20241101Staff 7-8 to AVU.pdf

RECEIVED
Friday, November 1, 2024 3.26.54 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 ) SECOND PRODUCTION
COST MODEL TO BE USED FOR AVOIDED ) REQUEST OF THE
COST CALCULATIONS ) 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 FRIDAY,NOVEMBER 15, 2024.1
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
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0318.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 1 NOVEMBER 1, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
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. 7: Please respond to the following regarding the proposed load forecast
for the period from 2025 through 2028:
a. 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 for the period from 2025
through 2028.
b. Specifically, what causes the initial difference between the two load forecasts in
2025?
c. Compared to the load forecast in Case No. AVU-E-23-13, if the load increase in this
case is due to customer additions, please provide a breakdown of customers by class
and by year of customer additions from 2025 through 2028.
REQUEST NO. 8: Response to Staff Production Request No. 6 states that the nameplate
of Clearwater is 60 MW within the context of the amount available to Avista as part of its
PURPA agreement, even though the overall nameplate of the generation facility is 132.2 MW.
Please respond to the following:
a. Does the PURPA agreement state the nameplate available to Avista is 60 MW? If so,
please provide the page number of the PURPA agreement that specifies the 60 MW.
b. If not, please explain how the 60 MW is determined.
DATED at Boise, Idaho, this 1st day of November 2024.
A am Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\AVU-E-24-10 PR#2.docx
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 2 NOVEMBER 1, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF OCTOBER 2024,
SERVED THE FOREGOING SECOND 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.andreagavistacorp.com E-mail: shawn.bonfieldgavistacorp.com
avistadockets&avistacorp.com
PATRICIA JORDAN S CRETARY
CERTIFICATE OF SERVICE