20240827AVU to Staff 28-34.pdf

RECEIVED
Tuesday,August 27, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/26/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 028 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
a. The Company incurred REC expenses during the PCA review period, however, those
expenses were excluded from the PCA.
b. These expenses reflect broker fees associated with REC transactions.
c. Broker fees associated with REC transactions are recorded in FERC Account 557171, in
accordance with GAAP.

RECEIVED
Tuesday,August 27, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/26/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 029 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Please see Avista's response Staff_PR_029C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
a. Purchases represent the expenses associated with acquiring power from outside of Avista's
generation fleet. Purchases include market purchases, PPA costs and EIM costs.
b. See Staff_PR 029C Confidential Attachment A.'
c. Account 555 is designated by FERC as Purchased Power.
1 Please note,within Schultz workpaper"IPUC Deferral Analysis,"the summation of excel row 32 (555 Purchased
Power), row 38 (90% Palouse Wind and Rattlesnake Flats), and row 39 (Remove Columbia Basin Hydro
Transmission Project) in total, $99,146,597, ties to the "Authorized 555 Purchased Power" in Staff_PR_029C
Confidential Attachment A.

RECEIVED
Tuesday,August 27, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/26/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 030 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
a. Sales represents the dollars received as a result of the sale of electricity to a counterparty. It
includes 447 Sales for Resale and also includes 456 Other Electric Revenue.
b. See the Company's response to Staff_PR_029C Confidential Attachment A.
c. Account 447 is designated by FERC as Sales for Resale.

RECEIVED
Tuesday,August 27, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/26/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 031 TELEPHONE: [phone]
REQUEST:
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;
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).
RESPONSE:
The Clearwater PPA does not contain specific language that determines the sharing of
transmission costs between Avista and Clearwater, however transmission costs are within the
definition of"Net Revenue from Sales of the Product"as included in the 2018 Clearwater contract.
The sharing provisions were determined via Commission Order (No. 34252) and Avista has
complied with that order since issued.
To provide evidence that transmission costs are subject to the referenced sharing mechanism,
please see Staff_PR_031 Attachment A for a copy of the monthly journal in which the adjustment
is recorded.

RECEIVED
Tuesday, August 27, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/26/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 032 TELEPHONE: [phone]
REQUEST:
Please explain why the power purchase expense that Avista pays Clearwater is not recorded in the
IPUC Deferral Analysis.
RESPONSE:
The Clearwater power purchase expense is recorded in Account 555380 ED.ID,which is included
in the IPUC Deferral Analysis under 555 Purchased Power. Please see tabs "Review Period
Actual", "2023", and "2024" of Staff_PR_029 Attachment A for the detailed actual expenses for
555 Purchased Power which includes account 555380.

RECEIVED
Tuesday,August 27, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/26/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 033 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
a. The June 2024 values provided in Holland workpapers were inadvertently left as an
estimate and should have been updated. This inadvertent error does not impact the
Company's data, calculations, variances or deferrals and would only result in a slight
variation in the presentment of Figures 1 and 2.
b. Mid-C prices represent the actual average price for energy during heavy load hours (HLH)
and light load hours (LLH) values during the month.

RECEIVED
Tuesday, August 27, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/26/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 034 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
a. The intent of the generation variance is to identify each resource's contribution to meeting
load. Using Mid-C pricing for each resource establishes a standardized value so the
variable in the equation is the generation amounts. If actual prices per resource were used,
the resulting variance would not be a generation variance and instead would be a mixture of
cost variance and generation variance. Total variance equals the cost variance plus the
generation variance. The cost variance incorporates the actual costs and quantities of each
resource's production as compared to authorized. The generation variance estimates the
value (at Mid-C actual prices) of the market purchases or sales that resulted from each
resource's generation volume variance.
b. In the context of the question asked, volumes as a component of a variance analysis are an
independent input and would not be impacted by a difference between actual prices and
Mid-C prices. The input costs of production affect the cost variance. The Mid-C prices
affect the generation variance. There is no relationship between costs of production and
Mid-C prices.