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HomeMy WebLinkAbout20210702Application.pdfj,istsra Avista Corp. 141 I East Mission P.O.Box3727 Spokane, Washington 99220-0500 Telephone 509-489-0500 Toll Free 800-727-9170 Jtl/ry 2,2021 Commission Secretary State of Idalro Idaho Public Utilities Commission 11331 W. Chinden Blvd. Building 8, Suite 201-4 Boise,Idaho 83714 Case No. AVIJ-G-21-0!L I.P.U.C. No. 27 - Natural Gas Service ln accordance with CaseNo. GNR-U-20-01, OrderNo.34602,which suspends the requirement to file physical copies, the Company has attached for electronic filing with the Commission are the following revised tariff sheets: Twenty-Ninth Revision Sheet 150 canceling Twenty-Eighth Revision Sheet 150 Twenty-Third Revision Sheet 155 canceling Twenty- Second Revision Sheet 155 The Company requests that the proposed tariffsheets be made effective September 1,202L. These tariffsheets reflect the Company's annual Purchased Gas Cost Adjustment ('PGA"). If approved, the Company's annual revenue will increase by approximately $9.0 million or approximately l3.5Yo. The proposed changes have no effect on the Company's earnings. Detailed information related to the Company's request was filed electonically along with the attached Application and supporting workpapers. Filed concurrently with this PGA is the Deferred Balances Credit filing. If both the PGA and Deferred Balances Credit filings are approved, residential natural gas customers in Idaho using an average of 63 therms per month would see their monthly bills increase from $49.49 to $54.05, an increase of $4.56 per month, or approximately 9.2%. The proposed natural gas rate changes would be effective September 1,2021. Based on discussions with Commission Staff, the Company will provide directly to Commission Staff capactty release detail as soon as it becomes available. If you have any questions regarding this filing, please contact Marcus Garbarino at (509) 495-2567. Sincerely, /s/ Patrick D. Ehrbar Patrick D. Ehrbar Director of Regulatory Affairs BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF AVISTA UTILITIES FOR AN ORDER APPROVING A CHANGE IN RATES FOR PURCHASED GAS COSTS AND AMORTIZATION OF GAS-RELATED DEFERRAL BALANCES ) ) ) ) ) CASE: AVU-G-21-01| Application is hereby made to the Idaho Public Utilities Commission for an Order approving a revised schedule of rates and charges for natural gas service in the state of Idaho. The Applicant requests that the proposed rates included in this Purchased Gas Cost Adjustment ("PGA") filing be made effective on September 1,2021. If approved as filed, the Company's annual revenue will increase by approximately $9.0 million or about 13.5%. In support of this Application, Applicant states as follows: The name of the Applicant is AVISTA CORPORATION, doing business as AVISTA UTILITIES (hereinafter Avista, Applicant or Company), a Washington corporation, whose principal business office is 141 I East Mission Avenue, Spokane, Washington, and is qualified to do business in the state of Idaho. Applicant maintains district offices in Moscow, Lewiston, Coeur d'Alene, Sandpoint, and Kellogg, Idaho. Communications in reference to this Application should be addressed to: Patrick D. Ehrbar Director of Regulatory Affairs Avista Utilities l4l I E. Mission Avenue Spokane, WA 99220-3727 Phone: (509) 495-8620 P at. ehrbar@a vi stacorp. corn Dockets@avistacom.com II. Attomey for the Applicant and his address is as follows: David J. Meyer Vice President and Chief Counsel for Regulatory And Governmental Affairs Avista Utilities 14l l E. Mission Avenue Spokane, WA 99220-3727 Phone: (509)495-4316 I. CaseNo. AVU-G-21-0 Page I of5 David.meyer@avistacorp.com The Applicant is a public utility engaged in the distribution of natural gas in certain portions of Northern Idaho, Eastern and Cenfral Washington, and Southwestern and Northeastern Oregon, and further engaged in the generation, transmission, and distibution of electricity in Northern Idaho and Eastem Washington. ry Twenty-Nineth Revision Sheet 150, which Applicant requests the Commission approve, is filed herewith as Exhibit "A'. Additionally, Twenty-Third Revision Sheet 155, which Applicant requests the Commission approve, is also filed herewith as Exhibit "A". Also included in Exhibit "A" is a copy of Twenty-Nineth Revision Sheet 150 and Twenty-Third Revision Tariff Sheet 155 with the changes underlined and a copy of Twenty-Eighth Revision Sheet 150 and Twenty-Second Revision TariffSheet 155 with the proposed changes shown by lining over the current language or rates. The existing rates and charges for natural gas service on file with the Commission and designated as Applicant's Tariff IPUC No. 27, which will be superseded by the rates and charges filed herewith, are incorporated herein as though fully attached hereto. VL Notice to the Public of Applicant's proposed tariffs is to be given simultaneously with the filing of this Application by posting, at each of the Company's district offices in Idaho, a Notice in the form attached hereto as Exhibit "B" and by means of a press release distributed to various informational agencies, a draft copy attached hereto in Exhibit *Co'. In addition, Exhibit "C" to this Application also contains the form of customer notice that the Company will send to its customers in its monthly bills in the July timeframe. VII The circumstances and conditions relied on for approval of Applicant's revised rates are as follows: Applicant purclases natural gas for customer usage and transports it over Williams Northwest Pipeline, Gas Transmission Northwest (GTN), TC Energy - Alberta, TC Energy - BC and Enbridge Energy Pipeline systems, and defers the efflect of timing differences due to implementation ofrate changes and differences between Applicant's actual weighted average cost of gas ("WACOG") purchased and the WACOG embedded in rates. Applicant also defers various pipeline refunds or charges and miscellaneous revenue received from natural gas related transactions including pipeline capacity releases. Workpapers for all proposed Commodity, Demand and Amortization costs are provided with this filing as Exhibit "D". il. V CaseNo. AW-G-21-0 VIII Page 2 of5 This frling reflects the Company's proposed annual PGA to: 1) pass through changes in the estimated cost of natural gas for the Septemb er 2021 through October 2022 fourteen-month period (Schedule I 50), and 2) revise the amortization rate(s) to refund or collect the balance of deferred natural gas costs (Schedule 155). Below is a table summainngthe proposed rate changes reflected in this filing: Service General Lg. General Lg General Intemrptible Tranryortation Commodify Change per therm $ 0.04022 $ 0.04022 $ 0.04022 $ 0.04022s- De,mand Change per thcrm $ 0.00238 $ 0.00238 $ 0.00238 $- $- Total Sch. 150 Change $ 0.04260 $ 0.04260 $ 0.04260 $ 0.04022 $- Amortizatbn Change per therm 0.05259 0.05259 TotalPGA Rate Change per therm $ 0.09519 $ 0.09519 $ 0.04260 $ 0.04022 $- Sch. No. 101ul tt2 131 t46 The Company is filing this Application earlier than the typical August-Septenrber timeframe in order to limit the bill impact to customers from the accumulated deferral and amortization surcharge balances that have increased due to rising natural gas costs in recent months since our last filing. The Company is filing another Application simultaneously with ttris application designed to refund deferred credit balances associated with depreciation expense, Accumulated Funds Used During Construction, and CARES Acts benefits that would decrease natural gas revenues bv approximatelv $19 million or 2.9olo effective September l. 2021. If both applications are approved the net chanse to natural sas revenue would be an increase of approximately $7.1 million or 10.6010 effective September l. 2021. IX. Schedule 150 / Purchase Gas Cost - Commoditv Costs As shown in the table above, the estimated WACOG change is an increase of $0.04022 per therm; the proposed WACOG of $0.20305 per therm compared to the present WACOG of $0.16283 per therm included in rates. The cost of natural gas commodity remains relatively low in comparison to historical periods, however, wholesale natural gas prices in recent months as well as the forward prices have risen substantially compared to the level presently included in rates. The market factors attributing to the rise in prices is an overall increase in demand and lower supply. The main driver in dernand has been record exports to Mexico, elevated LNG exports and increased use for power generation. On the supply side, production has been slow to ramp up to pre-pandemic levels. In addition, storage levels are well below where they were at this time last year and the current forecasted end of season level is seen as significantly below last year's level. The Company's nafural gas Procurement Plan ("Plan") uses a diversified approach to procure natural gas for the coming PGA year. While the Plan generally incorporates a more structured approach for the hedgrng portion of the portfolio, the Company exercises flexibility and discretion in all areas of the plan based on changes in the wholesale market. The Company typically meets with Commission Staffsemi- annually to discuss the state of the wholesale market and the status of the Company's Plan. In addition, the Company communicates with Staffwhen it believes it makes sense to deviate from its Plan anilor opportunities arise in the market. CaseNo. AW-G-21-0 Page 3 of5 Avista has been hedging natural gas on both a periodic and discretionary basis throughout the previous thirty-six months for the forthcoming PGA year. Approximately 27% of the annual load requirements for this year's PGA period (September 2021through October 2022) have been hedged at a fixed-price derived from the Company's Plan. Through May, the hedge volumes for the PGA period have been executed at a weighted average price of $1.81 per dekatherm ($0.181 per therm). The Company used a 60-day historical average of AECO forward prices (ending May 31, 2021) to develop an estimated cost associated with index purchases. These index purchases represent approximately 73% of estimated annual load requirements for the coming year. The annual weighted average price for these volumes is $2.34 per dekatherm (50.234 per therm). x. Schedule 150 / Purchase Gas Cost - Demand Costs Demand costs reflect the cost of pipeline transportation to the Company's system, as well as fixed costs associated with natural gas storage. As shown in the table above, demand costs are expected to slightly increase for residential customers by approximately $0.00238 per therm. This increase is related to a variety of factors including Canadian exchange rate, updated demand forecast, and new rates for Canadian pipelines effective June 1, 2021. XI Schedule 155 / Amortization Rate Chanee As shown in the table above, the proposed amortization rate change for Schedule l0l and Schedule 1l I is an increase in revenue (or expiration of the existing rebate and replacing with a surcharge) of $0.05259 per therm. The current rate applicable to Schedule l0l and Schedule I I I is $0.03754 per therm in the rebate direction; the proposed rate is $0.01505 per therm in the surcharge direction. ln the 2020 PGA filing, the Company forecast a total amortization rebate to customers of approximately $3.4 million effective Novernber 1,2020. The forecast did not materialize as projected, resulting in an actual amortization surcharge balance of $0.7 million as of November 1,2020. From November 1,2020 through May 3 I , 2021 ,the surcharge balance has grown to $3.5 million as customers have been receiving a rebate amortization rate. In this PGA frling, the Company has used the deferral and amortizatron balances as of May 2021. T\e result is a surcharge amortization rate to collect approximately $4.4 million from customers. To reduce the impact on customer bills, the Company has proposed an amortization period of 38 months, instead of the normal l2-month period. The Company will re-evaluate the amortization period during the next PGA filing and adjust if deemed appropriate. On a per therm basis, the net impact of the expiring amortization rebate and the new amortization surcharge is a change in the amortization rate of $0.05259 per therm. xII. If approved as filed, the Company's annual revenue will increase by approximately $9.0 million or about 135% effective September 1,2021. Residential or small commercial customers using an average of 63 CaseNo. AVU-G-21-0 Page 4 of5 therms per month would see an increase of $6.00 per month, or approximately l2.lYo. The present bill for 63 therms is $49.49 while the proposed bill is $55.49. XIII Exhibit "D" attached hereto contains support workpapers for the Proposed Tariff Rates proposed by Applicant contained in Exhibit *Au.r xrv Avista requests that the rates proposed in this filing be approved to become effective on September 1, 2021, and requests that the matter be processed under the Commission's Modified Procedure rules through the use of written comments. Avista stands ready for immediate consideration on its Application. XV WHEREFORE, Avista requests the Commission issue its Order finding its proposed rates to be just, reasonable, and nondiscriminatory and to become effective for all natural gas service on and after September 1,2021. The overall increase is approximately $9.0 million or 13.5%o. The Companyrequests that the matter be processed under the Commission's Modified Procedure rules through the use of written comments. Dated at Spokane, Washington, this 2ndday of July 2021 AVISTA UTILITIES BY /s/ David J. Meyer David J. Meyer Vice President and Chief Counsel for Regulatory & Govemmental Afflairs Avista Corporation I Based on discussions with Commission Staff, the Company will provide directly to Commission Staffcapacity release detail as soon as it becomes available. Case No. AVLI-G-21-0 Page 5 of 5 AVISTA UTILITIES Case No. AVU-G-21-0r EXHIBIT "A" Proposed Tariff Sheets AVISTA CORPORATION d/b/a Avista Utilities SCHEDULE 150 PURCHASE GAS COST ADJUSTMENT. IDAHO APPLICABLE: To Customers in the State of ldaho where Company has natural gas service available. PURPOSE: To pass through changes in costs resulting from purchasing and transporting natural gas, to become effective as noted below. RATE: (a)The retail rates of firm gas Schedules 101, 111 and 112are to be increased by 29.548$ per therm in all blocks of these rate schedules. The rates of interruptible Schedules 131 and 132 are to be increased by 20.3050, per therm. (c)The rate for transportation under Schedule 146 is to be decreased by 0.0000 per therm. \A/EIGHTED AVERAGE GAS COST: The above rate changes are based on the following weighted average cost of gas per therm as of the effective date shown below:Demand Commodity Total Schedules 101 9.2430, 20.305f 29.5480, Schedules 111 and 112 9.2430, 20.3050 29.5480 Schedules 131 and 132 0.0000 20.3050, 20.3050, The above amounts include a gross revenue factor. Demand Commodity Total Schedules 101 9.203i, 20.217(, 29.420A Schedules 111 and 112 9.203i, 20.2170, 29.4200, Schedules 131 and 132 0.0000 20.2170, 20.217i, The above amounts do not include a gross revenue factor. BALANCING ACCOUNT: The Company wi!! maintain a Purchase Gas Adjustment (PGA) Balancing Account whereby monthly entries into this Balancing Account wil! be made to reflect differences between the actual purchased gas costs collected from customers and the actual purchased gas costs incurred by the Company. Those differences are then collected from or refunded to customers under Schedule 155 - Gas Rate Adjustment. (b) lssued July 2,2021 Effective September1,2021 l.P.U.C. No.27 lssued by By Twenty-Nineth Revision Sheet 150 Replacing Twe E hth Revision Sheet 150 150 Avista Utilities Patrick Ehrbar - Director of Regulatory Affairs AVISTA CORPORATION d/b/a Avista Utilities SCHEDULE 150 PURCHASE GAS COST ADJUSTMENT. IDAHO APPLICABLE: To Customers in the State of ldaho where Company has natural gas service available. PURPOSE: To pass through changes in costs resulting from purchasing and transporting natural gas, to become effective as noted below. RATE:(a) The retail rates of firm gas Schedules 101 , 1 1 1 and 112 are to be increased by 25*8,80 per therm in all blocks of these rate schedules. (b)The rates of interruptible Schedules 131 and 132 are to be increased by{W( pertherm. (c)The rate for transportation under Schedule 146 is to be decreased by 0.0000 per therm. \A/EIGHTED AVERAGE GAS COST: The above rate changes are based on the following weighted average cost of gas per therm as of the effective date shown below:Demand Commodity Total Schedules l0l Schedules lll and 112 Schedules 131 and 132 0.0000 W The above amounts include a gross revenue factor. Demand Commodity Total Schedules l0l Schedules lll and 112 Schedules 131 and 132 0.0001 W The above amounts do not include a gross revenue factor. BAI.ANCING ACCOUNT: The Company will maintain a Purchase Gas Adjustment (PGA) Balancing Account whereby monthly entries into this Balancing Account will be made to reflect differences between the actual purchased gas costs collected from customers and the actual purchased gas costs incurred by the Company. Those differences are then collected from or refunded to customers under Schedule 155 - Gas Rate Adjustment. Effective November 1,2020lssued June 30,2020 l.P.U.C. No.27 lssued by By Twenty-Eighth Revision Sheet 150 Replacing Revision Sheet 150 150 Utilities Patrick Ehrbar- Director of Regulatory Affairs AVISTA CORPORATION d/b/a Avista Utilities SCHEDULE 150 PURCHASE GAS COST ADJUSTMENT - IDAHO APPLICABLE: To Customers in the State of ldaho where Company has natural gas service available. PURPOSE: To pass through changes in costs resulting from purchasing and transporting naturalgas, to become effective as noted below. RATE: (a)The retai! rates of firm gas Schedules 101 , 1 1 1 and 112 are to be increased by 29.548$ per therm in al! blocks of these rate schedules. (b) The rates of interruptible Schedules 131 and 132 are to be increased by 20.3050, per therm, (c)The rate for transportation under Schedule 146 is to be decreased by 0.000/ per therm. WEIGHTED AVERAGE GAS COST: The above rate changes are based on the following weighted average cost of gas per therm as of the effective date shown below:Demand Commodity Total Schedules 101 9.243d, 203056 29.5486 Schedules 111 and 112 9.243d, 20.3056, 29.5486 Schedules 131 and 132 0.0000 20.305d 20.305d The above amounts include a gross revenue factor. Demand Commodity Total Schedules 101 9.203d, 20.2176, 29.420d, Schedules 111 and 112 9.2036 20.2176, 29.420d Schedules 131 and 132 0.000P 20.2176, 20.2176, The above amounts do not include a gross revenue factor. BALANCING ACCOUNT: The Company will maintain a Purchase Gas Adjustment (PGA) Balancing Account whereby monthly entries into this Balancing Account will be made to reflect differences between the actual purchased gas costs collected from customers and the actual purchased gas costs incurred by the Company. Those differences are then collected from or refunded to customers under Schedule 155 - Gas Rate Adjustment. lssued July 2,2021 Effective September 1,202'l LP.U.C. No.27 lssued by By Twenty-Nineth Revision Sheet 150 Replacing Revision Sheet 150 150 Avista Utilities Patrick Ehrbar - Director of Regulatory Affairs AVISTA CORPORATION d/b/a Avista Utilities SCHEDULE 155 GAS RATE ADJUSTMENT. IDAHO AVAILABLE: To Customers in the State of ldaho where Company has natural gas service available. PURPOSE: To adjust gas rates for amounts generated by the sources listed below. MONTHLY RATE:(a) The rates of firm gas Schedules 101 and 111 are to be increased by 1.5050 per therm in all blocks of these rate schedules.(b) The rate of interruptible gas Schedule 131 is to be decreased by 0.0000 per therm.(c) The rate of transportation gas Schedule 146 is to be decreased by 0.000d per therm. SOURCES OF MONTHLY RATE: Changes in the monthly rates above result from amounts which have been accumulated in the Purchase Gas Adjustment (PGA) Balancing Account as described in Schedule 150 - Purchase Gas Cost Adjustment. SPECIAL TERMS AND CONDITIONS: The above Monthly Rate is subject to the provisions of Tax Adjustment Schedule 158. Effective September1,2021lssued July 2,2021 LP.U.C. No.27 lssued by By Twenty-Third Revision Sheet 155 Canceling Second Revision Sheet 155 155 tit Patrick Ehrbar, Director of Regulatory Affairs AVISTA CORPORATION d/b/a Avista Utilities SCHEDULE 155 GAS RATE ADJUSTMENT - IDAHO AVAIHBLE: To Customers in the State of ldaho where Company has natural gas service available. PURPOSE: To adjust gas rates for amounts generated by the sources listed below. MONTHLY RATE:(a) The rates of firm gas Schedules 101 and 111 are to be deereased by W4 pertherm in all blocks of these rate schedules.(b) The rate of interruptible gas Schedule 131 is to be decreased by 0.0000 per therm.(c) The rate of transportation gas Schedule 146 is to be decreased by 0.0000 per therm. SOURCES OF MONTHLY RATE: Changes in the monthly rates above result from amounts which have been accumulated in the Purchase Gas Adjustment (PGA) Balancing Account as described in Schedule 150 - Purchase Gas Cost Adjustment. SPECIAL TERMS AND CONDITIONS: The above Monthly Rate is subject to the provisions of Tax Adjustment Schedule 158. lssued June 30,2020 Effective November 1, 2020 I.P.U.C. No.27 lssued by By Twenty-Second Revision Sheet 155 Canceling Revision Sheet 155 155 Avista Utilities Patrick Ehrbar, Director of Regulatory Affairs AVISTA CORPORATION d/b/a Avista Utilities SCHEDULE 155 GAS RATE ADJUSTMENT. IDAHO AVAILABLE: To Customers in the State of ldaho where Company has natural gas service available. PURPOSE: To adjust gas rates for amounts generated by the sources listed below. MONTHLY RATE:(a) The rates of firm gas Schedules 101 and 111 are to be increased by 1.505d per therm in all blocks of these rate schedules.(b) The rate of interruptible gas Schedule 131 is to be decreased by 0.0000 per therm.(c) The rate of transportation gas Schedule 146 is to be decreased by 0.0000 per therm. SOURCES OF MONTHLY RATE: Changes in the monthly rates above result from amounts which have been accumulated in the Purchase Gas Adjustment (PGA) Balancing Account as described in Schedule 150 - Purchase Gas Cost Adjustment. SPECIAL TERMS AND CONDITIONS: The above Monthly Rate is subject to the provisions of Tax Adjustment Schedule 1 58. lssued July 2,2021 Effective September 1,2021 l.P.U.C. No.27 lssued by By Twenty-Third Revision Sheet 155 Canceling Second Revision Sheet 155 155 Avista Utilities Patrick Ehrbar, Director of Regulatory Affairs AVISTA UTILITIES Case No. AVU-G-?I-0L DGIIBIT'OB" Notice of Public Applieant's Proposed Tariffs Important Notice for Idaho Customers DRAFT (July 2021) Avista has filed two rate adjustment requests with the Idaho Public Utilities Commission (Commission), that if approved, are designed to increase overall natural gas revenue by approximately $7.1 million or 10.6% effective Sept. 1,2021. These filings have no impact on Avista's earnings. The first adjustment is related to the annual Purchased Gas Cost Adjustment (PGA) filing. The PGA is filed each year to balance the actual cost of wholesale natural gas purchased by Avista to serve customers with the amount included in rates. This includes the natural gas commodity cost as well as the cost to transport natural gas on interstate pipelines to Avista's local distribution system. The increase is primarily driven by two factors: l) wholesale natural gas costs that are higher than the level presently included in rates, and 2) the expiration of a rebate customers are currently receiving from last year's PGA. If approved, Avista's request is designed to increase annual natural gas revenues by approximately $9.0 million or 13.5%. The second filing is the Deferred Balances Credit filing. This filing returns to customers deferred balances related to depreciation expense, Accumulated Funds Used During Construction (AFUDC), and CARES Act benefits. If approved, Avista's request is designed to decrease natural gas revenues by approximately $1.9 million or2.9Yo. These rate adjustment filings are separate and distinct from the Settlement Stipulation filed on June 14, 2021related to the pending general rate case filing, that, if approved, would reduce customer's natural gas bills by an overall 4.5Yo, also on Sept. I , 202 I . Customer Bills Natural Gas If the natural gas PGA and the Deferred Balances Credit filings are approved, residential natural gas customers in Idaho using an average of 63 therms per month would see their monthly bills increase from $49.49 to $54.05, an increase of $4.56 per month, or approximately 9.2%o. The proposed natural gas rate changes would be effective Sept. 1,2021. The net effect, on an annual revenue basis, for the requested natural gas rate changes by rate schedule are: General Service - Schedule l0l Large General Service - Schedules lll & ll2 Transportation Service - Schedule 146 Overall 9.2% 16.3% -2.9% 10.6% Rate Application Procedure The Company's applications are proposals, subject to public review and a Commission decision. Copies of the applications are available for public review at the offrces of both the Commission and Avista, and on the Commission's website (www.puc.idaho.eov). Customers may file with the Commission wriffen comments related to the Company's filings. Customers may also subscribe to the Commission's RSS feed (http://ww.rv.puc.idaho.gov/rssfeeds/rss.htm) to receive periodic updates via e-mail about the case. Copies of rate filings are also available on our website,www.myavista. com/rates If you would like to submit commmts on tfu proeosod ratc chmgg you cao do so by going to tbe Commissio,n website or mailing comments to: Idaho Public Utilitics Commission P.O. Box 83720 Boise, [D 83?2&m74 Avistaoffors anrmberofprograrns and services to hclp customcrs manage 6cir encqgruse and cosb. Visit www.myavista.com for information on these progrrms which irch& Comfort kvel Billing, bill palment options, nrtonrated palme,nt servicc, assistance progltrl$, cooscrvation tips, and encrgr cfficieocy rebotcs. AVAA74i DAVID J. MEYER VICE PRESIDENT AND CHIEF COUNSEL FOR REGULATORY & GOVERNMENTAL AFFAIRS AVISTA CORPORATION P.O.BOX3727 I4I I EAST MISSION AVENUE SPOKANE, WASHINGTON 99220-37 27 TELEPHONE: (509) 495-431 6 FACSIMILE: (509) 49s-88s I DAVTD.MEYER@AVr STACORP. COM BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF TTIE APPLICATION OF AVISTA CORPORATION FORA}I ORDER APPROVING A CTIANGE IN NATURAL GAS RATES AND CHARGES TO NATURAL GAS CUSTOMERS IN TIIE STATE OF IDAHO ) ) ) ) ) ) ) ) ) CASE NO. AW.G.2I.LIf ATTORNEY'S CERTIFICATE CLAIM OF CONFIDENTIALITY RELATING TO PORTIONS OF AVISTA'S EXHIBIT'S A}.{D WORKPAPERS 1 2 3 4 5 6 7 8 9 FOR AVISTA CORPORATION I, David J. Meyer, represent Avista Corporation. I am Vice President and Chief Counsel for Regulatory and Governmental Affairs for Avista Corporation (Avista or Company) and I am appearing on its behalf in this proceeding. I make this certification and claim of confidentiality pursuant to IDAPA 31.01.01 because Avista, through its supporting workpapers, is disclosing certain information that is CONFIDENTIAL and constitutes TRADE SECRETS as defined by Idaho Code Section 9-340 and 48-801 and protected under IDAPA 31.01.01.067 and 31.01.01.233. The electronic information Avista provides will, as required under IDAPA Rule 31.01.01 .067,be marked as CONFIDENTIAL on all documents. In accordance with Case No. GNR-U-20-01, Order No. 34602 which suspends the requirement to physically file documents due to the COVID-I9 Pandemic, the Company will file all work papers, tariffs, and exhibits only in electronic format. The confidential information that Avista is disclosing includes, but is not limited to certain forward wholesale natural gas pricing which is provided by a third-party vendor, who does not allow public access to their proprietary information. Avista herein asserts that the aforementioned information is confidential in that making third-party pricing data public will violate the terms of our agreement with the vendor. I am of the opinion that this information is CONFIDENTIAL, as defined by Idaho Code Sections 9-340D and 48-801, should therefore be protected from public inspection, examination and copying, and should be utilized only in accordance with the terms of the protective agreement between Avista Corporation and Parties who have requested such an agreement. 10 t_ l_ L2 1-3 1,4 L6 L7 t_8 1,9 20 2t l_5 22 23 ATTORNEY'S CERTIFICATE . I 1 2 3 4 5 6 7 RESPECTFULLY SUBMITTED this 2nd day of July 2021 /s/ DaidJ. Maw DavidJ" Meyer Vice Fresideot and Chief Co-unsel for Regulatory & Govmmental Affairs Avista Corporation ATTORNEY'S CERTIFICATE . 2