20230620Staff 5-9 to AVU.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL .noIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA'S APPLICATION)
FOR AN ACCOUNTING ORDER TO MODIFY )CASE NO.AVU-E-23-04
ITS POWER COST ADJUSTMENT )MECHANISM TO ACCOUNT FOR COSTS )ASSOCIATED WITH WASHINGTON'S )THIRD PRODUCTION
CLIMATE COMMITMENT ACT )REQUESTOF THE
ALLOWANCES )COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy Attorney General,requests that Avista Corporation ("Company"or
"Avista")provide the followingdocuments and information as soon as possible,but no later than
WEDNESDAY,JULY 5,2023.1
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 telephonenumber of
I Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 1 JUNE 20,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
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.
REQUESTNO.5:Please provide Idaho's monthlyClimate Commitment Act ("CCA")
costs since the implementation of the CCA and explain how each month's CCA costs are
calculated.Please provide workpapers with all formula intact.
REQUESTNO.6:Please respond to the followingregarding the white paper
"Consideration of Electricity Imports and Determination of the Electricity Importer Under the
Climate Commitment Act"dated March 1,2023:
a.Please explain how the proposed methods in the white paper will affect Idaho's
CCA costs.
b.When will the proposed methods in the white paper become effective?
c.Please explain whether the proposed methods affect existing Idaho CCA costs,
retroactively.
d.If the proposed methods are to be applied retroactively,please quantifythe
adjustments to Idaho's existing monthlyCCA costs and provide workpapers that
calculates the adjustments with all formula intact.
REQUESTNO.7:Please respond to the followingregarding the Lesser-Öf Analysis
that allows netting of non-emittingresources at the Mid-C trading hub for off-system sales:
a.Please clarify whether this method _only allows Mid-C hydro generation contracts
to offset off-system sales.
b.Response to Staff Production Request No.4 states that in-Washington generation
can be used to offset wholesale sales and that in-Washington generationdoes not
have to be renewable energy.Please explain what other energy sources can be
used to offset off-system sales,besides Mid-C hydro generation.
c.Please explain whether this method of netting only pertains to off-system sales
through the Mid-C trading hub.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 2 JUNE 20,2023
d.Please provide a list of current Mid-C hydro contracts.
e.Please explain in detail how the Company plans to implement the netting method.
f.Does the Company plan to implement the netting at the monthlylevel?
g.Please provide an example using actual data to illustrate the netting process.
REQUESTNO.8:Please respond to the Wheel-Through method in the white paper:
a.Please explain in detail how the Company plans to implement the Wheel-Through
method.
b.Does the Company plan to implement the Wheel-Through method at the monthly
level?
c.Please provide an example using actual data to illustrate the Wheel-Through
method.
REQUESTNO.9:Appendix 2 of the white paper provides a Wheel-Through example,
where 100 MW of the imported 125 MW from Hermiston,Oregon is wheeled through
Washington to Oregon.It appears that the hubbing arrangement with Wanapum and Priest
Rapids hydro projects does not play a role.Please explain how the hubbing arrangement affects
the Wheel-Through process in the example.
DATED at Boise,Idaho,this day of June 2023.
laire Sharp
Deputy Attorney General
i:umise:prodreq/avue23.4csyy prod req 3
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 3 JUNE 20,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF JUNE 2023,SERVED
THE FOREGOING THIRD PRODUCTION REQUESTOF THE COMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NO.AVU-E-23-04,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:[e-mail] E-mail:[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE