HomeMy WebLinkAbout20230201Dillon Direct.pdf
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: (509) 495-4316
DAVID.MEYER@AVISTACORP.COM
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-E-23-01
OF AVISTA CORPORATION FOR THE )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC AND ) DIRECT TESTIMONY
NATURAL GAS SERVICE TO ELECTRIC ) OF
AND NATURAL GAS CUSTOMERS IN THE ) KENNETH DILLON
STATE OF IDAHO )
)
FOR AVISTA CORPORATION
(ELECTRIC)
Dillon, Di 1
Avista Corporation
I. INTRODUCTION 1
Q. Please state your name, employer and business address. 2
A. My name is Kenneth Dillon. I am employed by Avista Corporation as Senior 3
Manager, FERC Policy and Transmission Services. My business address is 1411 East 4
Mission, Spokane, Washington. 5
Q. Please briefly describe your educational background and professional 6
experience. 7
A. I am a 2002 graduate of Washington State University with a degree in 8
Electrical Engineering and completed a Master in Business Administration at Portland State 9
University in 2007. I spent five years with Portland General Electric in transmission planning 10
prior to joining the Company in 2007 as a Transmission Contracts Analyst. 11
Over the past 15 years I have worked primarily in the Transmission Operations area 12
with responsibilities covering Federal Energy Regulatory Commission (FERC) transmission 13
policy and compliance with open access transmission regulations, transmission contracts, 14
transmission and generation interconnection processes, and regional transmission policy 15
coordination. In my current role I have responsibility for all transmission revenue and 16
expenses. 17
Q. What is the scope of your testimony? 18
A. My testimony presents Avista’s transmission revenues and expenses included 19
in the Company’s request for rate relief over the Two-Year Rate Plan, supporting updated 20
transmission revenues effective September 1, 2023 (Rate Year 1) and September 1, 2024 (Rate 21
Year 2). 22
Dillon, Di 2
Avista Corporation
A table of contents for my testimony is as follows: 1
Description Page 2
I. INTRODUCTION .................................................................................................... 1 3
II. TRANSMISSION EXPENSES ................................................................................ 2 4
III. TRANSMISSION REVENUES ............................................................................... 3 5
6
Q. Are you sponsoring any exhibits? 7
A. Yes. Exhibit No. 8, Schedule 1 provides the transmission expense and revenue 8
during the Two-Year Rate Plan, beginning September 1, 2023 through August 31, 2025. 9
Additionally, supporting workpapers for each of the expense and revenue items have been 10
included with the Company’s filed case. 11
12
II. TRANSMISSION EXPENSES 13
Q. Please describe any adjustments to the twelve-months-ended June 30, 14
2022 test year transmission expenses, to arrive at transmission expenses included in this 15
case effective September 1, 2023. 16
A. No adjustments were made in this filing to incorporate updated information for 17
any changes in transmission expenses from the twelve-months-ended June 30, 2022 (“12ME 18
06.30.2022”) test period used in this case, for the rate effective period beginning September 19
1, 2023. Over the past several years there have been revisions to the organizational structures 20
through which Avista acquires certain functional services required by mandatory federal 21
reliability standards and Federal Energy Regulatory Commission (FERC) transmission 22
planning requirements. The Company now participates in NorthernGrid, in compliance with 23
FERC regional transmission planning requirements, and acquires Reliability Coordination 24
Services from RC West, a functional arm under the California Independent System Operator. 25
Dillon, Di 3
Avista Corporation
These revised structures were in place prior to the June 30, 2022 test year. The Company 1
foresees no substantive adjustments to these and other transmission expenses during the Two-2
Year Rate Plan. Accordingly, as can be seen in Exhibit No. 8, Schedule 1, no adjustments 3
have been made in this filing to incorporate changes in transmission expenses beyond the 4
12ME 06.30.2022 test year levels of $1.08 million (electric system). This level of transmission 5
expense, therefore, is expected to effectively remain the same over the Two-Year Rate Plan. 6
7
III. TRANSMISSION REVENUES 8
Q. Please summarize the adjustments to the twelve-months-ended June 30, 9
2022 test year transmission revenues to arrive at transmission revenues included in this 10
case effective September 1, 2023 and September 1, 2024. 11
A. Adjustments have been made in this filing to incorporate updated information 12
for transmission revenues from the 12ME 06.30.2022 test year to that expected in this case 13
effective September 1, 2023 for Rate Year 1 (“RY1”) and September 1, 2024 for Rate Year 2 14
(“RY2”). These adjustments include: (i) the application of increased transmission rates that 15
apply to long-term transmission service agreements under the Company’s Open Access 16
Transmission Tariff,1 (ii) long-term firm transmission service agreements entered into by the 17
Company either during or following the historical test year, and (iii) long-term firm 18
transmission service agreements that have expired or will expire during the Two-Year Rate 19
Plan. As outlined in Exhibit No. 8, Schedule 1, I have provided the expected changes in 20
1 The Company attained FERC acceptance of updated transmission rates under the Company’s Open Access
Transmission Tariff effective October 1, 2021.
Dillon, Di 4
Avista Corporation
transmission revenues beyond the 12ME 06.30.2022 test year levels.2 Company witness Ms. 1
Schultz has pro formed the transmission revenues within the revenue requirement in this case, 2
increasing Idaho transmission revenue by $1,793,000 effective September 1, 2023 (RY1), and 3
reducing Idaho transmission revenue by $335,000 effective September 1, 2024 (RY2).3 / 4 4
Q. Please describe the adjustments to the 12ME 06.30.2022 test year 5
transmission revenues to arrive at transmission revenues included in this case effective 6
September 1, 2023 and September 1, 2024. 7
A. Each revenue item described below is at a system level and is included in 8
Exhibit No. 8, Schedule 1. Table No. 1 provides a detailed summary of the changes in 9
transmission revenues, as well as a listing of transmission revenues not changing at this time. 10
An explanation of each follows the table. 11
2 Transmission Revenues (FERC Account 456 – other Electric Revenue) are included and tracked as a part of
the Company’s Power Cost Adjustment (PCA). The total transmission revenue of $32.126 million (electric
system) is therefore included in Company witness Mr. Kalich’s Exhibit No. 7, Schedule 5 reflecting the proposed
PCA net base power supply expense, offset by transmission revenues, representing the proposed “Total
Authorized Expense” on a system (Idaho and Washington) basis for Rate Year 1. Idaho’s share of the net power
supply revenues and expenses is equal to 34.47% of the system total, based on the Production/Transmission
(P/T) ratio updated annually as of December 2021. The PCA net base power supply expense and transmission
revenues are also updated effective September 1, 2024 (RY2).
3 As discussed by Ms. Schultz, transmission revenues are adjusted in Pro Forma Transmission Adjustment PF
3.00T (RY1) from the 12ME 06.30.2022 historical test period level of $27.286 million (system) to the RY1 pro
forma level of $32.126 million (system) as of September 1, 2023. The overall increase in transmission revenues
in RY1 are approximately $4.84 million on a system basis, or after considering certain direct assigned
transmission revenues, $1.79 million for Idaho operations for RY1. Ms. Schultz also reflects through Pro Forma
Transmission Adjustments PF 24.00T, beginning September 1, 2024, the RY2 transmission revenue reduction
from $32.126 million (system) in RY1 to $31.246 million (system) for RY2, a system reduction of $880,000 for
Rate Year 2, below Rate Year 1 levels. After considering certain direct assigned transmission revenues, this
change reduces RY2 Idaho transmission revenues by $335,000 below RY1 levels.
4 Pro Forma transmission revenues of $32.126 in RY1 versus current authorized transmission revenues of
$23.471 million, result in an increase in transmission revenues of $8.44 million on a system basis, or $2.9 million
Idaho share.
Dillon, Di 5
Avista Corporation
Table No. 1: Transmission Revenue Adjustment 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Transmission Revenue Adjustment - 2023-24 and 2024-25 Rate Periods
Rate Year 1(1)
(09.01.2023 - 08.31.2024)
Rate Year 2(2)
(09.01.2024 - 08.31.2025)
456100 Transmission
OASIS (Non-Firm and ST Firm)(773)$ -$
Bonneville Power Administration (202)$ (154)$
Consolidated Irrigation District -$ -$
East Greenacres Irrigation District 1$ -$
Spokane Tribe of Indians 2$ -$
Grant County PUD No. 2 -$ -$
PacifiCorp (Dry Gulch)(2)$ -$
Seattle City Light/Tacoma Power (Main Canal)22$ (10)$
Seattle City Light/Tacoma Power (Summer Falls)-$ (150)$
City of Spokane Waste to Energy -$ -$
Stimson Lumber Company -$ -$
Hydro Tech - Meyers Falls -$ -$
Deep Creek Energy LLC -$ -$
Kootenai Electric Cooperative (34)$ (58)$
Idaho Power 1 (100MW) 225$ -$
Idaho Power 2 (100MW) 2,748$ -$
Powerex (137MW)3,765$ -$
456017 Other Electric Revenue
Columbia Basin Hydropower -$ -$
Palouse Wind O&M (2)$ -$
Adams Neilson Solar O&M (1)$ -$
Rattlesnake Flat O&M 2$ -$
456030 Clearwater Paper Transmission
Clearwater Paper Transmission (859)$ (495)$
456120 Parallel Capacity Support
BPA Parallel Capacity Support -$ -$
456130 Ancillary Services
Bonneville Power Adminstration (45)$ -$
Consolidated Irrigation District -$ -$
East Greenacres Irrigation District -$ -$
Spokane Tribe of Indians (1)$ -$
Kootenai Electric Cooperative (6)$ (13)$
Douglas PUD (Backup Service)(11)$ -$
456700 Other - Low Voltage
Consolidated Irrigation District 10$ -$
East Greenacres Irrigation District -$ -$
Spokane Tribe of Indians -$ -$
456705 Low Voltage BPA
Bonneville Power Administration 1$ -$
Total Transmission Revenue Adjustment 4,840$ (880)$
(1) Represents the change in revenue above or below the twelve-months-ended 06.30.2022 historical test year level on a System basis.
(2) Represents the change in revenue above or below the Rate Year 1 level on a System basis.
Dillon, Di 6
Avista Corporation
The Company provides transmission service to wholesale customers under the 1
jurisdiction of the FERC. The components of what has traditionally been known as 2
“wheeling” service include: (i) transmission service over the Company’s transmission 3
facilities that are operated at or above 115kV, (ii) operations and maintenance (O&M) charges 4
associated with Company transmission assets for which an interconnection customer provided 5
contributions in aid to construction, (iii) ancillary services (generation-related services that 6
are required to be offered in conjunction with transmission service), and (iv) low-voltage 7
wheeling services over substation and distribution facilities that are operated below 115kV. 8
The Company attained FERC acceptance of updated transmission rates under its open access 9
transmission tariff effective October 1, 2021. 10
An explanation of each transmission revenue change as shown in Table No. 1 above 11
are described as follows for the periods 09.01.2023 – 08.31.2024 (RY1) and 09.01.2024 – 12
08.31.2025 (RY2): 13
OASIS Non-Firm and Short-Term Firm Transmission Service (RY1: -$773,000; RY2: 14
$0) – OASIS is an acronym for Open Access Same-time Information System. This is the 15
system used by electric transmission providers for selling available transmission capacity to 16
eligible customers. The terms and conditions under which the Company sells its transmission 17
capacity via its OASIS are pursuant to FERC regulations and Avista’s Open Access 18
Transmission Tariff. Consistent with prior Avista general rate cases, the Company calculates 19
its rate year adjustments using a three-year average of actual OASIS Non-Firm and Short-20
Term Firm revenue. OASIS transmission revenue may vary significantly depending upon a 21
number of factors, including current wholesale power market conditions, forced or planned 22
generation resource outage situations in the region, the current load-resource balance status of 23
Dillon, Di 7
Avista Corporation
regional load-serving entities, and the availability of parallel transmission paths for 1
prospective transmission customers. 2
The use of a three-year average is intended to strike a balance in mitigating both long-3
term and short-term impacts to OASIS revenue. A three-year period is intended to be long 4
enough to mitigate the impacts of non-substantial temporary operational conditions (for 5
generation and transmission) that may occur during a given year, and short-enough so as to 6
not dilute the impacts of long-term transmission and generation topography changes (e.g., 7
major transmission projects which may impact the availability of the Company’s transmission 8
capacity or competing transmission paths, and major generation projects which may impact 9
the load-resource balance needs of prospective transmission customers). If there are known 10
events or factors that occurred during the period that would cause the average to not be 11
representative of future expectations, then adjustments may be made to the three-year average 12
methodology. 13
However, volatility in OASIS revenue from year-to-year can be expected, entirely 14
outside the scope and purview of the Company as a transmission provider. For example, the 15
Company experienced several months of higher-than-normal OASIS revenues between 16
November 2018 and March 2019 and from November 2019 through December 2019 due to 17
the loss of a major natural gas transportation pipeline in western British Columbia. It is 18
apparent that the impact of this event upon the dispatch of generation resources in the region 19
facilitated increased short-term use of the Company’s transmission system. In this filing, the 20
Company is using a three-year average for the time period of July 2019 to June 2022. To 21
mitigate the anomalous impacts of the gas pipeline outage, in calculating its three-year average 22
the Company has adjusted the revenue in the two impacted months (November and December 23
Dillon, Di 8
Avista Corporation
2019) by using the average revenue in each such month during the three-years prior to the gas 1
pipeline outage. The OASIS revenue for the 12ME 06.30.2022 test year was $7.610 million 2
and the three-year average calculated for both the RY1 and RY2 rate periods is $6.837 million, 3
or a reduction of $773,000. 4
Bonneville Power Administration – Transmission (RY1: -$202,000; RY2: -$154,000) 5
– The Company provides Network Integration Transmission Service to the Bonneville Power 6
Administration (BPA) under a series of thirteen agreements serving BPA’s utility customers 7
connected to the Company’s transmission system. Network Service revenue is based upon a 8
rolling 12-month average of BPA’s loads. Also impacting Network Service revenue is the 9
applicability of any long-term firm point-to-point transmission service, for which the 10
Company has recently entered into four recent agreements that will apply during the rate 11
periods. BPA Network Service revenue was $8.691 million for the 12ME 06.30.2022 test 12
year. Based upon three-year averages calculated from July 2019 through June 2022 and 13
adjusted to reflect the Company’s updated transmission rates and new long-term firm 14
transmission service agreements, the Company expects BPA Network Service revenue to be 15
$8,489,000 during the RY1 rate period, or $202,000 less than the 12ME 06.30.2022 test year, 16
and then $8,335,000 during RY2, or $154,000 less than RY1. 17
Consolidated Irrigation District – Transmission (RY1: $0; RY2: $0) – The Company 18
provides Long-Term Firm Point-to-Point Transmission Service to the Consolidated Irrigation 19
District under an agreement effective October 1, 2021 through September 30, 2026. 20
Consolidated Irrigation transmission revenue was $33,000 for the 12ME 06.30.2022 test year 21
and the Company expects there will be no change over the Two-Year Rate Plan. 22
East Greenacres Irrigation District – Transmission (RY1: +$1,000; RY2: $0) – The 23
Dillon, Di 9
Avista Corporation
Company provides Long-Term Firm Point-to-Point Transmission Service to East Greenacres 1
Irrigation District under an agreement effective through September 30, 2024. The Company 2
expects a follow-on agreement to be executed with comparable terms. East Greenacres 3
transmission revenue was $14,000 for the 12ME 06.30.2022 test year and, reflecting the 4
Company’s updated transmission rates, the Company expects this revenue to be $15,000 5
during the Two-Year Rate Plan, or an increase of $1,000 above the 12ME 06.30.2022 test 6
year. 7
Spokane Tribe of Indians – Transmission (RY1: +$2,000; RY2: $0) – The Company 8
provides Long-Term Firm Point-to-Point Transmission Service to the Spokane Tribe of 9
Indians under an agreement effective January 1, 2020 through December 31, 2024. The 10
Company expects a follow-on agreement to be executed with comparable terms. Spokane 11
Tribe transmission revenue was $23,000 for the 12ME 06.30.2022 test year and, reflecting the 12
Company’s updated transmission rates, the Company expects this revenue to be $25,000 13
during the Two-Year Rate Plan, or an increase of $2,000 above the 12ME 06.30.2022 test 14
year. 15
Grant County PUD – Transmission (RY1: $0; RY2: $0) – The Company provides 16
long-term transmission service to Grant County PUD for service to its Coulee City and Wilson 17
Creek loads connected to the Company’s transmission system. Revenue under the Power 18
Transfer Agreement varies according to Grant PUD’s actual loads and was $28,000 for the 19
12ME 06.30.2022 test year. Based upon a three-year average from July 2019 through June 20
2022, the Company expects there will be no substantive change during the Two-Year Rate 21
Plan. 22
PacifiCorp – Dry Gulch Transmission (RY1: -$2,000; RY2: $0) – The Company 23
Dillon, Di 10
Avista Corporation
provides long-term transmission service under a use-of-facilities agreement with PacifiCorp 1
for use of the Company’s Dry Gulch Substation. The agreement includes a twelve-month 2
rolling ratchet provision and is based upon actual PacifiCorp use. Revenue under the Dry 3
Gulch agreement was $233,000 during the 12ME 06.30.2022 test year. Based upon a three-4
year average from July 2019 through June 2022, the Company expects this revenue to be 5
$231,000 during the Two-Year Rate Plan, or $2,000 less than the 12ME 06.30.2022 test year. 6
Seattle and Tacoma – Main Canal Transmission (RY1: +$22,000; RY2: -$10,000) – 7
The Company provides Long-Term Firm Point-to-Point Transmission Service to the City of 8
Seattle and Tacoma Power, under agreements effective through October 31, 2026, to transfer 9
output from the Main Canal hydroelectric project to the Company’s transmission 10
interconnections with Grant County PUD. Service is provided during the eight months of the 11
year (March through October) in which the Main Canal project operates, and the agreements 12
include a three-year ratchet demand provision. Revenues under these two agreements totaled 13
$462,000 during the 12ME 06.30.2022 test year and, reflecting the Company’s updated 14
transmission rates and ratchet demands, the Company expects this revenue to be $484,000 15
during RY1, or an increase of $22,000 above the 12ME 06.30.2022 test year, and then 16
$474,000 during RY2, or $10,000 less than RY1. 17
Seattle and Tacoma – Summer Falls Transmission (RY1: $0; RY2: -$150,000) – The 18
Company provides long-term use-of-facilities transmission service to the City of Seattle and 19
Tacoma Power, under agreements effective through October 31, 2024, to transfer output from 20
the Summer Falls hydroelectric project across the Company’s Stratford 115kV Switching 21
Station facilities, to the Company’s Stratford interconnection with Grant County PUD. 22
Charges under these use-of-facilities arrangements are based upon the Company’s investment 23
Dillon, Di 11
Avista Corporation
in its Stratford Switching Station and are not impacted by the Company’s transmission service 1
rates under its Open Access Transmission Tariff. Revenues under these two agreements 2
totaled $180,000 during the 12ME 06.30.2022 test year and the Company expects there will 3
be no change during RY1. Reflecting the contract’s termination in October 2024, the 4
Company expects this revenue to be $30,000 during RY2, or $150,000 less than RY1. 5
City of Spokane – Waste to Energy Transmission (RY1: $0; RY2: $0) – The City of 6
Spokane pays a use-of-facilities charge for the ongoing use of its interconnection to the 7
Company’s transmission system. Use-of-facilities charges were $28,000 for the 12ME 8
06.30.2022 test year and the Company expects there to be no change during the Two-Year 9
Rate Plan. 10
Stimson Lumber PURPA (RY1: $0; RY2: $0) – Low-voltage facilities associated with 11
the Company’s Plummer Substation are dedicated for use by Stimson Lumber under a PURPA 12
arrangement. Low-voltage use-of-facilities revenue was $8,000 for the 12ME 06.30.2022 13
test year and the Company expects there will be no change during the Two-Year Rate Plan. 14
Hydro Tech Systems PURPA (RY1: $0; RY2: $0) – Low-voltage facilities in the 15
Company’s Greenwood Substation are dedicated for use by the Meyers Falls generation 16
project under a PURPA arrangement. Low-voltage use-of-facilities revenue was $6,000 17
during the 12ME 06.30.2022 test year and the Company expects there will be no change 18
during the Two-Year Rate Plan. 19
Deep Creek PURPA (RY1: $0; RY2: $0) – The Company owns and operates low 20
voltage facilities that are dedicated for use by the Deep Creek generation project under a 21
PURPA arrangement. Low-voltage use-of-facilities revenue was less than $1,000 during the 22
12ME 06.30.2022 test year and the Company expects there will be no change during the Two-23
Dillon, Di 12
Avista Corporation
Year Rate Plan. 1
Kootenai Electric Cooperative – Transmission (RY1: -$34,000; RY2: -$58,000) – The 2
Company provides Long-Term Firm Point-to-Point Transmission Service to Kootenai Electric 3
Cooperative under an agreement effective through March 31, 2024, to transfer the output of 4
the Fighting Creek generation project. The Company understands that Kootenai Electric 5
Cooperative plans to make different arrangements for addressing the output of this project 6
upon expiration of the agreement. Transmission revenue was $92,000 during the 12ME 7
06.30.2022 test year and, reflecting the Company’s updated transmission rates and contract 8
expiration, the Company expects this revenue to be $58,000 during RY1, or $34,000 less than 9
the 12ME 06.30.2022 test year, and $0 during RY2, or $58,000 less than RY1. 10
Idaho Power 1 – Transmission (RY1: +$225,000; RY2: $0) – The Company provides 11
Long-Term Firm Point-to-Point Transmission Service to Idaho Power under an agreement 12
effective May 1, 2021 through April 30, 2026. Transmission revenue was $3.073 million for 13
the 12ME 06.30.2022 test year and, reflecting the Company’s updated transmission rates, the 14
Company expects this revenue to be $3.298 million during the Two-Year Rate Plan, or an 15
increase of $225,000 above the 12ME 06.30.2022 test year. 16
Idaho Power 2 – Transmission (RY1: +$2,748,000; RY2: $0) – The Company provides 17
Long-Term Firm Point-to-Point Transmission Service to Idaho Power under a second 18
agreement effective May 1, 2022 through April 30, 2027. Transmission revenue was 19
$550,000 for the 12ME 06.30.2022 test year and, reflecting the contract term, the Company 20
expects this revenue to be $3.298 million during the Two-Year Rate Plan, or an increase of 21
$2.748 million above the 12ME 06.30.2022 test year. 22
Powerex – Transmission (RY1: +$3,765,000; RY2: $0) – The Company provides 23
Dillon, Di 13
Avista Corporation
Long-Term Firm Point-to-Point Transmission Service to Powerex under an agreement 1
effective May 1, 2022 through April 30, 2024 and a second agreement effective May 1, 2024 2
through April 30, 2026. Transmission revenue was $753,000 for the 12ME 06.30.2022 test 3
year and, reflecting the contract terms, the Company expects this revenue to be $4.518 million 4
during the Two-Year Rate Plan, or an increase of $3.765 million above the 12ME 06.30.2022 5
test year. 6
Columbia Basin Hydropower (RY1: $0; RY2: $0) – The Company provides operations 7
and maintenance services on the Stratford-Summer Falls 115kV Transmission Line to 8
Columbia Basin Hydropower under a contract signed in March 2006. These services are 9
provided for a fixed annual fee. Annual charges under this contract were $8,000 in the 12ME 10
06.30.2022 test year and the Company expects there to be no change during the Two-Year 11
Rate Plan. 12
Palouse Wind O&M (RY1: -$2,000; RY2: $0) – Per the Company’s interconnection 13
agreement with the Palouse Wind project, the interconnection customer pays O&M fees 14
associated with directly-assigned interconnection facilities owned and operated by the 15
Company. O&M revenue for the 12ME 06.30.2022 test year was $44,000 and, reflecting the 16
Company’s updated transmission expenses in its FERC transmission rate filing, the Company 17
expects this revenue to be $42,000 during the Two-Year Rate Plan, or $2,000 less than the 18
12ME 06.30.2022 test year. 19
Adams Neilson Solar O&M (RY1: -$1,000; RY2: $0) – Per the Company’s 20
interconnection agreement with the Adams Neilson Solar project, the interconnection 21
customer pays O&M fees associated with directly-assigned interconnection facilities owned 22
and operated by the Company. O&M revenue for the 12ME 06.30.2022 test year was $9,000 23
Dillon, Di 14
Avista Corporation
and, reflecting the Company’s updated expenses in its FERC transmission rate filing, the 1
Company expects this revenue to be $8,000 during the Two-Year Rate Plan, or $1,000 less 2
than the 12ME 06.30.2022 test year. 3
Rattlesnake Flat O&M (RY1: +$2,000; RY2: $0) – Per the Company’s interconnection 4
agreement with the Rattlesnake Flat Wind project, the interconnection customer pays O&M 5
fees associated with directly-assigned interconnection facilities owned and operated by the 6
Company. O&M revenue for the 12ME 06.30.2022 test year was $61,000 and, reflecting the 7
Company’s updated transmission expenses in its FERC transmission rate filing, the Company 8
expects this revenue to be $63,000 during the Two-Year Rate Plan, or an increase of $2,000 9
above the 12ME 06.30.2022 test year. 10
Clearwater Paper Transmission (RY1: -$859,000; RY2: -$495,000) – As part of the 11
Company’s agreement with Clearwater Paper, which terminates December 31, 2023, the 12
Company allocates a portion of its revenue to transmission service. Transmission revenue for 13
the 12ME 06.30.2022 test year was $1.354 million and, reflecting the contract term, the 14
Company expects this revenue to be $495,000 during RY1, or $859,000 less than the 12ME 15
06.30.2022 test year, and $0 during RY2, or $495,000 less than RY1. 16
Bonneville Power Administration – Parallel Capacity Support (RY1: $0; RY2: $0) – 17
The Company and BPA executed a Parallel Capacity Support Agreement effective February 18
1, 2017, with a minimum term extending to December 31, 2026, in which the Company 19
provides BPA with parallel transmission capacity in support of BPA’s integration of several 20
wind resource projects. Revenue was $924,000 during the 12ME 06.30.2022 test year and the 21
Company expects that there will be no change during the Two-Year Rate Plan. 22
Bonneville Power Administration – Ancillary Services (RY1: -$45,000; RY2: $0) – 23
Dillon, Di 15
Avista Corporation
The Company provides Ancillary Services to BPA under its Network Integration 1
Transmission Service agreements. Subject to a FERC order in Docket No. EL20-36-000, 2
BPA began self-supply of operating reserves under the agreements in April 2021. BPA 3
Ancillary Services revenue was $1.086 million for the 12ME 06.30.2022 test year. Based on 4
a three-year average of actual BPA peak loads from July 2019 through June 2022, the 5
Company expects this revenue to be approximately $1.041 million during the Two-Year Rate 6
Plan, or $45,000 less than the 12ME 06.30.2022 test year. 7
Consolidated Irrigation District – Ancillary Services (RY1: $0; RY2: $0) – The 8
Company provides Ancillary Services to the Consolidated Irrigation District under its Long-9
Term Firm Point-to-Point Transmission Service agreement. Ancillary Service revenue was 10
$10,000 for the 12ME 06.30.2022 test year and, based upon a three-year average from July 11
2019 through June 2022, the Company expects there will be no change during the Two-Year 12
Rate Plan. 13
East Greenacres Irrigation District – Ancillary Services (RY1: $0; RY2: $0) – The 14
Company provides Ancillary Services to East Greenacres Irrigation District under its Long-15
Term Firm Point-to-Point Transmission Service agreement. Ancillary Service revenue was 16
$6,000 for the 12ME 06.30.2022 test year and, based upon a three-year average from July 17
2019 through June 2022, the Company expects there will be no change during the Two-Year 18
Rate Plan. 19
Spokane Tribe of Indians – Ancillary Services (RY1: -$1,000; RY2: $0) – The 20
Company provides Ancillary Services to the Spokane Tribe of Indians under its Long-Term 21
Firm Point-to-Point Transmission Service agreement. Ancillary Service revenue was $8,000 22
for the 12ME 06.30.2022 test year and, based upon a three-year average from July 2019 23
Dillon, Di 16
Avista Corporation
through June 2022, the Company expects this revenue to be $7,000 during the Two-Year Rate 1
Plan, or $1,000 less than the 12ME 06.30.2022 test year. 2
Kootenai Electric Cooperative – Ancillary Services (RY1: -$6,000; RY2: -$13,000) – 3
The Company provides Ancillary Services to Kootenai Electric Cooperative under its Long-4
Term Firm Point-to-Point Transmission Service agreement. Ancillary Service revenue was 5
$19,000 for the 12ME 06.30.2022 test year, reflecting the contract term, the Company expects 6
this revenue to be $13,000 during RY1, or $6,000 less than the 12ME 06.30.2022 test year, 7
and $0 during RY2, or $13,000 less than RY1. 8
Douglas PUD (Backup Service) (RY1: -$11,000; RY2: $0) – The Company provides 9
Backup Service Ancillary Services to Douglas PUD. Ancillary Service revenue was $11,000 10
for the 12ME 06.30.2022 test year and, reflecting the contract term, this revenue is $0 during 11
the Two-Year Rate Plan, or $11,000 less than the 12ME 06.30.2022 test year. 12
Consolidated Irrigation District – Low-Voltage (WA Only) (RY1: +$10,000; RY2: 13
$0) – The Company provides transfer service over low voltage facilities to Consolidated 14
Irrigation District under the Electric Distribution Services Agreement, effective April 22, 15
2022 through September 30, 2026. Low-voltage charges were $94,000 during the 12ME 16
06.30.2022 test year and the Company expects this revenue to be $104,000 during the RY1 17
and RY2 rate periods. The low voltage transfer service impacts Washington only and has no 18
effect on Idaho operations. 19
East Greenacres Irrigation District – Low-Voltage (ID Only) (RY1: $0; RY2: $0) – 20
The Company provides transfer service over low voltage facilities to East Greenacres 21
Irrigation District under the Electric Distribution Services Agreement, effective January 1, 22
2020 through September 30, 2024. Low-voltage charges were $63,000 during the 12ME 23
Dillon, Di 17
Avista Corporation
06.30.2022 test year and the Company expects there to be no change during the Two-Year 1
Rate Plan. This low voltage transfer service is directly applied to Idaho operations only. 2
Spokane Tribe of Indians – Low-Voltage (WA Only) (RY1: $0; RY2: $0) – The 3
Company provides transfer service over low voltage facilities to the Spokane Tribe of Indians 4
under the Electric Distribution Services Agreement, effective January 1, 2020 through 5
December 31, 2024. Low-voltage charges were $25,000 during the 12ME 06.30.2022 test 6
year and the Company expects there to be no change during the Two-Year Rate Plan. The 7
low voltage transfer service impacts Washington only and has no effect on Idaho operations. 8
Bonneville Power Administration – Low-Voltage (RY1: $0; RY2: $0) – The Company 9
provides transfer service over low-voltage facilities to BPA under its Network Integration 10
Transmission Service agreements. BPA low-voltage revenue was $1,779,000 during the 11
12ME 06.30.2022 test year and the Company expects there to be no change during the Two-12
Year Rate Plan. 13
Q. Does this complete your pre-filed direct testimony? 14
A. Yes, it does. 15