20220420Staff 15-18 to Avista.pdf

'. r:-. i i; '-' l_ i-.rDAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
' ,- ,',:;ll ,:i F:l 3t I 2
Street Address for Express Mail:
1 I 3 3 I W CHINDEN BLVD, BLDG 8, SUITE 20 1 -A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S PROPOSED TARIFF
SCHEDULE l9s-OPTIONAL RENEWABLE
NATURAL GAS
CASE NO. AVU.G.22-OI
SECOND 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 Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than
WEDNESDAY, MAY ll, 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 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 telephone number of
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION
)
)
)
)
)
)
)
)
)
APRIL 20,2022
the person preparing the documents. Please also identiff 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. 15: In response to Production Request No. 1, the Company provided a
copy of an e-newsletter sent to its Washington and ldaho customers. The newsletter states
Washington customers can participate in the Company's renewable natural gas ("RNG")
program but makes no mention of the proposed program for Idaho customers. If the program is
approved in Idaho, would the Company provide similar communication to Idaho customers?
Please explain.
REQUEST NO. 16: In response to Production Request No. 6, the Company provided a
sample Washington customer's bill.
a. Please provide an Idaho specific example of a customer bill showing how monthly
charges for program participation will be presented.
b. Please explain if 1.5 therms of RNG are actually purchased by the Company for each
program block purchased by a customer. If so, will a customer's total energy charges
for traditional natural gas be reduced or credited by 1.5 therms for each program
block purchased?
c. Please describe all environmental attributes associated with 1.5 therms of RNG and
how each attribute impacts the $5 block cost.
d. If a meter multiplier will be used on Idaho customers' bills, please explain how the
multiplier value is determined. Please provide supporting workpapers.
REQUEST NO. 17: In response to Production Request No. 9, the Company stated that
there is no definitive timeline to offer hydrogen as a program option. Please explain why
hydrogen is listed as a program option in proposed tariff Schedule 195.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 2 APRIL 20,2022
REQUEST NO. 18: Please describe all financial incentives relatedto RNG thatthe
Company considered for this program. If the Company did not consider Federal Renewable Fuel
Standard (*RlNs") orthe Califomia Low Carbon Fuel Standaxd ("LCFS") please explain why
not.
DATED at Boise,Idalro, this ?Mu,of April2022.
Deputy Attorney General
i:umisc:prodre{avue22. Idhksk prod req 2
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 3 APRIL 20,2022
CERTTFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF APRIL 2022,
SERVED TI{E FOREGOING SECOND PRODUCTION REQTIEST OF TIIE
COMMISSTON STAX'F TO AVISTA CORPORATION, IN CASE NO. AW-c-22-01,
BY E-MAILING A COPY THEREOF, TO TTIE FOLLOMNG:
SHAWN BONFIELD
SR MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-MAIL: shawn.bonfi [e-mail]
AMANDA GHERING
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-mail: amanda. [e-mail]
SECRETARY
CERTIFICATE OF SERVICE