20201117Staff 9-10 to Avista.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-001 4
(208) 334-O3r4
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 BB USED FOR AVOIDED
COST CALCULATIONS
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Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. AVU.E.2O.lO
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
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 TUESDAY,
NOVEMBER 24,2020.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 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney
at [phone].
SECOND PRODUCTION REQUEST
TO AVISTA I NOVEMBER 17 ,2020
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.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. 9: The natural gas price forecast filed in this case uses a blend of
forward market prices, forecasts from U.S. Energy Information Administration (EIA)'s 2020
Annual Energy Outlook, and forecasts from two national consultants. This methodology was
discussed in the Company's second Technical Advisory Committee meeting on August 6,2020,
for the 2O2l Integrated Resource Plan (IRP). However, over the past IRPs such as the 2020 IRP
in AVU-E-19-01, Avista used a blend of forward market prices and forecasts from two national
consultants without using forecasts from EIA. Please explain why the Company added the EIA
forecast to the methodology.
REQUEST NO. 10: Please provide the difference in the resulting forecast without the
addition of the EIA forecast. Please provide the two forecasts and the difference in Excel format
with all formula enabled.
DATED at Boise,Idaho, this /7* day of November ZOZO.
Edward J
Deputy General
i:umisc:prodreq/avue20. I Oejyykk prod req2
SECOND PRODUCTION REQUEST
TO AVISTA NOVEMBER 17,2O2O2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ITth DAY OF NOVEMBER 2020,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSTON STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-20-10,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
POBO)(3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
avistadockets @ avi stacorp.com
ARY
CERTIFICATE OF SERVICE