20230828Staff 8 to AVU.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL p .c,
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA'S 2023 )CASE NO.AVU-E-23-05
ELECTRIC INTEGRATED RESOURCE PLAN.)
)SECOND PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Avista Corporation dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and information as soon as
possible,but no later than MONDAY,SEPTEMBER 18,2023.
This Production Request is to be considered as continuing,and Avista is requested to
provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION l AUGUST 28,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.8:In the 2023 natural gas IRP filing,Case No.AVU-G-23-05,the
Company included a national carbon tax on the cost of natural gas beginning in 2030.The 2023
electric IRP at 8-15 describes a similar tax but with a 33%chance of being implemented.
a.Please explain how the national carbon tax is modeled in the 2023 electric IRP and its
impact on the Preferred Resource Strategy;
b.Please explain the effect that the carbon tax has on each of the avoided cost value
streams presented in "Staff-PR-007 Attachment A"provided by the Company in
response to Production Request No.7;and
c.Please provide an updated version of "Staff-PR-007 Attachment A"that has the
impact of the described national carbon tax removed from the avoided costs.
DATED at Boise,Idaho,this Ÿ day of August 2023.
Chris Burdin
Deputy Attorney General
i:umise:prodreq/avue23.5cbme prod req 2
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 28,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF AUGUST 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-E-23-05,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:david.meyer avistacorp.com
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE