20231114Comments of the Commission Staff.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION O U*C a
PO BOX 83720
BOISE,IDAHO 83720-0074 "'im(208)334-0320
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA'S ANNUAL )COMPLIANCE FILING TO UPDATE THE )CASE NO.AVU-E-23-13
LOAD AND GAS FORECASTS IN THE )INCREMENTAL COST INTEGRATED )RESOURCE PLAN AVOIDED COST MODEL )COMMENTS OF THE
TO BE USED FOR AVOIDED COST )COMMISSION STAFF
CALCULATIONS )
COMMISSION STAFF ("STAFF")OF the Idaho Public Utilities Commission,by and
through its Attorney of record,Michael Duval,Deputy AttorneyGeneral,submits the following
comments.
BACKGROUND
Integrated Resource Plan ("IRP")based avoided cost rates are available to qualifying
facilities that are above the resource-specific project eligibilitycap for published avoided cost
rates under Idaho's implementation of the Public Utility Regulatory Policies Act of 1978
("PURPA").
On December 18,2012,the Idaho Public Utilities Commission ("Commission")issued
Order No.32697 determining that the inputs to the IRP avoided cost methodology shall be
updated every two years upon the filing of each IRP,with an exception of the load forecast and
the natural gas forecast-which is to be updated annuallyby June 1 of each year.
STAFF COMMENTS 1 NOVEMBER 14,2023
On January 8,2013,Idaho Power filed Petition for Clarification and/or Reconsideration,
asking for the Commission to consider a different effective date,because Idaho Power completed
its natural gas forecast and load forecast in October of each year.
On February 5,2013,the Commission issued Order No.32737,granting clarification on
the issue of annual updates and directing all three utilities to collaborate and propose a suitable
date when all three utilities can provide their latest gas and load forecast updates.
On March 15,2013,the utilities filed notice that they all agreed that the update should
occur annuallyon October 15.
On May 6,2013,the Commission issued Order No.32802,requiring the annual update to
occur on October 15.
On December 28,2021,the Commission issued Order No.35274,keeping October 15 as
the annual update filing date,but changing the effective date to January 1 of each year so that the
filing deadline and the effective date are not identical.
On September 19,2023,Avista Corporation ("Company")filed a compliance filing
("Filing")requesting that the Commission issue an order accepting its updated load forecast,
natural gas price forecast,and contract information used as inputs to calculate its IRP-based
avoided cost rates.
STAFF ANALYSIS
Staff has reviewed the Company's load forecast,natural gas forecast,and contract
changes.Staff recommends that the Company submit an updated load forecast and an updated
natural gas price forecast in an amended compliance filing.
Load and Gas Forecasts
Staff recommends that the Company submit an updated load forecast and an updated
natural gas price forecast in an amended compliance filing,because the Filing presented
forecasts from last year's annual update case (Case No.AVU-E-22-15).Staff believes refiling
last year's forecasts does comply with Order No.32697,because the order requires utilities to
update the natural gas price forecast and the load forecast annuallyto maintain accuracy of
avoided cost rates.The Commission stated:
STAFF COMMENTS 2 NOVEMBER 14,2023
We find that,in order to maintain the most accurate and up-to-date
reflection of a utility's true avoided cost,utilities must update fuel price
forecasts and load forecasts annually-between IRP filings...In addition,
it is appropriateto consider long-term contract commitments because of the
potential effect that such commitments have on a utility's load and resource
balance...We further find it appropriateto consider PURPA contracts that
have terminated or expired in each utility's load and resource balance.
Order No.32697 at 22.
In addition,the Company previouslyfailed to comply with the Commission's annual
update requirements in Case No.AVU-21-14.The Company used the previous year's forecasts
for its annual update as was done in this case.Althoughthe Company was able to provide
updated forecasts throughdiscovery prior to the comment deadline in that case,the Company has
indicated that it will not be able to provide the updated forecasts until after the comment deadline
in this case.
The Company states that a new load forecast will be available in November of 2023.
Response to Staff Production Request No.1.The Company has also stated that that a new
natural gas forecast will be available in December of 2023.Response to Staff Production
Request No.2.Staff recommends that the Company file these updated forecasts through an
amended compliance filing and explain the difference between last year's forecasts and the
updated forecasts.If the Commission agrees with Staff's recommendation,Staff will propose
subsequent comment and reply comment deadlines to the Commission after an initial review of
the amended compliance filing.
Contract Information
Staff has reviewed the contract changes since last year's annual update filing,and Staff
believes that the contract changes are reasonable.Since last year's filing,the Company has
signed one new PURPA contract (Elf Solar)and two new non-PURPA contracts (Clearwater
Wind and Columbia Basin Hydro).The Company has also extended two PURPA contracts
(Clearwater Paper and Stimson Lumber)and one non-PURPA contract (Lancaster).
STAFF COMMENTS 3 NOVEMBER 14,2023
STAFF RECOMMENDATION
Staff recommends that the Company file these updated forecasts through an amended
compliance filing and explain the difference between last year's forecasts and the updated
forecasts.
Respectfullysubmitted this 14th day of November 2023.
Michael Duval
Deputy Attorney General
Technical Staff:Yao Yin
i:umisc/comments/AVU-E-23-13 Comments
STAFF COMMENTS 4 NOVEMBER 14,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF NOVEMBER 2023,SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TOAVISTACORPORATION,IN CASE NO.AVU-E-23-13,BY MAILING A COPYTHEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
MICHAEL G.ANDREA SHAWN BONFIELDSENIORCOUNSELSR.MANAGER,REGULATORYPOLICYAVISTACORPORATIONAVISTACORPORATIONPOBOX3727POBOX3727SPOKANEWA99220-3727 SPOKANE WA 99220-3727E-mail:michael.andrea avistacorp.com E-mail:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE