20240917Reply Comments.pdf

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Avista Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
September 17, 2024
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A
Boise, Idaho 83714
RE: Case No. AVU-E-24-07 - Avista Utilities Proposed Tariff Schedule 66 “Power Cost
Adjustment”
Dear Commission Secretary:
Avista Corporation dba Avista Utilities (Avista or the Company) provides the following reply
comments in Case No. AVU-E-24-07, regarding Avista’s proposed annual tariff Schedule 66
Power Cost Adjustment Rate Filing. The comments contained herein are in response to the
comments filed by Commission Staff on September 11, 2024.
Avista would like to thank Staff for their thorough analysis and recommended approval of the
Company’s proposed PCA tariff schedule with modifications. The Company supports the tariff
changes and annual reporting recommendation proposed by Staff and will submit updated tariff
sheets upon approval of the updated PCA rates as noted by Staff.
In particular, through the process of discovery, the Company identified an inadvertent error in the
accounting for the Clearwater purchased power expense. The Company agrees with the adjustment
to the Clearwater expense due to an incorrect avoided cost rate for January through June of 2024,
resulting in an additional rebate to Idaho customers of $741,566, after the 90/10 sharing.
The Company is also supportive of the Chelan Hydro recommendation as detailed by Staff. The
Company and Staff met on numerous occasions over the past several weeks to discuss the
mechanics of the Chelan Hydro adjustment. The Company appreciates Staff’s acknowledgment
that “the mechanism may be unfairly accounting for the cost of the contract relative to the benefits
by using unit cost “lower of” monthly comparisons.” The Company supports the adjustment of
$581,315 (additional rebate to Idaho customers) as a reasonable compromise to resolve the Chelan
Hydro issue for this year’s PCA. The Company commits to meet with Staff and interested parties
after the case is closed to re-evaluate the mechanism to ensure it protects Idaho customers while
balancing benefits the contract may provide prior to filing the next PCA, as proposed by Staff.
RECEIVED
Tuesday, September 17, 2024
IDAHO PUBLIC
UTILITIES COMMISSION

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In regard to CCA Allowance Costs, Staff recommends the Company track the cost impact of using
a Boulder Park dispatch cost without the cost of allowances over the remaining PCA year to be
reported in next year’s PCA filing. The Company is supportive of Staff’s recommendation and
commits to the additional reporting as detailed in Staff’s comments.

Please direct any questions regarding these comments to Kaylene Schultz at
[e-mail] or 509-495-2482.

Sincerely,

/s/Patrick Ehrbar

Patrick Ehrbar
Director of Regulatory Affairs
Avista Utilities
509-495-8620
[e-mail]