20201029Staff 1-8 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10446
IN THE MATTER OF AVISTA
CORPORATION'S ANNUAL COMPLIANCE
FILING TO UPDATE THE LOAD AND GAS
FORECASTS IN THE INCREMENTAL COST
INTEGRATED RESOURCE PLAN AVOIDED
COST MODEL TO BE USED FOR AVOIDED
COST CALCULATIONS
CASE NO. AVU.E.2O.lO
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Avista Corporation (Company) provide
the following documents and information as soon as possible, or by FRIDAY,
NOVEMBER 13, 2020.r
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
I Staffis requesting an expedited response. Ifresponding by this date will be problematic, please call Staffs attorney
at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA ocToBER 29,2020I
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.u.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the date when the Company's peak and energy
forecast data used in the 2020Integrated Resource Plan in AVU-E-19-01 was developed.
RBQUEST NO.2: Please provide the Company's peak and energy forecast data used in
the2020Integrated Resource Plan in AVU-E-19-01 in the same format as Table 1 in the
Compliance Filing in AVU-E-20-10.
REQUEST NO.3: Please provide all changes that the Company has made to the peak
and energy forecast, ifany, fromthe one used in the 2O2Olntegrated Resource Plan in
AVU-E-19-01 to the one filed in AVU-E-2O-10, and explain why such changes were made.
REQUEST NO.4: Please provide the date when the Company's natural gas price
forecast data used in the 2020Integrated Resource Plan in AVU-E-19-01 was developed.
REQUEST NO.5: Please provide the Company's natural gas price forecast data used in
the2020 Integrated Resource Plan in AVU-E-19-01 in the same format as Table 2 in the
Compliance Filing in AVU-E-20-10.
REQUEST NO.6: Please provide all changes that the Company has made to the
natural gas price forecast, if any, from the one used in the Z02oIntegrated Resource Plan in
AVU-E-19-01 to the one filed in AVU-E-20-10, and explain why such changes were made.
REQUEST NO.7: On page 3 of the AVU-E-20-10 Compliance Filing, the Company
provides a Natural Gas Forecast with prices at Stanfield. Please explain why Stanfield was
specifically selected and used for this filing. Additionally, please explain why Stanfield was
FIRST PRODUCTION REQUEST
TO AVISTA ocroBER 29,20202
used in the Company's most recent natural gas Forward Price Curve and specifically discussed in
the Company's Z0}0lntegrated Resource Plan (for example, page 10-10).
REQUEST NO.8: Please identify factors that make it difficult to submit these update
filings earlier to allow processing prior to an October 15 effective date.
DATED at Boise,Idaho, this 29rH day of October 2020.
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Deputy General
i:umisc:prodreq/avue20. I Oejyykk prod reql
FIRST PRODUCTION REQUEST
TO AVISTA J ocToBER 29,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF OCTOBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
coMl\drssloN STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-20-I0,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
POBO)(3727
SPoKANE WA99220-3727
E-MAIL: michael.andrea@ avistacorp.com
avistadockets @ avistacorp.com
SECRETARY
CERTIFICATE OF SERVICE