20240820Staff 27-33 to AVU.pdf

RECEIVED
Tuesday, August 20, 2024 3.49.06 PM
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 )
THIRD 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 TUESDAY,AUGUST 27, 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.
THIRD PRODUCTION REQUEST
TO AVISTA 1 AUGUST 20, 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. 27: Order No. 33605 directed the Company to break out separate line
items for actual and authorized REC revenue and expenses outside its Resource Optimization
account. Please respond to the following:
a. Please explain if the Company incurs any REC expenses during the deferral period;
b. If so,please list the specific causes for the REC expenses; and
c. Please explain which account includes REC expenses in the IPUC Deferral Analysis.
REQUEST NO. 28: Please respond to the following regarding "Purchases" on Tab
"Detail" of the"July 2023 - June 2024 Variance Analysis.xlsx" file:
a. Please define "Purchases" and explain what purchase items are included;
b. Please break Line 17 (actual Purchases), Line 38 (authorized Purchases), Line 59
(cost variance of Purchases)by each item; and
c. Please explain the relationship between"Purchases" and Account 555.
REQUEST NO. 29: Please respond to the following regarding "Sales" on Tab "Detail"
of the "July 2023 -June 2024 Variance Analysis.xlsx" file:
a. Please define "Sales" and explain what sale items are included;
b. Please break Line 18 (actual Sales), Line 39 (authorized Sales), Line 60 (cost
variance of Sales)by each item; and
c. Please explain the relationship between "Sales" and Account 447.
REQUEST NO. 30: Please respond to the following regarding Clearwater Agreement:
a. Please provide the contract provision(s)that determine the sharing of transmission
costs between Avista and Clearwater reflected in Line "456030 ED ID— Sch 25P
Transmission" in the IPUC Deferral Analysis;
THIRD PRODUCTION REQUEST
TO AVISTA 2 AUGUST 20, 2024

b. Please reference the page number of the contract provision(s) in the Clearwater
Agreement; and
c. Please provide evidence showing that the amount of transmission costs complies with
the contract provision(s).
REQUEST NO. 31: Please explain why the power purchase expense that Avista pays
Clearwater is not recorded in the IPUC Deferral Analysis.
REQUEST NO. 32: Please respond to the following regarding Tab "Prices" of the
"2024 Idaho PCA—Holland Workpapers—Testimony Charts.xlsx" file and Tab "Detail" of the
"July 2023 - June 2024 Variance Analysis.xlsx" file:
a. Please reconcile the Mid-C on-peak prices and off-peak prices for June 2024 on this
Tab with those on Tab "Detail" of the "July 2023 - June 2024 Variance
Analysis.xlsx" file and explain what causes the difference; and
b. Please explain how the Mid-C on-peak prices and off-peak prices for June 2024 on
Tab "Detail" of the"July 2023 - June 2024 Variance Analysis.xlsx" file are
calculated.
REQUEST NO. 33: The footnote on page 15 of Holland's Direct Testimony shows
generation various is calculated as follows:
Gen. Var=(actual HL MWh—authorized HL MWh) * Actual HL price + (actual LL MWh—
authorized LL MWh) * Actual LL price, where Actual HL price and Actual LL price are actual
Mid-C on-peak and off-peak prices.
a. Please explain why the Company uses the actual Mid-C prices in the calculation,
instead of the actual prices of each resource being analyzed (such as gas, hydro, coal,
etc.); and
b. Please explain whether the impact of volume variance will be overestimated or
underestimated when the actual prices of each resource being analyzed deviates from
the actual Mid-C prices.
THIRD PRODUCTION REQUEST
TO AVISTA 3 AUGUST 20, 2024

DATED at Boise, Idaho, this 20'b day of August 2024.
b"j-t'
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\AVU-E-24-07 PR#3.docx
THIRD PRODUCTION REQUEST
TO AVISTA 4 AUGUST 20, 2024

CERTIFICATE OF SERVICE
el
I HEREBY CERTIFY THAT I HAVE THIS 2VtDAY OF AUGUST 2024,
SERVED THE FOREGOING THIRD 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.me er ,avistacorp.com
docketskavistacorp.com
PATRICIA JORDAT4, SECRETARY
CERTIFICATE OF SERVICE