20220224Comments.pdf

;i:;i'l:DTAYLOR R. BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11542
., .II:: :; Fl.; L: 3l
iClj
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE MATTER OF AVISTA UTILITIES
PETITION FOR AI\i EXTENSION TO FILE
ITS 2023 ELECTRIC INTEGRATEI)
RESOURCE PLAII
CASE NO. AYT]-E.-Z2-OI
COMMENTS OT THE
COMMISSION STAFF
COMES NOW the Staffof the Idaho Public Utilities Commission, ("StafP') by and
through its Attorney of record Taylor R. Brooks, Deputy Attomey General, and submits the
following comments:
BACKGROUNI)
On January 4,2022, Avista Corporation dlb/aAvista Utilities ("Company") petitioned
the Idaho Public Utilities Commission ("Commission") for a two-month extension to file its
2023 elecfrc integrated resource plan ("IRP"F-+uch that it would be filed June l, 2023, rather
than April 1,2023.
The IRP is a public process to identiff and evaluate various energy resource options to
meet future customer load requirements and indicate potential shortfalls. Company's Petition at
2. The Company submits its electric IRP to the Commission every two years pursuant to Order
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STAFF COMMENTS FEBRUARY 24,2022
No.22299.hd. As such, the Company's next IRP is required to be filed with the Commission on
or before April 1,2023.ld.
The Company uses All-Source Request for Proposals ("RFP") to comply with Purchase
of Resource (PoR) rules in Washinglon See WAC 480-107.t The Company's November l,
2021, RFP draft is scheduled to be released in the first quarter of 2022 and is scheduled to be
completed in the fourth quarter of 2022. Petition at2-3. Because of this schedule, the Company
is requesting a two-month extension to file its IRP with the Commission o'in order to provide
enough time for the conclusion of its 2022 [RFPs]. . . [which] enables any changes in resource
acquisitions that may impact IRP modeling . . .." Id. The Company states that without the
completed RFP, the IRP modeling results would be premature and incomplete. Id. at3.
STAFF RE\rIEW
Staffrecommends that the Commission allow the two-month extension requested by the
Company to file its 2023 IRP for three reasons: ( I ) the inclusion of the RFP results will result in
a more accurate resource plan; (2) it will allow Technical Advisory Committee (*TAC")
members additional time to provide input; and (3) there will be limited impact to upcoming
filings that are dependent upon the IRP. Therefore, Staff recommends that the Commission grant
the Company's request for filing the2023IRP to no later than the first business day of June
2023.
Inclusion of RFP Results
Delaying the frling of the 2023 IRP to allow for the included results of the RFP will result
in a more complete plan and will also eliminate uncertainty of the selected resources and their
costs which otherwise might require the Company to speculate in its IRP models. With
uncertainty mitigated, the result likely involves less overall risk and a more accurate basis for
other future resource evaluations examined in the IRP.
I https://www.mvavista.comiabout-us/integrated-resource-plannine/2022-all-source-rfp
2STAFF COMMENTS FEBRUARY 24,2022
IRP TAC
Staffsupports a thorough development and analysis of a resource plan with the lowest
cost and most risk averse analysis. The TAC membership consists of major industrial customers,
irrigation representatives, elected officials, members of the environmental community, public
utility commission representatives, and other interested parties. A series of public meetings have
been and are scheduled to be held throughoutZA22 and2023. Accordingly, the Company cannot
take full advantage of TAC's input and expertise prior to filing in April of 2023 and believes its
customers are best served by an IRP that includes the results of the RFP and allows ample time
for stakeholder input. Staffsupports the Company's willingness to continue holding public
meetings in order to collect stakeholder input. The Company should continue to hold TAC
meetings on the scheduled dates to keep the filing on time. Staffbelieves it is appropriate to
permit the IRP extension to allow the Company time to resolve issues and concerns that are
discussed in TAC meetings.
Related IRP Cases
Staff recognizes that the IRP delay may lead to a delayed update of the First Capacity
Deficiency Date ("Deficiency Date") used for avoided cost pricing under both the Strrogate
Avoided Resource Method and the IRP Method, since the Deficiency Date case is filed after
acknowledgement of each IRP. See Order Nos. 33917 and34649. A delay in the filing of this
case may result in extending the curently authorized Deficiency Date for a longer period; the
timing of which will depend on whether the new Deficiency Date is earlier or later than the
Deficiency Date currently authorized. However, Staffbelieves that delaying the authorization of
a new Deficiency Date by two months is not unreasonable, given the benefits of including the
RFP results in the IRP as discussed above.
STAFF RECOMMENDATIONS
Staffrecommends the Commission grant an extension for filing the 2023IRP from the
first business day of April 2023 to no later than the f,rrst business day of June 2023.
aJSTAFF COMMENTS FEBRUARY 24,2022
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Tehical Staff: Mi&aol Eldred
Thvis Culber6on
imir,bomcurrvrZlllD@c mem
4STAFF COI\{IVIENTS FEBRUARY 24,2022
CERTIFICATE OF SERYICE
I TIEREBY CERT-IFY TI{AT I HAVE THIS 24TH DAY OF FEBRUARY 2022,
SERVED TI{E FOREGOING COMMENTS OT TIIE COMMISSION STAFF, IN
CASE NO. AVU-E-22.01, BY E.MAILING A COPY THEREOF, TO TIIE
FOLLOWING:
SHAWN BONFIELD
SR MGR REGULATORY POLICY
AVISTA CORPORATION
POBO]{3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
dockets@avi stacorp. com
DAVID J MEYER
VP & CHIEF COI.]NSEL
AVISTA CORPORATION
POBOX3727
sPoKAl.IE W A 99220-37 27
E-mail: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE