20220322Staff 1-14 to Avista.pdf

ldaho Public Utilities Commission
Office of the SecretaryRECEIVED
MAR 2 2 2022
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Boise, ldaho
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE,ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S DBA AVISTA UTILITIES
PROPOSED NEW TARIFF SCHEDULE 195
''OPTIONAL RENEWABLE NATURAL GAS.''
CASE NO. AVU.G-22.0I
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attomey General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than
TUESDAY, APRrL 12, 2022.
This Production Request is to be considered as continuing, and Avista Corporation is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behall 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
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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I MARCH 22,2022
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. l: Please describe and provide copies of any Idaho specific public
outreach the Company has conducted. Please separate by customer class.
REQUEST NO. 2: Please describe the number of Idaho customers that have expressed
interest in the program. Please separate by customer class.
REQUEST NO. 3: Please describe how program costs will be allocated between
jurisdictions, if approved.
REQUEST NO.4: Please describe and quantifu specific value Idaho customers would
recognize if the program were approved and implemented in Idaho. Please also explain how the
Company will measure satisfaction of this value with its customers after the program has been
implemented.
REQUEST NO. 5: Please provide descriptions of the performance metrics the Company
will use to measure program performance including a copy of the NPS survey mentioned on
page 4 of the Application.
REQUEST NO. 6: Please provide an example of how monthly charges for program
participation will be presented on customer bills.
REQUEST NO. 7: Please explain why proposed Schedule 195 language regarding use
of a tracking system includes "as required by the Idaho State Legislature."
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MARCH 22,2022
REQUEST NO. 8: Please explain and identiff the specific "environmental attributes"
mentioned in the Company's application and proposed tariff. Do the athibutes include
Renewable Identification Numbers ("RlNs")?
REQUEST NO. 9: Please respond to the following about renewable hydrogen as
addressed in the Schedule 195:
a. Please provide a definition of renewable hydrogen.
b. When does the Company plan to offer a program option for renewable hydrogen?
c. Would the renewable attributes of the renewable hydrogen be retired through
Midwest Renewable Energy Tracking System ("M-RETS")? If not, please explain
REQUEST NO. 10: Please respond to the following about the Washington Optional
Renewable Natural Gas program described on page 2 of the Application:
a. Please provide copies of all documents related to the Washington Optional
Renewable Natural Gas program sent to or available for Washington customers.
b. Please provide the case number and effective date of the program.
c. Please explain if the Washington program is different from the proposed Idaho RNG
program.
d. Please provide the total number of participants and blocks purchased for each month
since the program's inception.
e. Please provide any reports for the program.
REQUEST NO. 11: Please explain the Company's intent for reporting on the program.
In the response, please include frequency of reporting, key performance indicators to be included
in the reports, and any other pertinent information.
REQUEST NO. 12: For the signed agreement with Puget Sound Energy ("PSE"),
please respond to the following:
a. Please provide a copy of the Company's signed agreement with PSE.
b. Please identiff if the Company has a minimum or maximum amount of RNG to
purchase from PSE.
FIRST PRODUCTION REQUEST
TO AVTSTA CORPORATION J MARCH 22,2022
c. Please identiff if the Company must purchase a minimum or maximum amount of
RNG PSE that will be dedicated to the Company's Washington or Idaho customers.
d. Please explain whether the RNG purchased from PSE can be stored in the Company's
storage facilities.
e. Please explain whether the RNG attributes can be banked for use in future years. If
so, please explain quantities, how long they can be banked and accounting treatment
for banking of RNG attributes.
RBQUEST NO. 13: In the Application the Company stated it will utilize M-RETS for
the purpose of retiring renewable attributes for participating customers. Please respond to the
following:
a. Please describe any experience the Company has with using the M-RETS and costs
associated with using the system.
b. Has the Company evaluated other companies plans or policies for retiring the
renewable attributes? Please explain.
c. Please explain the renewable attributes that M-RETS will retire.
d. M-RETS is commonly used for Renewable Energy Credits ("REC") tracking. Please
explain M-RETS ability and experience with retiring RNG attributes.
e. Is the Washington RNG Program using M-RETs? If not, please explain.
REQUEST NO. 14: Please describe how the Company derived its participation forecast.
DATED at Boise, Idaho, ,n rLP day of Mar ch2022
i:umisc:prodreq/avue22. ldhksklc prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4
Deputy Attomey General
MARCH 22,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF MARCH 2022,
SERVED TTM FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO AVTSTA CORPORATTON, IN CASE NO. AVU-G-22-01,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
SHAWN BONFIELD
SR MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL : shawn.bonfi [e-mail]
AMANDA GHERING
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: amanda. [e-mail]
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SECRETART
CERTIFICATE OF SERVICE