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Home My WebLink About20230517AVU to IFG 58_61-63_65-68 .pdfAVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 05/16/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IFG RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: IFG-058 TELEPHONE: 509-495-4658 REQUEST: Reference Kalitch Exhibit 7, Schedule 2, Page 1: Please provide workpapers detailing each of Avista’s transmission contracts with BPA and supporting the $1,427,000 increase to BPA Point to Point Transmission expenses on line 46 of the referenced workpaper. RESPONSE: Please see IFG_PR_058 Attachment A - ‘565 Transmission Expense’. RECEIVED 2023 May 17, 4:53PM IDAHO PUBLIC UTILITIES COMMISSION AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 05/16/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IFG RESPONDER: Annette Brandon TYPE: Production Request DEPARTMENT: Resource REQUEST NO.: IFG-061 TELEPHONE: 509-495-4324 REQUEST: Please identify all Washington Climate Commitment Act (“CCA”) allowances that Avista has purchased to date. Please identify the purpose and/or facility, for which the purchases were made. Please specify both the quantity and cost of the allowances. RESPONSE: Please see Avista's response IFG_PR_061C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 05/16/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IFG RESPONDER: Annette Brandon TYPE: Production Request DEPARTMENT: Resource REQUEST NO.: IFG-062 TELEPHONE: 509-495-4324 REQUEST: Please identify the quantity of free Washington CCA allowances that Avista has been granted to date. RESPONSE: Please see IFG_DR_062 Attachment A for the granted number of electric allowances. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 05/16/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IFG RESPONDER: Annette Brandon TYPE: Production Request DEPARTMENT: Resource REQUEST NO.: IFG-063 TELEPHONE: 509-495-4324 REQUEST: Please identify the quantity of free Washington CCA allowances that Avista expects to be granted in the respective test periods in this docket. RESPONSE: Please see IFG_DR_062 Attachment A for the granted number of electric allowances. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 05/16/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IFG RESPONDER: Annette Brandon TYPE: Production Request DEPARTMENT: Resource REQUEST NO.: IFG-065 TELEPHONE: 509-495-4324 REQUEST: Please identify and describe all legal proceedings challenging the Washington CCA of which Avista is aware. RESPONSE: The Company is aware of the following challenges/legal proceedings: 1. Invernergy Thermal, LLC and Grays Harbor Energy LLC v. Laura Watson: This is pending in the United States District Court for the Western District of Washington, Cause No 3:22cv-5967. This is a Complaint for injunctive and declaratory relief. 2. FERC Docket No. ER23-474-00 re California Independent System Operator. This is a FERC proceeding in which the Utah Public Service Commission filed an objection arguing that the CCA (and the tariff changes proposed by CAISO in relation to the CCA) violates the Dormant Commerce Clause. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 05/16/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IFG RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: IFG-066 TELEPHONE: 509-495-4658 REQUEST: Reference Avista’s response to IFG Production Request 1: Did Avista modify system dispatch in any way to accommodate the costs associated with the CCA, such as an adder to the cost of thermal dispatch and/or increase cost associated with market purchases? If yes, please describe these changes and quantify the impact of those changes on net power supply costs. If no, please explain how system dispatch will be impacted by CCA compliance. RESPONSE: A carbon adder was assigned to Boulder Park because it is a thermal plant located in Washington and exceeds the 25,000 tonnes threshold. The carbon adder is 34.47 percent of the ecology annual rate of $67.81. With the carbon adder, Boulder dispatch is decreased and impacts system net power supply costs by approximately $1,207,000 (see Kalich confidential workpaper ‘Confidential Exh 7 – Sch 1C – 5 01.09.2022.xlsx’ tab ‘Confidential Idaho CCA Costs’, line 6 * $67.81 * 34.47 percent). AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 05/16/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kenny Dillion REQUESTER: IFG RESPONDER: Kenny Dillion TYPE: Production Request DEPARTMENT: Transmission Services REQUEST NO.: IFG-067 TELEPHONE: 509-495-4437 REQUEST: Reference Shultz workpaper “3.00T - 24.00T PF - TRANSMISSION REVENUE & EXPENSE\ID AVU-E-23_Transmission Pro Forma 2023-2025 Summary,” Tab “Actuals Jul2021-Jun2022:” Please provide an updated version of the referenced workpaper with data for the year ending December 31, 2022. Please reconcile the wheeling revenues in the responsive workpaper to the $30,339,137 of wheeling revenues included on Avista’s 2023 FERC Form 1, Page 328-330. RESPONSE: Updated values for the line items provided in “3.00T - 24.00T PF - TRANSMISSION REVENUE & EXPENSE\ID AVU-E-23_Transmission Pro Forma 2023-2025 Summary,” Tab “Actuals Jul2021-Jun2022:” is attached (IFG_PR_067 Attachment A) is the most readily available format. That tab is now labeled as “Actuals Jan2022-Dec2022” and the data includes actual values for January 2022 through December 2022. To reconcile the previously submitted data with data provided in FERC Form 1, the following 456 FERC Accounts must be excluded: - 456017 OTHER ELECTRIC REVENUE - 456030 CLEARWATER PAPER TRANSMISSION - 456700 OTHER – LOW VOLTAGE - 456705 LOW VOLTAGE BPA AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 05/16/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kenny Dillion REQUESTER: IFG RESPONDER: Kenny Dillion TYPE: Production Request DEPARTMENT: Transmission Services REQUEST NO.: IFG-068 TELEPHONE: 509-495-4437 REQUEST: Reference Shultz workpaper “3.00T - 24.00T PF - TRANSMISSION REVENUE & EXPENSE\ID AVU-E-23_Transmission Pro Forma 2023-2025 Summary,” Tab “Actual vs Pro Forma,” Lines 30-31: a. Please explain how transmission revenues associated with the Clearwater Paper line item are being recovered and provide a copy of the contract governing the transmission services being acquired. b. Please explain why Avista assumed that the transmission service revenues would terminate on 31-Dec-2023, while assuming the contract would remain in place for purposes of rate design and revenue requirement. See, e.g., Avista’s response to IFG Production Request 19. RESPONSE: a. Transmission revenue is being collected at Avista’s FERC approved long term firm transmission rate of $32.98/kW-year or $2.7483/kW-month. A copy of the Power Purchase and Sale Agreement between Avista Corporation and Clearwater Paper Corporation is attached as Staff_PR_068 Attachment A. For an example calculation of the forecast revenue of $123,700 from September 2023 to December 2023, see Exhibit C, Item 5 using a rate of $2.7483/kW-month and a peak demand of 45,000kW. b. The Schultz workpaper “3.00T - 24.00T PF - TRANSMISSION REVENUE & EXPENSE\ID AVU-E-23_Transmission Pro Forma 2023-2025 Summary,” Tab “Actual vs Pro Forma,” assumed that the Power Purchase and Sale Agreement between Avista Corporation and Clearwater Paper Corporation would terminate on December 31, 2023 for the purposes of forecast transmission revenue. To be consistent with other responses in the rate case, the planned extension of this agreement and the associated revenue should also be included in the Rate Year 1 and Rate Year 2 calculations. Rate Year 1 would include an additional $989,600 in total revenue and Rate Year 2 would include an additional $1,484,000 in total revenue.