expansion of our nation's transmission infrastructure, as defined in the Energy Policy
Act of 2005.50 The Act was focused on reliability as well as development of a robust transmission
system. The Act was designed to promote transmission investment through pricing reform, enhance
grid reliability, and reduce congestion and system losses in order to provide cost savings for customers.
It is significant to note that all of the benefits just
mentioned are provided bytransmission, which
remains the smallest portion of an electric
customer's bill. On average, for the customer,
transmission typically comprises 11to 15% of
their bill.51
lnterestingly, the annual cost per kWh for
electricity in the 1950s approached 14 cents
(adjusted for inflation), where it is only about
12.5 cents today. Why? Back in 1960, the
Figure 12. National Residential Cost per kWh average customer used about half as much
Source: Edison Electric tnstitute energy as the average customer does today. This
indicates that the major driver of grid costs is the number of electricity customers, not how much
energy they use. ln other words, the number of customers
connected to the grid determines how many power lines,
transformers, meters, and utility staff are needed to safely
and reliably deliver electricity. Thus, installing solar panels
on your roof reduces load on the system, but it doesn't
reduce the cost of connecting you to the grid. Thus as
more customers reduce consumption with energy
efficiency or other such measures, the cost per kWh is
likely to increase for everyone.s2
A research study sponsored by T&D World Magazine in Avista rebuitding the Benewah-Moscow 230 kV
2017 found that transmission-related projects valued at line acrossthe Palouse
5129.6 billion are in planning or under construction. New
projects totaling Sgg.+ billion are expected to come online during the next five years, including 72
60 The Energy Policy Act of 2005 in full can be found at https://www.energy.gov/sites/prod/files/edg/media/HR6PP%281%29.pdf
61 Matt Pilon, "Federal Regulator Probes Electric Transmission Rates Amid Rising Costs," January 18, 2016,
http://www.hartfordbusiness.com/articlei201601 18/PRINTEDITI0N/301 149893/fed-regulator-probes-electric{ransmission-rates-amid-rising-costs
62'The U.S. Electric Grid's Cost in 2 Charts," Scientific American, April 5, 2017, hftps://blogs.scientificamerican.com/plugged-in/the-u-s-eleckic-grids-cost-
in-2-charts/ Raw dala source: https://www.eia.gov/totalenergy/data/annual/showtext.php?t=ptb081 0 and
https://www.eia.gov/electricity/monthly/epm_table_grapher.php?t=epmt-5_3
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 30 of 1 28
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Average Retail Prices of Electricity: Residential
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1960 1955 7910 7915 1980 1985 1990 1995 2m0 2m5 2010 2015
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major projects with estimated costs of over S1OO miltion each. This study noted that the American
Society of Civil Engineers has rated the entire energy infrastructure sector with a grade of D+, which
means there is a lot of enhancement work needed in the years to come.63 Nationwide and for Avista,
significant investment in transmission is needed for a variety of reasons including:
o lnterconnecting new generation resources and
making allowances for plant retirements (especially
coal plants).
o Attempting to decrease congestion and increase
market efficiency, often in response to NERC
reliability requirements.o Replacing and upgrading aging transmission facilities.
o Supporting public policy goals (specifically
renewables and environmental regulations).
lmproving reliability / reducing the possibility of outages (again, in part driven by NERC
Standards.)
Adding new technologies designed to ensure a more flexible, resilient, modern grid and to meet
increasing customer expectations for service levels.
Meeting increasing costs to build new transmission as raw material costs continue to rise,
especially on large station equipment such as transformers, which are in high demand due to
the large number of transmission projects being built both nationally and globally.
Along with the need to replace aging infrastructure, new NERC regulations regarding reliability are
driving expansion and upgrades. ln fact, the Brattle Group
study found that NERC-related construction will add up to
approximately 7,500 circuit miles of transmission nationwide
over the next few years.6a As an example, Pacific Gas &
Electric hired a consulting firm to evaluate their 800 circuits
and learned that 150 of them, or nearly 2OYo, required NERC-
related mitigation measures.ss
Rebuilding the Benewah -Moscow 230 kV Line
The cost of building this needed transmission varies
significantly from place to place, as many of these costs are
dependent upon issues outside of the utility's control such as
regional, state and local regulations, environmental issues
and concerns, material cost and availability, impacts to neighboring utilities and the grid as a whole.66
63 Kent Knutson, "Drivers and Challenges for Transmission lnvestment," T&D World, May 11,2017, http://www.tdworld.com/transmission/drivers-and-
challenges-transmission-investment
6a "Dynamics and Opportunities in Transmission Development," December 2, 2014,
hftp//www.brattle.com/system/publications/pdfs/000/005/089/original/Dynamics_and_0pportunities_in_Transmission_Development.pdf?1417535596,
taken from chart on page 4.
6s "NERC Mitigation Projects," Burns McDonnell, 2017, http://www.burnsmcd.com/projects/nerc-mitigation-projects
66 James A. Holtkamp and Mark A. Davidson, 'Transmission Siting in the Western United States," 2009,
https://www.hollandhart.com/articles/transmission_siting_white_paper_final.pdf. Also see Appendix F "Siting Transmission Lines" on page 89.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 31 ol 128
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Avista's Transmission System is comprised of 31 lines rated for 230 kV (1- kV = 1,000 volts)and 140 lines
rated at 115 kV. These lines are supported by nearly 38,000 poles and structures6T and span
approximately 2,200 circuit miles.68 Ninety-one percent of this system is single circuit line.5s These lines
Avista Transmission Pole Marerial range in length from less than a mile to over 86 miles long,
and cover wide-ranging geographic territory, from steep
mountainous terrain to desert, farmland, and dense urban
a reas.
Ftr Avista's poles are primarily butt-treated Western Red
2% Cedar.7o Wood poles are often being replaced with steel
Lamlnate
poles as the lines undergo maintenance or replacement. The
initial cost of steel poles can be higher,71 but traditional
o% wood poles have a life-span of approximately 80 years, while
Figure L3. Avista Transmission Pote Types steel poles often remain in use for much longer periods than
wood.72 Other factors considered in replacing wood with
steel are fire resistance and the savings involved in not having to replace hard-to-reach poles upon
failure. Steel poles also tend to strengthen the line, suffer less damage during catastrophic events or
from humans or animals, and require less
general maintenance.
Avista's first transmission line was completed
between Spokane and Burke, ldaho in 1903. At
that time it was the longest high voltage (50 kV) line in the world.73 The Company rapidly expanded its
transmission system beginning about L905, and by 1915 provided wholesale electricity to local
67 Poles are single wood structures; structures may be comprised of two or more poles (such as an "H" frame) used together in place of a single pole due
to design conditions such as high wind issues, requirements for additional strength when the line turns a corner or makes an angle, or anytime there is a
high level of tension on the line.
68 For a single circuit transmission line, the circuit miles equal the line (or geographic) miles; for a double circuit line the circuit miles would be twice the line
miles.
6s Single circuit has three conductors for the three phases of one circuit (i.e. one line) versus double circuit which has six conductors and two circuits (i.e.
two lines). Double circuit is used where greater reliability is needed, to transfer more power over a particular distance, or to utilize one right-of-way.
70 Western Red Cedar is known to be highly durable and has natural insecticidal properties. 'Wood Utility Pole Life Cycle,"
https://enviroliteracy.org/environmentsociety/life-cycle-analysis/wood-utility-poleJife-cycle/
71 For example, a 60 foot wood pole may cost $1 850 versus a 60 foot steel pole at $3200, depending upon the market and other factors. lnterestingly, the
cost of wood versus steel is a controversial subject. For more information see: "Pole Wars: Wood or Steel Argumenl Continues,"
http//www.elp.com/articles/prinUvolume-78/issue-1 1/departments/technology/pole-wars-wood-or-steeFthe-argument-continues.html and "Steel Utility
Poles Versus Wood," httpJ/www.steeltimesinl.com/contentimages/features/environment.pdf or Electricity Today's "Utility Pole Showdown: Wood vs Steel,"
https://www.electricity{oday.com/overhead{d/the-utility-pole-showdown-wood-vs-steel
72 Avista's experience (and our climate) indicates that our wood poles last approximately 50 to 60 years, depending upon species and environment, and
that steel poles can last up to 150 years. ln the industry as a whole, wood poles are expected to last about 30 years; steel can last 80 years or more. For
more information on pole lifespan, please see: https://www.galvanizeit.org/about-aga/news/article/take-a-second-look-at-steel-hdg-distribution-poles
73 Steve Blewett, 'A History of The Washington Water Power Company, 1889-1989: Building on a Century of Service," The Washington Water Power
Company, 1989
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2, Page 32 oI 128
Unknown
L%
o
O
o
Strudures 18,246 26,ffi M,U6
26.ffi 9,305 35,905Poles
Air Switches z 188 190
Condudor (Miles)585 L,537 2,223
@,202 83,180lnsulators22,978
AssetCategory 230 kv 115 kV Total
Larch
l3Yo
Steel
72%
Cedar
72Yo
o distribution systems scattered as far away as the Cascade Mountains and through most of North
Central ldaho. Avista established the first utility interconnection in the Pacific Northwest when it built
an interconnection with Pacific Power & Light in 1915.74
Avista faces problems similar to most
utilities nationwide: aging infrastructure
and increasing frequency of extreme
weather events. Over half of Avista's
transmission lines are over 50 years old
and 20% are over 70 years old. Avista's
transmission poles face the same
situation. Sixty-nine percent of the
Company's poles are 50 years old or
older (which is over 26,000 poles). Aging
poles and cross arm failures have caused
almost 40% of Avista's unplanned
transmission outages since 2002, with
Avista's Transmission Miles of Circuit
conductor adding another 22% of the outages. Although segments of these lines have been rebuilt and
structures and equipment have been replaced, the fact remains that our transmission system is coping
with the issues and problems discussed earlier. Many of our assets are at or near the end of their
useful life, making them more vulnerable to extreme weather events and increasing the risk of failure.
Often outages caused by disruptions in
the high-voltage transmission system
are not noticed by customers, because
automatic controls and system
operators can limit their impact on the
distribution system. The transmission
system does occasionally experience
problems that result in loss of service to
customers. For example, overloads in
one part of the system can propagate
to other parts of the system, like ripples
in a pond, overloading substations and
Figure 15. Avista Transmission Line Age leading to loss of electricity to the
distribution system. Power service can
also be lost if there is an outage on a radially-fed (rather than a redundant)transmission line that
serves a remote substation, as mentioned earlier.
74'Washington Water Power/Avista Milestones 1889-2005,'
http://avanet.avistacorp.com/news/company/eviewi2005/documentsMWP_Avista_Milestones.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 33 of 1 28
60 W Circuit
115 kV Underground Crcuit
115 kVDouble Circuit
23O kV Double Circuit
115-29) kV Double Grcuit
230 kV SinSle Ciroit
115 kvsinSh cirait
40 6m 1m0 1400 1600
Miles ol Ciriltt
Figure L4. Avista Transmission Miles and Type of Circuit
2m0
o
I
Avista Transmission Line Age Profile
35
30
25
Iroo
c-z 10
5
0
-".dt ""€"
-rus' -"*s- -"*.'"."*t*t" -r"-* yC
o
1200
Iransmissron line (three arms above) with
Another transmission reliability concern
related to distribution is the use of
"underbuild," a common condition across
Avista's service territory. ln this situation,
the utility utilizes a single right-of-way to
run two lines. One is a transmission line
(which may have more than one circuit like
the two transmission circuits on the pole
shown in the photograph on the left)with a
distribution underbuild below (single arm distribution line attached to the pole at a
c/osest to the ground) safe distance below the transmission lines.
lf the pole is damaged by fire, storm, car-hit-pole, etc., both distribution feeders
and transmission facilities can be taken out of service.
Electricity outages disproportionately stem from disruptions on the distribution
system,Ts both in terms of the duration and frequency of outages. However,
outages on the transmission system while infrequent can result in more widespread major power
outages that affect large numbers of customers with significant economic consequences.
AvIsTI,s ELEcTRIG SYSTEM RELIABILITY
Each year we track and report on how
well our system has performed as
measured by the number of service
interruptions and the duration of the
outages experienced by our
customers. The Company's annual
reliability performance for the years
2004 throu gh 2OL7 is shown in Figure
16.
Although our overall reliability trend
is generally stable, the year-to-year
fluctuation in performance is a
common feature of utility electric Figure L6. The Average Number & Duration of Avista Electric System Outages
systems. Outage causes can be
quite variable each year and many are largely beyond the control of the utility, such as wind and ice
7s Over 90 percent of electric power interruptions occur on the distribution system. Source: U.S. Department of Energy, "Ensuring Eleckicity System
Reliability, Security, and Resilience."
https://energy.gov/sites/prod/files/2017l01ll34lChaplero/o2}lVo/o2}Ensuring%20Electricity%20System%20Reliability%2C%20Security%2C%20and%20Res
ilience.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 34 of 128
T ra n sm ission -o n ly I i n e
of two circuits with three
phases/conductors
each on the boftom and
a shield wire on top
(no underbuild)
o
oAvista Electric System Reliability
2004 - Praent
2004 2m5 2m5 ?@7 2@8 2m9 2010 2011 2012 2073 2014 2015 2076 2017
EAwEge tength of Artages (minutes)
-AwEge
Number of Outa8es Per Customer
250
.E 2m
.t rso
o
o5rm@c
Isu
0
2.5
E
l-I
3
1.5 U
o
o1L
!
Ez0.5 o
go
0
o
o storms, fires, heavy snowfall, animals, vehicle accidents, etc.75 ln addition to these primary statistics,
we report on several other utility-wide measures of reliability, track the geographic areas of greatest
reliability concern on our electric system, and develop plans to improve service performance in those
areas. Avista is continually looking at ways to improve reliability even though we are providing
adequate service according to industry standards.
Anlmal
Error
Fiqure 77. Transmission Outage Causes 2002 - Present Figure 18. Unplanned Outages & Line Age
Avrsra. Hrstonrc TRANsMrssroN INvEsmraENTs
Beginning in 2OO4, the Company began rebuilding its aging 230 kV
transmission infrastructure. Eighteen transmission lines had been built
priorto 1930, another 57 lines were constructed between 1930 and
1960. Not only were these lines feeling their age, but there were
congestion issues on Avista's portion of the interconnected system
that could affect our neighboring utilities during certain operating
conditions. The Company developed a multi-phase plan to address the
end-of-life transmission assets in the system and to ensure that the
interconnected grid
continued to be stable and
reliable into the future. This
plan, which had a significant
impact on Avista's historic
expend itures, is described
in the next few pages.
76 The measuring protocol for SAIDI and SAIFI excludes outages caused by very large outage events such as the windstorm of November 2015. These
extreme events are refened to a "major evenl days." Even with these major events excluded, however, we can still experience substantial variability
caused by storms or other circumstances that do not qualify as major events.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 35 of 1 28
Avista Transmission Outages
Top Tq - 2002 lo h 6ent
lolo- NezP€re
Erou - Cabinet
Addy- ktde Fdls
BereMh - Pine Geek 230
GEngeville - Ner PerceS1
Devils 6ap - Statford
laype - Orofino
Burte-EneCr@k13
-
Labh-M@w-
addy-DditsGap
-
20 40 60 80 lm 120 140 160
Age oJ Llna ln YeR
I Age of Line in YeaR r Number of OutaSes
1S 2m
o
o
a_
3%
o%
Weather
3A%
Equipment
L2%
Tree
6%
Public
Unknown
t$v"
Pole Fire
roo/.Outate
7Yo
I
West of Hatwai Project
- The West of Hatwai
path consists of ten
related transmission
lines, generally
located west and
south of Spokane. lt is
a heavily used path
that carries power
flowing from Montana
to the West Coast and
into California. This
path is primarily
owned by Bonneville
Power Administration
(BPA), but Avista's
transmission system is
an integral part of this
segment of the Figure 19. west of Hatwai Path (shown with red orrow) 77
interconnected grid.
Beginning in the mid-L990s, this path grew increasingly constrained. lnitially BPA was able to manage
operation of the path through available operating practices of the time, including short-term remedial
actions, and customer needs were met while maintaining the reliability of the path. However, in 2001,
several major industrial loads shut down in the Pacific Northwest. Two of
BPA's large direct service industry (DSl) customers, aluminum smelters
located east of the transmission path, closed their facilities. This led to a
situation where electricity generated on the east side of the path was no
longer serving load located on the east side of the path. That energy was
then made available to users west of the path, thus increasing the energy
available to flow west on the path. Transmission congestion on the path
grew as more energy was available to users West of Hatwai. lt became
very difficult to reliably balance this change in path flow, and at times led
to significant curtailments to users.
o
o
BPA's Bell-Coulee 500 kV line
built to help relieve
congestion between Grand
Coulee Dam and Spokane to
the West Coast. (Avista's 230
line visible on the left.)
The problem was particularly acute in the early spring and summer
months due to the large amount of power generated by dams east of the
path during spring runoff conditions. The amount of power available to
move through this area during these months could at times exceed the
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 36 of 128
77 Map courtesy of Bonneville Power Administration https://transmission.bpa.gov/Business/Operations/Paths/Flowg aleo/o2lMap]015-06-23.pdf o
Northwest Transmission
Lines and FlowgatesIIINGTO
1..
of
ol
ut^riCALIFORNEVAD.{l
IIONT..T}{A
ID,TIIO
)
(_
OREGON.,
o
o
o
carrying capacity of the existing
transmission lines. By the summer of
2001, all available operating practices
to mitigate the capacity limitations of
the West of Hatwaitransmission path
became insufficient as a long-term
solution. lt was apparent that there
was no way to ensure the flow of
power while maintaining system
reliability.
BPA planned to increase capacity of
the path by constructing the Bell-
Coulee 500 kV line and making a few
other system im provements.
However, in order to uprate the path,
upgrades were also required on
Avista's interconnected 230 kV
system. All of these upgrades were
reliability based, meaning that in
order to increase the path rating,
Avista had to ensure capacity under a
variety of transmission outage scenarios including lines, substation equipment, and communication
failures.
The West of Hatwai Agreement between Avista and BPA was developed in an effort to strengthen the
region's transmission system and to deal with this reliability situation. Between 2003 and 2007, Avista
added over 100 circuit miles of new 230 kV transmission line. Over 50 miles of line were upgraded with
additional capacity. Two new substations were completed and three existing substations were
reconstructed. The project incl uded
(1) 2003: Hatwai-Lolo 230 kV transmission line upgrade to 800
megawatts (MW).
(2) 2003: Hatwai-North Lewiston
230 kV transmission line
upgrade to 800 MW.
Updated the relay and
remedial action schemes at
this substation.
(3) 2004: Beacon-Rathdrum 230
kV Line: Reconstructed the 50 Beacon Substation Dry Creek Capacitor Bank
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page37 ol 128
Avista's 230 kV Facilities
2002 Bdseline.t Substation
-
J1.111511issio1 Line
B.[ (BP.t)
llorcor !J0
I(.Isistotr
Cabiutr Goigt
Iioroa
R.ildruet
BaDrsaL
SLmrc
Il'dlidG ' Bcecol
Eltr.i(BP.{)
Llo
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t
tv
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rL-
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)'
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r:'
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-'-:,
year old backbone line between Coeur d'Alene and Spokane, increasing transfer capacity from
300 MW to 1500 MW (eventually to 2000 MW) using new high temperature conductor and
adding an additional 25 miles of new 230 kV circuit.
@l 2OO : Rathdrum 230 kV Substation: Upgraded to become Avista's first fully redundant 230 kV
substation, relieving a bottleneck between
North ldaho and Eastern Washington and
significantly increasing reliability in the area
by eliminating loss of load when the old main
bus would fail. The old bus was replaced with
a double bus double circuit breaker
configuration,T8 which is fully redundant.
Previously bus failures could cause very low
voltage in the area leading to significant loss
of customer load.Rathdrum Substation
o
o
(5) 2004-2005: Lewiston-Clarkston Transmission and New Dry Creek 230 kV Substation: Created a
35 mile 230 kV transmission "ting" around
Lewiston and Clarkston, relieving congestion
during heavy load periods. This ring required
the new Dry Creek 230 kV Substation that
included a 23O/tL5 kV autotransformer that
improved load service and reliability in the
Lewiston/Clarkston area. The station also
included a 230 kV capacitor bank required
for voltage support under certain operating
Dry Creek Substation ScenariOS and COntingenCieS.
(6) 2005: New Boulder230 kVSubstation: lnstalled between Beacon and Rathdrum substationsfor
increased 230 kV reliability and operational flexibility
Also required to increase capacity for the 115 kV
system serving the greater Spokane Valley area, as
well as transformer capacity support for both the
Beacon and Rathdrum Substations. Built fully
redundant on the 230 kV side as double breaker
double bus configuration.
o
(7) 2004-2006: Benewah 230 kV Substation: Rebuilt the
230 kV yard to fully redundant double breaker double
bus configuration in order to reliably integrate the
Pine Creek, Boulder, Moscow, and (new)Shawnee 230
lines. The station also included the installation of a 230
kV Constructing Boulder Substation
kV capacitor bank required for voltage
78 A double bus double breaker bus configuration consisls of two main buses, each normally energized and electrically connected to each other in such a
way that if one is removed from service by a fault or for maintenance, the other breaker continues to function, so there is no intenuption to service.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 38 of '128
o
O
Building Benewah Sub
Coeur d'Alene, lD
Spokane,WA
I
l.
fbet
E.6.l
Avisto 230 kV Transmisslon System
-Now
or Upgraded Linea Now or Rcconstruct€d Substation
Moscortt, lD
Puilman,WA
ID
Clarkston,WA
\
support under certain operating scenarios and contingencies.
Later in 2007-2008, the 230/LL5 kV transformer and the L15 kV
breakers and associated relaying were replaced and upgraded.
(8) 2006: Palouse Reinforcement
with new Benewah-Shawnee
230 kV Line: Added 60 miles of
230 kV line designed to carry
1,000 megawatts and adding
redundancy to a main path
Constructing the Palouse 230 kV line
between Avista's North (Spokane)
and South (Lewiston/Moscow/Pullman) urban areas.
(9) 2006-2009: Lolo 230 kV Substation: Rebuilt the 230 kV yard to
fully redundant double breaker double bus configuration to
complete the Lewiston-Clarkston area 230 kV upgrades. This
upgrade integrated the 230 kV lines connecting to Dry Creek
and Hatwai substations as well as enhanced Avista's interconnection to ldaho Power, improving
the station reliability and operational flexibility.
The Avista portion of this project cost
approximately Sf gS million over four years, which
included over 100 miles of new 230 kV circuit, 50
miles of upgraded circuit, two new substations,
three upgraded substations, upgraded equipment
at five of its remaining seven 230 kV substations,
750 MVA of additional230lLLS kV transformation,
400 MVAR of reactive supply,Ts over 200 miles of
fiber optic communications cable, and several fully
red undant com munications systems. This project
was implemented to mitigate exceedances of
equipment ratings, minimize negative impacts on
neighboring utilities, reduce the constraints Avista's
system placed on BPA's system, reduce congestion
and constraints on other interconnected paths, and
allow maximum use of the bulk power marketplace.
Resources can now freely move from Montana to
the West, increasing resiliency for customers by
adding redundancy to key paths and improving reliability to the Western grid in general.
7s Reactive power is a by-product of the AC power system, measured in Volt Ampere Reactive (MVAR). lt helps maintain voltage and is also critical to
magnetic-based equipment like large motors. For descriptions of this equipment or definitions of these terms, please see Appendix J (page 97)
"Transmission System Equipment" or Appendix Z (page 103) "Transmission Glossary of Terms" at the end of this report.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 39 of 128
U
I
',1
t
I
o
-&T
\
I
ln August 2003 North America experienced the worst blackout in American history; 50 million people
lost power (over 61,800 megawatts) for up to two days throughout the Northeast and Midwest and
into Ontario, Canada. Eleven people died. lnvestigations revealed practices that varied from utility to
utility, human decisions, poor communication, vegetation management issues, and equipment
inadequacies all contributed to this outage. The situation prompted Congress to take a hard look at
creating consistent standards with penalties for non-compliance. Prior to this, the industry operated
under a set of voluntary planning and operating criteria. ln 2005 Congress passed The Energy Policy
Act, which granted the Federal Energy Regulatory Commission significant new responsibility and
authority in overseeing the nation's energy grid. This led to an increasing number of mandatory
Reliability Standards that directly impact Avista's operations and associated transmission related
expenditures.
Currently electric utilities are highly regulated at the federal and regional levels. The Federal Energy
Regulatory Commission (FERC) oversees all electricity transmission and wholesale marketing in the
United States. FERC has regulatory authority over
both the reliability of Avista's system and the
commercial aspects of Avista's wholesale uses of its
transmission. FERC has delegated reliability
standard development and enforcement to the
North American Electric Reliability Corporation
(NERC). NERC delegates reliability standard
compliance enforcement to regional entities, in
Avista's case, the Western Electricity Coordinating
Council (WECC) and Peak Reliability. Peak Reliability
(Peak), is a Reliability Coordinator, meaning it has
the highest level of operational authority within its
StondordEnlorcement I Stondord Enlorcenent
o
o
-
Operutionol
Requhements
Figure 20. The Basic Levels of Regulation Affecting the footprint (the Western lnterconnection), monitoring
Avista Transmission svstem and ensuring the reliable operation of the western
lnterconnected electric system. Avista is subject to all operating rules and practices established by Peak
Reliability as well as those developed by NERC and FERC. All of these organizations add increasingly
complex layers of standards and regulations that are mandatory and enforceable.so
Regulation of the utility industry is considered critical, as these companies provide essential services
necessary to the well-being of society. ln addition to being a critical component in providing essential
services to nearly every person in America, utility infrastructure is an integral part of our communities.
Transmission and distribution lines and associated equipment exist throughout our surroundings,
80 For detailed information about the layers of regulation affecting Avista, please see Appendix B "Utility Regulation" beginning on page 68.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 40 of 128
Federal Energy
Regulatory Commission
(FERC)
North American Electric
Reliability Corporation
(NERc)
Western Elect.icity
Coordinating Council
(wEcc)
Avista utilities Peak Reliability
(Reliability Coordinator)
o
Ovenutew oF Etecrnrc TnertsrutsstoN REGULATTaN
o
o
creating potential safety risks and hazards to humans and the environment that require oversight.
Utilities are also natural monopolies, thus regulation helps protect the public interest by ensuring that
prices are fair and just, service is adequate, health,
environmental, and safety issues are considered, and that
companies are responsive to consumer needs.sl The complexity
of regulation related to utilities continues to evolve as the
business itself continues to evolve, with new technologies,
increasing threats (specifically related to cyber and physical
security) and ever-changing consumer expectations.
These mandatory standards heavily inform Avista's decision-
making processes and behaviors. They also help in ensuring
that the Company's system is reliable, resilient, and secure. However, decisions that were once based
on qualitative risk assessment under a voluntary framework are now made based on deterministic
criteria within standards required by law, with non-compliance resulting in substantialfinancial
penalties. This has resulted in changes which influence the Company's capital spending decisions and
operating practices to a significant degree.
ln addition to the regulating bodies mentioned above, the electric power industry must comply with
literally hundreds of national, state and local environmental regulations (including those under the
Clean Air and Clean Water Acts). Utilities are governed by laws related to crossing federal lands or
affecting unique interests, such as culturally significant sites or endangered species. The National
Electrical Safety Code defines the rules for installation of electrical gear, electrical protection, methods
and materials and even communications for all electric utilities. The Securities and Exchange
Commission and the Commodities Futures Trading Commission enforce regulations related to financial
and accounting requirements; anti-trust regulations come from the Department of Justice and the
FederalTrade Commission. The Occupational Safety and Health Administration (OSHA) regulates safety
standards. State and local authorities and regulators focus on facility
siting and zoning, safety regulations, taxes and more; state regulatory
commissions determine revenue requirements, allocate costs, set
service quality standards and oversee the financial responsibilities of
the utility. All of these regulators and regulations have developed over
time to ensure that people and equipment stay safe and that the lights
stay on. At the same time, required regulations and standards
dramatically infl uence Avista's investment decisions.
For details about the history of regulation and the specific entities
regulating Avista and their roles, please see Appendix B, beginning on
page 58.
at "Electricity Regulation in the US: A Guide," March 2011, The RegulatoryAssistance Project. Electric utilities are natural monopolies, thus regulation
helps protect the public interesl in a variety of ways.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 41 ol 128
o
rl
rL
i
I
r !t
o
Over the next five years Avista expects to invest an average of about SZS million annually for its electric
transmission system capital expenditures. The expected investment by driver for this period is shown
S4s
S40
S3s
S30
S2s
S2o
51s
510
$s
So
Electric Transmission Infrastructure Investments
by Year & Investment Driver
!
E
,.il lfiil
Mondotqy & custmer Requested Pe$ommce & Asset c@ditbn Foiled Pl@t &
Complion@ cqpdcity oryrotio$'
12018 r 2019 a2AO A2027 a2A2
in Figure 21
Avista must continuously invest in its
transmission infrastructure in order to
maintain safe and reliable service for our
customers and to meet mandatory
federal reliability standards. These
investments replace equipment that has
reached the end of its useful life, meet
customer req uests for intercon nection
or service enhancement, repair or
Fisure 2L. Ptanned
"r*;:;::irr;{,_r;l;;f,enditures
bylnvestmenr replace infrastructure that fails, meet
our regulatory compliance
requirements, ensure the availability of critical equipment when needed, and enhance the capacity or
performance of the system to meet Company standards or to serve additional load.
Expected capital expenditures by
Driver category are shown below
in Table 1. A basic description of
the programs in each category
follows. Details about specific
capital projects and expenditures
are available in Appendix A
beginning on page 58.
Table 1. Planned Capital Expenditures by Investment Driver
82 Note that the Failed Plant & Operations budget is split between Distribution & Transmission - this chart reflects 18.71% of the total budget, as that has
been the average percent used by Transmission for storm expenditures over the past tive years.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 42 ol '128
o
)
Autsre C un ngNTLy PLA NN ED Tna rusrutsg t oN lttt vesnw gNrs
20 I 4.2022
Mondotory & Complionce ses,rrs,oool se4,sgs,oool s3z35s,ooo s26,e3O,OOOl s22,660,OOO
Customer Requested s1,2sO,OOOl sol so sol so
Performonce & Capocity s4,2so,oool s3,8oo,oool s3,sso,ooo s23,sso,oool s2s,7oo,ooo
s30,343,4201 s30,343,420Asset Condition szt,zoa,+zol izt,ut,+zol 522,u3,420
s613,3141 s81,7431 ss92,882 Ssse,zzol Sss&720Foiled Plont & Operotions
Total 57!,496,734 567,170,763 564,351,302 581,422,14a 579,302,140
lnvestment Driver 2018 20L9 2020 202L 2022
o
.,]
o
o
AvIsra. Tn^e.NsrrrlssloN Qaplag Pnoene,rrrs BY INVESTMENT DnrvEn
As a way to create more clarity around the particular needs being addressed by Avista's transmission
spending, as well as simplifying the organization and understanding of our overall electric spending,
the Company has organized the infrastructure investments described in this report by the classification
of need or investment driver. The need for investments associated with each investment driver is
briefly defined below.
For Avista, expenditures for our transmission system are primarily driven by asset condition (i.e. aging
infrastructure) and required compliance; at times these two elements go hand-in-hand, as the West of
Hatwai project depicts.
Customer Requested
These projects are triggered by
customer requests for new service
con ne ctio n s, li ne exte nsion s,
tra n sm issi o n i nte rco n necti on s,
tronsmission capacity, or system
reinforcements to serve customers. ln some cases, the
Company must construct a distribution substation with an
associated transmission line extension in order to meet the
requested new load requirements of an industrial or large
commercial customer. Other situations may involve a
requested transmission interconnection with a neighboring
utility or a customer-owned generation project. ln the current
five year budget period, this category includes an interconnection required to integrate Avista's 20
megawatt solar project being built in Lind, Washington. This project is owned by an independent solar
developer who requested interconnection.
Mandatory & Compliance
Left: Avista's
Community Solar
Prolect
Below: New
Transmission &
Substation Built in
Response to the
Palouse Wind
Prqject
The 50 year old Beacon-Rathdrum line
Exhibit No. 8
Case No. AVU-E-I9-04
H. Rosentrater, Avista
Schedule 2, Page 43 of 128
The investments in transmission infrastructure made under this
category ore investments driven typicolly by compliance with lows,
rules, ond controct requirements thot ore externol to the Compony
and typically identified by planning studies and operational issues
measured against NERC Reliability Standards. Compliance with
these standards became mandatory underfederal law in 2007,
and failure to comply may result in monetary penalties of up to
St million per day per infraction. ln addition, imbedded within wx relylt 1s part of the west of
every transmission construction project are environmental Hatwai Pro'1ect
compliance costs. These costs vary by project and can cover an array of issues; each project includeso
numerous requirements for natural and cultural resource protection that didn't exist in the past and
that add additional expenses.
NERC standards address transmission planning, operation, and equipment maintenance, requiring
utilities to plan and operate their systems to System Operating Limit (SOL) exceedances and reliability
risks in real-time. Specifically, the transmission system must be operated so that the next contingency
will not result in operating limit exceedances or cascading outages. This requires planning each outage
so that the transmission system can absorb the next contingency without any SOL exceedances. Stated
differently, the loss of any single facility must not cause any other
facility in service to exceed its system operating limit (voltage or
capacity ratings) or cause the interconnected transmission grid to
operate outside specified reliability limits (voltage and stability
limits). This includes circumstances where transmission facilities
suffer an outage event, or are purposefully removed from service
for maintenance or construction work. The System Operator must
determine in advance whether any single outage will result in a
Installing air switches to help protecr violation of a system operating limit, and mitigate for thatequipment and isolate faults occurrence prior to such a contingency occurring. This means the
system must be designed and built to remain in a reliable state or System Operators must be able to
take proactive action to mitigate the expected impacts of a potential contingency. As a result, Avista
must ensure that its system can be operated reliably during a variety of seasonal and other outage
scenarios. Often projects are developed to provide this system flexibility as required by national
standards.
Other examples in this category include our contractual obligation to pay LL% of all costs related to
Avista's shared ownership of the Colstrip transmission system, as well as general compliance costs for
environmental protection and mitigation, leases on tribal lands, contractual obligations, and safety
sta ndards.
Performance & Capacity
Transmission investments driven by Performance and Capacity arc o ronge of investments thot oddress
the copobility of assets to meet defined performonce stondords, typically developed by the Compony, or
to mointoin or enhonce the performonce level of ossets bosed on
need or finonciol onalysis. When the load-carrying capacity of
electric facilities is exceeded for any extended period of time, it
can stress and damage equipment and lead to equipment failures
that can result in customer outages. ln the case of substation and
transmission facilities, the Company must plan for sufficient
capacity in the system to accommodate a planned or forced
outage. For example, to take a substation out of service for
necessary maintenance, the Company must plan for sufficient capacity in neighboring substations and
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 44 ot 128
o
o
o
o
o
connecting lines so the outage does not disrupt service to customers. lnvestments like Supervisory
Control and Data Acquisition (SCADA) systems enable the System Operator to effectively monitor and
controlthe system to ensure proper system performance and operation.
Asset Condition
lnvestments in transmission infrastructure related to Asset Condition are fo reploce ossefs bosed on
estoblished osset monogement principles ond strotegies adopted by the Company, which are designed
to optimize the overall lifecycle volue of the investment for our customers. This category includes
rebuilds related to aging or end-of-life assets and upgrades related to design, safety, or construction
standards' lt also includes specific Avista Transmission outages Related to Equipment
technology upgrades related to 2002'Present
interconnected system reliability. The
Company closely monitors outages and
replaces equipment that is either
impacting customer service or is likely
to do so. Some equipment is so critical
that it cannot be allowed to fail. When
this equipment reaches an age when it
Relay
Connector
CutouVFuse
Regulator
Breaker
capacitor
Transformer
lnsulator
Switch/Disconnect
is close to or at the end of its useful life, conductor
the Company preventively replaces it to Pole/crossarm
maintain reliability and acceptable
levels of service.
20 /m 60 E0 lm
Numberol Outoges
120
Failed Plant & Operations Figure 22. Transmission Equipment Related Outages
Transmission investments in this category are primarily the result of storm domoge to the Company's
transmission system ond the funding needed to support
ongoing capitol, operotions, and mointenonce. Causes of
damage to our system include major wind events,
lightning, fire, snow and ice, downed trees/vegetation,
wildfires, human or animal caused damage, and equipment
failure. Routine repairs to the system often require the
installation of poles, transformers, crossarms, or overhead
conductor. Other failures include the
unanticipated loss of assets due to a range of
factors including age and condition. Planned
spending for this category is shared between
Distribution, Substations, and Transmission.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 45 of 128
o
0
r-
Avrsta TneNsna rssr oN O pgn^erroNs & Me.r TTENANcE I NvEsrM ENTs
Over the next five years Avista expects to invest approximately 52 million annually in maintaining its
electric transmission system through five primary programs shown in the pie chart in Figure 23. The
expected investment for this period by investment driver
is shown in Figure 24.
Avista must continuously invest in its transmission
infrastructure to maintain safe and reliable service.
Properly planned and executed maintenance helps ensure
that our assets will serve customers for the maximum
time period and at a high level of effectiveness, reducing
outages, and increasing reliability. Aligned with
these goals, the Company has five primary
Transmission maintenance programs, each of which
is described below
Figure 24. Yearly Average Expected Transmission O&.M
Expenditures 20L8 - 2022
Foundation Work
Power pole foundations are an integral part of the structure. They can comprise up to 30% of the cost
of installation.83 The value of foundations is critical in providing stability for the entire transmission
line. Maintenance is of high importance to ensure that these bases remain solid and effective. Avista
has two 230 kV lines that have unique steel structures where the interface between the steel sleeve in
the foundation and the above-ground structure requires re-grouting after approximately 30 years in
order to avoid destructive corrosion. The Company plans to invest 5500,000 over the next five years to
grouting one of these lines, the Cabinet - Rathdrum 230 kV Line.
83 Freeman Thompson et al, "lntegration of Optimum, High Voltage Transmission Line Foundations," 2009,
http://cruxsub.com/core/files/cruxsub/papers/c6988e90fb75df65fa9a4603809f6286.pdf, page 3.
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2, Page 46 of 128
Work
4%
Figure 2i. Program Percentage of Transmission O&M
Expenditures 20L8 - 2022
o
o
L3%
VeBetation
ManaBement
65%
Aerial Patrols
5%
Electric Transmission Planned 0&M Expenditures
Average per Year 2018-2022
$1,4r)0,m
1r,200,m
lr,m0,0m
$m,m0
$m,m0
$4m,m0
f2m,(xl0
$0
Vegetation Mgmt. Fire Retardant Ground lnspedions Aerial Patrols Foundation Work
s1,200,000
$80,ooo
-
$250,000 92$,000rI $111,000
J
o
Ground
lnspections
12%
Fire
o
o
Steps in creating a steel transmission pole foundation
Aerial lnspections
The Avista transmission system covers a large geographical area and includes varied and sometimes
inaccessible terrain for traditional vehicles. ln order to thoroughly inspect the transmission system,
aerial patrols are utilized to provide a thorough and efficient above-ground inspection. These
inspections identify significant problems that require attention,
such as lightning damage, cracked or sagging crossarms, fire
damage, bird nests, hazard trees/vegetation, as well as improper
uses of the transmission right-of-way such as dwellings, grain bins,
and other types of clearance problems. Winter conditions often
create overloading on the lines and structures as a result of snow or
ice accumulation or high winds, potentially
resulting in component failures. Avista
Broken crossarm conducts aerial inspections on the lines in
spring and early summer in time to find and remedy these types of issues as
quickly as possible after they occur and before the
summer peak season begins or the equipment goes
through another winter.
Patrols are performed bytrained and qualified personnel
from the Transmission Design Department and typically
include local experts such as linemen or area engineers for
added perspective. ln the event that aerial patrols cannot
cover a specific structure or area, or if they are unable to
visually inspect to the level desired due to tree growth,
fog, wind, construction or other obstacles, a request is made to area managers to have ground crews
provide additional inspection. ldentified issues are assigned priorities based on safety, risk, criticality to
customer service and the integrity of the system, and are closely monitored to ensure that even low
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 47 of 128
Above: Aerial
inspection spots a
lightning strike next
to a pole
Left: A raptor nest on
a crossarm
o
\
, :.
prioritysa conditions are tracked and remedied. Area managers are notified of the problems found in
their area so they can follow up on mitigation of any identified issue.
One of the tools used in Avista's aerial inspections is LIDAR (Light
Detection and Ranging), which consists of a laser, a scanner, and
a specialized GPS receiver. This device emits thousands of
infrared pulses every second, generating precise, three-
dimensional information about the Earth and its surface
cha racteristics. lt accu rately measu res structu res, cond uctors,
vegetation, and various features ofthe ground surface. The data
LiDAR provides can be rapidly analyzed to determine where
there may be threats to line reliability. lt is also a valuable tool
when building new lines or rebuilding existing lines, as it
provides a very accurate picture of the physical aspects
of the area in which the line is or will be located. This
makes the design work highly efficient.
o
Avista fully meets NERC Reliability Standard FAC-003-2,85
which requires that overhead transmission lines be
inspected at least once a year, with no more than 18
months between inspections. Actual aerial patrol
expenditures average approximately Sttt,000 per year,
with 5103,000 set aside over the next five years for this
important and NERC required function.
L|DAR images indicating
vegeta tion height above
the ground.o
Transmission Aerial Inspections
s160,@0
s14o,mo
Suo,mo
s100,60
S8o,o@
560,000
s40,000
s20,000
So
2012 2073 2014 2015 20L6 20t7 2018 2019 2020 2021 2022
Helicopter flies the Pine Creek -
Eurke Thompson line
Figure 25. Avista Aerial Inspection O&M Actuals &. Budgets
8a Low Priority in this case meaning issues that will not cause any immediate concem, such as a broken bell on an insulator string or a slight lean on the
pole.
8s NERC Transmission Vegetation Management Standard FAC-003-2,
http://www.nerc.com/pa/Stand/Proleclo/o20200707o/o20Transmission%20Vegetation%20ManagemenUFAC-003-2-White-Paper-2009Sept9.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 48 oI 128
o
Actual Budget
it
Ll
r1r1r1
o Ground lnspections
lndustry studies have indicated that a robust pole inspection and
remediation program can add significantly to utility pole service life, up
to 30%. Assuming an average wood pole will last 50 years, it is
estimated that inspecting and remediating issues when found can add
up to an additional 15 years of service life, giving poles closer to 65
years of service.s6 Avista has a highly effective transmission Wood Pole
Management inspection program in place to optimize the life, cost,
reliability and serviceability of Company poles.
Today, approximately 87% of Avista's
o
existing tranSmission strugtures are wOOd Wood Pole Inspection
(83% of these are cedar).87 Avista's
Transmission Ground lnspections Program tests for decay (the most
common cause of wood pole failure is internal and external decay at or
near the ground line), as well as other types of damage
caused by insects, birds and animals, lightning, fire,
mechanical damage, equipment failure such as broken
guy wires, grounding or soil issues which can cause
poles to lean, or unauthorized attachments. The
inspection helps determine which poles must be
reinforced or replaced as well as identifying any other
work that needs to be done.
Ground
inspection finds
lightning-
damaged pole
Ground inspection notes
"leaners" on the Devils Gap -
Line 115 kV Line
ln the "field" wood pole inspection program (versus the aerial inspection program),
inspectors physically inspect the poles on a 15 year cycle, targeting 2,400 wood
transmission poles each year.88 The transmission lines are prioritized by the length of
time since the area was last surveyed and the associated poles were examined.
Experience indicates that approximately t5% of the inspected poles will need
replacement or reinforcement. This is in great part due to the age of Avista's poles;
approximately 45% of the Company's transmission poles and structures are over 50
years old.8s
86 The 50 year lifespan is based on industry averages. Avista typically experiences longer lifespans on poles due to the dry climate of the service area. For
more information see Jeffrey J. Morrell, Department of Wood Science and Engineering, Oregon State University, "Estimated Service Life of Wood Poles,'
2016, http//woodpoles.org/portals/2/documents/TB-ServiceLife.pdf and http://www.steeltimesint.com/contentimages/features/environment.pdf
87 The lifetime costs of a power pole do not.just include the purchase price of the pole, but must take into account the cost of the labor to install the pole
and attach the hardware and wires, the expenses related to the truck used to deliver the pole, employee cost for set up, installing and maintaining the
pole. lf a pole decays quickly or fails, these additional costs are eventually borne by the customer. Avista attempts to keep expenses low by utilizing
Western red cedar for our poles, as cedar is widely prefened for utility poles due to their resistance to decay and durability, ease in climbing, strength and
endurance. RAM Utilities LLC, 'Your Best Pole Purchase," http://www.ramutilities.com/best-new-pole-purchase.html
88 The 15 year cycle was selected based upon Asset Management analysis. Details available upon request.
8e Maximo Data Pull 1012312017
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 49 of 128
o
,d
I
?
I
Transmission Ground Inspections Expendihres
s3s0,m0
s300,m0
s2s0,m0
s200,m0
S150,mo
s100,m0
ssopm
So
Actuol Budget
ruru%%
2012 2013 2014 2015 2076 20L7 2018 2019 2020 2071 2022
Avista is currently developing a steel pole inspection program to complement our existing wood pole
inspection program. This new program will maximize the efficiency of our existing inspection processes
by adding steel pole inspection criteria to current wood pole inspection practices. Previously inspectors
would pass by a steel structure due to the lack of information
required to develop an inspection specification. When the new
program is fully developed, the inspectors will have the proper
guidelines to follow. These guidelines will cover the following
evaluations: assessment of the environmental conditions that affect
the rate of corrosion, structural appraisal of each tower and pole to
determine existing corrosion and its effect on the integrity of the
structure, any nicks or bends in the metal, foundation condition, and a
visual overhead inspection. Once the guidelines are established,
Avista's steel poles will be monitored and tracked with the same
effectiveness and efficiency that is used in the Company's current
Wood Pole Management inspection program.
Steel Pole & Foundation Inspection
Avista's Ground lnspection Program is
invaluable in identifying poles needing repair or
replacement before they fail and cause outages
Replacing a transmission pole on a planned
basis costs approximately 53500 to 54500;
experience indicates that replacing a pole on an
emergency basis can cost up to three times
more.so lnspections offer the opportunity to
identify problems so they can be repaired on a
planned basis before they can reach the point
of failure.
Figure 26. Avista Ground Inspection O&M Actuals & Budgets
Fire Retardant Coatings
study was performed in 2008 which
determined that systematic coating of poles
with fire retardant would be a cost effective
means of protecting these investments. The
entire 230 kV system has been deemed
adequately protected and coating the 1L5 kV
system is currently approximately 37%
Replacing the fire retardant coating on
the Lolo-Oxbow 230 kV line
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 50 of 1 28
o
o
os0'Transmission Wood Pole Management Model Review," Rodney Pickett, Avista Asset Management.
t%
After several wildfires caused significant damage to Avista's transmission system, 3 'r
o
o
Transmission Fire Retardant Expendihres
s300,@0
s2so,mo
s2oo,mo
s1s0,@0
5100,@0
Sso,o@
So
2012 2073 2014 2015 2076 7077 2018 2019 2020 2027 2022
The Company has experienced the success
Figure 27. Avista Fire Retardant Expenditures Budgets & Actuals of this coating in several recent wildfires'
comptete. coatings are expected to remain effective for L2 ',[:r:#:f;!;';flr:!;y;!rY:'f"; *,
years. Targeted areas include those subject to grassland fires see the fire retardant pottion of the pole is
and which are in ctose proximity to raitroads.el protective :::il'tr:?:'l'^Yi[:::::::fl1'nlr,"
coating is not applied in heavily forested areas as fires in these the protected level.
environments tend to be at such a height that coatings cannot adequately protect the poles.
ln the past, the Company has spent an average of 5136,000 per year for this program. The current
budget of 5242,000 per year is based on coating or re-coating 1,000 poles each year. These coatings
have been proven to be highly effective industry widee2 and in Avista's own experience. The cost of
coating and the insurance it provides is significantly less than the cost of installing a new pole or
structure.
Transm ission Vegetation Management
Unfortunate interactions between trees and powerlines have caused
numerous outages as well as significant wildfires. Some of the largest
outages in the United States and Canada were caused by trees growing,
falling, or sagging into powerlines,s3 which led to stringent regulations
around issues such as vegetation management practices. ln 1990, Avista
developed a formalVegetation Management Program to proactively mitigate
vegetation-related outages and risks. Since that time the Company has
applied a centralized approach that includes transmission, distribution, and
e1 Trains can emit sparks (carbon sparks from exhaust as well as brakes) and create heat that can ignite. lnterestingly, the Milwaukee Road used to have
maintenance cars follow a few miles behind trains to spot fires and put them out. Source: Trains Forum "Sparks From Train Starting A Fire?",
http://cs.trains.conltrnlll1l1lll46526.aspx and 'Wildland Fires Resulting From Railway Operations - A Public Safety Threat," Canadian lnteragency Forest
Fire Centre, July 24,2007, http//www.tc.gc.calmedia/documents/rsa-lsf/ciffc.pdf
e2As an example, in 2015 a fire burned morethan 42 square miles in Arizona, burning 220 un-coated poles butfailing todestroyeven one of the 1,100
poles that had been treated with a fire retardant coating. Osmose, "Protecting Wood Utility Poles from Wildfire," http://www.osmose.com/newsletter-2015-
q3-fire-protection
e3 Sagging is especially problematic wtren lines are heavily loaded and lemperatures are high. ln addition, once a line fails, the power on that line is
diverted onto other lines, potentially overloading them and causing a cascading outage.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 51 ot 128
Actual Budget
o
high pressure gas lines. This program was initially designed to improve reliability for our customers and
to enhance safety for line workers and the general public. When North
American Reliability Corporation (NERC) vegetation management
o
o
regulations became effective in June 2007 ,s4 the Transmission Vegetation
Management Program (TVMP) was formalized with a focus on reliability,
compliance, sustainability, and envi ron mental stewardship of Avista's
transmission system.ss Access road maintenance was added to the
transmission program in 2009.
Avista Tree-Related Transmlssion Outages Avista's
Transmission
Vegetation
Management
Program has been
very successful,
leading to tree-
related outages
declining
significantly over
the past 26 years
as can be seen in
Figure 28.e6 This is
50
45
40
35
$30
o"
NERC Reliability
Requirements:
R1 and R2 Prevent Minimum
Vegetation Clearance
Distance Encroachment and
sustained outages due to fall-
ins and grow-ins from inside
the right-of-way on all 200 kV
and higher transmission lines
and Western lnterconnection
designated critical paths.
R3 Document maintenance
strategies (including
prevention techniques).
R4 lf vegetation capable of
causing a fault is identified,
the control center/switching
authority must be notified
immediately with no
intentional time delay.
R5 When constrained from
performing vegetation work
for some reason (such as
landowner disputes) evidence
must be provided, including
that the line was de-energized
until the work could be
completed.
R6 100% of applicable
transmission lines must be
inspected/patrolled at least
once a year with no more
20
1S
10
5
0
1990 1992 1994 196 198 2m0 2m1 2@4 2m6 2m8 2010 2012 2014 2016
Figure 28. Avista Tree-Related Transmission Outages
directly attributable to active vegetation management on all transmission
rights-of-way. Note that outage data prior to 2000 is inconsistent due to a
lack of outage cause categories in data reporting, and because it took a few
years for all of the rights-of-way to be cleared once this program was
initiated.
Compliance
Avista is in compliance with NERC Transmission Vegetation Standards lm:il:*" between
which are designed to prevent tree-related outages that could lead to R7 rooo/.imptementation or
cascading outages throughout the interconnection. These standards define annualwork plan.
minimum vegetation clearance distances based on voltage and elevation
and are designed to prevent flashovers caused by vegetation. Transmission owners are required to
demonstrate that they considered potential encroachments related to movement of the conductor
u North American Reliability Corporation Transmission Vegetation Management Standard FAC-0034,
http://www. nerc.com/pa/Stand/Reliability%20Standards/FAC-003-4. pdf
e5 Note that hansmission and distribution require different levels of vegetation expertise. Transmission tends to be in forested areas, requiring forestry
knowledge and expertise versus distribution, which tends to involve arborist activities such as trimming trees to meet customer requirements.
e6 Outage data management has greatly improved over the past 25 years. The data for this chart was gleaned from System Operator Log and
Transmission Outage Reports, The data was hand filtered to capture only tree related outages on lines owned and operated by Avista, and to provide
consistency in the outage cause. These outages may or may not have affected Avista customers. Because it has been hand filtered, this is not data that
has been previously reported to NERC or the Public Utility Commission. Note that prior to 2007 (FAC-003 implementation) reportable kee related outages
on applicable lines had been zero due to lack of outage cause categories.
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 52 of 128
o
s.
1 l-lbwffi
o
o
due to wind, heat, line load, icing, and other factors that could cause sag or sway of the conductor.
NERC fines can be assessed for allowing vegetation to get too close to power lines even if it has not
caused an outage. Other requirements include annual patrols, 100% implementation of annual work
plans (i.e. issues identified), documenting maintenance strategies, and having a process for reporting
imminent threat of tree outage. A summary of these requirements is shown in the text box on the
previous page.eT
Budgets and Expenditures
The Washington Utilities and Transportation Commission issued an order in March of 2005 requiring
Avista to commit to spending SZ.g million each year on Vegetation Management including both
distribution and transmission programs in Washington State.ss The ldaho Public Utilities Commission
issued a similar Order in October of 2004, allowing St.g million for ldaho tree trimming.ee
Avista Vegetation Management Expendihres The transmission and
d istribution vegetation
management programs
were split into separate
programs in 200L.
The transmission piece of
Avista's Vegetation
Management Program has
averaged $t.t million per
year since the split, as
shown in Figure 29, with
St.Z million budgeted each
year for the next five years
as shown in Figure 30 on
the next page. The
program developed by
Semo,mo
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szmo,mo
S5,mo,mo
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s4m0,m0
s3,m0,m0
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oc,
Uq
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o,
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6oo
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R
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fn<|n
oooNNd
o
oN
t Distribution ITranvnission EJoint Program: Eefore Split Total For Avista J
o
Figure 29. Avista Historic Vegetation Management Expenditures
Avista is cost effective, as it is much less expensive to maintain the rights-of-way than to perform any
of the intensive treatments required to initially clear the land around and under transmission lines.
The Transmission Vegetation Management Program (TVMP)
The TVMP is managed by the Transmission System Forester. Avista operates 985 miles of 230 kV and
1,675 miles of 115 kV transmission lines for a total of 32,000 acres of rights-of-way. Lines cross private
property, lands owned or managed byfederaland state agencies, and tribal nations. Typical land use
types are forest, agricultural, channeled scabland, Palouse prairie, and urban, rural and residential
areas. Land management activities both on and adjacent to transmission rights-of-way impact
e7 North American Reliability Corporalion Transmission Vegetation Management Standard FAC-003-4,
http://www. nerc.com/pa/Stand/Rel iability%20Standards/FAC-0034. pdf
s8 Washington Utilities and Transportation Commission, Docket Nos. UE-050482 and UG-050483 Order #5, December 21, 2005, page 8. This Order
further specified that if this spending falls short in any year, the difference would be spent in a future year or returned to customers via a credit.
ee ldaho Public Utilities Commission Case No. AVU-E-04-1, Order #29602, October 8, 2004.
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 53 of 128
reliability, safety, access and cost
controls. Thus communication and good
working relationships with landowners
and land managers are an essential part
of Avista's program.
RICTANGLE:
PRoc6sS
Avista Transmission Vegetation tr{anagement Expenditures
Actual Budget
tlltlll
"d"drdrotrdrotrdr0t"ot""l,trd,udrdr$"Srot"Srotrotrd.trd|rd
Active management is required on
rights-of-way to promote specific
vegetation communitiesl00 that will not
grow into transmission lines and that
wll/ promote the long term well-being
of the affected environment. lntegrated
Vegetation Management (lVM) has
been adopted as the Avista Figure 30. Avista Historic & Proiected vegetation Management Budget
methodology, as it is both a scientific approach and is considered a best management practice in the
industry.101 Avista's objectives are to use ecological principles and practices to promote dominance of
low growing vegetation and exclusion of tall growing plant species that can interfere with electrical
wires. Sustainable low growing plant communities provide a variety of environmental benefits,
including wildlife and pollinator habitat and soil conservation while protecting the functional right-of-
way, access for work on the lines, service reliability, and safety.102
Avista's transmission vegetation management is condition-based. lt is not a rigid set of activities
repeated over time but is governed by a variety of
considerations including critical infrastructure lines,
voltage, long-term desired state for the right-of-way,
landowner goals and activities, budgets, outage patterns
and history, construction project schedules, weather
conditions, site access, and contractor crew and
equ ipment availabi lity. Standa rd clea ra nces are
determined by voltage level, easement, and line
construction type. The System Forester is responsible for
managing vegetation-related projects and ensuring that
the work is done to meet technical specifications and
environmental welfare, handling landowner communications, quality review and inspection of work
100 "Communities" refers to particular combinations of vegetation in an area.
101 Tree Care lndustry Association: ANSI A300 (Part 7)-2012 lntegrated Vegetation Management (lVM),
https://www.tcia.orgIlClA/BUSINESS/ANSI_A300_Standards_/Part_7_lntegrated_Vegetation_ManagemenUTClA/BUSINESS/A300_Standards/Part_7
aspx?hkey=/6s94a09-1 32b-4b45-a926-6aa043b1 8465
102 IVM Flowchart courtesy of Randall H. Miller, "lntegrated Vegetation Management for Utility Rights-of-Way," 2014. For more information about this,
please see Mr. Miller's testimony before the House Natural Resources Committee, http://docs.house.gov/meetings/ll/|,1131201405071102191/HHRG-113-
I I 1 3-Bio-MillerR-201 40507.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 54 of 128
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o completed, and maintaining all documentation. A variety of methodologies are available to manage
vegetation in transmission rights-of-way. These
options are discussed below.
Aerial and Ground Patrols
Patrols are used to evaluate vegetation conditions
within the right-of-way, along the edges, and
including adjacent land management activities
such as logging, land clearing, home construction
and road work. Line patrols are completed annually
on all 230 kV lines and on other lines considered
critical to the Western lnterconnection.l03 This is
done using helicopter patrols, ground vehicles
(including all-terrain vehicles), and hiking. All of the
115 kV lines are also patrolled on a regular basis prioritized by time of last inspection, outages issues,
localized insect or disease outbreaks, and land use type. Patrols are used to assess general vegetation
conditions on the right-of-way and surrounding area, identify hazard trees, and note future potential
growth encroachments. Vegetation treatment or work recommendations are developed from field
assessments and either remedied or monitored over time through subsequent patrols.
Treatment
When treatment is required, vegetation conditions, legal requirements and restrictions, and cost
effectiveness are all
factored in to
determining which
treatment is the best
option. There are also
vegetation-related
considerations such as
species, size, topogra phy,
slope, right-of-way width,
permits and easements,
restrictions, access, and
fire risk. Based upon these
evaluations, the Company
determines which methodology
or combination of methods is
most effective. Examples are
shown below.
103 This would include any kansmission lines above 100 kV that could impact the interconnected grid (other transmission owners/operators) if they went
out of service. NERC Bulk Electric System Definition Reference Documenl,
http://www.nerc.com/pa/RAP,A/BES%20DUbes_phase2_reference_document_20140325_final_clean.pdf and NERC Transmission Vegetation
Management FAC-0034, http://www.nerc.com/pa/Stand/Reliability%20Standards/FAC-0034.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
I
o
Left: Tree caused
outage on the
Cabinet-Rathdrum line
Below: Cleared right-
of-way on the Cabinet
- Rathdrum line
o
. Mechanical Brush Mowing/
Mastication
r Logging
o Manual Hand Cutting
o Selective Herbicide
Application
o Hazard Tree ldentification &
Removal
o Ornamental Tree Pruning
o Vine removal. Biological controls. Cultural Controls
lntegrated Vegetation
Management Treatment
Options
Schedule 2, Page 55 of 1 28
Power
Muimum
Y
Mechanical Brush
Mowing/Mastication
. First step in establishing
maintained right-of-way
. Useful for high stem density, large
contiguous acreage or rural cross-
country areas. Non-selective clearing. Machine shatters stumps and
throws debris chunks up to 300'. Soil disturbance issues: creates
favorable conditions for noxious
weed infestation
. Requires good access roads and
trails. Can work up lo a 35% slope, but
not on side hills. Limited by rocky talus, steep, or
wetland areas. Uses up to 70 gallons of diesel per
10 hour day. 51,000- 52,500 per acre
Benewah Pine Creek 230 kV - First growing season
ofter mowing. Grass, seedlings ond greenery growing
on the right-of-way
Benewoh Pine Creek 230 kV- 7998 prior to mowing
Mower mochine
with o grinding
mower head. This
mochine hos o
working height of
11', weighs 80,000
pounds, ond has o
5,200 pound
mowing head,
octuoted 270
degrees side to
side. The boom
reaches out 35' in
both directions.
o
o
Exhibit No. 8
Case No. AVU-E-'19-04
H. Rosentrater, Avista
Schedule 2, Page 56 of '128
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. Clearing right-of-way to full
easement width and specifications
o Merchantable size timber. Landowner retains timber rights. Provides U.S. Forest Service &
Bureau of Land Management
timber sales. Requires Safe Practices (Hot Line
Hold or Line Clearance). Requires heavy equipment: dozer,
skidder, loader, haul trucks. Hand-falling needed for steep
terrain
o Sometimes costs more to log and
haul than sawmill receipts
o $2,000- s+,000/ acre
Loggingo
775 kV Burke-Pine Creek #4 Right-of-
way before logging ond mowing full
width
Every tree has to be sofely controlled
as it is felled odjocent to
transmission lines. The mochine
pushes the tree over os the sowyer
cuts it off ot the base. lt must be
felled in o woy thot it can be moved
ond safely looded onto trucks to be
houled to the sowmill.
o
115 kV Burke-Pine Creek #4 ofier logging and
mowing to full width
o
Hand cleoring work olong the
Noxon Pine Creek 230 kV ROW.
The hill is extremely steep ond
inoccessible to mochinery. Note
heovy slosh remoining.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page57 ot 128
. Used in areas not accessible to
mowers:
o Excessively steep
o Rocky
o Wetlands and stream
crossings
o Small acreage
o Along roadsides
o Rural residential areas
o Geographically isolated. Selective method of clearing. Heavy manual labor: 3-8 man
crews
o Safety concerns of running
chainsaw on steep rocky ground. Logistics include hiking into
inaccessible spots and packing all
equipment in
o Heavy slash remains on site,
increasing fire danger. Difficult to patrol
o $2,000- 54,000 per acre
Manual Hand Cutting
,l
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B.j
J
. Used to maintain right-of-way after
mowing, logging, hand-cutting and
access road maintenance. Based on ecological strategies and
plant dynamics. Selective detailed application
o Safety through using specific
application methods, product
selection, and the use of licensed
applicators. Conversion process to low growing
native plant communities. Minimizes soil disturbance. lmproves wildlife habitat, forage
and nesting cover for large and
small mammals, songbirds,
raptors, amphibians, and polli
species
o $100- 5600 per acre
Herbicide Application o
Trees "brown out" during the some yeor
as the herbicide applicotion. This is on
important reason to schedule frequent
treotment entries and to target trees less
thon 6'toll. Over time, as desirable
shrubs, ferns, ond grasses occupy the
site, there is less density of toll growing
trees which leads to less herbicide
necessary to mointoin the right-of-woy,
tronsloting to less cost.
One yeor ofter selective herbicide treotment.o
Western pine beetle
infestdtion in Lodge Pole
Pines on the Lolo Oxbow 2i0
kV line
Hozard tree patrol using GPS to collect hozard
tree locotion ond other informotion
Exhibit No. 8
Case No. AVU-E-'!9-04
H. Rosentrater, Avista
Schedule 2, Page 58 of 1 28
. Hazard tree definition: "Visibly
dead, diseased, dying, damaged,
structurally defective, or recently
exposed tree that could fall into
the conductol"
. Assessment of dead and green
trees located both on and off the
right-of-way
. ldentified during annual aerial and
ground patrols, reports from line
offices, local reps and other field
personnel
. Hazard tree patrols are done by
experienced forester
. Hazard trees are cut as soon as
practicable after identified.
Hazard Tree ldentification and
Mitigation
o
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^t
. Used sparingly in residential
landscape situations
. Communication and negotiation
with landowner for tree removal
and replacement with low
growing tree species is first
option
. Requires special equipment
. Requires more frequent attention
than rural conditions
. Expensive work due to job set up,
communication, crew travel time
to each site, and specialty
equipment logistics
Ornamental Tree Pruningo
o
Bockyard 115 kV tronsmission line with londscope trees
directly underneath. Requires pruning every 2- 3 years.
\\
Shrub community ten
yeors after mowing and
four yeors after
herbicide treotments
Roadside LL5 kV transmission line. Requires aerial lift truck and
chipper crew every j yeors to mointain cleorance.
Left: Six yeors ofter mowing.
Ferns hove on ollelopothic
elfect on conifers, which means
they inhibit their growth
through chem ica I i nte roction
via the roots, out-competing
conifer seedlings.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 59 of 128
o Uses plant biology and
ecological principles to adjust
plant cover types on the
right-of-way
. Uses natural methods to
suppress undesirable plant
species
o Desired state is sustainable
shrub community that
inhibits forest species
o Must actively manage
through selective cutting and
herbicide application to
maintain desired state
Biological Control
o
4,.4,.
t1.
:.
Access Roads
Access to the transmission lines is an important component to maintenance and reliability that is often
overlooked. Adequately maintaining existing access roads helps protect expensive line trucks and other
equipment and aids with outage restoration during major
storms and other events. These roads also minimize the
disruption and environmental impacts when heavy
equipment is needed to perform upgrades or repairs on
transmission lines.
Avista's Transmission
Vegetation
Management Program
includes the mandate
to maintain access
roads and keep them
in good drivable condition. This benefits both Avista, agencies, and
private landowners, and can minimize impacts to the environment.
Collaboration with University of ldaho
ln order to try to maximize the environmental benefits of
vegetation management practices, Avista is working with the
University of ldaho to evaluate cultural and biological treatments
that promote dominance of low-growing shrubs, grasses, and other
vegetation that often out-compete tall growing forest trees. This
three year research project is providing direct benefits to
transmission right-of-way vegetation management objectives and
operations.
Summary
The Transmission Vegetation Management Program promotes
reliability, safety, and compliance. Rights-of-way are managed for
the specific purpose of reducing vegetation-caused line outages.
The strategies and methods developed by Avista's program also
provide ecological benefits including wildl ife habitat, controlling
non-native vegetation, and protection for sensitive species, stream
courses, soil, and cultural resources. Avista has made a substantial
investment in reclaiming and managing the transmission rights-of-
way and has built an environmentally sound, cost effective program that will continue to garner
benefits in future years. Because of the nature of vegetation management, it is crucial to continue with
regular active maintenance activities on the rights-of-way. Through proper management and
maintenance, reliability, safety, and compliance will be preserved.
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2,Page 60 of 128
o
o
AVISTA COLLABORATION
WITH THE UNIVERSITY OF
IDAHO _ RESEARCH
OBI ECTIVES:
1. Evaluate effectiveness of various
chemical products and mechanical
techniques for controlling
undesirable tree species and non-
native invasive plants.
2. fusess value of compatible shrub,
flowering plants, grass species, and
ground cover in inhibiting
reestablishment of undesirable
trees through cultural and
biological controls.
3. Determine timing of treatments
necessary to maintain desired
vegetation.
4. Develop operational techniques for
cultivating shrub communities,
including the efficacy of various
herbicide formulations, in
controlling incompatible plants
while restoring native plants from
germination available in the soil
seed bank.
5. Appraise quality and quantity of
plants for pollinator, butterfly and
bird habitat.
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Unplanned Spending
Avista refers to unplanned spending as the cost of dealing with circumstances that cannot be readily
predicted. Typical causes in the transmission system are storms, snow and ice loading, or wildfires. The
amount spent varies significantly by year as can be seen in Figure 31. This chart shows major storms in
s4s00,m0 Avista Uaplanned Capital Transmission Expenditures
December of 2O06, July and August of
20L4, and the most significant storm in the
Company's history in November of 2015.
This storm impacted almost half of all
Avista customers for up to two weeks. By
contrast, we experienced no major
weather events in 2016. However, in 20L7,
wildfires caused significant issues and
expenditures. A fire in July and August
burned several miles of the Lolo-Oxbow
230 kV line. ln August, fire burned through
seven miles of Avista's 230 kV Walla Walla
- Wanapum line. The damage caused by
these two events cost 52.6 million to repair.
s4mo,m
S2"soo,@o
samo,m
stm,m
slo0,q)0
ssm.mo
So
2@5 2m6 2@7 2@8 2@9 2m0 2011 2012 2013 2014 2015 2016 2017
Figure 31. Avista Unplanned Capital Transmission Expenditures
o
There were also multiple weather and fire events on the 115 kV lines in 2017 which added another
St.5 million in repairs.
Avista Weather Related Outases
ffi
10
.&*
ob60
!oz
20
0
2m3 2m4 265 2ffi llJ0r 2@A 2m9 2010 2011 2012 2013 2014 2it5 ZOfi m7
rSnfl/le rlightning rWnd
What is left of a transmission structure on the
Walla Walla - Wanapum 230 kV line after a
wildfire in August 20L7.
Figure 32. Transmission Weather-Related Outages 2003 - Present
Snow/Ice loading causes a
line to sag in Spokane
Snow; rain, sleet or hail, Avista linemen are always on the job
A big windstorm in Rathdrum
snapped several transmission
poles in the area in 2014
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page61 ot 128
t
fr,
I
Transmission System Operations & Planning
Real-time Operations (System Operators)
SCADA/E nergy M a nagem ent System s/Autom ated Generation Control Systems
Operational Planning (12 months and less)
System Operations Training Program (System Operators and support staff)
System Operating Procedures (SOP's)
Outage Management & Coordination
Emergency Operations
Short- and Long-Term Planning
Processes & Procedures
Regional and National lnvolvement
Transmission Design & Engineering Standards
Project Scoping
Project Budgeting
Structural and Foundation Design
Project Management
Construction Standards
Compliance
Construction Management
Construction Liaison
Equipment (including Air Switches)
Vegetation Management
Pole & Structure lnspection
Transm ission Reinforcement
Transmission Services
Open Access Transmission Tariff
Long-Term Transmission Contracts - Negotlation and Administration
Open Access Same-Time lnformation System (OASIS)
Short-Term and Non-Firm Transmission Service
After-the-Fact Scheduling and Metering lnformation
ColumbiaGrid
Generation lnterconnection Process
Transmission Request Study Process
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o
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 62 of 128
o
Avtsra TnaNsrutsstoN OnoeNEeTIoN FuNcrtoNs
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CUSToTTER REQUESTED
Lind Solar Project -Avista is in the process of developing a solar facility of up to 20 megawatts.104 This
project was designed to align with State policy goals related to renewable energy. lt achieves societal
benefits and is responsive to our customers' needs and interests. lt also allows Avista to play a unique
role in promoting greater customer access to affordable renewable energy. The project will be located
just outside of Lind, Washington, adjacent to an existing Avista substation. An independent solar
developer will build, operate, and maintain the solar array, which will provide Avista's commercial
customers with an opportunity to voluntarily purchase solar energy. The developer requested an
interconnection with Avista's transmission system, the costs of which are shown in this business driver
category in 2018.
Table 2. Planned Capital Expenditures Based on Customer Requests
Ma.No^aroRY & CoupuANcE
As previously described, many of Avista's infrastructure decisions are based upon the requirement to
comply with NERC reliability standards. NERC Rules of Procedure are very clear regarding the
responsibility and accountability of utilities to be in compliance with Standards and what can happen if
they fail to meet the Reliability Standards, including significant fines and penalties. Other planned
projects are required by contractual commitments. Ten infrastructure projects required to meet these
obligations, described on the following pages.
Colstrip Transmission - Avista owns a 15% share in Colstrip Units 3 & 4 as well as the associated 250
miles of double circuit 500 kV transmission lines that transfer this energy to Avista customers.
NorthWestern Energy is the assigned operator of the Colstrip
transmission system and facilities. NorthWestern is responsible
for actual maintenance. As a joint owner of the Colstrip
Transmission System Avista is contractually obligated to pay its
commensurate ownership share of all capital improvements,
operations, and maintenance costs, as well as any costs
associated with compliance with reliability standards. Any failure
to comply would cause Avista to be in default of its contractual
Colstrip Transmission
1M Capacity ratings for utility-scale power stations are usually given in megawatts, which for most technologies means alternating cunent (AC). However
for solar plants this is sometimes expressed in terms of the direct current (DC) peak capacity of the solar array, which for this project would be about 28
megawatts. The 20 megawatts shown for Avista's solar project is in terms of altemating current, which is more consistent with how Avista typically
describes generation projects.
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 63 of 'l28
o
Aeeerlpx A: AVISTA CaeTreL PRoJEcT DETATLS
Lind Solar ct lnterconnection
Customer Requested 2018 2019 20m 2027 2022
s1,2s0,00c So SO SO Sc
Total s1,2s0.0m s So s0 So
UnlBl&2 obligations, and the Company
would forfeit its rights to the
Colstrip system, eliminating the
ability to utilize this key asset
which is being paid for by our
customers.los The Company's
capital spending for Colstrip
since 2011 has averaged
S36t,ooo per year; an average of
approximately 54t6,000 per year
is expected in 2018 through
2022.Typical expenditures in the
past have included end-of-life
replacement of circuit breakers
Ninth & Central Substation
o
Cotstrip Ownership and relays, erosion mitigation
around key structures,
installation of communication equipment, and hardware/software upgrades related to meeting
relia bil ity standa rds.
Ninth & Central 230 kV Station & Transmission - The Spokane area transmission system is heavily
dependent upon the Beacon Substation, which is networked
to the Bell Substation as well as eight 115 kV transmission
lines. ln order to reduce this dependency, create
redundancy, enhance customer reliability, and remain in
compliance with mandatory standards, Avista is upgrading
the infrastructure of the Ninth & Central Substation. The
Company is adding new 230 kV infrastructure to
Beacon Substation
accommodate a
23017L5 kV auto-
transformer and
associated circuit breakers, and putting in place additional
transformer capacity for the Spokane transmission system. This
project will also build eight miles of new transmission lines,
utilizing existing 1L5 kV corridors in a double circuit configuration
to fortify the Spokane area transmission system. This project
significantly strengthens the electric system in the Spokane area.
. :=/-'o
105 Colship Transmission Agreement, https://www.sec.gov/Archives/edgarldalal112771210000950123000109201y41907ex10-5_b.txt. Avista has the right
to approximalely 225 megawatts of Colstrip capacity.
Exhibit No. B
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 64 of 128
o
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OM€d by Puget
Erergy,
AYlsta,
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Noxon Switchyard 230 kV Breaker Replacements - The rated ability of the current oil circuit breakers
at Noxon Switchyard is inadequate for current requirements. This situation presents safety, reliability,
Noxon Rapids Dam with Switchyard on the Right
and compliance
concerns. The scope
of this project
involves replacing
and upgrading the
bus work, including
all bus and line
disconnect switches.
ln addition, all oil circuit breakers are being replaced with gas circuit breakers
with a sufficient interrupting capability.los Avista Highvoftage
Circuit Breaker
Protection System Upgrade - NERC Reliability Standard PRC-002-2107 defines Undergoing Maintenance
the disturbance monitoring and reporting requirements for Bulk Electric
System elements.108 This Standard requires collecting and recording data needed to analyze
disturbances. The Standard also
requires 50% compliance by 2020
and 100% compliance with these
data requirements by 2022.To
achieve compliance, Avista is
required to upgrade fault recording
capability at several substations
including: Beacon, Boulder,
Rathdrum, Cabinet Gorge, North
Lewiston, Lolo, Pine Creek, Shawnee
and Westside.
Geoeroton
0xind lutirBl
3. Trlp
Sent
2. Fault
at Substation
4. Breaker
Opens
O
South Region Transmission Voltage l'Faultoccurs
Control - Avista's south region 230 kV system, primarily in the Lewiston-Clarkston area, experiences
excessively high voltage during light load periods. The voltage levels currently exceed equipment
ratings over 35%o of the time. Long, lightly loaded transmission lines like those in this region produce
large amounts of line charging currentloe which increases system voltage. Currently, there is no
106 Gas circuit breakers have superior insulating and arc extinguishing qualities and can carry higher current levels. They are also non-flammable and
chemically stable, require much less maintenance, and are considered more effective at providing the ability to open a circuit to interrupt the flow of
electricity, protecting people and equipmenl.
107 NERC PRC-002-2 "Disturbance Monitoring & Reporting Requirements," http://www.nerc.com/_layouts/PrintStandard.aspx?standardnumber=PRC-002-
2&title=Disturbance%20Monitoringo/o2}ando/o2lReporting%20Requirements&jurisdiction=United%20States
108 NERC defines the Bulk Electric System as any transmission element operated at 100 kV or higher that has the potential to impact the grid.
1m Line charging cunent is also called reactive power, which is measured in VARs or mega VARs and is required for electrical components, as it allows
them to make use of alternatlve cunent. Many electronic devices such as computers or televisions only draw current during part of their cycle, and the
"leftover" eleckicity creates reactive load that the electrical system must handle or the voltage stability of the grid can be compromised.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 65 of 1 28
/
!
practical way to correct this high voltage issue on the existing 230 kV transmission system without
taking lines out of service. Removing lines from service is not practical, as it degrades system
performance for the next contingency. ln addition,
operating equipment outside manufactu rer's ratings
increases the possibility of equipment failure and
presents hazards to personnel. To mitigate this
situation, the Company plans to install 50 MVAR shunt
reactorsllo at the North Lewiston Substation. This
investment provides automatic control, resulting in
over-voltages being reduced or eliminated on the 230
kV buses at Dry Creek, Lolo, North Lewiston, Moscow
and Shawnee. This project should be complete by the
end of 2018.
Nofth Lewiston Reactors help regulate the voltage
and reactive power in this area
o
o
O
Saddle Mountain Station - lt was identified by Avista System Planning
studies and outside entities that the western portion of the Avista's
existing system is not meeting NERC performance requirements during
heavy load scenarios. The Saddle Mountain project, to be undertaken in
two phases, will allow Avista to continue serving Company load in the
Big Bend Area near Othello while eliminating pressure on the Grant
County Public Utility District system. This problem will be solved by
constructing a new 230/tL5 kV substation where the Walla Walla -
Wanapum 230 kV and the Benton - Othello 115 kV
transmission lines cross. This new sub will consist of a
three-terminal 230 kV double bus double breaker
configuration,llt a 250 MVA 230/Lts kV auto-
transformer,ll2 four 115 kV breakers, rebuilding existing
aging 115 kV transmission lines, and building ten miles of
new 115 kV transmission. This project will greatly improve
the reliability of transmission in the area and remove an
existing single point of failure situation which could create
widespread outages as well as mitigate potential thermal overloading and voltage issues.
Spokane Valley Transmission Reinforcement Project - This project reinforces transmission in the
Spokane Valley area, spurred by load growth in the region as well as compliance with the NERC TPL-
110 Shunl reactors absorb reaclive power, basically consuming reactive VARs, increasing efficiency and stabilizing the system.
111 A double bus double breaker bus configuration consists oftwo main buses, each normally energized and electrically connected to each other so that if
one is removed from service by a fault or for maintenance, the other breaker continues to function, so there is no interruption to service.
112 An auto-transformer is used mainly to adjust line voltages or hold them conslant, and can step up or step down voltages in the 1 1 5 kV and 230 kV
range, for example, providing a 1 15 kV tap from a 230 kV line.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 66 of 1 28
-
J
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o
001-4 Reliability Standard.113 This project includes the construction of a new substation and rebuilding
part of the Beacon-Boulder #2 LL5 kV transmission line. These changes will not only address
compliance issues, but will make the transmission system in this urban area more robust, specifically
for serving large industrial customers.
Transmission Construction: Reliability - This
program covers the transmission rebuild work, line
reconductoring, and new construction outlined in
the Corrective Action Plan developed under NERC
Rel ia bil ity Standard TPL-001-4.114 This standa rd
mandates completion of annual system planning
assessments studied against specific system
conditions and an updated Corrective Action Plan to
mitigate the transmission system reliability issues identified. Construction of these facilities will
mitigate currently identified reliability issues in compliance with NERC requirements.
Transmission - NERC Low Risk Priority Lines Mitigation - This program was initiated in response to
NERC's October 7,20L0, NERC Alert Recommendation to the lndustry, titled "Consideration of Actual
Field Conditions in Determination of Facility Ratings."11s lt addresses mitigation required on Avista's
"Low Risk" 115 kV transmission lines, and brings these lines into compliance with National Electric
Safety Code (NESC) minimum clearance values. These safety code
requirements have been adopted into the State of Washington's
Administrative Code (WAC 296-46B-010).116 lnvestments made under
this program reconfigure insulator attachments, rebuild existing
transmission line structures, or remove earth from beneath
transmission lines to mitigate ratings/sag discrepancies found between
the designs and actual
field conditions.
Placing conductor using a
helicopter (above) and by
hand (right)
113 NERC Standard TPL-0014: http://www.nerc.com/files/tpl-0014.pdf which requires the Company to avoid load loss and have circuit breakers with
sufficient intenupting capability for faults.
114 NERC Standard Application Guide TPL-0014, Version 2, http://www.nerc.com/pa/comp/guidance/ER0EndorsedlmplementationGuidance/TPL-001-
4_Standard_Application_Guide_endorsed.pdf
115 NERC Facility Ratings Alert, http://www.nerc.com/pa/nm/bpsa/Pages/Facility-Ratings-Alert.aspx
116 Washington State Legislature, WAC-296468-101, National Electrical Code legislation, http//app.leg.wa.gov/wac/default.aspx?cite=29646B-010
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page67 of 128
o
Westside 23OlLLs kV Station "Brownfield Rebuild"117 - Loads on
the existing Westside #L 23OltL5 kV transformer exceed its facility
rating when the #2 transformer is
taken out of service. This
overloading cou ld potentia I ly
cause load shedding, which may
impact compliance with NERC TPL-
001-4, a Standard which defines
system planning performance
requirements.ll8 This project was
developed to replace the existing
#1 transformer and upgrade the breakers and buses to a double bus double breaker configuration.
These types of transformers are highly specialized, must be custom-ordered, and can take months to
t t
arrive. They weigh
approximately 1-70 tons
(making transportation costs an
issue) and have prices tags of
approximately S2,ooo,oo011s so
entail a great deal of planning
and preparation as well as
- 2 months - 1.2 months - 1.2 months
a
- Fervrveeks
to monlhs'
- 2-{ month3 installation time.o
- Fewdrys to - 2.{ monlhg
Large Power Transformer Procurement Process and Estimated Lead Time -
Not Including Installation Time
Table 3. Planned Capital Expenditures for Mandatory & Compliance
t
Above: Westside #1 230/115 kV
Transformer
Left: Westside #2 Transformer
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 68 of 128
o
117 A (Brownfield" project refers to a project that takes place on land that has been occupied by a "permanent" structure at some point, requiring
demolishing or renovating a prior structure, versus a "Greenfield" project that will be built in a place where nothing had been built before.
118 NERC TPL-001 4, http://www.nerc.com/files/tpl-001 4.pdf
1le U.S. Department of Energy, "Large Power Transformers and the U.S. Electric Grid," 2012,
https://www.wecc.bizlReliability/2014_TEPPC_Transmission_CapCost_Report_B+V.pdf , page 7,
SubmltBld
ConUrct
Speclfic!Uon
Ncgouroon,
Techrilcrl
ldentlyNeed
trnsporrr&n&glbSet{p
Product on Purchas€MrErLls
s40s,000 s360,000Colstrip Transmission s47o,ooo 54ss,000 s39o,ooo
Ninth & Central 230kV Station & Transmission So Ssoo ooo s2,7oo,ooo S10,8oo,ooo s15,ooo,om
Noxon Switchyard 230kV Breaker Replacement s1,600,ooo So 5o So Sc
s1,32s,000 s42s,000 S3oo,omProtection System Upgrade s1,39s,ooo s1,390,000
South Region Voltase Control Ssoo,ooo So so $o Sc
Saddle Mountain 230/115kV Station Phase L s6,600,ooo s10,800,000 s1s,9oo,ooo So sc
Saddle Mountain 230/115kV Station Phase 2 so Ssoo,om sl,sso,ooo 58,7oo,ooo Sc
so So ScSpokane Val ley Transmission Rei nforcement Project ss,2so,ooo sTso,ooo
Transmission Construction - Compliance S143oo,ooo s12,soo,ooo SZsoo,ooo sloo,ooo 56,mo,om
Transmission NERC Low-Risk Priority Lines Mitigation 51,soo,ooo sl,soo,ooo sl,soo,ooo So Sc
ScWestside 23Ol t75kV Station " Brownf ie I d Re bui ld "s6,soo,ooo s6,soo,ooo s6,s00,000 SG,5m,mo
Total S38,11t000 534,891000 $37,365,000 525,930,000 S2a6@,000
Mandatory & Compliance 2018 mLg 2020 202L 2022
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Ileslgn
Requesttor
Propo3rl
Tesdng
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PERFoRMANCE & CEPN.CITV
SCADA Build Out Program - This project will complete the installations of Supervisory Control and Data
Acquisition (SCADA) and EMS/DMS (Energy Management
System/Distribution Management System) capability to all Avista
substations. These systems provide full visibility of system
conditions and operations, system status indication, and operator
control at each substation. SCADA provides automation capability
on distribution feeders that allows operators to sectionalize
feeders, reducing the number of customers impacted by an outage
This system also provides real time and historical data to the
Transmission System Planning, Asset Management, Operations, and Engineering groups to enable
efficient, flexible and safe design, planning, and operation of the Company's transmission and
distribution systems.
Substation - New Distribution Station Capacity - Adding new substations for load growth and
reliability is critical to the long term safe, reliable, and cost-effective operation of the system. As load
demands increase and customer expectations related to reliability
continue to increase, incremental substation capacity is required
to serve those demands. Funding under this category is based on
the historical experience of needing to add approximately two new
substations to the system per year, or rebuilding/upgrading
existing substations to ensure that the system is growing at an
adequate pace to maintain the current level of service and
reliability. The capital allocated to this program is shared between
Transmission, Substations, and Distribution but the entire amount
Crew setting distribution transformer is shown here, as the transmission function creates and managesat the old rown ' this program.
Transmission New Construction - lnvestments made under this program support the addition of new
substations due to load growth in a particular area or to reinforce existing substations with new
transmission required for increased performance. lnvestments are typically requested by Transmission
Planning or Operations. ln addition, funding in this category is used to increase reliability to existing
substations by providing a redundant transmission feeds to radially-fed substations, reducing the
potential for customer outages. This program is managed through the joint efforts of Avista's
Transmission Design & Engineering, Substations, Operations, and Transmission Planning groups.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 69 of 128
SCADA Build-Out Program Sz,ooo,oool Sz,ooo,oool S3,ooo,mol Ss,ooo,oool Ss,ooo,000
Substation - New Distribution Station Capacity Sz,zso,oool Sr,soo,oool Sol Srs,soo,oool Ss,ooo,ooo
sol sol ssso,oool sg,oso,oool s11,7oo,oooTransmission New Construction
Total s4,250,q)0 s3,8{D,000 s3,550,0m $8,550,000 $25,700,000
Performance &2018 2019 2020 202t 2022
o Table 4. Planned Capital Expenditures Based on Performance & Capacity
rlE
AssET Cor*ptrroN
This category includes rebuilds related to aging or end-of-life assets and upgrades related to design,
safety, or construction standards. lt can also include technology upgrades to hardware, software, or
other technology-based systems. An example is upgrading the Supervisory Control and Data
Acquisition (SCADA) systems used by System Operations personnel in both the primary System
Operations Office and the Backup Control Center. This is necessary to ensure that System Operators
are able to adequately monitor the electric system without interruption. System Operators perform
switching operations, maintain system voltage, respond to abnormal conditions, and maintain constant
communication with neighboring systems and regional authorities to
assure overall interconnected system reliability using specialized control
and communications systems that must be online and available without
fail and which is updated as necessary.
o
oLatah-Moscow 115 kV Line,
Built in 1924
The Company's Transmission System Asset Management Plan120
recommends a 30-year replacement period for transmission assets, which
requires an investment of S21.1 million per year, split 511.3 million for LL5
kV facilities and S9.8 million for 230 kV facilities. Current spending on the
replacement of transmission facilities due to asset condition is just under
StO million per year, meaning the Company is currently on a funding level
track that will require some transmission assets to operate reliably at an
age beyond 60 years.121
Substation - Station Rebuilds Program - Replacing and upgrading major substation apparatus and
equipment as it approaches end-of-life or becomes obsolete is a routine part of Avista's maintenance
strategy. Replacing this equipment before it fails is necessary to maintain the safe and reliable
operations of the transmission and distribution systems, as substations are at the heart of these
intercon nected systems.
lnvestments include updating old equipment to
meet new safety and construction standards,
install ing com mu nications systems, a nd replacing
or upgrading primary equipment such as circuit
breakers, reclosers, switches, capacitor banks,
transformers, and regulators. ln addition,
supporting equipment like relays, meters,
batteries, panel housing, and fences must be
replaced periodically to ensure the full The new pine Creek AutoTransformer
functionality and safety of Avista's substations. Please note that
capital allocated for this program is shared between Transmission, Substations, and Distribution but
the entire amount is shown here as the transmission function creates and manages this program.
120 2016 Electric Transmission System Asset Management Plan,
http//www.puc.idaho.gov/fileroom/cases/elec/AVU/AVUE1603/company/20160526ROSENTRATER EXHIBIT 7.PDF
121 Heather Rosentrater testimony, HLR-1 T,
https//www.utc.wa.gov/_layouts/15/CasesPublicWebsite/GetDocument.ashx?doclD=485&year=2016&docketNumber= 160228
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2, Page 70 ol 128
o
r
I
I
o
o
Transmission Minor Rebuild - The Company tracks outages with a key focus on recurring outages that
require further investigation and, at times, repair or replacement of existing equipment. The
Transmission Minor Rebuild category funds transmission structure and air switch replacements based
upon the results of the Company's outage tracking, annual wood
pole field and aerial patrol inspection programs, and field
operations requests regarding the condition of assets. lssues
typically addressed include a broken or rotting cross arm, broken or
damaged conductor, malfunctioning air switch, or a missing guy
line.
Replacing a broken insulator string is
pan of the Minor Rebuild program.
Transmission Major Rebuild - For significant capital outlays, the
Engineering Roundtable prioritizes projects based upon input from
Company subject matter experts. This extensive contribution of
expertise by function ensures that projects are funded in a manner
that maximizes overall customer value and that the system receives
the level of maintenance required to insure continued reliable
service.
lnvestments made under this program rebuild existing transmission lines based on overall asset
condition as measured by useful life or condition-related outages. Factors such as operational issues,
ease of access during outages, and need to add
automation or communications equipment are
also factored into the prioritization of major
transmission capital projects under the
guidance of the Engineering Roundtable. The
failure to timely replace aging transmission
infrastructure on a planned basis would
ultimately subject customers to reduced
reliability and increased risk of outages. ln
addition to customer outages, failure to
properly invest builds a bow-wave of needed
investments in the future.
Working on the Benewah - Moscow 230 kV line
Exhibit No. B
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page71 ol 128
Substation - Station Rebuilds Program S13,42s,mol Srs,ooo,oool Sls,ooo,oool Srs,ooo,oool S1s,ooo,om
Transmission - Minor Rebuild Sr,a+a,+zol 51,843,4201 51,ep,3,4201 5t,u3,4zol 5t,s/,3,420
Transmission Maior Rebuild - Asset Condition S12,ooo,oool 511,ooo,oool 56,000,000l S13,soo,oml SB,soo,ooo
Total 527,2f8,r20 $27,843,420 s?2,/&i3,420t s3O,:!43,420 5yD,343,42!D
Asset Condition 2018 2019 2020 202L 2022
o
Table 5. Planned Capital Expenditures Based on Asset Conditron
r
r
Farleo Pla.Nr & OpemrroNs
The spending in this category is typically related to weather events but can also include more routine
failures that happen as assets age and wear out. The amount budgeted is based upon prior years of
spending and experience. Most of this spending is applied toward Distribution, which historically
experiences the most storm damage expenditures. The amount shown in the table below for
Transmission indicates 18% of the Company's total
Failed Plant budget, which is the percentage of the
storm expenditures utilized by Transmission over
the past five years.
Table 6. Planned Capital Expenditures Expected for Failed Plant & Operations
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2, Page 72of 128
o
o
Electric Storm - Total Distribution and Transmission Se,zze,oool Sa,:zo,sool 53,168,8001 g,2oo,oo0 s3,2oo,om
Electric Storm - Transmission Expected 2U/o of Total S6ss,60ol Sozs,aool s633,76ol s64o,ooo $oao,ooo
Failed Plant & Operations 2018 2019 2020 2021,2022
a
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o
Electric utilities are highly regulated at the federal and state levels. The Federal Energy Regulatory
Commission (FERC) oversees all electricity transmission and wholesale marketing from the federal level
via their enforcement arm, the North American Electric Reliability Corporation (NERC). ln addition, the
electric power industry must comply with literally hundreds of national, state and local environmental
regulations (including those under the Clean Air and Clean Water Acts). They are governed by laws
related to crossing federal lands or
affecting unique interests, such as
culturally significant sites or endangered
species, primarily enforced by the U.S.
Environmental Protection Agency as well
as state environmental entities. The
National Electrical Safety Code defines the
rules for installation of electrical gear,
electrical protection, methods and
materials and even communications for all
electric utilities.122 The Securities and
Reliability Regulations H istory
* 1958: NERC is established* L977: New York City Blackout
* 1996: Western US Blackout* 2003: US/Canada Blackout* 2005: U.S. Energy Policy Act is passed
.1. 2006: FERC certifies NERC as it's official
Electric Reliability Organization
* 2OO7: NERCstandards become
mandatory & enforceable
o Exchange Commission and the Commodities Futures Trading Commission enforce regulations related
to financial and accounting requirements; anti-trust regulations come from the Department of Justice
and the FederalTrade Commission. The Occupational Safety and Health Administration (OSHA)
regulates safety standards. State and local regulators focus on facility siting and zoning, safety
regulations, taxes and more; state regulatory commissions determine revenue requirements, allocate
costs, set service quality standards and oversee the financial responsibilities of the utility.
All of these regulators and regulations have developed over time to ensure the safety of people and
equipment and protect the integrity and reliability of the interconnected system.
TnE Hsronv oF REGUI-ATION
ln July of 7977, New York City experienced a blackout that affected most of the
city. lt started with a lightning strike, but ended with cascading outages due
primarily to lack of communications. New York Power Pool's definition of shed
load (meaning "immediately") did not match Con Edison's definition of shed
load (meaning "using a series of steps"). The system quickly collapsed. This
widespread outage caught the attention of the federal government, who
instituted voluntary and limited reliability standards to encourage some
consistency in operating the national grid (and in communicating with one
another).
122 https://en.wikipedia.org/wiki/National_Electrical_Code and http://www.lni.wa.gov/TradesLicensing/Electrical/LawRulePol/LawsRules/default.asp
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 73 of 128
AeeExptx B: UrTtrTY REGULATIaN
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Then, in 1996, the nation experienced two more severe blackouts in July and August across the entire
Western United States and into Canada and Mexico. These outages, only six weeks apart, were thought
to have been primarily caused by excess demand during a very hot summer, as well as vegetation
management issues (an overloaded transmission line sagged into a tree). President Clinton directed
the Department of Energy to investigate, eventually leading to voluntarily paid fines for reliability
violations. Again reliability gained national attention.
Then, in August of 2003, North America experienced the worst
blackout in American history; 50 million people lost power (over
6L,800 megawatts) for up to two days throughout the Northeast
and Midwest and into Ontario, Canada. Cost estimates in the U.S.
Northeast Blackout, August 1 4, 2003
alone ranged
from 54 to
S10 billion.
Eleven people
died.
lnvestigations
revealed that
specific
practices
(which varied
from utility to utility), human decisions, poor communications, vegetation management issues
(excessive line sagging into trees again), and equipment inadequacies all contributed to this situation
Communications and technology were so lacking that many of the affected utilities did not even
recognize the deteriorating condition of the system until the blackout occurred.
This situation prompted the Federal Energy Regulatory Commission (FERC) to take a hard look at
creating consistent standards related to the planning, design, and operation of the national grid and to
make such standards mandotory and enforceable with penalties for non-compliance.123 ln 2005 the
United States Congress authorized a bill, The Energy Policy Act
of 2005, which granted FERC significant new responsibilities and
authority, including the government's blessing on overseeing
the reliability of the nation's electric grid and promoting the
expansion and modernization of the nationaltransmission
system.l2a The Act called for the creation of an Electric Reliability
Organization (ERO)to develop and enforce compliance with
mandatory reliability standards in the United States.
tzg "Final Report on the August 14, 2003 Blackout in the United States and Canada: Causes and Recommendations", U.S.-Canada Power System Outage
Task Force, April 2004, https://energy.gov/sites/prod/files/oeprod/DocumentsandMedia/BlackoutFinal-Web.pdf
124 (Energy Policy Act of 2005," Fact Sheet, https://www.ferc.gov/legal/fed-sta/epactfactsheet.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 74 ol '128
o
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ln 2005, FERC certified the North American Electric Reliability Corporation (NERC) as the Electric
Reliability Organization (ERO) for the United States, with the purpose of insuring the reliability of the
North American interconnected electric system. NERC was granted authority to assess, monitor, and
enforce mandatory reliability standards, certify bulk power system
operators, maintain situational awareness of potential threatening
issues, monitor security, investigate and analyze disturbances, and
continually update standards as needed.l2s
ln 2OOT,compliance with NERC reliability standards became a
legal requirement for utilities with transmission circuits crossing
state/province lines in North America, called the "Bulk Electric
System" (BES). These requirements cover owners, operators, and
users of this system.126 Today, NERC continues to develop and
approve mandatory reliability standards aimed at ensuring Bulk Electric System reliability. These
reliability standards can require significant utility capital investments.
TNnxSu IssIoN REGUI-ATIONS GOVEnNI NG AvISTA' s TRa.N sM IssIoN
Svsrerrr
FERC has regulatory authority over both the reliability and commercial aspects of Avista's transmission
system. The commercial aspects relate to Avista's Open Access Transmission Tariff (OATT).127 FERC has
delegated reliability standard development and enforcement to the Electric Reliability Organization
(ERO), a role that is fulfilled by the North American Electric Reliability Corporation (NERC). NERC
delegates reliability standard compliance enforcement to Regional Entities, assuming they will have
expertise regarding their particular areas of the country. ln Avista's case, this is the Western Electricity
Coordinating Council (WECC) that oversees the Western
lnterconnection. All of these entities will be discussed in
further detail in later sections of this Appendix.
Reliability standards can be developed nationally through
the NERC process, or regionally within the Regional Entity
(WECC). ln either case, NERC's Board of Trustees must
approve the reliability standard. After NERC approves a
reliability standard, it moves to FERC, where FERC may
either approve or remand the standard for further
125 For more details, see: http://wwunerc.com/AboutNERC/keyplayers/Documents/ERO_Enterprise_Operating_Model_Feb2014.pdf
126 NERC Glossary Bulk-Power System: (A) facilities and control systems necessary for operating an interconnected electric energy transmission network
(or any portion thereof); and (B) electric energy from generation facilities needed to maintain transmission system reliability. The term does not include
facilities used in the local distribution of electric energy. For more details see: http://www.nerc.com/mwg-internal/de5fs23hu73ds/progress?id=QUcpT-
pcF40aV605eTSOC4ShELZTfcUGWASkXdu34FU,&dl
12 The 0ATT is a tariff that helps insure that all transmission owners and customers have fair and open access to the grid, includes rights and
responsibilities of these groups, cost recovery and allocations and system planning requirements. The history of OATT:
84 for information about Open Access Same-Time lnformation System (OASIS).
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 75 ol 128
Note thot the terms Bulk Electric
System (BES) and Bulk Power
System (BPS) ore often used
interchongeobly, but thot is
incorrect. BES facilities ore subject
to NERC Stondards; BPS may
include some focilities thot ore not
subject to NERC Stondards.
r FERC generates an order regarding a reliability
issue
o NERC (delegated authority, but not a
governmental agency) begins industry-driven
process to develop reliability standards in
addressing the FERC order(s). FERC has approval or denial authority over
reliability standards and enforcement actions
proposed by NERC
How do FERC and NERC Fit Together?
Federal Energy
Regulatory Commission
(FERC)
development. Once FERC has approved the reliability standard, it becomes mandatory and
enforceable.
o
o
Stondord Enforcement
I
I
E
Operotionol
Requirements
lstondordEnlorcement PeakReliabilitysystemoperatingLimits
Under these reliability standards, a Reliability
Coordinator (RC) is assigned responsibility for
the reliable operation of the facilities that make
up their portion of the interconnected system.
WECC designated Peak Reliability to be the
Reliability Coordinator for the Western
lnterconnection. The RC has the authority and
responsibility to set operating rules that
maintain system reliability for the Western
lnterconnection. One example of this is the
Methodology. This document defines how
Transmission Operators, such as Avista, must
rate their facilities and operate their systems to
rhe Bosic Levels of Resulotion Affectins the maintain system reliability' Whereas in the past'
AvistaTransmissionsystem Transmission operators like Avista could define
their own System Operating Limits based on a
multitude of criteria, Peak's methodology ensures consistency with all of the Transmission Operators
within its jurisdiction. Each Reliability Coordinator has complete operational authority within its
designated area, and its operating instructions are fully enforceable.
The primary regulatory bodies are described in more detail below.
Federal Energy Regulatory Commission (FERC)
The FERC is an independent U.S. government agency organized under the Department of Energy. lts
mandate is to "protect the public and energy customers, ensuring that regulated energy companies are
acting within the 1aw."128 This agency regulates the overall reliability of the electric grid, interstate
transmission of electricity and natural gas, and the wholesale sale of electricity and related energy
markets. lt also licenses hydroelectric power plants and approves construction of interstate gas
pipelines, storage facilities and liquefied natural gas terminals. Note that FERC does not regulate the
construction of electrical transmission and distribution systems or generation, but has regulatory
jurisdiction over all wholesale uses of these assets that are owned and operated by public utilities as
defined under the Federal Power Act.12s FERC delegated authority to the North American Electrical
Reliability Corporation (NERC) as the Electric Reliability Organization, responsible for overseeing the
security and reliability of the bulk power system in North America subject to FERC oversight. Although
NERC covers most of North America, FERC jurisdiction is limited to the U.S.
128'What is FERC?" https://www.ferc.gov/students/whatisferc.asp
12e Definition of a "public utility" is any person or company that owns or operates facilities used for the transmission of electrical energy in interstate
commerce, per Lawrence R. Greenfield, 'An Overview of the Federal Energy Regulatory Commission and Federal Regulation of Public Utilities in the
United States," Federal Energy Regulatory Commission, December 2010, https://www.ferc.gov/abouUferc-does/ferc101.pdf, page 11.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 76 ot 128
North American Electric
Reliability Corporation
(NERC)
Western Electricity
Coordinating Council
(wEcc)
Avista Utilities Peak Reliability
(Reliability Coordinatorl
o
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North American Electric Reliability Corporation (NERC)
The NERC is the electric utility industry's primary point of contact with the U.S. government. NERC is
responsible for developing and enforcing standards related to the interconnected grid, with jurisdiction
over users, owners, and operators serving over 334 million electric customers in North America.
NERC's primary job is to ensure the reliability of the national grid - that there is a continuous supply of
electricity at the proper voltage and frequency. lt continually assesses the adequacy of the national
grid, certifies that critical infrastructure is adequately planned, maintained and operated, audits
owners, and warrants that operators and users are adequately prepared to handle routine as well as
unexpected events. ln addition, it educates and trains industry personnel. NERC's purview spans the
continental United States, much of Canada and parts of Mexico, although NERC has no enforcement
authority outside of the United States other than that created by agreement.
NERC's role in Canada is similar to its role in the United States. While the process for approving NERC
Reliability Standards varies in the different Canadian jurisdictions, most of the provinces have agreed
that NERC Standards-in some cases modified to reflect the jurisdictions' reliability regimes-are
mandatory and enforceable in the provinces of Ontario, New Brunswick, Alberta, British Columbia,
Saskatchewan, Manitoba, Nova Scotia and Quebec. Enforcement programs vary among the provinces,
with provincial regulators having ultimate
authority for monitoring and enforcing
compliance in most provinces. Authority
over electricity generation and
transmission in Canada rests primarily
with provincial governments. However, all
have recognized NERC as the electric
reliabi lity standards-setting organization
and have committed to supporting NERC
in its standards-setting and oversight role
in North America.l3o
Florlda ln Mexico, the Mexican Federal Regulatory
Commission, Comisi6n Reguladora de
Energia (CRE)and the Mexico System
Operator, Centro Nacional de Control de
Energfa (CENACE) which manages the
operation and planning of the Mexico
130 NERC, http://www.nerc.com/AboutNERC/keyplayers/Pages/Canada.aspx. For detailed informalion about each Canadian Province's agreement with
NERC: http//www.nerc.com/AboutNERC/keyplayers/Documents/Canadian%20Provincial%20Summaries%200f%20Standard-
Making%20and%20Enforcement%20Functions%20with%20US%20Comparators%20(2).pdf. Cunently Newfoundland and Labrador are connected to
each other but not to the rest of Canada. Upon completion of a high voltage DC line to Nova Scotla cunently under construction, they will determine
whether to agree to NERC Standards.
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 77 ot 128
NERC Operating
Areas
o
I
ReliabilityFtrst
national power grid, have adopted at least ten of NERC's primary Reliability Standards.l3l Though the
two countries have worked together on this in the past and Mexico has voluntarily followed NERC
guidelines, a memorandum of understanding between the three agencies was signed on March 8,
2017, which recognizes the growing interconnections between Mexico and the United States and
establishes a collaborative mechanism for identification, assessment and prevention of reliability risks
to strengthen grid security, resiliency and reliability of grid across North America.
NERC defines the Bulk Electric System (BES) as the electrical generation resources, transmission lines,
interconnections with neighboring systems, and associated equipment, operated at voltages of 100 kV
or higher (but not including radial transmission serving only one load with one transmission source).132
It defines a reliable BES as one that can meet the electricity needs of end-use customers even when
unexpected equipment failures or conditions reduce the amount of available electricity on the system.
That entails both adequocy (sufficient resources) and security (resiliency). Since NERC has regulatory
authority over the entire North American grid, it developed standards to ensure that the entire
interconnected system is reliable according to its definition of this term, and that those standards are
enforced nationwide and industry-wide.
ln order to do all of this, NERC develops standards designed to promote consistency in grid planning
and operations. They set standards for resource and load balancing, emergency preparedness,
communications, facilities design and maintenance, and coordination with neighboring utilities. NERC
Reliability Standards are developed using an industry-driven process; stakeholders actively participate
to ensure that all perspectives are
considered.l33 North Amerlcan Electric Rellabllity Corpontion lnterconnections
EASIEET.I
IilIERCONNTCNON
NERC reliability standards are designed
so that the grid is planned and operated
such that no credible contingency can
create a cascading outage or
uncontrolled blackout. They also address
emergency operating conditions, such as
system restoration from a widespread
outage, facility rating methodologies, and
personnel training requirements.
,'\---
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INIERCOI{NECTrcN aaaa,a
,\\
ELECTRrcTY REIIASUTY
couilc[or rExAs
INTERCOI{NECflON
ln order to incorporate all of the national
and international issues and differences
most efficiently, NERC created several
layers of regulation and oversight. The nation United Stotes Primory Grids
131 Baja California Norte, Mexico, is part of the WECC but only by agreement - WECC helps them monitor their compliance with certain standards but has
no enforcement authority. WECC offers compliance monitoring for CFE in the portion of Baja California Norte that is interconnected to California.
1u North American Electric Reliability Corporation Memorandum, April 10, 2012, http//www.nerc.com/files/final_bes_vs%20_bps-memo_20120410.pdf
133 "NERC Roles & Responsibilities," http://www.nerc.com/pa/Stand/Resources/Documents/DraftingTeam_Roles_and_Responsibilities.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 78 of 128
a
NERC REGIONAL
OPERATING ENTITIES
* Florida Reliability
Coordinating
Council (FRCC)
+ Midwest Reliability
Organization
(MRo)
* Northeast Power
Coordinating
Council (NPCC)
* ReliabilityFirst(RF)
{' SERC Reliability
Corporation (SERC)
* Southwest Power
Pool lnc. (SPP RE)
* Texas Reliability
Entity (Texas RE)
{. Western Electricity
Coordinating
Council (WECC)
o
o
is broken into three primary grids: Eastern, Western, and Texas, which operate largely independent of
each other and with limited transfers of power between them.134 All of
the electric utilities within each of these three interconnections are tied
together during normal operating conditions and operate at a
synchronized frequency of 60 Hertz. Although all of the North American
interconnections operate at the same average frequency, the three
individual interconnections are not in synch with one another and
therefore cannot be directly connected through AC transmission lines.
These three primary entitiesl3s can be tied to each other via high-voltage
direct current (DC)transmission lines or with variable-frequency
transformers,l3s which permit a controlled flow of energy while
functionally isolating them from each other.137
These three areas are divided into eight Regional Operating Entities
(shown in the text box on the left), each of whom are responsible for
ensuring that their area of the grid is reliable, adequate, and secure.
These entities enforce all NERC standards and, in addition, may develop
region-specific reliability standards based on local and regional technical
expertise and system characteristics. NERC believes that, given the
"highly technical and intricate complexities of planning and operating" a
national grid that is "dispersed, interdependent and asymmetrical", the
concept of local and
regional expertise
provides a much more
effective means of
triangulating and
add ressing risks.138 These
eight entities monitor
N ERC compliance through
a number of discovery
13a The Eastem lnterconnection encompasses the area east of the Rocky Mountains and a portion of northern Texas and consists of 36 balancing
authorities: 31 in the United States and 5 in Canada. The Western lnterconnection encompasses the area from the Rockies west to the Pacific Ocean and
consists of 37 balancing authorities: 34 in the United States, 2 in Canada, and 1 in Mexico. The Electric Reliability Council of Texas (ERCOT) covers most,
but not all, of Texas and consists of a single balancing authority.
13s There are also two "minor" interconnections: Quebec and Alaska. Texas is sometimes called a "minor interconnection' as compared to the Western
and Eastern interconnections. Texas built its own power grid and is not connected to the rest of the country in order to avoid federal regulation of its
electricity system.
136 A variable frequency transformer is a highly specialized piece of equipment that allows transmission of electricity between two "incompatible" domains;
it operates like a continuously adjusting phase-shifting transformer.
1il There are cunenlly six DC ties between the Eastern and Western lnterconnections and one in Canada. Note that these entities are isolated from each
other, in part, to protect the integrity of the United States so that, in essence, a cascading outage cannot impact the entire country.
138 !lmproving Coordinated Operations Across The Electric Reliability Organization (ERO) Enterprise," February 2014,
http://www.nerc.com/AboutNERC/keyplayers/Documents/ERO_Enterprise_0perating_Model_Feb2014.pdf
Exhibit No. B
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 79 ol 128
Violations by Method of Discovery
complalnt
L%
L%
Compllance
Audlt
lnvestigation
6%
Self-Report
O
certification
30%
44%
methods, including regularly scheduled compliance audits, random spot checks, compliance
investigations, and a complaint process.l3e When a reliability standard requirement has not been met
and violations are identified, financial penalties and other sanctions may be levied. The appropriate
level of the penalties is based on guidance from FERC and NERC. These penalties can be up to 5L
million per day per violation.lao When a violation is identified, the parties use a NERC collaborative
review process to identify what happened with the goal of learning from it and improving operations
going forward to help insure that it doesn't happen again.
The eight Regional Operating Entities are further segmented into 18 Reliability Coordinators, who
monitor their systems in real time, providing overall reliability evaluations to the Operating Entities
(discussed below) within their regions. Reliability Coordinators are the highest level of operational
authority for their part of the grid, ultimately responsible for the reliable operation of the Bulk Electric
System within their footprint. They utilize operating tools, processes, procedures and authority to
prevent or mitigate emergency situations in both next-day and real-time operations.l4l Their wide-area
view allows them to calculate the lnterconnection Reliability Limits for their entire section, which is
typically beyond the perspective of the individualtransmission system operators or utilities.
NERC Reliability Coordinators
As of.lune 1,2015
o
o?
qed dryvatFv&q !&Oa6va\t-MhFry
Alberta flEtrtc syrtem opentol
tl(trk R€lirbtity Counct of Te6
Fldid. R.liability C@rdimtin6 Cornci
Hyd.o qEbcc TEGEnsSlc
EO N{ Engl8nd, Irc.
Mldondnent ISO
NGw 8runswl* Pffi r f.orpoEtlon
Ne Yorl lMepadat S!6l€m Opsator
O.rtarb lnd@€ndcnf Ebctricity Systm op€ato.
Pe.l [eli.bility
PIM lnteEmrEt6
Sashthewan fuwa Ctrpmdon
Southem Company ServlG, lm
SoudrEf Pm{er Pool
BA3 radn f,C *Y!t6 fiom SPP dWA
TennsE Valley Authdity
8As rEa'E nC mirr fiom WA q MEO
VACAn Sodh
13e Any person or company may submit a complaint to report the possible violation of a Reliability Standard to NERC or WECC. 'NERC-WECC
Compliance Monitoring and Enforcement Program," Janu ary 1 ,2011,
http://www.nerc.com/pa/comp/lmplementation%20Plans%20DU201 l Yo21WECCYo2}CMEP%20lmplementation%20Plan.pdf , page 21, and
https://www.wecc.bizlPages/Compliance-UnitedStates.aspx, "Compliance Hotline - Complaints."
140 United States of America before the Federal Energy Regulalory Commission, Docket #P110-4-000,
http://www.nerc.com/files/FinalFiled_Comments_on_PenaltyGuidelines%20(2).pdf. Note that the penalties can be very large. ln 2008 Florida Power &
Light was hit with a $25 million penalty, primarily based on business silos existing in the organization. http://provencompliance.com/web/blog/152-highesl
penalty-ever-u n related-to-an-event
141 For more details about the levels of entities set out by NERC and the responsibilities of each, please see; "Reliability Functional Model,"
http://www. nerc.com/f i les/f u nctional_model_vS_fi nal_2009dec1 . pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 80 of 128
a
I
AESO
sPc
soco
ERCOT
o
o
a
These 18 areas are further broken into Balancing Authorities and Transmission Operators. NERC
defines a Balancing Authority as "The responsible entity that integrates resource plans ahead of time,
maintains load-interchange-generation balance within a Balancing Authority Area, and supports
lnterconnection frequency in real-time." A Balancing Authority is the collection of generation,
transmission, and loads within the metered boundaries of the Balancing Authority, and they are
N E RC Bo lo nci ng Authoritie s
responsible for maintaining the load-resource balance within this area. Balancing Authorities manage
load, generation, and interchange schedules, regulation, frequency response, contingency reserves,
and area control error. They also manage reliability related services. A Balancing Authority does not
operate transmission facilities; that function is performed by a Transmission Operator.
A Transmission Operator is defined as "the entity responsible for the reliability of its 'local'
transmission system, and that operates or directs the operations of the transmission Facilities."142 The
Transmission Operator is responsible for operational control and real-time reliability of the Bulk
Electric System assets within its own area of the system. Avista is both a Balancing Authority and a
Tra nsmission Operator.
142 NERC T0P-001-1 at http://www.nerc.com/filesffOP-001-1.pdf and NERC "Reliability Responsibilities and Authorities,"
http://www.nerc.com/_layouts/PrintStandard.aspx?standardnumberTOP-001-
1a&title=Reliability%20Responsibilities%20and%20Authorities&jurisdiction=United%20States
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 81 ol 128
Avista
r
Geated udng Vfftyx Velo.ity tufte,
O 2016Vmtyr, an ABBCmpany FRCC
tsPcTE
ONT
AESO
PEAK
Western Electricity Coordinating Council
(wEcc)
Avista is a member of the Western Electricity
Coordinating Council (WECC), one of NERC's eight
Regional Operating Entities. The WECC is the largest
and most diverse of all the Entities, extending over 1.8
million square miles and serving over 80 million
customers from Canada to Mexico and the L4
Western states in between. The Western
lnterconnection is made up of approximately L2L,2O0
circuit-miles of transmission in 66 primary paths and
nearly 160,000 megawatts of resources.la3
NERC designated WECC as an "informed regulalsT't!44
for the Western United States, expecting this
organization to have a deep understanding of the
Western interconnection and the risks and challenges
this specific area faces, and to develop the
appropriate risk-mitigating measures and activities.las
The WECC facilitates its member's cooperation in
establishing operating processes related to physical
security, trai n ing, reporting, maintena nce, required
equipment, apparatus settings, performance
Major Transrnission Lines of the
Weste rn I nterconnectio n
Weste rn E lectric ity Coo rd i na ti n g Co u n ci I Tra ns m iss ion
System Typical Power Flow
o
o
a
expectations, vegetation management practices, etc.
It is also an enforcement entity. Typically, when a reliability standard has not been met, the entity will
self-report the issue to WECC with a mitigation plan. Additionally, WECC audits entities on a three year
cycle to ensure each entity is complying with the reliability standards.
NERC has also developed the Event Analysis Processlas which is a voluntary process the industry uses
to analyze Bulk Electric System events for root cause and to identify trends or emerging reliability
issues. The Regional Entities, WECC in this case, work with the reporting entity to ensure that the Event
Analysis reports are detailed as to what occurred, why it occurred, and how it can be prevented. These
events are tracked and trended to identify emerging system reliability issues and to improve overall
reliability by sharing the lessons learned from these events. The Event Analysis Process was put in
place by NERC in October, 2010.
143 Craig L. Williams, "Overview of WECC System Operations," WECC, May 4, 2015, https//www.wecc.bizlmwg-
internal/de5fs23hu73ds/progress?id=ath6s20HznCltlhNXnLRsB9VyRJmkJol wx0NpU 1 a8Eg,
144 iRegulatory Philosophy: Western Electricity Coordinating Council", September 21, 2016, https://www.wecc.bizlReliabilityMECC-Regulatory-
Philosophy-Final. pdf.
145 For a complete list of WECC Standards, please see https://www.wecc.biz/Standards/Pages/Default.aspx
146 For more information, please see: http://www.nerc.com/pa/rrm/ea/Pages/EA-Program.aspx
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 82 of 128
o
o
As a regional entity, WECC was initially responsible for developing, monitoring, and enforcing
standards for the reliability of the Bulk Electric System in the Western lnterconnection. However, FERC
raised concerns over the level of independence between WECC as a Reliability Coordinator and as a
Regional Operating Entity, charged with reliability compliance and enforcement functions. As a result,
in 2013 FERC granted WECC the authority to establish a separate, independent company to serve as
the Reliability Coordinator within the Western lnterconnection.laT This newly created entity is Peak
Reliability, a completely independent entity from the WECC. WECC continues to work with its members
to ensure the general reliability of the Western Grid, helps members develop forecasts, coordinate
operations, and perform planning functions. Peak is now the Reliability Coordinator for the Western
lntercon nection.
Peak Reliability
Peak Reliability (Peak), as a Reliability Coordinator, has the
highest level of operational authority in its footprint,
monitoring and ensuring the reliable operation of the bulk
electric system within the Western lnterconnection. Peak
monitors system frequency and identifies sources of Area
Control Error (ACE),148 system operating limit exceedances,
and inadvertent interchange.las Peak works with Balancing
Authorities, Generator Operators, and Transmission
Operators to ensure an uninterrupted flow of electricity to
consumers. They have clear decision-making authority to
act and direct actions to be taken to preserve the reliability
and integrity of the lnterconnection. Among the many tools Peak uses to do this are a system-wide
model, which provides them with a view of the entire Western Grid in real-time. Peak ensures that the
grid is operated within Operating Limits,lso monitors Time Error Correction,lsl coordinates and directs
restoration efforts if a blackout occurs, coordinates generation and transmission outages among
entities, and monitors general operations related to the grid.1s2
It should be noted that neither WECC nor Peak have jurisdiction over construction of transmission
facilities or any related siting, permitting, or cost allocation.
147 Troutman Sanders LLP, 'FERC Grants WECC Permission to Divide into Two Entities," June 24,2013,
http://www.troutmansandersenergyreport.com/2013/06/ferc-grants-wecc-permission-to-divide-into-two-entities/
148 Area Control Error (ACE) occurs when scheduled and actual generation within a control area don't match, which can place an undue burden on other
utilities, cause unnecessary generator control movements, etc. For more information about this see: "Balancing and Frequency Control,"
http://www.nerc.com/docs/ocirs/NERC%20Balancingo/o20ando/o2lFrequency%20Control%200405201 11.pdf
1ae lnadvertent interchange happens when more energy passes through a system than has been agreed upon, again impacting other utilities.
150 Operating Limits are the values of MW, MVAR, frequency, etc. that satisfy the most limiting operating criteria for keeping the interconnections stable
and reliable without violating NERC standards.
151 Time Enor occurs when the synchronous lnterconnection operates at a frequency different than the lnterconnection's scheduled frequency, resulting in
an imbalance between generation and loads/losses and creating lnadvertent lnterchange (when more energy passes through a system than has been
agreed upon.) For some interesting information about Time Enor and Time Correction, see Appendix H (page 92).
1s2 Peak Reliability Coordinator Plan, http//www.nerc.com/comm/OC/ORS%20Reliability%20Plans%20DUPeak_Reliability_RC_Plan_formatted.pdf
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 83 of 1 28
Peak Reliabilaty has 123 members
in l4 Westem States, British
Columbia, and Baja Calitomia,
Mexico
o
iak
)L
U.S. Power Markets
Northwest Power Pool
The Northwest Power Pool (of which Avista is a member)
is not a regulating body. lt is primarily a partnership
among its 32 membersls3 where public and private
utilities, system operators, and government agencies
coordinate operations and planning. This group
developed a number of communally beneficial programs,
such as a fully automated contingency reserve sharing
program which allows members to immediately cover the
loss of another member's generating unit. The NWPP also
provided the means to successfully negotiate the
Columbia River Treatylsa between the U.S. and Canada. ln
order to be ratified by Canada's parliament, one unified
NonrrrwEsT PowER
Poor- MgMeens
. Alberta Electic System Operator. Avista Corporation. Balancing Authoity ofNofthem
Californiao B.C Hydro. Bonneville Power Administration. Calpine Energy Solutions. Chelan County PUDc ColumbiaGid. Cowlitz County PUD. Douglas County PUD. Eugene Water and Electic Boardo FortisBC. Grant County PUD. Gidforce Energy Management. Avangid Networl<s. ldaho Power. NaturEner USA and Canadac NorthWestem Energyo NVEnergy (Nevada). PacifCorp. Pend Oreille PUD. Poftland General Electic. Powerex. Puget Sound Energy. Seaff/e CiW Light. Snohomish County PUC. Tacoma Power. Tutlock lnigation District / TID
Water and Power. U.S. Amy Corps of Engineers. U.S. Depf. of lnterioro Westem Area Power
Administration. Energy Keepers lnc.
o
o
stateside power entity was required so Canada would not have to deal with dozens of separate U.S.
utilities. The NWPP provided this platform. The NWPP is not, unlike FERC, NERC, WECC and Peak, a
regulating body, but it does have influence over Avista's practices and provides interconnection
benefits.iss Avista is a Balancing Authority within the NWPP.
153 In 2016 the membership of the Northwest Power Pool included: Alberta Electric System Operator, Avista Corporation, Balancing Authority of Northern
California, Bonneville Power Administration, British Columbia Hydro & Power Authority, Calpine Energy Services LP, Chelan County PUD No. 1,
ColumbiaGrid, Cowlitz County PUD No. l, Douglas County PUD No. 1, Eugene Water & Electric Board, FortisB0, Grant County PUD No. 2, GridForce,
lberdrola Renewable, ldaho Power Company, NaturEner, NorthWestern Energy, NV Energy, PacifiCorp, Pend Oreille County PUD No. 1, Powerex,
Portland General Electric, Puget Sound Energy, Seattle City Light, Snohomish County PUD No. 1, Tacoma Power, Turlock lnigation District, U.S. Bureau
of Reclamation, Western Area Power Administration-Upper Great Plains, and Energy Keepers, lnc. The U.S. Army Corps of Engineers was also involved
in the Northwest Power Pool as a signatory to the Paciflc Northwest Coordination Agreement, but was not a signatory to the Power Pool Membership
Agreement. The Northwest Power Pool covers an area encompassing eight states and two provinces.
lil Jim Kirshner, "Pacific Northwest Coordination Agreement to Manage Power and Water on Columbia River System is Signed on September 1 5, 1964,'
http//www.historylink.org/File/11207 and "Columbia River Treaty," https://www.bpa.gov/projects/initiatives/pages/columbia+iver-treaty.aspx For
information on the Columbia River Treaty, please see: https//www.crt2014-2024review.govl
155 For more information about the NWPP, see: http//www.historylink.org/File/11199
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 84 ot 128
o
)
Southeast
-- l
O
o
ColumbiaGrid
ln late 1999, FERC Order 2000 was issued. This Order encouraged a system of RegionalTransmission
Organizations (RTO) and lndependent System Operators (lSO).1s6 lt was believed that this system
would further separate the control of transmission
from power marketers, as these organizations have no
financial interests and are not controllable by
marketers; they are completely neutral. FERC
subsequently issued Order 890, which required every
FERC-ju risdictional transmission provider to
participate in a coordinated regional transmission
planning process.
Following an
extended series of
public processes,
two primary
regional
transmission
planning
organizations were
developed in the
Pacific Northwest:
ColumbiaGrid and the Northern Tier Transmission Group. Avista
complies with FERC's transmission planning requirements through its
membership in ColumbiaGrid,lsT a Washington-based non-profit.
Due to the large presence of non-FERC jurisdictional entities in the
Northwest, ColumbiaGrid's processes were carefully constructed to
enable participation by these entities. ln the independent spirit of
the Northwest, ColumbiaGrid only performs those transmission-
related functions that its members request.
KEYAITB\S oF REGUI-AToRY Focus
Since June of 2007 , NERC has implemented mandatory Reliability
Standards related to the Bulk Electric System. Reliability Standards
addressing system models, system planning methodologies,
operating requirements, facility rating methodologies, personnel
training, and other issues generally covering all aspects of grid
North American lSOs:
r California ISO
e New York lndependent
System Operator
r Electric Reliability
Council of Texas
o Midcontinent ISO
o ISO New England
o Alberta Electric System
Operator
North American
RTOs:
r New Brunswick Power
System Operator
o Ontario ISO
o PJM lnterconnection
o Southwest Power Pool
Non-RTOs: Western
Reeional Planning
Organizations
r Columbia Gridr Northern Tier
Transmission Group. Westconnect
o Colorado Coordinated
Planning Group
o
156 The differences are very subtle. Both operate a regional, multi-utility grid, coordinating, controlling, and monitoring multi-state utilities, though an RTO
typically covers a larger geographic area. RTO's have a closer tie to FERC regulation and have some added responsibilities, playing a more "hands-on"
role in operating the system.
157 ColumbiaGrid members: Avista, Bonneville Power Administration, Tacoma Power, Chelan County PUD, Grant County PUD, Puget Sound Energy,
Seattle City Light, and Snohomish County PUD. The othertransmission planning group in the northwest is the Northern TierTransmission Group, which
includes ldaho Power, Deseret G&T, NorthWestern Energy, PaciflCorp, and Portland General Electric. For more information about ColumbiaGrid, please
see: https://www.columbiagrid.org/
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 85 of 128
rdss:cunEnl l,lrssltr{ sluo8r
n /colltmDl.crl0
/r./ OtiiTtl|triltgon
coiumDtsGrld
III-
\\
ooperation and performance have been established. The intent of the Standards is to prevent a
cascading and widespread blackout due to any credible contingency. There are currently approximately
100 NERC standards applicable to Avista. This number varies over time as new standards are developed
and others are retired. Each Standard also has multiple Requirements which vary by Standard.
NERC Reliability Standards are designed to facilitate the engineering and construction of a power
system that can be operated safely and reliably under all expected operating conditions. These
expected operating conditions include the loss of generation resources or the credible outage of a
transmission facility. The loss of a single system element is commonly called an N-1 operating condition
or criterion. The normal system, with N elements, must be safe and reliable under the worst expected
single contingency (N-1). ln real-time operations, the system must always be in a configuration where
the system is safe and secure for the next contingency. This second sequential contingency is often
called the N-1-1 situation. Maintaining a safe and secure system for the next contingency requires:
1.. A System Planning methodology that considers outages of key facilities due to planned or
unplanned outages;
2. Operation of the system such that the system is always prepared to suffer the next contingency
without creating cascading outages (a secure system);
3. Adequate generation resources to serve load;
4. Adequate generation reserve to replace generation lost due to a contingency.
The NERC Reliability Standards essentially codify the four previous points. lt is important to note that in
real-time operations, there are nearly always one or more facilities out of service due to maintenance
or a forced outage. Operating to maintain system reliability under the next contingency in real-time
can be very challenging, and requires careful planning and coordination of scheduled outages both
internal to Avista and with external entities. lt is essential that the planning and construction of the
system be done to facilitate real-time operation of the system as it is actually operated.
The Mechanism of a GascadinEl Outa$e
NERC clearly recognizes that failures will occur:
"The brutol facts, os they say, ore thot utilities connot offord to build or operate the interconnection to avoid
all risks. The generotion and tronsmission systems ore finite ond limited and alwoys will be. At some point,
the failure of o significant number of tronsmission lines will couse part of the lnterconnection to become
unstable and lose its integrity, regardless of outomotic or system operqtor octions. And hurricanes ond ice
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 86 of 1 28
o
* Unscheduled loss
of geneEtion
'Single Fault
i comblnation of
Above
'UnexpectedHeaw Loads
Trigger
I Del.y in takint
+ Delay ln
GEspint
Situation
D.lry in
communieting
with nelthboB
mititating
action
ln
Response
t Power Oscillation
I Overloading
t voltage
Oeclines
r Loss of
Synchronism
* Frequency
Lines
'GeneBtors
' TEnsformeE
I Combination
of Above
o
Event Action
o
o
o
storms will take their toll. All the world's money connot construct an electric system robust enough to
remoin unscothed from extremely unlikely ond extremely severe events. While the consequences moy be
vdst, some risks ore simply unavoidoble. Saying these consequences ore also unacceptoble is moot. Soying
we don't want the events to hoppen is obvious. The important point is that we plon ond operote the
lnterconnection so that credible contingencies result in acceptable performance. And ofter these
contingences hoppen, the system operator is oble to adjust the system to be oble to hondle the next credible
contingency."lss
That being said, the goal remains to keep the interconnection strong and stable through routine and
expected events such as loss of a generator, a transformer or a
line. FERC and NERC strongly believe that, though it is
impossible to eliminate risk, proper planning and operations
will reduce such risk, and that proper planning will ensure that
after contingences happen, the system operator will be able to
adjust the system to handle the next credible contingency and
restore the system to full performance as quickly as possible.
As mentioned earlier, mandating the manner in which utilities
plan their transmission systems is one piece of the FERC/NERC
requirements puzzle. Operating the system is another. Several NERC Standards are related to
transmission operations. System Planners perform long-range (greater than one year into the future)
planning studies to design the system so it can operate within specific parameters of safety and
reliability, and to be able to withstand events that may cause failure or outages. Operations Engineers
study and plan for reliable system operations in the next day to next year timeframe. System Operators
are responsible for ensuring that these well planned systems operate as intended and within very
specific parameters in real time.
To NERC, interconnection integrity and equipment protection are a priority, as it believes that
customer service depends upon maintaining the integrity of the interconnection and protecting
generation and transmission equipment from catastrophic damage. lts goal is that the system is
planned and operated in a way that if "credible contingencies/1ss occur, the system can isolate these
events, preventing them from causing the interconnection to fail with a cascading outage.
It is expected that this methodology will prevent customers from
losing service, as the grid (and its operators) will respond in a
way that maintains reliability to meet the sudden need for
increased generation or to re-route around a failed facility.
NERC's goal is always to maintain customer service, but not at
any cost - it states clearly that a short term customer outage is
preferable to loss of interconnection integrity or damage to
equipment (which would ultimately result in longer term
customer outages). Thus, System Operators manage risk in real time by monitoring and controlling
158 NERC Reliability Concepts, Version 1.0.2, http://www.nerc.com/files/concepls_v1.0.2.pdf
15s A'bredible contingency" has two attributes: 1) plausibility / believability and 2) likelihood / probability,
Exhibit No. B
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page87 of 128
-,si
ogenerating dispatch and reserves, line flows, voltage profiles, load-generation balance, etc. This is done
for two primary reasons: 1) to maintain interconnection integrity, and 2) to protect generation and
transmission equipment from catastrophic failures and/or damage. The operator's success in achieving
these expectations during normal operating conditions, emergencies, and system restoration activities
directly impacts customer service in the short and long term.
Open Access to Transmission Markets
The North American electric system was originally designed to meet each utility's own native load
customer needs for both average and peak loads and, secondarily to connect the utilities to each
other to support inter-utility transacti
and provide greater reliability for the
entire system. This system is, as we have
noted, highly regulated by FERC and
overseen by NERC and its eight Regional
Operating Entities. However, increasing
pressure to make the electric market
more competitive and to allow non-
traditional parties to participate in
buying and selling energy pushed FERC
into considering options to address these
concerns.160
ln 1996 FERC issued Orders 888 and
889,161 which forever changed the
manner in which electricity market
participants gain access to transmission systems. Order 888 required public utilities to provide "non-
discriminatory" open access to their transmission systems, and to provide transmission service to
others under the same rates, terms, conditions and service priority that they provide for themselves
and for their native load retail customers. lntending to facilitate a competitive wholesale market for
energy, Order 888 opened the national
transmission system to electric market
competitors, created functional separation
between transmission and marketing functions,
required a standard form of open access
transmission tariff, and gave utilities with large
stranded investments (if they went through
restructuring) the ability to recover those costs
160 Electricity 101 graphic courtesy of http/islideplayer.com/slide/10915029i Slide 7.
161 For more information about Order 888 and Order 889, please see: https://www.ferc.gov/legal/maj-ord+eg/land-docs/orde1888.asp and
https //www.ferc. govilegal/maj-ord-reg/land-docs/rm95-9-00k.lxt
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 88 of 1 28
o
Electricity lil:
Expanding Your Utility Vocahulary
Open Access Some Time lnformation System (OASIS)
An electronic information system that allows users to instantly receive
data on the current operating status and transmission capacity of a
transmission provider. FERC established standards for OASIS in Order No.
889. OASIS is designed to provide
infurmation on:
-The availability of transmission services
-Hourlytransftr capabilitiesbetween control areas
-Hourly amounts of firm and non-firm power scheduled at various
points
{urrent outage information
-Load flow data
{urrent requests for transmission service
-Secondary market anformation regarding capacity rights that
customers wish to resell
[I4'
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qx i)
, s'l,(J
Ancillary Services for OASIS:
Sources
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from customers. lt also unbundled transmission related charges, specifying a set of ancillary services.
Ancillary services are system support services required to reliably operate the transmission system and
a control area (such as load regulation, operating reserves and voltage control) and must be offered by
each transmission provider and purchased by each transmission customer. These ancillary services
must be offered and purchased individually rather than being bundled together when transmission
service is provided. ln essence, this Order enabled open access to the entire transmission system with
the goal of reducing customer costs, adding increased reliability, and facilitating a competitive market
for wholesale electric services.
With its companion order, Order 889, FERC sought to insure that transmission owners cannot have an
unfair advantage over other market participants by having priority access to transmission information.
This Order outlined the transmission capacity information that must be publicly available, and required
each transmission provider to create a bulletin board to use in posting its information, called OASIS
(Open Access Same-Time
lnformation System). An
OASIS is used to offer and
reserve transmission
capacity on each public
utility transmission
system. These bulletin
boards are entirely
internet based, and public
access is limited to eligible
parties: electric utilities
(investor-owned, public
power, co-ops), federal
power agencies, Canadian
and Mexican utilities that
participate in the grid, or
individuals generating
electric energy for sale at
wholesale rates.162
Gradually the transmission business has become a confusing mixture of regulated and unregulated
services, with various companies controlling fragmented pieces. However, Avista has migrated
successfully in accepting and adapting to these Orders, though implementation has added significant
costs and operational issues and constraints.163
162 Note that retail customers can only obtain unbundled transmission service pursuant to state requirements or a voluntary offer of such service by a
transmission provider. Entities that engage solely in brokering energy are also not eligible, as they do not take title to electricity and therefore do not
engage in the purchase or sale of electric energy, nor do they generate energy. Findlaw "FERC Reaffirms and Clarifies Groundbreaking Rules on Open
Access Transmission, Recovery of Stranded lnvestment and Operation of Open Access Same Time lnformation Systems,"
http://corporate.findlaw.com/litigation-disputes/ferc-reafflrms-and-clarifies-groundbreaking+ules-on-open-access.html and see Marcel Lamoureux,
"FERC's lmpact on Electric Utilities,' http://ieeexplore.ieee.org/stamp/stamp.jsp?arnumber=948252
163 The (U.S. Electricity Timeline" chart source: "A $48 Billion Opportunity for U.S. Electric Customers," John Farrell, December 15,2014,lnstitute for
Local Self-Reliance, https://ilsr.org/u-s-utility-customers-save-48-billion-solar-efficiency/
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 89 of 1 28
*- wind dnd soldr
Per copito eledricity use
Averdqe annual retail electricity prices
- lnterstdte tronsmi$ion spending
-
. Statesadoptenergy
,i;ri;v;;;
Sourcet: woild Bonk, tl4 US Ceksut, 5El4 LBNL
go
a2(x)O 2010
non-offergenerdtion
IISR
STABILITY DEREGULATION
@@@
The U.S. Electricity Timeline
. Regulatedmonopolies
and net metering
. lndependent
produceE rise, as
do interstate
transactions
. Prices fall. Demand rises
MARKET
CHANGES
. Prices rise. sales slow. Competition starts
RULE
CHANGES
generation
sales
. Profits from sales. Profits fiom new
power plants. 'bigger is bette/'
. Fedsopenwholesale
market. Statesadopt
renewable standards
o
"GOLDEN AGE"sHocK &
Aeezxptx C: Tng NartoNet Tna,Ns*ttsstoN Gnp
The national transmission grid, of which Avista is a part, connects utilities in North America to each
other. This interconnectedness has several key advantages:
1) Provides enhanced reliability by diversifying both intermittent generation sources (such as wind or
solar) and base load resources (such as hydro or coal), managing variances in generation and load
across regions rather than just locally.
2) Enables remote generotion resources - plants can be built in lower cost locations. Remotely sited
resources (including renewables) can be integrated onto the grid and their energy sent to where
demand exists, regardless of the plant's physical location.
3) Allows access to multiple generation resources even those outside a utility's own system. lf one unit
fails, the others on the system automatically increase to compensate. Mitigates interregional
swings in load patterns; resources across a wide region can react and compensate. With
interconnection, more resources are made
available to make up for the variability, and utilities
are able to aid each other upon loss of resources or
equipment. Customers are less likely to suffer an
outage.
4) Affords more poths over which bulk electricity can
flow, so if one path is lost, there are other options
to keep the power flowing.
5) Reduces the need to invest in transmission
infrastructure, as a utility may not need to build a peaking facility if they can contract for that
energy with another utility. Creates synergies between various transmission systems and utilities.
6) Multiple generators, owners, and costs provide economic competition, helping keep electric rates
lower and providing opportunities for utilities to sell excess energy to others or shop for energy
needed to meet their own loads with price competition,
ultimately reducing the costs to their own customers. Creates
valuable trading opportunities across regions, and a
competitive market for energy.
7l Reduces costs; allows lower cost resources to operate at
optimum levels, as the output can be utilized across a wide
area of load so these resources don't need to be backed down
when regional load fluctuates. This is both cost effective and
also easier on this equipment mechanically.
8) Provides additional levels of safety ond fdult tolerance margins; more resources are available to
meet reserve requirements system-wide.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 90 of 1 28
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9l Provides insurance. Each utility is able to set aside less extra capacity in reserve in case of
emergency; they know they can count on each other, so more of their generation can be used to
provide service to customers ratherthan being held in reserve, reducing risk and cost.16a
However, there is one distinct disadvantage: the interconnections give
system instability a wider channel over which to spread, and the sheer
geographic size and diversity make it difficult to protect assets.
Regardless, it is clear that a reliable and secure national grid and the
interconnections it offers is in the best interests of customers across
the nation.
As mentioned, the power grid is made up of many power generators,
connected by transmission lines and substations. ln order to work
together, all of these generators must be synchronized, with equal line
Bell-Westside 230 kV Linethat voltage, frequency, phase angle, phase sequence, and waveform. An AC
Avisfa shares with BPA generator cannot deliver power to the grid unless it is running at the
very same frequency as the network. Connecting a synchronous generator to a large interconnected
power system is a dynamic process, requiring a coordinated operation of many components and
systems, with the goal of connecting a spinning generator to the system without causing any bumps,
surges, or power swings. lf a unit is brought online
without being synchronized to the exact frequency of
the operating grid, anything from a very loud bang to
complete destruction of the unit is possible. Even
rotating a little too fast or slow can cause a rapid
acceleration or deceleration of the rotating parts and
shear bolts or damage the shaft. ln addition, as the
external grid tries to "pull" the unit into line with the
rest of the grid, transient power flows can be created,
damaging equipment or creating oscillations that can
ca use cascading outages.lss
Turbine failure in Australia when it went out of
Normally a power grid is stable and does not oscillate on synchronization^y':!^'!'grid and its protection
its own, but under certain conditions oscillation can equipmentfailed
happen if an attached generator becomes overloaded and lags behind, falling out of phase with the
other generators, or if controls designed to keep the generator from lagging take too long to kick in.
Special protective equipment is used to automatically synchronize generators to the grid at precisely
the right frequency and to protect the integrity of the grid.
164 United Nations Sustainable Development Knowledge Platform, "Economic and Financial lmpacts of Grid lnterconnection,"
http://www. u n.org/esa/sustdev/pu blications/energy/chapte13. pdf
165 fs1 3 great discussion on oscillation, please see: 'An Overview of Power Grids," https://midimagic.sgc-hosting.com/powgrid.htm and
https//www.linkedin.com/pulse/south-australia-powering-up-grid-takes-time-justin-wearne
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 91 ot 128
I
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1
.i
AeesNotx D: AC Vsnsus DC Lntss o
Most transmission lines are high voltage three-phase alternating current (AC), though high voltage
direct current (DC) lines provide greater efficiency over very long distances with very little line losses.
However, AC has a couple of distinct advantages: large electrical generators happen to generate AC
naturally, so no conversion is required, and AC equipment is ultimately less expensive when it comes to
repair, maintenance, and equipment costs. Expensive (and very large) converter stations are needed at
each end of a DC line to convert its power to a usable level for customers. ln addition, transformers
don't work for DC power and the ability to change voltages is important, as different classes of loads
(for example lighting versus motors) require different voltage levels.
The AC and DC options have been compared to a local versus an express train. Localtrains (AC lines)
allow people to get on and off at different stops with a great deal of flexibility, but are not efficient if
from Northwest hydropower plants can hop on the DC lntertie and run directly to L.A. ln the winter
when the Northwest's reservoirs are largely depleted, Southern California can help with Northwest
winter heating peaks by sending generation to the north. DC lines allow very large amounts of power
to efficiently flow north or south depending on the different regions' peaking needs.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 92 ot 128
l-
n
fl o
o
TEnsmision Nominal
Voltage: +/-.loo kv
HVDC
Type: Tower
Typical Tower Height:
145-18(l feet
Typical Right-of-Way
width:
16()-1AO feet
TEnsmission Nominal
voltage: 161 kv
Type: single Pole
Typical Tower Height:
7O-95 feet
Typical Right-of-Way
width:
1OO-150 feet
Transmission Nomiml
Voltage: 5OO kV
Type: Tower
TypiGl Tower Height:
9{F15O f€et
TypiEl tught-of-way
width:
16ll-2OO feet
TEnsmision Nominal
volt ge: 345 kV
Type: Double Ckt
Pole
Typical Towtr Height:
115-15{l feet
Typical Right-of-way
width:
1,llF16() feet
TEnsmi$ion
Nominal Voltage:
23{1 kV
Type: H-Frame
TypiGl Tower
Height:
60-90 feet
Typical Right-of-way
\rvidth:
1OO-160 feet
f
Traremision Nominal
Voltage: ll5 kv
Type: single Pole
TyIliGl Tower Height:
55-80 fet
Typicl Right-of-Way
width:
9{F13O feet
TEnsmision Nminal
voltage: 69 kv
Typ€: sitrgle Pole
Typicl Tows Height:
5l}-70 feet
Typical Right-of-way
Mdth:
7O-1OO feet
the end of the line is your
destination. Express trains (DC lines)
can move a lot of people over a long
d istance extremely efficiently, but
with limited flexibility. However, DC
systems compliment AC systems
nicely. ln the United States, DC lines
are used to connect to AC systems
that are not synchronized, allowing
the transfer of power from one AC
grid to another (such as the Eastern
and Western lnterconnects, which
are slightly out of phase.) lt is also a
very attractive option in connecting
remote areas with complementary
power needs, as with the Pacific
lntertie, which runs from Oregon to
Southern California. In the summer,
the Pacific Northwest typically has a
lot of hydropower available just
when Los Angeles can use extra
power to cover its big summer air-
conditioning peak. Power generated
tr
A
f
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o
Aeegr,tptx E: NERC Conngcrtvz AcrroN EvsNrs
Category lnitial Condition
&ent r Fault Typo BES Level lnterruptlon of
Frm
Transmission
Seruice
Allfled.
i,lon-
Consequential
Load Lcs
Allowed
PO
No Contingency Normal System
None N/A EHV HV No No
Loss ofone ofthe following:
1. Generator
2. Transmission Circuit
3. Transformer s
4. Shunt Device 6
30
Normal SystemP1
Single Contingency
5. Single Pole of a DC line SLG
EHV HV Nos Norz
1. Opening of a line section wlo ataullT N/A EHV HV Nos Norz
EHV Nos No2. Bus Section Fault SLG HV Yes Yes
EHV Nos No3. lnternal Breaker Fault 8
(non-Bus-tie Breaker)SLG HV Yes Yes
Single Contingency
P2 Normal System
4. lnternal Breaker Fault (Bus-tie Breaker) s SLG EHV, HV Yes Yes
Loss ofone ofthe following1. Generator2. TransmissionCircuit
3. Transformer s4. ShuntDevice6
30
Multiple Contingency
P3 Loss of generator unit
followed by S)6tem
adjustmentse
5. Single pole of a DC line SLG
EHV HV Nos Norz
EHV Nog NoLoss of multiple elements €used bya stuck
breaker ldnon-Bus-tie Breaker) attempting to
clear a Fault on one of the following:
1- Generator
2. Transmission Circuit
3. Transformer 5
4. ShuntDevice6
5. Bus Section
SLG
HV Yes Yes
P4
Multiple Contingency
(Fault plus stuck
breakero)
Normal S)6tem
6. Loss of multiple elements €used bya
stuck breakerlo (Bus-tie Breaker) attempting to
clear a Fault on the associated bus
SLG EHV HV Yes Yes
EHV Nos No
P5
Multiple Contingency
(Fault plus relay
failure to operate)
Normal System
Dela!€d Fault Clearing due to the failure of a
non-redundant relayr3 protecdng the Faulted
element to operate as designed, ior one ofthe
following:
1. Generator
2. Transmission Circuit
3. Transformer s4. ShuntDevice6
5. Bus Section
SLG HV Yes Yes
Loss ofone ofthe following
1. Transmission Circuit
2. Transformer 5
3. Shunt Oevice 6
EHV HV Yes Yes
P6
Multiple Contjngency
(Tw ovedapping
slng/es)
Loss ofone ofthe
following followed by
S! stem adiustments.e
1. Transmission Circuit
2. Transformer s
3. Shunt Device6
4. Single pole of a DC
line 4. Single pole of a DC line SLG EHV HV Yes Yes
P7
Multiple
Contingency
(Common
Structure)
Normal 5)6tem
1 . Anytwo adjacent (wrticallyor horiantally)
circuits on common structure 1,
2. Loss ofa bipolar DC line
The loss of:
SLG EHV HV Yes Yes
Table 1 - Steady State & Stability Performance Planning Events
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 93 of 1 28
o
Aepgrtotx F: Strtrto TnaNsnpstoN LtNgs
It is important to note that transmission planning and construction is becoming increasingly complex. lt
used to be that utilities planned for reliability and facilities based on local load growth, generation and
load interconnections. With FERC and NERC regulations in place, utilities must now plan for strictly
regulated reliability requirements; they must develop system hardening and resiliency to minimize
adverse events (primarily related to terrorism and vandalism), accommodate ever-changing public
policy regulations and the associated uncertainty, enhance grid security, consider impacts on
neighboring utilities and the interconnected system, and provide ever greater
flexibility in operations. ln addition, transmission is impacted by shifts in
generation such as increasing numbers of renewable resources and reductions
in traditional generation sources. All of these issues often require adding or
enhancing transmission.
Building transmission lines presents a number of constructability issues, with
three primary barriers: public opposition, environmental concerns, and
regulatory complexity. Although FERC has jurisdiction over interstate
transmission commerce and the federal government has authority over siting
transmission lines on federal lands (which make up a significant percentage of
land in many western states), states retain jurisdiction over actually permitting and siting transmission
lines, even if they cross state lines. Generally, states define transmission lines as a public use, which
allows the application of eminent domain upon payment of just compensation under the Fifth
Amendment to the U.S. Constitution. ln Washing1sp166 and ldaho157, utilities can condemn properties
to build transmission if it is determined to be for public use, with each state having a process that must
be completed before this can occur. Washington gives counties broad eminent domain powers and
declares that the exercise of these powers is a public use when "it is directly or indirectly,
approximately or remotely for the general benefit or welfare of the county or of the inhabitants
thereof" (Rev. Code of Wash. S 8.08.20).168
ln Washington, the Washington Energy Facility Site Evaluation Council is responsible for siting
transmission of 115 kV or greater in agreement with localjurisdictions. The process for obtaining site
approval for electric transmission facilities in Washington comprises several steps, including
undergoing a preliminary site study, completing a detailed application proposal, public hearings, a
recommendation to the governor, and finally a Site Certification Agreement (SCA) executed by the
Governor.l6e lt typically involves a detailed Environmental lmpact Statement as well as air, water, and
hazardous waste permits. lnterestingly, in Washington the applicant is not required to demonstrate
the need for transmission, because the Washington State Legislature has already declared the
"pressing need for increased energy facilities" in the state.170 ln addition, the Council is explicitly
166 US Legal, 'Washington Eminent Domain Laws," https://eminentdomain.uslegal.com/state-laws-on-eminent-domain/washington/
167 US Legal, "ldaho Eminent Domain Laws," https//eminentdomain.uslegal.com/stateJaws-on-eminenldomain/idaho/
168 Kevin E. McCarthy, "'Public Use' and Eminent Domain," OLR Research, July 27 ,2005, https//www.cga.ct.gov/2005/rpU2005-R-0570.htm
16s James A. Holtkamp and Mark A. Davidson, 'Transmission Siting in the Western United States," 2009,
https://www.hollandhart.com/articles/transmission_siting_white_paper_flnal.pdf
1zo Washington State Legislature WAC 463-60-021, http//apps.leg.wa.gov/wac/default.aspx?cite=463-60-021
Exhibit No. B
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 94 ol 128
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prohibited from considering the fuel source of the electricity carried by the proposed transmission
facilities.lTl
One of the problems with state authorization is that each state will
naturally focus on the needs of its own citizens. However, interstate
transmission lines provide regional or even national benefits that may
overshadow any in-state benefits. This is particularly true for long
distance transmission lines that bring renewable energy from remote
locations to population centers that may be one or even several states
away. While the state with the long distance transmission line crossing it
may see minor benefits in increased grid reliability, that benefit may not
be outweighed by physical impacts to property, viewscapes, natural
resources, or the environment that the state must face.
Another issue creating significant time delays is allocating costs among
the various entities that would benefit from the line and ensuring that the line meets the requirements
and needs of all affected parties, as touched upon in the regulation section above. Obtaining funding is
also an issue. ln addition, costs for raw materials are increasing rapidly; the United States is competing
in a global market for transformers and other components of the electrical system. The United States
currently imports 85% of its large power transformers, competing directly with rapidly expanding
electric systems in China, for example, for raw materials and limited production.
Siting transmission can also be a polarizing issue, sometimes requiring years to get through. Not only
are utilities dealing with the familiar NIMBY principle (Not ln My Back Yard), but they are now seeing
more extreme positions (such as BANANA: Build Absolutely Nothing Anywhere Near Anything). lssues
including public opposition, environmental and geographic constraints, interagency coordination
problems, and local, state, and federal regulations all create huge barriers to permitting and
construction. Given the scope of the constraints affecting new projects, siting transmission is a broad,
complex problem for which solutions are not obvious or well understood. To make matters worse,
transmission lines are particularly visible and impact multiple government agencies, all of which have
their own agendas.
A siting study by Holland and Hart sited a "bewildering variety" of federal, regional, state and local
requirements for siting, building, and operating a transmission line. Their study noted that not only do
many people object to the aesthetic and other impacts of a major power line in their own
communities, but there is a growing number of objections to power lines in remote areas due to
environmental and recreational impacts.172 One estimate is that actually getting a new transmission
line built can take up to 10 years or longer.173
171 ln otherwords, no favoritism is allowed for renewable resources. Washington State Legislature Washington Revised Code Title 80. Public Utilities g
80.50.045, http://codes.findlaw.com/wa/title-80-public-utilities/wa-rev-code-80-50-045.html
172 James A. Holtkamp and Mark A. Davidson, 'Transmission Siting in the Western United States," 2009,
https://www.hollandhart.com/articles/hansmission_siting_white_paper_final.pdf.
173 Gail Tverberg, "The U.S. Electric Grid: Will lt Be 0ur Undoing?" May 7, 2008, http://www.resilience.org/stories/2008-05-07/u-s-electric-grid-will-itbe-
our-undoing/
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 95 of 128
o
AeegNorx G: Cg,aNGING W4aTHER P*IIaNTTS
Below are several charts showing data related to weather, most of which were put together by the
National Oceanic and Atmospheric Administration or Munich Re, a widely respected worldwide
insurance provider. These charts indicate the increasing number of large weather events that impact
the grid:
Above Source: Munich Re
Above Source: NOAA
Chort Below Source: Munich
Nofe: Munich Re is on
i nt e r n otio n ol insuron ce
compony widely
recognized for their
experfise on weother-
reloted disosters.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 96 of 1 28
o
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U.S. Winter Storm lnsured Loss Trends,198O- 2016,il: t birrions)
1080 1982 t08{ t9S6 lEr 19re i992 1991 19S l$a 2000 20@ 200r Aqr m 2010 2012 2014 2016
E6dresEqqE
Soutce: {f 2Ol7 Munkh Goo PlslG 20i-NatCntSERVICE As ol
&M!*&06rE.spdc
I hsuEdl6s
lio 2015 veruc5l
- Sytu mem
l,',,,,,,,1,,,,,1,,,,l,,ilhlllilh
This figure showsthe percentaae ofthe land area ofthe contiSuous48 states where a much
greaterthan normal podion oftotal annual pr€ipitauon has come frcm extreme single-day
precip:tation ryents- The bas represent indMduatyeas, while the line is a nineyearweighted
Disasters on the rise
The chat stpffi he nmlber of dE6tss hat causM at lesl 51 tilEon h damage.
Extreme One-Day Precipitation Events in the Contiguous2lS States, 19lO-2O15
25
I
1920 1970 1950 19aO 1990 2000 2010 2020
average-
ecg8ts3s:Ec8g38B9s:9
'P9999g999RRRRR8BRR
o
191O
zo
E15
cio
4
1940 1960 1970
Yeat
Number of World Natural Disasters 198O-2O{6
900
000
400
2m
I C.{phyrF.lcYcl|ts(ElrfEutQ. GlJMi.
volcrib ldiviy)
I ua&orolo(rlcrl avarlr3
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I Hydrologlcrlevents(FH.@r!@@it)
I ctlrotdoghrlc6ls(€Irffi temperdur.
&ilEllltoro.rtc)
1e80 19€2 1e8t i086 ',rC0a r0t0 1e02 lelt 1ee0 1gt8 ?000 ?002 20(}1 20oc
Sourre: Nunich Re. Geo Risks Res€arch. 20t7
2010 mrz 2014 2010
Numhr
A{aadd#M(tdlbx@HBduFffcddmfr6br6: Lrst lG. 3U(. lm.6lnO(F6g @ llr 6rrrd l'rd&*cm rqf dh sfthd rsEr)o
a
3
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Since 1930 electric clocks have kept the time based on the rate of the electrical current that flows
through them at 60 cycles per second (though it often varies between 59.98 and 60.02). lf that current
changes, clocks run a little faster or a little slower. Utilities take steps to keep the frequency of the
current - and thus the time - as accurate and precise as possible.
This all started in 1916, when Henry E. Warren invented the self-starting
synchronous motor. Three years later the motor was used for the
production of the Telechron Clock. The Telechron Clock was a
synchronous electric clock which used alternating current (AC)
electricity to measure time. lts accuracy depended on the frequency of
the power grid. To incentivize electric system operators to regulate
frequency in a way that kept the clocks running accurately, the Warren
Clock Company, which was manufacturing the Telechron Clock at the
time, gave free electric clocks to electric system operators. The idea
worked! System operators began regulating the frequency as desired by
the Warren Clock Company.
During the L920s, other companies developed synchronous motor
clocks and used the same marketing strategy, giving away electric clocks
to system operators. ln 7926 Lauren Hammond gave away hundreds of
electric clocks with synchronous motors to power station owners, encouraging them to maintain a
steady 60-cycle frequency. His inexpensive clocks became "uniquely practical" in homes and
businesses as well. The message began to spread. As the penetration of the synchronous electric clock
increased, the incremental electric revenue to utilities from the additional electric clock motors
justified the relatively small cost to utilities to regulate system time by modifying system frequency.
This additional revenue helped ensure that manual Time Error Correction (TEC) would be an ongoing
service provided by the electric utility industry, and that remains the case today.
As the electric system became more interconnected, the service of providing manualTEC was
incorporated into the industry's general operating practice. The current form of manual TEC is a legacy
commercial practice that originated in the L920s as a commercial service and was not related to the
reliability of the electric grid. While documentation is available from as late as 1976 that synchronous
electric clocks are still being used for important applications, by 1969, alternative methods of keeping
accurate time penetrated the market and gradually displaced the electric clock. For example, the
introduction of the first mass-produced quartz watch provided a more reliable and less expensive
method to keep accurate time. Additionally, L5 years later, the United States made the Global
Positioning System available for free, which is a space-based satellite navigation system that provides
location and time information. However, today power network operators still regulate the daily
average frequency so that electric clocks stay within a few seconds of the correct time.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page97 ot 128
AeesNotx H: How Tng Gnn CortraoLs Tttwg
Wrun
SELF.STARTING
ELECTRIC CTOCKS
%:
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Using near-term system models,
Operations Engineers perform studies
covering the next day to the next year
by modeling loads, resources,
transmission configuration, outages,
reactive support, operating limits, and
interchange schedules to insure that
strategies are in place to manage their
respective portions of the
lnterconnection and to be prepared
for the next credible contingency (or
worse). Operations Engineers and
System Operators are responsible for
keeping the system within its
operating limits, mitigating
unexpected events, and restoring the
system if, heaven forbid, a blackout
occurs.lTa
"You can't just look at your system.
You've got to Iook at how your
system affects your neighbors and
vicg velsa." - Arshod ll4onsoor, vice president
of power delivery ond utilizotion with the Electric
Power Reseorch lnstitute (EPRI)
Separate
ngiloflal
lamlted
HIO{E:5t CAPACITY
FoWEE UI{ES (ldorolB)
-
5r0O to525
-
7!5to76)
-
Dtectcun.nt
But tednlcal oDclrdes m.ao tha grlds havr
to h€b ea(h othcr In e,rergendes,
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ln. lQl3lrnt rq.ul
o
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thtq56dl6.qlt,xE {a!md,(lsol l$ ara mEtld lq da,lry.
NERC Electrical System InterconnectionslTs
Avista's Operations Engineers develop System Operating Procedures (SOPs) that are reviewed and
updated annually. These Procedures provide System Operators a plan or road map in addressing
certain operating conditions or contingencies. Avista currently has 38 such SOPs.
System Operators go through extensive internal and external annual training and must be certified by
NERC prior to working in one of the two real-time system operations positions. The first position is the
Transmission Operator, who is responsible for all switching activity on the transmission system,
including communications with crews who are working on the
lines. The other key position is the Reliability Operator, who is
responsible for monitoring the Company's generation resources,
system load levels, and power schedules to, from, and across the
transmission grid. Avista must also coordinate all of its planned
outages of either generation or transmission facilities with all of
its regional neighbors to insure that the broader regional
transmission grid, under the purview of Peak Reliability, is able to
be operated reliably and that the potential impact of Avista's scheduled outages is mitigated.
The specialized positions related to operating Avista's system will be discussed in a bit more detail on
the following pages.
174 Note that a System Operator has NERC authorization to shed load if they see no other way to return the system to its acceptable operating limits within
an acceptable time frame.
175 Graphic counesy of Rebecca Smith, "U.S. Risks National Blackout From Small-Scale Attack," The Wall Street Journal, Marct 12,2014,
https://www.wsj.com/articles/u-s+isks-national-blackout-from-small-scale-attack-1394664965
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 98 of 1 28
o
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Outage Coordination
As mentioned, one of NERC's primary focus areas is grid reliability. As an interconnected system, each
utility's operations have the potential to impact their neighbors or even the entire grid. The Outage
Coordination Process is designed to provide a way to coordinate substation, transmission,
communication and generation outages in a waythat
ensures that the entire North American system is
operated in a known and reliable state and that outage
impacts are mitigated. NERC mandates the basic
requirements for outage coordination in Standards IRO-
917-fia and TOP-0033ttt which require every Reliability
Coordinator, Transmission Operator (TOP) and Balancing
Authority (BA) to have a specific process in place for
handling outages. Avista's Reliability Coordinator is Peak
Reliability (for more information on Peak Reliability, see
page 78).
Peak requires that outages be scheduled and submitted consistent with their Outage Coordination
Process, which includes an online tool called the Coordinated Outage System. This tool allows Peak to
collect and view all outages across the interconnection. Their operations
engineers utilize a modeling program that simulates the system so they
can study potential impacts on the grid. Peak reporting requirements
apply to their associated Balancing Authorities, who are required to
provide generation outage information. These reporting requirements
also apply to Transmission Operators, who are required to provide
transmission-related outage information. Avista is both a Balancing
Authority and a Transmission Operator within the Peak jurisdiction, and
has an Outage Coordinator who is responsible for managing both areas.
At Avista, the Outage Coordinator position is filled by either a senior system operator or an
experienced electrical engineer. They are responsible for providing the necessary interface between
System Operations, field personnel, neighboring utilities, internal departments, and construction
offices. This position ensures continuity, consistency and
coordination of required work activities pertaining to outage
coordination on the interconnected Bulk Electric System, including
generation and substation outages. This position is tasked with the
authority and responsibility to operate the Avista transmission
system in such a manner as to comply with all appropriate NERC
and Peak Reliability Standards. The Outage Coordinator creates
accurate switching orders, resolves construction scheduling
176 NERC Outage Coordination, lR0-017-1, http://www.nerc.com/pa/Stand/Reliability%20Standards/lRO-017-1 .pdf
177 NERC Operational Reliability Data, TOP-003-3, httpJ/www.nerc.com/pa/Stand/Reliability%20Standards/TOP-003-3.pdf
Exhibit No. I
Case No. AVU-E-I9-04
H. Rosentrater, Avista
Schedule 2,Page 99 of 128
v --r?l-l
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conflicts, organizes and leads outage coordination meetings, and develops and maintains switching
standards for Avista System Operations.
Both transmission and generation outages have the potential to cause or contribute to regional
operating area limits or to impact neighboring utilities. For prescheduled outages, the Outage
Coordinator notifies anyone who might be affected to give them a
heads-up and awareness of the event. lf an outage happens in real-
time, the System Operator makes these same notifications. The
Outage Coordinator plans and coordinates outages with any other
Balancing Authorities or Transmission Operators (neighbors) who
may be affected, strategizing with them on what may be needed for
system reliability and insuring communication is in place so they can
coordinate closely during the outage.
The Outage Coordinator is also responsible for insuring that adequate
studies and assessments have been done before an outage is approved to ensure that no reliability
issues will be created. The Outage Coordinator is responsible for keeping all affected parties informed
on the planning, status, and any updates related to planned or unplanned outages.
Note that Peak has the authority not only to study the potential impacts of a planned outage, but also
to approve or deny it.
Reporhble Disturbances by Gategory in U.S. Portion of WECC
Ye.r 20r4 42015 02015
25
20
r5
10
5
0
Irlnnding L$s ot 163 of Lo.d [6r of RAs
Gen*ation or Monitoring or Mbop€rrtionTrammitiion Control
o
oSystem Operator Training
System Operations controls the transmission and
generation system in real time. They are
mandated by NERC Standards requiring that
utilities maintain frequency, voltage, interchange
and system stability within acceptable ranges
and respond to emergencies accurately and
within a specified time frame. System Operators
must respond to ever-changing conditions of
normal operations and emergency conditions
due to weather, equipment malfunctions, public accidents and even vandalism and sabotage.
This high level of responsibility requires experienced, highly capable and well trained employees that
must pass a national certification test administered by NERC. System Operators at Avista are seasoned
employees that normally come from the crafts, such as generator operators, electricians and linemen.
They must be individuals who have excellent communication and critical decision making skills, as well
as the ability to act thoughtfully and calmly under the extremely stressful and challenging conditions
that can accompany an unexpected outage.178
ffiIiiffitf.il';#J|.:ffii::xlffJ:,.lff,ll,.liiillli.iiTr?;/'wEcc
Generation' Transmission Loss Events spike"'June 18'2017' RT, rnsider' o
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 1 00 of 1 28
o Reliability Desk
Avista has a robust in-house System Operator training program that meets NERC requirements in PER-
gg5-2.rts This program follows a systematic approach to training as mandated by NERC. Each operator
must go through a rigorous initialtraining program, and then pass the NERC certification test. Upon
completion of their certification, Operators go through an "on the job" training program before they
are able to cover a shift. During this on-the-job-trainine (OJT) they must be signed off as being
competent in over 80 tasks.
Once these tasks are completed, the trainee is qualified to work on the reliability desk. This desk is
responsible for generation and interchange monitoring as well as responding to emergency conditions
related to load and generation. They must perform their tasks in accordance with all NERC standards.
The reliability desk operators also assist the Transmission
Reliability Operator and continue to receive training to be able
to progress to the Transmission Operations Desk.
Transmission Operations Desk
The Transmission Reliability Operator must go through more OJT
and be qualified in an additional 1"40 tasks (beyond those
required for the Reliability Desk). These tasks include everything Typical Utility Dbpatch Centero
o
from monitoring the system, issuing clearances, to emergency
operations and more. Once they have been signed off as being competent in these tasks, they are
qualified to operate the Transmission Operations Desk, also referred to as the "senior desk."
NERC also requires continuing training to maintain NERC certification. All System Operators receive 200
hours of continuing training every three years. Avista has an in-house training program administered
by the System Operator Training Coordinator, which includes training on all of the system operating
procedures, NERC standards, and emergency operating procedures, including restoration following full
blackout of the system. Much of the training includes use of a simulator. The training program is
reviewed yearly by the Chief System Operator, the Training Coordinator, the Senior Operations
Engineer and the System Operators. The effectiveness of the program is reviewed and checked for any
errors or deficiencies. lndividual development plans are
prepared for each System Operator as well to ensure that
all operators are receiving the required training.
Avista also participates in regional restoration training
provided by the Regional Reliability Coordinator. This is a
yearly event and includes all of the entities in the
Northwestern United States. This training simulates a
widespread blackout, with all of the entities working
together to restore the electrical system. This exercise helps build cooperation, coordination, and
camaraderie between utilities as well as enhancing expertise.
17e NERC Operational Personnel Training, PER-005-2, http://www.nerc.comipa/Stand/Reliability%20Standards/PER-005-2.pdf
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2,Page 101 ot 128
\
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Conductor: Conductor is large wire, usually 1-2 inches in diameter, made up of multiple aluminum
strands surrounding a steel core that work together to carry electricity.lso The conductor is strung
between transmission structures. A "line" is typically comprised of a single conductor or multiple (up to
four) conductors bundled together. Alltransmission lines generate a small amount electrical discharge,
or corona, which causes the surrounding air molecules to ionize. At times you
can hear this effect as a slight humming or crackling sound close to a line.
Corona is accompanied by power loss and can even damage electrical
components over time, as the gases released by it are corrosive. Higher voltage
lines and larger diameter conductor reduce the corona effect and also create
rransmission Conductor less resistance and resulting losses. To create larger lines and further reduce the
corona effect, conductors are bundled together to increase the effective diameter of the conductor.
Bundling also allows a line to carry more capacity. Conductor cannot be put under too much tension or
it will fail. Therefore it is attached to structures in a way that creates a dip in the lines between
structures. Determining the proper amount of sag is a complex calculation that takes into account
clearance to ground and to other conductors on the same line, length of the span, tension and weight
of the conductor, relative location of poles to each other (such as going up a hill), and external factors
such as heat, loading, wind, ice weight, and ambient temperature.
Structure: Transmission poles are the most visible component of
the electric transmission system. Their primary purpose is to keep
the high-voltage cond uctors
separated from their
surroundings and from each
other while providing the means
for the conductor to travel from
the generation source to the
substation. These structures are
typically between 60 and 140
feet tall. Structure designs vary
by utility and depend in great
part on load/capacity, weather,
geogra phic settings/terrain,
access/transportation, soil conditions,
distance between structures, right-of-
way widths, cost, and pole height
Right:
Steel "Armless" Pole
Above: Transmission H-Frame Structure
180 Aluminum is used because it is highly conduclive and light weight. Aluminum is 61% conductive versus steel, which is 3-15% conductive. Source:
'Which Metals Conduct Electricity?" https://www.metalsupermarkets.com/which-metals-conduct-electricity/
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 102 ol 128
Above: Steel Self-
Supporting Pole
with Davit Arms
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Crossarm )
'7Y'"
o Stub Pole
required to meet clearance requirements. ln addition, different
types of poles may be needed at the point where a line changes
direction. This adds additional stress to a structure, and often
requires guy lines, stub poles, or self-sustaining structures for
additional strength. Structures can include a single steel or wood
pole with a cross-arm, or have "armless" construction, in which
insulators are attached directly to the side of a pole. Other types
of structures include the "H Frame" or a lattice tower. Structures must be designed to carry the loads
imposed on them by the weight of the conductor plus wind, ice accumulation, heat, and vibration.
They must be also be tall enough to keep the conductor above the ground at a level that meets safety
requirements established by the National Electric Safety Code
GuyWire
lnsulator: An insulator is usually made of glass, porcelain, or a composite
polymer. They are used to attach the conductor to a transmission
structure/pole in order to prevent short-
ff*' circuiting. lnsulators are frequently shaped like
umbrellas with what are sometimes called
"petticoats" to allow rain to drip away from the
bottom of the insulator to help prevent flash-
one Piece over. Depending on voltage level, insulator strings are
lnsulator mounted on a crossarm or tower as shown in the
photograph on the right. Another common type of insulator is a strain
insulatorthat is used when there is a lot of tension on the line, such as
at a sharp corner.
Pollm€r
Itruhtor
o Above: String of
Glass lnsulators
Left: Strain
lnsulators on a
corner pole
Jumper: At times insulator strings are mounted on each side of a pole and are electrically connected
by a jumper conductor to make the connection complete and ensure continuity of the line.
Transmission lines typically have jumpers when
the line has been dead-ended on a pole due to
the line ending or
making an angle.
The jumper allows
the line to get to the
dead-end on the
other side of the
pole so it can
continue on, keeping
the connection intact.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Jumpers on an Avista line in
1926
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Jumpers on Avista lines today
Schedule 2, Page 1 03 of 1 28
T i
oAir Switch: High-voltage air switches are installed in electrical
transmission networks to de-energize line
sections between substations. This allows
construction crews to conduct maintenance
and repairs. Typically transmission air switches
have two different types of interruption
devices: line-charge dropping quick-break
whips or pa ral lel-breaking vacuum interrupter
bottles. ln certain scenarios, air switches are
Shield
Wire
\
also equipped with SCADA controlled or auto- Above: Air
sectionalizing motors so they can be operated t*'ttn*fl:;tj|:
automatically or manually so that they can be transmission
reset and reused without sending out a person ttructure
to reset them. (More information on these air switches can be found
in Appendix Z on page 103.)
Shield Wire: Shield wires, also called static wires or earth wires, are
usually made of steel and are connected to the top of a transmission structure then grounded to the
pole with wires running down to the earth. These wires help protect against lightning strikes. They are
typically installed above power lines, as lightning is more
likely to strike the shield wire then be routed quickly to the
ground. This protects the power lines and equipment by
preventing lightning
surges from
continuing down a
power line and into
a substation or a
customer's home or
business. Often
opticalfibers are
embedded in the
shield wire,181 giving Lightning striking a shield wire
it a dual purpose in
providing both lightning protection and as a system control
and communications path.
Double Circuit Lattice Tower with three phases on
each side and a shield wire on the top cross-arm.
Note the spacers separating the conductor strands.
181 When telecommunications is embedded, it is often called an "optical ground wire'or an "optical fiber composite overhead ground wire."
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 104o1 128
Akturitrh in
l{trip
Above: High Speed Whip Air Switch
Below: Bottle Vacuum Air Switch
o
Close-up of a
Spacer:
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Vacuum
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Spacer
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o Spacer: Spacers are often used when multiple conductors are located on
the same touchpoint on an insulator. The lines run very closely together
making them prone to clashing, twisting, or entwining
with each other. The spacer provides adequate gaps ,,".Tf,|l;3"Tli:"c|,jil
between the ConduCtOr lines to keep them Separated ground wire on the top
from each other, reducing corona, and helping dampen crossarms)
the effects of wind and the resulting vibration on the
lines.
Above: Single
Circuit Transmission
Lines with the
traditional three
phase conductor
Concrete
Caisson
Foundation
Traditional Direct Embed Transmission Foundations
Sin$le Circuit: Single circuit lines
contain three electrical phases, one
conductor per phase, running from
the generating source to the
substation.
Double Circuit: A double circuit
provides a single path for two
circuits on one physical right-of-
way, reducing the costs and the
footprint associated with installing two separate lines. However, this configuration
is more expensive, generally requires a more robust structure, and also increases
the risk of loss, as both circuits are exposed to the same potential physical hazards.
Foundatiofl: The base of the transmission pole is critical. lt must be designed to
withstand the weight of the tower or pole and all of the associated conductor and
equipment as well as tolerate the uplift and lateral forces from wind and weather.
The foundation is so critical that it can
comprise LO%to 3O% of the cost to
construct a transmission tower.182 The value of foundations is
of tremendous importance in providing
stability for the entire transmission line. The
loss of one pole can cause the entire line to
fail. Designing a foundation includes
consideration of many factors including: soil
conditions, geographic location (hillside, river
crossing, farmland), water and ground water
conditions, area weather patterns, type of
pole/structure and supporting equipment,
potential corrosion issues, etc.
182 Freeman Thompson et al, "lntegration of Optimum, High Voltage Transmission Line Foundations," 2009,
http://cruxsub.comicoreifiles/cruxsub/papers/c6988e90fb75df6Sfa9a4603809f6286.pdf, page 3.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 105 of 128
o
Left: The failure of one pole
can create enough tension
to cause a whole section of
line to fail. (Photo taken in
Othello)
Single Pole
Foundation
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oTransformers: Only three percent of all substation transformers are high voltage, but these
transformers carry 60%-70% of the nation's electricity.ls3 This critical piece of equipment provides an
important link in moving power from the generator to the fficustomer, managing all of the transformations the ffi
electricity must make in order to arrive at its destination in
a usefulform. Power must be reduced from hundreds of
thousands of volts to only 110 volts in order to be used by
the average household appliance. ln order to do this, step-
up transformers are used to increase the voltage from the
generatorls4 to high voltage transmission levellss in order
to move the
long distances
to reach a
SUbStatiOn This is one of the lorgest tronsformers we purchose.
It connects the 230 kV ond 115 kV systems.
near a load
source. At the substation, the energy enters a step-down
transformer to transition to the distribution system voltage
level. Transformers are used again at the customer load site
to reduce the distribution-level energy to a level that
customers can use.
Transformers in Nez Perce Substation
As an example, electricity is generated at L4.4 kv at Noxon
Rapids Dam, then stepped up to 230 kV at the generator step-up transformer located at the power
plant in order to jump on to the Noxon-Pine Creek transmission line. On that line, it travels to a
centralized substation where it is reduced to 115 kV and travels on to a Coeur d'Alene distribution
substation. At that point a transformer decreases the voltage of L3.2 kV. The electricity is delivered at
Left to Right: Transmission Line to Distribution Substation
Step-Down Transformer, then Step-Down Tronsformer to
Distribution System, then to Customer Tronsformer, then
to Customer
I
Generator to Tra nsmission Substotion Step-U p Tro nsformer,
then Step-Up Transformer to Transmission Line
o
183 Paul Parfomak, "Physical Security of the U.S. Power Grid: High-Voltage Transformer Substations," Report to Congress, 2014,
https:i/fas.org/sgp/crs/homesec/R43604.pdf, summary page.
1e lt is cheaper and more efficient to generate at low voltage then step it up to transmission level, so most power plants are designed to run at around 11
kV. 'Why Generator Voltage is 1 1 kV 50Hz o 13.8 kV 60 Hz," http//www.gohz.com/why-generator-voltage-is-1 1kv-50h2-or-138kv-60h2
185 Voltage is stepped up to 60 kV, 1 15 kV and 230 kV for Avista, up to 765 kV in the United States. China is proposing 800 kV; lndia is proposing a 1200
kV line.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 106 of '128
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13.2 kV throughout the Coeur d'Alene area until it gets to a customer's house, where it passes through
a distribution transformer and reaches its final voltage of 240VlL2O V. The electricity then enters the
customer's house where it energizes the electric panel and can be used for everyday devices.
Transmission Substations: As mentioned above, transformers modify electric energy voltage
levels. Transmission transformers are usually located in one of the following two types of substations
1) A step-up substation receives power from a generator and uses a transformer to increase the
voltage to a high enough level that it can be
transmitted long distance across
transmission lines.
2) A step-down substation can connect
different parts of the grid as well as being a
place where transmission-level voltage is
converted to sub-transmission voltage
which is then transferred to the distribution
system. These types of substations can also
be tapped as a source of energy for
industrial customers.Typical Avista Transmission Substation
Substations are the heart of the power system. They are required for the safe and reliable operation of
the system, and are the physical locations to remotely monitor and control the system. They are also a
key component for equipment protection, switching for outage management, and isolating circuits for
maintenance or to reduce the number of customers impacted by an outage.
Right of Way: Every transmission line has a corridor that provides a safety margin between the
transmission lines and surrounding vegetation and structures. These areas
are set aside specifically to accommodate the line, and are typically
cleared of vegetation or planted with low height vegetation. These areas
are carefully monitored to ensure that vegetation, buildings, or other
elements do not impose upon the line, creating potential safety issues or
outages. The corridor may also contain an access road to allow repair and
inspection of the line. The width of a right-of-way varies depending on the
voltage level of the line, but is typically from 50 to 175 feet.
Above: Nicely trimmed right-of-way
running down the valley for the
Noxon - Pine Creek 230 kV line.
Right: Right-of-Way on Addy - Devils
Gap showing access road.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 1O7 of 128
o
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AeeENotx Z: TneNsMrssroN GtossaRy oF Tgnrus
Active Power (or Generation) Control(AGC) Because there are many generators supplying power into
the interconnected system, there has to be a means of allocating any changes in demands and
required generation across the entire grid so loads and generation always remain precisely balanced
and no one generator or utility has to make up the entire deviation. This balance is measured using
system frequency. To stay perfectly in balance and keep the frequency level stable, automatic
generation control is used to allow the system to adjust multiple generators at different power plants
around the grid at exactly the same time, keeping the system
perfectly in balance and the generators producing precisely what
is needed.
Air Break Switch is a high voltage breaker designed for automatic
and controllable high speed interruption of faults on a line. lt uses
compressed air to open the contacts and quench any arcs.
Ancillory Seruice These are services necessary to support the
transmission of capacity and energy from resources to loads while
maintaining reliable operation of the Transmission Service Provider's transmission system in
accordance with good utility practice. (From FERC order 888-A.186)
Area Control Error (ACE) is the instantaneous difference between a Balancing Authority's net actuol
and net scheduled interchange, taking into account the effects of frequency bias and correction for
meter error. Area Control Error occurs when scheduled and actual generation within a control area
don't match, which can place an undue burden on other utilities as well as cause unnecessary
generator control movements.
Ared lnterchonge Methodology ln order to make sure that the interconnected system is not over-
subscribed, a simulation was developed that determines how much total capacity (TotalTransfer
Capability or TTC) is available on the system, then the Capacity Benefit Margin, Transmission Reliability
Margin, and existing transmission commitments such as serving native load or existing contracts with
other utilities are all deducted, and counterflows are added back in, leaving the space that is actually
available to move power on the lines.
Auto Trdnsformer Has only one winding around a laminated
core versus a regular transformer, which has two windings, a
primary and a secondary, which are not connected. When an
auto transformer is under load, part of the load current is
obtained from the supply and the rest is from the transformer
itself, so it works as a voltage regulator. The voltage can be
stepped up or stepped down just by reversing the connections.
Since there is only one winding, it contains less copper so it is
less expensive. These transformers tend to be smaller and more
Auto Tronsformer in 7930
t86 [Jni{sd States of America Federal Energy Regulatory Commission, 18 CFR Part 35, https://www.ferc.gov/legal/maj-ord-reg/land-docs/rm95-8p1-000.txt
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 1 08 of 1 28
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efficient as well as being more effective at voltage regulation. However, there is no insulation between
the primary and secondary since both are wound around the same core, so it cannot be safely used in
situations where there is a variation in the voltage, like transforming transmission level to distribution
level voltage. lf there is an issue and high voltage crosses to the low voltage side, the equipment can be
significantly da maged.
Todoy's outo transformer - the Pine Creek Auto Tronsformer being moved into position
Automatic Generation Control (AGC) This is also called Active Power Control. The interconnected
system requires adjusting multiple generators at the same time in response to changes in load across
the system. AGC equipment allows this to happen automatically without operator intervention. This
insures that the system stays completely in balance.
Avdilable Transfer Copability (ATC)This is a measure of the transfer capability remaining in the
physical transmission network for further commercial activity over and above already committed uses.
It is defined as Total Transfer Capability less existing transmission commitments, including retail
customer service, less a Capacity Benefit Margin, less a Transmission Reliability Margin. Basically ATC is
a function of how much unused capacity is available on the most limited transmission facility, allowing
for a single and sometimes multiple contingencies.
Balancing Authority (BA)The BA is the responsible
entity that integrates resource plans ahead of time,
maintains load-interchange-generation balance within
a Balancing Authority Area, and supports
interconnection frequency in real time.
Balancing Authority Area The actual operation of the electric system is managed by entities called
Balancing Authorities. Most, but not all, balancing authorities are electric utilities that have taken on
the balancing responsibilities for a specific portion of the power system, the area of their responsibility.
The Balancing Authority maintains load-resource balance within that specific area, ensuring in real time
that the power system supply and demand are perfectly matched.
Bulk Electric System This includes transmission lines, interconnections with neighboring systems, and
associated equipment that is operated at voltages of 100 kV or higher, or generation resources above
20 MVA. Radial transmission facilities serving only load with one transmission source are generally not
included in this definition.l8T
187 Cynthia S. Bogorad and Latif M. Nurani, "NERC's Definition of the Bulk Electric System,"
httpJ/www.spiegelmcd.com/liles/APPA_Legal-Seminar-Paper-NERC-BES_2012_10_25_09_08_5'l .pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 109 of '128
NERC ESSENTIAL RELiABTLITY
BUILDING BLocKs
@+@=@
Frequency ISupport I
Voltage
Control
Load &
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Balance
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Bulk-Power System This includes all facilities and control systems necessary for operating an
interconnected electric transmission network (or any part of it) as well as the electric energy from
generation facilities needed to maintain transmission system reliability. These are facilities that, if
disrupted, would impact the grid beyond just one location. The difference between the "Bulk Power
System" and the "Bulk Electric System" is that, in the former, facilities do not have a minimum voltage
requirement.
Capacity Allocation The transfer capacity of a path is allocated among the rights-holders on that path
based on their negotiated agreements unless impacted by system operating conditions such as
emergencies that reduce the capacity of the line. This transfer capacity becomes a right that the holder
may use for their own loads or sell to others.
Copacity Benefit Morgin (CBM) is the amount of Total Transmission Capacity (TTC) held back by energy
providers to allow for importing generation (thanks to their interconnections) to meet generation
reliability requirements if they face a generotion loss. Reservation of CBM by a load-serving entity
allows them to reduce their own generating capacity because they have interconnections available to
help them meet load requirements if they get in a bind. However, CBM is, in essence, a last resort and
can only be called upon when all non-firm sales have been terminated, direct load management has
been implemented, and all interruptible customers have been interrupted.
Capacity Emergency A capacity emergency exists when a Balancing Authority Area's operating
capacity, plus firm purchases from other systems, to the extent available or limited by transfer
capability, is inadequate to meet its demand and it's regulating requirements.
Capacity Margin Formula = (Available Resources - Peak Firm Load) / Available Resources
Coscoding Outage The uncontrolled
successive loss of system elements triggered
by an incident at any location can cause a
cascading outage that rolls across several
sections or the entire interconnection.
Usually there is one or more initiating
events, such as heavy loading on a line due
to high temperatures and heavy loads in
conjunction with the line sagging into a tree.
The line fails, which
shifts the load it was
carrying to other
interconnected lines,
overloading them, and triggering cascading events in widespread electric service
interruption that reaches a point where it cannot be stopped from spreading
beyond the area in which it started.
a
o
Circuit Breaker is an essential device usually located in a substation for
interrupting excessive current flow typically initiated by a fault or heavy loading.
Circuit breakers cut the power until someone can fix the problem. ln addition,
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 110 of '128
Circuit Breaker o
Cascoding Outage in the Northeost in 2003
:oo3SAT3: I5 Ge o S t a rEST L4 45ALr
o using a circuit breaker, interruption and reclosing times can
be adjusted to keep temporary faults from resulting in a
sustained outage. The circuit breaker can sense whether the
fault is transient and choose to keep the electricity flowing. lf
it is a serious fault that must be addressed, the breaker halts
the flow.
Confirmed lnterchange happens when the transmission
owner and the entity that wishes to purchase transmission
rights have come to agreemen! no involved party has issues
with the contract and all required parties have approved the
Arranged lnterchange.
Conductor The physical line that carries electricity from one
place to another. lt must be very durable and conductive as
well as being light weight, so is typically made of aluminum
with a steel or copper core.188
500,000-rolt line
14 conductorsl
iffif="."8#
Milliomolt line
(8 conductors):4+:+Wireffi"",e#ffi=F
Single-conductor line
(usod mainly for
154,000 volts or loss)
Multironductor lin€
(us6d mainly lor
275,000 volts)
1.5"
r lvire
/Aluminum rvirc: 45 strands \ /Aluminum wilt:54 strands \I Coooerrviru:7 strands I I CoEpelwirc:7 strands I\ unit rveight: b pounds / \ Unit weighl: 5 pounds /
Consequential Load loss This includes all load
that is no longer served by the transmission
system as a result of transmission facilities
being removed from service or tripped by a
protection system operation designed to
isolate the fault.o
a
Contingency is the unexpected failure or
outage of a system component, such as a
generator, tra nsmission line, ci rcu it brea ker,
switch or other electrical element or the loss of
energy being imported. lt is basically anything
that causes an unexpected imbalance between generation and loads in the interconnected system.lse
Contingency Reserue is capacity that has been set aside by the Balancing Authority so they can
respond to a system emergency (an emergency as defined by NERC) in accordance with the Balancing
Authority's Emergency Operating Plan. These reserves
must be available in a very short period of time so the
system can respond when an event disrupts the power
supply.
Control CenterThe control center may be one or more
facilities hosting operating personnel that monitor and
control the Bulk Electric System (BES) in real-time,
performing reliability tasks. lt also includes associated
188 Conductor illustration courtesy of Tokyo Electric Power Company, https://www4.tepco.co.jp/en/corpinfo/ir/kojin/supply/transmission-e.html
18e NERC glossary of terms: http://www.nerc.com/pa/Stand/Glossaryo/o20oP/o20Terms/Glossary_of_Terms.pdf
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 111 of 128
A Lesson in Electricity
I[Ihat happens if
lightning strikes?
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strik$ a mbEtatim or p@r
lire, E spihe in Elt&ge llashs
along the tffililB
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will se$e the Epike ild
triggs the contacts to openildtmolttheIltrof p@.
il
Clralt bul.r
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Utility Control Center
odata centers of: 1) a Reliability Coordinator,2l a Balancing Authority, 3) a Transmission Operator for
transmission facilities at two or more locations, and/or 4) a Generator Operator for generation
facilities at two or more locations.
Corona All electric transmission lines can generate a small amount of sound energy as a result of
corona. This happens under certain conditions when the localized electric field near energized
components and conductors produces a tiny electric discharge, called corona. This causes the
surrounding air molecules to ionize or undergo a slight change of
electric charge. Utilities try to reduce the amount of corona
because, in addition to the low levels of noise that it creates,
corona creates power loss, and in extreme cases it can damage
system components over time. lt becomes more noticeable at
higher voltages (345 kV and higher) and during wet and humid
conditions as water drops collect on the conductors and increase
corona activity. Under these conditions, a crackling or humming
sound may be heard in the immediate vicinity of the line. ln fair
corono Effect weather conditions, the audible noise from corona is minor and
rarely noticed. To reduce corona, utilities bundle the conductor to make the diameter of the line
larger, which reduces corona, resistance and thus losses. They also work to eliminate any sharp points
where electric charges tend to form.
Counterflows Electricity is bought and sold using scheduled delivery routes. However, the electricity
itself follows routes ordained bythe laws of physics, which are not necessarily identicalto the paths set
by the buyers, the sellers, or the operators of the grid. When the actual electricity path differs from the
routes it is scheduled to be on, the difference is known as counterflow or "loop flow." Loop flows occur
in all interconnected transmission systems as the flow of electricity follows physical laws across the
continent. Loop flows can incur unnecessary costs, impacting lines not associated with the schedule
and changing their load levels, potentially leading to overloads on
"innocent" lines.
Corrective Action P/on This is a list of actions and an associated
timetable for implementation to remedy a specific problem. ln some
situations these are mandated by NERC.
CriticolAssets include facilities, systems, and equipment which, if
destroyed, degraded, or otherwise rendered unavailable, would
affect the reliability or operability of the Bulk Electric System.
Crosssrm A crossarm is a piece of hardware providing an attachment
point for insulators to support the loading of overhead conductors.
The crossarm is typically made of wood, steel or fiberglass.
Curtailability The transmission provider has the right to interrupt all
or part of a transmission service due to constraints that reduce the ability of the network to provide
that service. This is called curtailability.
Exhibit No. B
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 112 of 128
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o Curtailment is a reduction in the output of a generator from what it could otherwise produce given its
available resources, typically on an involuntary basis. lt can also refer to a reduction in the amount of
scheduled capacity or energy delivery on a transmission path, typically due to unexpected
circumstances or as agreed upon by both parties to the contract. As an example, a utility may have an
interruptible customer that has agreed to power reductions if loads reach a certain level in exchange
for a reduced rate.
..."
Cutout is a "C" shaped piece of insulated hardware with a tubular insulator that
is designed to melt or break when the circuit through it exceeds its rated value.
This serves to disconnect one section of the line from another section of the line
for maintenance or repair or to prevent an outage from spreading.
Cyber Assets include programmable electronic devices and communication
networks, hardware, software, and data that if rendered unavailable, degraded,
or misused would, within L5 minutes of its required operation, mis-operation, or
non-operation, adversely impact the reliable operation of the Bulk Electric System
Above and right: Dead End
Structures
'' ./l
v
Cutout
o
Cyber Security lncidenf Any malicious act or suspicious event that compromises, attempts to
compromise, or disrupts the electronic or physical security perimeter of a Critical Asset is considered a
Grlund cyber security incident
Deod End Structure is a distribution or transmission
pole where the tension of an overhead line is
terminated. Conductor and ground wires are pulled
only on one side unless it is a double dead-end, where
an overhead line in both directions is terminated. With
a double dead-end the conductor is pulled by ground
wires in two directions to insure adequate support.
Jumpers can be used to connect each end ofthe
conductor so the line can continue. Dead ends are
often used where lines end, turn at a large angle, are at
a major crossing like a river or highway, or where a line
will be divided into sections. These structures help
alleviate the added tension and stresses caused by these conditions and reinforce the line.
Disturbance is defined as either: L) An unplanned event that produces an abnormal system condition;
2) Any agitation to the electrical system; or 3) The sudden failure of generation or interruption of load.
Dyndmic lnterchange Schedule or Dynomic Schedule This is a time-varying energy transfer that is
updated in real-time and used as a schedule for accounting purposes. Commonly used for scheduling
jointly owned generation to or from another Balancing Authority Area, especially if the utility wants to
use its remote generation for Automatic Generation Control (AGC) or for serving loads in a different
control area. This type of schedule is used to transfer Colstrip energy in Montana to Avista customers
in Washington. lt is also used when the host control area cannot tolerate significant differences
between schedules and actuals.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 1 'l 3 of 128
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Eorth Wire:This is also called a static wire. lt is a low-
resistance ground wire connected to the earth or buried in
the ground. lt is located above the transmission conductor
so that lightning is more likely to strike the earth wire and
the resulting current flows into the ground rather than
across the transmission line to the substation. Thus it is
designed to help protect electrical equipment.
Emergency Operating Plon establishes the criteria to be
followed in the event of an Extraordinary Contingency,
Firm Lood is the electric power that is guaranteed by the
utility to be available except when uncontrollable forces create
an outage. This load includes the utility's own customers.
Conductor
Anyone see a problem here?
Note: This is not on Avisto's System!
which is an event that causes a significant frequency deviation, capacity or energy deficiency,
unacceptable voltage levels, or other system emergency.leo
Energy Emergency is a condition when a Load-Serving Entity
or Balancing Authority has exhausted all other resource
options and can no longer meet its expected load
obligations.
Extraordinary Contingency includes any act of God, actions
by a non-affiliated third party, labor disturbance, act of the
public enemy, war, insurrection, riot, fire, storm or flood,
earthquake, explosion, accident to or breakage, failure or
malfunction of machinery or equipment, or any other cause
beyond reasonable control; provided that prudent industry
standards (e.g. maintenance, design, operation) have been
employed.
Fqult Afault is an abnormal condition present on the power
system, usually a
short circuit caused
by lightning, tree
contact, windblown
object in the lines,
or other similar
problem.
o
Firm Tronsmission Seruice is the highest quality or priority service offered to customers under a filed
rate schedule that anticipates no planned interruption. Typically all other contracts are cut before a
firm contract is cut.
1e0 Avista's Emergency Operating Plan is overseen by Peak Reliability.
https//www.peakrc.com/_layouts/download.aspx?SourceUrl=/RCDocs/Emergency%20Operations%20Procedure%20v6.0.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 114 ol 128
Overhead Suitch
Autcnratic 5plic+
Ann
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It
Lightning
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tilritdtif+
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Flowgote The boundary between two parts of a transmission system that may be congested is called a
flowgate. At this point there is a limitation in the amount of power allowed or able to flow across that
boundary.
Forced Outage Typically a forced outage is either the removal from service availability of a generating
unit, transmission line, or other facility for emergency reasons, or the condition in which the
equipment is unavailable due to unanticipated failure.
Frequency Generators connected to the grid function as a team, synchronized with each other. The key
common denominator between them is frequency, which is the change in direction in current flow in
an alternating current (AC) system. ln the U.S., the grid frequency is 60 Hertz (cycles per second). This
frequency is directly linked to the speed of the rotation of the generators. The frequency varies
constantly, usually in a very small range of +/-.5 Hertz or less. Governors controlthe speed of
individual generators to help them stay at 60 Hertz. As the load on the grid increases, generators tend
to slow down, so the governors compensate by pushing the generators into increasing their speed to
maintain the frequency. lf a generator cannot increase its speed, another one on the grid will
compensate by increasing its speed. When all of the generators on the grid have reached their
maximum ability to compensate, the grid will operate at a frequency less than 60 Hertz, indicating that
the grid is overloaded and demand must be reduced.
Frequency Bias The Balancing Authority is
responsible to provide or absorb fluctuations
in the frequency of the interconnected grid
in order to keep the frequency stable. For
example, if frequency goes low, each
Balancing Authority is asked to contribute a
small amount of extra generation in
proportion to its system's established bias,
usually expressed in megawatts per 0.1
Hertz (MW/0.1 Hz). Each Balancing Authority uses common meters on the tie-lines with its neighbors
for control and accounting of how much they contribute to keeping the grid stable. These meters
insure that this extra generation or reduced generation is distributed fairly.lsl
Frequency Bias Setting is a value, usually expressed in MW/0.1 Hertz, set into a Balancing Authority
Area Control Error calculation that allows the Balancing Authority to contribute its frequency response
to the lnterconnection and do its fair share of keeping the grid frequency stable.
Frequency Deviation is a change in interconnection frequency, usually managed by the automatic
response of generating units (using AGC) across the grid, increasing or decreasing output to keep the
frequency stable.
Frequency Erroris the difference between the actualand scheduled frequency.
Frequency Response is the ability of a system or elements of the system to react or respond to a
change in system frequency following the sudden loss of generation or load, and is a critical
1e1 For more information on this, see: NERC Frequency Control,
http://www.nerc.com/docs/oc/rs/NERC%20Balancingo/o?lando/o2lFrequency%20Control%200405201 11.pdf
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 115 of 128
Normal Range
Btackout blackinBout
60
U.5. Grid Frequency
Hz
Start to trip lotal
Blackout
o
component, particularly during disturbances and recoveries. Frequency response is predominately
provided by the automatic and autonomous actions of turbine governors. Failure to maintain
frequency can disrupt the operation of equipment and initiate disconnection of power plant
equipment to prevent it from being damaged, which could lead to widespread blackouts. Frequency is
the sum of change in demand plus the change in generation, divided by the change in frequency,
expressed in megawatts per 0.1 Hertz
Eyr
Fuse (or junction fuse) is a device that
limits the amount of current flowing
through the circuit. The fuse is
constructed with a small piece of metal
that, when exposed to high current
Anchor
typically caused by a fault, melts and Fuse
interrupts the flow of electricity. Fuses
are typically placed on lateral tap lines off the main circuit.
Guy wire is a non-energized wire connected from a
distribution or transmission pole to an anchor in the ground to
offset the tension of overhead conductors. A guy wire is
typically found on a dead-end structure or side-angle structure
On a dead-end structure the entire tension of the conductor is
offset by a guy wire. lf the guy wire is struck by a vehicle or
other object and damaged, the tension ofthe overhead
conductor, without proper support of the guy wire, can break
the pole.
Governors These devices control the speed of individual generators to help them stay at 60 Hertz.
When the load on the generator increases, it causes the generator to work harder. Without a governor,
the generator slows down, lowering both voltage and
frequency. Likewise, when the load on the generator is
reduced, the generator speeds up, roising voltage and
frequency. With no load whatsoever, the generator
would "freewheel," and run at a very high speed, likely
causing damage. The governor constantly monitors
voltage and frequency, adding or subtracting electrical
loads as needed to compensate for human usage and
helping the generator stay at exactly the "perfect" load,
known as Design Load, which is the right speed for proper voltage and frequency. lf one generator
Shaft Electricity attached to the grid cannot increase
its speed, another one on the grid will
compensate by increasing its speed
via a governor to keep the grid in
perfect balance.
Rotational Speed &
Change of Speed
Exhibit No. I
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 116 ol 128
h
$
Guy
Strein
lnsulator
Govemgr
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Rod
Guy
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Hydro GeneEtor
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Hydro
Turbine Generator
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lce loading During the winter, ice forms from moisture that accumulates on overhead conductors. This
accumulation of ice causes increased stress and
tension on both the conductor and the supporting
structures. This added stress can result in the
breaking of either the support structure or the
overhead conductor. Under certain conditions, the
formation of the ice will act as an air foil. The ice
air foil is similar to an airplane wing and can cause
the overhead conductors to oscillate or "gallop,"
adding further strain.
lmplemented lnterchonge This occurs when the
Balancing Authority enters the amount of the agreed-upon transmission contract capacity into its Area
Control Error equation so it is officially part of the capacity posted on OASIS for a line.
lnadvertent lnterchonge happens when more energy passes through a system than has been agreed
upon. lt is the difference between the Balancing Authority's Net Actuallnterchange and Net Scheduled
lnterchange.
lnterruptible Load Some utility customers, typically large industrial or commercial customers, have an
arrangement with the utility to allow their load to be reduced or cut based upon specific, typically
adverse, conditions such as extreme weather. Businesses that can afford to have their services
interrupted or that can significantly reduce their consumption when notified by the utility can get
better rates by having non-firm service/interruptible load, so it is an attractive option for the customer
but also for the utility, which can use this interruptible load as a resource.
lnsulator lnsulators have the duty of keeping the electrically charged transmission line from touching
the poles or towers so the line can continue to transmit and is not grounded
lnsulators must be strong enough to
withstand the weight of the conductor and
the potential stress of the electricity
wanting to connect to the earth. They are
designed to be non-conducting, but getting tnsutatorwith pin
wet can cause flashovers, which is
why many insulators are designed
with an umbrella or petticoat at
Strings of transmission insulators,
sometimes called bells
the top to keep the lower part insulated
from the rain.1s2 Extreme weather,
Snow & ice loading in Reardon breaks
conductor and shatters a pole
Stay lnsulator
Dead-end lnsulator
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 117 of 128
sun and vandalism can reduce the
strength of the insulator, making it more likely to break and cause an
outage so insulators are monitored during inspections. There are many
kinds of insulators depending upon their application, including the most
common:
o 1e2 For more than you ever wanted to know about insulators, see: https://www,insulators.info/general/glossary/
o
Post
lnsulator
I/ Pin lnsulator: is mounted on an insulator pin, typically made of glass, porcelain or
composite polymer and is the insulating property between the energized conductor and
the crossarm.
2) Post insulator: bolts directly to the pole or crossarm and does not require an insulator
pin.
3/ Dead-end insulator: is designed to handle the tension of an overhead conductor when
it is terminated at a pole.
4/ Guv strain or stav insulator: is inserted into a guy wire to prevent the guy wire from
becoming energized. These insulators are typically made from a polymer or fiberglass
material.
lnsulator pln This is a piece of overhead hardware that fastens the insulator to
the crossarm. The insulator pin is bolted through the crossarm and the insulator is
screwed onto the top of the insulator pin.
lnterchange is the energy transfers that cross Balancing Authority boundaries.
lnterchange Authority is the responsible entity that authorizes implementation of
valid and balanced lnterchange Schedules between Balancing Authority Areas,
and ensures communication of information for reliability assessment purposes.
lslanding This happens when a Balancing Area or portion of one is isolated from
the grid. Usually this is unintentional, but occasionally a utility will island from the
grid to prevent a cascading outage.
Jumper Conductor connects two ends of a conductor/line when the line is
interrupted at a pole such as when it makes a corner and the tension of the
corner requires the line to be directly connected to the pole for additionalJumper Conductor
strength
kV is 1,000 volts or kilovolts.
kVA Also called apparent power,
this is the sum of kVAR and KW.
ln the analogy on the right, this
is the total contents of the mug
including both the beer and the
foam.
W[at is
Pouer ]aclorfl
Powor hctor ir the prrentage of rppennt
pow€r that doo. roal work. Urdef5tand Porer
factor using Beer Mug Analogy,kvA
Reactive
o
. 'lvaded"Ehctricity
.- "tbabl.'ElGct hity
kVAR Also called reactive power
or wasted power, this is the
power that magnetic based
equipment such as
transformers, motors, and relays
need to run. lt is also the portion of electricity that establishes and sustains the electric field of AC
equipment. lt is essential in transferring power across transmission lines. ln the beer analogy, this is
the foam part. lt is a necessary "part of the beer experience but it does not quench a thirst."
Exhibit No. 8
Case No. AVU-E-I9-04
H. Rosentrater, Avista
Schedule 2, Page 118 ol 128
3
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FilturlW
Jtoy.trw.6O
TUP6E(tW)e,
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kW is a thousand watts. Also called working power, actual power or real
power because it is the part of power that actually powers equipment and
performs useful work. ln the analogy above, it is the actual beer part.
Lightning arrester is a piece of hardware that reduces voltage surges from
direct or nearby lightning strikes. When a lighting strike occurs, the overhead
conductor experiences higher than normal voltage levels. This high voltage is
dissipated into the lighting arrester, mitigating potential damage to
equipment.
Long Term Transmission Planning Horizon This is the time period that covers
years 6 to 10 and beyond.
Looped refers to a transmission or distribution line that has a redundant feed; it provides options to
serve a customer via a different line or direction if one line fails.
Misoperation This occurs when a protection system does not operate
with its specified time period or it does not stop a fault or other abnormal
condition within its area of control. lt can also occur if the protection
system operates when it is not supposed to do so.
Most Severe Single Contingency is that single contingency which results
in the most adverse system performance under any operating condition or anticipated mode of
operation.
Multiple Contingency Outoges is the loss of two or
more system elements caused by unrelated events
or by a single low probability event occurring
within a time interval too short, less than ten
minutes, to permit system adjustment in response
to any of the losses.
Native Load means the end-use customer load of
a utility.
Poner
PlanB
Distribution
Upto'1,0{X}kV 23OkV {{5kV 6SkV 7-t3kV
Transmission Sub-
Transmission
o
Nedr Term Transmission Planning Horizon is the time period that covers 1 to 5 years.
Non-Consequentidl Load Loss This tends to be a controversial term, as the industry and the NERC could
not agree upon what constitutes "non-consequential" so there are still some ambiguities. The NERC
definition is basically that "Non-Consequential" is anything not "consequential," which means load
tripped off when transmission facility protection systems operate to isolate a fault, loads tripped off
due to voltage sensitivity, or load that is disconnected or tripped from the System by the customer or
their equipment.
Non-Firm Tronsmission Seruice Non-firm transmission service is reserved on an as-available basis and
is subject to curtailment or interruption. This tends to be the first thing utilities cut when they
experience system contingencies.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 119 ol 128
Transmi$ion
System
I
ArrE.toil
o
US Reportable Disturbances by Category
Year e2014 O2O15 42016
25
20
15
10
)iL iJ L
iJlanding Loss of
Generation or
Transmission
Loss of Load Loss of RAS
Moniloring or MisopeEtion
Control
Courtesy of Western Electricity Coordinating Council
https://www.wecc.biz/epubs/StateofThelnterconnection/Pages/Events-
Non-Spinning Reserue is a generating unit
not connected to the system but capable of
serving demand within a specified time. lt
can also be interruptible load that can be
removed from the system within a
specified time.
Reportable Disturbance Any event that
causes area control error changes greater
than or equal to 80% of a Balancing
Authority's or Reserve Sharing Group's
most severe contingency is considered
reportable. These events include: islanding,
loss of three or more Bulk Electric System
facilities from a common cause, any loss
Above:
Washington Water
Power's First Line
Truck early 1900
Left: Linemen
stringing the
Palouse line in
1930
outases/Disturbances aspx greater than 2,000 megawatts of generation,
loss of more than 200 megawatts of firm load for 15 minutes or more, loss of the ability to monitor or
control operations for 30 minutes or more, or failure/mis-operation of a Remedial Action Scheme.
Open Access Some Time lnformdtion Seruice (OASIS) This is an electronic posting system that the
Transmission Service Provider maintains for transmission access data and that allows all transmission
customers to view the data simultaneously. Used to make reservations on a utilities transmission
system.
Open Access Trdnsmission Tarilf PATD is an electronic
transmission tariff accepted by the U.S. Federal Energy
Regulatory Commission (FERC) requiring a Transmission Service
Provider to furnish all transmission service purchasers with
non-discriminating service comparable to that provided by
Transmission Owners to themselves and their own customers.
Operating lnstruction This is a command by operating
personnel responsible for the real-time
operation of the interconnected Bulk
Electric System to change or preserve the
state, status, output, or input of an
element or facility of the BES. Note that a
discussion of general information and of
potential options or alternatives to resolve
Bulk Electric System operating concerns is
not a command and is not considered an
Operating I nstruction.
Operating Procedure is a document that identifies specific steps or tasks that should be taken by one
or more specific operating positions to achieve specific operating goal(s). The steps in an Operating
Procedure should be followed in the order in which they are presented, and should be performed by
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
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Schedule 2, Page 120 of 128
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Postback is a positive adjustment to posted available transmission
capacity, including processing redirects and unscheduled service.
the position(s) identified. For example, this may be a document that lists the specific steps for a system
operator to take in removing a transmission line from service.
Operating Reserue is the capability above firm system demand required to provide for regulation, load
forecasting error, equipment forced and scheduled outages and local area protection. lt consists of
spinning and non-spinning reserve.
Out-of-Step Blocking This is a protection system that can tellthe difference between a fault and a
power swing. lf it is a power swing, the protection system blocks or prevents tripping associated
transmission facilities; if it is a fault, the protection system trips the facility to protect it.
Physical Access Control Systems are cyber assets that control
alert, or log access to the physical perimeter of a facility, not
including locally mounted hardware or devices such as motion
sensors, electronic lock control mechanisms, and badge
readers.
Physicol Security Perimeter is the physical, completely enclosed
border su rrou nding computer rooms, telecom munications
rooms, operations centers, and other locations in which Critical
Cyber Assets are housed and for which access is controlled.SMUD implemented security measures
that led to a tenfold drop in facility
intrusions in two years.
Power Factor is the percentage of Apparent Power that does real work.
Power System Stabilizer (PSS) These are part of the Automatic Voltage Regulation system of a
generator, designed to add or subtract torque to the
generator to help dampen oscillations on the grid.
Oscillations occur as a result of many machines being
connected to one section of the grid and not being exactly in
phase with a group of machines on another part of the grid,
in essence, creating the potential for the grid to become a
giant oscillator. ln order to prevent that, system stabilizers
are installed on synchronous generators of a size that can
mitigate this issue.
Protection System Protective relays, associated
communication systems, voltage and current sensing devices, station batteries and DC control circuitry
designed to protect equipment and facilities comprise
protection systems.
Protective Reloys These detect and attempt to correct
faults. They read measurements such as current,
voltage, and frequency and can be set to recognize
when these indicate a problem. For example, if a
protective relay senses that a circuit breaker is interrupting the system, it can disconnect it
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 121 of 128
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Pseudo-Tie This occurs when two control areas electronically link their Automatic Generation Control
Dynamic Schedute
(AGC). ln this case, the transfer of generation or
load is treated as a new point of interconnection
(a "pseudo-tie") but there is no actual physical tie
or metering. The host control area (for example,
for Colstrip it is NorthWestern) can transmit a
revised schedule to the other owner(s) such as
Avista as load or generation changes, dynamically
changing the flow of energy.
A cute depiction of pseudo-tie from pJM tnterconnection Qualified Transfer Paths A transfer path
designated as being qualified for unscheduled
flow mitigation, where a schedule can be established, actualflow is metered, and a System Operating
Limit has been established.
Radialis a transmission or distribution line that does not
have a redundant feed - it is a single line running from
the generator to the customer, so if this line is lost,
customers lose service, versus a redundant system that
has another line or lines available to serve load if one line
is lost (see Looped or Redundant).
Rated System Path Methodology The Rated System Path Methodology is characterized by an initial
TotalTransfer Capability (TTC) determined via modeling and/or simulation. Capacity Benefit Margin,
Transmission Reliability Margin, and Existing Transmission Commitments are subtracted from TTC, and
postbacks and counterflows are added back in as applicable to derive Available Transfer Capability.
Under the Rated System Path Methodology, TTC results are generally reported as specific transmission
path capabilities.
Reactive Power Measured in kVARs, this is the portion of electricity that establishes and sustains the
electric and magnetic fields of alternating-current
equipment. lt cannot be converted to another form
such as light or heat but is essential in transferring
power through transmission lines. lt creates the
oscillation between the generator and the load.
Reactive power must be supplied to most types of
magnetic-based equipment, such as motors and
transformers. Reactive power is provided by
generators, synch ronous condensers, or electrostatic
equipment such as capacitors, and directly influences
kvA
electric system voltage. lt is usually expressed in kilovars (kVAR) or megavars (MVAR).
Real Power is the portion of electricity that supplies energy to the load.
Recallability The right of a transmission provider to interrupt all or part of transmission service for any
reason, including economic reasons, as long as it is consistent with FERC policy, associated tariffs,
and/or contract provisions is called recallability.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 122 ot 128
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Recloser is a device that operates similarly to a circuit breaker but is
installed on a distribution circuit. Reclosers are available for both
single-phase and three-phase fault interruptions. The main purpose
of a recloser is to sectionalize a portion of a circuit from the rest of
the circuit to prevent outages from spreading.
Redundant This is also called Looped. ln the transmission world, this
means that more than one line or route runs between the generation
source and the end customer, so if one line is lost, the power is
rerouted via another line and the customer suffers either a shorter
outage or no outage at all.
Regional Reliobility Orgonization This is an entity that ensures that a defined area of the Bulk Electric
System is reliable, adequate and secure. (See Regional Operating Entities on page 74).
Regulating Reserue is an amount of reserve that automatically responds to Automatic Generation
Control when a generator trips offline or there is some other disruption to the electricity supply. lt can
come from a variety of generating resources and is typically a little bit of extra generation from several
different generating resources, providing sufficient energy to make up for the lost generation and
allow the grid to stay stable.
Reliability Coordinator has the highest level of authority in the Bulk
Electric System, responsible for the reliable operation of the grid. The
Reliability Coordinator has a wide-area view of the grid as well as the
operating tools, processes and procedures to control it, including the
authority to prevent or mitigate emergency operating situations in both
next-day analysis and real-time operations. The
Reliability Coordinator has a purview that is broad
enough to be able to calculate lnterconnection
Reliability Operating Limits for their entire section
of the grid, such as the Western lnterconnection,
which is based on the operating parameters of
many interconnected transmission systems. This
is beyond any one Transmission Operator's (such
as Avista's) vision. (For more information, see
page 78).
WESTERN
INTERCONNECTION
Viper Recloser
Transmission Pole next
to a Distribution Pole
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 123 of 128
Reliability Coordinator Area is the collection of generation, transmission, and
loads within the boundaries of the Reliability Coordinator. lts boundary
coincides with one or more Balancing Authority Areas. For Avista, this is Peak
Reliability.
Reliability Stdndord is a requirement, approved by the United States Federal
Energy Regulatory Commission under Section 215 of the Federal Power Act, or
approved or recognized by an applicable governmental authority in other
jurisdictions (such as Canada), to provide for Reliable Operation of the BulkO
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Power System. The term includes requirements for the operation of existing Bulk Power System
facilities, including cybersecurity protection, and the design of planned additions or modifications to
such facilities to the extent
necessary to provide for
Reliable Operation of the
Bulk Power System. The
term does not include any
requirement to enlarge
such facilities or to
construct new
transmission capacity or
generation capacity.
Remediol Action Scheme (RAS) detects predetermined system conditions and automatically takes
corrective actions that may include, but are not limited to, adjusting or tripping generation (megawatt
and MVAR), tripping load, or reconfiguring a system.
Remote Switching A remote switch is operated from a location other than the substation. These
switches are typically monitored, controlled and operated
by a dispatcher.
Reportable Cyber Security lncident A cyber security
incident that compromises or disrupts one or more
reliability tasks of a functional entity must be reported.
Reportable Disturbance Any event that causes an area
control error greater than or equal to 80% of a Balancing
Authority's or Reserve Sharing Group's most severe
contingency must be reported. The definition of a
reportable disturbance is specified by each Regional Reliability Organization, which for Avista is Peak
Reliability. Peak defines a reportable disturbance as communication failures, loss of generation, load,
or transmission, some types of vandalism and security threats.ls3
Electricity Concepts - The Water Analogy
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Curent is like the amount of
water flowing through the pipe A capacitor is the opposite of an inducton
Its like a full holding tank that can release
a burst of water in an instant.
Reserue Morgin This is generation
that is held in reserve above what is
expected for peak load demands in
case the system faces an
unexpected event such as the loss
of a generating resource or a
transmission line. The formula =
(Available Resources - Peak Firm
Load) / Peak Firm Load
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 124 ol 128
The total electric charge
would be analogous to the
amount of water in lhe tank
Voltage is akin to the
difference in water height
outlet. Voltage flows like
waler from hiqh to low
A resistor is like a
constriction in the pipe
An inductor (a.k.a. reactive load)
is like a water wheel in the flow
path. lt takes a long lime to get
going, but once its moving at the
same speed as the current, it no
longer requires extra energy
1e3 For more detail: https//www.wecc.bizlReliability/2016%20SOTl%20Final.pdf o
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o Sag For overhead transmission lines, sag is the difference between the point of support, being the
transmission pole or tower, and the lowest point on the conductor. Calculating sag is critical, as
conductor must be held at a safe tension level to insure that it does not break under its own weight or
the added weight of snow and/or ice or
as it is stressed by wind, loads, or
ambient temperatures. Engineers also
carefully calculate the amount of sag to
insure that the conductor remains a safe
distance from the ground. This is
especially tricky when the line is on
uneven terrain.
Scheduled Frequency has the goal of 60.0 Hertz, except during a time correction.
Single Contingency is the loss of a single system element under any operating condition or anticipated
mode of operation.
Speciol Protection Systems (5P5) Also called a RemedialAction Scheme (RAS), this is an automatic
protection system designed to detect abnormal system conditions and take corrective actions other
than isolating a faulted component. Typically this includes changes in generation levels or shedding
load. An SPS is a system not included as an undervoltage or underfrequency system or out-of-step
relaying.
Spinning Reserue Unloaded "extra" generation that is synchronized to the grid and instantly ready to
serve additional demand as needed in case of unexpected circumstances is called spinning reserve.
Ressrve Often it is extra capacity available on a
generator such as adding extra torque
to a turbine's rotor so it can increase
its power output. Spinning reserve can
also be load that is fully removable
from the system (interruptible load) if
there is a contingency event.
Stability The ability of an electric
system to maintain a state of
tIJind
equilibrium during normal and abnormal conditions or disturbances defines that system's stability.
Stobility Limit is the maximum power flow possible through some particular point in the system while
maintaining stability in the entire system.
Step-Up and Step-Down Tronsformers ln a step-up
transformer, the output or secondary voltage is
greater than its input or primary voltage. A step-up
transformer is used for converting the low voltage
produced by a power plant into the high voltage that
transmission lines use to move electricity to the Step Up Transformer
Exhibit No. 8
Case No. AVU-E-'l9-04
H. Rosentrater, Avista
Schedule 2, Page 125 ot '128
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substation. A step-down transformer is the opposite.
There are fewer secondary windings than primary
windings, so it converts high-voltage, low-current
power into low-voltage, high-current power used for
customers. A good example of the use of a step-down
transformer is a doorbell, which has a step-down
transformer to convert the 110 volt household current
into the L6 volts the doorbell needs.
Above: Air Switch in open
position
Right: Air switches woiting
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Switchgeor
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 126 of 128
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Sustoined Outage This is the de-energized condition of a transmission line resulting from a fault or
disturbance following an unsuccessful automatic reclosing sequence and/or unsuccessful manual
reclosing procedure.
Switch is a disconnection point used to interrupt the
flow of electricity. Switches can be mounted on
overhead lines, on underground lines and in
substations. Switches mounted overhead and
underground are used as a disconnection point as well
as a sectionalizing device. During outages the switch
can be opened in order to sectionalize the faulted or
damaged part of the circuit. Switches mounted in a
substation can be used to isolate devices in a
substation, such as a regulator, to protect them in case
of fault.
Switching Station (or Switchyord/ This is a substation
that does not have any transformers, but operates at
a single voltage level. lt is used for connecting and
disconnecting transmission lines. lt is also used to
isolate faulty portions of a line very quickly, keeping
the grid stable.
Switchgear This is a combination of electrical
switches, fuses or
circuit breakers along
Lewiston Switch Yord in L9iL With COntrOl SyStemS
such as transformers,
relays, and circuitry used to control, protect, or isolate equipment,
usually for maintenance or to clear faults.
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System Emergency NERC defines this as any abnormal system condition
that requires automatic or immediate manual action to prevent or limit
the failure of transmission facilities or generation supply that could adversely affect
the reliability of the Bulk Electric System.
System Operating Limit Operating the elements of the Bulk Power System within equipment and
electric system thermal, voltage, and stability limits is required so that instability, uncontrolled
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separation (islanding), or cascading failures of the system will not occur as a result of a sudden
disturbance, including a cybersecurity incident, or unanticipated failure of system elements. lt is a limit
put in place to prevent entering an unstable operating state (Emergency or Extreme).
Tap (or Tap Point) A tap is a segment of transmission that ties the line
into a substation.
Three-Part Communicdtion Protocol A communication protocol
required by NERC for system operators where:
L. lnformation is verbally stated by an initiating party;
2. The receiving party repeats the information back correctly (not
necessarily verbatim) to the initiating party; and then
3. The initiating party either confirms the information repeated by
the receiving party is correct, or reinitiates the
communication until the information repeated by the
receiving party is confirmed to be correct.
Tie Line is a circuit connecting two Balancing Authority Areas (individual utilities) such as the tie
between ldaho Power and Avista which allows them to share energy and reserves.
Time Error occurs when the synchronous interconnection
operates at a frequency different than the interconnection's
scheduled frequency, resulting in an imbalance between
generation and loads/losses, and thus creating inadvertent
interchange, when more energy passes through a system than
has been agreed upon.
Time Error Correction is an offset to the interconnection's
scheduled frequency to return the interconnection's time
error to a predetermined and accurate value.
Totol Transfer Capability fffQ is the amount of electric
power that can be moved or transferred reliably from one
area to another area of the interconnected transmission
systems by way of all transmission lines or paths between
those areas (under specific system conditions.
Transfer Capability This is the measure of the ability of
interconnected electric systems to move or transfer power in
a reliable manner from one area to another over all
transmission lines or paths between those areas (under
specific system conditions). The units of transfer capability are
expressed in terms of electric power, generally in megawatts
(MW). Note that the transfer capability from "Area A" to
"Area B" is not always equal to the transfer capability from
"Area B" to "Arga A."
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2,Page 127 of 128
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oTransmission Constrdint is the limitation on one or more transmission elements that may be reached
during normal or contingency system operations.
Transmission Reliability Morgin (TRM) is the amount of transmission transfer capability necessary to
provide reasonable assurance that the interconnected transmission network will be secure. TRM
accounts for the uncertainty in the transmission system and provides some flexibility in keeping the
system operating smoothly when system conditions change due to line loss, generation loss, or
unexpected weather.
Trip ond Reclose (T/R) Also called a breaker momentary, a trip and reclose occurs when a circuit
breaker is able to clear a fault and quickly restore power by closing the circuit breaker to put the line
back in service.
Vacuum lnterrupter Air Switch This uses electrical contacts inside a
vacuum inside a container to interrupt the circuit on a transmission line.
When a circuit is broken, it creates an arc. ln this type of device, the arc is
contained inside the interrupter and is quickly extinguished.
Voltage regulator is hardware installed in a
substation or out on the distribution circuit
that adjusts to keep the voltage within
acceptable limits during heavy and light
loading periods. Sometimes used on long distribution feeders to keep
the voltage up over great distances.oWhip Type Air Switch is used to interrupt the
circuit on a transmission line. An arc is drawn
when a circuit is opened as a result of the capacitive charging current of the
bus and the connected voltage transformers. The arc is quickly extinguished
by the switch's arc whips.
Exhibit No. 8
Case No. AVU-E-19-04
H. Rosentrater, Avista
Schedule 2, Page 128 ol 128
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