20231213Final_Order_No_36023.pdf

ORDER NO. 36023 1
Office of the Secretary
Service Date
December 13, 2023

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF AVISTA’S ANNUAL
COMPLIANCE FILING TO UPDATE THE
LOAD AND GAS FORECASTS IN THE
INCREMENTAL COST INTEGRATED
RESOURCE PLAN AVOIDED COST MODEL
TO BE USED FOR AVOIDED COST
CALCULATIONS
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CASE NO. AVU-E-23-13

ORDER NO. 36023

On September 19, 2023, Avista Corporation (“Company”) submitted a compliance filing
requesting an order accepting its updated load forecast, natural gas price forecast, and contract
information components used as inputs to calculate its incremental cost Integrated Resource Plan
(“IRP”) avoided cost rates (“Filing”). The Company must update these inputs by October 15 of
each year. See Order Nos. 32697, 32802, and 35274. IRP avoided cost rates are available to
qualifying facilities (“QF”) that are above the resource-specific project eligibility cap for published
avoided cost rates under Idaho’s implementation of the Public Utility Regulatory Policies Act of
1978 (“PURPA”). The Company requested its Filing be processed by Modified Procedure with an
effective date of January 1, 2024.
On October 11, 2023, the Commission issued a Notice of Filing and Notice of Modified
Procedure establishing public comment and Company reply deadlines. Order No. 35952. Staff
filed comments, and the Company replied that it supported Staff’s recommendations.
Having reviewed the record in this case, the Commission approves the Company’s annual
update subject to a compliance filing as described below.
BACKGROUND
Pursuant to the PURPA and the Federal Energy Regulatory Commission’s (“FERC”)
implementing regulations, this Commission has approved the IRP Method to calculate avoided
cost rates for QFs that are above the resource-specific project eligibility cap. QFs that are below
the applicable project eligibility cap are eligible to receive published avoided cost rates calculated
using the surrogate avoided resource (“SAR Method”). See Order No. 32697 at 7-8. The avoided
cost rate is the purchase price paid to QFs for the energy, or the energy and capacity, that the QF
provides to the utility. 18 C.F.R. § 292.101(b)(6)(defining “avoided cost”). To ensure that avoided

ORDER NO. 36023 2
costs most accurately reflect the utility’s marginal cost of energy or capacity, the Commission has
directed utilities to “update fuel price forecasts and load forecasts annually – between IRP filings,”
and to update the Commission about their “long-term contract commitments because of [their]
potential effect . . . on a utility’s load and resource balance.” Order No. 32697 at 22.
THE FILING
The Company represented the energy load forecast increases at 0.74% annual average
growth rate for years 2024 through 2045.
The Company stated its natural gas forecast was developed using a combination of “the
U.S. Energy Information Administration’s Annual Energy Outlook. . . and forward market prices
as of July 26, 2022.” Filing at 3.
The Company noted that, since its 2022 filing, the Company has signed one new long-term
PURPA contract and extended three existing Power Purchase Agreements. The Company also
indicated that it has plans to extend two PURPA contracts that are set to expire at the end of 2023.
STAFF COMMENTS
Staff recommended that the Company file updated forecasts for its load and natural gas
prices in a compliance filing.
i. Load and Gas Forecasts
Staff noted that Order No. 32697 requires utilities to file their applicable load and natural
gas forecasts annually. The purpose of the annual filing is, at least in part, to ensure that the
Commission is reviewing current data. Staff argued that the Company’s filing in this case is too
reliant on data from last year’s filing. Staff also noted that the Company failed to comply with
Commission requirements in Case No. AVU-E-21-14 by using old data from last years’ filing.
Staff noted that, through discovery, the Company indicated that it would not be able to
update its load and natural gas forecasts until November and December, respectively. Staff
recommended that, once the Company has this information, it should submit a compliance filing
explaining the difference between last year’s forecasts and its updated forecasts.
ii. Contract Information
Staff reviewed the Company’s new and extended contracts and believed that the new
contracts—and changes to existing contracts—appeared to be reasonable.

ORDER NO. 36023 3
COMPANY REPLY
The Company supported Staff’s recommendation and stated that it would shortly provide
the data necessary for a compliance filing. The Company indicated that it expected to file its update
on or before December 20, 2023.
COMMISSION FINDINGS AND DISCUSSION
The Commission has jurisdiction over this matter under Idaho Code §§ 61-501, -502 and -
503. The Commission is empowered to investigate rates, charges, rules, regulations, practices, and
contracts of public utilities and to determine whether they are just, reasonable, preferential,
discriminatory, or in violation of any provision of law, and to fix the same by order. Idaho Code §§
61-502 and -503. In addition, the Commission has authority under PURPA and FERC regulations
to set avoided costs, to order electric utilities to enter fixed-term obligations for the purchase of
energy from QFs, and to implement FERC rules. The Commission may enter any final order
consistent with its authority under Title 61 and PURPA.
Pursuant to this authority, we have reviewed the record in this case including the Filing,
Staff’s comments, and the Company’s reply comments. We find that this Filing does not comply
with the requirements of Order No. 32697 in that has failed to use sufficiently current data. Rather,
this Filing duplicates certain data from last year’s filing. The Company stated in its reply comments
that it would be able to assemble the necessary information and submit a compliance filing on or
before December 20, 2023. The Company shall compile the relevant data and then submit a
compliance filing that enumerates the differences between its updated forecasts and the forecasts
that were submitted last year.
O R D E R
IT IS HEREBY ORDERED that the Company must file an updated load and natural gas
forecasts in a compliance filing that also explains the differences between its updated forecasts
and the Company’s forecasts from last year.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order about any matter
decided in this Order. Within seven (7) days after any person has petitioned for reconsideration,
any other person may cross-petition for reconsideration. Idaho Code § 61-626.

ORDER NO. 36023 4
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 13th day of
December 2023.

__________________________________________
ERIC ANDERSON, PRESIDENT

__________________________________________
JOHN R. HAMMOND JR., COMMISSIONER

__________________________________________
EDWARD LODGE, COMMISSIONER

ATTEST:

Monica Barrios-Sanchez
Interim Commission Secretary

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