20080117Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 6864
C i:1 L.
JAN I 7 Pi, 2= 0 I
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING BY A VISTA' )
CORPORATION DBA A VISTA UTILITIES OF )
ITS 2007 INTEGRA TED RESOURCE PLAN )(IRP). )
)
)
CASE NO. A VU-E-07-8
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through it Attorney of Record,
Neil Price, Deputy Attorney General, in response to the Notice of Filing and Notice of Modified
Procedure, issued on November 21,2007, Order No. 30464, submits the following comments.
BACKGROUND
On August 30,2007, Avista Corporation dba Avista Utilties (Avista; Company) fied its
2007 Integrated Resource Plan (IRP; Plan) with the Commission pursuant to the biennial filing
requirement mandated in Order No. 22299, as modified in Order No. 30262. The IRP describes
the Company's growing customer base, load growth, supply-side resources, demand-side
management and risk analyses. Additionally, the IRP document and related appendices contain
information regarding available resource options, planning period forecasts, potential resource
portfolios, a ten-year resource plan, and a near-term action plan.
STAFF COMMENTS 1 JANUARY 17,2008
STAFF ANALYSIS
Load Forecasts
In general, capacity deficiencies drive Avista's resource needs. Avista currently has
sufficient capacity resources, due primarly to the relatively large amount of hydroelectric
generation in its resource portfolio. However, capacity deficits begin in 2011 with the Company
being short by 146 MW. The deficits continue to grow as peakng requirements increase with load
growth, and the Company's resource base declines due to the expiration of market purchases and
reductions in power from Mid-Columbia hydroelectric project contracts. Peak loads are expected
to grow at 2.4 percent over the next 10 years and 2.1 percent over the entire 20-year forecast. For
the most par, future capacity requirements will be met through the acquisition of new resources,
which provide both capacity and energy. Table 1 presents the Company's net position forecast
during the first 10 years of the study.
Table 1: Net Position Forecast
Net Position 2008 2009 2010 2011 2012 2015 2017 2020 2027
Energy (aMW)121 79 33 -83 -170 -228 -272 -341 -513
Capacity (MW)148 94 5 -146 -251 -357 -300 -530 -835
As a general guideline, the anual energy position is used to determine when the Company
needs to acquire additional base-load energy resources. Avista estimates that it will experience
system-wide anual energy deficits beginning in 2011, with loads exceeding resource capabilties
by 83 average megawatts (aMW) and rising to 272 aMW in 2017 and to 513 aMW in 2027.
A vista attributes the energy resource deficits to an estimated 2.3 percent energy and capacity load
growth through 2017 and the expiration of certain long-term supply contracts.
On a monthly basis, A vista expects to encounter energy deficits during some months in all
years of the forecast. In 2008, for example, the Company position is deficit in January and
October even though the anual position is surplus by 121 aMW. In other months, paricularly
during spring ruoff, A vista is in a surlus position. As usual, the Company plans to balance its
monthly positions through short-term market purchases or sales, exchanges or other arangements.
However, over the long-term, the Company's strategy is not to rely on long-term market purchases
to serve future base load requirements.
STAFF COMMENTS 2 JANUARY 17,2008
Staff believes that the load forecast prepared and used by A vista for its 2007 IRP is
reasonable. In addition to considering a base case forecast, "high" and "low" economic forecasts
were also prepared to evaluate plausible changes in load due to population change within the
Company's existing service area.
Demand Side Management and Supply Side Effciency
A vista plans to increase its acquisition of demand side management (DSM) electrical
energy approximately 25 percent over the Company's 2005 IRP and by more than 85 percent from
its 2003 IRP. As the costs of other generation alternatives rise, more DSM becomes cost effective.
Additionally, the 2007 IRP recognizes other factors for the first time that increase the value of this
resource; namely capacity value, risk reduction, transmission and distribution savings. These
additional factors are inherent in the selection of supply-side resources. The application of new
analytical techniques enables the Company to assign values for these benefits.
Avista's past DSM efforts have decreased its electrical energy requirements by nearly 100
aMW since programs began in the late 1970s. With additional fuding recommended by the IRP
and through a conservation and energy effciency initiative called the "Heritage Project," the
Company expects its future conservation to lower its projected load growth 87 aMW by 2017.
The Heritage Project is intended to build on the Company's long-time commitment to energy
conservation and efficiency, introducing new products and services to decrease its customers'
peak demands as well as their energy use.
Staff appreciates Avista's long-held and continuing commitment to helping its customers
reduce their bils through cost-effective demand side management. Staff further appreciates that
A vista does not limit its review and recalculation of DSM resource potential to the biennial IRP
process and, instead, is continually searching for ways to cost-effectively help customers use
energy more effciently. It is obvious, as stated in the IRP, that as future estimated supply costs
and risks increase, the potential for DSM to cost-effectively supplant the need for those resources
also increases. Staff believes Avista's approach to identifying and updating DSM potential is
governed by sound research and well-reasoned principles.
However, Staff notes that throughout the IRP, Avista references only the total resource
cost test (TRC) for evaluating cost-effective DSM potentiaL. Historically, the TRC test is but one
of the four cost-effectiveness tests that A vista has used to plan and evaluate DSM. The others are
STAFF COMMENTS 3 JANUARY 17,2008
the utilty cost test (UCT), paricipant test, and ratepayer impact test (RIM). Avista has informed
the Staff that it has not abandoned, and is not planing to abandon, the other cost-effectiveness
tests and that these tests are, in fact, considered in development of Avista's more detailed business
plan. Nevertheless, in recognition that some entities do rely almost exclusively upon the TRC test,
we caution against a possible over-reliance upon the TRC. The TRC is a good test, but by itself it
is not sufficient for evaluating maximum, long-term, cost-effective DSM for a utility's entire
customer base and equitable treatment among customers. For example, because the TRC test does
not include incentive payments made by a utilty to its customers as a resource cost, over reliance
on this test can result in perverse and inequitable DSM programs.
The IRP also identifies five planed and potential efficiency upgrades to four hydro-
generation facilties. If all five of the upgrades are completed, the result wil be a 38.4 MW
(5.9%) generating capacity increase.
Preferred Resource Strategy
A vista's Preferred Resource Strategy (PRS) provides direction and guidance for resource
acquisitions over the 20-year IRP planning horizon. The 2007 PRS primarily includes gas-fired
generation, wind generation, and other small renewables. It also includes a significant increase in
conservation acquisition from today's levels. The specific resources contained within the PRS for
the 2007 IRP, in cumulative nameplate capabilty, are shown in Table 2.
Table 2: 2007 Preferred Resource Strategy Selections (Cumulative Nameplate MW)
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
CCCT 0 0 0 280 280 280 350 350 350 350
Coal 0 0 0 0 0 0 0 0 0 0
Wind 0 0 0 0 0 0 100 100 200 300
Other Renewables 0 0 0 20 30 30 35 35 35 35
Conservation 6 13 20 27 36 46 56 66 76 87
Total 6 13 20 327 346 356 541 551 661 772
Selection of the PRS considered generation, transmission and emissions costs for the
various alternatives. The PRS strikes a reasonable balance between keeping average costs and
STAFF COMMENTS 4 JANUARY 17,2008
variation in year-to-year costs low. The PRS requires between $1.0 and $1.5 bilion in new
investments over the next 10 years.
Differences from the 2005 IRP
One of the most significant differences between the 2005 and 2007 IRPs is that the coal-
fired generation in previous plans is replaced entirely with fixed price natural gas-fired resources.
Recent legislation in Washington (Senate Bil 6001; Executive Order No. 07-02 (Washington
Climate Change Challenge)), prevents utilties from entering into any long-term financial
commitment for resources that exceed a greenhouse gas emissions performance standard of 1,100
IbsIMWh. The legislation provides for the stadard to be lowered even further after 2012. The
emission performance standard effectively precludes A vista from acquiring any new pulverized
coal plant or a long-term contract with an existing one. IGCC (Integrated Gasification Combined
Cycle) plants might be able to meet emission stadards, but only with carbon sequestration. So
far, however, carbon sequestration technology is yet to be proven and suitable sites have not been
identified.
In addition to Washington legislation, the Western Regional Climate Action Initiative
signed by the governors of five Western states seeks to decrease greenhouse gas (GHG) emissions,
increase employment levels in green energy resources, reduce fuel imports and increase overall
renewable generation levels. Oregon has similar renewable and emissions goals and laws in place
or in development. Other states throughout the Western Interconnect are also developing or have
already enacted GHG reductions and renewable portfolio standards. Finally, federal carbon
limiting legislation is also becoming an increasing possibilty. Although Idaho curently has no
carbon emission standard or renewables portfolio stadard, the mandates and requirements being
implemented in surounding states and possibly at the federal level limit coal from being a viable
option for new generation to serve Idaho loads.
A second reason that A vista has removed coal from its Preferred Resource Strategy is
because of higher costs associated with coal-fired generation. A vista, in a j oint study with Idao
Power, investigated options for new coal-fired generation. One of the findings of the study was
that coal plants are projected to cost much more than had previously been estimated. The higher
cost estimates make coal-fired generation less competitive with other generation alternatives.
STAFF COMMENTS 5 JANUARY 17,2008
Another significant difference between the 2005 and 2007 IRPs is that the 2007 IRP
includes fewer renewables. The expected contribution of renewable resources over the first 10
years of the plan has been reduced from 500 MW in the 2005 plan to below 350 MW (300 MW
wind) in this plan. The Company states that the cost of wind resources has increased more than
100 percent over the past six years and more than 50 percent since the 2005 IRP. In addition,
recent legislation in Washington, Oregon and throughout the West requiring the use of renewable
resources has increased the demand for these resources and contributed to increasing their costs.
Other renewable technologies, including geothermal and biomass, were slated in the 2005 plan to
make up nearly 80 MW, but now total only 35 MW by 2017 in the 2007 plan.
A vista currently serves approximately one-half of customer requirements with renewable
resources (hydro, wind and biomass), and these resources will meet 40 percent of the Company's
load obligations in 2017. However, new legislation passed in November 2006 (Washington
Energy Independence Act, Initiative 937; 1-937) requires larger utilties in Washington to serve 15
percent of retail load with renewables by 2020. Unfortunately, only a small portion of Avista's
curent renewable resource portfolio qualifies under 1-937. Consequently, to ensure compliance, it
is likely that renewable resources wil need to be acquired regardless of physical resource balance.
Obtaining resources in an environment with significant competition has already resulted in a
scramble to obtain the best resources, A vista states. The Company wil consider turney or power
purchase agreements, as well as investing in potential renewable energy sites for future
development. A vista will also consider purchasing qualifying renewable energy credits to meet its
statutory obligations.
Return to Gas-Fired Generation
Avista moved away from natural gas-fired resources in its 2005 IRP because of the fuel's
inherent price volatility. In addition, natural gas prices rose drastically between the 2003 and 2005
plans. Compared to other resource options, namely traditional coal-fired resources, natural gas
became both costly and volatile. Because wind and other renewables were expected to be cost
effective and reasonably plentiful, natural gas was not selected in the 2005 plan. A vista believes
that conditions are different today, however.
As discussed previously, Avista has eliminated coal-fired generation completely, and there
are fewer cost effective renewables in the 2007 IRP. Except for increasing its DSM efforts, one of
STAFF COMMENTS 6 JANUARY 17,2008
the only viable options left is to retur to plans to acquire natural gas-fired generation. The 2007
Preferred Resource Strategy includes nearly 350 MW of natural gas-fired combined cycle plants in
the first 10 years.
Natural gas-fired plant costs have not risen as significantly as other options. Rising capital
costs make gas-fired generation more attractive because it is a less capital-intensive resource than
coal, wind or other renewable options. A vista contends that gas represents a comparatively more
attactive resource today than it was in 2005, even absent changing social policies.
Staff recognizes the increasingly limited resource choices available for new generation due
to increasing costs of coal and renewables, not to mention new legislation limiting emissions.
However, we also recognize that increasing reliance on gas-fired generation introduces additional
volatilty into the Company's portfolio. Because of the increased risk and volatilty associated
with gas, Staff believes it is extremely important for A vista to continue to explore options to
minimize gas price risk and volatilty.
Risk Analysis
A vista made considerable analytical effort to evaluate the Preferred Resource Strategy
against several alternative strategies under various scenarios of load, hydro conditions, emissions
charges, wind generation and fuel prices. In addition, scenarios were investigated that included
availabilty of nuclear plants beginning in 2015, and an influx in the use of electric cars. Overall,
the Preferred Resource Strategy performed well, both in the Base Case and under numerous
scenarios. The chosen combination of resources provides for a significant reduction of risk at a
very modest impact to expected costs.
Staff believes that the Company's risk analysis was rigorous and thorough, and that a
reasonable range of risks and scenarios were considered. Staff concurs that the Preferred
Resource Strategy selected by the Company is superior to the other resource strategies considered
in the IRP.
Lancaster
Avista anounced the sale of its energy marketing company, Avista Energy, in April 2007.
It subsequently anounced that Avista Energy's contract for the Lancaster Generation Facilty
output is available to the utilty beginning in 2010. The Lancaster Generation Facilty is a 245
MW gas-fired combined-cycle combustion turbine with an additional 30 MW of duct firing
STAFF COMMENTS 7 JANUARY 17,2008
capability. It began commercial service in 2001. The plant is located in Rathdr, Idaho, in the
center of Avista's service territory.
The Preferred Resource Strategy, as detailed earlier, includes 350 MW of natural gas-fired
generation over its first 10 years. Because Lancaster is the same technology and available in
approximately the same timeframe as the 280 MW gas-fired combined cycle resource identified in
the PRS for acquisition in 2011, A vista recently completed preliminar analysis to determine
whether Lancaster is a potentially cost effective resource to meet customer load requirements. It
appears that the facilty is significantly lower in cost than a green field plant. As a result, the
Table 3: Net Position Forecast with Lancaster
Net Position 2008 2009 2010 2011 2012 2015 2017
Energy (aMW)121 79 288 181 79 37 -8
Capacity (MW)148 94 280 129 24 -82 -25
Lancaster plant is assumed to replace a significant portion of the gas-fired CCCT plant included in
the PRS. With Lancaster, resource deficits are pushed back to 2014, with loads exceeding
resource capabilty by 49 MW. Table 3 presents the Company's net position with the inclusion of
Lancaster, but without other resources in the Preferred Resource Strategy.
To date, A vista has not sought Commission approval of a contract for output from the
Lancaster facilty. Once Avista seeks to recover costs associated with purchases from the project,
Staff expects to review whether purchase of the plant output by A vista is reasonable compared to
other alternatives. Staff wil also consider ratemaking treatment for purchases made in advance of
need.
Lowering Volatilty with Long-Term Fixed Price Gas
As discussed previously, coal-fired generation that comprised a significant portion of
Avista's PRS mix in prior IRPs has been entirely replaced by gas-fired generation in the 2007 IRP.
Coal-fired plants provide a hedge against volatile electricity and natual gas prices because so
much of their costs are fixed through large capital investments. Variable operating and fuel costs
at a coal plant are modest compared to gas-fired resources. A resource profie containing coal
contributes to stable power supply expenses.
STAFF COMMENTS 8 JANUARY 17,2008
Natural gas plants, by comparison, are far less expensive to build, but have much higher
and more volatile fuel costs over their lifetime. Utilty portolios with large concentrations of gas-
fired generation can cause highly volatile electric prices. As more utilties tu to gas-fired
generation in order to meet greenhouse gas regulations, the demand and cost of natural gas is
bound to increase and become even more volatile.
In the 2007 IRP, A vista began exploring the possibilty of locking in natural gas costs in
order to make a gas-fired combined cycle combustion turbine (CCCT) cost structure behave
financially like a coal-fired resource, therefore reducing price volatilty. Avista suggests that this
might be accomplished through a long-term fixed price contract, an investment in a pipeline-
quality coal gasification plant, an investment in gas fields or through other means. Varable costs
are much less volatile, the Company contends, because a significant portion of its largest variable
component-gas fuel-is not tied to the natural gas market. In both high and low gas market
conditions the price paid by customers is the same. Although fixing gas prices does not lower
absolute cost over the long term, it can effectively limit price volatilty.
Staff is intrigued by the idea of acquiring long-term fixed price gas as a means to reduce
price volatilty, and believes the concept should be fuher studied. More investigation needs to be
done to determine whether gas suppliers are wiling to lock-in long-term prices, and whether the
other mechanisms identified by the Company are, in fact, viable and cost effective. As gas-fired
generation is relied upon more heavily in the future, controllng price volatilty wil become
extremely important.
General Comments
In the past, integrated resource planing entailed assessing the utilty's timing and need for
new resources, identifying various options for new generation and conservation, evaluating the
risks of various alternatives and building a resource portfolio reflecting the least cost, least risk
combination of resources. Nearly all options were open to consideration, restricted only by their
costs, risks and availabilty. Today, however, planing is constrained by an increasingly limited
menu of options due to enactment of new laws imposing emission performance standards on fossil
fueled generation resources acquired by electric utilties in Washington, Oregon, California and,
perhaps soon, nationwide. In addition, many states are implementing renewable portfolio
STAFF COMMENTS 9 JANUARY 17,2008
standards that require specific amounts of renewable generation in the future, irrespective of
whether they are least cost.
Ironically, Idaho presently has neither carbon emission standards nor renewable portfolio
stadards, yet the new legislation in other states has effectively limited the new generation choices
for serving Idaho's loads. Multi-jurisdictional utilties, like Avista, must meet the requirements in
all states in which they serve, and it is impractical to develop new generation projects devoted
solely to serve Idaho loads, particularly when some new generation, like coal-fired plants, are
likely to require the joint paricipation of multiple utilties and customers in multiple states.
In the beginning of this decade, gas-fired generation seemed to be the resource of choice.
Gas-fired plants were relatively easy to permit, relatively cheap to build, relatively quick to bring
online, and perceived as environmentally friendly. However, when gas prices skyrocketed in
2000-2001, utilties and customers became painfully aware of the costs and potential volatilty of
gas-fired generation. Moreover, competition for gas to generate electricity raised cost for other
natual gas end uses.
For a brief period of time, coal-fired generation emerged as the new resource of choice due
to its cost certainty, low fuel cost and its ability to moderate prices. In just the past year, however,
plans for numerous coal-fired projects have been scrapped across the country. The planing
questions associated with coal have quickly evolved from "How much will it cost to pay carbon
taxes?" to "Can the plant be built at all, given existing or potential greenhouse gas legislation?"
Many other utilties besides A vista, including Idaho Power and PacifiCorp, have also dropped
coal-fired generation from their integrated resource plans.
With concerns being raised about emissions from pulverized coal plants, IGCC captured
the attention of many due to its promises of lower emissions and its potential for futue capture
and sequestration of C02. Recently, however, there seems to be increasing recognition that IGCC
technology must be fuher developed and mature, and that it may not be a realistic alternative in
the near term. In addition, some states have required that proposed IGCC plants be able to capture
and sequester C02 from the day they sta operating, not simply to promise to have that capabilty
at some future date.
Restrictions on building traditional coal-fired generation, the uncertainties surrounding
IGCC, and the fuel price risk associated with natual gas have changed the planing process.
Outside factors, other than cost, risk and availabilty of resources, now dictate the choices
STAFF COMMENTS 10 JANUARY 17,2008
available to the utilty. In this new planing environment, Staff believes it wil be important for
utilties to maximize acquisition of cost effective DSM, fully exploit renewable generation
options, and continue to closely monitor advances in fossil-fuel generation technology. In
addition, utilties should begin to seriously examine nuclear energy as a potential long-term
option. Finally, Staff believes it is imperative that utilties devise and pursue methods to reduce
the volatilty associated with gas-fired generation, as it becomes a larger part of the portfolio.
2007 IRP Action Plan
Avista's IRP contains the Company's 2007 Action Plan as well as its assessment regarding
its progress toward implementing its 2005 IRP Action Plan. The 2007 Action Plan contains
activities and studies to be developed and studied in the Company's 2009 IRP. It includes specific
items in four areas: renewable energy and emissions, modeling enhancements, transmission
modeling and research and conservation.
Significant 2007 Action Plan items are listed below.
Renewable Energy
. Continue studying wind potential in the Company's service territory, possibly including
the placement of anemometers at the most promising wind sites.
. Commission a study of Montana wind resources that are strategically located near existing
Company transmission assets.
. Lear more about non-wind renewable resources to satisfy renewable portfolio stadard
requirements and decrease the Company's carbon footprint.
Demand Side Management
. Update processes and protocols for integrating energy efficiency programs into the IRP to
improve and streamline the process.
. Study and quantify transmission and distribution system effciency concepts.
. Determine the potential impacts and costs of load management options curently being
reviewed as par of the Heritage Project.
. Develop and quantify the long-term impacts of the newly signed contractual relationship
with the Northwest Sustainable Energy for Economic Development organization.
Emissions
. Continue to evaluate the implications of new rules and regulations affecting power plant
operations, most notably greenhouse gases.
. Continue to evaluate the merits of various carbon quantification methods and emissions
markets.
STAFF COMMENTS 11 JANUARY 17,2008
Modeling and Forecasting Enhancements
· Study the potential for fixing natual gas prices through financial instrents, coal
gasification, investments in gas fields or other means.
· Continue studying the efficient frontier modeling approach to identify more and better uses
for its information.
. Furher enhance and refine the PRiSM LP modeL.
. Continue to study the impact of climate on the load forecast.
· Monitor the following conditions relevant to the load forecast: large commercial load
additions, Shoshone county mining developments and the market penetration of electric
cars.
Transmission Planning
· Work to maintain/retain existing transmission rights on the Company's transmission
system, under applicable FERC policies, for transmission service to bundled retail native
load.
. Continue involvement in BP A transmission practice processes and rate proceedings to
minimize costs of integrating existing resources outside of the Company's service area.
· Continue paricipation in regional and sub-regional efforts to establish new regional
transmission structures (Columbia Grid and other forus) to faciltate long-term expansion
of the regional transmission system.
· Evaluate costs to integrate new resources across Avista's service territory and from regions
outside of the Northwest.
The 2007 Action Plan, Staff believes, is a reasonable set of actions that will allow A vista
to continue to meet its load obligations cost effectively, while also supporting the preferred
resource strategy identified in the IRP and improving the planing process going forward.
STAFF RECOMMENDATIONS
Avista's load-resource balance indicates both capacity and energy deficits beginning in
2011. The Company's Preferred Resource Strategy includes 350 MW of gas-fired generation in
its first 10 years. Because output from the Lancaster gas-fired combined cycle plant is available in
approximately the same time frame as needed by A vista, it intends to secure the output from this
plant. By adding Lancaster to its portfolio, acquiring additional renewables and increasing its
DSM efforts, A vista will extend to 2014 its need for other new resources.
While there will be no need for major new resource additions until 2015, however, Staff
believes that A vista should be mindful of the volatilty associated with increased reliance on
natural gas. Staff recommends that the Company continue to investigate tactics to reduce
volatilty. In addition, Staff recommends that the cost and availabilty of renew abIes resources be
STAFF COMMENTS 12 JANUARY 17,2008
closely monitored. Despite its current higher costs and despite emission restrictions, Staff believes
A vista should closely follow advances in clean coal technology. Nuclear energy should also be
seriously investigated in futue IRPs.
In summary, Staff believes that Avista has done a good job in assessing its load-resource
conditions, incorporating demand-side management, evaluating new resource alternatives,
analyzing risk and in selecting a reasonable portfolio of new resources.
Staff recommends that Avista's 2007 IRP be accepted and acknowledged.
Respectfully submitted this ~ day of Januar 2008.;.
l)~
Deputy Attorney General
Technical Staff: Rick Sterling
Lynn Anderson
i :umisc: commentsavue07 .8nprps
STAFF COMMENTS 13 JANUARY 17,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF JANUARY 2008,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. AVU-E-07-8, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
CLINT KALICH, MANAGER
RESOURCE PLANING & ANALYSIS
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
EMAIL: clintkalich(iavistacorp.com
LINDA GERV AIS
REGULATORY COMPLIANCE
AVISTA CORPORATION
1411 E MISSION AVE
SPOKANE WA 99220
~.\(0ç
SECRETARY
CERTIFICATE OF SERVICE