20170202Comments.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING OF AVISTA )
CORPORATION DBA AVISTA UTILITIES' 2016)
NATURAL GAS INTEGRATED RESOURCE )
PLAN )
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)
)
CASE NO. AVU-G-16-03
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Daphne Huang, Deputy Attorney General, submits the following comments.
BACKGROUND
On August 31 , 2016, Avista Corporation dba Avista Utilities filed its 2016 natural gas
Integrated Resource Plan (IRP). The Company files a natural gas IRP every two years to
describe the Company 's plans to meet its customers' future natural gas needs. The IRP must
discuss the subjects required by Commission Order Nos. 25342, 27024 and 27098, and Section
303(b)(3) of the Public Utility Regulatory Policies Act (PURPA), 15 U.S.C. § 3203(b)(3).
The Company's natural gas IRP , including appendices, is about 800 pages long. The IRP
contains an Executive Summary, and chapters on Demand Forecasts; Demand-Side Resources ;
Supply-Side Resources; Integrated Resource Portfolio; Alternate Scenarios, Portfolios, and
Stochastic Analysis; Distribution Planning; and the Company's Action Plan.
STAFF COMMENTS FEBRUARY 2, 2017
STAFF REVIEW
Staff reviewed the Company's 2016 natural gas IRP to determine if it complies with
requirements specified by prior Commission orders. Staff believes that the 2016 IRP contains
the required information.
Staff examined the Company's natural gas demand forecasts, supply-side resources,
distribution planning, and demand-side management (DSM), with each of these subjects
addressed in greater depth in sections below. The Company modeled multiple demand
scenarios -Average Case, Expected Case, High Growth/Low Price, Low Growth/High Price,
Alternate Weather Standard, and Expected Case/Low Price -to account for variations in
customer growth, usage and weather. The Company's analysis shows that with several
significant distribution upgrades, existing resources meet demand in all Idaho scenarios with the
exception of unserved demand in 203 7 in the high growth/low price scenario. Based on its
analysis, Staff believes the Company's estimates cover a range of possibilities and are
reasonable.
Natural Gas Demand
The Company determines demand forecasts by defining eight distinct demand areas in its
service territory. The demand forecast accounts for several factors influencing demand,
including natural gas prices, weather, customer growth and use, conservation technology,
industry innovations, and regulation.
The Company expects minimal growth in the residential, commercial, and industrial
segments. However, the Company recognizes that in today's natural gas market of low price and
abundant supply there is increasing interest in use of gas for power generation, transportation
fuel, industrial feedstock, and liquefied natural gas (LNG). While most of the markets would not
be customers of the Company, they could impact the natural gas infrastructure and pricing in its
service area.
The Company forecasts a 0.5% annual growth rate (net of projected DSM program
savings), with average day, system-wide core1 demand increasing from an average of 94,164
dekatherms per day (Dth/day) in 2016 to 102,840 Dth/day in 2035. IRP at 3. The Company
forecasts that coincident peak day, system-wide core demand will increase from a peak of
1 The Company's core (retail) customers are residential, commercial, and very few industrial customers.
Transportation-only customers are not included in peak day IRP planning.
STAFF COMMENTS 2 FEBRUARY 2, 2017
361,901 Dth/day in 2016 to 425,144 Dth/day in 2035 , for a 0.8% annual average annual growth
rate in peak day requirements (net of projected DSM savings). Id. Non-coincident peak day
system-wide core demand is forecasted to increase from a peak of 331 ,820 Dth/day in 2016 to
387,742 Dth/day in 2035 for a 0.8% average. Id. In the Washington/Idaho service territory,
number of customers is projected to increase at an average annual rate of 1.10 percent, with gas
demand increasing at a compounded average annual rate of 0.36 percent. Id. at 39.
Staff reviewed the Company's projections of its average system-wide consumption,
coincident peak day consumption, and non-coincident peak day consumption. Staff believes the
Company's projections are based on a reasonable analysis of growth and consumption patterns in
its Idaho service territory.
Natural Gas Supply Resources and Options
The Company states it has a "diversified portfolio of natural gas supply resources,"
including contracts to buy gas from several supply basins, stored gas, and firm capacity rights on
six pipelines. Id. at 6. In addition, the Company considers "incremental pipeline transportation,
storage options, distribution enhancements, and various forms of LNG storage or service" as
potential resource additions. Id. at 6.
The Company discusses projected resource needs including near term distribution
upgrades, and states that the Average Case and Expected Case demand scenarios show it will not
need additional upstream capacity or storage in the 20-year planning horizon. However, the
Company expects to spend approximately $4M in 2017 and $5 .5M in 2018 on distribution
projects in Idaho. The Company anticipates that, "where an upstream resource deficiency is
[ expected to be] nearly present," it will have "time to carefully monitor, plan and take action on
potential resource additions." Id. at 8-9.
In addition to Staffs review of the IRP, Staff also evaluates supply side resources
through participation in the IRP Technical Advisory Committee (TAC) team and semi-annual
discussions with the Company. The Company has positioned itself to address current and
changing market conditions. Specifically, the Company modified its procurement strategy which
includes hedging, storage, and index purchases to minimize cost and risk. Id. at 65 . In 2018, the
Company intends to research procuring a derivative base contract, 10-year forward strip, and
natural gas reserves. Id. at 13.
STAFF COMMENTS 3 FEBRUARY 2, 2017
Distribution Planning
The Company utilizes a computer based modeling tool (GL Noble Denton Synergi) to
monitor and study loads to assess distribution system needs and growth. The tool provides a
graphic representation of the Company's system which behaves very close to the actual system
allowing users to model alternatives. Transportation-only customers are excluded in long-term
planning exercises but are included in distribution planning exercises because they utilize the
Company's distribution system. The Company states, "Securing adequate natural gas supply and
ensuring sufficient pipeline transportation capacity to Avista's city gates become secondary
issues if distribution system growth behind the city gates increases faster than expected and the
system becomes severely constrained." Id. at 129. The Company also assesses its distribution
system integrity which generally occurs due to an increased number of customers and load
growth but can also be because maintenance upgrades are necessary. Id. at 130.
Staff agrees with the Company's perspective and believes it is important to closely
monitor the distribution system for capacity constraints even if transportation capacity exists
upstream of the city gate.
As mentioned previously, the Company is planning a number of projects in Idaho to
upgrade the distribution system. The Company is initiating a project (Coeur d'Alene High
Pressure Reinforcement) to reinforce the Coeur d'Alene system to address low pressure
conditions in the Hayden Lake system that generally occur when demand is high during cold
winter conditions. Id. at 136. The total project cost is approximately $8M from 2017 to 2018.
Id. The project includes two regulator stations and roughly 17,000 feet of high pressure steel
main. Id. The Company selected an option which utilizes the GTN-TransCanada pipeline since
Northwest Pipeline's CDA lateral is at capacity. Id. This choice provides a second gas source to
the Company's system and is the least cost routing solution. An additional 2018 distribution
project (Schweitzer Mountain Rd High Pressure Reinforcement) is scheduled at a cost of $1.SM.
Id. Currently, the Company is monitoring other Idaho city gate stations with minimal capacity
constraints and has tentatively scheduled projects for 2019 or later at the Athol #219, Bonners
Ferry #208, and Genesee #320 gate stations. Id. at 137.
Staff believes the Company should evaluate and more thoroughly describe alternatives,
including conservation, in order to determine the least-cost approach to meeting its distribution
capacity needs.
STAFF COMMENTS 4 FEBRUARY 2, 2017
Demand-Side Management
The Company suspended natural gas DSM programs in 2012. In the Company's 2012
Application it advised the Commission that gas costs were lower than the existing avoided costs
rendering its gas DSM program cost-ineffective. Order No. 32650. On October 28, 2015, the
Company filed an application to: (1) resume natural gas energy efficiency programs and projects
to residential (including low income), commercial, and industrial natural gas customers; and fund
these programs by increasing its "Energy Efficiency Rider" rates. Case No. A VU-G-15-03. The
Company claimed that its historic method of measuring DSM cost-effectiveness, through the
Total Resource Cost (TRC) test, has the potential for bias against conservation programs.
Consequently, the Company proposed the use of the Utility Cost Test (UCT). Additionally, the
Company proposed modifications to its avoided cost calculation to include the demand portion
of Schedule 150 Purchased Gas Cost Adjustment. The Commission approved the Company's
application to resume its natural gas energy efficiency programs on December 24, 2015. Order
No . 33444.
The Company contracted with Applied Energy Group (AEG) to complete a CPA
(Conservation Potential Assessment) with results published in April of 2016. AEG created a
baseline forecast and consumption projections by end use which excluded utility programs and
naturally occurring conservation. The Company states that; "The baseline forecast is the
foundation for the analysis of savings from future DSM programs as well as the metric against
which potential savings are measured." IRP at 4 7. The results of the CPA compared to the
baseline forecast are shown below:
Conservation Potential Summary for ldaho2
2015 Natural Gas Sales (Dth) 2017 to 2018 2017 to 2018 2017 to 2018
Cumulative Cumulative Cumulative
Achievable Savings Economic Savings Technical Savings
Potential ffith) Potential (Dth) Potential (Dth)
Residential 4,304740 62% 25 ,406 108,042 165,579
Commercial 2,456,621 35% 21,619 58,035 94,327
Industrial 187,203 3% 641 1,450 5,049
Total 6,948,564 100% 47,666 167,527 264,955
2 "Achievable potential" is the theoretical lower limit and applies ramp rates to establish an acquisition target that is
perceived to be more realistic. "Economic potential" incorporates cost-effective measures. "Technical potential" is
the theoretical upper limit and assumes all customers replace equipment with the most efficient option available
regardless of cost-effectiveness.
STAFF COMMENTS 5 FEBRUARY 2, 2017
The Company is exploring a number of DSM alternatives for the 2018 IRP. Id. at 144.
One possibility is targeted DSM which is in the process of being evaluated as an alternative to
distribution upgrades. For example it may be possible to defer upgrades if large commercial or
industrial customers located on capacity constrained laterals participated in DSM programs to
reduce gas consumption. The Company's Demand Side Management, Gas Supply, and Gas
Engineering groups are currently determining if a pilot program is feasible. However, the
Company has determined that the effects of standard DSM offerings will not resolve or defer
required Idaho upgrade projects. The Company states that it is evaluating avoided cost
approaches with the DSM Advisory Group in the spring of 2017 and with the 2018 IRP TAC at
its first 2018 meeting. Id. at 46. Staff supports the Company's continued evaluation of DSM
avoided costs. Additionally, Staff is encouraged by the Company's interest in evaluating
targeted DSM alternatives as an approach to deferring distribution capacity upgrades that have
been tentatively scheduled.
Action Plan
As stated in the above Background section, the Company's IRP includes an Action Plan
that contains a 2015-2016 review section detailing progress on last year's action items. In
summary, highlights of 2015-2016 results include implementation of a new storage optimization
program, continued progress on DSM avoided cost methodologies, completion of gate station
analysis, improved forecasting methodology awareness by providing TAC members with an
overview of the Sendout system, and inclusion of distribution system project overviews in this
IRP.
According to the Company, "Avista's 2017-2018 Action Plan outlines activities for
study, development and preparation for the 2018 IRP." Id. at 144. The following summary
includes key points from the 2017-2018 Action Plan. Summary of the Action Plan include:
• The price of natural gas has dropped significantly since the 2014 IRP.
Consequently, the Company will research market opportunities including
procuring a derivative base contract, 10-year forward strip, and natural gas
reserves.
• The Company's 2018 IRP will support the selection of conservation
(DSM) to meet unserved demand in individual portfolios.
STAFF COMMENTS 6 FEBRUARY 2, 2017
• Monitor actual demand for accelerated growth [to] address resource
deficiencies arising from exposure to "flat demand" risk.
• Continue to monitor supply resource trends including the availability and
price of natural gas to the region, LNG exports, methanol plants, supply
and market dynamics and pipeline and storage infrastructure availability.
• Monitor availability of resource options and assess new resource lead-time
requirements relative to resource need to preserve flexibility.
• Meet regularly with Commission Staff to provide information on market
activities and significant changes in assumptions and/or status of A vista
activities related to the IRP or natural gas procurement practices.
• Appropriate management of existing resources including optimizing
underutilized resources to help reduce costs to customers.
Staff is supportive of the Company's 2017-2018 Action Plan. Staff supports addressing
DSM avoided cost methodologies through participation in the DSM Advisory Group and IRP
TAC team. Additionally, Staff believes that exploring the potential for deferring additional
supply or distribution resources through targeted conservation programs is important given the
planned near term (2017-2018) distribution upgrades at a projected cost of over $8M.
Public Participation
The Company conducted four TAC meetings with the first held in Portland, Oregon and
the remaining three at Company headquarters in Spokane, Washington. Id. at 21. Each of the
four meetings was also available online via WebEx and by phone. Meetings were conducted in
an interactive manner to include feedback and input from TAC team members as well as
stakeholders. TAC team members were provided an opportunity to review a draft of the IRP, ask
questions, and offer suggestions prior to publication. Id. at 21.
The Company provided opportunities to any individual or entity interested in
participating in the planning process by posting meeting details and presentations on the
Company website. See Attachment A at 1. During the four TAC meetings there was a mix of
Avista employees, staff from commissions (Idaho, Oregon, and Washington), state agency staff
(Oregon and Washington), other regional gas utilities, pipeline companies, and trade
associations. Id. at 1-9. Average meeting participation was a mix of roughly 9 (30%) A vista
STAFF COMMENTS 7 FEBRUARY 2, 2017
employees and 22 (70%) stakeholders including Staff that participated in all four meetings. Id.
at 2-9.
Staff appreciates public access to presentations and availability of information on the
Company's website but believes additional outreach to Idaho customers, local and state officials,
and other stakeholders is appropriate. Incremental outreach could include bill stuffers, public
flyers, local media, individual invitations, and other methods to encourage and enhance public
participation. It is important for the public to understand how the Company forecasts future
resource requirements and spending and how rates could be affected. Additionally, Staff
suggests the Company consider conducting a workshop in the proximity of areas impacted by
future projects.
STAFF RECOMMENDATION
Staff believes that the Company's 2016 Natural Gas IRP satisfies the requirements for a
natural gas IRP set forth in Commission Order Nos. 25342, 27024, 27098, 32233, and 32698.
Staff recommends the Company's 2016 Natural Gas IRP be acknowledged and accepted for
filing.
V'4
Respectfully submitted this Y day of February 2017.
Technical Staff: Kevin Keyt
Michael Morrison
I: umisc: comments/avugl6.3djhkskmm comments
STAFF COMMENTS 8
Daphn uang
Deputy Attorney General
FEBRUARY 2, 2017
----------------------------------------·---···-··-·------
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
REQUEST:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO
A VU-G-16-03
IPUC
Production Request
Staff-OJ
DATE PREPARED:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
01/12/2017
NIA
Tom Pardee
Natural Gas Resources
[phone]
Page 1 of the Avista 2016 Natural Gas IRP Appendix lists organizations and representatives that
participated in the 2016 Natural Gas IRP TAC meetings. Please provide the telephonic and in­
person attendance records for each of the TAC meetings, including attendee names and
corresponding organizations. Additionally, please provide copies of any notifications, flyers, or
publications sent to the public regarding the 2016 Natural Gas IRP.
RESPONSE:
Please see Staff_PR_Ol Attachment A for the attendees at each Technical Advisory Committee
(TAC) meeting during the 2016 Natural Gas IRP.
Throughout the planning phase of the 2016 IRP, the presentations and meeting locations were all
posted to the Avista Utilities website (www.avistautilities.com) under the "Inside Avista" section
link to "Resources and Transmission Services". More importantly there is contact information for
any individual or entity requesting to participate in this planning process.
Page I ofl Attachment A
Case No. AVU-G-16-03
Staff Comments
02/02/17 Page l of 8
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2nct DAY OF FEBRUARY 2017,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. AVU-G-16-03, BY E-MAILING AND MAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
LINDA GERVAIS
MGR REGULATORY POLICY
A VISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE