20240415Reply Comments.pdf

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RECEIVED
Monday,April 15,2024 4:25:57 PM
Avista Corp. IDAHO PUBLIC
1411 East Mission P.O. Box 3727 UTILITIES COMMISSION
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
April 15, 2024
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A
Boise, Idaho 83714
RE: Case No. AVU-E-24-03 —Reply Comments of Avista Utilities
Commission Secretary:
On April 8, 2024, Commission Staff submitted comments in the above-referenced case in which
Staff recommended (i) against approval of the proposed amendment that would relieve the QF
from its obligation to pay a use-of-facilities charge during periods of extended shutdowns, and(ii)
that Avista meet with Staff to discuss the development of a tariff to address recovery of use-of-
facility costs. Avista Corporation, doing business as Avista Utilities (Avista), appreciates
Commission Staff s Comments.
Avista understands Staff s concern regarding the recovery of costs of the facilities that are the
subject of the use-of-facilities charge. The proposed amendment to require Stimson to pay the
use-of-facilities charge only when Stimson operates its QF attempts to strike a balance that relieves
the QF from paying the use-of-facilities charge when its QF is shutdown for extended periods of
time while at the same time requiring payment when the QF does operate.The amendment attempts
to find a solution that preserves both the QF's ability to generate and sell its output,and the utility's
ability to collect the use-of-facilities charge if and when the QF does generate. The inclusion of a
minimum collection of$8,448' does not relieve the economic impact faced by the QF when it does
not generate. While this amount is not material to the overall PCA, it does create a significant
economic consideration for the QF's operations. The petition submitted by the Company attempts
to releave the burden for the QF with a minimal impact to the PCA.
In response to Staff s recommention that the Company meet with Staff to explore the potential
development of a tariff schedule for recovery of use-of-facilities related costs, Avista is open to
meeting with Staff on this issue. However, Avista notes that the use-of-facilities arrangement at
' Per the Company's response to Staff_PR_001, it is estimated that only $2,620.06 impacts the Idaho PCA after
allocations between Washington and Idaho,and cost sharing(90%customer, 10%Company).

issue in this proceeding is a unique arrangement. Avista does not anticipate any additional similar
arrangements in the future. Accordingly, a tariff schedule for recovery of use-of-facility costs is
not necessary at this time.
Sincerely,
Paul Kimball
Manager of Compliance & Discovery
Avista Utilities
509-495-4582
paul.kimballgavistacorp.com
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