20250724Comments.pdf

RECEIVED
July 24, 2025
Avista Corp. IDAHO PUBLIC
1411 East Mission P.O. Box 3727 UTILITIES COMMISSION
Spokane, Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
July 24, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
RE: Case No. GNR-E-25-01 — Avista's Comments on Staff s Application for Approval of an
RFP Oversight Process for the Acquisition of Large Supply-Side Electrical Resources
Dear Commission Secretary:
Avista Corporation, dba Avista Utilities (Avista or the Company), hereby submits the following
comments regarding Idaho Public Utilities Commission Staffs (Staff) application for approval of
an oversight process for the acquisition of large supply-side resources. The Company appreciates
the collaborative efforts of Staff throughout the development of this oversight process and the
opportunity to provide comments on this matter.
Avista generally supports the proposed principles and procedures proposed by Staff, as they
closely align with the methodology currently employed in the Copmany's resource acquisition
process. However, as a multi jurisdictional utility, Avista has identified potential areas of conflict
within the proposed language and the Company's other jurisdiction. Accordingly, the Company
offers the following comments for consideration:
GuidingPrinciples
rinciples
(2) The RFP selection process should be designed to select least-cost least-risk resources that
satisfy the system need. The selection process should avoid bias toward any other objectives unless
those objectives are clearly stated and convincingly justified.
Avista supports the identification and acquisition of least-cost, least-risk resources to meet
system-wide needs. However, the Company must also ensure that its resource planning and
procurement decisions remain consistent with the distinct regulatory requirements and
obligations of both Idaho and Washington State. While this principle provides flexibility by
allowing for additional objectives when they are "clearly stated and convincingly justified,"
Avista recommends modifying the principle to explicitly acknowledge the potential for

jurisdictional differences. This clarification would help ensure that multi jurisdictional utilities
can transparently incorporate state-specific requirements into their selection criteria without
conflicting with the overarching least-cost, least-risk framework.
Procedure
(1)(a)Standard Solicitation Process:
Prior to issuing the RFP, the Company must file an application with the Commission and
obtain approval. The application should include the RFP, the RFP Selection Plan, ' the RFP
Announcement Plan,2 and other documents relevant to the solicitation.
Washington State has prescriptive filing requirements that must be met prior to issuing an RFP,
including detailed pre-approval processes and timeline. Idaho's proposed requirement under
Section (1)(a) may result in procedural misalignment between jurisdictions. These differences in
approval timelines could create challenges in coordinating system-wide resource acquisitions in a
timely manner. Avista respectfully requests that the Commission provide flexibility in the Idaho
timeline to mitigate potential conflicts and ensure efficient and equitable resource procurement
across both states. The waiver process under Section (2) of the proposal may mitigate some of the
potential conflicts, however, it is not entirely clear.
Sincerely,
ls/S"
Shawn Bonfield
Sr. Manager of Regulatory Policy& Strategy
Shawn.bonfield(&,avistacorp.com
509-434-6502
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