20221103Staff 1-5 to Avista.pdf

MICHAEL DWAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. II7I4
IN THE MATTER OF AVISTA
CORPORATION'S AI\NUAL COMPLIANCE
FILING TO UPDATE THE LOAD AND GAS
FORECASTS IN THE INCREMENTAL COST
INTEGRATED RESOURCE PLAI\ AVOIDED
COST MODEL TO BE USED FOR AVOIDEI)
COST CALCULATIONS
cAsE NO. AVU-B,-22-ts
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA UTILITTES
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Street Address for Express Mail:
I 1331 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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Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Avista Utilities ("Company") provide the
following documents and information as soon as possible, but no later than THURSDAY,
NOVEMBER 17, 2022.r
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
I Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO AVISTA UTILITIES I NOVEMBER3,2022
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: The following table and graph compare Avista's 2021 energy
forecast in Case No. AVU-E-21-14 and Avista's 2022 energy forecast in this case:
2021 Energy Forecast
(aMW)
2022 Energy Forecast
(aMW)
2023 LILT tLtz
2024 LLLg.7 1119
2025 1122.3 tL22
2026 L125.3 tt27
2027 1128.8 7732
2028 tt32.8 1139
2029 1135.4 Lt44
2030 7737.5 7t49
2031 1139.5 1155
2032 Lt42 tt64
2033 1L43.3 ttTt
2034 7745.2 tt79
2035 tt47.t 1188
2036 1149.8 LL97
2037 7t5L.4 L206
2038 LLs3.7 L2L6
2039 7t56.2 L226
2040 1159.9 t238
2041 7162.6 L250
2042 1155.5 1263
2043 r171.2 1277
FIRST PRODUCTION REQUEST
TO AVISTA UTILITIES 1 NOVEMBER3,2022
Avista Energy Load Forecast
1300
1250
1200
015B
lB --t----'----
--- --o-
----------
1100
1000
20232024202s202620272028202920302031,203220332034203520362037 203820392040204720422043
too )Q)! Energy Forecast (aMW)
-2022
Energy Forecast (aMW)
a. Please provide a breakdown of the 2021 andthe2022 forecasts by customer class
(residential, commercial, and industrial, etc.) in Excel format.
b. Please explain the method and basis used to determine the2022 forecast for each
customer class.
c. Please explain why the 2022 energy forecast is growing more rapidly than the 2021
forecast. In the explanation, please identify the major drivers or causes for each
customer class affecting the change.
REQUEST NO. 2: Please respond to the following regarding the Public Utility
Regulatory Policies Act of 1978 ("PURPA") projects listed in the Excel file labeled:
"AVU-E-2 2- I 5 Attachment_A (Confi dential)_ I 0- 1 4- 22.xlsx ;'
a. Please explain how Expected Energy is calculated.
b. Please explain how Peak Contribution is determined for each project and what peak
timeframes Peak Contribution corresponds to.
c. Please explain how Expected Energy and Peak Contribution are used in calculating
the Integrated Resource Plan ("IRP-based") avoided cost rates.
REQUEST NO.3: Please respond to the following regarding the Chelan PUD contract
listed in the Excel file labeled: "AVU-E-22-15 Attachment A (Confidential)_10-14-22.xlsx;'
FIRST PRODUCTION REQUEST
TO AVISTA UTILITIES
10s0
J NOVEMBER3,2022
a. The nameplate capacity listed in the'Nameplate Capacity" column on Tab PPAs
does not match the nameplate capacity stated in the "Notes" column. Please reconcile
the difference and provide the most accurate amount.
b. Please explain how Peak Contribution is determined and provide the timeframe that
the Peak Contribution corresponds to.
c. Please explain how Expected Energy is calculated.
d. Please explain how Expected Energy and Peak Contribution are used in calculating
the lRP-based avoided cost rates.
REQUEST NO. 4: Order No. 33357 requires utilities to create a queue to track the order
in which QF projects have entered negotiations with a utility to ensure proposed prices
(indicative pricing in the IRP Methodology) are more accurate. Please respond to the following.
a. Please describe the types of projects in Avista's queue. Specifically, which of the
following are included:
o PURPA projects with contracts in negotiation
o Non-PURPA projects with contracts in negotiation
o PURPA projects with signed contracts but not yet Commission approved
o Non-PURPA projects with signed contracts but not yet Commission approved
o PURPA projects with Commission-approved contracts
b. Please describe in detail how Avista manages its queue. Specially, what criteria are
used to determine additions and removals of projects in the queue?
c. Please describe in detail how Avista determines the sequence of projects in the queue.
d. Please describe in detail how a QF's position in the queue determines its indicative
pricing.
REQUEST NO. 5: Please confirm that the final IRP-based avoided cost rates used in a
signed contract (not the initial indicative pricing) are determined based on projects approved by
the Commission at the time when the lRP-based contract is signed, which do not include
"projects in negotiation" or "projects with a signed contract but not yet Commission approved."
FIRST PRODUCTION REQUEST
TO AVISTA UTILTTIES 4 NOVEMBER3,2022
ADATED atBoise,Idatro, this 1 day ofNovember2A22.WtMiohasl Duval
Deprty Attorney General
iugiso:prodrcq/avue2. lSmdyy pmd rcq I
FIRST PRODUCTION REQIJEST
TO AVISTA UTILITIES 5 NOVEIUtsER3,2A22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF NOVEMBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO AVISTA UTILITIES, IN CASE NO. AVU-E-22-15, 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]
dockets@ avi stacorp.com
SHAWN BONFIELD
SR MGR., REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE W499220-3727
E-mail: [e-mail]
,b/L/.a'L
SECRETAY
CERTIFICATE OF SERVICE