20230929Staff 1-4 to AVU.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )CASE NO.AVU-E-23-13
CORPERATION'S ANNUAL COMPLIANCE )FILING TO UPDATE THE LOAD AND GAS )CONFIDENTIAL FIRST
FORECASTS IN THE INCREMENTAL COST )PRODUCTION REQUESTOF
INTEGRATED RESOURCE PLAN AVOIDED )THE COMMISSION STAFF
COST MODEL TO BE USED FOR AVOIDED )TO AVISTA CORPORATION
COSTCALCULATIONS;)
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Avista Corporation d/b/a Avista Utilities
("Company")provide the followingdocuments and information as soon as possible,but no later
than FRIDAY,OCTOBER 20,2023.
This Production Request is to be considered as continuing,and the Company 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
telephonenumber of the record holder.
CONFIDENTIAL FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 SEPTEMBER 29,2023
RECEIVED
2023 September 29 9:40 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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.1:Page 2 of the Application states that the proposed load is the
Company's most recent peak and energy forecast,which was developed in the summer of 2022
and presented at the electric Integrated Resource Plan ("IRP")Technical Advisory Committee
meeting held on October 11,2022.However,this proposed load is the same as the load used in
last year's annual update case (Case No.AVU-E-22-15).Please respond to the following:
a.Has the Company developed a new load forecast as of the date that the Company
responded to this request and if not,when will a new load forecast be developed?
b.If a new load forecast has been developed,please provide the new load forecast;
c.If a new load forecast has been developed,please compare the new load forecast
with the proposed load forecast and explain the causes of the difference;and
d.If a new load forecast has not been developed,please explain why the Company
has not developeda new load forecast since the load forecast was developed for
case No.AVU-E-22-15.
REQUESTNO.2:Page 3 of the Application states that the proposed gas forecast is the
Company's most recent natural gas Forward Price Curve developed for the 2023 Natural Gas
IRP.However,this proposed gas forecast is the same as the gas forecast used in last year's
annual update case (Case No.AVU-E-22-15).Please respond to the following:
a.Has the Company developed a new gas forecast as of the date that the Company
responded to this request and if not,when will a new gas forecast be developed?
b.If a new gas forecast has been developed,please provide the new gas forecast;
c.If a new load forecast has been developed,please compare the new gas forecast
with the proposed gas forecast and explain the causes of the differences;and
d.If a new load forecast has not been developed,please explain why the Company
has not developed a new gas forecast since the forecast was developed for Case
No.AVU-E-22-15.
CONFIDENTIAL FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 SEPTEMBER 29,2023
REQUESTNO.3:Page 4 of the Application states that two PURPA contracts are
scheduled to conclude at the end of 2023,but they are currentlybeing negotiated for extensions.
Please describe the extension status of each project.
REQUESTNO.4:Please explain how Peak Contribution for each project is determined in
the Confidential Attachment file included in the Application.Also please answer the following:
a.If the Company uses the Western Resource Adequacy Program ("WRAP")
method to determine Peak Contribution,please provide the Peak Contribution of
each project based on the method used in the last load and natural gas annual
update case (AVU-E-22-15);
b.Please explain the difference between the two methods.If the Company does not
use the WRAP method,please explain why the Company does not use it in this
filing but uses it in the 2023 IRP;
c.Please explain why the Peak Contribution of seven Columbia Basin Hydro is
zero;and
d.Elf 1 Solar has a nameplate capacity of 19 MWand its Peak Contribution is 0.627
MW.Please explain how the Peak Contribution was calculated and why the
Company believes it is reasonable.
DATED at Boise,Idaho,this day of September 2023.
Michael Duval
Deputy AttorneyGeneral
i:umise:prodreq/AVU-E-23-13 PR#l
CONFIDENTIAL FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 SEPTEMBER 29,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF SEPTEMBER 2023,
SERVED THE FOREGOING CONFIDENTIAL FIRST PRODUCTION REQUESTOF
THE COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NO.AVU-E-
23-13,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
MICHAEL G.ANDREA SHAWN BONFIELD
SENIOR COUNSEL SR.MANAGER,REGULATORY POLICY
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE