20240828AVU to Staff 10_13.pdf

RECEIVED
Wednesday, August 28, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/28/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Annette Brandon
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff-010 Supplemental TELEPHONE: [phone]
REQUEST:
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.
SUPPLEMENTAL RESPONSE (08/28/2024):
Please see the following responses regarding surplus thermal generation:
As described in the original response to Staff_PR 010, part (c), Avista does not include carbon
allowance pricing in its dispatch decisions. Avista dispatches its generation fleet based on
commitment and incremental dispatch costs. Once dispatched the energy is then sold into the
market (i.e. off-system sales) or delivered to serve load. The costs associated with dispatch form
the basis for sales price. As such, no carbon costs are included in the "prices of sold energy."
ORIGINAL RESPONSE (08/22/2024)
Please see the following responses regarding surplus thermal generation:
a. The Department of Ecology has yet to confirm whether Avista will be held accountable to
the formula associated with WAC 173-441 (greenhouse gas reporting) or WAC 173-446
(climate commitment act).
b. In Washington State, electric ratepayers receive no-cost allowances. As noted in the
response to part(a), it is yet to be determined if off-system sales are covered in the true up
mechanism.
c. No, the Company does not include CCA allowance cost in its dispatch decisions, with the
exception of Idaho's portion(approximately 35%) of obligations related to Boulder Park.

RECEIVED
Wednesday, August 28, 2024
IDAHO PUBLIC
d. No. The Company currently operates its electric operations on a system-level l�aJisT`IvE1COMMISSION
the exception of Boulder Park.

RECEIVED
Wednesday, August 28, 2024
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/28/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Annette Brandon
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff-013 Supplemental TELEPHONE: [phone]
REQUEST:
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 CCA costs with the dispatch of Boulder Park in this
PCA.
SUPPLEMENTAL RESPONSE (08/28/2024):
a. Please see the Company's response to Staff_PR_010 that notes"No,the Company does not
include CCA allowance cost in its dispatch decisions,with the exception of Idaho's portion
(approximately,) of obligations related to Boulder Park" (emphasis added). However,
please note shareholders bear the cost associated with Idaho's portion of allowances.
b. The Company understands this production request is specific to cost considerations for the
Climate Commitment Act, and not the overall dispatch decision-making process. As such,
please see the response to part (a) above.
c. Yes. As noted above, the Company only includes Idaho's share of carbon allowance costs
in its dispatch decisions. Until such time as additional guidance is provided concerning
which standard the Company will be held accountable to (the forecast vs. the reporting
requirements), the Company assumes Boulder will be covered by no-cost allowances for
Washington's customers. Please see the Company's response to Staff PR 010 part(a).
d. Allowance costs are recorded in account 509.10. However, as Avista was ordered not to
include any costs associated with the Climate Commitment act in Idaho's PCA,no amount
was included in the PCA calculation.
e. No expenses associated with the Climate Commitment Act are included in the PCA, in
accordance with Commission requirements.
ORIGINAL RESPONSE (08/22/2024):
Parts (a)—(d): Please see the Company's response to Staff PR_011.

RECEIVED
Wednesday, August 28, 2024
Part (e): No expenses associated with the Climate Commitment Act are included in the PCA J$AHO PUBLIC
accordance with Commission requirements. UTILITItS COMMISSION