20211104Staff 1-2 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF AVISTA'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.2I.14
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
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Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 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,
Dayn Hardie, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than MONDAY,
NOVEMBER 15, 2021.1
This Production Request is to be considered as continuing, and Avista Corporation 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.
I Staff is requesting an expedited response after discussions with the Company. If responding by this date will be
problematic, please call Staff s attomey at (208) 334-12.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION I NOVEMBER 4,2021
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 identiff 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 on CD with formulas intact and enabled.
REQUEST NO. 1: Please answer the following questions regarding the load forecast in
CaseNo. AVU-E-21-14.
a. Please explain why the Company used last year's load forecast in Case No. AVU-
E-20-10 for this year's annual update.
b. Please confirm that last year's load forecast was developed in the summer of
2020.
c. If a newer load forecast has become available since Case No. AVU-E-20- I 0 was
submitted, please provide the data. If not, please explain why there is not a newer
load forecast available.
REQUEST NO. 2: Please answer the following questions regarding the natural gas
price forecast in Case No. AYU-E-21-14.
a. Please explain why the Company used last year's natural gas price forecast in
Case No. AVLI-E-20-10 for this year's annual update.
a. The Application in this case states that the Company's most recent Forward Price
Curve was developed using the blend of two national price forecasting
consultant's most recent forecasts, the U.S. Energy Information Administration's
Annual Energy Outlook, and forward market prices as of June 30,2020. Please
explain if these sources have updated their data since last year's update in AVU-
E-20-10.
b. Please provide the natural gas price forecast that has incorporated the latest
information from the four sources mentioned above.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 NOVEMBER 4,2021
,t{L| ' day of Nove,mber 2021.DATED atBoise, Idaho, this
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FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
Hardie
Attorney General
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3 NOVEh/BER 4, 2021
CERTTFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF NOVEMBER 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST TO AVISTA
CORPoRATION, IN CASE NO. AVU-E-2I-14, By E-MAILING A COpy THEREOF,
TO THE FOLLOWING:
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
[e-mail]
SHAWN BONFIELD
SR MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL: shawn .com
CERTIFICATE OF SERVICE