20220706Reply Comments.pdf

Avista Corp.
141 I East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
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Jluly 6,2022
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A
Boise,Idaho 83714
RE: Case No. LVU-C,-22-01 - Avista Utilities Proposed Tariff Schedule 195 "Optional
Renewable Natural Gas"
Dear Ms. Noriyuki:
Avista Corporation dba Avista Utilities (Avista or the Company) provides the following reply
comments in Case No. AW-G-22-01, regarding Avista's proposed tariff Schedule 195 to offer
Idaho natural gas customers with an optional renewable natural gas (RNG) program. The
comments contained herein are in response to the comments filed by Commission Staff on June
23,2022.
Avista would like to thank Staff for their thorough analysis and recommended approval of the
Company's proposed Optional Renewable Natural Gas tariffschedule. The Company supports the
tariff changes and annual reporting recommendation proposed by Staff and will submit updated
tariffsheets upon approval of its Option RNG program. Avista proposes that the annual reports be
provided by April30ft of each year.
In response to Staffs concems pertaining to the adoption of the M-RETS system and use of
Renewable Thermal Certificates (RTCs), the Company would like to clarifu that it does have
processes in place to verifr the RNG and corresponding RTCs are transferred from PSE to Avista
when an RNG purchase is made. Gas Schedulers will purchase appropriate amounts of RNG to
support the customers enrolled in its Optional RNG Program. Once the purchase is made the RTCs
(for each dth of gas purchased) will be transferred to Avista's MRETs account upon delivery of
the RNG. The Gas Scheduler will then veriff the RTCs have been tansferred from PSE to Avista,
ensuring that no other party is utilizing the same RTCs or being used under any other greenhouse
gas reduction program.
In its comments, Staff notes that the Company has 69 customer enrollments in its Optional RNG
program to date. As of June 21,2022, Avista has a total of 517 customers enrolled in its Optional
RNG prograrn with 378 enrollnents in Washington and 139 in Oregon. Avista is confident that
the growing interest in the program in both Washington and Oregon will also be reflective of its
customers in Idaho.
Please direct any questions regarding these comments to Amanda Ghering at
amanda. [e-mail] or 509-495-7950.
Sincerely,
lolstarrn &a$ldd
Shawn Bonfield
Sr. Manager of Regulatory Policy & Stategy
Avista Utilities
509-495-2782
shawn.bonfi eld@avistacom. com
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