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Home My WebLink About20250307Staff 69 to 90.pdf RECEIVED 2025 March 6, 3:33PM IDAHO PUBLIC ADAM TRIPLETT UTILITIES COMMISSION DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334- 0318 IDAHO BAR NO. 10221 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 AVISTA ) CORPORATION'S APPLICATION FOR THE ) CASE NOS. AVU-E-25-01; AVU- AUTHORITY TO INCREASE ITS RATE AND ) G-25-01 CHARGES FOR ELECTRIC AND NATURAL ) GAS SERVICE TO ELECTRIC AND ) NATURAL GAS CUSTOMERS IN THE ) THIRD PRODUCTION STATE OF IDAHO ) REQUEST OF THE COMMISSION STAFF TO AVISTA CORPORATION Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Adam Triplett, Deputy Attorney General, requests that Avista Corporation("Company")provide the following documents and information as soon as possible,but no later than THURSDAY, MARCH 27, 2025. 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 the person preparing the documents. Please also identify the name,job title, location, and telephone number of the record holder. THIRD PRODUCTION REQUEST TO AVISTA CORPORATION 1 MARCH 6, 2025 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. 69: Please identify how many Customer Service Representatives ("CSR's") are employed by the Contact Centers. REQUEST NO. 70: Please list how many CSR's work in the Contact Centers located in Spokane, WA, Coeur d'Alene, ID, and Lewiston, ID respectively and how many work remote? REQUEST NO. 74: Please list the operating hours of the Contact Centers in each of its locations. REQUEST NO. 72: Please describe the types advertising (radio, tv,bill insert, welcome kit, etc.)that are conducted in Idaho to inform and educate customers about the following: a. Energy assistance and bill payment options; b. Energy conservation; and c. Winter Moratorium and the Winter Payment Plan. In addition,please provide copies of any written brochures or documents sent or otherwise provided to customers for each defined category listed in this question. REQUEST NO. 73: Please describe in detail the type of payment plans/arrangements the Company offers its customers. REQUEST NO. 74: For each of the past three years (2022, 2023, and 2024), how many participants were under Winter Moratorium each year. Of that amount, how many participants agreed to be placed on the winter payment plan and how many were unable to meet their monthly payment? REQUEST NO. 75: Please explain the efforts put forth by the Company to promote Project Share. THIRD PRODUCTION REQUEST TO AVISTA CORPORATION 2 MARCH 6, 2025 REQUEST NO. 76: Please provide in detail the services the Customer Assistance Referral and Evaluation Services ("CARES") team provides. REQUEST NO. 77: Please provide the number of customers the CARES team has assisted in each of the past three years (2022, 2023, and 2024) in total and jurisdiction. REQUEST NO. 78: Please explain how the CSRs determine that a customer may need to be referred to the CARES team? REQUEST NO. 79: Please list hydro projects that are controlled by the Company and hydro projects that are NOT controlled by the Company. Please also explain why the former is modeled based on the most recent five years of historical data, while the latter is modeled based on the most recent 30 years of historical data. REQUEST NO. 80: Please explain why the Forced Outage Rate for Kettle Falls Combustion Turbine was much higher in the last general rate case (Case No. AVU-E-23-01) than in this case. REQUEST NO. 81: Please respond to the following regarding the Adams-Neilson Solar Project. a. Please explain why the Adams-Neilson Solar Project enters the portfolio to serve all customers beginning January 1, 2027, instead of serving Washington State Solar Select program customers only; b. Please explain whether the project is included in the Aurora as a resource; c. Please explain why the project incurs Net Power Costs and also generates revenues; and d. Please explain how the Company removed the Net Power Costs and the revenues associated with the project out of base rates for Idaho before January 1, 2027. REQUEST NO. 82: Please explain how Washington's Climate Commitment Act ("CCA") costs are determined in this case. THIRD PRODUCTION REQUEST TO AVISTA CORPORATION 3 MARCH 6, 2025 REQUEST NO. 83: Has Kettle Falls been subject to CCA and incurred allowance costs in this case? Please explain. REQUEST NO. 84: Page 4 of Mr. Kalich's testimony states that"[m]odeled operations use the one-month average of Intercontinental Exchange ("ICE")prices from October 1, 2024, through October 31, 2024." Please update Net Power Costs using the latest one-month average of ICE prices and provide updated"Confidential Exh No 8 - Sch I - 5 —workpaper.xlsx," accordingly. REQUEST NO. 85: Please list all the physical hedging arrangements and explain how they are modeled in Aurora. Also, please explain how their costs or revenues are reflected in "Confidential Exh No 8 - Sch 1 C - 5 —workpaper.xlsx". REQUEST NO. 86: Please list all the financial hedging arrangements and explain how they are modeled in Aurora. Also, please explain how their costs or revenues are reflected in "Confidential Exh No 8 - Sch 1 C - 5 —workpaper.xlsx". REQUEST NO. 87: Please respond to the following questions regarding the new wholesale contracts that the Company proposes to be included in the base rates. a. Besides Chelan, Columbia Basin Hydro, Palouse Wind, Rattlesnake Wind, Clearwater Wind, Lancaster, Adam-Neilson(beginning in 2027), are there any other new wholesale contracts that the Company proposes to be included in the base rates? If so,please include them to make a complete list("Complete List"). b. For projects in the Complete List, please provide each project's nameplate capacity, capacity factor, energy value in aMW, first operation dates, contract length. c. Please explain what drove each project in the Complete List(i.e. capacity needs, energy needs, or Washington's environmental polices). Check all choices that apply and provide evidence to support your answers, such as the amounts and timing of capacity needs, energy needs, or environmental compliance needs. d. Please explain whether each project is appropriately sized for each need and support your answers with evidence. THIRD PRODUCTION REQUEST TO AVISTA CORPORATION 4 MARCH 6, 2025 REQUEST NO. 88: For projects in the Complete List that are only driven by Washington's environmental policies,please compare the cost of each project and the cost of purchasing equivalent energy and/or capacity from market on a net-present-value-basis using the following criteria: a. The start date of the analysis should be September 1, 2025, or the first operational date, whichever is later. b. The end date of the analysis should be the last day of the contract. c. Market prices should be based on the Mid-C market forecast prices without the impacts of CCA determined in the 2025 Integrated Resource Plan ("IRP"). d. Generation profiles of each project should be used. e. If transmission costs are associated with each project, they need to be included in the total cost of the project. f. If a project includes multiple smaller projects, each small project should be evaluated individually. g. If Renewable Energy Credits ("RECs") are generated,please include them in the analysis, but broken out separately. h. Please provide workpapers that calculate and compare the net present values. REQUEST NO. 89: For projects in the Complete List that are driven by energy needs, please explain the competitive procurement process, discuss whether the competitive procurement process was open to all sources, and provide evidence that these projects were the least-cost, least-risk projects in the bid pool (including purchases from market) at the time when they were selected. Also,please compare the cost of each project and the cost of purchasing equivalent energy and/or capacity from market on a net-present-value-basis using the following criteria: a. The start date of the analysis should be September 1, 2025, or the first operational date, whichever is later. b. The end date of the analysis should be the last day of the contract. c. Market prices should be based on the Mid-C market forecast prices without the impacts of CCA determined in the 2025 IRP. d. Generation profiles of each project should be used. THIRD PRODUCTION REQUEST TO AVISTA CORPORATION 5 MARCH 6, 2025 e. If transmission costs are associated with each project, they need to be included in the total cost of the project. f. If a project includes multiple smaller projects, each small project should be evaluated individually. g. If RECs are generated, please include them in the analysis, but broken out separately. h. Please provide workpapers that calculate and compare the net present values. REQUEST NO. 90: For projects in the Complete List that are driven by capaci . needs, please explain the competitive procurement process, discuss whether the competitive procurement process was open to all sources, and provide evidence that these projects were the least-cost, least-risk projects in the pool (including purchases from market) at the time when they were selected. Also, please compare the cost of each project and the cost of purchasing equivalent energy and/or capacity from market on a net-present-value-basis using the following criteria: a. The start date of the analysis should be September 1, 2025, or the first operational date, whichever is later. b. The end date of the analysis should be the last day of the contract. c. Market prices should be based on the Mid-C market forecast prices without the impacts of CCA determined in the 2025 IRP. d. Generation profiles of each project should be used. e. If transmission costs are associated with each project, they need to be included in the total cost of the project. f. If a project includes multiple smaller projects, each small project should be evaluated individually. g. If RECs are generated, please include them in the analysis, but broken out separately. h. Please provide workpapers that calculate and compare the net present values. THIRD PRODUCTION REQUEST TO AVISTA CORPORATION 6 MARCH 6, 2025 DATED at Boise, Idaho, this 6th day of March 2025. Adam Triplett Deputy Attorney General I:\Utility\UMISC\PRDREQ\AVU-E-25-01;AVU-G-25-01 PR#3.docx THIRD PRODUCTION REQUEST TO AVISTA CORPORATION 7 MARCH 6, 2025 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS DAY OF MARCH 2O25, SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO AVISTA CORPORATION , IN CASE NO. AVU-E-25-01/AVU-G-25-01, 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.ehrbarka avistacorp.com E-mail: david.meyerkavistacorp.com avistadocketskavistacorp.com PETER J RICHARDSON DR DON READING RICHARDSON ADAMS PLLC 6070 HILL ROAD 515 N 27TH ST BOISE ID 83703 BOISE ID 83702 E-mail: dreadingkmindsprin com E-mail: peterka richardsonadams.com ELECTRONIC ONLY Andrew P. Moratzka carol.haugenkclearwaterpaper.com Eden A. Faure Jamie.mcdonaldkclearwaterpaper.com Stoel Rives LLP 33 South 61h Street Minneapolis, MN 55402 E-MAIL: andrew.moratzkakstoel.com eden.faure(k stoel.com Jennifer S. Palmer Stoel Rives LLP 101 S. Capitol Blvd., Ste. 1900 Boise, ID 83702 E-MAIL: jenny_palmerkstoel.com �r PAT I IA JORDAN, ECRETARY CERTIFICATE OF SERVICE