20210423Notice_of_Filing_Order_No_35021.pdf

NOTICE OF FILING
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 35021 1
Office of the Secretary
Service Date
April 23, 2021
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF AVISTA
CORPORATION DBA AVISTA UTILITIES’
2021 NATURAL GAS INTEGRATED
RESOURCE PLAN
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CASE NO. AVU-G-21-02

NOTICE OF FILING

NOTICE OF INTERVENTION
DEADLINE

ORDER NO. 35021

On March 31, 2021, Avista Corporation dba Avista Utilities (“Company”) filed its
2021 Natural Gas Integrated Resource Plan (“IRP”). The Company filed its IRP by the deadline
set in Order No. 34697, which extended the Company’s typical, August 31, 2020 filing deadline
to April 1, 2021.1 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 USC § 3202. With this Order, the Commission provides notice of the IRP filing and sets
deadlines for interested persons to petition to intervene.
NOTICE OF IRP FILING
YOU ARE HEREBY NOTIFIED that the Company’s natural gas IRP contains an
Executive Summary, and chapters on Demand Forecasts; Demand-Side Resources; Supply-Side
Resources; Carbon Reduction; the Company’s Integrated Resource Portfolio; Alternate Scenarios,
Portfolios, and Stochastic Analysis; Distribution Planning; and the Company’s Action Plan. The
following information comes from the IRP’s Executive Summary. Further detail may be obtained
in the IRP’s remaining chapters and appendices.
YOU ARE FURTHER NOTIFIED that the Company states its IRP identifies a strategic
natural gas resource portfolio that meets expected customer demand requirements over the next 20
years. The IRP involves input from the Company’s Technical Advisory Committee (“TAC”),
which includes Commission Staff, peer utilities, customers, and other stakeholders. Topics
discussed with the TAC include natural gas demand forecasts, demand-side management, supply-
side resources, modeling tools, distribution planning, and policy issues. The Company states the

1 Per Commission Order No. 32233, Avista must file its IRP by August 31 of every even-numbered year.

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IRP process results in an integrated resource portfolio designed to serve customers’ natural gas
needs while balancing cost and risk. IRP at 1-2.
YOU ARE FURTHER NOTIFIED that the Company states the IRP addresses
uncertainties surrounding supply and demand by evaluating multiple scenarios with wide-ranging
possible outcomes. Id. at 2.
YOU ARE FURTHER NOTIFIED that the Company discusses its demand forecasts.
The Company estimates average day, system-wide core demand increasing from 95,126
dekatherms per day (Dth/day) in 2021 to 102,054 Dth/day in 2040. The Company forecasts that
coincidental peak day, system-wide core demand will increase from a peak of 363,586 Dth/day in
2021 to 407,216 Dth/day in 2040. Forecasted non-coincidental peak day demand peaks at 349,210
Dth/day in 2020 and increases to 388,615 Dth/day in 2040. Id at 2-4.
YOU ARE FURTHER NOTIFIED that the Company presents its natural gas price
forecasts. The Company states gas prices are a significant part of the total cost of a resource option,
which affects the avoided cost threshold for determining cost-effectiveness of conservation
measures and how customers consume natural gas. The Company expects carbon legislation in
Oregon and Washington and stated its current IRP price forecast includes higher carbon adders in
those states, but not in Idaho. The Company combined forward prices with three fundamental price
forecasts to develop high and low expected price strips at the Henry Hub. The Company notes it
used an expected elasticity response factor to model how customers’ consumption of natural gas
will respond to price changes. Id. at 5-6.
YOU ARE FURTHER NOTIFIED that the Company discusses existing and potential
natural gas supply resources. The Company states it has a diversified portfolio of gas supply
resources, including contracts to buy gas from several supply basins, owned and contracted storage
providing supply source flexibility, and firm capacity rights on six pipelines. The Company
considers incremental pipeline transportation, renewable natural gas, storage options, hydrogen,
distribution enhancements, and various forms of liquified natural gas (“LNG”) storage or services
as potential resource additions. Id. at 6.
YOU ARE FURTHER NOTIFIED that the Company discusses projected resource
needs. In the high growth and low-price and carbon reduction (cost of carbon) scenarios, resource
deficiencies were identified. The high growth and low-price scenario observed an energy shortage
which would require additional assets to supply more energy. The carbon reduction scenario did
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not include an energy shortage, but a need for carbon neutral or carbon reducing resources.
However, the Company was not resource deficient in the expected case for the 20-year planning
horizon. The Company indicated it would integrate additional information on goals and legislation
that come into focus. Id. at 7-9.
YOU ARE FURTHER NOTIFIED that the Company states that even with the
planning, analysis, and conclusions reached in the IRP, uncertainty still exists. The Company states
it will diligently monitor issues and challenges, including: (1) demand scenarios that will provide
insight into how quickly resource needs can change if demand varies from the expected case; (2)
how natural gas demand in international markets will affect regional gas infrastructure and natural
gas pricing; (3) use of natural gas to back up renewable resources and for replacement of retired
coal plants; and (4) other issues that might affect demand and pricing. Id. at 11-12.
YOU ARE FURTHER NOTIFIED that the IRP contains a 2021-2022 Action Plan
outlining activities identified by the IRP team with input from Company management and TAC
members. The Company states the Action Plan positions the Company to provide the best cost/risk
resource portfolio and to support and improve IRP planning. The Company states ongoing
activities include:
• Monitoring supply and resource trends including the availability and price
of natural gas, LNG exports, methanol plants, supply and market dynamics,
and pipeline and storage infrastructure availability;

• Monitoring availability of resource options;

• Meeting regularly with Staff to provide information on market activities and
significant changes in assumptions and/or status of activities related to the
IRP or natural gas procurement; and

• Managing existing resources and optimizing underutilized resources.
Id. at 174-75
The Company states new activities for the study, development, and preparation of the 2023 IRP
include:
• Completing additional modeling on carbon reduction (Oregon and
Washington);

• Investigating new resource plan modeling software and integrating the
Company’s system to run parallel with current modeling software;

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• Modeling all requirements from Executive Order 20-04 (Oregon);

• Ensuring the Energy Trust (“ETO”) has sufficient funding to acquire therm
savings of the amount identified and approved by the Energy Trust Board;

• Exploring the feasibility of using projected future weather conditions in its
design day methods;

• Discuss integration of Energy Trust (ETO) and Conservation Potential
Assessment data, program experience, knowledge of current and
development markets, and future codes and standards; and

• Performing high pressure distribution or city gate station capital work as
needed.

Id. at 12-13, 174-75.
YOU ARE FURTHER NOTIFIED that the Company’s IRP and supporting workpapers
are available for public inspection during regular business hours at the Commission’s office. These
documents are also available on the Commission’s web site at www.puc.idaho.gov. Click on the
“NATURAL GAS” icon, select “Open Cases,” then click on the case number as shown on the
front of this document.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held
pursuant to the Commission’s jurisdiction under Title 61 of the Idaho Code.
YOU ARE FURTHER NOTIFIED 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 who wish to intervene in this matter
to obtain the rights of party (e.g., to file formal discovery, or present evidence, or cross-examine
witnesses at a hearing) must file a Petition to Intervene with the Commission under the
Commission’s Rules of Procedure 72 and 73, IDAPA 31.01.01.072 and .073. Persons who wish
to intervene as a party must file a Petition to Intervene no later than 21 days from the service
date of this Order. Such persons shall also provide the Commission Secretary with their e-mail
address to facilitate further communications. After the intervention deadline runs, the Commission
Secretary shall issue a Notice of Parties that identifies the parties and assigns exhibit numbers to
each party. Once the Notice of Parties has issued, Commission Staff shall informally confer with
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the Company and any intervening parties about how to further process this case and shall then
report back to the Commission on a proposed case schedule.
YOU ARE FURTHER NOTIFIED that persons who would like to present their views
without parties’ rights of participation and cross-examination are not required to intervene but may
present their views by submitting written comments to the Commission.
O R D E R
IT IS HEREBY ORDERED that persons desiring to intervene in this matter shall file
a Petition to Intervene no later than 21 days from the service date of this Order. Once the deadline
has passed, the Commission Secretary shall prepare and issue a Notice of Parties.
IT IS FURTHER ORDERED that, after the Notice of Parties has issued, Commission
Staff shall confer with the parties regarding a procedural schedule for this matter.
IT IS FURTHER ORDERED that parties should continue to comply with Order No.
34781, issued September 17, 2020. All pleadings should be filed with the Commission
electronically and shall be deemed timely filed when received by the Commission Secretary. See
Rule 14.02. Service between parties should also be accomplished electronically. Voluminous
discovery-related documents may be filed and served on CD-ROM or a USB flash drive.

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NOTICE OF INTERVENTION DEADLINE
ORDER NO. 35021 6
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 23rd day
of April 2021.

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

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