20230518AVU to Staff 1-2.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-04 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Annette Brandon TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-001 TELEPHONE: [phone] REQUEST:
Please explain in detail how the Company plans to determine actual emission expenses for Idaho under Washington's Climate Commitment Act ("CCA"). RESPONSE:

Please reference the following section from Company witness Kalich’s direct testimony in Case AVU-E-23-01/AVU-G-23-01, page 8, lines 10:16: Specific to Avista, the new law covers carbon emissions generated by the following:
• Washington situs-based thermal plants (except Kettle Falls Generating Station and Northeast Combustion Turbine as their annual emissions fall below the 25,000 metric ton threshold),
• Washington’s multi-jurisdictional share of thermal plants located outside of
Washington State,
• Carbon-emitting thermal generation imported into Washington, and
• All non-specified electricity imported into Washington.1

At the point when each of those situations arise, Avista incurs a carbon obligation, and an expense must be recorded to the general ledger. For additional information, including the interaction of these expenses with the purchase of the carbon allowance, please see the Company’s response to Staff_PR_169 in the above referenced case, and which has been attached here at Staff_PR_001
Attachment A

1 The Kettle Falls biomass facility, and its small gas-fired turbine are exempt from the CCA law because their
historical emissions during the 2015-2019 period fell below 25,000 tons of carbon.
RECEIVED
Thursday, May 18, 2023 3:39:45 PM
IDAHO PUBLIC
UTILITIES COMMISSION
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/05/2023 CASE NO: AVU-E-23-04 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Clint Kalich TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-002 TELEPHONE: [phone] REQUEST: Please explain what the "Wheel-Through" proposal and "Lesser Of Schedule" proposal are and
what the impacts of the proposals are on the current CCA law. Also, please explain the process for approving different proposals and provide the most current status of the proposals relative to where each is at in the process.
RESPONSE:
“Wheel Through” means power that originates outside of Washington and has its final point of delivery outside of Washington.
Under Washington’s CCA law, all wholesale sales of surplus power generated outside of
Washington and sold at Mid-C would be required to retire 0.437 allowance per MWh under current industry scheduling practices. “Lesser Of” scheduling, as proposed by industry to Washington State Ecology, is a practice whereby total wholesale sales in an hour are summed and compared to in-Washington generation. Only wholesale sales exceeding in-Washington
generation is then defined as “unspecified power” and subject to the requirement of retiring 0.437 allowance per MWh. We believe wheel through transactions are exempt from CCA legislation. The Lesser Of
methodology still is being reviewed by Ecology and is in the public comment stage. We are
hopeful Ecology will rule on Lesser Of sometime this year.