20211123_dh1.pdf

DECISION MEMORANDUM 1

DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF

FROM: DAYN HARDIE
DEPUTY ATTORNEY GENERAL

DATE: NOVEMBER 19, 2021

SUBJECT: IN THE MATTER OF AVISTA’S ANNUAL COMPLIANCE FILING TO
UPDATE THE LOAD AND GAS FORECASTS IN THE INCREMENTAL
COST INTEGRATED RESOURCE PLAN AVOIDED COST MODEL TO
BE USED FOR AVOIDED COST CALCULATIONS; CASE NO. AVU-E-21-
14.

On October 13, 2021, Avista Corporation (“Company”) filed a compliance filing
requesting the Commission issue an order accepting its updated load forecast, natural gas price
forecast, and contracts used as inputs to calculate its incremental cost Integrated Resource Plan
avoided cost rates, as required by Order Nos. 32697 and 32802. The Company requested its Filing
be processed by Modified Procedure.
On November 5, 2021, the Commission issued a Notice of Application and established
a November 26, 2021 public comment deadline and a December 3, 2021 Company reply deadline.
Order No. 35220.
BACKGROUND
The Company included the same load forecast submitted in last year’s Annual Load
and Natural Gas Forecast Update, Case No. AVU-E-20-10, with its Application. An updated load
forecast, along with the most recent natural gas forecast and updated contracts are used as an input
into the Company’s incremental cost integrated resource plan avoided cost model to ensure
accurate avoided cost rates for new PURPA contracts. Through production requests, Staff
discovered that the load forecast filed with the Application was the same forecast submitted in last
year’s filing but has developed a more recent load forecast. Staff also learned it was not submitted
DECISION MEMORANDUM 2

with the Company’s Application because the Annual Load and Natural Gas Forecast Update has
not been fully vetted through the Company’s internal processes.
Staff has discussed this with the Company, which requested additional time to review
the updated forecast before submitting it to the Commission. The Company has committed to
submitting it by December 3, 2021. Staff and the Company agree the procedural schedule should
be amended to allow additional time for the Company to provide the updated forecast. The Parties
agree an amended schedule will allow for a final order to issue before January 1, 2022.
STAFF RECOMMENDATION
Staff recommends that the Commission vacate the comment and Company reply
deadlines established in Order No. 35220 and issue a Notice of Amended Comment Deadlines
establishing a December 14, 2021 public comment deadline and December 21, 2021 Company
reply deadline.
COMMISSION DECISION
Does the Commission wish to vacate the comment and Company reply deadlines
established in Order No. 35220 and issue a Notice of Amended Comment Deadlines establishing
a December 14, 2021 public comment deadline and December 21, 2021 Company reply deadline?

Dayn Hardie
Deputy Attorney General

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