20230629Notice_of_Filing_Order_No_35829.pdf

NOTICE OF FILING
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 35829 1
Office of the Secretary
Service Date
June 29, 2023
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF AVISTA’S 2023
ELECTRIC INTEGRATED RESOURCE
PLAN
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CASE NOS. AVU-E-23-05

NOTICE OF FILING

NOTICE OF
INTERVENTION DEADLINE

ORDER NO. 35829

On May 31, 2023, Avista Corporation d/b/a/ Avista Utilities (“Company”) filed its 2023
Electric Integrated Resource Plan (“2023 IRP”) with the Idaho Public Utilities Commission
(“Commission”). The 2023 IRP outlines and analyzes the Company’s strategy for meeting its
customers’ projected energy needs. The Company files an IRP every two years and uses it to guide
resource acquisitions. With this Order, the Commission provides notice that the Company has filed
its 2023 Electric IRP and sets deadlines for interested persons to petition to intervene in the case.
NOTICE OF FILING
YOU ARE HEREBY NOTIFIED that the Company’s 2023 IRP is approximately two
hundred and eighty (280) pages, with approximately one thousand five hundred (1,500) pages of
appendices. The 2023 IRP sets forth twelve sections: (1) Introduction; (2) Economic & Load
Forecast; (3) Existing Supply Resources; (4) Long-Term Position; (5) Distributed Energy
Resources; (6) Supply-Side Resource Options; (7) Transmission & Distribution Planning; (8)
Market Analysis; (9) Preferred Resource Strategy; (10) Portfolio Scenario Analysis; (11)
Washington Customer Impacts; and (12) Action Items. 2023 IRP at v-vi.
YOU ARE FURTHER NOTIFIED that the Company represents that it is a
multijurisdictional utility serving electric customers in Washington and Idaho, and the Company
endeavors to consolidate state requirements into one plan filed every other year. Id. at 1-1. The
Company states that it was able to adjust its filing date for the 2023 IRP in Idaho to June 2023 due
to finalizing the 2022 All-Source Request for Proposal. Id.
YOU ARE FURTHER NOTIFIED that the Company represents that the 2023 IRP process
includes a series of public meetings with a mix of the traditional technical experts, such as utility
commission staff, regional utility professionals, project developers, advocacy, and environmental
groups, concerned state agencies, and both commercial and residential customers. Id. The
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Company states that various issues are combined with assumptions made about them and included
in analysis and modeling that provides an expectation of future prices for different resources,
energy efficiency, demand response, and storage options. Id. at 1-2. The Company then develops
a preferred portfolio of resources to serve future needs. Id.
YOU ARE FURTHER NOTIFIED that the Company represents that the 2023 IRP satisfies
Idaho’s regulatory requirements as provided in Commission Order Nos. 22299 and 25260. Id. at
1-8.
YOU ARE FURTHER NOTIFIED that the Company represents that it made several
material changes to the methodology of the analysis since the 2021 IRP. Id. at 1-13. The Company
states that the major changes are the capacity and energy position methodology; updated energy
efficiency and demand response potentials; updates to supply-side resource options and costs;
refreshed wholesale market analysis; and additional methods for the portfolio optimization
analysis. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its economic and load forecast. The Company represents that the
energy forecast grows 0.85% per year, which is higher than the 0.24% annual growth rate in the
2021 IRP. Id. at 2-1. The Company represents that the higher growth largely reflects higher
residential and commercial electric vehicles (“EV”) forecasts, and new building electrification. Id.
The Company expects a 146 average megawatt (“aMW”) increase in total load from residential
and commercial EVs, and a net decrease of 21 aMW from residential and commercial solar by
2045. Id. the Company represents that peak load growth is 1.16% in the winter and 1.24% in the
summer. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its existing supply resources. The Company states that hydro represents
approximately half of the Company’s winter generating capability, and that natural gas-fired plants
represent the largest portion of the Company’s thermal generation portfolio. Id. at 3-1. The
Company has agreed to transfer ownership of Colstrip 3 & 4 to Northwestern Energy on January
1, 2026, and that recently signed hydro agreements with Chelan PUD and Columbia Basin Hydro
are included within the 2023 IRP plan. Id. The Company represents that it plans to upgrade Kettle
Falls Generating Station and Post Falls Hydroelectric Development, and that the Lancaster PPA is
extended through 2041 as a result of the recent Request for Proposal process. Id.
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YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its long-term position. The Company states that its Planning Reserve
Margin requirement is 22% in the winter, and 13% in the summer until the Western Resource
Adequacy Program (“WRAP”) is a binding program. Id. at 4-1. The Company’s first capacity and
energy resource deficiency begins in January 2034, and the WRAP’s qualifying capacity credits
are used for the Company’s resource capacity position. Id. The Company represents that it has
sufficient clean energy resources to meet its projected Washington’s Clean Energy Transformation
Act targets through 2033 under normal conditions. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its distributed energy resources. The Company represents that energy
efficiency currently serves 155 aMW of load, representing nearly 11.4% of customer demand. Id.
at 5-1. The Company states that over two thousand six hundred (2,600) energy efficiency measures
and sixteen (16) demand response options are considered for resource selection. Id. The Company
represents that its net metering program includes two thousand six hundred and two (2,602)
customers generating 18.8 megawatts, and that Community solar, roof-top solar, energy efficiency,
demand response, and distributed energy storage are options for utility resource selection. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its supply-side resource options. The Company represents that solar,
wind, and other renewable resource options are modeled as Purchase Power Agreements instead
of utility ownership. Id. at 6-1. The Company states that future competitive acquisition processes
might identify different technologies available at a different cost, size, or operating characteristics,
and may include existing generation options. Id. The Company represents that Inflation Reduction
Act tax incentives are included in resource costs, and that the Company models several energy
storage options including pumped storage hydro, lithium-ion, vanadium flow, zinc bromide flow,
liquid air, hydrogen, iron-oxide, and ammonia. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its transmission and distribution planning. The Company represents
that it actively participates in regional transmission planning forums. Id. at 7-1. The Company
states that it develops annual transmission and distribution system plans, and that Transmission
Planning estimates costs of locating new generation on the Company system for the IRP. Id. The
Company represents that it formed a Distribution Planning Advisory Group for additional
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stakeholder involvement, education, and transparency, and that increasing electrical infrastructure
to electrify both building and transportation in the Washington State service area is estimated to
cost an additional 4 cents per kWh. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its market analysis. The Company represents that solar and wind
dominate future generation across the West while natural gas and increasing amounts of storage
will ensure resource adequacy as existing coal and natural gas plants retired or reduce dispatch. Id.
at 8-1. The Company states that by 2045, this study assumes 94% of generation in the Pacific
Northwest will be carbon free, up from approximately 70-80% today, depending on hydro
conditions. Id. The Company represents that greenhouse gas emissions will fall to historic lows
with the expansion of renewables and continued coal and natural gas plant retirements. Id. The
Company represents that by 2045, expected emissions will be 62% less than in 1990. Id. The
Company states that the 22-year wholesale electric price forecast (2024-2045) is $35.34 per MWh,
and that expansion of renewables reduces future mid-day prices, but evening and nighttime prices
will be at a premium compared to today’s pricing. Id. The Company represents that natural gas
prices continue to remain low; for example, the levelized price at Stanfield (2024-2045) is $3.98
per dekatherm. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its preferred resource strategy. The Company represents that the 2022
All-Source RFP resource selections satisfy the customer’s load and capacity forecast through the
mid-2030s. Id. at 9-1. The Company states that energy efficiency’s impact on future load growth
is slowing due to saturation, and that the Named Community Investment Fund will increase
distributed energy resources such as energy efficiency, small-scale renewables, and energy
storage. Id. The Company represents that non-energy impacts are included to evaluate both
demand-side and supply-side resource selection for Washington resources, and that the Company
needs long-duration storage to serve customers in peak hours after 2035 to achieve 100% clean
energy targets. Id. The Company states that greenhouse gas emissions fall by 80% by 2045 with
the Preferred Resource Strategy, and that new transmission is needed to achieve Washington’s
100% clean energy goals. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its portfolio scenario analysis. The Company represents that all
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portfolios studied include greenhouse gas emission reductions. Id. at 10-1. The Company states
that moving to 100% clean energy will have significant rate impact to Idaho customers toward the
end of the plan, and that new and replacement natural gas peaking generation is cost effective for
Idaho customers even when considering social costs and potential national greenhouse gas fees.
Id. The Company represents that the WRAP continues to provide small financial benefits to the
Company in exchange for a more reliable energy marketplace. Id. The Company states that
electrification of either transportation and/or buildings will require significant amount of new
generation, transmission, and distribution resources. Id.
YOU ARE FURTHER NOTIFIED that the Company presents some highlighted
information with respect to its Washington customer impacts. The Company represents that its
2021 Clean Energy Implementation Plan was approved with thirty-eight (38) conditions by the
Washington Utility and Transportation Commission. Id. at 11-1. The Company states that seven
Customer Benefit Indicators (“CBI”) are applicable to resource planning, and that the non-energy
impacts are used to enhance resource selection by accounting for benefits to customers. Id. The
Company represents that its planning methodology for CBIs was reviewed by the newly formed
Equity Advisory Group. Id. The Company states that it created a Named Community Investment
Fund to increase energy related investments in disadvantaged communities. Id.
YOU ARE FURTHER NOTIFIED that the Company presents nine action items in the
2023 IRP. Id. at 12-4. The Company represents that the 2023 Action Plan was developed with
input from Commission Staff, the Company’s management team, and members of the TAC on the
analytical and other projects needed to further development and inclusion in the 2025 IRP. Id.
The Company’s action items include: (1) Incorporate the results of the DER potential study
where appropriate for resource planning and load forecasting; (2) Finalize the Variable Energy
Resource (VER) study; (3) Study alternative load forecasting methods, including end use load
forecast considering future customer decisions on electrification; (4) Investigate the potential use
of PLEXOS for portfolio optimization, transmission, and resource valuation in future IRPs; (5)
Continue to work with the Western Power Pool’s WRAP process to develop both Qualifying
Capacity Credits and Planning Reserve Margins for use in resource planning; (6) Evaluate long-
duration storage opportunities and technologies, including pumped hydro, iron-oxide, hydrogen,
ammonia storage, and any other promising technology; (7) Determine if the Company can estimate
energy efficiency for Named Communities versus low-income; (8) Study transmission access
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required to access energy markets as surplus clean energy resources are developed; and (9) Further
discuss planning requirements for Washington’s 2045 100% clean energy goals. Id.
YOU ARE FURTHER NOTIFIED that the 2023 IRP and supporting documentation have
been filed with the Commission and are available for public inspection during regular business
hours at the Commission’s office. These documents are also available on the Commission’s
website at www.puc.idaho.gov. Click on the “ELECTRIC” icon, select “Open Cases,” and click
on the case number as shown on the front of this document.
YOU ARE FURTHER NOTIFIED that the Commission has jurisdiction over the
Company, its filing, and the issues pertaining to this case pursuant to Title 61 of the Idaho Code,
and 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 desiring to intervene in this matter to
obtain parties’ rights of participation must file a Petition to Intervene with the Commission
pursuant to this Commission’s Rules of Procedure 71-73, IDAPA 31.01.01.072-073. Persons who
wish to intervene as a party must file a Petition to Intervene no later than 21 days after the
date of service of this Order. Persons desiring to present their views without parties’ rights of
participation do not have to intervene and may present their comments without prior notification
to the Commission or the parties.
YOU ARE FURTHER NOTIFIED that the Commission Secretary shall issue a Notice of
Parties after the deadline for intervention has passed. The Notice of Parties shall assign exhibit
numbers to each party in this proceeding.
YOU ARE FURTHER NOTIFIED that once the Notice of Parties is issued, Commission
Staff will informally confer with the parties to discuss a schedule to process this case and other
issues as may be raised by the parties.
YOU ARE FURTHER NOTIFIED that the following persons are designated as the
Company’s representatives in this matter:

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NOTICE OF INTERVENTION DEADLINE
ORDER NO. 35829 7
David J. Meyer, Esq.
Vice President and Chief Counsel for
Regulatory & Governmental Affairs
Avista Corporation
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
[e-mail]

Patrick D. Ehrbar
Director of Regulatory Affairs
Avista Utilities
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
[e-mail]
[e-mail]
ORDER
IT IS HEREBY ORDERED that persons desiring to intervene in this case for the purpose
of obtaining parties’ rights of participation must file a Petition to Intervene with the Commission,
under Rules 71-73, IDAPA 31.01.01.071-073, no later than 21 days after the service date of this
Order.
IT IS FURTHER ORDERED that, after the Secretary issues a Notice of Parties, Staff will
informally confer with the parties to discuss the appropriate scheduling of this case.
IT IS FURTHER ORDERED that parties comply with Order No. 35375, issued April 21,
2022. Generally, all pleadings should be filed with the Commission electronically and will be
deemed timely filed when received by the Commission Secretary. See Rule 14.02. Service between
parties should continue to be accomplished electronically when possible. However, voluminous
discovery-related documents may be filed and served on CD-ROM or a USB flash drive.
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NOTICE OF FILING
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 35829 8
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 29th day of
June 2023.

__________________________________________
ERIC ANDERSON, PRESIDENT

__________________________________________
JOHN R. HAMMOND JR., COMMISSIONER

__________________________________________
EDWARD LODGE, COMMISSIONER

ATTEST:

___________________________________
Jan Noriyuki
Commission Secretary

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