20220601Avista to Staff 19-20.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 06/01/2022 CASE NO: AVU-G-22-01 WITNESS: N/A REQUESTER: Staff RESPONDER: Amanda Ghering TYPE: Production Request DEPARTMENT: Regulatory Affairs REQUEST NO.: Staff-019 TELEPHONE: [phone]
REQUEST:
Please respond to the following regarding RTCs and the MRETS platform.
a. Please explain how the Company verifies that no financial incentives or environmentalattributes (i.e., RINs or RTCs) have been applied to the RNG being provided for the program priorto 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 iscertified.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 platform in support of the proposed program.f.Please explain how the Company will verify, track, and report compliance to state regulatorswhere the program is offered.g.Please explain how and when RTCs will be retired.
RESPONSE:
a.The MRET’s tracking system verifies that the RTC’s Avista is purchasing from PSE have not
been sold to any other party or used for any other program prior to their transfer to Avista. The
supply contract Avista has with PSE also states that the RTC’s must not be sold to a third party orrecognized under any other greenhouse gas reduction program.
b.Please see Avista’s response to part (a) above.
c.The MRETS tracking system requires the Klickitat PUD RNG facility to meet the certificationrequirements in order to assign RTC’s for the gas produced at their facility.
d.PSE certifies the facility with MRETS such that RTC’s are created in the MRETS system as
RNG is produced. When Avista purchases RNG from PSE, the associated RTC’s are transferredfrom PSE to Avista’s account. Avista retires the RTC’s as the customers in the program consumethe RNG.
e.Please see Avista’s responses parts (a), (c), and (d) above.
RECEIVED
2022 JUN-1 PM 3:48

IDAHO PUBLIC
UTILITIES COMMISSION
f. The Company is not currently required to report compliance to state regulators in Washington or Oregon but will utilize M-RETS to track and verify RTCs purchased on behalf of its customers.

g. Avista will retire the RTCs for RNG consumed by participating customers at the end of each calendar year.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 06/01/2022 CASE NO: AVU-G-22-01 WITNESS: N/A REQUESTER: Staff RESPONDER: Amanda Ghering TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-020 TELEPHONE: [phone] REQUEST:
For the RNG program environmental benefits, please explain the reasoning for using RTCs through MRETs versus using RINS under the Renewable Fuel Standard established by Congress in the Energy Policy Act of 2005.
RESPONSE:
RINs and RTCs are both terms used for the process of tracking renewable thermal resources. They are technically the same term but utilized in two separate tracking platforms. RIN’s or Renewable Identification Numbers are credits used for compliance under the Renewable Fuel Standard
Program which Avista’s customers are not subject to obligations under. A Renewable Thermal
Certificate (RTC) is the same as a RIN and confirms that the source of the gas is renewable. It could, for example, be sold into the RIN market in California. It can also be used to satisfy Avista’s customers desire to purchase blocks of renewable natural gas under Avista’s voluntary program. Please see Figure 1 below which outlines everything encompassed within an RTC.
The MRETS tracking system ensures that the RTC’s we purchase have not been marketed to any other user as either RTC’s or RIN’s. Avista’s contract with Puget Sound Energy also stipulates that the RTC’s we are purchasing cannot be sold to or used by any other party.
Figure 1 – What does an RTC Look Like?