20231025Staff 1-7 to AVU.pdf

MICHAEL DUVAL D
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 BLiCBOISE,IDAHO 83720-0074 MWSSION
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION )CASE NO.AVU-E-23-15
OF AVISTA CORPORATION AND )CLEARWATER PAPER CORPORATION )FOR APPROVAL OF AMENDMENT 1 TO )FIRST PRODUCTION
THE ELECTRIC SERVICE AGREEMENT.)REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Avista Corporation ("Company")
provide the followingdocuments and information as soon as possible,but no later than
WEDNESDAY,NOVEMBER 15,2023.
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
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 October 25,2023
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.1:Page 1 of Amendment No.2 to the Transaction Confirmation
mentioned Amendment No.1 dated February 27,2019.Please respond to the following:
a.Please provide a copy of Amendment No.1 to the REC Agreement dated
February 27,2019;
b.Please explain why the Company did not submit Amendment No.1 of the REC
Agreement for Commission approval;and
c.Please explain why the Company is submitting Amendment No.2 of the REC
Agreement for Commission approval.
REQUESTNO.2:Page 2 of the Application states that Clearwater owns and operates a
generation system of approximately 132.2 mega-volt amps ("MVA")as a QualifyingFacility
under Public Utility Regulatory Policies Act of 1978 and 18 C.F.R.Part 292.Please provide the
capacity of the facility in megawatts.
REQUESTNO.3:Amendment No.1 to the Power Purchase and Sale Agreement,dated
October 2,2023,states "Amendment No.1 to the REC Agreement is attached to this
Amendment as Attachment A."(Emphasis added.)Please confirm that "Amendment No.l"in
the quote should have been "Amendment No.2".
REQUESTNO.4:The original Power Purchase and Sale Agreement approved in Case
No.AVU-E-18-13 defines "REC Agreement"as "Transaction Confirmation between Avista and
MSCG dated December 15,2018,under which Avista is to sell and MSCG is to buy the RECs
generated by the Project bundled with energy..."Please confirm that "December 15,2018,"
should have been "October 19,2018."
REQUESTNO.5:Amendment No.2 to the Transaction Confirmation uses Powerdex
Mid-Columbia Hourly Price (or mutuallyagreed to alternative)for DeliveryPeriod 1 and uses
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 October 25,2023
Intercontinental Exchange ("ICE")Mid-Columbia Firm Prices (or mutually agreed to alternative)
for Delivery Period 2.Please respond to the following:
a.Please explain why the Parties switched to ICE Mid-Columbia Firm Prices for
DeliveryPeriod 2;and
b.Please explain why ICE Mid-Columbia Firm Prices provide reasonable prices to
value the energy generated by Clearwater.
REQUESTNO.6:Amendment No.2 to the Transaction Confirmation uses the
followingREC Prices:
Delivery Period 1 Delivery Period 2
PCC1 RECs $9.00/MWh $27.10/MWh
PCC2 RECs $4.50/MWh $27.10/MWh
Please respond to the following:
a.Please explain how PCCl REC Prices and PCC2 REC Prices are determined for
DeliveryPeriod 1 and Delivery Period 2;
b.Please explain why PCCl REC Prices are higher than PCC2 REC Prices in
DeliveryPeriod 1 and why PCCl REC Prices are the same as PCC2 REC Prices
in Delivery Period 2;and
c.Please explain why REC Prices in Delivery Period 1 are much lower than REC
Prices in Delivery Period 2.
REQUESTNO.7:Please calculate Schedule 25P Block 2 PURPA Rates for the
extended three years using the same method used in Case No.AVU-E-18-13 (i.e.a blend of IRP-
based avoided cost rate and forward market prices).This should include (1)Clearwater's
Generation Load Rate with Commission fees that Clearwater pays,and (2)Clearwater's
Generation and REC Rate without Commission fees that Avista pays.In addition,please
respond to the following:
a.Please provide the two rates with workpapers showing the calculations with
formula intact;and
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 October 25,2023
b.Please explain why the rate Clearwater pays includes Commission fees but the
rate Avista pays does not under the current 2018 Agreement.
DATED at Boise,Idaho,this 25th day of October 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreq/AVU-E-23-15 PR#1
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 October 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF OCTOBER 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-E-23-15,
BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
MICHAEL G.ANDREA MICHAEL S GADD
SENIOR COUNSEL CLEARWATER PAPER CORP
AVISTA CORPORATION 601 W RIVERSIDE AVE
PO BOX 3727 STE 1100
SPOKANE WA 99220-3727 SPOKANE WA 99201
E-mail:[e-mail]
PETER RICHARDSON
RICHARDSONADAMS PLLC
505 N 27TH ST
BOISE ID 83702
E-mail:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE