20200116Petition.pdf

Aitttsra
Avista Corp.
l4l I East Mission P.O. Box 3727
Spokane. Wash ington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
Januxy 15,2020
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
I l33l W Chinden Blvd.
Boise, ID 83714
Re: Avista Application No. AVU-G-20Q1
Dear Ms. Hanian:
Attached for filing is an original and seven (7) copies of Avista Corporation Nblal Avista
Utilities Petition for an Extension of its Natural Cas Integrated Resource Plan Filing from
August 31, 2020 to April 1,2021. Ifyou have any questions regarding this filing, please contact
me at 509-495-4975, Tom Pardee at 509-495-2159.
Sincerely,
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Linda Gervais
Sr. Manager, Regulatory Policy & Strategy
Avista Utilities
509-495-4975
linda. [e-mail]
ziv
II. BACKGROUND
'Ihe Company submits the IRP to the Commission every two years as outlined in Case No.
tJ-I500-165. OrderNo. 22299. Avista's next IRP is due to be filed with the Commission on or
before August 31,2020. the IRP is a methodology for identilying and evaluating various
resource options and is a process by which to establish a plan of action for resource decisions.
Avista uses SENDOUI'@ (a PC based programming model widely used to solve natural gas
supply and transportation optimization questions) for peak day demand, resource valuation and
for conducting Monte-Carlo style risk analyses. SENDOUT@ modeling results are used to selcct
the Preferred Resource Strategy (PRS).
Avista uses a public prooess to solicit technical expertise and feedback throughout the
development ol the IRP through a series of Technical Advisory Committee (TAC) meetings.
For the reasons stated herein. Avista requests a six-month extension from August 31. 2020
to April 1.2021 to submit the Company's Natural Gas IRP to provide enough time ibr the
conclusion of various state legislative sessions so that Avista can integrate any changed
regulations that may impact its IRP modeling and assumptions.
III. SUPPORT FOR EXTE,NSION
Therc are currently numerous legislative proposals in the States of Washington and Oregon
that will have major impacts on natural gas planning, including Washington's Senate Clean
Energy Transformation Act (CETA) or Senate Bill 5116, Washington House Bills 1257 and
1444, and Oregon Senate Bill 98. Final rules and expectations for natural gas distribution
utilities with respect to each of these bills are expected to take several more months to create
and implement, which will aflect the ability to fully realize the impacts to the IRP process.
-l
PEl'I'TION OF AVISTA CORPORATION
PA(iE 2
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY AND GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
I4I I E. MISSION AVENUE
P.O.BOX3727
SPOKANE, WASHINGTON 99220
PHONE: (509) 49s-4316
IN TIIE MATTER OF TIIE PE I ITION OF
AVIS'IA CORPORATION FOR AN
EXTENSION 1'O FILE ITS NATURAL GAS
INTEGRATED RESOURCE PLAN
David Meyer
Vice President and ChiefCounsel lbr
Regulalory & Govemmental Affairs
Avista Corp.
P. O. Box 3727
1411 E. Mission Avenue, MSC XX
Spokane, Washington 99220 -3727
1'elephone: [phone]
E-mail: david.meyer@a vistacom.com
PETITION OF AVISTA CORPORAl'ION
I}EFORE THE IDAHO PUBLIC UTILITIES COMMISSION
) CASE NO. AVU-G-2o
)
)
) PETITION OF
) AVISTA CORPORA'|ION
I. INTRODUCTION
Avista Corporalion, doing business as Avista Utilities ("Avista" or "Company"). at l4l I
East Mission Avenue, Spokane. Washington, respectfully petitions the Idaho Public Utilities
Commission (Commission) to issue an order authorizing a six-month extension from August
31.2020 to April1,2021to submit the Company's Natural Gas lntegrated Resource Plan (lRP).
The Company requests that this filing be processed under the Commission's Modified
Procedure rules through the use of written comments.
Please direct all correspondence related to this Petition as lollows:
PACE I
Linda Gervais
Senior Manager of Regulatory Policy
Regulatory Affairs
Avista Corp.
P. O. Box 3727
141 I E. Mission Avenue" MSC 27
Spokane. Washington 99220 -37 27
Telephone: [phone]
E-mail: [e-mail]
6 CETA requires 100% carbon free electricity serving Washington customers by 2045 and
references renewable natural gas investments for distribution or consumption. Washington
House Bills 1257 and 1444 call for new energy efficiency requirements with new requirements
for buildings and appliance standards and will affect Avista's conservation potential assessment
(CPA) going forward, taking effect by 2022. A set of renewable natural gas and fuels bills,
including Oregon SB 98. and Washington HB 1257. open up a path forward to acquire these
supply side resources as a means to reduce carbon emissions.
With all of these legislative uncertainties, IRP modeling at this time would be premature.
The impact ofsuch legislation could fundamenlally change the regional (and Avista's) resource
mix, and therefore have an impact on Avista's customers. Thus, to the extent any ofthe potential
legislation is enacted, new models would need to be run to account for the actual impact ofsuch
legislation. Further, recall that in almost every scenario provided in the Company's 2018 IRP,
Avista did not have transportation resource needs in the 20 year planning horizon.
Avista is currently assessing the alignment ofportions of its electric and natural gas IRPs
to reduce redundancy in analyics and economic assumptions. The newly requested filing date
lor the natural gas IRP is April 1, 2021. In Avista's 2018 Natural Gas IRP the expected case
displayed no resource shortages.
I
PE'TITION OF AVISTA CORPORATION
PACI 3
IV. CONCLUSION
9 WHEREFORE, Avista respectfully requests the Commission issue its Order approving a
six-month extension of the Company's from August 31,2020 to April 1, 2021 to submit the
Company's Natural Gas Integrated Resource Plan (lRP) as explained in this Petition and the
request thal it be processed under Modified Procedure through the use of written comments.
DATED this 1 5th day of January 2020
By
David J.
Vice President and ChiefCounsel fbr
Rcgulatory and Governmental Affairs
PETITION OF AVISTA CORPORAIION
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