Loading...
HomeMy WebLinkAbout20220401Avista to Staff 1-4.pdf',r'!*1 f4r(:frl '1\1,--iL-t i LU ruzuSDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: AYISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATTON IDAHO AW-G-22-01 Staff Production Request Staff-001 iii?: &FR * i Pfi 3: h I DATE pREpARED: 04lll2o22 .,j ' :" ''i"^', :.'- :il',,,.iiSSt0llWITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST: Please describe and provide copies of any Idaho specific public outreach the Company has conducted. Please separate by customer class. RESPONSE: Avista sent an e-newsletter communication to its Washington and Idaho customers in March 2022. The e-newsletter communication is provided in Staff-PR-0Ol Attachment A. ::* Renewable Natural Gas How Avtsta ts movtng anr dean energy strategy foruad As a locus on clean energy cootinues to grow at the natbnal, regbnal and local levels, Avisla is moving our dean energy strategy forward. Our customers and communities conlinue to ogress interest in how Avista is planning for the future and the longterm sustainability of our communilies. Last year Avista announced our aEiralional goals to reduce natural gas enissions 30% by 2030 and to be carbon neutralin our nalural gas operations by 2045. These goals built on he dean eleddcity goals we set in 2019. Keepng costs afiordable will continue to be cenfal in how we rnove forward, and innovation and new technolqies are neoesssry to adrleve these goals. At the same tirne, we recognize the value of a diverse portfdio and energy nix today and in the frrture and that adrieving trese goals will require a rrulti-faceted approach. Avista's approach to re&rcing natural gas emissions includes investing in new lechnologies, like renqrable naturalgas (RNG). hydrogen and other reneuraHe biofuels. Wtrile we continue to evaluale hor to best integrate RNG into our gas supply portfolio and researdr hydrogen as anofier renewable fuel, we are also ergandng our customer facing options. Our Washington Natural gas customers can now elecl to parlicipate in our renewable natural gas program. Participation in the program allows customers to continue to receive all of the great benefits associated with natural gas, wih he same level of reliability and a lower carbon footprint. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO CASE NO: AVU-G-22-01 REQUESTER: StaffTYPE: Production Request REQUEST NO.: Staff-002 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST: Please describe the number of Idaho customers that have expressed interest in the program. Please separate by customer class. RESPONSE: Avista conducted a Renewable Natural Gas (RNG) survey with residential customers in July 2020, which 232 respondents, 48 of which were ldaho customers. The table below reflects the Idaho only responses for the question: "Which of the below options would you be most interested in purchasing?"o 3 Idaho customers expressed interest in purchasing RNGo Another 22ldaho customers expressed an interest in purchasing a blended option that includes both RNG and carbon offsets In Idaho, there are 92,862 gas customers, based on the table below, an estimated 60/o or 5,570 customers could potentially be interested in the program based on the survey results. Avista also utilized a third-party vendor, The Shelton Group, to conduct an RNG survey with its commercial customers in 2019. The survey results were not separated by state, therefore Avista can only share the overall results. The survey showed that 4.6Yo of large commercial customers and 6.2Yo of small/medium commercial customers were likely to participate in an RNG program. Interest in Purchasing (Single Choice) Renewable Natural Gas and Carbon Offsets are two ways to reduce your carbon footprint, but both come at different price points and from different sources. Which of the below options would you be most interested in purchasing? Total: 48 responses Total Total 48 Renewable Natural Gas (RNG) comes from food waste, agriculture waste and landfills that capture methane and I converts it into a useful output in the form of RNG. It is more expensive than conventional Natural Gas and 6% likely more expensive than Carbon Offsets. Carbon Offsets benefit the environment in an indirect manner by planting trees or preserving forests. These 2 actions are a lower-cost way to offset the Green House Gas (GHG) emissions associated with your Natural Gas 25% use. A blended option that includes a combination of Carbon Offsets and Renewable Natural Gas to provide customers a mid-range price option to reduce your carbon fooprint. None -l 4 460/o 23% AVISTA CORPORATION RESPONSE TO REQUEST FOR TNFORMATTON JURISDICTION: IDAHO CASE NO: AW-G-22-01 REQUESTER: StaffTYPE: Production Request REQUEST NO.: Staff-003 DATE PREPARED WITNESS: RESPONDER: DEPARTMENT: TELEPHONE: 04nt2022 N/A Amanda Ghering Regulatory Affairs 509-495-7950 REQUEST: Please describe how program costs will be allocated between jurisdictions, if approved. RESPONSE: All program costs and revenues are accounted for separately from utility operations. The customers who voluntarily opt to participate in the program in each jurisdiction bear the costs of the program with no subsidization from non-participating customers. The expenses for all jurisdictions are contained in one accounting project, with cost allocation to each state being based on the actual participants of each state and their subscribed volumes of RNG. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AW-G-22-01 Staff Production Request Staft-004 DATE PREPARED WITNESS: RESPONDER: DEPARTMENT: TELEPHONE: 041u2022 N/A Amanda Ghering Regulatory Affairs 509-49s-79s0 REQUEST: Please describe and quantiff 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 implernented. RESPONSE Capturing the methane created by landfills, agricultural, or food waste prevents it from being released into the atmosphere. By capturing methane released from organic waste and re-purposing it as Renewable Natural Gas, it reduces direct methane emissions and supplants ernissions associated with traditional fossil natural gas. Subscribing to renewable natural gas provides progftlm participants the ability to reduce the carbon emissions associated with their natural gas usage and customers may even become carbon neutral when offsetting 100 percent of their natural gas usage. The quantifiable value to customers will be measured in the amount of carbon emissions they are offsetting by enrolling in this progritm. At the end of each year, participants will receive a summary of their carbon emission offset by participating in the program. Customer satisfaction will be measured through a Net Promoter Score survey that will be sent to all participants. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATTON ruRISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AYU-G-22-0t Staff Production Request Staff-005 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST: 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. RESPONSE: Program performance will be measured by achieving the following Key Performance Indicators (KPIs) outlined below. KPIs or goals for the program for 2022 are as follows:o Net Promotor Score (NPS) of 45+o Program participation count of 1,000o Web Page views of 10,000 With the Voluntary RNG Program being new to the Company's set of customer program options, the annual NPS survey for this program has not yet been formally developed. The Company anticipates the NPS survey to look similar to the questions below: 1. How likely is it that you would recommend the Voluntary Renewable Natural Gas Program to a friend or colleague? [0, Not at all likely - 10, Extremely likely] 2. Why? Please provide comments to help us understand why you ranked the Voluntary RNG Program the way you did. [comment box] 3. Thank you for your feedback. Our team may want to reach out to you to leam more about how we can further improve Renewable Natural Gas so it exceeds your expectations. Would you be willing to speak to us by phone some time? a. Yes >> Q4b. No >> End Survey 4. Great! What is the best number to reach you? [comment box] 5. And what is the best time to call? a. During the weekday between Sam and 5pm b. Weekdays between 5pm and 8pm AVISTA CORPORATION RESPONSE TO REQUEST FOR TNFORMATTON ruRISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-G-22-01 Staff Production Request Stafl006 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST: Please provide an example of how monthly charges for program participation will be presented on customer bills. RESPONSE: Please see Staff PR_006 Attachment A for an example of a customer bill who has subscribed to the Company's Voluntary RNG Program. frvtsr,' mt,.Ytroadi(m)rzrrtt Jen: Dor SnEr.rtOrD: Gla!fiusruc.Iit -: talt EI|33I)ll Monthly Statement lilxr! fur t or2 *1UM,|l;fabir.ri.F{ - Bill at a Gbnce BadroOl.tt0c7t frf!.b.Tbrol!rffighe Your Message Center llrtaPrrtnfft fu€tvd oo 03J072@2 - Ihent yo.-t0tr!Pb-ra frFgtXA{ts E Uoll l{a Glurgr(rl R.rEtr&ae l{etu dca3 To a.t nl rilEt hrd.otlEllli ilqf,Hillof,irfr..riElFalqrillre.ffi. Toaa 5 tf h5il.(1 \,'r caril hffira irf t-U a oda. rhbDr.tilrhltre!.AllE rE- AF rfi& it iTtr.ranOoC.PLrfrrr 0.00 o.ral t00 tcllfurilOurff.IoilDtrm(ld.bcrdrt-o.tyf:I0.r!AIl1,''Er Contact tls C(.larrSrYld: l f,,|lzl,rtl',lrlqury lIq8h f ncry , t.ln to, p.nStdaygt.fir. b 5 prl. Afu? xar?rCrrtl{E5: I m, ZIt4lO 465 Spd.rn.wA 0o52.mi I.CJa:.iFYatrao.tt ll', tarulc- O, -awcnurt g klralffirg.npl.drt:tErqtdr r-t-r 6 r {s0)E335388 t ,ic..nDod.rEb:Ast Cridns S.nfta t'lsc-3a FOSor tl27SC6I$WA@0nr2, V Ffu*C+hd drd rtlul l'aLuiyill.:{lj df Fr.trflrsl. Y finsta )lf"ffi*n.rrro.r' ^orrffilatl E LEoli. $ormlrA9251(D01 Rqttgsrcorrlatd! Elia tr$ tr3ro EotE - l,ddblflAtto.rrA/.) Lnd.Itt aErrlolrd t fhfr Futryarrprynirt. h[tr]trld{lrl}$rld.rr{i.}trIl}ilrlIld ffi AVISTA!a!r Ettssto{A\rE sFoa(ArC, wA9s252s1 Tdl &murn OUc Om O.t t 2ora SrdsrAddlrr lall E nl5srcil sPot(AtGwAgqr(E MrtrTdel3&1.78 E ,",rol Gas Dctail RedDeE;Ofr2zlZ2bBtAnZ. - 29 Dtr Ehr tartstt IrtatL l!t.r,UIEME5ItmGTI R.!.Sclulr tor YorlcflrI.I.tUU.ta J 'I a 6 I a ! 0 Ic.rft-fnrlb!icrcrllLHtrlvri?.tlrE L2tl-Fo,tcE) llE- I i !l! !'!'i'i"i'i''! i ,{rnlortllnl.l t t fEaf,l+l It /lo I other Charges bSE nmllllfrrld tbrs.o 150ffi AYISTA CORPORATION RESPONSE TO REQUEST FOR TNFORMATTON JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-G-22-01 Staff Production Request Staff-007 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST: Please explain why proposed Schedule 195 language regarding use of a tracking system includes "as required by the Idaho State Legislature.' RESPONSE: The Company's inadvertently included this language within its filing as a result of copying the proposed tarifflanguage from the approved Washington version of the same tariff. Avista is not aware of any voluntary RNG requirements provided by the Idaho Legislature and will file a substitute tariffpage to remove this language. AVISTA CORPORATION RESPONSE TO REQUEST FOR TNFORMATTON ruRISDICTION: IDAHO CASE NO: AW-G-22-01 REQUESTER: StaffTYPE: Production Request REQUEST NO.: Staffi008 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Tom Pardee DEPARTMENT: Natural Gas Resources TELEPHONE: 509-495-2159 REQUEST: Please explain and identifu the specific "environmental atfributes" mentioned in the Company's application and proposed tariff. Do the attributes include Renewable Identification Numbers ("RINs")? RESPONSE: The contract specifies the purchase of biogas and the associated renewable attributes but refers to the athibutes as "Renewable Thennal Certificates". The 66RIN" acronym is not used. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION ruRISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-G-22-01 Staff Production Request Stafl009 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Tom Pardee DEPARTMENT: Natural Gas Resources TELEPHONE: 509-495-2159 REQUEST: 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 progftlm 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. RBSPONSE: a. Renewable hydrogen is hydrogen created by a renewable energy source such as wind and solar. b. There is no definitive timeline to offer hydrogen as a program option to Avista customers. c. A systerr such as "M-RETS" would likely be required for confirmation of the environmental attributes. Further investigation would be necessary prior to offering this option under Schedule 195. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION ruRISDICTION: IDAHO CASE NO: AW-G-22-01 REQUESTER: StaffTYPE: Production Request REQUEST NO.: Staff-Ol0 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST: 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. RESPONSE: a. Please see Staff PR_010 Attachment A. The article titled "Renewable Natural Gas" was sent to all Avista's gas customers in the Company's March newsletter. While the communication titled "'We're Offering a New Renewable Energy Option" was sent to Washington gas customers in March of 2022. b. Avista's Voluntary RNG Program in Washington became effective October 15,2021 as approved in Docket UG-210690. The Company had a soft launch to employees in November 2021 andjust recently started promoting the new program to its Washington customers. c. The proposed Idaho Voluntary RNG program is the same as the Washington Voluntary RNG program. d. The table below summarizes monthly enrollments in Avista's Voluntary RNG Program in Washington as of March 23,2022 and includes all 'billed' renewable natural gas. There are a total of 170 customers enrolled in the Voluntary RNG program, 33 of which have not received their first bill with the program included. I)ecember January February March Total Customer Count I 3 45 88 t37 Billed Therms 1.5 6 I 18.5 249 375 e. The Company is not required to provide reporting to the Washington State Utilities and Transportation Commission (WUTC) on its Voluntary RNG Program. Renewable Natural Gas low Awsta ts npwng wr dean energy stategy forward [s a focus on clean energy continues to g]ow at the natbnal, regftroal and oca! levels, Avista b moving our dean energy stretegy forward. Our custorners md communities continue to erpress interest in how Avista is planning for the uture and the longrterm sustainability of our comrnunfties. -ast year Avista announced our asdrational goals to reduce natulal gas missions 30% by 2030 and to be ca6on neutral in our natural gas operations by 1045. These goals buih on the dean dedricity goals we set in 2019. (eepng costs afiordable will ontinue to be central in how we move forward, and nnovation and new tedtnolqies are neoessery to achieve these goals. At the iame time, we recognize the value of a diverse portfolio and energy n*x today lnd in the frrture and that adrieving lhese goals will require a mJlti-faceled ryproach. $ista's approach to reducing naturalgas enissions includes investing in neur echnologfes, like reneurable naturalgas (RNG), hy&ogen and other renewaHe *ofu€b. While we continue to evaluate how to best integrale RNG into our gasiuffi portfolio and researdt hydrogen as another renewable fuel, we are also lxpandng our customer facing options. )ur Washington Natural gas cusilomers can now elecl to parlicipate in our enewable natural gas program. Participation in the program allows cuslorners to nntinue to receive allof the greal benefits associated with naturalgas, with the ;ame level of reliatrilitv and a lower carbon footpdnt. *'."*-I Curfuinrr, an Avista nstral ges olstonrer in Washington, ytxt noy have a new oplinn to renewable natral gns and lo*ur your ca6on f@rin[. Yotr can recdve d great beneftts of naturd gos, wt0r no eqlhmeril or appliance dranges, al the hvd of ref,abti$ natural gs (RNG) b made from tho weryday waste of paople ard Mehane gas from that waste b captred befure €scepir€ inlo our deaned and saHy k{ected ido the pipe$ne to be used as energy spdng, Avlsta announed ar goab to reducs natural gas efl{ssions by 30% 2030 and to be carbon nflfd h qrr natural gas operations by 2045. Ihb b step to ge[ us doeerlo tnt goal and gives you tro oppoiluffiy to loln us. you sigrr up, you can oftet your natural gas usage with Ri,lG for as fftde as a mon$. Your s6scridion can be canceled at any tme. Eadr $5 represents envlronmental ben€fr| associated wifi 1.5 th€ms of RNG. Avista natural gas or$onres in Washingilon cen now eled to enrol in tre online or by cafhg into custonnrsewke at 800-227-9187 can visit our urcbeil€ to dsover more about tft opdon, read FAQs or to pro$am b one of he firsl of many ways we are worldng toward our dean goab. Cfck belw to read more about Avista's oomiltment to a dean future here. We're offe t enr.w allle t,nel qy o;rtrr>lr AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AW-G-22-01 Staff Production Request Staft-0l l DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST: 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 rqrorts, and any other p ertinent information. RESPONSE: The Company does not have intentions of regular reporting on the program, if approved. Rather, information can be made available for the program as requested by Staff. However, if Stafffeels regular reporting is desired or necessary, the Company is open to discussing such reporting with Staff. AYISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-G-22-01 Staff Production Request Staff-012 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Erik Soreng DEPARTMENT: Natural Gas Resources TELEPHONE: 509-495-2553 REQUEST: For the signed agreement with Puget Sound Energy (uPSEu), 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. c. Please identiff if the Company must purchase a minimum or maximum amount of RNG from 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 atfibutes 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. RESPONSE a. Please see Staff-PR-Ol2C Confidential Attachment A. b. The contract minimum for each month is 0 dth. The maximum allowable volume per month is as follows: 2022: 900 dth per month 2023: 950 dth per month 2024: 1000 dth per month c. The Company does not need to purchase a minimum or ma:iimum amount of RNG that will be dedicated for Washington or Idaho customers. d. Yes, RNG procured from PSE can be stored in Avista's storage facilities e. Avista is using the MRET's system to track the RNG atfributes associated with the RNG purchased from PSE. The attributes can be stored in the system indefinitely; however, the Washington voluntary RNG program restricts the use of e,nvironmental attributes to a vintage of the current or prior year. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION ftruSDICTION CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-G-22-01 Staff Production Request StaffiOl3 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST 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 re'newable 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 athibutes. e. Is the Washington RNG Program using M-RETs? If not, please explain. RESPONSE: a. Avista recently obtained a subscription to the M-RETS system to meet Renewable Thermal Certificate (RTC) tracking requireme,nts set forth in Oregon's Senate Bill 98 Renewable Natural Gas Program rules outlined in OPUC Docket No. AR 632.The natural gas utilities in Washington all agreed to use M-RETS as well. To avoid duplicative systems, efforts, and expenses, Avista plans to utilize M-RETS as its single platform for its Oregon, Idaho, and Washington jurisdictions. The over-all annual costs associated with using the M-RETS system is $2,200. b. For the reasons stated in item (a) above, Avista has not considered, and is not aware of other systems that offer the regulatory visibility into RTC attribute tracking via a transparent, web-based system and as such, has not evaluated other companies plans or policies for retiring the renewable attributes. c. Avista will utilize the M-RETS system to track RTCs from creation, and or trading via purchase and sales to retirement. d. The M-RETS systern has adapted their expertise in tracking RECs to track attributes being traded in the emerging thermal market. While M-RETS only began RTC tracking in January 2020,Avista is confident in their abilities to accurately track RTCs on behalf ofthe Company. More details on the M-RETs system can be found at: https://www.mrets.ors/. e. Yes, Avista's Washington Voluntary RNG Program, and Oregon if approved, is utilizing the MRETs system to track RTCs. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATTON ruRISDICTION CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AW-G-22-01 Staff Production Request Staff-O14 DATE PREPARED: 041112022WITNESS: N/A RESPONDER: Amanda Ghering DEPARTMENT: Regulatory Affairs TELEPHONE: 509-495-7950 REQUEST: Please describe how the Company derived its participation forecast. RESPONSE: The participation forecast is based off customer research, market analysis and peer program performance. Historical participation in Avista's My Clean Energy program was used to inform the Voluntary RNG Program participation forecast. From past research, about 5%o of customers surveyed said they were interested in the My Clean Energy program, but only a fraction of that 5o/o actually enrolled in My Clean Energy. This same approach was used to forecast how many customers would potentially participate in the Voluntary RNG program in ldaho. In Idaho, there arc92,862 gas customers. In the survey performed in2020,6Yo or 5,570 expressed interest in the voluntary renewable natural gas program. That forecast was reduced to 4,200 based on experience with the My Clean Energy program.