20220531Staff 19-20 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )CORPORATION'S PROPOSED TARIFF )CASE NO.AVU-G-22-01
SCHEDULE 195-OPTIONAL RENEWABLE )NATURAL GAS )
)THIRD PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy AttorneyGeneral,requests that Avista Corporation provide the following
documents and information as soon as possible,but no later than TUESDAY,JUNE 7,2022.1
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 telephonenumber of
I Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION l MAY 31,2022
the person preparing the documents.Please also identify 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.
REQUESTNO.19:Please respond to the followingregarding RTCs and the MRETS
platform.
a.Please explain how the Company verifles that no financial incentives or
environmental attributes (i.e.,RINs or RTCs)have been applied to the RNG being
provided for the program prior to issuance of an RTC.
b.Please explain if the Company has verified that no financial incentive or
environmental attributes have been retired for the RNG being provided for the
program by Klickitat Public Utility District and Puget Sound Energy ("PSE").
c.Please describe how the Company ensures and verifies that all RNG supplied for the
program is certified.
d.Please explain the roles of the Company and PSE in use of the MRETS platform in
support of the proposed program.
e.Please explain how the Company uses the MRETS platformin support of the
proposed program.
f.Please explain how the Company will verify,track,and report compliance to state
regulators where the program is offered.
g.Please explain how and when RTCs will be retired.
REQUESTNO.20:For the RNG program environmental benefits,please explain the
reasoning for using RTCs throughMRETs versus using RINS under the Renewable Fuel
Standard established by Congress in the Energy Policy Act of 2005.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MAY 31,2022
DATED at Boise,Idaho,this day of May 2022.
n HarÁi
Deputy A rney General
i:umisc:prodreq/avue22.ldhksk prod reg 3
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 3 MAY 31,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31ST DAY OF MAY 2022,SERVED THE FOREGOING THIRD PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-G-22-01,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
SHAWN BONFIELD AMANDA GHERING
SR MGR REGULATORY POLICY AVISTA CORPORATION
AVISTA CORPORATION PO BOX 3727
PO BOX 3727 SPOKANE WA 99220-3727
SPOKANE WA 99220-3727 E-mail:[e-mail]-MAIL:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE