20200902Reply Comments.pdf

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Avista Corp.
141 1 East Mission P.O. Box 3721
Spokane, Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
September 2,2020
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
1331 W Chinden Blvd, Bldg 8, Suite 201-A
Boise, lD 83714
RE: CASE NO. AW-E-19-01
REPLY COMMENTS OF AVISTA CORPORATION REGARDING THE COMPANY'S 2O2O
ELECTRIC INTEGRATED RESOURCE PLAN
Dear Ms. Noriyuki:
Attached for filing with the Commission is Avista Corporation's, doing business as
Avista Utilities, reply comments regarding the Company's 2020 Elecfrc Integrated Resource
Plan (IRP) in accordance with Order No. 34666.
If you have any questions regarding these reply comments, please contact James Gall at 509-
495-2189 or me at509-495-2782.
Sincerely
lslslarrn &odl"/d
Shawn Bonfield
Sr. Manager Regulatory Policy & Stategy
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MICHAEL G. ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
14I1 EAST MISSION AVENUE
P.O.BO)(3727
SPOKANE, WASHINGTON 99220 -37 27
PHONE: [phone]
michael. andrea@ avistacorp.com
IDAHO BAR #8317
BEFORE THE IDAI{O PUBLIC UTILITIES COMN{ISSION
IN THE MATTER OF THE AVISTA
CORPORATION' S 2O2O ELECTRIC
INTEGRATED RESOURCE PLAN
CASE NO. AVU-E-I9-OI
REPLY COMMENTS OF AVISTA
CORPORATION
I. INTRODUCTION
Avista Corporation, doing business as Avista Utilities (hereinafter Avista or
Company), at l4ll East Mission Avenue, Spokane, Washington, respectfully submits
reply comments regarding the Company's 2020 Electic Integrated Resource Plan ("2020
tRP') in accordance with Order No. 34666. Avista requests that the Commission
acknowledg e the 2020 IRP as filed.
II. BACKGROUND
The Commission issued a Notice of Modified Procedure, Order No. 34666, on May
l3,z}z},setting forth a comment deadline of August 19,2020. Commission Staff("Staff')
and the ldaho Conservation League ("[CL"), submitted comments on or prior to the
deadline. The deadline for reply comments is September 2,2020.
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REPLY COMMEN'TS OF AVISTA COPJORATION - 1
III. COMPANY RESPONSE
Avista's IRP process is open and public. The IRP itself is developed with the help
of a Technical Advisory Committee ("TAC") made up of customers, utility commission
staff, consumer advocates, environmental advocates, academics, utility peers, government
agency staff and Avista's energy analysts. Avista would like to thank Staff and ICL for
supporting the 2020IRP and for their continued participation and involvement in past and
future IRP planning processes.
In total, Avista invites over 100 representatives from many outside organizations.
Six TAC meetings were held at Avista headquarters between July 25,2018 and November
19,2019 to inform members and receive feedback. Avista was also available and discussed
IRP-related information via telephone, email, and in-person meetings.
None of the commenters in this matter recommend the Commission not
acknowledge the 2020 IRP. Staff states specifically the IRP meets the requirements of
Commission Orders for developing and filing an IRP. There is ample evidence to support
acknowledging the 2020IRP as filed.
Commenters do ask the Commission to direct Avista to perform various analyses
in future IRP processes and provide an annual report related to Colstrip. Avista provides
the following response to various issues raised by Staffand ICL.
A. Response to StaffComments
The Company acknowledges Staff s concerns about the 2020IRP. The following
discussion provides information to help address those concerns. Avista looks forward to
further addressing these concerns in the 2021 IRP and future resource planning processes.
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A draft of Avista's 2021 IRP will be available by January 4,2021. This shortened
IRP process is driven by Washington's Clean Energy Transformation Act ("CETA").
Following the 2021 IRP, the next IRP for Washington will be due on April 1,2025.
Washington is moving to a four-year IRP cycle with an IRP update two years after the
filing of an IRP. Accordingly, Avista will be required to update its Washington IRP by
April 1, 2023. Avista intends to continue aligning Idaho and Washinglon's biannual
requirements going forward. Avista hopes to continue a collaborative process with Staffto
resolve any differences in energy requirernents between Idaho and Washington and to
prevent any adverse impacts between Avista's customers in these states.
i. Colstrip
Staff raised certain concerns, beginning on page five of their comments, related
to the 2020 tRP's Colstrip economic analysis. CETA effectively ensures that Avista
will not be able to use the plant to serve Washington customer loads beginningin2026.
Avista has stated in TAC meetings the plant remains a resource option to continue
serving Idaho loads as long as it remains economic for those customers. The
presentations and meeting notes from TAC meetings show Avista's modeling found
the plant to be uneconomic in the 2020 IRP for Idaho customers by the end of 2025.
At the frfth TAC meeting, which was held on October 15,2019, Avista presented
its draft Preferred Resource Strategy ("PRS"). The PRS included an economic analysis
of whether Colstrip should be removed from the portfolio beginning in2025 or whether
it should remain in the Company's portfolio past that time. On page 12 (2020 IRP
Appendix A, p. 575) ofthe presentation, Colstrip Units 3 and 4 were shown as removed
from the portfolio due to the projected economics of the plant. Avista found portfolio
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costs are lower for Idaho customers when removing the plant from the portfolio based
on the scenario analysis presented at this TAC meeting. Avista highlighted this result
again in its presentation on the preliminary PRS on page 24 (2020IRP Appendix A, p.
s87).
This information regarding the future of Colship was shared as part of the results
of the draft IRP. The Company uses the information to develop and refine its actual
resource strategy after the IRP is finalized. The additional complexities of Colstrip
having multiple owners increases the challenge of a future strategy for the plant because
Avista cannot contractually make a unilateral decision to close the plant.
Avista showed the final PRS at the sixth TAC meeting, which was held on
November 19, 2019. The results of the final PRS continued to show Colstrip exiting
the portfolio by the end of 2025 based on economics.
Avista understands there are concerns whether Idaho customers will pay
Washington's share after 2026. However, Avista specifically indicated Idaho
customers would not pay for any costs associated with Washington's share of the plant
and understands that this is a critical issue for the Idaho Commission and its customers
in Idaho.
Avista performed additional Colstrip modeling at the request of Staff through
both audit and production requests after the 2020 IRP was filed. The analyses included
allowing the portfolio selection model ("PRiSM") to choose the timing for Colstrip to
exit the portfolio. This modeling effort suggested an even earlier economic exit for
Colstrip than the end of 2025.
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While this analysis is informative, as with the 2025 date, it will take time to
develop a viable exit strategy and time to implement the execution of that strategy.
This is particularly true given that there are multiple owners involved. The 2020 IRP
analysis makes clear that the Company should evaluate options to exit the Colstrip plant
by the end of 2025. Avista's 2021 IRP is currently in process and the Company
continues studying the economic operation of Colstrip. Assuming the 2021 IRP will
reach the same conclusion as the 2020IRP Colstrip, Avista will continue to evaluate
options as it develops an exit strategy. The Company will continue to apprise the Staff
and TAC members as it develops the Colstrip stategy outside ofthe IRP process, much
like it does in the pursuit of a new resource in an RFP process after the IRP identifies
the need for a new resource.
ii. Future Portfolio Modeling
In reference to pages five and seven of the Staff comments, Avista did discuss the
ramifications of developing separate Washington and Idaho resource plans to address
the impacts of Washington policy and potential cost allocation issues. Given the
responses from the TAC, Avista will continue planning to operate as a single system
within the IRP. However, Washington regulatory obligations will require future IRPs
to have additional sections not directly applicable to Idaho.
Avista will select resources in its upcoming2}2l IRP using new optimization logic
for selecting new or removing existing resources based on state responsibility in
relation to its load and share of resources. The PRiSM model will select new resoluces
and allocate their costs to only Idaho, only Washington, or to both states based on
needs, economics and policy requirements. This methodology should resolve questions
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regarding whether new resources are added solely to meet Washington law and are not
least cost absent CETA requirements. This process for the 2021 IRP will also allow
Colstrip to be selected as an option to continue serving Idaho customers, if it proves to
be economic. Lastly, the enhanced PRiSM logic will allow the value of RECs resulting
from ldaho's investment in clean resources to either be retained for Idaho customers or
monetized through sale for the benefit of Idaho customers.
Avista's 2020 IRP included a requirement by Washington to include the social
cost of carbon. This requirement in the prior PRiSM methodology could only be
satisfied by assigning Washington's share to all resources. Cost allocation would have
to be done outside of the PRiSM model. The proposed change to the PRiSM logic for
the 2021IRP will allow additional costs to be applied only to Washington, but also
allow for scenarios testing the application of the social cost of carbon for Idaho.
This new modeling framework can begin the process for determining potential
mechanisms for cost allocation between Washington and Idaho as Avista adds new
resources required to meet Washington law that may be higher cost than the lowest
resource cost. Avista looks forward to future workshops with both Idaho and
Washington staffs to develop a new cost allocation methodology suitable to both states.
iii. Peak Load Forecasting
Staff s next area of concern with the 2020 IRP's conclusion is whether Avista
will remain a winter-peaking utility. Since 2012 over 7,500 customers have switched
from electric to natural gas creating a lower trajectory of winter peak loads since
historical highs. In recent years, Avista's service territory has experienced hotter
sufilmers and milder winters, resulting in a few higher peak summer loads than winter
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peak loads. Statistically, on a 50ft percentile basis of historical weather, loads have not
reached the point where Avista has switched to a summer peaking utility, but it is an
area Avista is monitoring.
Staff mentions concerns with autoregressive components ("AR[MA") included
when discussing the peak load forecast. The Company notes that there are no
autoregressive components used in the peak load forecasting model. Although Avista
forecasts an average peak, it also forecasts high and low bounds for the summer and
winter peak forecast based on each historical weather year for each month. These are
shown in Figure 3.16 of the IRP.
iv. Price Elasticity
Avista does not have a precise estimate of price elasticity of demand for its load
in the long run, although, setting elasticity to zero would significantly overstate long-
term load growth. There is substantial academic evidence that long-run price elasticity
is relatively inelastic, but it is not zero or perfectly inelastic. Also, as explained during
a conference call with Stafe the staff from other state commissions have historically
wanted Avista to maintain an adjustment for the long-run price effects of elasticity. The
divergence in the jurisdictions' opinion about elasticity is difficult to reconcile in a
forecast that applies to multiple states.
v. Other Load Forecasting Issues
The ARIMA terms used in the medium-term energy forecast (bi-annual forecast
for the revenue and earnings models) have the most influence over a l2-month
horizon. After this time, the influence of the ARIMA terms on the forecast disappears.
The point of ARIMA terms is to improve forecast accuracy over that near-term 12-
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month period. This is important for revenue and earnings models. In other words, not
using the ARIMA terms means leaving information off the table which can improve
forecasts in the shorter term and is material for the financial forecast. In terms of StafPs
comments regarding model stability, the software automatically performs the Dicky-
Fuller stationarity tests on the final errors of the estimation model. The potential for
forecast instability would present as a failure to pass these tests, which did not occur
when running the load forecast. In addition, if model stability is a major issue, the
software sends a warning that it failed to estimate the model because stable regression
coefficients could not be found. No such warninss regarding model stability were noted
during the development of the load forecast.
vi. Natural Gas Prices
Avista concurs with Staffs assertion that natural gas prices remain volatile.
Consequently, Avista models natural gas prices in a lognormal format to estimate the
risk of higher prices. Natural gas prices are expected to still set marginal prices for a
majority of future hours in the electricity markets. However, the importance of natural
gas on electric market prices is decreasing each year due to the amounts of intermittent
renewable energy added to the system to meet clean energy goals. This decreasing
importance is shown by the very low electric price forecast in the 2020 IRP, generally
athibuted to the variability of renewable resources. Wholesale electric prices could be
very volatile in the future as an increasing amount ofrenewable resources with variable
output enter the market.
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vii. Storage Resources
Avista agrees with Staffthat energy storage will be an important part of the future
resource portfolio due to intermittent renewable resources and the expected price
reductions of storage technology. Staff s conclusions on liquid air storage vary greatly
from Avista's conclusions. Avista's engineering staff has spent considerable time
researching this issue. The Company therefore proposes providing a more in-depth
presentation to Staff on this technology. The Company is excited for this technology's
potential and believes it could be cost effective relative to other options available to the
industry for long duration storage. Liquid air storage has been used in the oil and gas
industry and shows potential for application to the power business given the economics
created by renewable energy.
viii. Intermittent Generation Costs/Ancillary Services Study
Avista retained EnerNex to help with a new intermittent generation integration
cost study to be completed and available for use in the 2021 IRP. These costs will be
studied using the Avista Decision Support System ("ADSS") software along with the
ancillary services benefits of new storage resources. Until the study is complete, the
2007 study's low market price case remains relevant given that Avista's non-variable
energy resource portfolio has not changed significantly since the 2007 study was
completed.
ix. Retiability Analysis and Resource Adequacy
Avista appreciates Staffs attention to the reliability studies performed for the
2020 IRP and agrees it will need to continue to improve it modeling efforts in this area.
Additional years and portfolios will be studied in the 2021 IRP to ensure the system is
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reliable for customers. This additional analysis will remove reliance on a single-year
planning reserve margin. Avista continues to evaluate new tools for use beyond the
2021 IRP. Avista anticipates the Northwest will be successful in developing a Resource
Adequacy ("RA"; progftlm and associated market products. A Northwest RA program
can supplement Avista's resource planning methodology by using the regional RA
requirements and estimates for resource peak capacity credit, as opposed to solely
relying on the Company's own analyses.
x. Energy Efficiency and Demand Response Programs
In its comments, Staff notes concerns regarding the accuracy of the savings
reported by the Company's energy efficiency program by referring to an agreed-upon
Stipulation and Settlement ("Stipulation") approved in Avista's most recent energy
efficiency prudency case (Order No. 34647, Case No. AVU-E-18-12), then further
remarks that "Staff looks forward to the improvements outlined in the Stipulation and
will review the results of the Company's revised methodology for estimating the peak
reductions attributable to the Company's energy efficiency programs when it becomes
available." (Staff Comments, Case No. AVU-E-19-01, page l6). Avista is encouraged
by Staffs attention to its energy efficiency improvements, and has directly addressed
each of the eleven Staffcomments within its "Idaho Commission StaffComments and
Recommendations Implementation Report", included in its July 31,2020, compliance
reporting in Case Nos. AVU-E-18-12 and AVU-G-18-08. The Company seeks
clarification regarding the expectation of a revised methodology for estimating peak
reductions attributable to the Company's energy efficiency programs, as those concerns
were not voiced by Staffwithin written comments or within other prudence documents,
REPLY COMMENTS OF AVISTA CORPORATION - 10
nor was there any mention of such concerns in the Stipulation or Commission Order
No. 34647. Avista's energy efficiency team is hopeful the improvements already made
to its energy efficiency program are appreciated and is open to collaborating with Staff
on any further concerns with its approach to energy efficiency.
To avoid overstating the peak load reduction obtained from Avista's energy
efficiency programs, savings achieved by these programs are verified by an
independent third-party evaluator as part of its EM&V process. That process includes
a billing analysis and other on-site verification processes to ensure that the savings
reported by Avista have been realized on Avista's system by participating customers.
Historically, the energy efficiency programs include a capacity value based on winter
peak savings for the overall cost-effectiveness of the programs. A dual peaking model
could shift the amount of avoided cost for winter peaking measures, thereby changing
the overall cost effectiveness of the progftrms. However, the amount of energy
efficiency savings achieved per measure installed would remain constant unless other
factors affect the unit energy savings value and the analysis of customers' use.
Avista's energy efficiency potential study by Applied Energy Group includes
average energy savings for each program along with estimated winter and summerpeak
savings. This estimate is summarized on page 1l-10 of the 2020 IRP. These estimates
are used to identiff and to select cost effective measures for inclusion in the PRS.
Avista's peak load forecast is ultimately used for supply/demand response ("DR")
programs subject to small variances due to the iterative process of re-adding energy
efficiency measures back into the peak load forecast. Avista is committed to offering
the TAC details about the specific winter and summer savings data in addition to the
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energy savings projections inthe2O2l IRP. This will provide more information to help
with the concern over the potential for overreliance on winter peaking efficiency
measures.
The next area of Staff concern is about the Company's focus on winter peaking
events which may result in acquisition of energy efficiency and DR resources that are
ineffective at reducing surlmer peak loads. Avista's IRP analysis studies multiple
aspects of the energy and peak load needs of the Company's system, including energy,
one-hour winter and summer capacity, and three day six-hour consecutive peaks. The
mix of energy efficiency, DR and new generation were selected to meet the most
stringent limiting factor across all of these different measures of needs. While the
Company does show a higher potential for programs that produce energy savings
during peak loads, energy efficiency programs use an 8,760-hour model which factors
in time-of-day impacts along with seasonal impacts. The largest program within the
energy efficiency portfolio continues to be non-residential lighting which remains cost-
effective in both summer and winter peaking events.
As for DR and rate design DR programs, Avista will continue to model these
resources in the 2021 IRP. In addition, Avista will be able to model separate DR
programs for Idaho and Washington customers.
xi. Request for Proposals ("RFP")
Avista is currently reviewing the responses to its 2020 renewables RFP and likely
will issue a capacity RFP at a later date. Avista sequenced the RFPs in this manner to
clariff the amount of future capacity needs in the event the renewables RFP process
yielded resources providing some capacity contribution. Avista anticipates considering
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all capacity resources to compete in the RFP, including liquid air, pumped hydro, wind,
solar, lithium ion storage, natural gas and other resources. The RFP is the preferred
place for identifuing specific resource acquisitions and resource decision making as the
IRP only estimates likely selections in a future RFP based on modeling assumptions.
IRPs should focus on resource need, meaning the amount of energy and capacity
needed along with its timing and any policy driven requirements, not specific resource
choices as the options included in the IRP are estimates and not specific bids from real
projects.
xii. Staff Recommendations
a. Avista thanks Idaho Stafffor support for acknowledgement ofthe 2020 IRP.
Avista is developing a2021IRP in an accelerated schedule in order to meet
Washington's new IRP requirements and it will address many of StafPs
concerns identified in the 2020IRP.
b. Avista agrees with and supports the Staff recommendation of an annual
Colstrip report until Avista has exited the facility and to notiff the
Commission of decisions made by co-owners within 30 days if they
materially impact Idaho customers.
B. Response to ICL
Avista is encouraged by ICL's support for the general direction of the IRP and
hopes ICL can continue to support Avista's efforts to transform its electric system in a way
to protect the environment, while recognizing the importance of low cost and reliable
service for all customers. ICL makes four recommendations for the Company in future
IRPs, which the Company addresses in the following responses.
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i. Social Cost of Carbon
ICL requests that Avista use the social cost of carbon ("SCC") for resource
decision making. Avista compared all resource portfolios serving Idaho and
Washington customers with a carbon price equal to the SCC for market operations. In
this market future scenario, Avista's Clean Resource Plan portfolio performed the best
out of the 15 portfolios examined. This scenario yields similar results to ICL's request.
The Clean Resource Plan portfolio increases the Present Value of Revenue
Requirement ("PVRR") from $l1.8 billion to $12.4 billion or a rate of 15.6 cents per
kWh as compared to 14.1 cents per kWh for the average customer in 2045. This
information is shown throughout Chapter 12 and specifically on page 12-19. Avista did
not choose this portfolio due to its cost impact on Idaho customers.
Avista agrees to include a scenario in the forthcoming 2021 IRP where it will
model the SCC on its entire retail load to understand the change in results as discussed
above in Staffcomments.
ii. Colstrip
Avista's 2020 IRP shows that by the end of 2025 the Colstrip plant is not
economic for Idaho customers. Avista is diligently working to find a path to exit the
plant given the circumstances of the ownership arangement. Avista is hopeful ICL can
support Avista's efforts to exit Colstrip and can assist in finding a viable path to exiting
ownership or closure of the plant in the most prudent manner for Avista's customers.
iii. Natural Gas Price Forecasts
Avista uses nationally known and respected consultants to estimate future natural
gas prices blended with 36 months of forward market prices. Avista must respect the
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industry-standard confidentiality of contracts with consultants. Avista makes extra
effort to provide the prices without attaching names so TAC participants can see the
price forecasts utilized by Avista in the IRP. Without this protection, Avista would not
have access to this data and would spend significantly more to develop prices internally
or would have to rely on lesser quality public pricing from govemment sources.
After the Company blended the consultant's forecasts with forward prices it
published its natural gas price forecast along with the consultant forecasts nthe2020
IRP document on pages 10-7 through l0-10. Avista also discussed the forecast in detail
early in the 2020 IRP cycle at a TAC meeting held on August 6, 20219, where
participants, including ICL, had an opportunity to provide their perspectives and
request other pricing scenarios. Avista looks forward to ICL's participation in
upcoming TAC meetings to hear its suggestions on how Avista can better represent the
natural gas markets in its IRP.
iv. Renewable Energy Credits
ICL asks for a full explanation and accounting for how renewable energy credits
("RECs") are treated in the IRP. In response to ICL's comments during the TAC
process, Avista specifically included this information in Figure 11.9 of the 2020 IRP,
as well as the draft IRP. Responding to ICL's comments, the figure shows the amount
of clean energy produced with RECs assigned to each state for the PRS. Specifically,
the orange line in Figure 1 1.9 indicates the amount of renewable energy retained for
Idaho customers as a percent of its retail sales. Until receiving their comments, Avista
was not aware that ICL had any concerns with Figure 11.9.
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C. Conclusion
Avista appreciates the opportunity to provide reply comments regarding the
Company's 2020IRP. Please direct any questions regarding these comments to James Gall
at 509-495-2189 or John Lyons at 509-495-8515.
DATED at Spokane, Washington, this 2"d day of September 2020
AVISTA CORPORATION
Bv /s/lVlichael Andrea
Michael G. Andrea
Senior Counsel
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 2'd day of September 2020, served the foregoing Reply
Comments in Case No. AVU-E-19-01 upon the following parties, by emailing a copy thereof
sent to:
JanNoriyki
Idaho Public Utilities Commission
11331 W Chinden Blvd, Bldg 8, Suite 201-A
Boise,lD 8371,4
i an. norivuki @Fuc. idaho. com
Benjamin Otto
Matthew A. Nykiel
Idaho Conservation League
710 N 6m Street
Sandpoint,ID 83701
botto@ idahoconservation. ore
mnvkiel@ idahoconservation. ore
lolslaarrc gorilkH
Shawn Bonfield
Sr. Mgr. Regulatory Policy & Stategy
Avista Utilities