20241003Staff 1-6 to AVU (Redacted).pdf

RECEIVED
Thursday, October 3, 2024 3:18:56 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S ANNUAL COMPLIANCE ) CASE NO.AVU-E-24-10
FILING TO UPDATE THE LOAD AND GAS )
FORECASTS IN THE INCREMENTAL COST )
INTEGRATED RESOURCE PLAN AVOIDED ) REDACTED FIRST
COST MODEL TO BE USED FOR AVOIDED ) PRODUCTION REQUEST OF
COST CALCULATIONS ) THE COMMISSION STAFF
TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Avista Corporation d/b/a Avista Utilities
("Company")provide the following documents and information as soon as possible, but no later
than THURSDAY, OCTOBER 24, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 OCTOBER 3, 2024

In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide the value of Year 2025 in the energy load forecast
and explain why it was not provided in the Company's Compliance Filing.
REQUEST NO. 2: In Case No. AVU-E-23-13, the approved load forecast used two
forecasting methods. For the period from 2024 through 2028, the Company utilized traditional
supply and demand econometric models. For the period from 2029 through 2045, the Company
used end-use forecasting methods. Please explain whether the Company uses the same
methodology to determine the proposed energy load forecast. If not, please explain the
methodology the Company used to determine the proposed energy load forecast in this case.
REQUEST NO. 3: Figure No. 1 below compared the proposed load forecast in this case
and the approved load forecast in Case No. AVU-E-23-13. Please explain why the proposed
load forecast in this case is consistently higher than the approved load forecast in Case No.
AVU-E-23-13.
Fip-ure No. l: Load Forecast Comparison
Load Forecast Comparison
1600
1400
1200
1000
800
600
400
200
0
tD r` W M 0 rV m V Ln t0 r\ oc 01 O .-+ N m d' Ln
N N N N M M M M M M M m M m 1t C V V V
O O O O O O O O O O O O O O O O O O O O
N N N N N N N N N N N N N rV N fV N N N fV
Proposed Load Forecast in Case No.AVU-E-24-10
Approved Load Forecast in Case No.AVU-E-23-13
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 OCTOBER 3, 2024

REQUEST NO. 4: Please provide the value of Year 2025 in the natural gas price
forecast and explain why it was not provided in the Company's Compliance Filing.
REQUEST NO. 5: The proposed natural gas price forecast in this case is the same as
the approved natural gas price forecast in Case No. AVU-E-23-13. Please explain why the
Company did not file an updated natural gas price forecast and provide justification as to why it
is reasonable to use the same natural gas price forecast in this case.
REQUEST NO. 6: The confidential attachment of the Compliance Filing listed the
nameplate capacity of Clearwater Paper as M W. However, Response to Staff Production
Request No. 2 in Case No. AVU-E-23-15 states that Clearwater's nameplate is 132.2 MW.
Please reconcile the two numbers and explain the cause for the difference.
DATED at Boise, Idaho, this 3rd day of October 2024.
Adam Triplett
Deputy Attorney General
1:\Utility\UMISCIPRDREQ\AVU-E-24-10 PR#1 Redacted.docx
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 OCTOBER 3, 2024

CERTIFICATE OF SERVICE
4
I HEREBY CERTIFY THAT I HAVE THIq /DAY OF OCTOBER 2024,
SERVED THE FOREGOING REDACTED FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-24- 10,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL G ANDREA SHAWN J BONFIELD
SENIOR COUNSEL SR MGR REGULATORY POLICY
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: michael.andrea 0vistacorp.com E-mail: shawn.bonfield i avistacorp.com
avistadockets(a),avistacpM.com
PATRICIA JORDAN, S&RETARY
CERTIFICATE OF SERVICE