20240815Staff 9-27 to AVU.pdf

RECEIVED
Thursday, August 15, 2024 11:48:35 AM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE POWER COST )
ADJUSTMENT (PCA)ANNUAL RATE ) CASE NO. AVU-E-24-07
ADJUSTMENT FILING OF AVISTA )
CORPORATION )
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Avista Corporation, doing business as
Avista Utilities (hereinafter"Avista" or"Company")provide the following documents and
information as soon as possible, but no later than MONDAY,AUGUST 26, 2024.1
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0314.
SECOND PRODUCTION REQUEST
TO AVISTA 1 AUGUST 15, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 9: Please respond to the following regarding the EIM benefits:
a. Please provide the dollar value of EIM benefits;
b. Please explain how the dollar values of EIM benefits are determined;
c. Please explain whether the methodology that determines EIM benefits is approved by
the Commission; and
d. Please provide evidence showing that EIM O&M included in the PCA does not
exceed EIM benefits.
REQUEST NO. 10: Please respond to the following regarding the CCA costs associated
with surplus thermal generation imported into Washington and subsequently sold to the market
as off-system sales ("off-system sales").
a. Please explain whether no-cost allowances for Washington's portion of the CCA
costs associated with the off-system sales are provided by the Washington
Department of Ecology.
b. Please confirm that Washington ratepayers pay for Washington's portion of CCA
costs associated with the off-system sales.
c. When the Company decides to make off-system sales, does it consider the CCA costs
in setting the prices of sold energy? Please describe the price-setting considerations
in the decision-making process.
d. Are the price-setting considerations for Idaho ratepayers different than those for
Washington ratepayers? Please explain.
REQUEST NO. 11: Page 14 of Holland's Direct Testimony states that"Avista
shareholders absorbed approximately $700,000 in carbon expense for the sales benefit." Please
respond to the following:
SECOND PRODUCTION REQUEST
TO AVISTA 2 AUGUST 15, 2024

a. Please explain how the $700,000 is calculated and provide workpapers for the
calculation.
b. Is the $700,000 based on the expenses associated with CCA allowance purchases,
regardless of whether the allowances are retired to meet the CCA target?
c. Is the $700,000 only associated with Idaho's allocation of off-system sales or does it
include Washington's allocation of the off-system sales? Please explain.
REQUEST NO. 12: Please respond to the following regarding CCA costs associated
with Idaho's share of Boulder Park generation:
a. Please explain the amount of CCA costs associated with Idaho's share of Boulder
Park generation;
b. Please explain whether the amount is absorbed by Avista shareholders; and
c. Is the amount based on the expenses associated with CCA allowance purchases,
regardless of whether the allowances are retired to meet the CCA target? Please
explain.
REQUEST NO. 13: Please respond to the following regarding Boulder Park's dispatch
costs:
a. Please explain whether CCA costs are considered in the dispatch costs of Boulder
Park.
b. Please describe the cost-setting considerations in the dispatch decision-making
process.
c. Are the dispatch costs of Boulder Park set differently for Idaho ratepayers than for
Washington ratepayers? Please explain.
d. Please explain which accounts captured those CCA costs associated with the dispatch
of Boulder Park.
e. Please provide the total amount of the CCA costs with the dispatch of Boulder Park in
this PCA.
REQUEST NO. 14: Please explain whether only 90% of the Palouse Wind costs are
included in the actual net power costs. Please provide evidence to support your answer.
SECOND PRODUCTION REQUEST
TO AVISTA 3 AUGUST 15, 2024

REQUEST NO. 15: Please explain whether only 90% of the Rattlesnake Flat Wind
costs are included in the actual net power costs and provide evidence to support your answer.
REQUEST NO. 16: Please provide the workpapers that calculate the actual monthly
costs of the Chelan contract.
REQUEST NO. 17: Please provide the workpapers that calculate the actual monthly
costs of the Columbia Basin Hydro ("CBH") contract.
REQUEST NO. 18: Please provide the workpapers that calculate the actual monthly
costs of the CBH transmission.
REQUEST NO. 19: The actual purchased power expenses incurred by the Company are
different than those reflected in Account 555 in IPUC Deferral Analysis due to reasons such as
the Stipulation in Case No. AVU-E-23-01. Please provide a breakdown of the Company's actual
purchased power expenses by month and by seller and a breakdown of the actual Account 555
included in the IPUC Deferral Analysis by month and by counterparty. Please reconcile the two
and explain the cause for the difference.
REQUEST NO. 20: The actual transmission expenses incurred by the Company are
different than those reflected in Account 565 in IPUC Deferral Analysis due to reasons such as
the Stipulation in Case No. AVU-E-23-01. Please provide a breakdown of the Company's actual
transmission expenses by month and by transmission provider and a breakdown of the actual
Account 565 included in the IPUC Deferral Analysis by month and by counterparty. Please
reconcile the two and explain the cause for the difference.
REQUEST NO. 21: Please define Cost Variance in Table No. 1, on page 16 of
Holland's Direct Testimony. Also,please explain why the sum of all Cost Variances is equal to
the Total Variance.
SECOND PRODUCTION REQUEST
TO AVISTA 4 AUGUST 15, 2024

REQUEST NO. 22: Please define Generation Variance in Table No. 1, on page 16 of
Holland's Direct Testimony. Also,please explain why the sum of all Generation Variances is
zero.
REQUEST NO. 23: According to the Clearwater Agreement, net revenue from the sale
of Clearwater generated RECs will be split between the Company(10%) and Clearwater(90%).
Please provide evidence showing that the amounts of revenue reflected in Line "456380 ED ID—
Sch 25P REC Revenue" in the IPUC Deferral Analysis corresponds to 10% of the net revenue
from the sale of Clearwater generated RECs.
REQUEST NO. 24: Please respond to the following regarding Line "456030 ED ID-
Sch 25 P Transmission"in the IPUC Deferral Analysis:
a. Please explain what Line "456030 ED ID-Sch 25 P Transmission"represents;
b. Please explain how the values on the Line "456030 ED ID-Sch 25 P Transmission"
are determined and provide workpapers that calculate the values;
c. Please explain how the MWhs used in the calculation of actual purchase power
expenses are determined;
d. Please explain why the value remains at the same level ($13,750) from July 2023
through February of 2024;
e. Please explain why the value starts changing from March of 2024 on; and
f. Please explain why the value varies from month-to-month after March of 2024.
REQUEST NO. 25: If Line "456030 ED ID-Sch 25 P Transmission" does not represent
the deferral of purchase power expenses the Company pays Clearwater,please explain where
such a deferral is located in the IPUC Deferral Analysis. Also,please provide workpapers that
calculate such a deferral. Lastly,please explain how the MWhs used in the calculation of actual
purchase power expenses of Clearwater are determined.
REQUEST NO. 26: Please provide Clearwater's amount of generation and load by month
during the deferral period.
SECOND PRODUCTION REQUEST
TO AVISTA 5 AUGUST 15, 2024

REQUEST NO. 27: Please provide the forced and unforced downtime that lasted over
24 hours for each of the Company's generation plants during the deferral period and provide the
causes of each downtime.
DATED at Boise, Idaho, this 15th day of August 2024.
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\AVU-E-24-07 PR 42.docx
SECOND PRODUCTION REQUEST
TO AVISTA 6 AUGUST 15, 2024

CERTIFICATE OF SERVICE
5
I HEREBY CERTIFY THAT I HAVE THIS 1 DAY OF AUGUST 2024,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-24-07, BY
E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP & CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: patrick.ehrbargavistacorp.com E-mail: david.meyergavistacorp.com
docketskavistacorp.com
PA RICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE