20230519Staff 1-3 to Avista.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
U \lIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )CORPORATION'S 2023 NATURAL GAS )CASE NO.AVU-G-23-03INTEGRATEDRESOURCEPLAN(IRP))
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Avista Corporation ("Company"or
"Avista")provide the followingdocuments and information as soon as possible,but no later than
FRIDAY,JUNE 9,2023.
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 informationproduced.
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 identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 MAY 19,2023
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.1:In reference to the Company's response to the 2021 IRP Action Item
number 2 discussed on page 9-4 of Avista's 2023 Natural Gas IRP,please respond to the
followingitems:
a.Please explain the Company's process to verify the PLEXOS initial model build
against Sendout;
b.Please provide any results obtained during the Company's verification process of
the PLEXOS initial model build against Sendout;
c.Please explain the Company's process to verify the climate policies and any other
additional functionalities used in PLEXOS are providing modeling results that
represent actual operations and implementation of policies;and
d.Please provide any results obtained during the Company's verification process of
climate policies and any other additional functionalities used in PLEXOS.
REQUESTNO.2:In reference to Figures 6.17 and 6.18 on page 6-23 of Avista's 2023
Natural Gas IRP,please explain the reason for the variability in energy demand shown in the
years 2023-2029.
REQUESTNO.3:Please provide results of the Company's Renewable Natural Gas
("RNG")Q4 2022 Requests For Proposal ("RFP").IRP at 4-16.Include a copy of the RFP,
selection criteria,and copies of submittals.
DATED at Boise,Idaho,this n day of May 2023.
Claire Sharp
Deputy Attorney General
i:umise:prodreq/avug23.3cskk prod req 1
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MAY 19,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF MAY 2023,SERVEDTHEFOREGOINGFIRSTPRODUCTIONREQUESTOFTHECOMMISSIONSTAFFTOAVISTACORPORATION,IN CASE NO.AVU-G-23-03,BY E-MAILINGACOPYTHEREOF,TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYERDIROFREGULATORYAFFAIRSVP&CHIEF COUNSELAVISTACORPORATIONAVISTACORPORATIONPOBOX3727POBOX3727SPOKANEWA99220-3727 SPOKANE WA 99220-3727E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
SECRE ARY
CERTIFICATEOF SERVICE