20181030Staff 1-7 to Avista.pdf

EDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5430
RilCEIVED
?018 OCT 30 Pt{ l: 59
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA CORPORATION
DBA AVISTA UTILITIES'2018 NATURAL GAS
INTEGRATED RESOURCE PLAN
CASE NO. AVU-G.18-05
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edith Pacillo, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than TUESDAY, NOVEMBER 20,
2018.
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.
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
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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1 ocToBER 30,2018
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the person preparing the documents. Please identify 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 and electronic files on CD with formulas activated.
REQUEST NO. 1: On page 96 of the Avista 2018 Natural Gas IRP, the Company
describes the Northwest Pipeline (NWP) system as being fully-contracted and states: "Capacity
expansions of these laterals would be lengthy and costly endeavors which Avista would likely
bear most of the incremental cost." Please describe what areas would potentially be impacted by
the Coeur d'Alene and Lewiston laterals and explain why Avista would "bear most of the cost"
for expansion. Additionally, please describe alternatives to lateral expansions on the NWP
system that the Company has considered.
REQUEST NO.2: On page 146 of the Avista 2018 Natural Gas IRP, the Company
describes use of a o'front line strategy" for transportation agreements. Please describe the
benefits and risks of a front line contracting strategy and to what extent this strategy is used.
REQUEST NO.3: Please provide an electronic copy of the eCommunity newsletter
sent by the Company on January 15, 2018.
REQUEST NO. 4: In the Company's 2016 IRP, targeted location conservation
programs were mentioned as a potential method to offset distribution system constraint areas. In
that case, Staff asked the Company to provide information about targeted location conservation
programs in Idaho. The Company responded that its Demand Side Management Group, Gas
Supply, and Gas Engineering teams would work together to determine projects for a pilot
program. Please provide a complete description of work done since the2016IRP to develop a
targeted location conservation pilot program.
REQUEST NO. 5: In the 2018 IRP, the Company suggests that targeted location
conservation programs might provide benefits to offset constraint areas and be an effective
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 ocToBER 30,2018
strategy. IRP at 173. Please describe the analysis of costs and benefits that would be used to
evaluate a targeted conservation program as a cost effective strategy.
REQUEST NO. 6: On page 7 of the Avista 2018 Natural Gas IRP, the Company states
that no resource deficiencies exist except under the High Growth and Low price scenario.
However, the Company shows several distribution resource projects will be required within the
planning horizon. Please explain how the Company considered DSM as a least-cost way to defer
or avoid the distribution projects listed in Table 8.1 of the Avista 2018 Natural Gas IRP. IRP at
t77.
REQUEST NO. 7: The 2018 IRP does not include any assumptions or costs for carbon
or other greenhouse gas emissions in Idaho. Most other utilities include a federal cost of carbon
or similar proxy at some point in the 2}-year planning horizon. Please explain why the
Company did not include this in its analysis.
DATED at Boise, Idaho, tfi, 7flry^yof October 2018
Edith Pacillo
Deputy Attomey General
i:umisc:prodreq/avug1 8.5epksk prod req 1
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION aJ ocroBER 30,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3OTH DAY OF OCTOBER 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTACORPORATION, IN CASE NO. AVU-G-18-05,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA99220-3727
E-MAIL: linda. gervais@,avi stacorp.com
avi stadockets@avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W A99220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE