20250228AVU to Staff 5 Attachment A - 2024 ID 3rd Qtr - Combined.pdf

Office of the Secretary
Service Date
July 2,2024
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA ) CASE NO.AVU-E-23-15
CORPORATION'S AND CLEARWATER )
PAPER CORPORATION'S JOINT PETITION ) ERRATA TO
FOR APPROVAL OF AMENDMENT NO. 1 ) ORDER NO. 36157
TO POWER PURCHASE AND SALE )
AGREEMENT )
On April 23, 2024, the Commission issued Order No. 36157 in Case No. AVU-E-23-15.
The following changes should be made to Order 36157:
Starting Page 1, paragraph 5:
READS:
As noted by Staff, despite this error, the avoided cost rate paid by Clearwater under the
Schedule 25P Block 2 Generation Load rate will offset the absence of capacity payments
for the one-month period in December 2026.
SHOULD READ:
Despite this error, Staff recommended approval of the avoided cost rate because the rate
will be offset by the Schedule 25P Block 2 Generation Load rate Clearwater pays Avista.
DATED at Boise, Idaho this 211d day of July 2024.
Mon'6aWa f rio
Commission Secretary
I:\Legal\ELECTRIC\AV U-E-23-15\orders\AV UE2315_Euata_36157_md.docx
ERRATA TO ORDER NO. 36157 1

Office of the Secretary
Service Date
August 5,2024
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA ) CASE NO. AVU-E-24-06
CORPORATION AND FORD HYDRO )
LIMITED PARTNERSHIP'S JOINT ) ORDER NO. 36282
PETITION FOR APPROVAL OF A POWER )
PURCHASE AGREEMENT )
On May 16, 2024,Avista Corporation d/b/a Avista Utilities ("Company") and Ford Hydro
Limited Partnership ("Seller") (collectively, "Parties") submitted a joint petition to the Idaho
Public Utilities Commission ("Commission") for approval of a Power Purchase Agreement
("PPA")that would authorize the sale of energy from Seller's hydroelectric facility("Facility")to
the Company ("Petition"). The proposed PPA was filed concurrently with the Petition as
Attachment A.
On June 20, 2024, the Commission issued a Notice of Petition and established public
comment and Party reply deadlines. Order No. 36234. Commission Staff("Staff') filed comments
to which the Parties did not respond.
With this Order, we approve the proposed PPA subject to a compliance filing as discussed
below.
THE PETITION
The Parties intend the proposed PPA to replace the current PPA which expired on June 30,
2024. The proposed PPA would expire on June 30, 2026.
The Parties stated that the proposed PPA largely parallels the existing PPA but has been
updated to reflect or clarify language regarding Commission mandates related to the 90/110 Rule,
the PPA's provisions regarding the modifications to the Facility, and the necessity of obtaining
Commission approval for amending the PPA.
STAFF COMMENTS
Staff recommended approval of the Parties' proposed PPA subject to a compliance filing
for the items discussed below.
ORDER NO. 36282 1

The PPA's Fourth Recital and the Rolling Window of Delivered Net Output Estimates
The proposed PPA's fourth recital mistakenly states that the current PPA's expiration date
is June 29, 2024, instead of June 30, 2024. Likewise, the Company stated during discovery that it
desired to adopt a three-month rolling window of Delivered Net Output estimates whereas the PPA
mistakenly stated it would have a six-month rolling window. Staff recommended that these errors
be corrected.
Renewable Energy Credits and Technology Type
The PPA stated that, to the full extent allowed by applicable laws or regulations, the
Company shall own 50% of the Environmental Attributes associated with the Net Delivered
Output. During discovery the Company further clarified that 100% of the Renewable Energy
Credits will go to the relevant qualifying facility in accordance with Commission Order No. 32802.
Staff also recommended that the PPA specify that the Facility is a non-seasonal hydro project to
ensure that it does not get mistakenly identified as a seasonal hydro project.
Section 10.6 (Modifications), Eli_ibility for Capacity Payments, and the 90/110 Rule
Staff recommended that Section 10.6 of the PPA cite Section 22 of the PPA (rather than
mistakenly citing Section 21) regarding modifications to the Facility. Relatedly, Staff
recommended that, regardless of the actual compensation paid to the Facility after modification,
the Company should only be allowed to recover (through the Power Cost Adjustment ("PCA"))
the net power supply expenses reflecting the authorized rate for energy delivered as of the first
operation date of the modified Facility.
Staff also reviewed the Commission's standards for receiving capacity payments and
recommended that the Company be granted capacity payments as part of the renewal of the PPA.
Staff stated that the Facility has a 1.8-megawatt nameplate capacity. Staff explained that,while the
Facility will operate past the operation date of the previous contract,this should not affect capacity
payments—since the Facility will not generate energy until December due to a lack of water flow.
Staff also discussed the 90/110 Rule and recommended that the PPA adopt it and the associated
five-day advanced notice relative to the Seller potentially adjusting its Delivered Net Output
Estimates.
ORDER NO. 36282 2

Avoided Cost Rates
Staff noted a mistake in Section 6.1 and recommended that the phrase"not Surplus Energy"
should be replaced with "not Surplus Energy or Shortfall Energy." Staff also believed that the
PPA's usage of the term "Effective Date" indicates July 1, 2024. Staff argued that the term
"Effective Date" should be replaced with the proper date of May 15, 2024. Staff stated that this
date should be used as this is the date that the Company established Legally Enforceable
Obligations and when avoided cost rates were locked in. Lastly, Staff noted that Exhibit E cites
Section 11.1—which does not exist. Staff believed that Exhibit E should have referenced Section
6.1. Staff recommended that these items be corrected.
Lapsed Contract Period
Staff echoed the Commission's concerns from previous cases regarding late filed renewal
contracts (this case was filed approximately 46 days before the requested effective date). Despite
the Company's late filing, Staff recommended that the Commission order a retroactive effective
date in this case of July 1, 2024. Staff noted that this way the Parties could use the avoided cost
rates in the approved contract and implement the necessary provisions related to the avoided cost
rates during the period between July 1, 2024, and the publication of the Final Order in this case.
Staff also cited other cases where a retroactive effective date was ordered by the Commission.
COMMISSION FINDINGS AND DECISION
The Commission has jurisdiction over this matter under Idaho Code §§ 61-502 and 61-
503. The Commission is empowered to investigate rates, charges,rules,regulations,practices, and
contracts of public utilities and to determine whether they are just, reasonable, preferential,
discriminatory, or in violation of any provision of law, and to fix the same by order. Idaho Code
§§ 61-502 and 61-503. The Commission also has authority under the Public Utility Regulatory
Policies Act of 1978 ("PURPA") and Federal Energy Regulatory Commission ("FERC")
regulations to set avoided cost rates, to order electric utilities to enter fixed-term obligations for
the purchase of energy from qualify facilities, and to implement FERC rules. The Commission
may enter any final order consistent with its authority under Title 61 and PURPA.
Having reviewed the record in this case, the Commission finds it reasonable and in the
public interest to approve the Company's request subject to a compliance filing correcting the
issues described in Staff s comments. The Commission notes that Staff s comments recommended
ORDER NO. 36282 3

that several typographical and other errors be corrected. The Company did not file any comments
to contest these recommendations. Accordingly, the Commission finds it reasonable to order the
Company to fix these issues identified by Staff and submit a compliance filing within 30 days of
issuance of this Order.
The Commission also orders that, if the Facility is modified, only the net power supply
expense that reflects the proper authorized rate for all energy delivered as of the first operation
date of the modified Facility be included in the Company's PCA, regardless of the compensation
paid to the modified Facility. This treatment is consistent with the Commission direction in Order
No. 35705.
Subject to the Company meeting the requirements of this Order, the Commission orders
that the PPA will have an effective date of July 1, 2024, and that all payments for purchases of
energy under the PPA be allowed as prudently incurred expenses for ratemaking purposes.
ORDER
IT IS HEREBY ORDERED that the Company's proposed PPA is approved subject to a
compliance filing correcting the typographical and other errors identified by Staff. This filing must
be submitted to the Commission within 30 days of the publication of this Order. Once these errors
have been corrected,the PPA shall be approved effective July 1,2024,and all payments for energy
and capacity shall be prudent for ratemaking purposes.
IT IS FURTHER ORDERED that, if the Facility is modified, only the net power supply
expense reflecting the authorized rate for all energy delivered as of the first operation date of the
modified Facility shall be included in the Company's PCA.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order about any matter
decided in this Order. Within seven (7) days after any person has petitioned for reconsideration,
any other person may cross-petition for reconsideration.Idaho Code § 61-626.
ORDER NO. 36282 4

DONE by order of the Idaho Public Utilities Commission at Boise, Idaho this 5th day of
August 2024.
ERIC ANDERSON, PRESIDENT
J R. HAMMOND JR., COMMISSIONER
EDWARD LODGE, COMMISSIONER
ATTEST:
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a Ba YCio
Commission Secre
IALega1\ELECTRIC\AVU-E-24-06_Ford Hydro\orders\AVUE2406_Final_md.docx
ORDER NO. 36282 5

Office of the Secretary
Service Date
August 30,2024
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA ) CASE NO. AVU-E-24-06
CORPORATION AND FORD HYDRO )
LIMITED PARTNERSHIP'S JOINT )
PETITION FOR APPROVAL OF POWER ) ORDER NO. 36310
PURCHASE AGREEMENT )
On May 16, 2024,Avista Corporation d/b/a Avista Utilities ("Company") and Ford Hydro
Limited Partnership ("Seller") (collectively, "Parties") submitted a joint petition to the Idaho
Public Utilities Commission ("Commission") for approval of a Power Purchase Agreement
("PPA") that would authorize the sale of energy from Seller's hydroelectric facility to the
Company ("Petition").
On August 5, 2024, the Commission issued Order No. 36282 that approved the PPA
contingent on the Parties correcting several typographical and other errors identified by the
Commission Staff("Staff'), effective July 1, 2024.
At the Commission's August 13, 2024, Decision Meeting, Staff presented a Decision
Memorandum which noted that Staff had reviewed the Company's July 23,2024,Amendment No.
1 to the PPA and recommended the Commission issue an Order specifying that the Company had
complied with Commission requirements set forth in Order No. 36282.
COMMISSION FINDINGS AND DISCUSSION
The Commission has jurisdiction over this matter under Idaho Code §§ 61-502 and 61-
503. The Commission is empowered to investigate rates, charges,rules,regulations,practices, and
contracts of public utilities and to determine whether they are just, reasonable, preferential,
discriminatory, or in violation of any provision of law, and to fix the same by order. Idaho Code
§§ 61-502 and 61-503.
The Commission finds the Company has complied with our requirement that the
typographical and other errors identified by Staff be corrected before the PPA is fully approved.
Pursuant to our findings in this Order, the PPA as modified by Amendment No. 1, is approved,
effective as of July 1, 2024. All payments for purchases of energy under the PPA be allowed as
prudently incurred expenses for ratemaking purposes.
ORDER NO. 36310 1

ORDER
IT IS HEREBY ORDERED that the Company's PPA, as modified by Amendment No. 1,
is approved effective July 1, 2024, and all payments for purchases of energy under the PPA shall
be allowed as prudently incurred expenses for ratemaking purposes.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order about any matter
decided in this Order. Within seven (7) days after any person has petitioned for reconsideration,
any other person may cross-petition for reconsideration.Idaho Code § 61-626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 30"' day of
August 2024.
ERIC ANDERSON, PRESIDENT
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HN R. HAMMOND JR., COMMISSIONER
G
EDWARD LODGE, CONWISSIONER
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Commission Secretary
I:\Legal\ELECTRIC\AVU-E-24-06_Ford Hydro\orders\AVUE2406_Comp_md.doex
ORDER NO. 36310 2

Office of the Secretary
Service Date
September 6,2024
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION ) CASE NO. GNR-E-24-01
STAFF'S APPLICATION TO UPDATE )
INPUTS TO THE SURROGATE AVOIDED ) NOTICE OF APPLICATION
RESOURCE METHOD AVOIDED COST )
RATES ) NOTICE OF INTERVENTION
DEADLINE
NOTICE OF MODIFIED
PROCEDURE
ORDER NO. 36314
On August 16, 2024, Staff of the Idaho Public Utilities Commission ("Staff') applied for
an order (1) updating Surrogate Avoided Resource Model ("SAR Model") inputs; (2) making
administrative changes to the SAR Model; and (3) approving SAR-based avoided cost rates
included with the Application. Staff asserts that updating the SAR Model inputs is necessary
because the U.S. Energy Information Administration ("EIA") did not publish an Annual Energy
Outlook in 2024, which previously served as the basis for annual SAR Model updates. Staff
proposes using different inputs to update the SAR Model until a new EIA forecast becomes
available. Staff requested this matter be processed via Modified Procedure.
The Commission now issues this Notice of Application, Notice of Intervention deadline,
and Notice of Modified Procedure and sets deadlines by which interested persons may intervene.
NOTICE OF APPLICATION
YOU ARE HEREBY NOTIFIED that, in Order No. 32697, the Commission found it
appropriate to update the SAR Model with the most recent annual gas forecast from EIA's Annual
Energy Outlook.
YOU ARE FURTHER NOTIFIED that Staff represents that the EIA did not publish an
Annual Energy Outlook in 2024. Therefore, changing the inputs to update the SAR Model is
necessary.
YOU ARE FURTHER NOTIFIED that Staff proposes using "the average of AECO Hub
prices, Stanfield Hub prices, Sumas Hub prices, and Opal Hub prices from the December 2023
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 36314 1

natural gas price forecast published by Northwest Power and Conservation Council"to update the
SAR Model until the EIA forecast becomes available. Application at 2.
YOU ARE FURTHER NOTIFIED that Staff proposes separating the SAR Model into a
separate model for each of Idaho's three largest electric utilities (i.e., an Avista SAR Model, an
Idaho Power SAR Model, and a Rocky Mountain Power SAR Model.). Staff contends this will
simplify the update process by avoiding multiple simultaneous updates to a single model by
different utilities.
YOU ARE FURTHER NOTIFIED that the Application and Attachments have been filed
with the Commission and are available for public inspection during regular business hours at the
Commission's office. These documents are also available on the Commission's website at
www.puc.idaho.gov. Click on the "Electric"icon, select"Open Cases,"and then click on the case
number as shown on the front of this document.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held pursuant
to the Commission's jurisdiction under Title 61 of the Idaho Code, and that all proceedings in this
matter will be conducted pursuant to the Commission's Rules of Procedure, IDAPA 31.01.01.000
et seq.
NOTICE OF INTERVENTION DEADLINE
YOU ARE FURTHER NOTIFIED that persons desiring to intervene in this matter to
obtain parties' rights of participation must file a Petition to Intervene with the Commission
pursuant to this Commission's Rules of Procedure 72 and 73, IDAPA 31.01.01.072 and -.073.
Persons who wish to intervene as a party must file a Petition to Intervene no later than 21
days after the date of service of this Order. Such persons shall also provide the Commission
Secretary with their email address to facilitate further communications. After the intervention
deadline runs, the Commission Secretary shall issue a Notice of Parties that identifies the parties
and assigns exhibit numbers to each party. Once the Notice of Parties has issued, Commission
Staff shall informally confer with the Company and any intervening parties about how to further
process this case and shall then report back to the Commission on a proposed case schedule.
YOU ARE FURTHER NOTIFIED that persons who would like to present their views
without parties' rights of participation and cross-examination do not have to intervene but may
present their views by submitting written comments to the Commission.
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 36314 2

NOTICE OF MODIFIED PROCEDURE
YOU ARE FURTHER NOTIFIED that the Commission has determined that the public
interest may not require a formal hearing in this matter, and it will review the case through written
submissions under the Commission's Rules of Modified Procedure Rules 201-204 of the Idaho
Public Utilities Commission's Rules of Procedure, IDAPA 31.01.01.201-204. The Commission
notes that Modified Procedure and written comments have proven to be an effective means for
obtaining public input and participation.
YOU ARE FURTHER NOTIFIED that persons desiring to state a position on this
Application may file a written comment explaining why they support or oppose the Application.
Persons who would like a hearing must specifically request a hearing in their written comments.
Persons shall have until October 10, 2024, to file written comments. Comments must be filed
through the Commission's website or by e-mail unless computer access is unavailable. To
comment electronically,please access the Commission's website at www.puc.idaho.gov. Click the
"Case Comment Form" and complete the form using the case number as it appears on the front of
this document.
To file by e-mail, persons must e-mail the comments to the Commission Secretary and all
parties at the e-mail addresses listed below. Persons submitting a comment by e-mail must provide
their name, address, and the Case Number under which they are commenting. Persons submitting
a comment by e-mail also acknowledge that submitting a comment in an open case constitutes a
public record under Idaho Code § 74-101(13), and all information provided by such person is
available for public and media inspection.
If computer access is unavailable, then comments may be mailed to the Commission and
the Parties at the addresses below.Persons submitting a comment by mail must provide their name,
address, and the Case Number under which they are commenting. Persons submitting a comment
by mail also acknowledge that submitting a comment in an open case constitutes a public record
under Idaho Code§ 74-101(13),and all information provided by such person is available for public
and media inspection.
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 36314 3

For the Idaho PUC:
Commission Secretary Adam Triplett
Idaho Public Utilities Commission Deputy Attorney General
P.O. Box 83720 Idaho Public Utilities Commission
Boise, ID 83720-0074 P.O. Box 83720
secretMgpuc.idaho.gov Boise, ID 83720-0074
Street Address for Express Mail:
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
YOU ARE FURTHER NOTIFIED that Staff must file any reply comments by October
24, 2024.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are received
within the time limit set,the Commission will consider this matter on its merits and enter its order
without a formal hearing. If written comments are received within the time limit set, the
Commission will consider them and, in its discretion, may set the same for formal hearing.
ORDER
IT IS HEREBY ORDERED that persons desiring to intervene in this matter must file a
Petition to Intervene no later than 21 days from the service date of this Order. Once the deadline
has passed, the Commission Secretary shall prepare and issue a Notice of Parties.
IT IS FURTHER ORDERED that Staff s Application be processed by Modified Procedure,
Rules 201-204. Persons interested in submitting written comments must do so by October 10,
2024. Staff must file any reply comments by October 24, 2024.
IT IS FURTHER ORDERED that parties comply with Order No. 35375, issued April 21,
2022. Generally, all pleadings should be filed with the Commission electronically and will be
deemed timely filed when received by the Commission Secretary.See Rule 14.02. Service between
parties should continue to be accomplished electronically when possible. However, voluminous
discovery-related documents may be filed and served on CD-ROM or a USB flash drive.
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 36314 4

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 6t' day of
September 2024.
ERIC ANDERSON, PRESIDENT
J R. HAMMOND JR., COMMISSIONER
G
Gv�
ED ARD LODGE, CO MI ONER
ATTEST:
Moni ios- a e
Commission Secretary
I:\Legat\ELECTRIC\GNR-E-24-01_SAR\orders\GNRE2401 NtcApp_Mod_Int_at.docx
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 36314 5