20210428Notice_of_Filing_Order_No_35022.pdf

NOTICE OF FILING
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 35022 1
Office of the Secretary
Service Date
April 28, 2021
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF AVISTA
CORPORATION’S 2021 ELECTRIC
INTEGRATED RESOURCE PLAN
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CASE NO. AVU-E-21-04

NOTICE OF FILING

NOTICE OF
INTERVENTION DEADLINE

ORDER NO. 35022

On March 31, 2021, Avista Corporation dba Avista Utilities (“Company”) filed its
2021 Electric Integrated Resource Plan (“Electric IRP” or “IRP”). The IRP outlines and analyzes
the Company’s strategy for meeting its customers’ projected energy needs over the next 24 years.
The Company files an IRP every two years and uses it to guide resource acquisitions.1 With this
Order, the Commission provides notice that the Company has filed its 2021 Electric IRP and sets
deadlines for interested persons to petition to intervene in the case.
NOTICE OF IRP FILING
YOU ARE HEREBY NOTIFIED that the Company’s 2021 Electric IRP is about 315
pages long and is accompanied by about 1,105 pages of appendices. The 2021 Electric IRP
includes the following sections: (1) Executive Summary, (2) Introduction & Stakeholder
Involvement, (3) Economic & Load Forecast, (4) Existing Supply Resources, (5) Energy
Efficiency, (6) Demand Response, (7) Long Term Position, (8) Transmission and Distribution, (9)
Supply-Side Resources, (10) Market Analysis, (11) Preferred Resource Strategy, (12) Portfolio
Scenarios, (13) Energy Equity, (14) Action Items, and Clean Energy. The information set forth
below is taken from the Executive Summary. Further details may be found in the IRP’s remaining
chapters and appendices.
YOU ARE FURTHER NOTIFIED that the 2021 Electric IRP guides the Company’s
resource strategy planned procurements over the next 24 years. It provides a snapshot of the

1 The Company was granted a six-month extension to file its 2019 IRP. Order No. 34312. The Commission changed
the caption for the Company’s filing to the “2020 Electric Integrated Resource Plan” when it issued the Notice of
Filing. Order No 34609. The Company’s 2020 IRP was acknowledged on October 15, 2020. Order No. 34814.

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ORDER NO. 35022 2
Company’s resources and loads and guides future resource acquisitions over a range of expected
and possible future conditions. IRP at 1-1.
YOU ARE FURTHER NOTIFIED that the Company states that its 2021 Preferred
Resource Strategy (“PRS”) development depends on modeling techniques to balance cost,
reliability, rate volatility, and environmental goals and mandates. The Company’s management
team and Technical Advisory Committee (“TAC”) guide the IRP development by providing input
and feedback on modeling and planning assumptions. TAC members include customers,
Commission Staff, the Northwest Power and Conservation Council, consumer advocates,
academics, environmental groups, utility peers, government agencies, and other interested parties.
Id.
YOU ARE FURTHER NOTIFIED that, in describing its resource needs, the Company
reports it expects its highest peak loads in the winter under extreme cold weather conditions. The
Company explains its peak-planning includes operating reserves, regulation, load following, wind
integration, and resource adequacy requirements. The Company states it can meet peak-load
requirements through December 2025 using existing resources and energy efficiency. Load growth
and the loss of Colstrip, Lancaster, Northeast, Boulder Park, and expiring hydro contracts drive
the Company’s resource deficits. Id.
YOU ARE FURTHER NOTIFIED that the Company explains that it develops its PRS
through a multi-step approach. First the Company identifies and quantifies fundamental changes
in the Western Interconnect between 2022 and 2045. The Company includes potential new
generation resources to serve projected electricity demand across the West as regional loads
transform and older resources are retired. Monte Carlo-style analyses vary hydroelectric and wind
generation, weather, forced outages, and natural gas price data over 500 iterations of potential
market conditions to forecast the Mid-Columbia electricity marketplace through 2045. Id. at 1-2.
YOU ARE FURTHER NOTIFIED that the Company’s 2021 IRP forecasts the Mid-
Columbia electricity price for the Expected Case, including the price range over the 500 Monte
Carlo iterations, to be a levelized price of $27.13 per megawatt hour in nominal dollars over the
2021-2045 timeframe. The Company observes that electricity and natural gas prices are highly
correlated because natural gas fuels marginal generation in the Northwest most of the year. The
Company reports that nominal levelized Expected Case natural gas prices at the Stanfield trading

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hub, and the forecast range from the 500 Monte Carlo iterations performed for the Expected Case,
result in an average $3.45 per dekatherm over the next 24 years. Id.
YOU ARE FURTHER NOTIFIED that the Company’s 2021 IRP includes a
Conservation Potential Assessment (“CPA”) and a Demand Response potential study to estimate
the potential for those applications in its service area. The CPA estimated that energy efficiency
will serve 68% of future load growth. Based on the study, the Company reports that its
conservation efforts since 1978 have decreased its load requirements by 14.5%. The Company
states Demand Response programs will be integral to serving peak load using several cost-effective
programs and rate redesigns. Id. at 1-3.
YOU ARE FURTHER NOTIFIED that the Company states that its management and
the TAC guided the development of the 2021 PRS after considering the information gathered and
analyzed in the IRP process. The resulting 2021 PRS meets future reliability and clean energy
requirements with upgrades at existing generation facilities, energy efficiency, natural gas peakers,
energy storage, contracts, new renewable resources, and demand response. The resource selections
are based on an economic decision-making process using societal and resource cost estimates. Id.
at 1-4.
YOU ARE FURTHER NOTIFIED that the Company states its 2021 PRS is the lowest-
reasonable cost plan to meet both reliability and environmental requirements. However, major
changes from the 2020 IRP include the return of natural gas peakers as long-term energy storage
is not yet cost effective as estimated in the 2020 IRP for the Company’s 2026 capacity need. The
PRS also lowers the estimated demand response, wind acquisition, and hydro upgrade quantities.
Id.
YOU ARE FURTHER NOTIFIED that the Company also states it values each new
supply- and demand-side resource option against the Mid-Columbia electricity market forecast to
identify its future value and inherent risk measured by year-to-year portfolio cost volatility. The
Company then inputs these values and their associated capital and fixed operation and maintenance
costs into a PRS Linear Programming Model (PRiSM) that optimally mixes new resources. Id.
YOU ARE FURTHER NOTIFIED that the Company explains that its PRS provides a
lowest-reasonable cost portfolio that minimizes future costs and risks within actual and expected
environmental constraints. Id. at 5. The Company states the PRS is a balance between cost and

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risk. The Company likens the approach to finding an optimal mix of risk and return in an
investment portfolio: as expected returns increase, so do risks. Conversely, reducing risk generally
reduces overall returns. The Company notes that lower power cost variability comes from
investments in more expensive—but less risky—resources like wind and hydroelectric upgrades.
Id. at 1-5.
YOU ARE FURTHER NOTIFIED that the Company states that acquiring an additional
375 Megawatts of new clean energy resources by 2031, along with upgrades to its hydro and
biomass facilities, will position the Company to meet or exceed Washington’s clean energy
requirements. This PRS allows the Company to meet 78% of its corporate clean energy goal to
provide customers with 100 percent net clean energy at competitive prices by 2027. The Company
also states it will exceed its obligations under Washington’s Energy Independence Act by relying
on output from the Palouse and Rattlesnake Flat Wind contracts, generation from the Kettle Falls
biomass facility, and upgrades to the Clark Fork and Spokane River hydro developments. Id. at 1-
6.
YOU ARE FURTHER NOTIFIED that the Company states its shift to clean energy
will reduce its greenhouse gas footprint significantly. In 2030, emissions will be 74 percent below
2019 levels. This represents an annual reduction of 2.2 million metric tons.2 The Company notes
that when accounting for its contributions through incentives and programs to shift transportation
fuel to electricity, regional greenhouse gas emission reductions could exceed those from the
removal of coal and natural gas plants. Id. at 1-7.
YOU ARE FURTHER NOTIFIED that Washington’s Clean Energy Transformation
Act expands the Company’s commitment to bring affordable clean energy to customers including
Highly Impacted Communities and vulnerable populations. The Company began to identify
vulnerable populations in its service area to understand the difference in energy burden and
reliability for those populations. The Company is committed to developing programs to increase
energy affordability for populations identified as vulnerable in its next IRP and Clean Energy
Implementation Plan. To being, the Company is developing an Equity Advisory Group and a low-
income energy efficiency pilot program. Id. at 1-8.

2 Figure 1.7 shows the Company forecasted greenhouse gas emissions from generation. The Company notes that for
comparison purposes, and due to uncertainty, Figure 1.7 shows emissions including Colstrip through 2025 and
excluding Colstrip starting in 2022.

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NOTICE OF INTERVENTION DEADLINE
ORDER NO. 35022 5
YOU ARE FURTHER NOTIFIED that the Company’s IRP and supporting workpapers
are available for public inspection during regular business hours at the Commission’s office. These
documents are also available on the Commission’s web site at www.puc.idaho.gov. Click on the
“ELECTRIC” icon, select “Open Cases,” then click on the case number as shown on the front of
this document.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held
pursuant to the Commission’s jurisdiction under Title 61 of the Idaho Code.
YOU ARE FURTHER NOTIFIED that all proceedings in this matter will be conducted
pursuant to the Commission’s Rules of Procedure, IDAPA 31.01.01.000 et seq.
NOTICE OF INTERVENTION DEADLINE
YOU ARE FURTHER NOTIFIED that persons who wish to intervene in this matter
to obtain the rights of party (e.g., to file formal discovery, or present evidence, or cross-examine
witnesses at a hearing) must file a Petition to Intervene with the Commission under the
Commission’s Rules of Procedure 72 and 73, IDAPA 31.01.01.072 and .073. Persons who wish
to intervene as a party must file a Petition to Intervene no later than 21 days from the service
date of this Order. Such persons shall also provide the Commission Secretary with their e-mail
address to facilitate further communications. After the intervention deadline runs, the Commission
Secretary shall issue a Notice of Parties that identifies the parties and assigns exhibit numbers to
each party. Once the Notice of Parties has issued, Commission Staff shall informally confer with
the Company and any intervening parties about how to further process this case and shall then
report back to the Commission on a proposed case schedule.
YOU ARE FURTHER NOTIFIED that persons who would like to present their views
without parties’ rights of participation and cross-examination are not required to intervene but may
present their views by submitting written comments to the Commission.
O R D E R
IT IS HEREBY ORDERED that persons desiring to intervene in this matter shall file
a Petition to Intervene no later than 21 days from the service date of this Order. Once the deadline
has passed, the Commission Secretary shall prepare and issue a Notice of Parties.
IT IS FURTHER ORDERED that, after the Notice of Parties has issued, Commission
Staff shall confer with the parties regarding a procedural schedule for this matter.

NOTICE OF FILING
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 35022 6
IT IS FURTHER ORDERED that parties should continue to comply with Order No.
34781, issued September 17, 2020. All pleadings should be filed with the Commission
electronically and shall be deemed timely filed when received by the Commission Secretary. See
Rule 14.02. Service between parties should also be accomplished electronically. Voluminous
discovery-related documents may be filed and served on CD-ROM or a USB flash drive.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 28th day
of April 2021.

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

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