20230626Staff 10-15 to AVU.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
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 )FOURTH 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 AttorneyGeneral,requests that Avista Corporation ("Company"or
"Avista")provide the followingdocuments and information as soon as possible,but no later than
MONDAY,JULY 3,2023.1
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 Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 1 JUNE 26,2023
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.10:Please respond to the followingregarding Tab "CCA Allowance
InventoryNew"of the excel file "Staff PR_003C Confidential Attachment A"provided in
Response to Staff Production Request No.3:
a.Please explain why the Company has not retired any allowances yet;
b.Please explain how the Company plans to retire allowances given the requirement
that a minimum of 30%of allowances to be retired in the year that emissions
occur with any balance due at the end of 2023-2026 Compliance.Specifically,
when,how often,and how many allowance will the Company plan to retire at any
given time and each year?and
c.Column N shows "Allowance EOM Market Price".Please explain what EOM
stands for,define the term,and explain how the values are determined.
REQUESTNO.11:Please respond to the followingregarding Tab "CCA LiabilityNew
Method"of the excel file "Staff_PR_003C Confidential Attachment A"provided in Response to
Staff Production Request No.3:
a.Please provide workpapers that calculate the values in Column I "Calculated
Allowances Needed YTD"with all formula intact;
b.Please explain why the value for May 2023 in Column I dropped significantly
compared to the previous month;
c.Column Q "Total LiabilityAccrued"includes "Value of Allowances Purchased"
and "Value of Allowances To Be Purchased".Does the Company plan to include
"Total LiabilityAccrued"amounts for recovery in the Power Cost Adjustment
("PCA")?If not,what values will be passed to the PCA through FERC Account
509?
d.Please explain why allowances are needed for Avista's electricity ratepayers in
Washington.Why aren't they covered by free allowances?
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 2 JUNE 26,2023
e.Please provide workpapers that calculate the values in Column AB "Calculated
Allowances Needed YTD"with all formula intact;and
f.Please explain why the value for May 2023 in Column AB does not drop
compared to the previous month,unlike the value for May 2023 in Column I.
REQUESTNO.12:Response to Staff Production Request No.3 states that the second
allowance auction was held on May 31,2023,with a settlement price of $56.01 and that the
results from the second auction will be factored in going forward.Please respond to the
following:
a.Did Avista purchase any allowances from the second auction?
b.If so,how many allowances did Avista purchase?and
c.Please explain how the results from the second auction will be used going
forward.
REQUESTNO.13:Please explain the strategies the Company will use during dispatch
to minimize the impact of the CCA and total net power cost (inclusive of the cost of allowances)
to Idaho ratepayers.Please provide examples illustratingthese strategies.
REQUESTNO.14:Please explain the strategies the Company will use to optimize its
resources to minimize the impact of the CCA and total cost to Idaho ratepayers.Please provide
examples illustratingthese strategies and provide potential model run scenarios to test these
strategies in the Company's Integrated Resource Plan.
REQUESTNO.15:Please provide a flow chart illustratingthe flow of allowances from
allowance acquisition through retirement.For each step in the process,please provide the
specific transactions that flow through the Company's various workpapers and ultimately into
the deferral in the PCA.Please include all corresponding accounts in the description and use an
example with spreadsheets attached to further illustrate the process.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 3 JUNE 26,2023
DATED at Boise,Idaho,this day of June 2023.
Claire Sharp
Deputy Attorney General
i:umisc:prodreq/avue23.4csyy prod req 4
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 4 JUNE 26,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26*DAY OF JUNE 2023,SERVEDTHEFOREGOINGFOURTHPRODUCTIONREQUESTOFTHECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NO.AVU-E-23-04,BY E-MAILINGACOPYTHEREOFTOTHEFOLLOWING:
PATRICK EHRBAR DAVID J MEYERDIROFREGULATORYAFFAIRSVP&CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATIONPOBOX3727POBOX3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727E-mail:patrick.ehrbar avistacorp.com E-mail:david.meyer avistacorp.com
avistadockets avistacorp.com
SECRETARY
CERTIFICATE OF SERVICE