20131113Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILTTIES COMMISSTON
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO, 5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF AVISTA
CORPORATION'S 2013 ELECTRIC
INTEGRATED RESOURCE PLAN.
l
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
i* !-,I
CASE NO. AVU.E.13-07
COMMENTS OF THE
COMMISSION STAF'F
The Staff of the Idaho Public Utilities Commission comments as follows on Avista
Corporation's Application for its 2013 Electric Integrated Resource Plan.
BACKGROUND
On August 29,2073, Avista Corporation dba Avista Utilities filed its 2013 Electric
Integrated Resource Plan ("IRP") with the Commission. Avista files an Electric IRP with the
Commission every two years to explain how it intends to meet its customers' expected energy
needs over the next2} years.
The 2013 Electric IRP guides Avista's resource strategy over the next two years and
directs resource procurements over the 2O-year plan. It provides a snapshot of Avista's resources
and loads and guides future resource acquisitions over a range of expected and possible future
conditions. IRP Executive Summary at i.
Avista says its 2013 Preferred Resource Strategy ("PRS") includes energy efficiency,
upgrades at existing generation and distribution facilities, demand response and new gas-fired
STAFF COMMENTS NOVEMBER 13, 2013
generation. The PRS balances cost, reliability, rate volatility, and renewable resource
requirements. Id.
The Company says its 2013 PRS significantly differs from the 2011 IRP resource
strategy. Table 1 compares the 2013 PRS with the 2011 PRS.
Table 2013 PRS compared to 2011 PRS (SCCT: Simple-Cycle Combustion Turbine;
Avista says its renewable and capacity needs have changed since the 2011 plan. For
example, the Company says it satisfied the2012 Northwest Wind component of the 2011 PRS by
adding Palouse Wind to its resource mix in December 2012. Also, changes in Washington law
eliminated the need for a201912020 wind resource. Finally, the Company says lower expected
CCCT: Combined-C Combustion Turbine
Year 2OI3 PRS 2011PRS
20r8 83 MW SCCT
20t9 83 MW SCCT 4 MW Thermal Upgrades
2019t2020 120 MW Northwest Wind
2020 83 MW SCCT
2021
20:22
2023 83 MW SCCT 270 MW CCCT
2024
2025
2026 270 MW CCCT 270 MW CCCT
2027
2028 6 MW Thermal Upgrade
2029 46 MW SCCT
2030
2031
2032 50 MW SCCT
Distribution Ef{iciencies <l MW peak reduction 28 MW peak reductron
Enerry Efficiency 221 MW peak reduction 419 MW peak reduction
Demand Response l9 MW peak reduction
STAFF COMMENTS NOVEMBER 13, 2013
load growth delays the first natural gas-fired resource by one year and eliminates the need for a
CCCT in2023. Id.
Avista says its 2013 Action Plan updates progress on the 201I Action items and outlines
activities Avista intends to perform for the 2015 IRP. Avista says the 2013 Action Plan includes
input from Commission Staff, the Company's management team, and the Technical Advisory
Committee ("TAC"). Action item categories include resource additions and analysis, demand-
side management, environmental policy, modeling and forecasting enhancements, and
transmission planning. Id. atx.
STAFF REVIEW
IRP Requirements
In 1993, the Commission issued Order No. 25260 adopting a statement of policy
addressing Integrated Resource Planning. This statement of policy specified that IRPs must:
o Be updated at least biennially;
o Provide an opportunity for public participation and comment; and
o Be filed with the Commission and available for public inspection.
Staff believes the Company's 2013 Electric IRP meets the requirements of Order No.
25260. First, the 2013 IRP updates the Company's 2011 IRP. Second, the Company provided
for public participation and comment through a series of TAC meetings held at Company
headquarters in Spokane, Washington. The Company says its management and the TAC guide
the development of the PRS and the IRP by providing significant input on modeling and
planning assumptions. TAC members include customers, Commission Stafl the Northwest
Power and Conservation Council ("NPCC"), consumer advocates, academics, utility peers,
government agencies, and interested internal parties. Id. Staff actively participated in the TAC
meetings and offered comments to the Company throughout the process. Staff thoroughly
reviewed the draft IRP and provided comments. The Company satisfactorily addressed Stafls
comments in preparing the final IRP document. Third, the 2013 IRP has been filed with the
Commission and is publicly available.
This 1993 statement of policy built upon an earlier order (OrderNo.22299 issued in
1989) outlining requirements for an electric Resource Management Report ("RMR"). An RMR
is now referred to as an IRP. The stated goal of Order No. 22299 is "to elicit concise, pertinent
STAFF COMMENTS NOVEMBER 13,2013
RMRs that provide the Commission, its staff, and other interested parties with an understanding
of the utility's present load/resource position, its expected responses to the variety of possible
future events, and the role of conservation therein." To meet that goal, Order No.22299 outlines
requirements for an IRP. The requirements most pertinent to current IRPs are:l
Identification, by category, of all existing power supply resources;
Discussion of known or potential changes to existing resources;
Estimation of future PURPA supplies along with a clear description of the basis for the
estimation;
o Expected 20 year load growth scenarios (including peak demand and average energy
consumption);
Identification of assumptions, methodologies, models used in load forecast;
Examination of load forecast uncertainties;
Identification of the utility's plan for meeting all potential jurisdictional load over the 20-
year planning period, including references to expected costs, reliability, and risks inherent
in the range of credible future scenarios; and
Consideration for conservation and demand management measures equivalent to the
consideration given generating resources.
Despite specific issues addressed in these comments, Staff believes the IRP meets the
requirements of Order No.22299 as discussed below.
Existing Power Supply Resources
Av i s t a - ow n e d fa c i I i t i e s
Avista-owned resources have a nameplate capacity of approximately 1,800 MW.
a
a
a
o
O
a
Hydroelectric plants make up over half (962 MW) of that nameplate capacity. Avista owns eight
hydroelectric facilities - six on the Spokane River and two on the Clark Fork River. The
Spokane River plants have a combined nameplate capacity of about 180 MW. Five of these
plants operate under a Federal Energy Regulatory Commission (FERC) license through 2059.
' Some of the requirements in this Order are outdated. For instance, this Order requires that utilities attach a copy of
their most recent Form EIA-714 to the IRP and include an appendix with detailed plant data such as the equivalent
forced outage rate by month and five-year historic generation from Public Utility Regulatory Policies Act
("PURPA") projects. The Order also stipulates that a resume of the project manager be included as an appendix to
the RMR.
STAFF COMMENTS NOVEMBER 13,2013
The remaining plant, Little Falls, operates under a state license and does not have an expiration
date. Two plants, Nine Mile and Little Falls, are currently being upgraded. The Nine Mile
upgrades will add 1.4 aMW of energy and 6.4 MW of capacity in 2016. The Clark Fork plants
have a combined nameplate capacity of approximately 780 MW and operate under a FERC
license through 2046. Both of these facilities have had recent upgrades,
Thermal resources make up the rest of Avista-owned resources. Avista-owned natural
gas plants have a combined nameplate capacity of 542 MW (30% of Avista-owned nameplate
capacity). The largest plant, Coyote Springs 2, is currently being upgraded. Avista owns 15% of
two coal-fired plants - Colstrip 3 and Colstrip 4. These two plants have a combined nameplate
capacity of 247 MW (I4% of Avista-owned nameplate capacity). The remaining Avista-owned
resource is a biomass facility using waste wood and natural gas.
P ower purchas e contracts
Avista has about 395 aMW in energy purchase agreements.2 The largest purchase
agreement is the Lancaster Power Purchase Agreement providing 222 aMW. Other large
contracts are with several Public Utility Districts ("PUDs") for the output of their Mid-Columbia
hydroelectric projects. Wind contracts (with Stateline and Palouse Wind) and PURPA contracts
make up the remaining power purchase contracts.
Customer -owne d ge ner at ion
Avista has 190 net-metering customers supplying 1 .1 MW of capacity. Most of these are
Washington customers generating solar power. These customers can qualify for incentives from
$0.12 to $0.54 per kWh from Washington State in addition to federal incentives worth up to
$0.42 per kWh. Avista provides an example showing that the maximum incentive ($0.96 per
kWh) can be greater than the cost of a solar energy system (estimated at $0.80 per kWh). Avista
notes that there might be net metering growth on their system due to the magnitude of these
incentives, and it is exploring ways to estimate future net metering effects on load. Staff is
looking forward to discussing these estimates further with the Company.
2 This includes l0 aMW from the Bonneville Power Administration ("BPA"), which encompasses both a purchase
agreement for 42 aMW and a sale agreement for 32 aMW.
STAFF COMMENTS NOVEMBER 13,2013
Changes to existing resources
Over the next 20 years, contracts supplying a total of 320 aMW will expire. The largest
of these is the Lancaster agreement - expiring in2026. Other large contracts will expire in:
o 2014 - contracts with Chelan PUD (31.7 aMW)
o 2014 - PURPA contract with City of Spokane (16 aMW)
o 2018 - contract with Douglas PUD for 14.7 aMW of annual energy
o 2019 - PURPA contract with City of Spokane (6 aMW)
o 2019 - WNP-3 contract with BPA for 42 aMW purchase and32 aMW sale
The WNP-3 agreement with BPA will not be renewed, as it was the product of a settlement
between Avista, BPA and Energy Northwest regarding construction delays of Washington
Nuclear Plant No. 3 (WNP-3). The status of the other agreements is uncertain. For planning
purposes, Avista anticipates that the Lancaster agreement and the agreements with Chelan PUD
and Douglas PUD will not be renewed. Avista expects to renegotiate the PURPA contracts after
they expire. It should be noted that 11 (out of 12) of Avista's PURPA agreements will expire in
the next l0 years. All of the projects except one would qualiff for Surrogate Avoided Resource
("SAR") published rates. As discussed above, there is also the potential for growth in net
metering.
An unknown with respect to existing resources is how future Environmental Protection
Agency ("EPA") regulations on greenhouse gas emissions under the Federal Clean Air Act will
affect current coal-fired plants. Furthermore, the State of Washington recently enacted
legislation to establish an independent evaluation of the costs and benefits of established
greenhouse gas emissions reductions programs. Results of this evaluation will be used by the
Washington State Climate Legislative and Executive Workgroup to recommend actions and
policies to reduce greenhouse gas emissions. These recommendations are due to the Washington
State Legislature by December 3 l, 2013, and will likely be incorporated in future IRP filings.
For this IRP, Avista includes a greenhouse gas reduction scenario in its modeling to understand
how these yet-to-be determined regulations could affect planning.
Load Forecast
Avista provides energy and peak (winter and summer) forecasts for the next 20 years.
There are several steps in these forecasts. For the energy forecast, Avista first purchases
STAFF COMMENTS NOVEMBER 13, 2OI3
population forecasts for the following metropolitan statistical areas: Spokane, Coeur d'Alene,
and Lewiston. Avista then forecasts:
o weather-normalized use-per-customer using temperature data; and
o long-run use-per-customer trends controlling for potential climate change and electric
vehicle adoption.
These forecasts combine for a long-term energy forecast. Avista estimates that net native load
will grow by l% annually through 2035.
Avista also forecasts both summer and winter peak demand. The steps in this forecast
are:
o normalize peak level usage using historical temperature data and data characterizing the
type of day (day of week, holiday, school day), season, and other factors;
o model normalized peak load growth as a function of Gross Domestic Product ("GDP")
growth.
Avista forecasts that peak load will grow 0.84% in the winter and0.90Yo in the sufllmer through
2035.
The forecasted energy and peak load growth rates are lower than those used in the 201I
IRP. The 201 1 IRP used a 7.4o/o arnual growth rate for energy and l.5Yo growth rates for
summer and winter peak demand. Avista attributes these decreases to downward revisions in
expected economic growth at both the national and regional level. Given the large decrease in
growth rates between the 201I and 2013 IRPs, Staff recommends Avista closely monitor actual
load growth in preparation for its 2015 IRP. The Company's high and low load growth analysis
provides an upper and lower bound allowing the Company to understand how uncertainties in
load growth can affect planning (see below).
Avista expects to completely restructure its forecasting methodology by the 2015 IRP
cycle. The Company will move to a more traditional time series modeling approach
implemented by its new Chief Economist.
STAFF COMMENTS NOVEMBER 13, 2013
Resource Deficiencies
Avista is resource deficient when its resources are not adequate to meet physical energy
and capacity needs. Avista has a short-term capacity need in 201412015 (64 MW) and
201512016 (84 MW). The Company plans on meeting these needs with market purchases - it
does not plan to acquire long-term generation assets while the NPCC forecasts the region to have
a significant surplus. Avista has long-term winter capacity deficiencies in 2020 and summer
capacity deficiencies in 2025.
For winter peak capacity planning, Avista uses a 14% planring margin in addition to
operating reserves. Avista notes that "Planning margins are not necessarily a precise target and
there is no universally accepted standard." Id. at 8-32. The Company does consider how
increasing the planning margin from l4Yo to 20%o would affect resource deficiencies (the first
long-term year deficit would occur in 2016).3 But it does not discuss whether l4o/o ontop of
operating reserves is too high given the region's surplus. In light of Avista's IRP analysis being
used to set avoided cost rates in the SAR model, Staff recommends additional review of the
Company's planning margin in its next IRP.
Avista also must meet Washington State renewable portfolio standards. Avista plans to
meet or exceed these requirements through the 2O-year plan with a combination of hydrelectric
upgrades, the Palouse Wind project, the Kettle Falls Generating Station and Renewable Energy
Certificate ("REC") purchases.
Energy Efficiency and Demand Response
The Company relies on its Conservation Potential Assessment ("CPA") to set the IRP's
energy efficiency targets. The CPA was conducted by EnerNoc and finalized on May 30,2013.
The CPA identifies the 20-year energy efficiency potential specific to Avista's service territory.
The Washington Energy Independence Act ("EIA") requires electric utilities to biannually
update their CPAs. Washington statute also requires the CPA to adhere to the NPCC's Sixth
Energy Plan procedures and methodologies for setting conservation targets. Avista cites several
reasons why its short term savings potential is lower than that shown in the Sixth Power Plan.
Notably, lower load growth projections, reduced avoided costs, and new residential appliance
standards factor into the updated targets.
' Avista chose the 20Yo merely to illustrate how the PRS would change under Higher Capacity Planning Margins.
STAFF COMMENTS NOVEMBER 13, 2OI3
Staff supports using a CPA as a foundation in conservation planning. That said, Staff
does not specifically endorse the final results. The Sixth Power Plan projects conservation
savings using regional assumptions that may differ from Avista's unique service territory. The
CPA adjusts the regional assumptions to better reflect considerations like customer preference,
product saturation, and program ramp rates specific to Avista. The end result is considered
'Achievable Potential' savings. Staff believes this is an appropriate procedure, and Staff wiil
work with the Company and EnerNoc to better understand the rationale applied to arrive at the
Achievable Potential savings.
Regarding Washington's EIA mandates, Avista must acquire all cost-effective energy
efficiency below the 110% avoided cost threshold. The 10oZ conservation premium is applied to
indicate a preference toward investing in demand-side resources rather than building supply-side
resources. The conservation premium results in a suboptimal level of conservation acquisition
from a purely least-cost perspective. The Company's analysis shows that an additional l0 aMW
of energy efficiency can be ascribed to the conservation adder over the planning period, adding
$5.3 million to the levelized PRS cost.
Avista uses an IRP methodology to calculate avoided cost for energy efficiency. The
Company uses AURORA to calculate a2D-year levelized market price, assuming no new
resource additions, to determine the market or energy conservation value. Capacity value is
calculated by building a least-cost resource portfolio to meet the Company's peak needs over the
planning horizon. Finally, the Company calculates the risk-reduction premium for energy
efficiency by quantifying the cost difference between the PRS and a PRS assuming no additional
conservation. The table below illustrates the levelized avoided cost components used in the 2013
IRP. Applying the avoided cost analysis results to the CPA produces 156 aMW of cumulative
energy efficiency savings through 2033:
STAFF COMMENTS NOVEMBER 13, 2013
Table 8.8: Nominal Levelized Avoided Costs of the PRS ($/MWh)
2014-2433'.
Energy Forecast 44.08
Capacity Value 11.74
Risk Premium 1.89
Transmission & Distribution Losses 2.69
Distribution Capacity Savings 1.35
Power Act Premium 6.t7
Total 67.92
The level of energy efficiency savings is significantly less than that included in the 201 1
IRP. There are a couple of notable contributing factors. First, the Company predicts lower load
growth relative to the 2011 forecast. Fewer sales generate fewer opportunities for conservation
savings. Also, the levelized avoided cost fell by nearly 25o/o fromthe 2011 IRP value. A
reduction of that magnitude can considerably diminish the number of measures that meet the
economic potential threshold.
In response to Staff s recommendation, Avista has included a modest level of demand
response in its PRS. Avista intends to assess the potential to acquire the identified20 MW of
demand response during the upcoming IRP cycle. The Company has limited experience
managing demand response programs. Currently, it participates in a pilot demand response
program as part of the Northwest Regional Smart Grid Demonstration Project.a The Company
previously conducted a two-year direct load control pilot between 2007 and 2009 in northern
Idaho. See Case No. AVU-E-07-04. Both programs focused on residential end use, providing
marginal per-participant load reduction. Avista intends to target commercial and industrial
participants for its future demand response program.
aMore information can be found at
http://www.avistautilities.com/inside/resourcesi smartgrid/pullrnan/Pages/default.asox
STAFF COMMENTS l0 NOVEMBER 13, 2013
Preferred Resource Strategy
Avista uses the AURORA and PRiSM models to determine its PRS. Avista used
AURORA to model the Western Interconnect electricity market. Avista inputs their "Expected
Case" into AURORA and AURORA generates electricity prices at key market hubs, resource
dispatch costs and values, and greenhouse gas emissions.
Avista's Expected Case has historically included forecasts of greenhouse gas emissions
costs. Given the current political environment, Avista no longer believes a national greenhouse
gas cap-and-trade system or tax is likely. But the Company's Expected Case does include the
retirement of coal-fired plants due to regulations. Avista considers each coal-fired plant in the
Western Interconnect and decides whether or not the plant is likely to face enough regulatory
burdens to make it uneconomic. If it does, Avista models it as retiring. The Company forecasts
that 12,300 MW of coal generation might shut down over the 2}-year planning horizon.
Uncertainties about the future are modeled in one of two ways - either through stochastic
modeling or scenario analysis. Stochastic modeling captures "potential" market futures. Monte
Carlo-style analysis varies hydroelectric and wind generation, loads, forced outages and natural
gas price data over 500 iterations of potential future market conditions. The simulation estimates
Mid-Columbia electricity market prices by iteration, and the results collectively form the IRP
Expected Case.
Scenario analysis captures the effect of very specific changes to the market or Avista's
underlying assumptions. For example, Avista's Carbon Pricing Scenario models potential cap
and trade mechanisms (high and low carbon pricing starting in either 2020 or 2025). Other
scenarios cover no coal-plant retirement, high and low natural gas prices, and increased state
renewable portfolio standards.
PRiSM combines the operating margins generated in AURORA with capital costs and
fixed operating costs. It then creates an efficient frontier ofresources given a certain risk level
and other constraints (including capacity, energy, and Washington State's renewable energy
requirements and its greenhouse gas emissions performance standard). This efficient frontier
consists of the optimized least cost portfolio for a given risk level. No resource portfolio can be
at a better cost and risk combination than these portfolios. The PRS is one of the portfolios on
the Efficient Frontier. Avista's management saw it as the most reasonable path to follow given
current information. Avista's PRS is found in Table 2. It should be noted that Avista's PRS
does not include retirement of either of the Company's coal-fired plants.
l1STAFF COMMENTS NOVEMBER 13, 2013
Table 2: Avista's Preferred Resource Strategy (PRS)
Resource By the End of Year Nameplate (MlY)Enerry (aM\If)
SCCT 2019 83 76
SCCT 2023 83 76
CCCT 2026 270 248
Rathdrum CT Upgrade 2028 6 5
SCCT 2032 50 46
Total 492 453
Efficiency Improvements Acquisition Range Peak Reduction Enerry (aM!tr)
Energy Efficiency 2014-2033 221 r64
Demand Response 2022-2027 19 0
Distribution Effi ciencres 2014-2017 <l <1
Total 240 164
The first resource acquisition is not until2019. While it is listed as a SCCT, the technology
selection will not be final until a future Request for Proposal ("RFP"). This RFP will likely be
released after the 2015 IRP. Avista may begin making major capital investments for this
addition in2017. As these deadlines approach, there will be more certainty about the technology
chosen and whether economies of scale could be realized by combining the 2019 and2023
acquisitions. The 2026 acquisition replaces the expiring Lancaster agreement, but might not be
needed if Avista can renegotiate the current agreement. In addition to new resources, the PRS
relies on energy efficiency, distribution efficiencies, and, for the first time, demand response.
Avista projects power supply costs for the term of the IRP. After considering future load
growth, Avista expects power supply costs to be lower than the 2012level until around
202312024.
The PRS is not the least cost strategy. The least cost strategy would use a SCCT in2026
instead of the CCCT. But the least cost strategy includes more market risk; i.e., there is more
variance in power supply costs under the potential market futures. Avista management decided
that the decrease in market risk was worth the increase in cost.
STAFF COMMENTS t2 NOVEMBER 13, 2013
Avista also considered how the PRS would change under different scenarios. These
scenarios include:
. Carbon Pricing Scenario - If national climate change legislation is enacted, SCCTs in the
PRS are replaced with hybrid CTs and additional energy efficiency is acquired. The
Climate Change PRS is higher cost but lower risk than the Expected Case PRS.
o Different Energy Efficiency Scenarios - Under Washington State law, Avista must
acquire all cost effective energy efficiency up to 110% of the avoided cost. To
understand the costs of this requirement, Avista constructed an optimal portfolio with
energy efficiency acquisitions up to 100% of avoided cost. Compared to the PRS, the
power supply costs of this new portfolio are2.7Yo lower and the market risk is 030%
higher. In other words, the Washington State law results in a higher-cost PRS.
o 'No Colstrip" Scenario - Avista examined a scenario in which Colstrip Units 3 and 4
were no longer resources. An altemative PRS excluding these coal-fired plants results in
an addition of a CCCT in20l7. Power supply costs under this scenario are 12.8% higher
than under the Expected Case PRS.
Avista also combined the Carbon Pricing Scenario (above) with this'No Colstrip"
Scenario. Even under carbon pricing, excluding the Colstrip plants results in power
supply costs 10.9% higher than the scenario with the plants.
o New Environmental Regulation Scenario - Avista does not anticipate that there will be
significant changes in operation at Colstrip Units 3 and 4 due to Mercury Air Toxic
Standards ("MATS") limitations or coal ash management/disposal issues. But Avista
does anticipate that these units could require emission controls in2027. Avista compared
the costs of adding Selective Catalytic Reduction Nitrous Oxide ("SCR NOx") controls
for the plants to the "No Colstrip" scenario and found that Colstrip Units 3 and 4 "remain
a viable and cost-effective resource for Avista's customers."
o Load Forecast Alternative Scenario - Avista examined how the PRS would change if
different load growth levels were used. Avista modeled Low Load Growth, Medium
Load Growth, and High Load Growth scenarios. The first new resource would be added
in2026 under the Low Load Growth Scenario, in2022 under the Medium Load Growth
Scenario, and2019 under the High Load Growth Scenario. While the Expected Case and
the High Load Growth Scenario result in resources being added in the same year, the
l3STAFF COMMENTS NOVEMBER 13, 2OI3
High Load Growth Scenario calls for a 150 MW SCCT while the Expected Case calls for
a 83 MW SCCT. Even if load growth is higher than expected, the Company has adequate
time to adjust its resource plans.
Action Items
The IRP contains the Company's 2013 Action Plan as well as its assessment regarding its
progress towards implementing its 2011 IRP Action Plan. The 2013 Action Plan contains
activities and studies developed and studied in the Company's 2011 IRP. Significant 2013
Action Plan items include:
. Consider Spokane and Clark Fork River hydro upgrade options in the next IRP as
potential resource options to meet energy, capacity, and environmental requirements;
o Continue to evaluate potential locations for the natural gas-fired resource identified to be
online by the end of 2019, including environmental reviews, transmission studies, and
potential land acquisition;
o Continue to participate in regional IRP and regional planning processes and to monitor
regional surplus capacity, and continue to participate in regional capacity planning
processes;
o Commission a demand-response potential and cost-assessment of commercial and
industrial customers per its inclusion in the PRS;
o Continue to monitor state and federal climate change policies and report work from
Avista's Climate Change Council;
o Review and update the energy forecast methodology to better integrate economic,
regional, and weather drivers of energy use;
o Evaluate the benefits of a short-term (up to 24-months) capacity position report;
o Evaluate options to integrate intermittent resources;
o Work with NPCC, the Washington Utilities and Transportation Commission ("WUTC"),
and others to resolve adjusted market baseline issues for setting energy efficiency target
setting and acquisition claims in Washington;
o Study and quantify transmission and distribution efficiency projects as they apply to EIA
goals;
o Update processes and protocols for conservation measurement, evaluation, and
verification;
STAFF COMMENTS t4 NOVEMBER 13, 2013
Assess energy efficiency potential on Avista's generation facilities. These are methods to
decrease load of station service at Avista's facilities, such as better lighting or more
efficient pumps;
Work to maintain Avista's existing transmission rights, under applicable FERC policies,
for transmission service to bundled retail native load;
Continue to participate in BPA transmission processes and rate proceedings to minimize
costs of integrating existing resources outside of Avista's service area; and
Continue to participate in regional and sub-regional efforts to establish new regional
transmission structures to facilitate long-term expansion of the regional transmission
system.
STAFF RECOMMENDATION
After reviewing Avista's 2013 IRP, Staff believes that the Company amply provided for
public participation and input through the TAC meetings. Furthernore, Staff believes that the
Company provided analysis sufficient to give interested parties an understanding of the
Company's present load position, how it would respond to different future events, and how
energy conservation plays a role in its plans. Staff thus believes this IRP satisfies the
requirements set out in Order Nos. 22299 and25260, and recommends that the Commission
acknowledge the Company's 2013 IRP.
Respectfully submitted this l3+day of November 2013.
Technical Staff: Cathleen McHugh
Bryan Lanspery
i:umisc/comments/avuel3.Tkkcmbl comments
la4
Karl T. Klein
Deputy Attorney General
STAFF COMMENTS t5 NOVEMBER 13, 2OI3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I3'H DAY oF NoVEMBER 20T3,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. AVU-E.13-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWNG:
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-MAIL: linda. [e-mail]
CERTIFICATE OF SERVICE