20210608Staff 1-8 to Avista.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
I133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, tD 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION DBA AVISTA UTILITIES'
2021 NATURAL GAS INTEGRATED
RESOURCE PLAN
CASE NO. AVU-G-2I-02
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,
Dayn Hardie, Deputy Attorney General, requests that Avista Corporation provide the following
documents and information as soon as possible, but no later than TUESDAY! JUNE 29r2021.
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
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION
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I JUNE 8,2021
In addition to the written copies provided in response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: The Company states "In terms of North American demand, exports
of LNG could consume 20 Bcf per day by 2030 and more than 30 Bcf per day by 2040." IRP at
11. If this were to occur, please explain any impacts on the Company and what would be done to
minimize impacts on gas pricing and availability?
REQUEST NO. 2: Are DSM conservation savings in Appendix 3.1 current, with Idaho
cumulative savings shown as 21.4 million therms over 20 years? IRP ot I I Table .1.2. Please
provide and explain any updates or changes made in savings forecasts, if applicable.
REQUEST NO. 3: The Company's Action Plan includes investigating and integrating
new resource plan modeling software into Avista's system to run in parallel with Sendofi. IRP
at I2. Please answer the following.
a. Please explain why the system would be run in parallel with Sendout. Please
explain any benefits.
b. Describe the requirements of the new system and include business attributes and
compatibility with current systems, programs, and applications.
c. When is the new system expected to go live?
REQUEST NO. 4: The Company states; "One of the most prominent risks in the IRP
involves policies meant to decrease the use of natural gas as outlined in Chapter 5- Carbon
Reduction. However, there is uncertainty about the timing and size of those policy decisions."
IRP at 22. Please explain what is being done to quantit/ the uncertainty and mitigate this risk.
REQUEST NO. 5: The Company states; "In comparison to Avista's 2018 IRP, the base
forecast for customer growth decreases by nearly 1,400 new customers." IRP at 27. Please
explain why the base forecast changed.
FIRST PRODUCTION REQUEST
TO AVTSTA CORPORATION 2 JUNE 8,2021
REQUEST NO. 6: Regarding 346,667 Dth/Day firm resources at Jackson Prairie, the
Company states;'oThis number only indicates how much we can withdraw from the facility, as
transport on NWP is needed to move it from the facility itself." IRP at 76. Please explain how
transport on NWP works for natural gas stored at Jackson Prairie and provide the rights the
Company holds to move gas from the storage facility to the Company's system when required.
REQUEST NO. 7: The Company states; 'New legislation allows LDC's to invest in
RNG infrastructure projects with feedstock partners." IRP at 105. Please provide an explanation
and a copy of the legislation.
REQUEST NO. 8: In the 2018 IRP, the Company discussed a number of distribution
system enhancement projects. Please provide the current status and cost to date for the following
projects.
a. The Coeur d'Alene High Pressure Reinforcement - Post Falls Phase.
Construction on the project started in 2018 and includes installation of
approximately 14,600 feet of high-pressure steel gas main pipe from Rathdrum to
Post Falls at an estimated cost of $4,000,000.
b. The Schweitzer Mountain Road High Pressure Reinforcement. The Schweitzer
Mountain Road project is estimated to cost $1,500,000.
c. The Warden High Pressure Reinforcement. The Warden High Pressure
Reinforcements project is estimated to cost $6,000,000.
#DATED at Boise, Idaho, this day ofJune 2021
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Dayn Hardie
Deputy Affomey General
i:umisc:prodreq/avug2l.2dhkk prod req I
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION J JUNE 8,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8th DAY OF JUNE 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMIVIISSION
srAFF TO AYISTA CORPORATION, IN CASE NO. AVU-G-21-02, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
SHAWN BONFIELD
DAVID J MEYER
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
david.meyer@ avi stacorp.com
Y
CERTIFICATE OF SERVICE