20250228AVU to Staff 5 Attachment A - 2024 OR 4th Qtr - Combined.pdf

ORDER NO. 24-352
ENTERED Oct 16 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UM 2318
In the Matter of
AVISTA CORPORATION, dba AVISTA ORDER
UTILITIES,
Application for Authorization to Defer
Certain Costs Associated with Energy
Efficiency Services to Natural Gas
Transport Customers.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its public meeting on October 15, 2024,the Public Utility Commission of Oregon
adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
tiiTY c
��� ° Alison Lackey
Chief Administrative Law Judge
°F*°REGOls
A party may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each parry to the
proceedings as provided in OAR 860-001-0180(2).A party may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-352
ITEM NO. CA4
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
PUBLIC MEETING DATE: October 15, 2024
REGULAR CONSENT X EFFECTIVE DATE N/A
DATE: September 25, 2024
TO: Public Utility Commission
FROM: Kathy Zarate
THROUGH: Caroline Moore, Scott Gibens, and Michelle Scala SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UM 2318)
Requests authorization of Deferred Accounting of Costs Associated with
Energy Efficiency Services for Natural Gas Transport Customers
STAFF RECOMMENDATION:
Staff recommends the Commission approve Avista Utilities' (Avista, AVA, or Company)
request for the authorization of deferred accounting for costs associated with Energy
Efficiency Services for Natural Gas Transport Customers, for the 12-month period
beginning on March 11, 2024.
DISCUSSION:
Issue
Whether the Commission should approve the Company's request for authorization of
deferred accounting of costs associated with Climate Protection Program-related energy
efficiency services for Natural Gas Transport Customers for the 12-month period
beginning March 11, 2024.
Applicable Law
In accordance with ORS 757.259 and OAR 860-027-0300, Avista Corporation, dba
Avista Utilities (Avista or Company), hereby submits for electronic filing an Application
for authorization of deferred accounting for all costs associated with energy efficiency
services provided to Natural Gas Transport Customers. The services provided are
directly attributable to the Climate Protection Program (CPP).
APPENDIX A
Page 1 of 5

ORDER NO. 24-352
Docket No. UM 2318
September 25, 2024
Page 2
Pursuant to ORS 757.259(2)(e) and OAR 860-027-0300, the Company hereby applies
to the Public Utility Commission of Oregon for an order authorizing deferred accounting
treatment for all costs associated with the Company's compliance with the Climate
Protection Program (CPP) with respect to acquiring energy efficiency services for
Natural Gas Transport Customers.
The Company respectfully requested that the deferral be effective for the 12-month
period commencing on March 11, 2024.
Analysis
Background
On December 16, 2021, the Oregon Department of Environmental Quality (ODEQ)
adopted the CPP, which are administrative rules that set GHG reduction targets.' The
CPP sets a declining limit, or cap, on greenhouse gas emissions from fossil fuels used
throughout the state of Oregon, including diesel, gasoline, natural gas and propane,
used in transportation, residential, commercial and industrial settings (the program is
not inclusive of fossil fuel used in electric generation).2
The CPP also regulates site-specific greenhouse gas emissions at large stationary
sources, such as emissions from industrial processes.
The Company is a "covered fuel supplier" under the CPP and is the point of regulation
for the emissions associated with natural gas used by its sales and transport customers.
Transport customers purchase the commodity they use directly from marketers and
suppliers and have historically only paid Avista for delivery via the distribution system.
Covered entities' emissions are reported annually through the existing ODEQ
greenhouse gas reporting program and compliance will be demonstrated by each
covered entity at the end of each three-year compliance period.
The Company can work to reduce natural gas usage through efficiency measures,
introduce renewable and low carbon alternative fuels, trade for additional compliance
instruments with other covered entities, or purchase a limited amount of Community
Climate Investments (CCIs).3
On September 13, 2022, Avista's filed an application seeking authorization of deferred
accounting for CPP costs related to energy efficiency measures for Natural Gas
OAR 340-271-0010—9000.
2 OAR 340-271-0110.
3 OAR 340-271-0450.
APPENDIX A
Page 2 of 5

ORDER NO. 24-352
Docket No. UM 2318
September 25, 2024
Page 3
Transport Customers, for the 12-month period beginning on September 13, 2022. On
April 21, 2023, the Commission approved Avista's request per Order No. 23-145.
However, the rules were invalidated by the Oregon Appeals Court (Court) on
December 23, 2023, as the Court found that the rules did not comply with
ORS 468A.315(1). Avista was one of the petitioners in the suit challenging the CPP
administrative rules.4
Nevertheless, in January 22, 2024, ODEQ issued notice that it accepted the Court's
decision, and it will begin the process to reinstate the CPP in the first quarter of 2024,
anticipating the rulemaking process will take about 12 months.
In the first reauthorization request in docket UM 2254, the Company again asked for
these costs associated with the CPP program be deferred. Staff proposed that the
Commission approve the deferral request up to the date the Court invalidated DEQ's
CPP rules. The Commission adopted Staff's recommendation in Order No. 24-228,
issued on July 10, 2024.
In a subsequent filing by Cascade, Docket No. UM 2257(1) a similar issue arose related
to deferral requests for CPP-related costs that included a time period over which the
CPP rules continued to not be in effect having been invalidated by the Court. In the Staff
review of that filing, Staff considered the issue further and recommended a different
approach which is to support the deferral request. The reasoning is provided below and
is taken from the Staff memo adopted by the Commission in Order No. 24-292, issued
on August 28, 2024.
Because the Court of Appeals ruled the CPP rules invalid, Staff
considered whether it was appropriate for Cascade to defer CPP costs
incurred after December 20, 2023. Staff believes that there are compelling
reasons to allow the Company to continue to track costs incurred after the
CPP was invalidated and before the successor rules to the CPP go into
effect. First, Staff notes that DEQ plans to pick the CPP back up as if there
was no delay in implementation and believes that certain actions taken
after the CPP was invalidated on December 20, 2023, may allow the
Company to more cost effectively comply with the successor rules to the
CPP. Second, the Company clarified to Staff that some costs were
committed to prior to when the CPP was invalidated, but not incurred until
after the CPP was invalidated. While Staff makes no determination about
the prudence of these costs or any other costs at this time, Staff believes
that it is reasonable to track these costs for later ratemaking.
4 Docket No. UM 2254.
APPENDIX A
Page 3 of 5

ORDER NO. 24-352
Docket No. UM 2318
September 25, 2024
Page 4
In making this recommendation, Staff notes that a new set of rules to
succeed the CPP is expected to go into effect January 1, 2025. Staff also
highlights that many of the costs that the Company sought to defer in its
application, such as the purchase of CCls, were not needed or incurred
during the deferral period, and other costs, such as EE investments, have
broad benefits that the Company should pursue even without a deferral.
Staff's recommendation to allow the Company to track costs incurred after
December 20, 2023, should not be interpreted as determining that any
particular cost incurred post-invalidation will be determined prudent.
In this filing, dated March 12, 2024, the Company makes two requests. First, the
Company asks for approval to defer costs associated with complying with the CPP with
respect to energy efficiency services provided to Natural Gas Transport Customers
(which is essentially a reauthorization request of UM 2254); and the second request is
to move all of the recorded deferral costs in UM 2254 into this deferral filing.-,
With respect to the first request, Staff believes that similar circumstances arise here as
in the Cascade example cited above. Avista is continuing a program already in
existence and started prior to any Court ruling. With respect to the second request, Staff
supports Avista's reasoning that moving the recorded expenditures will result in
administrate ease.
Reason for Deferral
Under ORS 757.259(2)(e), deferral of utility expenses or revenues is allowed when it
will appropriately match the costs borne and benefits received by customers.
Proposed Accounting
The Company records CPP compliance costs to FERC Account 182.3 (Other
Regulatory Assets), crediting FERC Account 407.4 (Regulatory Credits).
Estimate of Amounts
The current CPP Deferral balance from which the Company is requesting to transfer all
costs already recorded in support of providing energy efficiency services for transport
customers is approximately $266,847.
This amount includes both monthly distributions to Energy Trust for services rendered to
transport customers, as well as approximately $16,847 (included into $266,847)
expended as the transport customers' allocation for a third-party study to verify non-
energy impacts (NEls) for transport customers' avoided costs.
5 Docket No. UM 2318.
APPENDIX A
Page 4 of 5

ORDER NO. 24-352
Docket No. UM 2318
September 25, 2024
Page 5
Information Related to Future Amortization
• Earnings review — Cost recovery for costs associated with the costs of
compliance with the Climate Protection Plan will be subject to an earnings review
in accordance with ORS 757.259(5).
• Prudence Review—A prudence review will be performed by the OPUC Staff no
later than the proceeding to authorize amortization of the costs associated with
the costs of compliance with the CPP.
• Sharing — No Sharing mechanism.
• Rate Spread/Design — The rate spread/rate design will be determined during the
proceeding to authorize amortization of the costs associated with the deferral.
• Three Percent Test (ORS 757.259(6)) — Amortization of the deferred costs will be
subject to a three percent test in accordance with ORS 757.259(7) or possible six
percent test in accordance with ORS 757.259(8) and with Commission
authorization. These tests limit aggregated deferral amortizations during a
12-month period to no more than three or six percent of the utility's gross
revenues for the preceding year.
Conclusion
After Staff's review of Avista's application requesting authorization to defer, because the
application meets the requirements of ORS 757.259 and OAR 860-027-0300, Staff
recommends Avista's application be approved.
The Company has reviewed this memo and agrees with or expresses no objections to
Staff's recommendation.
PROPOSED COMMISSION MOTION:
Approve Avista's application for authorization to use deferred accounting for Climate
Protection Program (CPP) related costs, associated with energy efficiency programs for
Natural Gas Transport Customers, for the 12-month period beginning on
March 11, 2024.
Direct Avista to move to this docket any remaining costs previously deferred under
Docket No. UM 2254.
AVA UM 2318 CPP Deferral
APPENDIX A
Page 5 of 5

ORDER NO. 24-367
ENTERED Oct 31 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UG 496
In the Matter of
AVISTA CORPORATION dba AVISTA ORDER
UTILITIES,
Advice No. 24-03-G,Updates
Schedule 475, Decoupling Mechanism.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its Special Public Meeting on October 29, 2024,the Public Utility Commission of
Oregon adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
�,�NLIT Y cod Alison Lackey
Chief Administrative Law Judge
OR GO
A parry may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each party to the
proceedings as provided in OAR 860-001-0180(2).A parry may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-367
ITEM NO. CA1
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
SPECIAL PUBLIC MEETING DATE: October 29, 2024
REGULAR CONSENT X EFFECTIVE DATE November 1, 2024
DATE: October 15, 2024
TO: Public Utility Commission
FROM: David Abraham
THROUGH: Caroline Moore, Scott Gibbens, Anna Kim, and Ted Drennan SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UG 496/Advice No. 24-03-G)
Revises Schedule 475, Decoupling Mechanism.
STAFF RECOMMENDATION:
Staff recommends approval of Avista Utilities (Avista, AVA, or Company) proposed
Schedule 475 tariff, as described in the filing of Advice No. 24-03-G, effective for service
rendered on and after November 1, 2024.
DISCUSSION:
Issue
Whether the Commission should approve Avista's Advice No. 24-03-G, updating its
Schedule 475 to reflect the amortization of decoupling revenue associated with the
Company's decoupling mechanism.
Applicable Rule or Law
ORS 757.205(1) states that a public utility must file schedules showing all rates, tolls,
and charges for service that have been established and are in force at the time. The
Commission reviews tariffs filed under ORS 757.205 and ORS 757.210 to determine
whether they are fair, just, and reasonable.
ORS 757.220 requires that filings that make any change in rates, tolls, charges, rules,
or regulations be filed with the Commission at least 30 days before the effective date
of the change.
APPENDIX A
Page 1 of 6

ORDER NO. 24-367
Docket No. UG 496/Advice No. 24-03-G
October 15, 2024
Page 2
ORS 757.259(5) states that unless subject to an automatic adjustment clause,
amounts deferred under ORS 757.259 shall be allowed in rates only to the extent
authorized by the Commission in a proceeding under ORS 757.210 to change rates
and upon review of the utility's earnings at the time of application to amortize the
deferral. The Commission may require that amortization of deferred amounts be
subject to refund. The Commission's final determination on the amount of deferrals
allowable in the rates of the utility is subject to a finding by the Commission that the
amount was prudently incurred by the utility.
ORS 757.259(6) states that the overall average rate impact of the amortizations
authorized under this section in any one year may not exceed three percent of the
utility's gross revenues for the preceding calendar year.
OAR 860-022-0025 requires that revised tariff filings include statements showing the
change in rates, the number of customers affected and resulting change in annual
revenue, and the reasons for the tariff revision.
OAR 860-022-0030 requires that tariff filings which result in increased rates include
statements showing the number of customers affected, the annual revenue under
existing schedules, the annual revenue under proposed schedules, the average
monthly bills under existing and proposed schedules, and the reasons supporting the
proposed tariff.
Commission Order No. 08-263, modified by Order No. 10-279, sets out the interest
rate to use for deferral accounts and the interest rate to use when such amounts are
amortized.
Analysis
Background
Avista recovers a portion of its fixed costs through volumetric rates. During each rate
case, rates are set in a manner that if the Company has the expected number of
customers, and on average the customers use the expected amount of gas, the
Company will recover all of its fixed costs. If customers use less gas than forecasted,
the Company will not recover all of its fixed costs. Decoupling is a rate adjustment
mechanism that breaks the link between the amount of energy a utility sells, and the
revenue it collects to recover the fixed costs of providing service to customers.
Avista's decoupling mechanism was approved by the Commission in early 2016.' It
applies to residential and non-residential customers, but excludes some of the
Order No. 16-076.
APPENDIX A
Page 2 of 6

ORDER NO. 24-367
Docket No. UG 496/Advice No. 24-03-G
October 15, 2024
Page 3
Company's largest customers.2 As it is a full-decoupling mechanism, the Company
may recover its approved decoupling-related revenue regardless of what factors drive
variations in sales.3 The current filing represents the eighth consecutive year in which
the decoupling deferral will affect the Company's Oregon natural gas rates.4 The
Commission has decided that in the case of amortization of the requested deferral,
which is a component of an automatic adjustment clause, no earnings test or sharing is
required.-5
The difference between Avista's approved decoupling-related revenue per customer
and decoupling-related revenue received through volumetric rates, is recorded as a
deferral for each calendar year. The amount of the deferral, plus interest, is amortized
over the next 12-month amortization period.6
The deferral is tracked separately for residential and non-residential customers on a
monthly basis and totaled at the end of the year. As the amount of the deferral is
calculated in an identical manner for each month and customer type, Staff has outlined
the calculation performed for April 2023 in order to illustrate the deferral calculation in
Table 1 on the following page.
2 The decoupling mechanism applies to residential customers under Schedule 410, and non-residential
customers under Schedules 420, 424, 440, and 444. It excludes customers under Schedules 447 and
456.
3 National Renewable Energy Laboratory. "Decoupling Policies: Options to Encourage Energy Efficiency
Policies for Utilities". www.nrel.gov/docs/fy10osti/46606.pdf.
4 In its inaugural year(2016) the decoupling deferral covered the ten months from March through
December. In subsequent years it covers 12 months of the year, from January through December.
5 ORS 757.259 (5).
6 The 2024 calendar year deferral, which was approved in UM 1753, will be amortized between
November 1, 2024 and October 31, 2025.
APPENDIX A
Page 3 of 6

ORDER NO. 24-367
Docket No. UG 496/Advice No. 24-03-G
October 15, 2024
Page 4
Table 1 . April 2023 Deferral Calculation
Residential Non-Residential
Approved Revenue per Customer $ 31.58 $ 131.13
x Customers in month? 94,786 12,157
Approved Decoupling Revenue $ 2,993,622 $ 1,594,104
- Actual Decoupling Revenue Received $ 3,175,288 $ 2,027,157
Deferral $ (181,666) $ (433,054)
+ Adjustment for Expenses and Interest $ (6,683) $ (2,173)
= Deferred Revenue for April 2023 $ (188,348) $ (435,227)
The Company has demonstrated that in 2023 it over-collected revenue totaling
$1,367,435 from residential customers, and over-collected revenue totaling
$2,582,679 from non-residential customers. The amortization of 2023
decoupling-related deferred revenue will impact each customer type as detailed
below.
Residential
The current filing proposes a 2.657 cents per therm credit for residential customers,
representing a 2.7 percent decrease in residential rates. The credit is designed to
return $1,434,678 to residential customers. Avista's filing included a table that
summarizes the components of the Company's requested rebate; however, Staff
identified a transposing error in the Residential table. The Interest and Revenue
Related Expense entries included positive numbers that should be negative. The total
requested recovery does contain the correct credit request of $1,434,678 and Staff
was able to confirm the correct credit is included in the Attachment A rate calculation
and in the decoupling tariff.
Non-residential
The current filing proposes a 5.223 cents per therm credit for non-residential
customers, representing a 4.7 percent decrease in non-residential rates. The credit is
designed to return $2,667,603 to non-residential customers. A summary of all of the
aforementioned adjustments is displayed below in Table 2.
The lesser of either actual or allowed customers. New customers in excess of the rate year customer
forecast are excluded, in accordance with Order No. 16-076.
8 Adjusted to exclude revenue from new customers in excess of the rate year customer forecast, in
accordance with Order No. 16-076.
APPENDIX A
Page 4 of 6

ORDER NO. 24-367
Docket No. UG 496/Advice No. 24-03-G
October 15, 2024
Page 5
Table 2. Surcharge Rate Decomposition
Schedule 2 Schedule 3
Total Deferred Revenue $ (1,367,435) $ (2,582,679)
+ Prior Year Residual Balance $ 65,203 $ 173,335
+ Interest (to end of amortization period) $ (87,737) $ (174,499)
+ Revenue Related Expenses $ (44,709) $ (83,759)
= Total Surcharge/(Rebate) $ (1,434,678) $ (2,667,603)
Forecasted Sales in Amortization Period* 53,996,166 51,074,147
= Surcharge/(Rebate) Dollars per Therm $ (0.03) $ (0.05)
* Therms
In accordance with Order No. 16-076, the Company has tracked and reported the
proportion of the decoupling deferral which relates to either weather or conservation.
Staff has summarized this information below.
Table 3. Weather and Conservation Deferral Decomposition
Residential Non-Residential
Total Deferred Surcharge/ (Rebate) $ (1,367,435) $ (2,582,679)
Weather-related Surcharge/ (Rebate) $ (940,401) $ (532,961)
Conservation-related Surcharge/ (Rebate) $ (427,033) $ (2,049,717)
Conclusion
The approval of Avista's proposed Schedule 475 will result in a 2.7 percent decrease in
rates for residential customers, and a 4.7 percent decrease in rates for non-residential
customers.
Staff has reviewed the methodology used in this filing to ensure that it complies with the
Company's decoupling tariff. Staff notes that there has been no change to the
methodology used since the most recent approved filing.9
Staff has confirmed that there is no proposed change to the language of the tariff.
Staff has also verified the accuracy of the calculations performed by Avista, including
the calculations used to determine decoupled revenue that was deferred in UM 1753;
9 In the Matter ofAvista Utilities Decoupling Mechanism, Docket UG 468, Advice No. 23-03-G.
APPENDIX A
Page 5 of 6

ORDER NO. 24-367
Docket No. UG 496/Advice No. 24-03-G
October 15, 2024
Page 6
the calculation of interest and other revenue related charges for the projected
amortization, and the calculation of the per-therm rebate.
Finally, Staff confirmed the accuracy of the input data, with reference to the Company's
quarterly decoupling mechanism reports,10 and the approved rates in effect during the
period."
Staff has found no issues with Avista's proposed Schedule 475, and consequently
recommends that it is approved with an effective date of November 1, 2024.
The Company has reviewed this memo and agrees with its content.
PROPOSED COMMISSION MOTION:
Approve Avista's Advice No. 24-03-G relating to its Schedule 475, revising rates to
reflect the amortization of certain non-gas cost deferred accounts, for service rendered
on and after November 1, 2024.
AVA UG 496 Advice No.24-03-G Sch.475 Decoupling
10 See Docket RG 78.
11 Rates approved in Order No. 23-391, in Docket UG 468,were in effect during the period covered by this
filing.
APPENDIX A
Page 6 of 6

ORDER NO. 24-368
ENTERED Oct 31 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UG 497
In the Matter of
AVISTA CORPORATION dba AVISTA ORDER
UTILITIES,
Advice No. 24-04-G,Updates to Rates on
Schedule 476, Intervenor Funding.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its Special Public Meeting on October 29, 2024,the Public Utility Commission of
Oregon adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
��tiv�Tv cod Alison Lackey
Chief Administrative Law Judge
'U N
� z
GREGO
A parry may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each party to the
proceedings as provided in OAR 860-001-0180(2).A parry may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-368
ITEM NO. CA2
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
SPECIAL PUBLIC MEETING DATE: October 29, 2024
REGULAR CONSENT X EFFECTIVE DATE November 1, 2024
DATE: September 25, 2024
TO: Public Utility Commission
FROM: Mitchell Moore
THROUGH: Caroline Moore, Scott Gibbens, Anna Kim, and Ted Drennan SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UG 497/Advice No. 24-04-G)
Requests Amortization of Intervenor Funding, Revises Schedule 476.
STAFF RECOMMENDATION:
Staff recommends the Commission approve Avista Corporation's, dba Avista Utilities
(Avista, AVA, or Company), Advice No. 24-04-G, requesting amortization of Intervenor
Funding for inclusion in rates for service rendered on and after November 1, 2024.
DISCUSSION:
Issue
Whether the Commission should approve Avista's request to update Schedule 476 to
amortize deferred costs for grant funds paid to intervenors.
Applicable Rule or Law
ORS 757.072 allows energy utilities to enter into agreements for financial assistance to
organizations representing customer interests in Commission proceedings, contingent
upon Commission approval.
ORS 757.205 requires public utilities to file all rates, rules, and charges with the
Commission. ORS 757.210 provides that the Commission may approve tariff changes if
they are fair, just, and reasonable.
APPENDIX A
Page 1 of 4

ORDER NO. 24-368
Docket No. UG 497
September 25, 2024
Page 2
Under ORS 757.259, the Commission may authorize deferred accounting for later
incorporation into rates. Specifically, ORS 757.259(3) allows for deferral of costs that
fall under the cost category of financial assistance to organizations representing
customer interests.' Per ORS 757.259(4), deferred costs qualifying under
ORS 757.259(3) are not subject to an earnings review2 or three percent test.3 prior to
amortization of deferred costs.
OAR 860-022-0025 requires that revised tariff filings include statements showing the
change in rates, the number of customers affected and resulting change in annual
revenue, and the reasons for the tariff revision.
OAR 860-022-0030 requires that tariff filings which result in increased rates include
statements showing the number of customers affected, the annual revenue under
existing schedules, the annual revenue under proposed schedules, the average monthly
bills under existing and proposed schedules, and the reasons supporting the proposed
tariff.
OAR 860-027-0300 sets forth the deferred accounting procedures for public utilities.
Analysis
Background
An Intervenor Funding Agreement (IFA) governs intervenor funding grants under which
energy utilities may pay organizations representing customer interests in Commission
proceedings.4 The IFA sets forth eligibility criteria, regulatory procedures, and payment
issuance and review.
Expenses included for amortization in Docket No. UG 497 were deferred by the
Company during the 12-month period ending June 30, 2024, plus a rollover amount
from the previous deferral period. Use of intervenor funding grants for this deferral
period are in accordance with the Fifth Amended and Restated Intervenor Funding
Agreement, which was approved by the Commission in Order No. 22-506, and by
Commission Order No. 23-033 which approved a separate intervenor funding
agreement specific to environmental justice and low-income advocate organizations.
ORS 757.072.
2 ORS 757.259(5).
3 ORS 757.259(6).
4 Intervenor funding grants include the CUB Fund, Preauthorized Matching Fund, Issues Fund and
HB2475 Fund.
APPENDIX A
Page 2 of 4

ORDER NO. 24-368
Docket No. UG 497
September 25, 2024
Page 3
The Commission most recently approved deferral of Avista's intervenor funding costs in
Docket No. UM 1356(16), Order No. 23-411, for the 12 months beginning
November 1, 2023.
In this request, Avista proposes to amortize amounts deferred under Docket
No. UM 1356(16), with an effective date of November 1, 2024. The net effect of the new
temporary adjustment for intervenor funding, proposed to go into effect November 1, 2024,
will result in an increase in the Company's annual revenues in the amount of
approximately $21,000. As a result, Avista customers may experience the following bill
impacts:
• The average residential customer served under Rate Schedule 410, using an
average of 47 therms/month, will see a monthly increase of approximately $0.01.
• The average interruptible commercial or industrial customer served under Rate
Schedule 440, using an average of 30,567 therms/month, will see a monthly
increase of approximately $4.89.
• The average commercial and industrial customer for interruptible transportation
of customer owned natural gas served under Rate Schedule 456, using an
average of 84,900 therms/month, will see a monthly increase of approximately
$421.09.
Staffs prudence review focused on verification of the accounting methodology used to
determine the final amortization balance. Staff reviewed Avista's application and
supporting work papers to determine if the amortized amounts reconciled with the
previous year's balances, are consistent with intervenor funding grants that were paid
by the Company, that interest was applied correctly, and that the proposed rate
increments are applied correctly. Additionally, Staff checked the Company's records
against the OPUC Filing Center's Intervenor Funding Summary.5
The proposed rates for the amortization of the Intervenor Funding Account are
$0.00174 per therm for the residential Rate Schedule 410 customers, and $0.00111 for
Rate Schedules 440 and 456 industrial customers.
The number of customers affected by the proposed changes are 95,294 residential
customers, and 78 commercial and industrial customers combined.
5 Available at: https://www.oregon.gov/puc/filing-center/Pages/Intervenor-Funding.aspx.
APPENDIX A
Page 3 of 4

ORDER NO. 24-368
Docket No. UG 497
September 25, 2024
Page 4
Deferred expenses for residential customer are recorded in FERC Account 191723.
Deferred expenses for industrial customers are recorded in FERC Account 191724.
Staff reviewed the Company's work papers and found them to be sufficient in
demonstrating the validity of the amounts recorded and correct application of interest.
Staff also finds the Company's accounting to be consistent with Commission records of
intervenor funding activity.
As noted in the Applicable Rule or Law section above, deferred expenses for intervenor
funding grants are not subject to an earnings review or three percent test, and therefore,
no earnings review was performed for this application.
Conclusion
Staff finds that Avista's accounting, including the application and rate of interest, is
accurate. Staff also finds that the proposed rate increments are correctly calculated and
applied. For these reasons, Staff recommends the Commission approve this filing.
The Company reviewed this memo and agrees with its contents.
PROPOSED COMMISSION MOTION:
Approve Avista's Advice No. 24-04-G, requesting amortization of Intervenor Funding for
inclusion in rates for service rendered on and after November 1, 2024.
AVA UG 497 Intervenor Funding Amortization
APPENDIX A
Page 4 of 4

ORDER NO. 24-369
ENTERED Oct 31 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UG 498
In the Matter of
AVISTA CORPORATION dba AVISTA ORDER
UTILITIES,
Advice No. 24-05-G,Updates
Schedule 482, Oregon Regulatory Fees.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its Special Public Meeting on October 29, 2024,the Public Utility Commission of
Oregon adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
6u� -el\-
x,ITY Coy, Alison Lackey
Chief Administrative Law Judge
O�*OREG0
A parry may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each party to the
proceedings as provided in OAR 860-001-0180(2).A party may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-369
ITEM NO. CA3
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
SPECIAL PUBLIC MEETING DATE: October 29, 2024
REGULAR CONSENT X EFFECTIVE DATE November 1, 2024
DATE: September 25, 2024
TO: Public Utility Commission
FROM: Mitchell Moore
THROUGH: Caroline Moore, Scott Gibbens, Anna Kim, and Ted Drennan SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UG 498/Advice No. 24-05-G)
Requests Amortization of Amounts Deferred for Oregon Regulatory Fees;
Revises Schedule 482.
STAFF RECOMMENDATION:
Staff recommends the Public Utility Commission of Oregon (Commission) approve
Avista Corporation's, dba Avista Utilities (Avista, AVA or Company),
Advice No. 24-05-G, requesting amortization of the Commission Regulatory Fee for
inclusion in rates for service rendered on and after November 1, 2024.
DISCUSSION:
Issue
Whether to approve Avista's request to update Schedule 482 to amortize deferred costs
for changes in the Commission Regulatory Fee.
Applicable Rule or Law
Under ORS 756.310, each public utility must pay a fee to the Commission each
calendar year. The amount of the fee is equal to the amount that the Commission
deems necessary, together with the amount of all other fees paid or payable to the
Commission, to defray the costs of performing the duties imposed by law upon the
Commission with respect to the public utilities.
APPENDIX A
Page 1 of 4

ORDER NO. 24-369
Docket No. UG 498
September 25, 2024
Page 2
ORS 757.205 requires public utilities to file all rates, tolls, and charges with the
Commission. ORS 757.210 provides that the Commission may approve tariff changes if
they are fair, just, and reasonable.
Under ORS 757.259, the Commission may authorize deferred accounting for later
incorporation into rates. Unless subject to an automatic adjustment clause, amounts
deferred under ORS 757.259 shall only be allowed in rates to the extent authorized by
the Commission and upon review of the utility's earnings at the time of application to
amortize the deferral. The overall average rate impact of the amortizations authorized
under this section in any one year may not exceed three percent of the utility's gross
revenues for the preceding calendar year.
OAR 860-022-0025 requires that revised tariff filings include statements showing the
change in rates, the number of customers affected and resulting change in annual
revenue, and the reasons for the tariff revision.
OAR 860-022-0030 requires that tariff filings which result in increased rates include
statements showing the number of customers affected, the annual revenue under
existing schedules, the annual revenue under proposed schedules, the average monthly
bills under existing and proposed schedules, and the reasons supporting the proposed
tariff.
OAR 860-021-0034 sets forth the regulatory requirements and procedures for annual
fees payable to the Commission by gas or steam heat utilities.
OAR 860-027-0300 sets forth the deferred accounting procedures for public utilities.
Analysis
Background
Pursuant to ORS 756.310 and OAR 860-021-0034, as a gas utility, Avista must pay the
Commission a regulatory fee each year by April 1. The fee is determined by the
Commission and assessed as a percentage of the utility's gross operating revenues
attributable to Oregon. The rate is set annually, by March 1, in Docket No. UM 1012. In
2022, per Order No. 22-062, the annual fee was set at 0.43 percent of 2021 gross
operating revenues. This rate was increased to 0.45 percent, effective March 1, 2024,
in Order No. 24-054.'
In 2020, per Order No. 20-054, the Commission approved a rate of 0.35 percent. That rate was
increased in 2021, per Order No. 21-066 to 0.375 percent and again in 2022, per Order No. 22-062, to
0.43 percent. This rate was increased to 0.45 percent, effective March 1, 2024, in Order No. 24-054.
APPENDIX A
Page 2 of 4

ORDER NO. 24-369
Docket No. UG 498
September 25, 2024
Page 3
The Company submits an annual filing to defer costs associated with incremental
changes in the annual regulatory fee. The Commission most recently reauthorized the
deferral application in Docket No. UM 2053(4), Order No. 24-227. The deferral allows
the Company to recover any differences between the Commission regulatory fee
percentage collected in base rates and the Commission regulatory fee percentage set in
Docket No. UM 1012.
The purpose of the Company's filing is to request amortization of amounts deferred
pursuant to Commission Order No. 23-054 in UM 2053(3). The requested amortization
is the difference between the 0.43 percent collected in base rates under Docket
No. UG 461, and the current rate of 0.45 percent approved in UM 1012, plus the
forecasted surplus balance.
The effect of applying the new temporary rate adjustments is to decrease the
Company's annual revenues by $65,000 or about 0.01 percent. The amounts sought
for recovery represent an equal-percentage-of-revenue basis. The proposed rate
adjustment will affect 107,355 total customers:
Customer Type Count
Residential 95,294
Commercial 11,981
Industrial 80
The following table illustrates the average monthly bill impact to Avista's Residential
(Rate Schedule 410-411), Commercial (Rate Schedule 420), and Industrial (Rate
Schedule 424) customers:
Current Proposed
Avg. Avg.
Customer Avg. Monthly Monthly Difference
Type therms/month Bill Bill $
Residential 47 $70.11 $70.08 $.03
Commercial 204 $262.84 $262.72 $.12
Industrial 3,641 $2,227.85 $2,225.67 $2.18
Staff reviewed the work papers provided by the Company and found them sufficient to
demonstrate the validity of its calculations. Staff's review consisted of verifying the
accounting methodology employed by the Company to derive the final amortization
balance. Staff further confirmed that, pursuant to ORS 757.259(6), this filing does not
impose a rate increase greater than three percent of Avista's gross revenues. An
APPENDIX A
Page 3 of 4

ORDER NO. 24-369
Docket No. UG 498
September 25, 2024
Page 4
earnings review was not performed, other than the annual earnings review conducted
each spring, as the Commission regulatory fee is not subject to sharing.2
Conclusion
Staff concludes that the proposed rates are correctly calculated and applied to amortize
deferred costs associated with the Commission Regulatory fee. For these reasons,
Staff recommends the Commission approve this filing.
The Company has reviewed this memo and agrees with its content.
PROPOSED COMMISSION MOTION:
Approve Avista Advice No. 24-05-G, requesting amortization of the Commission
Regulatory Fee for inclusion in rates for service rendered on and after
November 1, 2024.
AVA UG 498 Advice 24-05-G Regulatory Fee
2 It is a fee that each public utility must pay pursuant to ORS 756.310 and OAR 860-021-0034.
APPENDIX A
Page 4 of 4

ORDER NO. 24-370
ENTERED Oct 31 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UG 499
In the Matter of
AVISTA CORPORATION dba AVISTA ORDER
UTILITIES,
Advice No. 24-06-G, Requests
Amortization of Schedule 493, Low-
Income Rate Assistance Program(LIRAP)
Rate Adjustment.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its Special Public Meeting on October 29, 2024,the Public Utility Commission of
Oregon adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
ITY C, Alison Lackey
Chief Administrative Law Judge
a • z
O�*OREGo�
A parry may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each parry to the
proceedings as provided in OAR 860-001-0180(2).A parry may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-370
ITEM NO. CA4
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
SPECIAL PUBLIC MEETING DATE: October 29, 2024
REGULAR CONSENT X EFFECTIVE DATE November 1, 2024
DATE: October 15, 2024
TO: Public Utility Commission
FROM: Kate Ayres
THROUGH: Caroline Moore, Scott Gibbens, Anna Kim, Ted Drennan, and Michelle
Scala SIGNED
SUBJECT: AVISTA CORPORATION:
(Docket No. UG 499/Advice No. 24-06-G)
Amortization of Schedule 493, Low-Income Rate Assistance Program
Rate Adjustment.
STAFF RECOMMENDATION:
Staff recommends that the Oregon Public Utility Commission (the Commission) approve
Avista Corporation dba Avista Utilities' (Avista or the Company) request to modify
Schedule 493, Residential Low-Income Rate Assistance Program (LIRAP) — Oregon,
with rates effective for service on or after November 1, 2024.
DISCUSSION:
Issue
Whether the Commission should approve Avista's request to modify its Schedule 493,
Residential Low-Income Rate Assistance Program — Oregon to reflect actual and
forecasted expenditures and collections of the Program and incorporate the
amortization of deferred costs associated with House Bill (HB) 2475, the Energy
Affordability Act.
APPENDIX A
Pagel of 8

ORDER NO. 24-370
Docket No. UG 499
October 15, 2024
Page 2
Applicable Rule or Law
ORS 757.205(1) states that a public utility must file schedules showing all rates, tolls,
and charges for service that have been established and are in force at the time. The
Commission reviews tariffs filed under ORS 757.205 and ORS 757.210 to determine
whether they are fair, just, and reasonable.
ORS 757.220 requires that filings that make any change in rates, tolls, charges, rules,
or regulations be filed with the Commission at least 30 days before the effective date of
the change.
ORS 757.259(5) states that unless subject to an automatic adjustment clause, amounts
deferred under ORS 757.259 shall be allowed in rates only to the extent authorized by
the Commission in a proceeding under ORS 757.210 to change rates and upon review
of the utility's earnings at the time of application to amortize the deferral. The
Commission may require that amortization of deferred amounts be subject to refund.'
The Commission's final determination on the amount of deferrals allowable in the rates
of the utility is subject to a finding by the Commission that the amount was prudently
incurred by the utility.2
ORS 757.259(6) states that the overall average rate impact of the amortizations
authorized under this section in any one year may not exceed three percent of the
utility's gross revenues for the preceding calendar year.
OAR 860-022-0025 requires that revised tariff filings include statements showing the
change in rates, the number of customers affected and resulting change in annual
revenue, and the reasons for the tariff revision.3
OAR 860-022-0030 requires that tariff filings which result in increased rates include
statements showing the number of customers affected, the annual revenue under
existing schedules, the annual revenue under proposed schedules, the average monthly
bills under existing and proposed schedules, and the reasons supporting the proposed
tariff.4
ORS 757.259(5).
2 Id.
3 OAR 860-022-0025(2).
4 OAR 860-022-0030(1).
APPENDIX A
Page 2 of 8

ORDER NO. 24-370
Docket No. UG 499
October 15, 2024
Page 3
Commission Order No. 08-263,5 modified by Order No. 10-279,6 sets out the interest
rate to use for deferral accounts and the interest rate to use when such amounts are
amortized.
ORS 757.230, as amended by House Bill (HB) 2475, provides the Commission authority
to take certain considerations into account when determining a comprehensive
classification of service for each public utility; including the quantity used, the time when
used, the purpose for which used, the existence of price competition or a service
alternative, the services being provided, the conditions of service, differential energy
burdens on low-income customers, and other economic, social equity, or environmental
justice factors that affect affordability for certain classes of utility customers.'
ORS 757.695, codifying HB 2475's Section (7)(1), provides that the Commission may
address the mitigation of energy burdens through bill reduction measures or programs
that may include, but need not be limited to, demand response or weatherization.8
Further, the costs of tariff schedules, rates, bill credits or program discounts allowed
pursuant to subsection (1) of Section (7) must be collected in the rates of an electric
company through charges paid by all retail electricity consumers, such that retail
electricity consumers that purchase electricity from electricity service suppliers pay the
same amount to address the mitigation of energy burdens as retail electricity consumers
that are not served by electricity service suppliers.9
Analysis
Summary
In this filing, Avista requests an adjustment to complete the approved amortization and
support the sustained growth of the LIRAP program. The rates in this requested tariff
revision are designed to reduce the net deferral balance to $0 at the end of October
2025. As of June 30, 2024, the total costs associated with the LIRAP program
(Schedule 493) was just over $1.6 million. With this requested revision, the average
5 Commission Order No. 08-263, Docket No. UM 1147, In the Matter of Public Utility Commission of
Oregon Staff Request to Open an Investigation Related to Deferred Accounting, May 22, 2008, accessed
at https://apps.puc.state.or.us/orders/2008ords/08-263.pdf.
6 Commission Order No. 10-279, Docket No. UM 1147, In the Matter of Public Utility Commission of
Oregon Staff Request to Open an Investigation Related to Deferred Accounting, July 23, 2010, accessed
at https://apps.puc.state.or.us/orders/201Oords/10-279.pdf.
ORS 757.230(1).
6 ORS 757.695(1).
9 ORS 757.695(2).
APPENDIX A
Page 3 of 8

ORDER NO. 24-370
Docket No. UG 499
October 15, 2024
Page 4
Avista residential customer bills would increase by $1.10. The Company's requested
revision is consistent with Staff's expectations regarding cost recovery for HB 2475
interim bill discount programs and effectively addresses ongoing learnings around the
interim programs in the current energy assistance landscape in Oregon. Staff supports
approval of this filing.
Background
Avista's LIRAP program, was initially approved by the Commission in 2002. As a result
of the passage of Oregon House Bill 2475 (HB 2475, or the Energy Affordability Act),
ORS 757.230 was expanded to permit the Commission to consider various factors
when determining rate classifications, including energy burdens on low-income
customers and other equity and environmental justice considerations. In response to
this and following stakeholder engagement on energy affordability, Avista transitioned
its formerly grant-based LIRAP into a jointly-ad ministered 10 income-based discount
model ("My Energy Discount", or MED) with a complementary arrearage assistance
option (Arrearage Management Plan (AMP) and Arrearage Forgiveness), to better serve
the specific energy burden of the households in Avista's Oregon service territory.11
With this change, Avista deferred all costs associated with offering differential rates to
qualifying customers pursuant to HB 2475 within Docket No. UM 2232 and approved in
Order No. 22-099. In 2023, Avista requested to amortize these costs via Avista's
Schedule 493 —which provides the revenues to support the program through a natural
gas surcharge — so that all costs borne by LIRAP go through the Company's Schedule
493 LIRAP tariff rather than the prior bifurcation of some expenses flowing through a
tariff and some being deferred. Schedule 493, which was historically applicable to, and
collected from, Schedule 410 residential customers, was also modified to spread cost
allocation to all residential, commercial, and industrial class sales customers (Schedules
410, 420, 424, 425, 439, 440, and 444). These revisions were approved by the
Commission in Order No. 23-294.
10 The Company defines "jointly administered"to mean that customers can enroll in LIRAP components at
both the Agencies as well as directly through Avista.
11 See Docket No. ADV 1410/Advice No. 22-03-G.
APPENDIX A
Page 4 of 8

ORDER NO. 24-370
Docket No. UG 499
October 15, 2024
Page 5
The table below summarizes Avista's current LIRAP model.
Table 1. Avista's LIRAP Assistance Model by Income Tier
Zero to 60% SMI
Bill Discount
Affordability Zero to 5% 6 to 20% SMI 21 to 40% SMI 41 to 60% SMI
SMI 60% discount 25% discount 15% discount
90% discount
Past Due Zero to 20% SMI 21 to 60% SMI
Balances Arrearage Forgiveness Arrearage Management Program
Hardship/ Customers experiencing hardship or energy emergency
Emergency Project Share
As of June 30, 2024, total costs recorded with LIRAP expense was approximately
$1.6 million. Associated with these amounts, Avista and its partner Community Action
Agencies (Agencies or CAAs) report providing a bill discount to approximately 10,038
households.12
Reason for Advice No. 24-06-G
Through this filing, Avista is requesting an adjustment in order to complete the approved
amortization and support the sustained growth of LIRAP as it continues to increase
participation rates and reach additional customers with energy assistance. The rates
included in the requested tariff revision are designed to reduce the net deferral balance
to $0 at the end of October 2025, inclusive of forecasted LIRAP expenditures and
Schedule 493 revenues.
Schedule 493 Deferral Activity
The Company's current Schedule 493 LIRAP deferral was most recently authorized on
May 31, 2024, in Docket No. UM 1978. The deferral records the funds collected through
Schedule 493 netted with the costs of LIRAP in a balancing account with any
adjustments needed requested in July of each year along with the Company's annual
Purchased Gas Adjustment (PGA) filings.
As of June 30, 2024, the net deferral, inclusive of residual amortization, is a surcharge
balance of$1,439,911 . In Avista's prior approval of the amortization and associated
12 Docket No. RG 100, Avista Utilities LIRAP Bill Discount Quarterly Reporting (Quarter 2) 2024.
APPENDIX A
Page 5 of 8

ORDER NO. 24-370
Docket No. UG 499
October 15, 2024
Page 6
LIRAP rate adjustment (ADV 1410/Advice No. 22-003-G), the Company had indicated
that 12-month amortization for UM 2232 balances would positively impact the need for
future LIRAP rate adjustments, as once the 12-month amortization of these funds was
completed, the LIRAP rates approved would mitigate the need for any additional rate
increases in the 2024-2025 program year, regardless of increasing customer
participation rates. This prediction was partially accurate, as Avista's LIRAP has
reached participation rates above the original estimates. Avista anticipated a 60%
LIRAP saturation rate for the entire Oct. 2023 — Sept. 2024 program year at the
expense of $1,645,579.13 The actual program results through June 2024 (three months
remaining in the program year) are a 62% saturation rate, with 10,038 enrolled
customers, and $1,632,593 spent.
The Company states that the prior forecasting contained a few assumptions that did not
ultimately come to fruition, thereby causing the need to increase LIRAP funding to meet
the needs of the program and the deferral balance for the upcoming program year.
One assumption was the inclusion of a $1.6 million offset to LIRAP spend based on
participants' anticipated receipt of federal Low-Income Home Energy Assistance
Program (LIHEAP) funding. The Company presumed that increased program saturation
for LIRAP would come hand-in-hand with increase participation in federal programs and
funding from LIHEAP would be further utilized to balance the potential increased spend
resulting from the new LIRAP design. This LIHEAP utilization was not realized. The
Company has adjusted the LIRAP budget forecasts to neutralize the anticipated
LIHEAP contribution to reflect a more accurate and conservative expectation. Staff
heard from Agencies at Avista's August 27, 2024, LIRAP Oregon Agency meeting that
the Avista LIRAP assistance covered many customers' natural gas costs, allowing the
agency to utilize LIHEAP funds to cover clients' electricity cost needs.
Additionally, the Company's 2023 filing forecasted tariff collections approximately
$0.2 million higher than actual collections through June 2024 ($2.3 million anticipated
vs. $2.1 million collected). Finally, residual spend within the prior HB 2475-related
deferral between the time the forecast was developed for filing (June 2023) to when the
amortization became effective (November 2023) added an additional $0.4 million to the
balances needing recovery.
13 Workpapers from ADV 1410/Advice No. 22-03-G.
APPENDIX A
Page 6 of 8

ORDER NO. 24-370
Docket No. UG 499
October 15, 2024
Page 7
Docket No. UM 1978: In Avista's October 2023 reauthorization application for deferral
of LIRAP expenses, the Company proposed that the interest rate applicable to the
balancing account use the current Modified Blended Treasury (MBT) rate, in
accordance with Order No. 23-294 in Docket No. UG 471. For 2024, the Company did
not provide an estimate of the expected deferral balance. Avista requested that the
Commission reauthorize the Company to defer the unspent funds or uncollected costs
of its low-income program for a 12-month period. Staff continues to support the Staff
recommendation from the Staff Report filed May 1, 2024 in Docket No. UM 1978
concluding that the proposal presented and adopted by the Commission at the May 28,
2024 meeting is an appropriate use of deferred accounting.
Staff finds the rate revision included in this proposal to reflect the increased participation
in the Company's LIRAP program, and to be reflective of the continued (earnings of
managing interim bill discount programs alongside longstanding energy assistance
programs. The recent changes to LIRAP driven by HB 2475 are expected to improve
the reach and effectiveness of the program, and thus increase the associated spend, as
seen here.
Rate Impacts
If approved, a residential customer using an average of 47 therms a month could expect
their bill to increase by $1 .10 or 1.6 percent, for a revised monthly bill of $71 .21 effective
November 1 , 2024. However, these amounts are fully offset by other regulatory filings
from the Company in this year's Purchased Gas Adjustment, where Avista has
forecasted an expected net reduction.
Pursuant to OAR 860-022-0025 and OAR 860-022-0030, Avista provided the total
number of customers affected by the filing and the annual revenue before and after the
impact of the proposed rate change in Table 2 below.
APPENDIX A
Page 7 of 8

ORDER NO. 24-370
Docket No. UG 499
October 15, 2024
Page 8
Table 2. Count of Affected Customers and Revenue Impacts by Customer
Schedule
Rate Schedule Present Revenue Change Proposed Revenue %Change Customers
Schedule 410/411 $ 88,443,720 $ 1,268,267 $ 89,711,987 1.4% 95,294
Schedule 420 $ 41,724,939 $ 468,277 $ 42,193,216 1.1% 11,981
Schedule 424/425 $ 3,919,829 $ 13,697 $ 3,933,526 0.3% 98
Schedule 439/440 $ 8,892,374 $ 29,651 $ 8,922,025 0.3% 47
Schedule 444 $ 175,406 $ 511 $ 175,917 0.3% 2
Schedule 456 $ 2,701,247 $ - $ 2,701,247 0.0% 31
$ 145,857,515 S 1,780,403 $ 147,637,918 1.2%
Conclusion
Based on the review of Avista's filing and the associated work papers, Staff believes
that it is reasonable to move forward with the proposed Schedule 493 revisions,
including the requested rate adjustment for the Company's LIRAP. Staff finds the
Company's request has been sufficiently described and justified and acknowledges that
the proposal reflects an understanding and adjustment of an ongoing learning process
with bill discount programs and their associated forecasting as programs become more
established. To this end, Staff recommends the Commission approve the Company's
filing as filed on July 31, 2024, in Advice No. 24-06-G.
PROPOSED COMMISSION MOTION:
Approve Avista Corporation dba Avista Utilities' request to modify its Schedule 493,
Residential Low-Income Rate Assistance Program — Oregon, with rates effective for
service on or after November 1, 2024.
CA4-UG 499
APPENDIX A
Page 8 of 8

ORDER NO. 24-371
ENTERED Oct 31 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UG 500
In the Matter of
AVISTA CORPORATION dba AVISTA ORDER
UTILITIES,
Advie No. 24-07-G, Updates
Schedule 467, COVID Deferred Costs.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its Special Public Meeting on October 29, 2024,the Public Utility Commission of
Oregon adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
��ttiiTY COS Alison Lackey
Chief Administrative Law Judge
� z
REGO
A parry may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each parry to the
proceedings as provided in OAR 860-001-0180(2).A parry may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-371
ITEM NO. CA5
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
SPECIAL PUBLIC MEETING DATE: October 29, 2024
REGULAR CONSENT X EFFECTIVE DATE November 1, 2024
DATE: October 9, 2024
TO: Public Utility Commission
FROM: Jean Falconer
THROUGH: Caroline Moore, Scott Gibbens, Anna Kim, Curtis Dlouhy, and Ted Drennan
SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UG 500 /Advice No. 24-07-G)
Schedule 467 First Revision — COVID-19 Deferred Costs.
STAFF RECOMMENDATION:
Approve Avista Corporation dba Avista Utilities (Avista, AVA, or Company) request to
revise its Schedule 467 tariff sheet, with rates effective for service rendered on or after
November 1, 2024.
DISCUSSION:
Issue
Whether the Commission should approve Avista's proposed revision to its Schedule
467 tariff sheet for amortization of the residual balance of the Company's COVID-19
deferral balances, representing a decrease in overall retail revenues of approximately
$205,000, or 0.2 percent, effective November 1, 2024.
Applicable Rule or Law
ORS 757.205 requires public utilities to file all rates, rules, and charges with the
Commission. ORS 757.210 provides that the Commission may approve tariff changes if
they are fair, just, and reasonable.
ORS 757.220 requires that filings that make any change in rates, tolls, charges, rules,
or regulations be filed with the Commission at least 30 days before the effective date of
the change.
APPENDIX A
Page 1 of 5

ORDER NO. 24-371
Docket No. UG 500
October 9, 2024
Page 2
ORS 757.259 allows the Commission to authorize the deferral of expenses or revenues
of a public utility for later incorporation into rates.
OAR 860-027-0300 allows the Commission to authorize amortization of deferred
amounts for utility expenses or revenues for which the Commission previously
authorized deferred accounting.
With some exceptions, under ORS 757.259(6) a company's amortization amount may
not exceed three percent of the utility's gross revenues for the preceding calendar year.
OAR 860-022-0025 requires that revised tariff filings include statements showing the
change in rates, the number of customers affected and resulting change in annual
revenue, and the reasons for the tariff revision.
OAR 860-027-0300(9)(b) allows an energy utility to request amortization at least
annually in the case of ongoing balancing accounts, although an amortization request
may not be made if the balancing account is currently being amortized.
Analysis
On March 8, 2020, Oregon Governor, Kate Brown, declared a state of emergency to
address the spread of COVID-19 in Oregon. The state of emergency ended on April 1,
2022, after multiple extensions.
On March 25, 2020, Avista filed Docket No. UM 2069, requesting that the Commission
authorize the Company to defer for later ratemaking treatment costs associated with the
COVID-19 public health emergency, which was approved by Order No. 20-378. Avista
filed two applications to reauthorize Docket No. UM 2069, one on March 22, 2021, and
the other February 22, 2022, both of which were approved by Order No. 22-103.
On April 29, 2022, Avista filed Docket No. ADV 1392, proposing its Schedule 467 tariff
sheet to amortize the Company's 2020 and 2021 COVID-19 deferral balances, totaling
$777,658 through December 31, 2021. A summary of these costs and benefits is on the
next page.
APPENDIX A
Page 2 of 5

ORDER NO. 24-371
Docket No. UG 500
October 9, 2024
Page 3
Oregon COS'ID Deferral 5umman-as of 12'31,'2021
Deferral Type amount
Bad Debt Expense S 546,034
COVID Debt Relief Program 970,429
Term Loan Interest'Fees 59,991
Other Direct COVID Costs 47,805
Late Fees 538,413
Total 182.3 2,162.672
Other Direct COVID Benefits (436,311)
CARES_act Tax Benefit (948,703)
Total 254 (1,385,014)
Total Ending Balance at 12.31.2021 S 777,658
Staff and Avista representatives discussed three alternative rate schedules, and on
October 12, 2022, Avista submitted a supplemental filing in Docket No. ADV 1392
documenting the consensus rate schedule, which consisted of a one percent increase in
revenues from Schedule 410 (residential customers) and no change in revenues from
Schedules 420, 424, 425, 439, 440, 444, and 456. The Commission approved this
consensus rate schedule at a public meeting on October 25, 2022, effective
November 1, 2022 through October 31, 2023.
Under Docket No. RG 89, Avista submitted COVID-19 deferred accounting quarterly
reports as required by Order No. 20-324 in Docket No. UM 2114, which states:
Each utility shall provide the Commission with reports that itemize the utility
costs, savings, and benefits resulting from COVID-19. The first report will be
for the period between March 1, 2020 and September 30, 2020, and shall be
filed by November 1, 2020. Thereafter, reports will be due 30 days after the
close of each quarter and shall include information from previous quarter.
Each utility shall file a Report for every quarter until the quarter ending
December 31, 2023, unless waived by the Commission.
In its final quarterly report, Avista stated that it deferred COVID-19 direct benefits and
costs through September 30, 2022, and that only Bad Debt Expense continued to be
deferred from September 30, 2022 through December 31, 2022. No further deferrals
occurred after December 31, 2022.
A summary of the overall costs and benefits of Avista's COVID-19 deferral is below.
APPENDIX A
Page 3 of 5

ORDER NO. 24-371
Docket No. UG 500
October 9, 2024
Page 4
Ore-gon COYM Deferral Summasti-as of lV31/2022
Deferral T�-pe Amount
Bad Debt Expense S 121,864
COVID Debt Relief Program 970,430
Term Loan InteresvFees 59,991
Other Direct COVID Costs 47,805
Late Fees 764,201
Total 182.3 1,964,291
Other Direct COVID Benefits (436,311)
CARES Act Tax Benefit (948.703)
Total 254 (1,385-014)
Total Ending Balance at 12.31.2022 S 579,277
Between December 31, 2021 and December 31, 2022, (the relevant period between
Dockets No. ADV 1392 and UG 500), the only deferral types that changed in value were
Bad Debt Expense, which decreased by $424,170, and Late Fees, which increased by
$225,788. Together, these account for the $198,381 decrease in the overall COVID-19
deferral balance.
On July 31, 2024, Avista filed Docket No. UG 500, proposing a revision to its
Schedule 467 tariff sheet to amortize the residual balance of deferred costs associated
with the Company's COVID-19 deferral. The Company has amortized $777,837 through
Schedule 467 compared to the ending deferral balance of$579,277, and as a result the
remaining net balance owed to customers is $198,560. Avista's application requests a
decrease in overall retail revenues of approximately $205,000, which is the remaining
deferral balance plus the estimated resulting change in revenue-sensitive costs. Avista
proposes to decrease the per therm rate paid by affected customers by $0.00379, for a
total per therm rate of$1.24846, representing an overall rate decrease of 0.2 percent,
effective November 1, 2024.
Avista proposes to assign the rate change solely to residential Schedules 410 and 411,
noting that the deferral balance was collected from this group of customers. The
proposed rate change is summarized in the table below.
Rate Schedule -Number of Customers Proposed Rate Change
Schedule 410,1411 95,294 -0.3%
Schedule 420 11,981 0.0%
Schedule 424/425 98 0.0%
Schedule 439/440 47 0.0%
Schedule 444 2 0.0%
Schedule 456 31 0.0%
Total 107,453 -0.20/0
APPENDIX A
Page 4 of 5

ORDER NO. 24-371
Docket No. UG 500
October 9, 2024
Page 5
In total, 95,294 customers will be affected by Avista's proposed rate change.
In a September 17, 2024, email, Staff asked Avista about the inclusion of Schedule 411 in
its proposed rate schedule, which did not appear in Docket No. ADV 1392. An Avista
representative clarified that Schedule 411 (Multi-Family Residential) did not exist when
the Commission approved the Schedule 467 tariff sheet on October 25, 2022. However,
since all residential customers participated in the deferral collection, Avista believes they
should participate in the refund.
Through phone and email communications on September 17, 2024, Staff asked Avista for
documentation explaining the changes in the COVID-19 deferral balance between
December 31, 2021 and December 31, 2022. Avista provided the requested
documentation for Bad Debt Expense and Late Fees, the only deferral types that
changed during this period, and walked Staff through the associated numbers. Staff also
asked for documentation supporting Avista's claim that it amortized $777,837 through
Schedule 467 during the November 1, 2022 to October 31, 2023, amortization period,
which Avista subsequently provided.
Conclusion
After review, Staff believes it is reasonable to move forward with the proposed
Schedule 467 revision amortizing the residual balance of deferred costs associated with
the Company's COVID-19 deferral. Staff finds the Company's request has been
sufficiently described and justified in the filing and associated work papers and
recommends the Commission approve the Company's filing, as filed on July 31, 2024,
in Advice No.24-07-G.
Avista has reviewed this memo and agrees with its content.
PROPOSED COMMISSION MOTION:
Approve Avista's request to revise its Schedule 467, with rates effective for service
rendered on or after November 1, 2024.
APPENDIX A
Page 5 of 5

ORDER NO. 24-372
ENTERED Oct 31 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UM 1356(17)
In the Matter of
AVISTA CORPORATION dba AVISTA ORDER
UTILITIES,
Request for Reauthorization to Defer
Certain Costs Related to Intervenor
Funding Grants.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its Special Public Meeting on October 29, 2024,the Public Utility Commission of
Oregon adopted Staffs recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
o�s�ITY oo� Alison Lackey
Chief Administrative Law Judge
OR Go
A party may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each parry to the
proceedings as provided in OAR 860-001-0180(2).A party may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-372
ITEM NO. CA6
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
SPECIAL PUBLIC MEETING DATE: October 29, 2024
REGULAR CONSENT X EFFECTIVE DATE November 1, 2024
DATE: October 9, 2024
TO: Public Utility Commission
FROM: Kathy Zarate
THROUGH: Caroline Moore, Scott Gibbens, Anna Kim, and Ted Drennan SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UM 1356(17))
Request for Re-authorization for Deferral of Costs Associated with
Intervenor Funding Grants
STAFF RECOMMENDATION:
Staff recommends that the Commission approve Avista Corporation's, dba Avista Utilities
(Avista, AVA, or Company) application for reauthorization to defer costs associated with
intervenor funding grants for the 12-month period beginning November 1 , 2024.
DISCUSSION:
Issue
Whether the Commission should approve Avista's request for reauthorization to record
and defer costs related to intervenor funding grants for the 12-month period beginning
November 1 , 2024.
Applicable Law
ORS 757.259(3) and OAR 860-027-0300 allow the deferral of expenses provided as
financial assistance under an agreement entered into under ORS 757.072 for later
incorporation in rates.
ORS 757.072 is the statute that authorizes public utilities to enter into funding
agreements with organizations that represent broad customer interests in Commission
proceedings. Once a funding agreement is approved by the Commission, organizations
APPENDIX A
Page 1 of 6

ORDER NO. 24-372
Docket No. UM 1356(17)
October 9, 2024
Page 2
eligible to receive grants under the funding agreement are identified pursuant to
OAR 860-001-0120. When a public utility provides financial assistance under a funding
agreement, ORS 757.072(4) states that the Commission must allow a public utility to
defer inclusion of the funding provided in rates as provided in ORS 757.259.
OAR 860-027-0300 specifies the required contents of an application for deferred
accounting, including a description of the expense or revenue for which deferral is
requested, the basis for the request, the accounts proposed for recording the amounts
to be deferred, an estimate of the amounts to be recorded in the deferred account, and
a copy of the notice of the application for deferred accounting.
Analysis
Background
Three funds are established by which grants could be made to certain intervenors (CUB
Fund, Preauthorized Matching Fund and an Issues Fund). The most recent Intervenor
Funding Agreement is the Fifth Amended and Restated Intervenor Funding Agreement
by Order No. 22-506 dated December 29, 2022, between the Company, Citizens' Utility
Board of Oregon (CUB) and Alliance of Western Energy Consumers (AWEC).
The Interim Funding Agreement (Interim Agreement), approved in Order No. 22-043
dated February 10, 2022 (Docket No. UM 2211), established one fund from which
grants could be made and approved Rogue Climate, the Coalition of Communities of
Color (CCC), the Community Action Partnership of Oregon (CAPO), and Community 12
Energy Project (CEP) as the preliminary groups eligible for funding.' The Interim
Agreement was later replaced with the Environmental Justice Communities Funding
Agreement (EJC Agreement) via Order No. 23-033 in Docket No. UM 2211, dated
February 8, 2023; the EJC Agreement was between the Company, Rogue Climate,
Verde, and Community Energy Project (CEP) and established two funds from which
grants could be made (Pre-certification Fund and Case Fund).2
Reason for Deferral
This request is made in accordance with ORS 757.259(3) that allows for the deferral of
Intervenor funds, which directs the Company to pay to intervenors the amounts made
available as defined and provided for in the Agreement.
Id. Appendix A, at 89.
2 Commission Order No. 23-033, Docket No. UM 2211, In the Matter of Public Utility Commission of
Oregon, Implementation of House Bill 2475, February 8, 2023, accessed at
https://apps.puc.state.or.us/orders/2023ords/23-033.pdf.
APPENDIX A
Page 2 of 6

ORDER NO. 24-372
Docket No. UM 1356(17)
October 9, 2024
Page 3
Description of Expenses
The intervenor Funding Agreement provides that pre-certified intervenors must submit a
proposed fund budget to the Commission that includes the following:
• A statement of the work to be performed by the applicant for which the applicant
is seeking an Issue Fund Grant;
• A description of the areas to be investigated by the intervenor;
• A description of the customer class(es) that will benefit from the intervenor's
participation;
• Identification of the specific account or accounts from which the intervenor is
seeking an Issue Fund Grant and an estimate of the amount of available funds in
that account;
• A budget showing estimated attorney fees, which may include the cost for
appropriate support staff and operational support;
• A budget showing estimated consultant fees and expert witness fees, which may
include the cost for appropriate support staff and operational support; and
• A representation that the intervenor will use matching funds from either in-house
resources or outside funding to account for or pay at least 20 percent of the
"Eligible Expenses" for the work to be performed for which the intervenor is
seeking an Issue Fund Grant.
The Interim Agreement provides that eligible recipients must submit a proposed budget
to the Commission that contains the following information:
• A statement of the work to be performed by the recipient for which the recipient is
seeking funding;
• A description of the areas to be investigated and addressed by the recipient;
• A budget showing estimated attorney fees, which may include the cost for
appropriate support staff and operational support; and
• A budget showing estimated consultant fees and expert witness fees, which may
include the cost for appropriate support staff and operational support.
APPENDIX A
Page 3 of 6

ORDER NO. 24-372
Docket No. UM 1356(17)
October 9, 2024
Page 4
The EJC Agreement provides that eligible recipients must submit a proposed budget to
the Commission that contains the following information:
• A statement of the work to be performed by the recipient for which the recipient is
seeking funding;
• A description of the areas to be investigated and addressed by the recipient;
• A budget showing estimated attorney fees, which may include the cost for
appropriate support staff and operational support;
• A budget showing estimated consultant fees and expert witness fees, which may
include the cost for appropriate support staff and operational support;
• A description of the low-income customers or Environmental Justice
Communities that will benefit from the recipient's participation; and
• A description of the Participating Public Utility account or accounts for which the
applicant seeks funds and how the initial payment should be apportioned.
After Commission approval of the proposed budget, the intervenor must file a Request
for Payment with the Commission. If the request meets the Intervenor Funding, Interim,
or EJC Agreement requirements, the Commission will order payment and specify which
customer class will be responsible for the grant.
Proposed Accounting
The Company proposes sub-accounts of FERC Account No. 191 to be used to record
the grant payments, specifically Account Nos. 191720, 191721, 191722, and 191725.
Current Deferral Activity
In accordance with Order No. 23-411, issued October 27, 2023, the Company deferred
the following:
CUB Preauthorizcd Issues JIB2475
Fund Matching Fund Fund Fund
19{ 1720} 19( 1721) 19i 17221 14[ 1725)
Per Order No. 23-335 $31,056
Per Order No. 23-368 $71,920
Per order No. 24-081 $20,000
Interest $1,317 $58 $7,790 $65
Balance at6/30/2024 $1,317 $58 $130,766 $65
Interest 7/1/2024— 10/31/2024 $32 $1 $3,182 $2
Balance to Amortize 1111/2024 $1,349 $59 $133,948 $67
APPENDIX A
Page 4 of 6

ORDER NO. 24-372
Docket No. UM 1356(17)
October 9, 2024
Page 5
Future Estimated Deferral
The Company estimates that the following amounts may be deferred during the
12-month period proposed in this application (November 1, 2024, through
October 31, 2025):
• CUB Fund3 $54,028
• Preauthorized Matching Fund $43,780
• Issues Fund $84,988
• Interim Agreement Fund $ 0
• E J C Agreement Fund $ 0
Amortization
Avista's annual PGA filing includes a request to recover the current deferral balances
shown and the remaining unamortized residual balances, over the upcoming traditional
PGA period (November 1, 2024 to October 31, 2025).
If this deferral application is approved, Avista proposes that the funds in general ledger
Account 191720 (CUB Fund) in the amount of$1,349 will be transferred to
Account 191723 (Residential); the funds in general ledger Account 191721
(Preauthorized Matching Fund) in the amount of$59 will be transferred to
Account 191724 (Industrial); $78,607 of the balance in general ledger Account 191722
(Issues Fund) will be transferred to Account 191723 (Residential); $55,341 of the
balance in general ledger Account 191722 (Issues Fund) will be transferred to
Account 191724 (Industrial); and the funds in general ledger Account 191725 (HB 2475
Fund) in the amount of$67 will be transferred to Account 191723 (Residential) for
amortization. These amounts include interest that will be accrued from July 1, 2024
through October 31, 2024, in accordance with the Intervenor Funding Agreement,
Interim Agreement, and E JC Agreement, all previously approved by the Commission.
Information Related to Future Amortization
• Earnings Review — Pursuant to ORS 757.259(4) and Commission Order
No. 18-017, Appendix A, page 28, paragraph 7.9, these costs are exempt from
the amortization caps and earnings test:
If a Participating Public Utility seeks rate recovery through a deferred account,
3 As stated in the Fifth Amended Intervenor Funding Agreement, the amount for 2023 is $51,175
increased by three percent each year thereafter resulting in an amount of$54,028 for the period
November 1, 2024 through October 31, 2025.
4 As stated in the Fifth Amended Intervenor Funding Agreement, the amount for 2023 is $80,500
increased by three percent each year thereafter resulting in an amount of$84,988 for the period
November 1, 2024 through October 31, 2025.
APPENDIX A
Page 5 of 6

ORDER NO. 24-372
Docket No. UM 1356(17)
October 9, 2024
Page 6
the account and amortization of the account shall be exempt from the
amortization caps and earnings test set forth in Subsections 5, 6, 7, 8, and 10 of
ORS 757.259, as such subsections may be amended from time to time and shall
not be included in any calculation of the amortization cap for other deferred
accounts.
• Prudence Review — For amortization, the prudence review should be limited to
verification of the accounting methodology used to determine the final
amortization balance.
• Sharing — This deferral is not subject to a sharing mechanism.
• Rate Spread/Design —Account balances are to be spread to the appropriate
customer classes per Order No. 18-017, Appendix A, page 27, paragraph 7.7(b).
• Three Percent Test (ORS 757.259(6)) — The three percent test does not apply to
amortization of this deferral. See "Earnings Review" above.
Conclusion
Staff finds that the Company's application meets the requirements of ORS 757.259 and
OAR 860-027-0300 for deferred accounting, and the reason for the deferral—costs
related to intervenor funding grants—is still valid. Therefore, Staff recommends the
Commission approve Avista's application.
The Company has reviewed this memo and agrees with its content.
PROPOSED COMMISSION MOTION:
Approve Avista's application for reauthorization to defer the costs associated with
intervenor funding grants for the 12-month period beginning November 1, 2024.
Avista UM 1356(17)
APPENDIX A
Page 6 of 6

ORDER NO. 24-373
ENTERED Oct 31 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UM 1497(14)
In the Matter of
AVISTA CORPORATION dba AVISTA ORDER
UTILITIES,
Request for Reauthorization to Defer
Purchased Gas Costs Differences.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its Special Public Meeting on October 29, 2024,the Public Utility Commission of
Oregon adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
�,�XXJT Y ?o ff
Alison Lackey
Chief Administrative Law Judge
OR Go
A party may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each party to the
proceedings as provided in OAR 860-001-0180(2).A parry may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-373
ITEM NO. CA7
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
SPECIAL PUBLIC MEETING DATE: October 29, 2024
REGULAR CONSENT X EFFECTIVE DATE N/A
DATE: October 9, 2024
TO: Public Utility Commission
FROM: Kathy Zarate
THROUGH: Caroline Moore, Scott Gibbens, Anna Kim, and Ted Drennan SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UM 1497(14))
Reauthorization to defer Purchased Gas Cost Differences.
STAFF RECOMMENDATION:
Staff recommends the Public Utility Commission of Oregon (Commission) approve
Avista Corporation dba Avista Utilities' (Avista, AVA, or Company) application for
reauthorization to defer purchased gas cost differences associated with the PGA
mechanism for the 12-month period beginning November 1, 2024.
DISCUSSION:
Issue
Whether the Commission should approve Avista's request for reauthorization to record
and defer costs related to Purchased Gas Cost Differences for the 12-month period
beginning November 1, 2024.
Applicable Law
This Application is filed pursuant to ORS 757.259(2)(e), which allows the Commission to
authorize the deferral of expenses or revenues of a public utility for later incorporation
into rates. Under ORS 757.259, the Commission may authorize deferred accounting for
later incorporation in rates.
In OAR 860-027-0300(3) the Commission has set forth the requirements for the
contents of deferred accounting applications. Applications for reauthorization must
APPENDIX A
Page 1 of 5

ORDER NO. 24-373
Docket No. UM 1497(14)
October 9, 2024
Page 2
include that information along with a description and explanation of the entries in the
deferred account to the date of the application for reauthorization and the reason for
continuation of deferred accounting. OAR 860-027-0300(4). Notice of the application
must be provided pursuant to OAR 860-027-0300(6).
In addition, due to the fluctuation of the wholesale price of natural gas, Commission
Order No. 89-1046 established the PGA mechanism to enable utilities to pass on to
customers actual gas costs while minimizing the frequency of rate changes and the
fluctuation of rate levels in accordance with ORS 757.259(2)(e).' Under the PGA
mechanism and pursuant to ORS 757.259(4), the Commission may authorize utilities to
defer actual purchased gas costs for a 12-month period. The difference between the
actual gas costs and the cost charged to customers is amortized and recovered in rates
if the utility's earnings are not excessive as defined by OAR 860-022-0070.2
Analysis
Background
The PGA mechanism allows utilities to regularly adjust the price of gas charged to
customers to reflect the costs incurred by the utility to purchase and transport the gas.
The monthly differences arise because utilities calculate the rates associated with gas
costs using forecasted gas prices and therm usage. Avista files an annual request to
amortize the accumulated deferral, to be effective November 1.
Additionally, the Company provides the calendar year regulated utility earnings, for
ratemaking purposes, for which the deferral activity and dollar totals took place. On an
annual basis, the Company files its Oregon Division Results of Operations report to
satisfy the reporting requirements associated with Docket No. UM 903 (associated
Order No. 99-272, and Order No. 99-284) as well as the standard Oregon annual
reporting requirements.
Reason for Deferral
The Company argues that due to the volatility of the price of natural gas purchased and
transported for customer use, the associated costs are difficult to establish with any
degree of certainty.
PGA Guidelines were acknowledged by the Commission in Docket No. UM 1286, Order No. 09-248, on
June 23, 2009. The Guidelines in Docket No. UM 1286 have been modified four different times since they
were first acknowledged by the Commission, in Order Nos. 10-197, 11-196, 14-238, and 18-144.
2 OAR 860-022-0070(1) ("...earnings are excessive only if a gas utility does not share with its customers
past revenues related to earnings that exceed an earnings threshold determined by the [C]omission").
APPENDIX A
Page 2 of 5

ORDER NO. 24-373
Docket No. UM 1497(14)
October 9, 2024
Page 3
This volatility makes the use of deferred accounting extremely important. It is
appropriate that the deferral is reauthorized for the Purchased Gas Cost differences for
the same reasons that originally established the PGA mechanism. Deferred accounting
minimizes both the frequency of rate changes and the fluctuation of rate levels pursuant
to subsection (2)(e) of ORS 757.259.
Proposed Accounting
The Company accumulates Purchased Gas Cost differences in two sub-accounts of
FERC Account No. 191, namely Account Nos. 191909, Commodity Deferrals and
191910, Demand Deferrals.
Ninety (90) percent of the difference between the forecasted commodity portion and
actual costs are recorded in Account No. 191909.
Description of Expense
The commodity portion of Purchased Gas Cost differences includes:
• The actual cost of purchasing natural gas,
• The variable cost of transporting the natural gas from the supply basins to the
Citygate,
• The benefits received from storage optimization,
• Off-system sales, and
• Other miscellaneous costs or benefits.
The demand portion of the Purchased Gas Cost differences includes fixed pipeline
costs, capacity releases, and miscellaneous pipeline related refunds or surcharges.
The Interest is calculated on the average net balance and included in the deferral
accounts.
Estimate of Amounts
As of June 30, 2024, the outstanding balance for the Purchased Gas Cost are as
follows:
Account 191909, Commodity Deferrals $(10,513,347)
Account 191910, Demand Deferrals $2,004,507
Account 191911, Prior Commodity Amortization $(1 ,540,423)
Account 191912, Prior Demand Amortization $(581,087)
Total $(10,630,350)
APPENDIX A
Page 3 of 5

ORDER NO. 24-373
Docket No. UM 1497(14)
October 9, 2024
Page 4
Information Related to Future Amortization
• Earnings Review — Prior to amortization, an annual spring earnings review will be
conducted pursuant to OAR 860-022-0070.
• Prudence Review — Prior to amortization, a prudence review will be conducted.
The review should include verification of the accounting methodology used to
determine the final amortization balance.
• Sharing — The Company will defer 90 percent of the difference between actual
commodity costs and the commodity costs collected from customers. Avista will
absorb the remaining ten percent.
The commodity portion of purchased gas cost differences includes purchasing
natural gas, the variable cost of transporting the gas from the supply basin to the
Citygate, the benefits received from storage optimization, off-system sales, and
other miscellaneous costs or benefits.
One hundred percent of the demand portion of the purchased gas cost
differences will be deferred. The demand portion includes fixed pipeline costs,
capacity releases, and miscellaneous pipeline related refunds or surcharges.
• Rate Spread/Design — Prudently incurred gas cost differences that have been
correctly accounted for should be developed into a rate per therm based on
estimated usage for the upcoming PGA year.
• Three Percent Test (ORS 757.259(6)) — The three percent test measures the
annual overall average effect on customer rates resulting from deferral
amortizations. The three percent test limits (exceptions at ORS 757.259(7) and
(8)) the aggregated deferral amortizations during a 12-month period to no more
than three percent of the utility's gross revenues for the preceding year.
This deferral is subject to the exception at ORS 757.259(7) that allows the
Commission to consider an overall average rate impact greater than that
specified in subsection (6) for natural gas commodity and pipeline transportation
costs incurred by a natural gas utility, if the Commission finds that allowing a
higher amortization rate is reasonable under the circumstances.
Conclusion
Based upon review of Avista's application, Staff concludes that the proposed
reauthorization represents an appropriate use of deferred accounting under
APPENDIX A
Page 4 of 5

ORDER NO. 24-373
Docket No. UM 1497(14)
October 9, 2024
Page 5
ORS 757.259. Additionally, Avista's application for reauthorization of deferred
accounting meets the requirements related to the establishment of the PGA mechanism
as well as the requirements of ORS 757.259 and OAR 860-027-0300.
The Company has reviewed a draft of this memo and voiced no concerns.
PROPOSED COMMISSION MOTION:
Approve Avista's application for reauthorization to defer Purchased Gas Cost
differences associated with the PGA mechanism for accounting purposes for the
12-month period beginning November 1, 2024.
Avista UM 1497(14)
APPENDIX A
Page 5 of 5

ORDER NO. 24-395
ENTERED Oct 31 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UG 495
In the Matter of
AVISTA CORPORATION dba AVISTA ORDER
UTILITIES,
Advice No. 24-02-G, Purchased Gas Cost
Adjustment, Schedule 461 and 462.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its Special Public Meeting on October 29, 2024,the Public Utility Commission of
Oregon adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
�,�11,ITY CO
.6u� -&,\,
Alison Lackey
� z Chief Administrative Law Judge
of? 60
A party may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each parry to the
proceedings as provided in OAR 860-001-0180(2).A party may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-395
ITEM NO. RA3
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
SPECIAL PUBLIC MEETING DATE: October 29, 2024
REGULAR X CONSENT EFFECTIVE DATE November 1, 2024
DATE: October 21, 2024
TO: Public Utility Commission
FROM: Anna Kim
THROUGH: Caroline Moore and Scott Gibbens SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UG 495/Advice No. 24-02-G)
Reflects changes in the cost of purchased gas and the amortization rate
for the Purchased Gas Adjustment (PGA) balancing account.
STAFF RECOMMENDATION:
Staff recommends approval of Avista Corporation dba Avista Utilities' (Avista, AVA, or
Company) Advice No. 24-02-G, which updates the Company's 2024 annual Purchase
Gas Adjustment (PGA) tariff sheets, for service rendered on and after
November 1 , 2024.
DISCUSSION:
Issue
Whether the Public Utility Commission of Oregon (Commission) should approve Avista's
2023 annual PGA as reflected in its Advice No. 24-02-G.
Applicable Rule or Law
ORS 757.205 requires public utilities to file all rates, tolls, and charges with the
Commission. ORS 757.210 provides that the Commission may approve tariff changes if
they are fair, just, and reasonable. Filings that make any change in rates, tolls, charges,
rules, or regulations must be filed with the Commission at least 30 days before the
effective date of the changes.
APPENDIX A
Page 1 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 2
ORS 757.259(5) states that unless subject to an automatic adjustment clause, amounts
deferred under ORS 757.259 shall be allowed in rates only to the extent authorized by
the Commission in a proceeding under ORS 757.210 to change rates and upon review
of the utility's earnings at the time of application to amortize the deferral. The
Commission may require that amortization of deferred amounts be subject to refund.
The Commission's final determination on the amount of deferrals allowable in the rates
of the utility is subject to a finding by the Commission that the amount was prudently
incurred by the utility.
ORS 757.259(6) states that the overall average rate impact of the amortizations
authorized under this section in any one year may not exceed three percent of the
utility's gross revenues for the preceding calendar year. ORS 757.259(7) allows the
Commission to consider an overall average rate impact greater than that specified in
subsection (6) for natural gas commodity and pipeline transportation costs incurred by a
natural gas utility, if the Commission finds that allowing a higher amortization rate is
reasonable under the circumstances.
OAR 860-022-0025 requires that revised tariff filings include statements showing the
change in rates, the number of customers affected and resulting change in annual
revenue, and the reasons for the tariff revision.
OAR 860-022-0030 requires that tariff filings which result in increased rates include
statements showing the number of customers affected, the annual revenue under
existing schedules, the annual revenue under proposed schedules, the average monthly
bills under existing and proposed schedules, and the reasons supporting the proposed
tariff.
The PGA mechanism was originally established by Order No. 89-1046 to minimize the
frequency of gas cost-related rate changes and the fluctuation of rate levels pursuant to
ORS 757.259(2)(e). Since the mechanism's creation in 1989, the Commission has
issued a series of orders concerning PGA filings through open-docket UM 1286.' Order
No. 18-144 is the most recent of these orders, and revises the Commission's
procedures and requirements of the Natural Gas Portfolio Development
Guidelines in Docket No. UM 1286 by adding language concerning review and approval
of long-term hedging instruments in a local distribution company's (LDC) natural gas
portfolio. No changes were made to the PGA Filing Guidelines previously established in
Order No. 14-238.
Order No. 08-504 established the form of the PGA Mechanism. PGA Guidelines were acknowledged by
the Commission in Docket No. UM 1286, Order No. 09-248, on June 23, 2009. The Guidelines in Docket
No. UM 1286 have been modified four different times since they were first acknowledged by the
Commission, in Order No. 10-197, in Order No. 11-196, in Order No. 14-238, and in Order No. 18-144.
APPENDIX A
Page 2 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21 , 2024
Page 3
On December 16, 2021, the Department of Environmental Quality (DEQ) adopted the
Oregon Climate Protection Program (CPP) rules, which set a cap on greenhouse gas
emissions from transportation fuels and natural gas. These rules were invalidated in
December 2023 by the Oregon Court of Appeals following challenges by multiple
parties.
Analysis
On July 31, 2024, Avista submitted Advice 24-02-G, which constitutes its annual PGA
filing (Initial 2024 PGA Filing). On September 13, 2024, Avista supplemented its initial
filing (Supplemental 2024 PGA Filing), which updated its commodity costs. In
aggregate, the filings are commonly referred to as the 2024 PGA Filing. The 2024 PGA
Filing is comprised of two parts: a forward-looking part (Projected Purchased Gas Cost
for the 2024-2025 Gas Year) and a backward-looking part (True-Up of the 2023--2024
Gas Year).
In 2023-2024, prices came in lower than expected: $2.50 in 2023 and $2.30 in 2024 to
date—much lower than the forecasted $3.24/MMBtu from the 2023 PGA. This time last
year, the EIA forecasted a Henry Hub price of $2.58/MMBtu for 2023 and $3.24/MMBtu
for 2024.
Several factors led to decreased natural gas prices:
• Winters were mild, reducing demand. A milder winter 2023 and fall 2024
resulted in slightly decreased demand and lower prices. However, in general,
the EIA expects relatively little change in energy bills from last winter to this
winter as lower prices will mostly offset colder weather for winter 2024.
• Production is high and increasing. For 2024 as a whole, production is expected
to average 103 Bcf/d (similar to 2023), and then rise to a new record of 105 Bcf/d
in 2025.
• Storage is full. Storage inventories were built up above the five-year average
which resulted in less gas injected this past injection season (April-October);
forecasted working inventories by the end of October are expected to be the
most in U.S. storage since November 2016.
• A healthy GDP growth and inflation rate have increased demand for production
inputs.
In 2025 prices are expected to increase from 2024 actuals. The EIA forecasts an
average $3.10 in 2025, which is higher than the current average for 2024, but lower
than last year's forecast for 2024.
APPENDIX A
Page 3 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 4
• The EIA forecasts Henry Hub to average $3.10 in 2025. This is compared to the
lower historic averages of$2.50 in 2023 and $2.30 in 2024 to date.
• Power production, industrial processes, and LNG exports are key drivers of
increased demand and price expected in 2025.
• LNG exports are expected to hit new records in 2025, which will increase total
demand as new export terminals crank up operations and tap into the growing
global use of natural gas. In contrast, demand was driven by domestic
consumption in 2024.
• Prices along the west coast remain relatively high in contrast to gas purchased at
AECO. Utilities who rely in part on west coast pipelines may see higher prices
than others.
For more information, please see RA1 - 2024 PGA Overview.
The Projected Purchased Gas Cost for the 2024-2025 Gas Year includes the costs of
natural gas for the upcoming gas year (i.e., November 1, 2024 to October 31, 2025) and
results in the new rates set forth in Schedule 461.2 The True-Up of the 2023-2024 Gas
Year trues up the costs of natural gas in the previous gas year (November 1, 2023 to
October 31, 2024) by comparing the amount collected from customers in that year with
the actual costs incurred by the Company in the same year. 3 Any over or
under-collection from customers in the 2023-2024 Gas Year, together with any over or
under-collection from previous years,4 is either given back (in the case of
over-collection) or surcharged (in the case of under-collection) to customers in the
upcoming gas year. The True-Up of the 2023-2024 Gas Year results in the new rates
set forth in Schedule 462.5
Projected Purchased Gas Cost for the 2024-2025 Gas Year(Rate Schedule 461)
The Projected Purchased Gas Cost for the 2024-2025 Gas Year comprises two rate
components: 1) the commodity component rate and 2) the capacity or demand
component rate. The rates for these components are represented in Table 1 on a dollar
per therm basis.
2 Schedule 461 is titled "Purchased Gas Cost Adjustment Provision - Oregon."
3 The 2023-2024 Gas Year began November 1, 2023, and concludes October 31, 2024. However, per
page 10 of Appendix A to Order No. 14-238 in Docket No. UM 1286 (See:
https://apps.puc.state.or.us/orders/2014ords/14-238.pdf), all deferrals to be amortized into rates will be
based on June deferral balances plus interest for July—October, and the deferrals that occur after June
will be carried forward to the next PGA period.
4 Any over-collection or under-collection from previous years is because actual volumetric sales of natural
gas will always be different from forecasted volumetric sales. Since amortizations are intended to be
recovered in volumetric forecasted sales, a remaining balance will always be present.
5 Schedule 462 is titled "Gas Cost Rate Adjustment- Oregon."
APPENDIX A
Page 4 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 5
Table 1: Projected Purchased Gas Cost for 2024-20256
($/Therm or as noted otherwise)
Item Current Rate Proposed Rate Change
Commodity 0.33928 0.27787 (0.06141)
Demand 0.15645 0.15493 (0.00152)
Total Gas Cost 0.49573 0.4328 (0.06293)
The commodity component of the weighted average cost of gas (WACOG) proposed for
the 2024-2025 Gas Year is decreasing by $0.06293 per therm, a decrease of 12.7
percent from the previous PGA gas year, as shown in Table 1. Last year, wholesale
natural gas prices were predicted to decrease. As stated above, gas prices are
predicted to continue to decline from the last year's prediction.
The proposed demand component reflects a decrease of approximately 0.00152 per
therm, a decrease of one percent from the previous PGA gas year.
Sharing Election
Avista again elects 90/10 sharing.
Filing and Portfolio Guidelines
Avista's 2024 PGA Filing meets the PGA Filing Guidelines and the Natural Gas Portfolio
Guidelines (Portfolio Guidelines). Avista has demonstrated its adherence to these
Guidelines with regard to natural gas supplies and financial hedges.' Staff's
conclusions are supported by the Company's comprehensive work papers and by
review and discussion as part of the quarterly PGA meetings.
Staff reviewed Avista's forecasted commodity and demand costs to determine whether
the Company complied with the Commission's Portfolio Guidelines. Accepted "best
practices" for the purchase of natural gas supply by a local distribution company (LDC)
results in a portfolio that balances the objectives of reliability, cost control, and
managing price volatility using diversity, flexibility, and balance in a LDC's gas portfolio.
The Portfolio Guidelines implement these "best practices" for Oregon LDCs. The
6 These values are addressed in "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR
COVID Tariff 467", sheets: Calculation - Commodity and Calculation - Demand.
The Portfolio Guidelines require gas utilities to include certain information related to their gas supply
portfolio with their annual PGA filing. Staff's analysis of and conclusions regarding Avista's natural gas
supply portfolio and related purchasing strategies and actions are based on the Portfolio Guidelines
provided in Docket No. UM 1286.
APPENDIX A
Page 5 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 6
Portfolio Guidelines also require each gas utility to include certain information related to
its gas supply portfolio with its annual PGA filing. This information assists the
Commission in determining the prudence of the LDC's costs.
Avista's portfolio preparation and planning process meets the standards in Section III of
the Portfolio Guidelines related to portfolio planning, as do Avista's physical gas
contracts and financial transactions related to natural gas pricing. Avista has also
demonstrated its adherence to the Portfolio Guidelines with regard to natural gas
supplies and financial hedges. In addition, Avista has provided all the information called
for in Section IV (Information and Work Papers), and Section V (Supporting Data and
Analysis) of the Portfolio Guidelines.
True-Up of the 2023-2024 Gas Year(Schedule 462)
Table 2: True-Up of the 2023-2024 Gas Year$
$/Therm or as noted otherwise
Item Current Proposed Change
Rate Rate 9
Commodity Amortization9 ($0.03504) ($0.12110) ($0.08606)
Demand Amortization10 ($0.01985) $0.01709 $0.03694
Total Amortization ($0.05489) ($0.10401) ($0.04912)
Deferral and amortization of residual gas costs from the current and previous PGA
periods results in a ratepayer credit of approximately $5.8 million due to over-collection
in the last year. The over-forecast in commodity prices combined with a smaller
under-forecast in demand produces an overall credit. There is a forecasted decrease of
commodity amortization of approximately $9 million for the period from November 2024
to October 2025 compared to the period from November 2023 to October 2024." This
credit will decrease the gas commodity amortization price by $0.08606 per therm after
accounting for the commodity cost variance sharing between the Company and
customers. There is also a forecasted increase of demand amortization of
approximately $3.2 million for the November 2024 to October 2025 period is forecast
compared to the period from November 2023 to October 2024.
8 Addressed in work paper: "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR
COVID Tariff 467", sheet: Calculation—Amortization.
9 These figures are for Weighted Average Cost of Gas (WACOG) Deferral only.
10 These figures are for Firm Demand Deferral only.
" Addressed in work paper: "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR
COVID Tariff 467", sheet: Attachment C.
APPENDIX A
Page 6 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 7
The percentage changes in Table 3 below reflect the change in revenues resulting from
the PGA filing, and five other advice filings with an effective date of November 1, 2024,
related to the non-base rate portion of the Company's gross revenues for the 2023-24
gas year based on projected customer usage and differs from the three percent
calculation.12
Table 3: Overall Commodity and Related Schedule Revenue and Rate Impact
$ or as noted otherwise
Total Revenue Increase / Change
Schedule Description Revenues at (Decrease) (%)
Current Rates
410 Residential $26,741,061 ($7,070,258) -26%
420 General $14,035,966 ($4,068,506) -29%
424 Large General $1,945,986 ($646,781) -33%
440 Interruptible $5,145,487 ($3,241,552) -63%
444 Seasonal $87,894 ($29,225) -33%
456 Transportation ($76,114) $2,842 NA
Total Commodity Only $47,880,280 ($15,053,480) -31%
Note that Table 3 addresses the aggregate impact of the PGA and associated dockets,
while Table 4 addresses only the Company's 2024 PGA.
Table 4 below reflects only the change in revenues related to the gas commodity portion
of the Company's gross revenues, (Purchased Gas Cost Adjustment Provision;
Schedule 461) and amortization of previous deferrals (Gas Cost Rate Adjustment;
Schedule 462) for the 2024-25 gas year based on projected customer usage.
12 Addressed in work paper: "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR
COVID Tariff 467", sheets: Attachment A Adjust Sched. Summary and Attach B Adjust. Sched. Detail.
APPENDIX A
Page 7 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 8
Table 4: PGA ONLY Revenue and Bill Impact13
$ or as noted otherwise
Total Revenue Increase / Change
Schedule Description Revenues at o
Current Rates (Decrease) (/o)
410 Residential $23,803,669 ($6,050,269) -25%
420 General $12,946,156 ($3,290,575) -25%
424 Large General $1,884,637 ($479,025) -25%
440 Interruptible $5,244,958 ($2,542,315) -48%
444 Seasonal $84,855 ($21,568) -25%
456 Int. Transportation $0 $0
Overall PGA Only $43,964,275 ($12,383,752) -28%
Table 5: 2024-2025 PGA (Including OCAT)
Proposed Residential Rate & Bill Impacts 14
Average Customer Current Proposed Change in % Change
Monthly Monthly Monthly
Therms Charge Bill Bill Bill in Bill
January
96 $11.25 $132.33 1 $119.76 ($12.57) -9.5%
Annual / Monthly
47 $70.53 $70.53 $64.38 ($6.15) -8.7%
Three Percent Test
Pursuant to ORS 757.259(6), ORS 757.259(7), and OAR 860-027-0300, the annual
average rate impact of the amortizations authorized under the statutes may not exceed
three percent of the natural gas utility's gross revenues for the preceding calendar year
unless the Commission finds that allowing a higher amortization rate is reasonable
under the circumstances.
13 Addressed in work paper"2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR
COVID Tariff 467", sheet: Attach B Adjust Sched Detail.
14 Addressed in work paper: "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR
COVID Tariff 467", sheets: Attachment A Adjust Sched. Summary and Attachment D.
APPENDIX A
Page 8 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21 , 2024
Page 9
The resulting annual average rate impact from the PGA amortization and five other
filings calculated in accordance with ORS 757.259 is a decrease in rates compared to
the Company's 2023 total gross revenues, which is below the three percent
amortization limitation specified in ORS 757.259(6).15
Conclusion
Avista's 2024 PGA filing, and five other advice filings filed on July 31 , 2024, reflect a
revenue decrease of $15.1 million, effective November 1 , 2024.
With all changes addressed herein, effective November 1, 2024, the monthly bill of a
residential customer using an average of 47 therms per month will decrease by $6.15,
or -8.7 percent, from $70.53 to $64.38.
Avista has reviewed this memo and agrees with its contents.
PROPOSED COMMISSION MOTION:
Approve Avista's Advice No. 24-02-G, which updates the Company's 2024 annual PGA
tariff sheets, for service rendered on and after November 1 , 2024.
15 The five other filings are: UG 496, UG 497, UG 498, UG 499, and UG 500.
APPENDIX A
Page 9 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 10
Attachment A: Avista Corp 2024 PGA and Related Dockets
Incremental Revenue Change by Customer Rate Schedule (Inclusive of prior COVID Deferral Costs)16
(Red) indicates negative numbers.
Gas Costs and %
Gas Costs and Incremental
Customer Adjustment Contribution
Rate Description Adjustment Revenues at Change Change to Total
Schedule Revenues at proposed in $ by Rate Incremental
Current Rates Rates Revenue Schedule Change
g
410/411 Residential $26,741,061 $19,670,803 ($7,070,258) -26.4% 47.0%
420 Small Commercial and Industrial $14,035,966 $9,967,460 ($4,068,506) -29.0% 26.9%
424 Large Commercial and Industrial $1,945,986 $1,299,205 ($646,781) -33.2% 4.3%
425 Transportation $0 $0 $0 0.0% 0.0%
439 Interruptible Transportation $0 $0 $0 0.0% 0.0%
440 Interruptible $5,145,487 $1,903,935 ($3,241,552) -63.0% 21.4%
444 Seasonal $87,894 $58,669 ($29,225) -33.3% 0.2%
456 Transportation ($76,114) ($73,272) $2,842 3.7% 0.0%
Overall $47,880,280 $32,826,800 ($15,053,480) -31.4% 100.0%
16 Values are drawn from "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR COVID Tariff 467", sheet: Attach A Adjust Sched
Summary in work papers.
" Revenue at "Current' does not reflect current revenues, but rather what the revenues would be if existing rates continued to be in effect during the
upcoming year(i.e., current rates times forecasted therms). There will be small differences with the Advice filings.
APPENDIX A
Page 10 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 11
Attachment B: Avista Corp. 2024 PGA and Related Dockets
Incremental Revenue Change by Adjustment Schedule'$
(Red) indicates negative numbers.
Gas Cost & Gas Cost &
Adjustment Adjustment Total %
Schedule Schedule Contribution
Adjustment Description Total Total Incremental Change Revenue to Total
Schedule Revenue at Revenue at Change Schedule
Rate Incremental
Current Proposed hedule Change
Rates Rates
461 Purchase Gas Adjustment $49,389,381 $42,803,511 ($6,585,870) -13% 44%
Purchase Gas Cost ($5,425,106) ($11,222,988) ($5,797,882) -107% 39%
462 Amortization
467 COVID Deferred Costs $0 ($204,645) ($204,645) 1%
469 Public Purposes $3,286,767 $3,286,767 $0 0% 0%
475 Decouplin $98,935 ($4,102,280) ($4,201,215) -4246% 28%
476 Intervenor Funding $127,376 $148,146 $20,770 16% 0%
478 Demand Side Management $0 $0 $0 0% 0%
Regulatory Fees $106,128 $40,874 ($65,254) -62% 0%
482 Amortization
486 Tax Customer Credit ($2,494,441) ($2,494,441) $0 0% 0%
487 Deferred Tax Credit $0 $0 $0 0% 0%
493 LIRAP $2,791,240 $4,571,859 $1,780,619 64% -12%
Overall $47,880,280 $32,826,803 ($15,053,477) -31% 100%
'$Values are drawn from "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR COVID Tariff 467", sheet: Attach B Rate Schedule
Summary in work papers.
APPENDIX A
Page 11 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 12
Attachment C: Avista Corp. 2024-2025 PGA Three Percent Test19
(Red) indicates negative numbers.
Surcharge Rebate
Prior Period Gas Cost Deferral $0 ($11,223,256)
True-Up
Non-Gas Cost Amortization
Decoupling (Advice No. 24-03-G) $0 ($4,201,216)
Intervenor Funding (Advice No. $148,824 $0
24-04-G
Regulatory Fees (Advice $40,602 $0
No 24-05-G
LIRAP (Advice No 24-06-G) $1,485,671 $0
COVID (Advice No 24-07-G) $0 ($204,870)
Subtotal $1,675,097 ($15,629,342)
Total ($13,954,245)
Total Proposed Amortization (Surcharge Less Credits) ($13,954,245)
Less intervenor Funding ($148,824)
Net Proposed Amortization (subject to the 3% test) ($14,103,069)
Utility Gross Revenue 2023 $171,339,357
3% of Utility Gross Revenue $5,140,181
Allowed Amortization ($14,103,069)
Allowed Amortization as % of Gross Revenues 0%
19 Values are drawn from "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR COVID Tariff 467", sheet: Attachment C.
APPENDIX A
Page 12 of 13

ORDER NO. 24-395
Docket No. UG 495/Advice No. 24-02-G
October 21, 2024
Page 13
Attachment D: 2024--2025 PGA
Proposed Rate & Bill Increases by Class of Service20
(Red) indicates negative numbers.
Rate ImpactS21
Class of Rate Current Rate Proposed Rate Change Rate % Change Rate
Service Schedule per Therm per Therm per Therm per Therm
Residential
Avista 410/411 $1.26 $1.13 ($0.13) -10.40%
Commercial
Avista 420 $1.20 $1.06 ($0.14) -11.50%
Industrial
Avista 424 $0.60 $0.45 ($0.15) -25.30%
Interruptible
Avista 440 $0.41 $0.23 ($0.19) -45.40%
20 Values are drawn from "2024 Confidential Oregon PGA Work papers (09.13.24) UPDATE FOR COVID Tariff 467", sheet: Attachment D in work
papers.
21 The residential rates illustrated above do not include pass-through charges included on customer bills that utilities are required to collect and
distribute to the appropriate third parties, such as for franchise fees or the Public Purposes Charge.
APPENDIX A
Page 13 of 13

ORDER NO. 24-403
ENTERED Nov 01 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UG 519
In the Matter of
ORDER
AVISTA CORPORATION, dba AVISTA
UTILITIES,
Request for a General Rate Revision.
DISPOSITION: TARIFF SHEETS SUSPENDED
On November 1, 2024, Avista Corporation, dba Avista Utilities, filed tariff sheets in
Advice No. 24-09-G to be effective December 1, 2024. The filing seeks a general
increase in customer rates. I find good and sufficient cause exists to investigate the
propriety and reasonableness of the tariff sheets under ORS 757.210 and 757.215.
ORS 757.215(1) authorizes the suspension of a rate filing for a period up to nine months.
I conclude at this time that a nine-month suspension is necessary to investigate this
general rate proceeding.
ORDER
IT IS ORDERED that Advice No. 24-09-G filed by Avista Corporation, dba Avista
Utilities, is suspended for a period of time of up to nine months from December 1, 2024,
the effective date of the tariff sheets.
Made, entered, and effective Nov 1,2024
Alison Lackey
Chief Administrative Law Judge
�cP
'a cP
OF'OREG0

ORDER NO. 24-426
ENTERED Nov 27 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UM 2211
In the Matter of
PUBLIC UTILITY COMMISSION OF ORDER
OREGON,
Implementation of House Bill 2475.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
This order memorializes our decision,made and effective at our November 26, 2024
Regular Public Meeting,to adopt Staff s recommendation regarding data sharing with the
Energy Trust of Oregon. Specifically, we direct Portland General Electric Company;
Northwest Natural Gas Company, dba NW Natural; PacifiCorp, dba Pacific Power;
Avista Corporation, dba Avista Utilities; and Cascade Natural Gas Corporation to share
bill discount program schedule customer participation indicators with Energy Trust of
Oregon beginning no later than January 2025. Additionally, as discussed during
deliberations,we expect collaboration between the Energy Trust of Oregon and existing
community partners and program providers in order to coordinate offers to maximize
access and reduce customer confusion. The Staff Report with the recommendation is
attached as Appendix A.
Made, entered, and effective Nov 27 2024
Megan W.Decker Letha Tawney
Chair Commissioner
�XI IT Y CO
v= ` Les Perkins
Commissioner
OF=OREGO�
A party may request rehearing or reconsideration of this order under ORS 756.561.A request
for rehearing or reconsideration must be filed with the Commission within 60 days of the date
of service of this order. The request must comply with the requirements in OAR 860-001-
0720.A copy of the request must also be served on each party to the proceedings as provided
in OAR 860-001-0180(2). A party may appeal this order by filing a petition for review with
the Circuit Court for Marion County in compliance with ORS 183.484.

ORDER NO. 24-426
ITEM NO. RA1
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
PUBLIC MEETING DATE: November 26, 2024
REGULAR x CONSENT EFFECTIVE DATE N/A
DATE: November 19, 2024
TO: Public Utility Commission
FROM: Michelle Scala, Kate Ayres, and Benedikt Springer
THROUGH: Caroline Moore and Scott Gibbens SIGNED
SUBJECT: OREGON PUBLIC UTILITY COMMISSION STAFF:
(Docket No. UM 2211)
Recommendations for addressing energy burden through arrearage,
disconnection, and customer program activities.
STAFF RECOMMENDATION:
Approve Oregon Public Utility Commission (OPUC or Commission) Staff's
recommendations regarding:
• Interim customer protections against the risks of arrearages and
disconnection as outlined in Attachment 1, and
• Utility data sharing requirements by directing Portland General Electric,
Northwest Natural Gas Company, Pacific Power, Avista Utilities, and Cascade
Natural Gas to include respective bill discount program schedule identifiers with
Energy Trust of Oregon beginning no later than January 2025.
DISCUSSION:
Issue
Whether the Commission should adopt Staff's near-term customer protections against
disconnection and guidance on customer program activities.
Further, whether the Commission should direct Portland General Electric, Northwest
Natural Gas Company, Pacific Power, Avista Utilities, and Cascade Natural Gas to
include respective bill discount program schedule identifiers with Energy Trust of
Oregon during their regular data sharing cycles.
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Docket No. UM 2211 ORDER NO. 24-426
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Page 2
Further, Staff supports a pause of PacifiCorp's Low-Income Discount Program re-
enrollment process. Staff does not believe that the Commission needs to take action to
accomplish this because the Company has agreed to a pause reenrollment through
March 1, 2025, and engage stakeholders.
Applicable Law
ORS 756.040 (2) vests the Commission with power and jurisdiction to supervise and
regulate every public utility in this state, and to do all things necessary and convenient
in the exercise of such power and jurisdiction.
ORS 757.205 requires public utilities to file schedules showing all rates, tolls, and
charges for service that have been established and are in force at the time. Pursuant to
ORS 757.210, the Commission may approve tariff changes if they are deemed to be
fair, just, and reasonable.
Under ORS 757.210(1)(b), "automatic adjustment clause" means "a provision of a rate
schedule that provides for rate increases or decreases or both, without prior hearing,
reflecting increases or decreases or both in costs incurred, taxes paid to units of
government or revenues earned by a utility and that is subject to review by the
commission at least once every two years."
Filings that make any change in rates, tolls, charges, rules, or regulations must be filed
with the Commission at least 30 days before the effective date of the changes.
ORS 757.220; OAR 860-022-0015. Tariff filings to be effective on less than 30 days
following notice of the change may be authorized with a waiver of less than statutory
notice pursuant to ORS 757.220 and OAR 860-022-0020.
ORS 757.230, as amended by HB 2475, provides the Commission authority to take
certain considerations into account when determining a comprehensive classification of
service for each public utility; including, the quantity used, the time when used, the
purpose for which used, the existence of price competition or a service alternative, the
services being provided, the conditions of service, differential energy burdens on low-
income customers and other economic, social equity or environmental justice factors
that affect affordability for certain classes of utility customers.'
ORS 757.695, codifying HB 2475's Section (7)(1), provides that the Commission may
address the mitigation of energy burdens through bill reduction measures or programs
that may include, but need not be limited to, demand response or weatherization.
Further, the statute provides that the costs of tariff schedules, rates, bill credits or
program discounts must be collected in the rates of an electric company through
The Energy Affordability Act(HB 2475—2021 Regular Session) amended ORS 756.610, ORS 757.230,
and ORS 757.072 and enacted new provisions to address equity in rate setting and participating in PUC
proceedings, effective January 1, 2022. Or Laws 2021 Ch. 90.
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Docket No. UM 2211 ORDER NO. 24-426
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Page 3
charges paid by all retail electricity consumers, such that retail electricity consumers
that purchase electricity from electricity service suppliers pay the same amount to
address the mitigation of energy burdens as retail electricity consumers that are not
served by electricity service suppliers.2
OAR 860-021-0407 establishes a severe weather moratorium on involuntary
disconnection of residential utility service for non-payment. Pursuant to this rule, a utility
may not disconnect a residential service for nonpayment from November through March
on any day that a temperature of less than 32 degrees Fahrenheit is forecasted or a
winter storm warning indicating weather conditions that pose a threat to life or property
is issued by the applicable weather reporting service. OAR 860-021-0407(1). Similarly,
an electric utility must not disconnect residential service for nonpayment on any day a
local heat advisory is issued by the weather reporting service. OAR 860-021-0407(2).
Such moratoriums on disconnection must remain in effect until at least the start of the
next business day.
OAR 860-021-0305(c) states that an energy utility may disconnect a customer when the
customer fails to pay Oregon tariffed or price-listed charges for services rendered.
OAR 860-0407(9) provides that upon request from a customer who has been
disconnected for nonpayment within the previous 72 hours of a severe weather or air
quality condition outlined in sections (1), (2), and (3) of this rule, an energy utility must
make best efforts to reconnect service. The energy utility may apply reconnection fees
authorized in OAR 860-021-0330 to any reconnection.
OAR 860-021-0305(1)(a) provides that an energy utility may disconnect service when
an applicant or customer fails to pay a deposit or make payments in accordance with
the terms of a time payment agreement.
Pursuant to OAR 860-021-0330, an energy utility may charge a reconnection fee in its
tariff except for when the following exceptions apply: (1) when the utility has the ability
to perform remote reconnections, it may not charge a reconnection fee for a low-income
residential customer, (2) for utilities that do not have the ability to perform remote
reconnections, the utility may not charge the reconnection fee for a low-income
residential customer for the first two reconnections in a calendar year, and (3) natural
gas utilities may not assess reconnection fees for low income residential customers for
the first reconnection in a calendar year.
OAR 860-021-0335(2) provides that an energy utility shall provide service to a
residential customer or applicant upon receiving payment equal to at least one-half of
any overdue amount of an Oregon tariffed or price-listed charge and any other like
obligation related to a prior account...provided the customer or applicant has made
2 ORS 757.695(2).
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Docket No. UM 2211 ORDER NO. 24-426
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Page 4
reasonable or partial payment on the account during the time the service has been
discontinued.
OAR 860-021-0126 governs utility late-payment charges and states that an energy
utility may apply a late charge to customer accounts that are not paid in full each month,
provided the utility has filed the late-payment charge in its rate schedule. OAR 860-021-
0126(1). OAR 860-021-0126 further provides hat energy utilities shall not impose late-
payment charges on the accounts of low-income residential customers.
OAR 860-021-0200(2) authorizes utilities to collect deposits from customers that are not
low-income. Such deposit may be collected when a customer fails to establish credit for
utility service, was a previous customer of the utility before termination of service and
left with an outstanding balance or was terminated as a customer due to theft or
tampering with the utilities facilities.
OAR 860-021-0205(7) provides that "[i]f disconnection for nonpayment of a deposit
occurs, the customer disconnected shall pay the full amount of the deposit, any
applicable reconnection fee, late-payment fee, and on-half the past due amount before
service is restored."
OAR 860-021-0005 provides that the Commission, upon its own motions, may waive
any of the Division 021 rules for good cause shown.
OAR 860-086-0030(2)(i) states that electric companies must transfer rate schedule
identifier information for each customer account to Energy Trust. Similarly, OAR 860-
086-0040 (1)(a)(H) provides that gas utilities that offer energy conservation programs
through ETO must provide rate schedule identifier information for each customer
account with Energy Trust, provided the information is available in the gas utility's
records.
Analysis
Background
Effective January 1, 2022, Oregon House Bill 2475 (HB 2475) expanded language
under ORS 757.230 to include additional factors the Commission may consider when
establishing rate classifications. Such factors included "differential energy burdens on
low-income customers and other economic, social equality or environmental justice
factors that affect affordability for certain classes of utility customers." The Commission
has initiated a phased implementation effort that begins with interim actions to provide
customers near-term relief followed by a longer-term investigation to fully explore and
establish the Commission's policies for differential rates and programs.
In the first phase of HB 2475 implementation, the Commission approved interim bill
discount programs based on household income for Portland General Electric (PGE),
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Docket No. UM 2211 ORDER NO. 24-426
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Page 5
PacifiCorp (Pacific Power), Northwest Natural Gas Company (NW Natural), Avista
Utilities (Avista), and Cascade Natural Gas Company (Cascade). As of October 15,
2024, Idaho Power Company (IPC) has also implemented a bill discount program under
the authority of HB 2475.
Phase two of Staff's HB 2475 implementation effort was scoped in the first quarter of
2024 and focused on:
• Establishing an energy burden data reporting framework.3
• Identifying near-term opportunities to overcome barriers to access for
weatherization, energy efficiency, and current utility bill discount programs.
• Discussing bill discount program improvements in general rate cases and
initiating broader rates discussions in Q1 2025.4
Staff revised this strategy in August 2024 following concerns with the level of arrearages
and disconnections observed in 2024.5 The revised workstream allowed Staff to focus
its efforts on interim protections that would mitigate customer harms associated with
arrearages and disconnections prior to the 2024-2025 heating season.
In addition to the UM 2211 work streams, NW Energy Coalition (NWEC) and the
Coalition of Communities of Color (CCC) submitted a letter to the Commission on
November 13, 2024, requesting postponement of the re-enrollment process for
PacifiCorp's income qualified bill discount program until October 2025 or until PacifiCorp
can successfully engage with advocates on its outreach and support plans around re-
enrollment.6
Despite the volume of ratemaking dockets and complex matters before the Commission
in 2024, a broad group of UM 2211 participants made time to engage in a meaningful
discussion of near-term opportunities to advance the goals of HB 2475. This year-long
effort culminated in two sets of recommendations for consideration by the Commission:
1) interim arrearage and disconnection protections for the 2024-2025 heating season
and 2025 cooling season; and 2) near-term opportunities to enhance delivery of energy
efficiency and weatherization to energy burdened customers. The remainder of this
Staff report outlines Staff's key findings and recommendations in these two work
3 Staff plans to bring the energy burden data reporting framework to the Commission for consideration at
the December 10, 2024 Regular Public Meeting.
4 See In re OPUC Implementation of HB 2475, Staff's Phase 2 Survey Synthesis and Updates, OPUC
Docket No. UM 2211, April 16, 2024 (available at:
https://edocs.puc.state.or.us/efdocs/HAH/um2211 hah327921024.pdf).
5 See In re OPUC Implementation of HB 2475, Phase 2 Work Plan Update, OPUC Docket No. UM 2211,
Aug 6, 2024 (available at: https://edocs.puc.state.or.us/efdocs/HAH/um2211hah330538055.pdf
(accessed Nov 13, 2024).
6 See In re OPUC Implementation of HB 2475, NWEC and CCC Request to Temporarily Suspend PAC's
Low-Income Discount Re-Enrollment Process, OPUC Docket No. UM 2211, November 13, 2024
(available at: https://edocs.puc.state.or.us/efdocs/HAH/um2211 hah332933120.pdf).
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Docket No. UM 2211 ORDER NO. 24-426
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Page 6
streams and responds to stakeholders' request to pause PacifiCorp's reenrollment
process for its low-income discount program.
Arrearage and Disconnection Workstream
As several stakeholder comments have pointed out, rescoping Phase 2 to include the
arrearage and disconnection workstream and timeline necessitated an accelerated
engagement process, particularly given the urgency of having additional protections and
relief available in the 2024-2025 winter heating season. Staff endeavored to find ways
to meaningfully engage utility and non-utility stakeholders along this expedited timeline
and against concurrent docket schedules. Some of these concurrent proceedings
included contested general rate cases (GRC) where stakeholders participating in both
the GRC(s) and UM 2211 were raising similar concerns around arrearages and
disconnections and proposing potential Commission actions.
That said, through UM 2211, Staff provided a series of workshops and comment periods
in order to gather feedback and share Staff's ongoing review of available arrearage and
disconnection data, and emerging ideas on how to address these issues. In these
venues, Staff brought forward ideas for the group to consider from various sources,
including but not limited to: existing utility-specific programs; recently completed Oregon
Investor-Owned-Utility (IOU) Energy Burden Assessments (EBAs); Oregon IOU general
rate case testimony; Oregon's 2021 rulemaking to strengthen customer protections
concerning disconnections, AR 653; National research; and other state policies and
practices. Initiating discussions was Staff's workshop on the Staff Residential Arrearage
and Disconnection Assessment held on September 17, 2024.
Stakeholders provided comment on the assessment through October 18, 2024. Staff
notes that the review of the document and comments provided a valuable look at some
of the existing data challenges, including but not limited to, post-filing corrections and
reporting differences between utilities. Staff looks to address many of these challenges
for future reporting through its proposed Energy Burden Metrics Report (EBRM) coming
before the Commission as part of the data workstream. Staff also flags that during the
workshop, utility stakeholders helped to identify a limited set of inaccuracies on certain
graphs shown in the assessment. PGE and Avista provided corrected versions of the
affected graphs in October 9, 2024, comments.
To the extent that several utility stakeholder comments provided little feedback on
possible protections, implementation considerations, and existing arrearage and
disconnection mitigation proposals linked from other dockets and discussions, Staff
strived to develop a list of potential actions for the group to consider in a draft document
and provide direct comment with the goal of refining the list based on this input. As
such, on October 25, 2024, Staff filed its initial draft Arrearage and Disconnection Action
Plan for stakeholder comment. In response to requests for additional engagement and
comment periods, Staff agreed to an extended timeline inclusive of two additional
workshops to discuss the plan prior to a revised comment deadline and later public
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Docket No. UM 2211 ORDER NO. 24-426
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Page 7
meeting date.
While there was some misunderstanding regarding the state of finality and intent of
Staff's initial draft from utility stakeholders, positively, both the draft and subsequent
workshops provided a platform for robust dialogue, valuable information sharing, and
productive change. Staff genuinely appreciates stakeholders' willingness to come to the
table, particularly for limited noticed workshops, and talk through concerns, objectives,
and solutions. Following the second workshop, held on November 7, 2024, workshop,
Staff shared a second working draft, with redlines and working commentary, to help
stakeholders inform comments and memorialize the evolving action plan. One of Staff's
central goals with engagement in this process has been to create a final Action Plan
proposal that is reflective of the various concerns and perspectives of UM 2211 utility
and non-utility stakeholders, and centered on the overarching priorities of:
1. Reducing harms in high-risk conditions (e.g., weather and customer specific).
2. Reducing financial barriers to getting and staying connected.
3. Providing broad customer protections to increase reach and efficacy of priorities
1 and 2.
Staff Recommendations —Arrearage and Disconnection Protections
The following list captures Staff's final recommendations, in detail, to provide near-term
interim relief to residential customers from the harms of arrearages and disconnection.
Staff is recommending that the Commission adopt these temporary protections in
advance of significant seasonal spikes in residential usage attributable to the winter
heating season. Staff is also recommending the Commission allow the protections to
remain in effect through September 30, 2025, in order to maintain these enhanced
protections through the 2025 cooling season and until the conclusion of Staff's planned
rulemaking that would seek to formalize a version of enhanced protections against
disconnection. Staff also requests that to the extent a waiver is needed for utilities to
comply with these enhanced protections, that the Commission grant the necessary
waivers. A detailed list of the following table is provided in Attachment 1.
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Docket No. UM 2211 ORDER NO. 24-426
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Page 8
Open
Proposed •A• Recommended Exemptions
N M inGRC
Expanded Eligibility
la.Define neweligible population as"qualified households"(up to 80%SMI and med cert) N OAR 860-021-0180; Exemption for Idaho Power
OAR 860-021-0410
1b.Expand IPC Winter Protection Program to include IPC Bill Discount for Qualified N
Customers Program participants'
Cold Weather Protections
2a.Add Date-Based moratorium for qualified households(December 1-April 1) Y OAR 860-021-0407(1) Exemption for Idaho Power
Alternate recommendation:Exempt natural gas utilities
2b.Expand Low Temperature-Based Protections to cover 24-hours before severe weather N OAR 860-021-0407(1) Exemption for Idaho Power
Hot Weather Protections
3a.Expand the Temperature-Based moratorium to include the 24-hours before and 48 hours N OAR 860-021-0407(2) Exemption for all natural gas utilities and Idaho Power"
following a local heat advisory in counties where the Exposure Index is greater than 65
Reconnection Costs
4a.Allow recently disconnected qualified households to request reconnection up to 7 days N OAR 860-021-0407(9) Natural gas utilities exempt in severe hot weather
before severe weather without reconnection fees IPC applies to expanded definition of WPP customers
4b.Eliminate all reconnection charges for bill discount participants earning 0-15%SMI Y OAR 860-021-0330
Arrearage Relief
5a.One-time arrearage Forgiveness to households earning at or below 0-5%SMI Y Already in compliance:Avista,Cascade Natural Gas
Exemption for Idaho Power
5b.Offer qualified households enrolled in bill discount minimum 1-month date-based Already in compliance:Avista,Cascade Natural Gas
forbearance options on TPAs upon request(available Dec 1-April 1 and July 1—Sep 1) N Exemption for Idaho Power
HB 2475 Discounted Rate Programs
Already in compliance:Northwest Natural,Avista,
6a.Increase monthly discounts for tier(s)for 0-10%SMI Y Cascade Natural Gas
Exemption for Idaho Power
Noticing and Outreach
7a.Notify customer of enhanced protections during key touch points N
7b.Notify Community Action Agencies of enhanced protections N
7c.Post information on enhanced protections on website N
7d.Train customer service representatives on enhanced protections N
https://docs.idahopower.com/pdfs/aboutus/ratesregulatory/tariffs/bill-discount-qualified-customers-program.pdf
$Currently, only Multnomah County has an exposure index of>65. https://experience.arcgis.com/experience/5f6aOel785524df8853e94776693dOf7/page/HVI-County/.
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Docket No. UM 2211 ORDER NO. 24-426
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Actions removed from original draft near-term proposal to be explored In future proceeding
Define"Qualified Households"for enhanced protections beyond income
Direct contact for disconnection under before during and after severe weather
Standardize and direct minimum past-due amount for disconnection
Prohibit the use of disconnection prioritization scores on Qualified households
Limit the required balance pay-off for Qualified households seeking reconnection
Eliminate reconnection charges and all arrearage and disconnection related fees for Qualified
Households
Eliminate late fees for all residential customers y
Eliminate security deposits for all residential customers
Retroactively apply qualified discounts to customer arrears y
Arrearage Management with tiered matching payments
Adopt flexible TPA and AMP term structures
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Docket No. UM 2211 ORDER NO. 24-426
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Staff notes that Action Plan item (6) "HB 2475 Discounted Rate Programs" is only
applicable to Portland General Electric and PacifiCorp, as written. Further, changes to
the discounts of these programs are currently under Commission consideration in the
on-going general rate case proceedings. Staff would clarify that it has included that item
in this Action Plan to reflect Staff's opinion on the value of deeper discounts for lower
income tiers to reducing the harms of arrearages and disconnections. That said, the
presence of item (6) in the Action Plan is not intended to supersede or be duplicative of
any decisions on income qualified bill discount program proposals in either Portland
General Electric's UE 435 or PacifiCorp's UE 433. Staff's understanding is that it is at
the Commission's discretion to adopt guidance relative to qualified discount programs in
either the aforementioned rate cases or this docket, should it choose to at all. In the
event the Commission does adopt discount changes in either proceeding, Staff would
further clarify that the September 1, 2025, sunset date applicable to all other Action Plan
items, would not be expected to apply income qualified bill discount programs.
For the purposes of this docket and workstream, Staff is asking the Commission to
decide whether it will direct the utilities, to implement the near-term interim protections
as outlined in the summary table and detailed in Attachment 1. Accepting any or all of
Staff's recommended protections in this proceeding would provide a bridge between the
2024-2025 winter heating season and the adoption of permanent rules following
additional engagement and process in 2025. If the Commission declines to adopt Staff's
protection in favor of prioritizing the additional engagement and process, Staff will
endeavor to bring a proposal for a formal rulemaking before the Commission in or
before Quarter 2, 2025.
Strategic Approach
As noted earlier in this memo, Staff's primary focus in crafting its recommendations has
generally centered on three priorities. The first has been to advance actions that reduce
harms when the risk of harm is highest. For example, during severe weather and for
vulnerable households. Second, Staff sought to identify interim actions that promote
energy security for vulnerable households. For example, those that would provide for
targeted relief from arrearages and utility disconnection or reconnection policies that
exacerbate affordability challenges and customer harms. Lastly, given the reality that
eligibility-based protections often do not reach all the intended households, Staff has
recommended a limited selection of expanded protections that could be assessed
broadly across all residential customers without requiring enrollment or account
identification.
Staff reiterates that these actions are meant to provide near-term relief from the rate
pressures facing customers in both the 2024-2025 winter heating season and, for some
utilities, rate increases, effective January 1, 2025. While there is a hot-weather inclusion
that some have argued lacks the urgency of the cold-weather protections, Staff has put
this forward as a safeguard, should rules not materialize before the 2025 cooling
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Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 11
season when the urgency emerges to avoid heat-related harms.9
Staff has observed increases in both arrears and disconnections in response to both
seasonal usage spikes and immediately following a rate increase. It is widely known
and evidenced, across the state, country and globe, that the health and financial
consequence of an energy shut off can be significant. Research has shown energy
insecurity is linked to poor respiratory health, poor sleep, food insecurity, and adverse
mental health outcomes. The economic impacts of a customer's inability to pay and
resulting disconnection can also lead to evictions, foreclosures, low credit scores, the
inability to establish future service accounts, and children being removed from their
parent's care. These impacts disproportionately affect already vulnerable households,
such as low-income, black, and other environmental justice communities. These are
realities that are well-documented10 and persist regardless of interpretations on "the
level of crisis" between stakeholders. While Staff is certain that further investigation and
proposals are needed to fully explore and address these challenges, Staff believes the
Action Plan items proposed in this phase provide a balanced and measured strategy to
combat this climate of heightened risk and potential harms without overreaching ahead
of additional process.
Staff clarifies that these proposed protections are also a way of standardizing some
baseline and last stage protections against harms facing customers. There are some
utilities where current practices have the potential to provide greater protection for
customers in case-by-case scenarios. Staff appreciates those instances and policies
demonstrated by Avista's crisis grants and "feel free to fix it" practices. These are
excellent models that elevate the human component in utility service.
Staff believes that the proposal does not impede on these and other existing practices,
but rather raises the bottom line that utilities remain free to outperform, provides relief in
territories where these types of programs are not readily available or consistently
administered, and fills in persistent gaps within existing protections that have come to
light over the last year. Staff is confident that the final version of the Action Plan it has
brought before the Commission offers meaningful relief from the harms of disconnection
with thoughtful refinements that embrace collaboration and endeavor to accommodate
stakeholder feedback, particularly regarding implementation, fuel- and utility-specific
nuance, cost control, and intersections with existing rules. In the interest of providing
some additional context to the proposals Staff ultimately decided to include, Staff would
offer the following supporting discussion points behind the Action Plan:
lhttps://www.oregon.gov/oha/ph/preparedness/prepare/pages/prepareforextremeheat.aspx?utm source=
OHA&utm medium=eqov redirect&utm campaign=https%3A%2F%2Fwww.oregon.gov%2Fheat;
https://www.oregon.gov/oha/PH/H EALTHYENVI RON M ENTS/CLI MATECHANG E/Docu ments/FI NAL%20
Climate%20Health%20in%200regon%202023%2OyO7l l24%20(1).pdf.
10 Laird, J., & Hernandez, D. (2021). Surviving a shut-off: U.S. households at the greatest risk of utility
disconnections and how they cope. American Behavioral Scientist.
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Docket No. UM 2211 ORDER NO. 24-426
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• Cold- and Hot-weather Related Protections: Regarding severe weather,
Staff's proposal is designed to address major health risks associated with energy
limiting behaviors, poor housing infrastructure, climate change effects and heat
islanding. It is further meant to address gaps relative to disconnections that occur
more than 72 hours prior to a severe weather event, which can leave many
households exposed to dangerous temperatures if they are unable to reconnect
through traditional means. Staff finds that providing additional runway and safety
nets for households to get reconnected or preemptively heat and/or cool their
house in advance of dangerous temperatures can have a significant positive
impact on health and human safety and should be implemented prior to what is
forecasted to be a wetter and colder winter for Oregonians."
• Arrearage Relief, Reconnection Fees, and HB 2475 Discounts: Staff has
endeavored to take a very incremental and targeted approach, limiting its
proposals to households earning 10 percent SMI or below in terms of direct
assistance provisions, or 15 percent SMI and below for relief from reconnection
charges. It is important to note that customers struggling to pay existing energy
bills cannot respond to fee signals nor compound monthly energy bills with
unassisted payment arrangements for past due balances without incurring
additional harm. This harm takes form in cyclical disconnections, energy limiting
behavior, foregoing other essential household needs,12 and all the many
byproducts of those outcomes mentioned earlier in this section. By taking actions
that can reduce the monthly energy burden these households experience and the
degree to which arrearages and seasonal spikes exacerbate the burden, we will
be more successful and mitigating the associated harms of energy insecurity and
disconnection. Staff is recommending that utilities implement arrearage relief
terms adopted in this proceeding no later than January 1, 2025.
• Noticing and Outreach: Staff has tried to craft this part of the proposal to build
in flexibility for both input from community stakeholders and utility existing
practices. The primary objective in this section of the Action Plan is to ensure that
customers are made aware of their protections to the full extent possible and
particularly at critical junctures in the energy assistance and/or disconnection
process. Staff does not wish to be overly prescriptive but encourages actions that
avoid common pitfalls in communication and outreach strategies. Several utility
EBAs noted a significant number of customers eligible for assistance that did not
access it and were ultimately disconnected for nonpayment. Staff hopes that in
the interest of allowing any adopted actions to have meaningful impact for
customers, utilities can work with UM 2211 parties and their existing systems to
help households access the right programs and protections.
11 https://www.opb.org/article/2024/10/18/noaa-releases-annual-winter-outlook-for-2024-2025-season.
12 Bhattacharya, J., DeLeire, T., Haider, S., & Currie, J. (2003). Heat or eat? Cold-weather shocks and
nutrition in poor American Families.American Journal of Public Health. (93).
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• Expanded Eligibility: Staff has heard from several stakeholders and UM 2211
contributors that the current income-qualifying thresholds for many of the state's
assistance programs fail to reach many utility customers that experience the
same energy insecurity and persistent harms as those who do qualify. This is
because the gross income measure, particularly at 60 percent SMI, does not
account for other socioeconomic characteristics of the household that can lead to
disproportionate energy burden and increased risk for energy insecurity. While
Staff initially proposed a more comprehensive and inclusive definition of
"qualified households" to expand eligibility for enhanced protections, following
discussions with stakeholders, Staff ultimately decided to propose a more limited
change in recognition of near-term implementation needs and the need for
additional engagement and input on the definition and included populations. To
this end, Staff has proposed to define qualified households in this proceeding as
households who verify or self-attest to a household income up to 80 percent SMI,
adjusted for household size and medical certificate accounts. Additionally, due in
part to the exemptions afforded to Idaho Power Company for many cold weather
protections as a result of the Company's existing Winter Protection Program
(WPP), Staff has proposed to expand eligibility of the IPC WPP to include
participants in its Bill Discount Program for Qualified Customers. Staff believes
these expansions successfully mitigate the negative impacts of known gaps in
current eligibility thresholds and help extend relief to customers exposed to
similar level of risks as a result of hardships and vulnerabilities not reflected in
current eligibility assessments. Staff has also heard from utilities that this
approach presents fewer administrative challenges and is more likely to be
successful in providing targeted protections in the near term.
Staff would note that changes from actions proposed in Staff's initial draft should not be
interpreted as action lacking merit. Reasons for removal or refinement likely included
one or more of the following:
• Significant implementation challenges for utilities as a near-term action.
• Did not evidence sufficient urgency to address significant or disproportionate
harms in either the 2024-2025 winter heating or 2025 summer cooling season.
• Significant value to be garnered from additional process and investigation without
significant risk from delayed adoption.
• Reasonable alternative proposed in its place.
Staff intends to take many of the current and since removed or refined actions under
review within the more comprehensive process and rulemaking to go before the
Commission in 2025.
Stakeholder Comments
Overall, Stakeholders agreed upon the importance of data-supported actions that reflect
the available existing programs and any identified gaps. Joint Energy Justice (EJ)
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Docket No. UM 2211 ORDER NO. 24-426
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Advocates highlighted the importance of a shared understanding of disconnection
protections, practices, and available utility programs surrounding arrearages, along with
up to date data reporting from utilities to fully understand the scope and scale of the
problems.13 Joint Utilities stressed that the baseline information presented in Staff's
assessment and workshop surfaced questions about customer trends and urged for the
actions to be reflective of the currently available programs and utility systems along with
data.14 The following section summarizes and responds to key feedback on Staff's
proposal.
Level of Crisis and Need for Action
Within this workstream, Staff has focused on two aspects of minimizing exposure to the
most unsafe disconnections: addressing the magnitude of existing arrearage balances
and limiting the conditions under which customers get and remain disconnected.15
These areas of concern were observed in RO 12, the energy utility disconnection
reports, and within PacifiCorp's (UE 433) and PGE's (UE 435) recently filed rate cases.
For example, average arrears for each of the reported aged-buckets have risen for PGE
customers over the last two years where the data was reported. PacifiCorp customers in
various aged arrears have seen some declines in the last 24-months but total residential
arrears are more than double pre-pandemic levels. Staff sought action within this
workstream in alignment with HB 2475 as an additional step to monitor utility interim bill-
discount programs and to provide additional support to help mitigate energy burden for
vulnerable customer populations, which are often more susceptible to disconnection.
Stakeholder Comments
The Joint Utilities highlighted in comments that "arrearage and disconnection trends are
not uniform across all utilities and are not clearly in a broad state of crisis." Additionally,
Joint Utilities were concerned that Staff had not articulated an actionable problem
statement and stated that Staff implied disconnection itself was the problem.16
EJ Advocates' Additional Comments support near term action citing the data on
customer arrears pointing to a need for a different approach as indicated by utilities
Energy Burden Assessments.17 Additionally, Joint EJ Advocates flag that we are seeing
pre-pandemic levels of disconnection despite two years of HB 2475 interim discount
13 Joint Energy Justice Advocates, September 24, 2024, UM 2211 — Energy Advocate's Initial Comments
on Staff's Residential Arrearages and Disconnections Assessment,
https://edocs.puc.state.or.us/efdocs/HAC/um2211 hac331602120.pdf.
14 Joint Utilities, October 9, 2024, UM 2211, Joint Utility Response to Staff's Residential Arrearage and
Disconnection Assessment, https://edocs.puc.state.or.us/efdocs/HAC/um2211 hac331985120.pdf.
15 OPUC Staff, October 25, 2024. UM 2211, Staff's proposed Phase 2 Arrearage and Disconnection
Action Plan, https://edocs.puc.state.or.us/efdocs/HAH/um2211hah332395120.pdf.
16 Joint Utilities, October 9, 2024, UM 2211, Joint Utility Response to Staff's Residential Arrearage and
Disconnection Assessment, https://edocs.puc.state.or.us/efdocs/HAC/um2211 hac331985120.pdf.
1'Joint Energy Justice Advocates, October 18, 2024, UM 2211 — Energy Advocates' Additional
Comments on Arrearages and Disconnections Workstream,
https://edocs.puc.state.or.us/efdocs/HAC/um2211 hac332214120.pdf.
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Docket No. UM 2211 ORDER NO. 24-426
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programs and improvements to rules related to disconnection through AR 653.
Staffs Response
Staff has consistently maintained that the objective of the Arrearage and
Disconnection workstream in Phase 2 of UM 2211 is mitigating human harms
associated with these processes, particularly where they are exacerbated by
socioeconomic inequities. While the volume of aggregated arrearages and
disconnections varies across utilities, the level of risk to the most exposed
customers does not. Staffs interim proposal is focused on protections for the subset
of customers facing the most unsafe circumstances, rather than focusing on a
generic reduction in the volume of disconnections. To the extent that customers are
facing these circumstances at any utility, Staff does not see a benefit in restricting
access to the interim protections. To the extent that the utility has existing
mechanisms that offer similar or more comprehensive solutions, Staff has
endeavored to reflect that.
Staff also disagrees that current arrears and disconnection levels are safe for
customers simply because some utilities are returning to pre-pandemic levels. While
Cascade and Avista have seen declines in disconnection rates in the last year, they
are unique, and Staff does not believe that two-years and tens of millions of dollars
in assistance can have a negligible impact and not warrant additional review or
action. Further, if the energy burden mitigation effects of the discount programs can
reasonably be argued to have such a long runway, then Staff finds all the more
value in providing some additional enhancements to protections against the harms
of arrearages and disconnections while these programs take effect.
Administrative Challenges and Utility System Capabilities
Staff acknowledged in the draft Action Plan that many of the proposed actions require
utilities to adjust practices and systems to allow for identification of eligible customers
for enhanced protections and that this has previously been an area of expressed
concern.'$
Stakeholder Comments
Utilities raised concerns around the administrative challenges and system adjustments
that would be required to implement a number of the Action plan proposals by
January 1, 2025. In written comments utilities offered that they could include expanded
protections for known income-qualified households and medical certificate holders by
the January 1 timeline, but that for expanded households they would need a few
additional months for systems to be ready. Additionally, certain proposals would require
manual intervention. For example, reconnecting customers upon request in conjunction
with enhanced weather protections cannot be automated. In PGE comments, the utility
18 OPUC Staff, October 25, 2024. UM 2211, Staffs proposed Phase 2 Arrearage and Disconnection
Action Plan, https://edocs.puc.state.or.us/efdocs/HAH/um2211hah332395120.pdf.
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Docket No. UM 2211 ORDER NO. 24-426
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requested clarity on temporary actions and a desire for continuity for customers and
raised that expanding income thresholds would require collecting and standardizing new
income data, which would be difficult on an expedited basis. In written comments,
Cascade noted that with the number of protections they would need to hire an additional
staff member to manage implementation.
Staff's Response
Staff appreciates the valuable clarity that many of the utilities provided during the
workshops around how certain proposals could be administered, as well as
others where the ability to implement was unknown and potentially problematic.
Staff remains sensitive to administrative feasibility and the benefits of long-term
continuity for customers. In response, Staff made the following modifications to
its interim proposal: simplifying and narrowing the definition of qualified
households; eliminating broad residential customer fee relief; incorporating
relevant exemptions for fuel- and utility-specific considerations; removing direct
contact recommendations, and narrowing arrearage relief. For proposals that
remained intact or modified, Staff believes that it has either received sufficient
utility and broad stakeholder support, and/or the potential harm absent these
expansions outweighs the administrative burden of implementation.
That said, the inclusion of a "sunset date"and framing of certain elements as
one-time is meant to (1) balance Staff's belief in the need for near term action
with the reality that the traditional rulemaking process may not conclude prior to
the end of the 2024-2025 winter heating season or even potentially the 2025
cooling season; and (2) be responsive to the call from stakeholders for
assurances that Staff will provide the desired level of space, time, and
engagement before recommending permanent actions. It remains Staff's
intention to initiate and conclude additional process on this topic prior to the
September 1, 2025, sunset and as a byproduct, potentially resolve some
continuity concerns.
Balancing Utilities'Ability to Collect and Cost Shifting with Mitigating Harm
Staff's proposal prioritizes keeping people connected over assessing punitive fees.19
This has a direct impact on customer safety, but raised questions about cost shifting
and utility revenue.
Stakeholder Comments
Utilities highlighted concern around the balance of being able to continue collecting from
customers and incenting customers to pay their bills with the proposed protections. This
included wanting to prioritize actions that will have the biggest impact while having
hesitancy around what costs will look like for all customers. In the same workshop, EJ
19 OPUC Staff, October 25, 2024. UM 2211, Staff's proposed Phase 2 Arrearage and Disconnection
Action Plan, https://edocs.puc.state.or.us/efdocs/HAH/um2211hah332395120.pdf.
APPENDIX A
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Docket No. UM 2211 ORDER NO. 24-426
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Page 17
advocates flagged the weaponization of poverty in some of these conversations and
that keeping people alive is not always going to align with continuing to make revenue.
Natural gas utilities pointed out a seasonal usage concern where they see natural gas
customers choose to allow the utility to disconnect their service at the end of the winter
season, leaving past due balances on their accounts, and the utility without payment
until the customer seeks reconnection the following winter. This issue was raised in
response to the date-based moratorium proposal and highlighted that if gas customers
lacked any incentive to pay their gas bills during the protected months and subsequently
allowed disconnection to occur in April, unintended costs and consequences would
arise. Not only would the gas utility have very limited capacity to collect payment for the
services provided, but the customer would face significant charges to reconnect the
next winter.
Staff's Response
Staff has not observed nor seen reported large cost increases after implementing
the much more comprehensive expanded protections from AR 653. Further,
several states across the country offer date-based disconnection moratoriums for
utility customers. Staff is cognizant that overly broad moratoriums without
proactive utility efforts to help customers stay out of arrears can present risks to
the utility and customers, but a broad moratorium is not being proposed here.
Staff refined its draft to reduce administrative burden and remove some items
where additional costs were more likely to be not insignificant, such as limiting
the more comprehensive definition of qualified households to only 80 percent
SMI and medical certificate households and allowing for winter protection
program exemptions like in existing rules. Staff also remains interested in
understanding the significance of cost implications from expanding disconnection
protections in the limited manner it has been proposed.
Staff is also sensitive to the concern raised by natural gas utilities and can
confirm that seasonal usage and summer disconnections are a reality for these
companies. In Staff's arrearage and disconnection assessment, Staff observed
the ratio of reconnections to disconnections decline in the summer months for all
three gas utilities compared to the consistency of the measure for electric utilities.
Staff endeavored to explore ways to address the seasonal usage issue and
considered the possibility of an exemption for natural gas utilities, particularly
where other safeguards and services such as robust arrearage
forgiveness/management was available to customers. If the Commission were
sympathetic to this approach, then the winter date-based moratorium would only
apply to PacifiCorp and PGE. That said, Staff has not made that option its
primary recommendation to the extent that some gas customers could remain
exposed to unsafe shutoffs at a time when natural gas is most essential.
Staff recommends that the Commission authorize utilities to track the additional
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Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 18
costs from the interim measures in a manner that can be shared with Staff and
stakeholders on July 1, 2025, and after the final sunset date in the event of an
extension and/or adopted permanent rules. Staff further recommends that
incremental costs accrued for enhancing existing practices, such as waived
reconnection fees, reconnecting in advance of severe weather, be recorded for
recovery in the appropriate expense category consistent with existing utility
accounts (i.e., in the same manner additional costs from expanded protections in
AR 653 were managed). Finally, specific to arrearage support and any changes
to existing income-qualified bill discount programs adopted in this proceeding,
Staff recommends the Commission authorize recovery in the existing automatic
adjustment clause for these programs.
Expanding Protections to Additional Customer Groups
Currently, most protections and energy assistance programs available for Oregon IOU
customers are based on income-eligibility. Not only do these models pose access and
enrollment issues, but eligibility methodologies such as "gross income" tend to overlook
household characteristics that are strongly correlated with energy insecurity. Further,
the governing law driving this implementation effort explicitly includes "other economic,
social equity, or environmental justice factors that affect affordability for certain classes
of utility customers, and any other reasonable consideration"20 in the context of
developing rates, discounts, and programs to mitigate energy burden and affordability
challenges. It does not limit programs by income guidelines.
The current administrative rules provide enhanced protections for qualifying
households, defined as households at 60 percent SMI or below. Staff's original proposal
sought to introduce additional customer characteristics to the definition of qualifying
households, such receiving local, state, or federal public assistance.
Stakeholder Comments
Utilities raised concerns during Staff's two workshops around the broadness of
expanding to include "Qualified Households" flagging that without data it would be
difficult to know how many customers this expansion would include, how to verify these
customers, or whether customers that fall under the definition would actually struggle
with energy insecurity. Additionally, utilities had concerns about how quickly they could
build the systems to navigate expanding protections and offered that they currently have
flexibility for customers who call in seeking assistance, but that customers are not
reaching out.
EJ advocates offered looking at other state or federal programs where there could be
categorical eligibility to help with quicker implementation or adding a higher SMI
percentage alongside the definition to help ease utilities concerns. Additionally, EJ
advocates have discussed with Staff and included in comments that outreach and
20 ORS 757.230.
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Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 19
engagement around customer protections need to increase and should include clear
and accessible information so customer understand how to connect with available
protections, how long the protections will last, and other program information. In Idaho
Power's written comments, they raised concern with the definition when looking
specifically at their service territory, which the recent Low-Income Needs Assessment
indicated that nearly 80 percent of households in the Company's Oregon service
territory fall below 80 percent SMI which leads to uncertainty around the number of
customers that would meet a criterion that included a more expansive income cap.
Staff Response
Staff is sympathetic to the implementation challenges expanding qualifying
characteristics beyond discretely measurable values, such as income may pose
for utility systems. Staff also recognizes that introducing such a significant
evolution into an accelerated process with limited engagement and refinement
opportunities is less than ideal. Therefore, Staff revised its proposal for the
definition of qualifying households. Staff's revised proposal enhances the
definition of qualifying households to include customers at 80 percent SMI and
customers with medical certificate. Staff believes this information that is readily
available to the utilities and provides a reasonable bridge between what can be
achieved now, and what we hope to pursue in the future.
That said, Staff is committed to working with stakeholders to incorporate more
inclusive language in the rules on a permanent basis. EJ Advocates identified
other states with broader definitions and several Oregon IOU EBAs emphasized
the need to address "the assistance gap"and "ALICE"households (otherwise
known as Asset Limited, Income Constrained, Employed) where protections and
assistance is not available, but need and insecurity persist. In order to balance
the multitude of factors at this stage of implementation, including but not limited
to valid implementation concerns, real evidence of household need beyond the
60 percent SMI threshold, near-term relief objectives, and the value that would
come from additional collaboration on this issue, Staff has modified the proposal
to remain tied to income, but extend to 80 percent SMI and include medical
certificate accounts.
Arrearage and Disconnection Workstream Conclusion
Staff believes that accelerated, flexibility, shared goals, and collaborative stakeholder
engagement have allowed this process to be successful in terms of the final Action Plan
proposal before the Commission. Staff further believes that the proposed actions
provide implementable, strategic, and meaningful enhancements to arrearage and
disconnection protections that will ultimately reduce both risk and harm for residential
customers in the coming months. Should the Commission decline to adopt these near-
term recommendations but express interest in pursuing them in a more formalized
process, Staff would proceed with its plans to initiate an informal rulemaking process
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Docket No. UM 2211 ORDER NO. 24-426
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Page 20
where UM 2211 stakeholders can investigate the practicality and impacts of
implementing these and other previously proposed protections and program
enhancements for adoption some time in 2025.
That said, Staff would clarify that postponing the adoption of these interim protections
would eliminate the opportunity for customers to access the protections and related
positive impacts of this proposal prior to that time, prolonging risk exposure to the harms
of disconnection, particularly in the increasing cold of the 2024-2025 winter heating
season. To this end, we find that the Commission should adopt the proposed Action
Plan discussed in this section of the memo.
Energy Efficiency and Weatherization Workstream
Staff's goals in this workstream were to develop an overview of existing programs in the
space of low-income energy efficiency and weatherization, identify gaps and
opportunities, and outline a near-term action plan. Staff gathered information through
individual meetings with various stakeholders, as well as at a public workshop and
public comment period. Based on that, Staff developed eleven short term actions to
improve weatherization and energy efficiency services for low-income households as
discussed in Attachment 2. Staff believes it is too early to establish a new funding
mechanism under HB 2475 authority and create a new delivery network, as some
advocates request. Further coordination between state agencies, and potentially
legislators, is necessary to determine the best way forward regarding new funding
mechanisms. Staff will continue to evaluate throughout 2025 and update this
recommendation in 2026.
One of Staff's action items requires Commission action. Energy Trust should use utility
data to target low-income households with its low- and no-cost offers.21 Staff
memorialized this guidance in its recommendations on Energy Trust's budget in 2022,22
21 See In re OPUC Implementation of HB 2475, OPUC Docket No. UM 2211, Staff Presentation for
Workshop to be held on 10/10/24 at 11 am, filed by Benedikt Springer, Oct 3, 2024, available at:
https://edocs.puc.state.or.us/efdocs/HAH/um2211 hah331836120.pdf(accessed Nov 13, 2024) (stating
that to improve accessibility, the Energy Trust of Oregon should target low-income and high energy
efficiency potential users with utility data).
22 OPUC Staff Report, Energy Trust of Oregon:Presentation of 2023 Draft Budget and 2023-24 Action
Plan, Oct 25, 2022, available at:
https://oregonpuc.granicus.com/MetaViewer.php?view_id=2&clip_id=1040&meta_id=34576 (accessed
Nov 13, 2024).
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Docket No. UM 2211 ORDER NO. 24-426
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Page 21
2023,23 and 2024.24 The Commission adopted Staff's recommendations. However,
Staff believes that further Commission direction is required to ensure that all applicable
utilities are providing the data required for this.
Energy Trust has individual data-sharing agreements with PGE, PAC, Avista, Cascade
Natural Gas, and NWN that implement OAR Chapter 860 Division 086. In accordance
with the rules, utilities regularly share information such as customer names and
addresses, as well as usage and schedules. Energy Trust uses this information to
design measures, estimate feasible savings, and develop its marketing strategy.
PGE, PAC, Avista, Cascade, and NWN operate bill discount programs for customers at
or below 60 percent of state median income to alleviate energy burden. Staff finds that
participation in these schedules can serve as a good indicator of household income.
Hence, Staff believes that this data would be useful for Energy Trust to reference in
designing and marketing its offers for low-income households. Furthermore, Staff
believes that participation in bill discount programs is a rate schedule identifier that
needs to be shared with Energy Trust in accordance with the above cited rules.
Staff Outreach
PAC and Avista started sharing a variable, indicating a customer's participation in a bill
discount schedule shortly after initiating the program with Energy Trust as part of their
regular data delivery. After Energy Trust informed Staff that it had been unsuccessful in
convincing PGE, Cascade, and NWN to include their bill discount schedule in regular
data-sharing, Staff reached out to said utilities in June, informing them that sharing was
both useful and legally supported. After meeting with Staff, Cascade agreed to start
21 OPUC Staff Report, Energy Trust of Oregon:Presentation of 2024 Draft Budget and 2024-2025 Action
Plan, Oct 25, 2023, available at:
https://oregonpuc.granicus.com/MetaViewer.php?view_id=2&clip_id=1239&meta_id=37540 (accessed
Nov 13, 2024).
21 OPUC Staff Report, Energy Trust of Oregon:Presentation of 2025 Draft Budget and Action Plan, Oct
28, 2024, available at:
https://oregonpuc.granicus.com/MetaViewer.php?view_id=2&clip_id=1409&meta_id=40384 (accessed
Nov 13, 2024).
21 See OPUC Minutes of a Special Public Meeting, Energy Trust of Oregon :Presentation of 2023 Draft
Budget and 2023-24 Action Plan, Nov 3, 2022, available at:
https://oregonpuc.granicus.com/DocumentViewer.php?file=oregonpuc_1 fbOc37af826c68a8984622d 18a3f
8b6.pdf&view=1 (accessed Nov 13, 2024) (stating: "Motion was made by Chair Decker to adopt Staff
Recommendation..." and indicating that all Commissioners present voted for the Motion)., OPUC
Minutes of Public Meeting, Energy Trust of Oregon :Energy Trust 2024 Budget and 2024-2025 Action
Plan Presentation, Nov 2, 2023, available at:
https://oregonpuc.granicus.com/DocumentViewer.php?file=oregonpuc_61135756541 f8f365735cd229c3b
4a22.pdf&view=1 (accessed Nov 13, 2024) (stating: "Motion was made by Commissioner Tawney to
adopt Staff's Recommendation..." and indicating that all Commissioners present voted for the Motion).,
and OPUC Minutes of Public Meeting, Energy Trust of Oregon :Presentation of 2025 Draft Budget and
Action Plan, Nov 5, 2024, available at:
https://oregonpuc.granicus.com/DocumentViewer.php?file=oregonpuc_f608659f2293dc371 fc43ade551 dO
522.pdf&view=1 (accessed Nov 13, 2024) (stating: "Motion was made by Chair Decker to adopt Staff
Recommendation..." and indicating that all Commissioners present voted for the Motion).
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Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 22
sharing the information. Staff also met multiple times with representatives from PGE
and NWN, but no agreement was reached.
Utility Objections and Staff Responses
PGE and NWN brought forward two objections: (1) sharing bill discount schedule
identifiers with Energy Trust would likely violate the Oregon Consumer Privacy Act
(OCPA); and (2) concern that Energy Trust might use the data in ways that could harm
customers, for example by designing subpar programs.
The utilities first concern is unsubstantiated as nothing in the OCPA precludes utilities
from complying with state rules. Specifically, ORS 646A.572(3)(a) states that the OCPA
does not prohibit a "controller" or "processor" of data under the bill from complying with
federal, state, or local statutes or rules. In response to the utilities' second concern,
Staff agrees that Energy Trust should develop programs that benefit customers and not
use the data in harmful ways. However, Staff believes Energy Trust's stakeholder
engagement in program design, coupled with Commission oversight, significantly
reduces the likelihood of adverse outcomes. In the absence of evidence or historical
precedent supporting the utilities' concerns, Staff finds it inappropriate to withhold data
at this time.
Support for Staff Recommendation
Rules in OAR 860-086 govern which data electric and gas utilities must transfer to
Energy Trust. Specifically, OAR 860-036-0030(2)(i) states that electric companies must
transfer rate schedule identifier information for each customer account to Energy Trust.
Similarly, OAR 860-086-0040 (1)(a)(H) provides that gas utilities that offer energy
conservation programs through ETO must provide rate schedule identifier information
for each customer account with Energy Trust, provided the information is available in
the gas utility's records.
PGE's bill discount program can be found in Schedule 18 of its tariff, while NWN's bill
discount program is outlined in Schedule 330 of its tariff. Both represent rate schedule
identifiers. As such, and to achieve uniformity across all utility data sharing practices,
Staff recommends that the Commission direct Avista, Cascade, NWN, PAC, and
PGE to include rate schedule identifiers—indicating which of their customers
participate in their respective bill discount programs—as part of their monthly
data sharing with Energy Trust, in order to comply with the above cited rules.
Utilities should comply with this as soon as feasible, but not later than
January 2025 to allow Energy Trust to begin program implementation.
While Staff is only requesting this narrow Commission action, in Attachment 2, Staff
provides background information regarding Staff's research, findings, and proposed
actions over the foreseeable future to improve energy efficiency and weatherization
activities in the state.
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Docket No. UM 2211 ORDER NO. 24-426
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Page 23
PacifiCorp's Low-Income Discount Re-Enrollment
In their November 13, 2024, letter, the Joint Advocates flag that a lack of information
and engagement around PacifiCorp's re-enrollment plans, paired with the Company's
Energy Burden Assessment (EBA) asking for more effective outreach and the upcoming
winter heating season and possible rate increase, leaves customers at a disadvantage
and qualified customers may ultimately be unenrolled for non-response.26 The Joint
Advocates ask in their comments that the Commission suspend the section of the
Company's tariff requiring re-enrollment until October 2025 and that the Company not
be allowed to re-start until it collaborates on a re-enrollment outreach strategy, commits
to sharing data and process outcomes with stakeholders, and determines a timeline to
check-in with stakeholders throughout the re-enrollment process to discuss learnings.27
Re-enrollment is a period in the programs where customers must re-attest to their
income information and connect with the Company to continue receiving discounts.
Customers do not have to provide income verification and can self-attest income and
household size. Staff is sensitive to the barriers and challenges associated with
traditional enrollment processes and has heard within UM 2211 conversations that
intentionally crafted outreach and appropriate timelines can help with customer
confusion around processes. Staff flags that parties raised concerns related to the
Company's re-enrollment within UE 433, PacifiCorp's general rate case filing.
On November 18, 2024, the Company filed a response to the Joint advocates in
Docket No. UM 2211, indicating that it will postpone any disenrollments until March 1,
2025.28
Staff Response and Procedural Options
Staff supports the EJ Advocates' proposal for a limited pause on reenrollment
processes through March 1, 2025, in conjunction with a commitment to engaged
UM 2211 stakeholders on reenrollment that broadly aligns with the goals of reducing
exposure to unsafe disconnections this winter. Staff does not believe that the
Commission needs to take action now, because the Company has agreed to a pause
reenrollment through March 1, 2025. If an adequate revised process has not been
identified by March 1, 2025, Staff can return a Public Meeting with a recommendation
for the Commission to direct PacifiCorp to file a new version of their tariff with the
reenrollment process removed and continue to work toward a sufficient replacement
process.
26 NW Energy Coalition and the Coalition of Communities of Color, UM 2211 —Request to Temporarily
Suspend PAC's Low-Income Discount Re-Enrollment Process, filed November 13, 2024,
https://edocs.puc.state.or.us/efdocs/HAH/um2211 hah332933120.pdf.
27 Id.
28 PacifiCorp, UM 2211—PacifiCorp's Reply Comments to Northwest Energy Coalition and the Coalition
of Communities of Color, filed November 18, 2024,
https://edocs.puc.state.or.us/efdocs/HAC/um2211 hac333083033.pdf.
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Docket No. UM 2211 ORDER NO. 24-426
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While there is temporary resolution regarding this issue in this docket, Staff would also
like to note that this issue is also presented in the Company's general rate case (UE
433).
PROPOSED COMMISSION MOTION:
Approve Oregon Public Utility Commission Staff's recommendations regarding:
• Interim customer protections against the risks of arrearages and
disconnection as outlined in Attachment 1; and
• Utility data sharing requirements by directing Portland General Electric,
Northwest Natural Gas Company, Pacific Power, Avista Utilities, and Cascade
Natural Gas to include respective bill discount program schedule identifiers with
Energy Trust of Oregon beginning no later than January 2025.
APPENDIX A
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Docket No. UM 2211 ORDER NO. 24-426
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Page 25
Attachment 1. List of Staff's Proposed Actions for Near-term Interim Customer Protections
Against Disconnection
1. Staff recommends expanded eligibility requirements for disconnection protections
for the period of January 1, 2025 through September 1, 2025.
a. Therefore, Staff recommends that the Commission direct PAC, PGE, AVA,
CNG, and NWN to extend protections available to "Qualified household"
determined by their status as:
i. Low-Income Residential Customers.29
ii. Customers who verify or self-attest to a household
income, adjusted for household size, between 61-80
percent state median income (SMI).
iii. Medical certificate accounts.30
b. Therefore, Staff recommends that the Commission direct IPC to
expand Winter Protection Program31 (WPP) to include their Bill
Discount for Qualified Customers Program32 participants.
2. Staff recommends enhanced Cold Weather disconnection protections for the period
of January 1, 2025 through September 1, 2025.
a. Therefore, Staff recommends that the Commission direct PAC, PGE, AVA,
CNG, and NWN to add Date-Based Protections to prohibit disconnection for
qualified households between December 1 and April 1.
i. Staff recommends an OAR 860-021-0407(10) exemption for IPC.
b. Therefore, Staff recommends that the Commission direct PAC, PGE, AVA,
CNG, and NWN to expand the Temperature-Based moratorium prohibiting
disconnection per OAR 860-021-0407(1)33 to include the 24-hours before
severe weather.
i. Staff recommends an OAR 860-021-0407(10) exemption for IPC.
29"`Low-income residential customer' whose eligibility has been verified under OAR 860-021-0180".
31 Oregon Administrative Rule (OAR) 860-021-0410 provides an explanation of medical certificate provisions.
31 https://docs.idahopower.com/pdfs/aboutus/ratesregulatory/tariffs/63.pdf.
32 https://docs.idahopower.com/pdfs/aboutus/ratesregulatoEy/tariffs/bill-discount-qualified-customers-program.pdf.
33 Existing rule states that, "an energy utility must put into effect a moratorium on the disconnection of residential
service for nonpayment from November through March on any day a temperature of less than 32 degrees
Fahrenheit is forecasted by the applicable weather reporting service or a winter storm warning indicating weather
conditions pose a threat to life or property is issued by the applicable weather reporting service."
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Docket No. UM 2211 ORDER NO. 24-426
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3. Staff recommends enhanced Hot Weather disconnection protections for the period
of January 1, 2025 through September 1, 2025.
a. Therefore, Staff recommends that the Commission direct PAC and PGE to expand
the Temperature-Based moratorium prohibiting disconnections in OAR 860-021-
0407(2) to include the 24-hours before and 48-hours following a local heat advisory
issued by the applicable weather reporting service for residential customers served
in counties where the Oregon Department of Energy Cooling Study reports an
Exposure Index greater than 65.34,35
i. Staff recommends an OAR 860-021-0407(10) exemption for IPC.
ii. Staff recommends an exemption for AVA, CNG, and NWN.
4. Staff recommends protections for reconnection fees for the period of January 1,
2025 through September 1, 2025.
a. Therefore, Staff recommends that the Commission direct PAC and PGE to
expand OAR 860-021-0407(9)36 to provide qualified households that have
been disconnected for nonpayment within the previous 7-days of a severe
weather or air quality condition reconnection upon customer request.
i. Therefore, Staff recommends the Commission direct IPC to
provide customers eligible under for WPP (inclusive of bill
discount participants) that have been disconnected for
nonpayment within the previous 7-days of a severe weather
or air quality condition reconnection upon customer request.
ii. Therefore, Staff recommends that the Commission direct
AVA, CNG, and NWN to expand OAR 860-021-0407(9)37 to
provide qualified households that have been disconnected
for nonpayment within the previous 7-days of a cold weather
severe weather or air quality condition reconnection upon
customer request.
34 The Exposure Index evaluates historic temperatures and expected increases resulting in heat exposure. It also
considers tree canopy and impervious surfaces to identify areas prone to the urban heat island effect.
35 Currently, only Multnomah County has an exposure index of>65.
https://experience.arcgis.com/experience/5f6aOel 785524df8853e94776693dOf7/page/HVI-County/.
36 Existing rule states that, "upon request from a customer who has been disconnected for nonpayment within the
previous 72 hours of a severe weather or air quality condition outlined in sections (1), (2), and (3)of this rule, an
energy utility must make best efforts to reconnect service."
37 Existing rule states that, "upon request from a customer who has been disconnected for nonpayment within the
previous 72 hours of a severe weather or air quality condition outlined in sections (1), (2), and (3)of this rule, an
energy utility must make best efforts to reconnect service."
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Docket No. UM 2211 ORDER NO. 24-426
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b. Therefore, Staff recommends that the Commission direct IPC, PAC, PGE,
AVA, CNG, and NWN to revise utility tariffs to eliminate all reconnection
charges for residential accounts following disconnection for non-payment
provided the residential customer was enrolled in the utility's income-qualified
bill discount program prior to the disconnection, with a reported38 household
income of 0-15 percent SMI.
5. Staff recommends that utilities have an arrearage management offering available by
January 1, 2025.
a. Therefore, Staff recommends that the Commission direct PAC, PGE, and
NWN to Offer a one-time Arrearage Forgiveness grant to households earning
at or below 0-5 percent SMI, up to $1,000 effective January 1, 2025.39
i. Staff recommends an exemption for IPC.
b. Therefore, Staff recommends that the Commission direct PAC, PGE, and
NWN to, upon customer request, provide payment forbearance options of at
least one month, available between December 1 —April 1 and July 1 —
September 1 on Time Payment Arrangements (TPAs) for qualified
households enrolled in the utility's income-qualified bill discount program.40,4'
i. Staff recommends an exemption for IPC.
6. Staff recommends that utilities have sufficient HB 2475 Discounted Rate Program
tiers by January 1, 2025.
a. Therefore, Staff recommends that the Commission direct PAC and PGE to
implement qualified program monthly discounts applicable to customers
earning 0-5 percent SMI are no less than 80 percent; and for customers
earning 6-10 percent SMI, no less than 60 percent or otherwise aligned within
five percentage points of the level of energy assistance need determined by
the utility's most recently published energy burden assessment effective
January 1, 2025.42
i. Staff recommends an exemption for IPC.
38 Customer may"report"their qualifying income level via self-attestation either at the original bill discount enrollment or
when requesting reconnection under this provision.
39 AVA and CNG are already in compliance. NWN has committed to implement an AMP effective in March, but not January.
40 Application of this provision would not count as a renegotiation of the TPA to the extent that the number of
renegotiations are limited by the utility.
41 AVA and CNG are already in compliance. NWN has committed to implement an AMP effective in March, but not January.
42 AVA,CNG,and NWN are already in compliance.
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7. Staff recommends that utilities provide sufficient noticing and outreach related to
their disconnection and arrearage protections.
a. Therefore, Staff recommends that the Commission direct IPC, PAC, PGE,
AVA, CNG, and NWN to notify43 customers of the availability and terms of
applicable enhanced protections and/or programs any time a customer:
i. Enrolls in a qualified bill discount program.
ii. Contacts the utility regarding payment assistance.
iii. Receives a disconnection notice for nonpayment.
iv. Within 24 hours of being disconnected for nonpayment.
V. Requests reconnection following disconnection for
nonpayment.
b. Therefore, Staff recommends that the Commission direct IPC, PAC, PGE,
AVA, CNG, and NWN to notify partnering Community Action Agencies of its
available protections for qualifying customers and provide digital and/or paper
reference material(s).
c. Therefore, Staff recommends that the Commission direct IPC, PAC, PGE,
AVA, CNG, and NWN to include accessible44 information regarding the
availability of disconnection protections and their terms on its website.
d. Therefore, Staff recommends that the Commission direct IPC, PAC, PGE,
AVA, CNG, and NWN to train customer service representatives (CSRs) to
offer and discuss any applicable protections and programs adopted in this
process.
e. Therefore, Staff recommends that the Commission allow for exemptions to
parts 7(a) and (b) to the extent the utility proposes a comparable or improved
noticing and outreach plan to Staff.
as Notification should occur through the customer's most recently documented preferred communication method
and on printed materials issued in the disconnection process.
as Accessible may be defined in the manner that the utility determines other information is adapted for different
audiences, including but not limited to translation services, readability, and plain language.
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Attachment 2: Background on Energy Efficiency and Weatherization Workstream
Staff Review and Engagement
Staff's goals in this workstream were to develop an overview of existing programs in the
space of low-income energy efficiency and weatherization, identify gaps and
opportunities, and outline a near-term action plan. Staff discusses these aspects in the
following sections. First, Staff gathered information through individual meetings with
various stakeholders, including Energy Trust of Oregon, Energy Justice Advocates,45
Oregon Housing and Community Services (OHCS), and the Community Action
Partnership of Oregon (CAPO), as well as at a public workshop on October 10, 2024.
Energy Justice Advocates, Energy Trust, PGE, and NWN filed public comments
following the workshop.
As context, most of the funds for low-income weatherization and energy efficiency are
delivered through OHCS, which contracts with Community Action Agencies (CAA), with
the federal Weatherization Assistance Program (WAP) providing the anchor for most
activities. The state of Oregon sets some of the federal Low Income Home Energy
Assistance Program (LIHEAP) funds aside to enable activities that do not meet cost-
benefit requirements under WAP rules. Unlike most other programs, these funds are
available to customers independently of the heating fuel they use. OHCS also
distributes part of a legislatively-mandated public purpose charge to CAAs for low-
income weatherization and energy efficiency under the name Energy Conservation
Helping Oregonians (ECHO), only available to PGE and PAC customers using electric
heat. Another part of the public purpose charge serves multi-family properties, for which
OHCS contracts with TRC under the name Oregon Multifamily Energy Program (OR-
MEP). None of the activities listed above fall under the authority of the PUC.
Avista, Cascade, Idaho Power, and NWN have voluntary tariffs that collect funds for
low-income weatherization and energy-efficiency.46 Customers must use the individual
utilities' fuel as a primary heat source to be eligible. These funds are by large directly
allocated to CAAs, with the exception of NWN which funds other one-off projects on a
discretionary basis. OHCS promulgates some general rules for how CAAs must
administer many of these programs. As a result, all CAA's require documentation of
income and operate programs on a first-come, first-served basis; Comprehensive
weatherization measures are generally selected based on an energy audit that
determines interventions with a savings to investment ratio larger than one. At the same
time, specific implementation varies by organization. This means, for example, that a
customer in search of no-cost services would have to first ascertain which CAA serves
as NW Energy Coalition, Community Energy Project, Verde, Oregon Citizens' Utility Board, Coalition of
Communities of Color.
as Avista Oregon Low Income Energy Efficiency (AOLIEE), Cascade Oregon Low-Income Energy
Conservation (OLIEC), NWN Oregon Low Income Energy Efficiency Program (OLIEE) and Open
Solicitation Program (OSP), and Idaho Power Weatherization Assistance for Qualified Households
(WAQC).
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their county and then learn about the application process at that specific organization.
Table 1 below show spending and households served by the programs discussed
based on the latest publicly available data.
Table 1: Pro rams Administered through OHCS and/or CAAs
Name Source Expenditures Households Notes
served
WAP US DOE $3.7 million 499 Program Year 202247
LIHEAP US HHS $5.6 million Braided Program Year 202248
WX
PGE/PAC Program Years 2021
ECHO Public Purpose $28.5 million 972 to 2023. Revenue,
Charge via expenditures not
OHCS reported 49
AOLIEE Avista Tariff $0.5 million 37 202350
OLIEC Cascade $43,688 5 Program year
2022/202351
OLIEE/OSP NWN $5.6 million 825 Program Year
2022/202352
WAQC IPC Tariff $28,882 5 202353
PGE/PAC Program Years 2021
OR-MEP Public Purpose $4.5 million 2,987 to 2023. Revenue,
Charge via expenditures not
OHCS reported 54
Many community-based organizations (CBO), which are not CAAs, are active in the
low-income weatherization and energy efficiency space. CBOs often braid various
funding sources to offer services that vary in scope from DIY weatherization workshops
to comprehensive energy efficiency retrofits. In the last years, Energy Trust has made
substantive investments to better serve low-income communities. These investments
and activities are required to meet equity metrics under ORS 757.747, translated by the
Commission into performance measures in Order 22-478 and revised in Order No. 24-
079.55 These investments are by large delivered through community partners. Energy
Trust now works with thirty CBOs throughout the state, supporting them with various
47 WAP has an additional allocation of$30.6 million for 2023 to 2027 available. It is unclear how much of
that has already been spent. NASCSP, Annual Funding Tables, April 26, 2024.
48 NASCSP, Annual Funding Tables, April 26, 2024.
49 Evergreen Economics, PPC Legislative Report, 2024.
50 Docket No. RG 81, AOLIEE Annual Report, April 9, 2024.
51 Docket No. RG 7, OLIEC Annual Report, November 30, 2023.
52 Docket No. RG 13, OLIEE Annual Report, December 28, 2023.
53 Docket No. UM 1710, DSM Report, April 5, 2024.
54 Evergreen Economics, PPC Legislative Report, 2024.
55 Docket No. UM 1158, Order No. 22-478,December 14, 2022. Docket No. UM 1158, Order No. 24-079,
March 21, 2024.
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funding streams that enable the organizations to offer no- or low-cost services to clients.
As a result, there is an emerging network of low-income weatherization and energy
efficiency providers in Oregon that operates in parallel to CAA programs.
The work of these CBOs is supported by many other grants, like the EPA Community
Change Grant, the Oregon Healthy Homes Program, the Oregon DOE's Heat Pump
Programs, as well as local initiatives like the Portland Clean Energy Fund (PCEF).
While the breadth of services offered varies enormously between CBOs, together they
are subject to fewer rules and generally do not require extensive documentation to
qualify. While CAAs need to comply with a host of work specifications and quality
control standards, CBOs have often more leeway in how to handle these issues. In
2024, Energy Trust started the "In-House Services" program, which serves clients with
no-cost offers in areas with limited CBO capacity.
Energy Trust funding and capacity-building activities are one of the prime ways the PUC
can influence developments in this sector. Table 2 summarizes Energy Trust's activities.
In addition to CBOs, Energy Trust also works with large developers and multi-family
property owners, which may serve many renters in naturally-occurring affordable
housing. Energy Trust also has been awarded or serves as a sub-awardee for several
federal grants with total lifetime contract revenue of over $100 million, much of which is
expected beginning in the first quarter of 2026 and extend through 2029.56 These funds
will serve to expand no- and low-cost offers to low-income households.
Table 2: Ener Trust offers Serving Low-income Households57
Expenditures Households
Offer Eligibility Description (2023) Served
2023
Community Includes various no-
Partner cost offers, plus
Funding/ In- At or below enhanced incentives, $3.6 million 869
Home 60% of SMI plus access to regular
Services incentives, plus some
administrative costs
Savings Within At or below Enhanced incentives
Reach 120% of SMI for insulation and heat $2.8 million 2103
pumps
No Enhanced incentives
restrictions,
Regional likely served for insulation, gas $0.2 million 66
Promotions some low- furnaces, and heat
income pumps
66 Energy Trust of Oregon, 2025 Draft Budget and Action Plan, October 2, 2024.
51 Energy Trust of Oregon, 2023 Annual Report, April 15, 2024.
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Expenditures Households
Offer Eligibility Description (2023) Served
2023
households in
rural areas
May have
served some Various prescriptive
Rental Offers low-income measures through $4.1 million 2225
households in owners/managers
affordable
housing
No
restrictions, Enhanced incentives
Manufactured but likelyserved low- to for weatherization, $4.1 million 1172
Homes medium heat pumps, and
income
replacement
households
After review of existing programs and considering stakeholder feedback, Staff
concludes that there are the following gaps which should be addressed:
(1) Oregon's fragmented landscape of local providers braids multiple
funding streams to make offers to clients that vary in both depths
and quality. Neither delivery organizations, nor major funders
coordinate sufficiently. There are no uniform standards for safety
and quality.
(2) There is no central point for customers to learn about services
and access them. The system is hard for consumers to
understand.
(3) Services are largely distributed on a first-come, first-served basis
and are not specifically targeted to customers with high energy
burden and high energy efficiency potential.
(4) Costs are higher and delivery capacity is lower in rural areas,
leading to long wait lists and services being offered at lower
rates.
(5) Renters receive services at lower rates. While programs do not
generally discriminate against renters, it is more difficult for a
household in a single-family rental or multi-family property to
access services.
(6) Energy efficiency interventions are frequently deferred to due
maintenance issues that would require significant investments.
(7) Authority over funds being spent in Oregon is divided between
OHCS, ODOE, and PUC, not counting programs by counties and
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municipalities. The Climate Protection Plan, if reestablished, may
add DEQ as another major funder of low-income energy
efficiency. Among state agencies, there is no shared vision and
coordinating strategy for low-income weatherization and energy
efficiency.
Proposed Staff Action Plan
To address the gaps identified above, Staff believes that the following improvements
should be made within the next 12 months:
(1) Energy Trust should continually increase the number of low-
income customers that receive program offers. Energy Trust
should collaborate with community-based organizations and
acquire additional grants to offer these services at no cost— in no
case should low-income customers be advised to participate in
market rate programs. Ratepayer funds should be used under
the cost-effectiveness exception criterion of energy burden
mitigation in order to create and maintain delivery infrastructure
and no-cost offers as long as the Energy Trust portfolio remains
cost-effective.58
(2) Energy Trust should set work specifications and quality control
standards for its Community Partners.
(3) Energy Trust's activities should be complementary to
WAP/ECHO, including:
• Serving customers through culturally specific
organizations.
• Serving customers that are deterred by application
requirements like income documentation or ID/SSN
requirements.
• Serving customers in rural areas with limited delivery
capacity
• Creating offers that target rental housing.
• Ensuring community partners have input into program
design.
• Finding complementary funds to enable health and safety
and other home repairs that may thwart weatherization.
(4) Energy Trust should develop financing options for low/medium
income households.
(5) Energy Trust should use utility data to better reach high energy
burden/ high energy efficiency potential customers with targeted
low-income program offerings.
58 See Agreement to Direct Funding to Nongovernment Entity, Entered Between Energy Trust of Oregon,
Inc. and Public Utility Commission of Oregon, August 19, 2024, Exhibit A, 3. i. (H).
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• In the short term, Energy Trust should use targeted
marketing to reach bill discount participants with no-cost
offers. Staff recommends the Commission order all utilities
to provide this data in compliance with OAR 860-086-0030
(2)(i) and OAR 860-086-0040(1)(a)(H), as discussed in the
memo.
• In the medium term, Energy Trust should collaborate with
Community Partners and utilities to receive additional data
to prioritize specific customers.
(6) Energy Trust should improve information (e.g. its website and
related channels) for customers on how to access no-cost
services, including associated services not offered by Energy
Trust.
Staff plans work with utilities to pursue the following improvements:
(7) Utilities to share all relevant information (e.g. from Energy
Burden assessments) that may help prioritize high energy
burden/high energy efficiency potential customers with
implementers.
• Utilities to include rate schedule identifiers for bill discount
program participants with Energy Trust as part of their
regular data-sharing (as discussed in the memo).
• Staff expects utilities to enter conversations with Energy
Trust, CAAs, and OHCS on how to share insights from
Energy Burden Assessments.
(8) Avista, Cascade, IPC, and NWN should modify their low-income
weatherization tariffs to achieve the following:
• Conduct free energy audits for customers with high usage
and low incomes.
• Condition funding on pro-actively prioritizing customers
with high energy burden and high energy efficiency
potential. Utilities should regularly evaluate its delivery
contractors to ensure cost-effective use of funds. Funds
should be made available on a competitive basis.
• The number of households served should steadily
increase over the next five years, and more funding
should be made available if necessary.
(9) PGE and PAC should collaborate with recipients of PPC funds
(OHCS/CAAs) to:
• Initiate free energy audits for customers with high usage
and low incomes.
• Share information to enable implementer to pro-actively
prioritize customers with high energy burden and high
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energy efficiency potential.
Staff plans to pursue better coordination between various implementers of low-income
weatherization programs, including state agencies, and:
(10)Initiate coordination with ODOE, OHCS, and Energy Trust to
discuss braiding and prioritization in IRA rebates.
(11) Initiate closer collaboration between Energy Trust/Community
Partners and OHCS/CAAs with the goal of exploiting
opportunities for joint marketing, joint customer management,
and joint projects.
Staff's primary focus in crafting this action plan has been on short-term actions that
improve weatherization and energy efficiency services for low-income households.
Because the above list is already lengthy, Staff believes it is too early to establish a new
funding mechanism under HB 2475 authority and create a new delivery network, as
some advocates request. Further coordination between state agencies, and potentially
legislators, is necessary to determine the best way forward regarding new funding
mechanisms. Staff will continue to evaluate throughout 2025 and update this
recommendation in 2026.
Stakeholder Feedback
At the October 10, 2024, energy efficiency and weatherization workshop, and in
submitted comments, utility-and non-utility stakeholders expressed a need for
expanding resources spent on low-income weatherization and energy efficiency,
although utilities were skeptical about whether this need should be filled with ratepayer
funds. All stakeholders also underlined the necessity of better coordination between
OHCS/CAA-led programs and offers implemented through Energy Trust and CBOs, as
well as the need to create a centralized information resource. Energy Trust suggested a
broad convening of parties to determine shared objectives and joint implementation. All
stakeholders agreed that a shared strategy should include a more pro-active approach
of addressing energy burden by leveraging customer-level data.
Many parties commented on the need to supplement measure-specific funding with
health and safety funds that enable weatherization. Energy Justice Advocates
suggested a full-blown home repair fund should be set up.
There was no agreement among stakeholders about how increased funds for existing or
new sources are best spent. Some suggested that the network of CAAs is best situated
to offer comprehensive, high-quality services, and all low-income funds should be spent
through this pathway. Energy Justice Advocates asked that more funds be allocated
directly to CBOs, bypassing centralized organizations like OHCS or Energy Trust.
Energy Efficiency and Weatherization Workstream Conclusion
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Staff believes that its outlined action plan addresses many of the gaps identified by
stakeholders and finds a good middle ground where opinions diverged. Staff looks
forward to working with the relevant parties to advance these desired outcomes and
reporting back in 2026 on progress and continued opportunities. To this end, Staff
believes the only necessary item for Commission action regards data-sharing with
Energy Trust, as outlined in the body of the memo and in the proposed Commission
motion.
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Appendix A— Stakeholder Feedback on the Arrearage and Disconnection Action
Plan and Assessment
Arrearage and Disconnection Action Plan — Stakeholder Feedback
On October 25, 2024, Staff released its Proposed Phase 2 Arrearage and
Disconnection Action Plan for the ongoing UM 2211 HB 2475 Implementation. The
Action Plan includes multiple action items looking to identify and advance key near-term
actions to mitigate the significant human harms caused by energy insecurity going into
the upcoming winter heating season. Following requests for additional engagement and
comment periods, Staff agreed to extend the original timeline to include two additional
workshops prior to a revised comment deadline. Staff would revise the Action plan as
needed following the workshop engagement and comment deadline and then bring it to
a public meeting for Commission decision and guidance. The draft Phase 2 Proposed
Actions were broken out into seven buckets:
1. Vulnerable Population Definition(s),
2. Cold Weather Protections,
3. Hot Weather Protections,
4. Disconnection Practices & Triggers,
5. Reconnection Practices & Customer Fees,
6. Arrearage Relief, and
7. HB 2475 Discounted Rate Programs.
Staff collected feedback at the October 30 and November 7 workshops and received
filed comments on November 15 responding to the Action plan. The filed comments
included comments from:
Stakeholder Feedback
Topic 1: Vulnerable Population Definitions
Staff's proposed recommendation was to include additional populations as Qualified
Households for enhanced disconnection protections. Staff included a definition for
Qualified Households for Stakeholders to review and respond to as well.
Stakeholder Comments
Within workshops, utilities were generally supportive and open to the intent of this action
item and were open to try and expand the households that are eligible for programs but
had some concerns around the Qualified Households definition being self-attestation
and how to implement the definition administratively. Utilities were also concerned about
how much extending the definition of Qualified Households would expand protections
and thus, expand costs for customers. Additionally, utilities brought up the concern
about creating categories that are too broad that may result in finite resources not
reaching the customers who need it most.
EJ Advocates in workshops offered the suggestion of using programs like the
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Supplemental Nutrition Assistance Program (SNAP) for categorical eligibility.
Additionally, EJ Advocates offered padding this definition for the short-term with an
income threshold, with examples of 80-100 percent SMI or 200 percent Federal Poverty
Level (FPL). It was flagged that the law is broader than just income, and that it is
important to reflect information gleaned from utilities Energy Burden Assessments
(EBAs) that reflect need for higher income categories that are still energy burdened.
Within written comments, while many utilities understood the intent behind the
recommendation, all utilities were concerned about the broadness of the definition and
had questions around the full economic and administrative impacts of moving to the
"Qualified Households" definition. Idaho Power flagged that from their LINA, 80 percent
of their service territory fall below 80 percent SMI, which leads them to question how
many customers would qualify for protections if this was altered to an 80 percent SMI
standard. Cascade highlighted that additional staff would be needed to sufficiently
handle expanding qualifications and that focusing on improving the structures in place
today may be a higher priority. Avista supported including additional populations but
wanted additional clarity on definitions of what characteristics qualify a household under
the new term and that currently Avista does not have the ability to identify all of the
subsections under the definition.
EJ advocates strongly supported Staff's recognition that income is not the only factor for
vulnerability and supported self-attestation of the Qualified Household components.
They offered that if the Commission does not adopt Staff's proposal, they would
recommend that the definition cover customers with incomes at 80 percent SMI and
below while working with stakeholders and utilities to set in place systems for self-
attestation of other qualified customer types.
Topic 2: Cold Weather Protections
Staff proposed two recommendations, including:
a. Adding date-based protections to prohibit disconnection for
qualified households between December 1 and March 1,
b. Expanding temperature-based protections to prohibit
disconnection in the 24 hours before severe weather of a
forecasted low of less than 32 degrees Fahrenheit is forecasted
by the National Weather Service (NWS).
Stakeholder Comments
Gas utilities brought up in workshops that date-based disconnection moratoriums can
have some nuance, and that often gas disconnections peak in the spring and summer
months. Utilities also raised that there are already protections in place from AR 653, and
that current operations allow their systems to reconnect customers quickly and that the
proposals could result in hampering a utilities ability to collect from customers. Almost
all utilities offered that they provide a voluntary moratorium during the week of
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Thanksgiving and for roughly two weeks around Christmas. EJ advocates supported
stronger disconnection protections around cold weather and highlighted the need to
increase communication with customers during the disconnection process.
In written comments, most utilities were concerned with implementing date-based
protections/moratoriums to prohibit disconnections for qualified households. Many cited
the current rules are sufficient to providing temperature-based protections for vulnerable
customers. Cascade raised concerns around the moratorium reducing and eliminating
the Company's ability to collect unpaid bills which would result in an increase in bad
debt.59 Similar concerns were raised by PacifiCorp, but the Company stated that
notwithstanding concerns regarding the impact of such a change, PacifiCorp could
implement a moratorium on disconnection for non-payment 24 hours prior to a
forecasted low of 32 degrees. Idaho Power offered that the Company's current Winter
Protection Program, authorized by the Commission, satisfies the recommendations and
provides the desired protections and believes no further action is required in its service
area.
PGE stated that if the date-based protection was modified to apply to the existing
Medical Certification household classification, the Company believes it would lead to a
decrease in winter disconnections and would be supportive. PGE highlighted the
previous moratorium which led to higher arrearage levels, ultimately delaying
disconnections, and contributing to higher future costs for TPAs and/or increasing
uncollectible revenues. Additionally, PGE is concerned that an unintended consequence
would be a rush on energy assistance applications following the conclusion of the
moratorium. PGE offers a similar modification to prohibiting disconnection in the
24 hours before, the dates of, and 24 hours following a severe weather event, and
stated that the Company believes the recommendation if modified to apply to an
existing customer classification, such as Medical Certificate households or IQBD
participants, would reduce winter disconnections where Recommendation 2a is
withdrawn.
Avista offered (earnings from winter moratoriums in its Idaho service territory stating that
customers accessing the winter moratorium are often subject to service disconnection
immediately following the winter, with some customers carrying balances from one
winter season into another. Avista and NW Natural add that if the Commission
implements date-based cold weather protections, it should consider the differences
between utility fuel types and that natural gas customers often only use their natural gas
service between November and April, and the recommended protections could
encourage customers to limit their payments towards their utility bill, leaving them with
unmanageable balances to deal with prior to the next heating season. Avista offers that
the expansion of temperature-based protections in recommendation 2b is more
51 CNGC's Comments, UM 2211. Filed November 15, 2025,
https://edocs.puc.state.or.us/efdocs/HAC/um2211 hac333009120.pdf.
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appropriate than the date-based protection.
EJ advocates written comments support Staff's proposals adding that data analysis
shows that March is a cold month in Oregon with high usage patterns aligned with
December— February. Additionally, EJ advocates would like recommendation 2b to be
adjusted to include a prohibition on disconnection 72 hours ahead of, during, and
24 hours following a cold weather event. Finally, EJ advocates recommend that no
utility be able to opt out of Division 21 winter protection rules as a result of heaving a
Winter Protection Program that is less protective and encourage the Commission that
utilities with a WPP must also comply with these protections. EJ advocates specifically
highlight that adding in this modification will allow customers to be protected if they are
unaware of the WPP.
Topic 3: Hot Weather Protections
Staff's recommendation was to expand Temperature-Based Protections to prohibit
disconnection to 24 hours before, the dates of, and 24 hours following severe weather
days of more than a forecasted high of 95 degrees Fahrenheit for Qualified households,
and any residential customers served in counties where the overall heat vulnerability
index (OHVI) is greater than 60.
Stakeholder Comments
EJ advocates supported expanding temperature-based protections in the workshops
and highlighted a concern that adopting that within this process may be helpful if we are
unable to finalize the rulemaking before the cooling season. Utilities varied around
support of the overall protection proposal but brought up concerns with the workload
that this may add as many of the processes would be manual.
In written comments, all gas utilities supported natural gas utilities not being subject to
hot weather protections as natural gas is not typically used for home cooling in Oregon.
PGE does not believe that measures for summer 2025 should be adopted at this time
and added that hot weather disconnection protections can be reconsidered prior to
Summer 2025 if appropriate.60 PGE added that the Company is concerned with the
linkage to OHVI scores as a proxy for the heat sensitivity of individual households and
that this approach could extend protections to a subsect of PGE's service territory.
PacificCorp reiterated comments around the 24-hour prohibition from cold-weather
events and disagreed with having a prohibition on disconnection following a severe
weather day stating the protection is meant to occur during the severe weather event
and that future/forecasted weather events would be covered under existing rule.6' Idaho
Power highlighted the importance of considering service area criteria when establishing
temperature thresholds including that their Oregon service territory often sees
so PGE Comments on Staff's Recommendation, UM 2211, Filed November 15, 2024,
https://edocs.puc.state.or.us/efdocs/HAC/um2211 hac333052120.pdf.
61 PacifiCorp Comments on Proposed Action. UM 2211, Filed November 15, 2024,
https://apps.puc.state.or.us/edockets/DocketNoLayout.asp?Docketl D=23122.
APPENDIX A
Page 40 of 48

Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 41
temperatures over 95 degrees.62 The Company offered that the Commission should
consider utility specific recommendations similar to how cold weather temperature
thresholds are currently treated in Division 21 rule language.
EJ advocates written comments support Staff's proposal to include protections where
the OHVI is greater than 60.63 EJ advocates support Staff's proposal on expanding
temperature-based protections to better account for forecasted severe weather but
encourage expanding the protection from 24 to 72 hours prior to an event including that
disconnecting households when a severe weather event is approaching is inhumane
and dangerous.
Topic 4: Disconnection Practices & Triggers
Staff included three recommendations in its draft proposal:
a. Where disconnection is not already prohibited, require direct
contact in-person or via phone with an occupant of the
household over 18 years of age if the utility wishes to disconnect
any residential account within 24 hours before or 24 hours after a
severe weather day.
b. Standardize and direct minimum past-due amount for
disconnection to $200- or two-months past-due, whichever is
lower.
c. Prohibit the use of disconnection prioritization scores that result
in disproportionate and negative impacts to Qualified
households.
Staff notes that within its Revised Action Plan, this section of recommendations was
removed following discussions at Staff workshops around prioritizing near term actions
and acknowledging that these action items could benefit from continued discussion.
Stakeholder Comments
Utilities raised that they already are required to make phone calls for disconnection and
brought up concerns around how the direct contact could interact if a customers
preferred contact method was texting. Additionally, utilities brought up the additional
workload for field representatives as well as concerns around customers avoiding
utilities and that the workload may outweigh the benefit to customers. EJ advocates
recommended a method where texting a customer for a response could be an option to
explore. EJ advocates also raised that standardizing the discount amount and
prohibiting the use of prioritization scores could become more important if deeper
protections are not implemented before the winter heating season.
61 Idaho Power Company's Reply Comments, UM 2211. Filed November 15, 2024,
https://edocs.puc.state.or.us/efdocs/HAC/um2211 hac333060120.pdf.
63 Energy Justice Advocates Comments on Arrears and Disconnection Workstream, UM 2211. Filed
November 18, 2024, https://edocs.puc.state.or.us/efdocs/HAC/um2211hac333072120.pdf.
APPENDIX A
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Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 42
In written comments, Cascade agrees with Staff that a temperature or date-based
moratorium on disconnection for nonpayment would be much simpler to implement as
compared to the proposed action item list. Avista offered that it does not have the ability
to incorporate the OHVI currently and that investing in this platform would be a waste of
resources for the Company and unnecessary expenses for its customers. NW Natural
supported the utilities being able to use their own operational experience and business
practices and guidelines to set rules and triggers. PacifiCorp agreed to raising the
disconnection threshold to $200, and does not support making the prioritization change
but would be open to discussions with stakeholders to arrive at a balanced solution.
Topic 5: Reconnection Practices & Customer Fees
Staff's draft action plan included five recommendations including:
a. Required reconnection prior to 8:00 AM on the forecasted date of
severe weather for Qualified Households that were disconnected
within 7-days of a severe weather event.
b. Limit the required balance pay-off for Qualified households
seeking reconnection to not more than the amount of an average
monthly bill for that customer's previous account if the Qualified
household demonstrates reasonable efforts to connect with
energy assistance and enrolls in a TPA or AMP for the remaining
balance.
c. Eliminate all reconnection charges for Qualified Households.
d. Eliminate all punitive fees for Qualified Households, including but
not limited to, return payment charges.
e. Eliminate late fees for all residential customers.
f. Eliminate security deposits for all residential customers.
Stakeholder Comments
In written comments, EJ advocates strongly support eliminating reconnection charges
for Qualified Households to ensure they are not being penalized for lacking the financial
means to avoid disconnection through fees that compound the financial hardship that
resulted in them facing disconnection.
Many utilities written comments include being open to further discussions on these
topics. NW Natural offers that required reconnection can raise many potential problems
and questions that need additional workshopping. All natural gas utilities flag that field
crews are required to restart pilot lights when reconnecting, and that accessing
customers home before 8:00am could become an issue and would negatively impact
their trust with customers. Additionally, natural gas utilities highlight that eliminating
reconnection charges is a problem for gas companies as field crews are required to
enter homes, and that comes at a cost. PacifiCorp, PGE, and Idaho Power offered in
written comments that existing rule provides protection for customers who need service
reconnected during or before forecasted severe weather events. Additionally, the
APPENDIX A
Page 42 of 48

Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 43
Company disagreed with the other listed action items, stating that all the fees a
Company charges its customers have been approved by the Commission are in place
to ensure the actions of one customer do not increase costs for other customers. PGE
flagged they are open to feedback from stakeholders on how to conduct outreach
around current protections and that these recommendations be deferred for a future
phase in the UM 2211 docket that includes additional discussion with stakeholders.
Topic 6: Arrearage Relief
There were five recommendations for arrearage relief proposed by Staff:
a. Apply qualified discounts to all arrears of income qualified bill
discount program participants (inclusive of arrears accumulated
prior to enrollment).
b. Offer Arrearage Forgiveness to households earning at or below
0-5 percent SMI.
c. Offer Arrearage Management with tiered matching payments for
high energy burden households earning between 6-60 percent
SMI.
d. Adopt Date-Based Forbearance options on TPAs and AMPs for
Qualified Households.
e. Adopt flexible TPA and AMP term structures to ensure the sum
of current and past due charges does not exceed 6 percent of
the household's gross monthly income.
Stakeholder Comments
Utilities mentioned support for a one-time arrearage forgiveness program for 0-
5 percent SMI customers. Additionally, utilities flagged concern around date-based
forbearance as it could result in customers forestalling to pay their bill as well as the
possibility of seeing a similar result to COVID-19 moratorium with rising arrearage
balances. EJ advocates brought up the concern about comparing current situation to
COVID times as we are not all in a collective emergency as we were then, and that
while looking back can be helpful it is also of limited use. Utilities also discussed
exemptions to their bill discount program allowing for additional help to 60-80 percent
SMI customers, as well as previous crisis grants. Discussions at the workshop evolved
into having a more passive offering for customers who call in and need help having
assistance offered to them, which led to discussions around customers needing to me
more aware of their rights when navigating situations with utilities and whether
customers would need to ask specifically for the protections.
In written comments, Cascade provided it is willing to revise the applicability standard
so that arrearage forgiveness is offered to customers with a 200 percent FPL or
80 percent SMI (compared to the current program offered to 150 percent FPL or
60 percent SMI customers) but that the change would require a tariff filing, which would
require a minimum of 30 days. Cascade states the Company is opposed to dismantling
APPENDIX A
Page 43 of 48

Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 44
and redesigning its arrearage relief program at this time as it appears to be serving
customers as intended. Avista includes the Company's current program, which offers an
arrearage forgiveness and relief program. The Company states that many of the
recommendations do not apply, and those that would, may not result in a significant
benefit when compared to the system enhancement needed, as the current program is
designed to get a household to an energy burden of 3 percent or below. NW Natural
highlights they are currently developing an AMP program that will be provided after the
November 26 public meeting, and may support the concept of calculating an arrearage
grant based on multiplying a customer's arrearage balance times the customer's bill
discount percentage, but that flexibility for programs in the development stage is
warranted.
Idaho Power offers that arrearage relief programs are most appropriately tailored to
each utility to allow for analysis of current arrearage levels and overall costs involved in
implementing the relief. The Company includes that UE 426 includes a component of
Idaho Power convening stakeholders and recommends Staff propose the Commission
allow Idaho Power to fulfil that commitment. PacifiCorp comments it is open to a one-
time crisis forgiveness program and that any program offered should be studied more
carefully within UM 2211 to leverage learnings from other utilities. PacifiCorp disagrees
with applying discounts to all arrears prior to enrollment, implementing any tiered
matching payments, or offering date-based forbearance on time-payment
arrangements. PGE sought clarification in written comments on whether Staff intends
6a and 6b as one-time discount applications stating that the present proposal of 6a
presents complexities and is unlikely to have a significant impact on overall arrearage
balances and would provide limited 2025 protections. Additionally, PGE offered that the
Company offers programs that provide customers the most benefit and the additional
near programs complicate the existing flexible framework.
EJ advocates written comments are supportive of Staff's proposals and include that
arrearage relief programs can be key to avoiding disconnection and that forbearance
options allow for customers to realistically navigate above-usage months.
Topic 7: HB 2475 Discount Rate Programs
Staff recommended to increase monthly discounts for tier(s) applicable to customers
earning at or below 0-10 percent SMI.
Stakeholder Comments
In written comments, PacifiCorp was receptive to the recommendation as it aligns with
the Company's energy burden assessment (EBA and agrees with a 50 percent discount
for customers with incomes between 0-10 percent SMI. PacifiCorp highlights the EBA's
recommended hybrid approach of bill discounts and assistance grants and includes that
it would like Staff to hold a workshop(s) to explore this issue with all utilities and
stakeholders present to pursue best solutions. PGE comments that the most productive
near-term actions focus on increasing enrollment growth as the program scales maturity
APPENDIX A
Page 44 of 48

Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 45
and continues to close the energy assistance need and adding additional tiers would
take longer than the January 1, 2025, target date. The Company argues against a
conclusion that current disconnection trends indicate the IQBD's current structure is not
working and flag that depending on the scale of discount increases, changes could
increase 2025 IQBD costs by $10-20 million. Additionally, the Company states that the
funds would be directed mostly at current program participants and would not
necessarily be linked to increased adoption of energy efficiency and that effective
program design would avoid large steps between adjacent discount levels (i.e. 0-
5 percent SMI with a 90 percent discount and 6-10 percent SMI customer with a
40 percent discount). Finally, PGE states they are open to exploration of additional
concepts including expedited or required verification for higher discount tier customers,
a hybrid design suggested in PacifiCorp's EBA or an energy burden design similar to
what Idaho Power is implementing, but the additional complexities require more time
and remain the scope of upcoming UM 2211 phases.
EJ advocates written comments strongly support Staff's recommendation but suggest
expanding to include customers between 0-15 percent SMI.
APPENDIX A
Page 45 of 48

Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 46
Arrearage and Disconnection Assessment— Joint Environmental Justice
Advocates Proposed Action Items
Staff received the following proposed Action Items from Joint Environmental Justice
(EJ) Advocates (Verde, Coalition of Communities of Color, NW Energy Coalition,
Community Energy Project, Oregon Just Transition Alliance, Multnomah County Office
of Sustainability, and Oregon Citizens' Utility Board) within Joint EJ Advocates filed
comments following the September 16, 2024, Staff Arrearage and Disconnection
Assessment in UM 2211. EJ Advocates broke down their recommendations into near-
term and long-term actions.
Near-term actions:
• Enhance disconnection protections to cover vulnerable
communities.
o Extend disconnection protections to households with
children, households with folks living with disabilities,
households with elders, households with folks living with
chronic illnesses, and households living on fixed incomes.
o Protections for identified vulnerable customers, if not year-
round, need to include both winter and summer months
given the extreme heat and severe winter weather that
Oregon is increasingly experiencing.
• Enhance severe weather protections.
o Implement calendar-based seasonal disconnection
moratoriums to protect customers from disconnection in
winter and summer months.
o Alternatively, the Commission could adopt a moratorium
on disconnections when the National Weather Service
forecast severe weather in the next 72 hours.
o Disconnection protections should also include the full day
after a heat event has ended.
o Utilities should reconnect customers ahead of a severe
weather event.
o No customer should remain disconnected during a severe
weather disconnection moratorium.
• Structure Time Payment Arrangement (TPA) to recognize the
realities faced by low-income customers.
o Adopt seasonal TPA modifications that require utilities to
pause TPA payments on higher consumption months to
recognize households experiencing financial challenges.
o Extend the length of TPAs from 12 to 24 months, unless a
customer prefers a shorter time.
o Reevaluate how many times a customer can renegotiate a
TPA or miss a payment on a TPA.
APPENDIX A
Page 46 of 48

Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 47
• Adopt arrearage forgiveness/relief and arrears management
tools.
o Adopt an arrearage forgiveness/relief program for
households with the lowest incomes.
o Adopt an arrearage management program for higher
income households, including those who are at 61-
100 percent of State Median Income (SMI).
• Alter current reconnection requirements under OAR 860-021-
0335(2).
• Eliminate all reconnection fees for discount-program participants.
o Data indicates that a significant number of identified low-
income households continue to be disconnected and may
be subjected to reconnection fees that increase hurdles to
reconnection.
• Eliminate security deposits for all customers, as PGE and
Cascade have done.
• Increase disconnection "trigger" past due amounts.
• Move away from disconnection "prioritization" practices that
increase the risk of disconnection for low-income and other
environmental justice communities.
• Redesign utility disconnection notices and implement friendly
reminders that clearly outline assistance, to be utilized prior to
any disconnection notice or actual disconnection.
o Disconnection notices should list disconnection
protections, which include a customer's right to be
reconnected, and information on a utility's HB 2475 Bill
Discount Program.
• Disconnections should not be administered without face-to-face
contact, or at least direct contact via phone with the account
holder or a household member over the age of 18.
• Recognize the funding and timeline realities that customers
seeking energy assistance grants may face, by preventing
utilities from disconnecting customers who self-certify that they
are seeking energy assistance.
o Utilities should defer disconnection at least once when
customers self-certify their efforts to get an energy
assistance appointment.
o Utilities and stakeholders should commit to seeking a
reinstatement of the increased energy assistance fee that
expired in 2022.
• Allow low-income customers to access available payment plans.
• Recognize in rules and practices around disconnections and
arrearages that some customers are more vulnerable to
APPENDIX A
Page 47 of 48

Docket No. UM 2211 ORDER NO. 24-426
November 19, 2024
Page 48
disconnection and arrearages and will be impacted more
severely.
o In addition to disconnection moratoriums, potential
changes include greater timelines to pay bills and
arrearages, arrearage minimums for disconnection, notice
and contact requirements for vulnerable communities.
• Eliminate late fees for all customers.
• Extend bill timing — Extend bill due dates to at least 30 days after
the end of the billing cycle.
• Require utilities to adjust customer bill language to include
information about qualifying for and obtaining a medical
certificate.
Long-term actions:
• Severe weather:
o Enhancing protections in geographic areas known to be at
a higher risk from certain weather events.
o Direct utilities to engage with any disconnected customer
to inform them of requesting reconnections and of local
severe weather locations.
o Expand winter weather protections to customers in areas
currently covered by 860-021-0407(10).
• Greater protections for Functional and Access Needs
Populations — Consider "Functional and Access Needs/At Risk
Populations" concept when defining vulnerable communities.
• Implement a performance-based ratemaking pilot with incentives
and disincentives for utilities based on progress or regress on
disconnections.
• Evaluate utilities communications strategies around
reconnections and disconnections.
• Explore still relevant recommendations in Advocates'
Recommendations in UM 2114 that PUC, other agencies,
utilities, and stakeholders have yet to implement.
• Direct utilities to implement a pilot on alternatives to
disconnection as a collection mechanism.
• Evaluate language accessibility of disconnection practices.
• Require utilities to perform data analysis that looks into racial
disparities of who is being disconnection in their territories.
APPENDIX A
Page 48 of 48

ORDER NO. 24-429
ENTERED Nov 27 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UM 779
In the Matter of
PUBLIC UTILITY COMMISSION OF ORDER
OREGON,
Determination of Late-payment Rate and
Interest Accrued on Customer Deposits.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its public meeting on November 26, 2024,the Public Utility Commission of Oregon
adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
(�A
ITY cO
Alison Lackey
` Chief Administrative Law Judge
OF OREGG�
A party may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each party to the
proceedings as provided in OAR 860-001-0180(2).A party may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-429
ITEM NO. CA6
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
PUBLIC MEETING DATE: November 26, 2024
REGULAR CONSENT X EFFECTIVE DATE January 1, 2025
DATE: November 18, 2024
TO: Public Utility Commission
FROM: Madison Bolton
THROUGH: Caroline Moore, Scott Gibbens, and Curtis Dlouhy SIGNED
SUBJECT: OREGON PUBLIC UTILITY COMMISSION STAFF:
(Docket No. UM 779)
Commission determination of late payment rate and interest accrued on
customer deposits.
STAFF RECOMMENDATION:
Staff makes the following recommendations:
1. Approve a late payment rate of 2.4 percent monthly on overdue customer
accounts.
2. Approve an annual interest rate of 4.5 percent on customer deposits for calendar
year 2025.
3. Direct the affected utilities to refile their respective tariffs to reflect the new rates.
DISCUSSION:
Issue
Whether the Commission should change the late payment rate to 2.4 percent and
change the interest rate for customer deposits applicable for customer accounts in 2025
to 4.5 percent.
Applicable Rules or Laws
Oregon Administrative Rules (OAR) 860-021-0126(4), 860-036-1430(2), and
860-037-0115(2) specify that the Commission will determine the late payment rate
applicable to past-due accounts based on a survey of prevailing market rates for late
payment charges of commercial enterprises. Additionally, the OAR specify that the
APPENDIX A
Page I of 7

ORDER NO. 24-429
Docket No. UM 779
November 18, 2024
Page 2
Commission will advise all energy, large telecommunications, regulated water, and
wastewater utilities of the changes in the rate they may use to determine late payment
charges on overdue customer accounts. The current late-payment rate and the
conditions for its application to customer accounts shall be specified on the utility bill.
OAR 860-021-0210(1), 860-034-0160(1), 860-036-1250(1), and 860-037-0045(1)
specify that "each year, the Commission shall establish an annual interest rate that must
be paid on customer deposits." The rules specify that for energy and large
telecommunications, small telecommunications, rate-regulated water utilities, and
wastewater utilities, the Commission will:
Base the rate upon consideration of the effective interest rate for new
issues of one-year Treasury Bills issued during the last week of October,
the interest rate on the most recent issuance of one-year Treasury Bills, or
the effective interest rate for the average yield of Treasury Bills of the
closest term issued during the last week of October. This interest rate,
rounded to the nearest one-half of one percent, shall apply to deposits
held during January 1 through December 31 of the subsequent year.
These rules, and OAR 860-036-1240 relating to regulated water utilities, also specify
that the Commission will advise the respective utilities of the changes in the rate to be
paid on customer deposits.
Analysis
Analysis of Late Payment Charge on Customers'Past Due Balance
Nationally, many utility companies establish a monthly percentage rate for determining
late payment charges such that the cost of not paying a utility bill is roughly equal to the
cost of not paying a credit card. However, some publicly-owned utilities (water/sewer
and electricity) and insurance companies choose not to charge a late payment fee.
Generally, in either case, past due accounts may be subject to cancellation of the
services or policies.
The late payment rate adopted by the Commission is based on an average Annual
Percentage Rate (APR) from survey results of commercial enterprise late payment
charges. The rate sets forth the maximum amount any energy, large
telecommunications, regulated water, and wastewater utility may assess for a late fee.
Utilities may not include an additional flat fee.'
Many unregulated businesses (commercial enterprises)surveyed charge a flat fee for late payments up
to $41, in addition to a finance charge of 1.71 percent to 2.87 percent per month.
APPENDIX A
Page 2 of 7

ORDER NO. 24-429
Docket No. UM 779
November 18, 2024
Page 3
To collect the appropriate data for the late payment rate, Staff recently surveyed over
40 commercial enterprises believed to be reasonably representative of a range of
businesses patronized by utility customers.
The survey included department stores, retailers of gasoline, passenger rail and airline
travel, hotels, household appliances, furniture, clothing, tires, hardware, consumer
electronics, groceries, books, home improvement products and services, and other
general merchandise. The survey also included providers of water and sewer services,
recycling and disposal services, electricity and telecommunications services, and
insurance companies.
The survey indicated that a 2.418 (rounded to 2.4) percent monthly charge, or an
average APR of 29.02 percent, is commonly applied by businesses for late payments.
Staff recommends changing the current maximum late payment rate of 2.3 percent
monthly to 2.4 percent monthly (28.02 percent in 2024 to 29.02 percent APR) for
calendar year 2025.
Staff concludes that the monthly 2.4 percent late payment charge is reasonably
consistent with the practices of commercial enterprises based on the results of Staff's
survey.
The figure below shows the late-payment rates that the Commission established from
1995 to 2024.2
2 The rates shown reflect the average APR for commercial enterprises as surveyed by Staff. The
averages are shown with the year they were calculated.
APPENDIX A
Page 3 of 7

ORDER NO. 24-429
Docket No. UM 779
November 18, 2024
Page 4
OPUC Late-Payment Charge on Overdue Account
Annual Percentage Rate-APR% 1995-2024
25%
23%
21%
19%
17%
15%
95 '96 '97 '98 '99 '00 '01 '02 '03 '04 '05 '06 '07 '08 '09 '10 '11 '12 '13 '14 '15 '16
w APR% 18%18%18%18%22%22%21%19%19%20%20%20%20%19%19%21%21%22%22%22%22%22%24%24%25%23%23%26%28%29%
Analysis of Interest Paid on Customer Deposits
The Commission bases the rate upon consideration of the effective interest rate for new
issues of one-year Treasury Bills (T-bills)3 issued during the last week of October, the
interest rate on the most recent issuance of one-year T-bills, or the effective interest
rate for the average yield of T-bills of the closest term issued during the last week of
October.4
There were no new issuances of one-year T-bills that took place during the last week of
October 2024. Staff used the average yields of T-bills of the closest term issued during
the last week of October. On October 25, 28, 29, 30, and 31, 2024, The Wall Street
Journal reported that the T-bills maturing on October 2, 2025 (336-342 days to
maturity), had asking yields averaging 4.2658 percent for the week.
3 Treasury bills, or T-bills, are short-term debt instruments issued by the U.S Treasury and issued for a
term of one year of less. They do not pay interest, but rather are sold a discount to their face value.
`Treasury Yield' is the return on investment. T-bills are considered the world's safest debt as they are
backed by the full faith and credit of the United States government.
4 OAR 860-037-0045(1); OAR 860-036-1250. Although OAR 860-036-1250 specifies that the Commission
will determine the customer deposit interest rate for regulated water utilities, it does not include the guide
for calculating the rate that is included in the rules for the other utilities. Nonetheless, Staff recommends
that the Commission use the same rate for regulated water utilities.
APPENDIX A
Page 4 of 7

ORDER NO. 24-429
Docket No. UM 779
November 18, 2024
Page 5
Based on Staff's analysis, Staff recommends that the Commission change the
annualized minimum interest rate at which utilities must credit customers for deposits to
4.5 percent, effective January 1, 2025.
Per the applicable rules, the interest rate used for customer deposits should round to
the nearest 0.5 percent. By applying the rules' 0.5 percent rounding requirements, Staff
rounds the 4.2658 interest rate obtained in the analysis to 4.5 percent. Accordingly,
Staff recommends a 4.5 percent minimum interest rate at which utilities must credit
customers for deposits for calendar year 2025.
The figure below shows the changes of the Interest Paid on Customer Deposits Rates
that the Oregon PUC used from 1995 to 2024.5
OPUC Interest Paid on Customer Deposits
Treasury Bill,Asked YLD,1995-2024
6.5
6.0
5.5
5.0
4.5
4.0
3.5
3.0
2.5
2.0
1.5
1.0
0.5
0.0 D o o 0 0 e
.95 '96 '97 '98 '99 '00 '01 '02 '03 '04 '05 '06 '07 '08 '09 '10 '11 '12 '13 '14 '15 '16 '17 '18 '19 '20 '21 '22 '23 '24
oSeries2 6.006.005.005.004.075.482.021.491.022.114.205.154.021.420.380.210.110.160.090.090.290.651.422.651.580.120.114.605.424.27
The decrease from the currently effective 5.5 percent to 4.5 percent is supported by
information from the September meeting of the Federal Open Market Committee
(FOMC or the Committee). The Federal Reserve controls the three tools of monetary
policy: open market operations, the discount rate, and reserve requirements. On
September 18, 2024, the Federal Reserve issued a press release regarding the
FOMC's current goals related to federal funds rate and inflation.6 The FOMC has
determined that lowering the target range for the federal funds rate by half a percentage
5 The rates shown reflect the average effective interest rate on one-year T-Bills for the most recently
available issuances in the month of October. The averages are shown with the year they were
calculated.
6 Press Release, September 18, 2024, Federal Reserve issues FOMC statement:
https://www.federalreserve.aov/newsevents/pressreleases/monetary20240918a.htm.
APPENDIX A
Page 5 of 7

ORDER NO. 24-429
Docket No. UM 779
November 18, 2024
Page 6
point (to 4.75 - 5 percent) is necessary to continue making progress towards a two
percent inflation rate. The September FOMC statement summarized the Committee's
intent regarding the federal funds rate and inflation activity in the following excerpt:
Recent indicators suggest that economic activity has continued to expand
at a solid pace. Job gains have slowed, and the unemployment rate has
moved up but remains low. Inflation has made further progress toward the
Committee's 2 percent objective but remains somewhat elevated.
The Committee seeks to achieve maximum employment and inflation at
the rate of 2 percent over the longer run. The Committee has gained
greater confidence that inflation is moving sustainably toward 2 percent,
and judges that the risks to achieving its employment and inflation goals
are roughly in balance. The economic outlook is uncertain, and the
Committee is attentive to the risks to both sides of its dual mandate.
In light of the progress on inflation and the balance of risks, the Committee
decided to lower the target range for the federal funds rate by 1/2
percentage point to 4-3/4 to 5 percent. In considering additional
adjustments to the target range for the federal funds rate, the Committee
will carefully assess incoming data, the evolving outlook, and the balance
of risks. The Committee will continue reducing its holdings of Treasury
securities and agency debt and agency mortgage-backed securities. The
Committee is strongly committed to supporting maximum employment and
returning inflation to its 2 percent objective.
Conclusion
Staff concludes that a monthly 2.4 percent late payment charge for calendar year 2024
is reasonably consistent with the practices of commercial enterprises based on the
results of Staff's survey.
Staff concludes that a 4.5 percent minimum interest rate at which utilities must credit
customers for deposits for calendar year 2025 is consistent with federal funds rate and
monetary policy.
APPENDIX A
Page 6 of 7

ORDER NO. 24-429
Docket No. UM 779
November 18, 2024
Page 7
PROPOSED COMMISSION MOTION:
Staff recommends the Commission:
1. Approve a late-payment rate of 2.4 percent monthly on overdue customer
accounts.
2. Approve an annual interest rate of 4.5 percent on customer deposits for calendar
year 2025.
3. Direct affected utilities to refile their respective tariffs to reflect the new rates set
forth in Staff's memorandum.
Docket No. UM 779 (2024)
APPENDIX A
Page 7 of 7

ORDER NO. 24-435
ENTERED Dec 10 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UM 1753(9)
In the Matter of
AVISTA CORPORATION, dba AVISTA ORDER
UTILITIES,
Application for Reauthorization to Defer
Expenses or Revenues Related to the
Natural Gas Decoupling Mechanism.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its public meeting on December 10,2024, the Public Utility Commission of Oregon
adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
XLITY Alison Lackey
v r�� Chief Administrative Law Judge
ti z
OF*OREG0�
A parry may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each party to the
proceedings as provided in OAR 860-001-0180(2).A party may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-435
ITEM NO. CA8
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
PUBLIC MEETING DATE: December 10, 2024
REGULAR CONSENT X EFFECTIVE DATE N/A
DATE: November 25, 2024
TO: Public Utility Commission
FROM: Bret Stevens
THROUGH: Caroline Moore, Scott Gibbens, and Michelle Scala SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UM 1753(9))
Reauthorization of deferred accounting related to the natural gas
decoupling mechanism.
STAFF RECOMMENDATION:
Staff recommends the Public Utility Commission of Oregon (Commission) approve
Avista Corporation dba Avista Utilities' (Avista or Company) application for
reauthorization to defer revenue differences associated with the decoupling mechanism
for the 12-month period beginning January 1, 2025.
DISCUSSION:
Issue
Whether the Commission should approve Avista's application for reauthorization to
defer revenue differences associated with the Company's decoupling mechanism for the
12-month period beginning January 1, 2025.
Applicable Rule or Law
Deferred accounting means recording a current expense or revenue associated with
current service in a balance sheet account, with Commission authorization for later
reflection in rates. OAR 860-027-0300(1)(b). ORS 757.259 provides the Commission
authority to authorize deferred accounting for later incorporation in rates. ORS 757.259
also explains the types of amounts eligible for deferred accounting. As relevant here,
APPENDIX A
Page I of 6

ORDER NO. 24-435
Docket No. UM 1753(9)
November 25, 2024
Page 2
amounts eligible for deferred accounting treatment with interest authorized by the
Commission include:
Identifiable utility expenses or revenues, the recovery or refund of which
the commission finds should be deferred in order to minimize the
frequency of rate changes or the fluctuation of rate levels or to match
appropriately the costs borne by and benefits received by ratepayers.
ORS 757.259(2)(e).
OAR 860-027-0300(3) lists five items that must be included in an application for
deferred accounting: (1) a description of the expense or revenue for which deferral is
requested, (2) the basis for the request, (3) the accounts proposed for recording the
amounts to be deferred, (4) an estimate of the amounts to be recorded in the deferred
account for the subsequent 12-month period, and (5) a copy of the notice of the
application for deferred accounting.
Amounts may be deferred up to twelve months. ORS 757.259(4). For deferred
amounts to be allowed in rates, the utility applies to amortize the deferred accounts.
ORS 757.259(5). The Commission may authorize the amortization in a rate proceeding,
subject to a prudence review. ORS 757.259(5); OAR 860-027-0300(9). An earnings
review may be conducted. With some exceptions, a utility's amortization of amounts
deferred under ORS 757.259(5) cannot exceed an amount equal to three percent of the
company's gross revenues from the preceding year. See ORS 757.259(6) and (7).
Analysis
Background
In 2016, the Commission approved a decoupling mechanism to "compare actual
decoupled revenues, by rate group, to the allowed decoupled revenues determined on a
per-customer basis, with any differences deferred for later rebate or credit." In re Avista
Corp. Request for a General Rate Revision (UG 288) and Application for Authorization
to Defer Expenses or Revenues Related to the Natural Gas Decoupling Mechanism
(UM 1753), Order No. 16-109 at 3 (Mar. 15, 2016). Since that 2016 order, Avista has
submitted annual applications in this docket to reauthorize deferral of the revenue or
expenses related to the Company's Natural Gas Decoupling Mechanism. Avista's last
application was approved on July 9, 2024, by Order No. 24-225.
The authorization for deferred accounting treatment as described above can be
authorized pursuant to ORS 757.259(2)(e). The Company's Natural Gas Decoupling
Mechanism provides for decoupled revenue above or below the base level established
APPENDIX A
Page 2 of 6

ORDER NO. 24-435
Docket No. UM 1753(9)
November 25, 2024
Page 3
in the General Rate Case (GRC) associated with concurrent effective rates will be
tracked over a 12-month period, and later rebated or surcharged to customers.
The Commission further approved a Revenue-Per-Customer decoupling mechanism
that compares actual decoupled revenues, by rate group, to allowed decoupled
revenues determined on a per-customer basis, with any differences deferred for later
rebate or surcharge. The current form of the decoupling mechanism became effective
March 1, 2016, and was modified, in part, in Avista's 2019 GRC, Docket No. UG 366, as
well as in UG 433 that established two residential decoupling targets, one for existing
and another for new customers.
Avista filed a revised version of their filing on November 7, 2024. This revised version
corrected a scrivener error in their October 29, 2024, filing.
Reason for Deferral
The decoupling mechanism is designed to weaken the relationship between customers'
energy usage and the utility's revenues and allows the Company to defer the difference
between gas revenues allowed for collection (as determined in the Company's Docket
No. UG 433 general rate case proceeding) and gas revenues actually collected from
customers.
This difference between estimated revenues based on estimates of use per customer
and the number of customers in the general rate case and revenues based on actual
values of these parameters results in a surcharge or rebate to customers through tariff
Schedule 475 in the following year.
Proposed Accounting
The Company would continue to record the deferrals in Account 186 — Miscellaneous
Deferred Debits.
The amount approved for recovery or rebate would then be transferred into a
Regulatory Asset account (FERC Account 182 — Other Regulatory Asset) or Regulatory
Liability account (FERC Account 254 — Other Regulatory Liability) for amortization.
On the income statement, the Company will record both the deferred revenue and the
amortization of the deferred revenue through Account 495 (Other Gas Revenue), in
separate sub-accounts.
Description of Expense
The amount subject to deferral for the Natural Gas Decoupling Mechanism will be
dependent upon the difference between the actual, after-the-fact, per customer therm
APPENDIX A
Page 3 of 6

ORDER NO. 24-435
Docket No. UM 1753(9)
November 25, 2024
Page 4
sales, compared with the per customer therm sales used in the rate case to establish
base rates.
This difference in therm sales can be caused by conservation, weather, and changes in
the economy. The amount of the rate increase resulting from the decoupling
adjustment will be subject to an annual incremental limit of three percent, i.e., the
annual increase in the surcharge cannot exceed three percent of billed revenues for
each rate group, each year, with unrecovered balances carried forward to future years
for recovery.
The incremental surcharge (percentage) increase is determined by subtracting the
annual revenue amount recovered by the present surcharge rate from deferred revenue
to be recovered through the proposed surcharge rate and dividing that net amount by
the total "normalized" revenue by Rate Group for the most recent January through
December period.
The normalized revenue is determined by multiplying the weather-corrected usage for
the period by the present billing rates in effect. If the incremental surcharge exceeds a
three percent rate increase, only a three percent increase is implemented and any
additional deferred revenue will remain in the deferred revenue account, and could be
recovered the following year, subject to the three percent limitation.
Current Deferral and Amortization Balances
As of June 30, 2024,' the outstanding balances for the Company's Natural Gas
Decoupling Mechanism balancing accounts are as follows.
See page 3 of the Q2 2024 Natural Gas Decoupling Mechanism Quarterly Report (Docket
No. RG 78 (34)).
APPENDIX A
Page 4 of 6

ORDER NO. 24-435
Docket No. UM 1753(9)
November 25, 2024
Page 5
Table 1. Decoupling Account Balances
Residential
2022 Residual Balance $139,542.32
2023 Residual Balance ($1,404,773.59)
2024 Deferral $2,549,061.41
Current Balance $1,283,830.14
Commercial
2022 Residual Balance $0
2023 Residual Balance ($2,253,200.39)
2024 Deferral ($160,236.34)
Current Balance ($2,813,436.73)
Total
Current Balance ($1,529,606.59)
Information Related to Future Amortization
• Earnings Review—An earnings test is not applied to this deferral as it is a
decoupling-related deferral.
• Prudence Review— Prior to amortization, a prudence review will be conducted.
The review should include verification of the accounting methodology used to
determine the final amortization balance.
• Sharing — This deferral is not subject to a sharing mechanism.
• Rate Spread/Design — The difference between actual and allowed decoupled
revenues should be recovered through rates on an equal cents-per-therm basis
for each rate group.
• Three Percent Test (ORS 757.259(6)) — The three percent test measures the
annual overall average effect on customer rates resulting from deferral
amortizations. The three percent test limits (exceptions at ORS 757.259(7) and
(8)) the aggregated deferral amortizations during a 12-month period to no more
than three percent of the utility's gross revenues for the preceding year.
Note: This deferral may be subject to the exception at ORS 757.259(7) that allows the
Commission to consider an overall average rate impact greater than that specified in
subsection (6) for natural gas commodity and pipeline transportation costs incurred by a
natural gas utility if the Commission finds that allowing a higher amortization rate is
reasonable under the circumstances.
APPENDIX A
Page 5 of 6

ORDER NO. 24-435
Docket No. UM 1753(9)
November 25, 2024
Page 6
Conclusion
Based on Staff's review of Avista's application, Staff concludes the proposed
reauthorization represents an appropriate use of deferred accounting under
ORS 757.259. Additionally, the Company's application meets the requirements related
to the establishment of the decoupling mechanism.
The Company has reviewed this memorandum and agrees with its contents.
PROPOSED COMMISSION MOTION:
Approve Avista's application for reauthorization to defer revenue differences associated
with the decoupling mechanism for the 12-month period beginning January 1, 2025.
AVA UM 1753(9)Decoupling Deferral.
APPENDIX A
Page 6 of 6

ORDER NO. 24-444
ENTERED Dec 10 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UM 2211
In the Matter of
PUBLIC UTILITY COMMISSION OF ORDER
OREGON,
Implementation of House Bill 2475.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its public meeting on December 10, 2024, the Public Utility Commission of Oregon
adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
Alison Lackey
Chief Administrative Law Judge
OF=OREGO�
A party may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each party to the
proceedings as provided in OAR 860-001-0180(2).A party may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-444
ITEM NO. RA2
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
PUBLIC MEETING DATE: December 10, 2024
REGULAR X CONSENT EFFECTIVE DATE N/A
DATE: December 2, 2024
TO: Public Utility Commission
FROM: Bret Farrell
THROUGH: Caroline Moore, Scott Gibbens, and Curtis Dlouhy SIGNED
SUBJECT: OREGON PUBLIC UTILITY COMMISSION STAFF:
(Docket No. UM 2211)
Request to open a rulemaking for energy burden data collection and
reporting.
STAFF RECOMMENDATION:
Staff recommends that the Oregon Public Utility Commission (Commission) approve
Staff's request to open a formal rulemaking on energy burden metric reporting and issue
a notice of proposed rulemaking to adopt permanent rules.
DISCUSSION:
Issue
Whether the Commission should open a formal rulemaking to adopt rules regarding the
reporting of energy-burden related metrics.
Applicable Rule or Law
Pursuant to ORS 756.060, the Commission "may adopt and amend reasonable and
proper rules and regulations relative to all statutes administered by the commission and
may adopt and publish reasonable and proper rules to govern proceedings and to
regulate the mode and manner of all investigations and hearings of public utilities and
telecommunications utilities and other parties before the commission."
APPENDIX A
Page 1 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 2
When adopting a new permanent rule, the Commission must follow the rulemaking
procedures set forth in the Oregon Administrative Procedures Act' and Commission
rules OAR 860-001-0160 and OAR 860-001-0210 through OAR 860-001-0240.
When opening a proposed permanent rulemaking, the Commission must give notice by
publishing the notice in the Secretary of State's Oregon Bulletin at least 21 days before
the effective date.2 The Commission must also provide a copy of the proposed rule to
"persons on the Commission's applicable rulemaking notification lists" at least 28 days
prior the effective date and applicable legislators as specified in ORS 183.335(15) at
least 49 days before the effective date.3 The notice must include the following:
(a) A statement summarizing the subject matter, purpose, and need for the
proposed rule;
(b) The last date for comment on the proposed rule;
(c) The date of or ability to request a hearing; and
(d) A statement of fiscal impact quantifying the economic effect of the proposed
rule.4
The notice must also include a caption identifying the subject matter, a citation to the
statutory authority to promulgate the rule, a statement of need, a list of principal
documents, a fiscal impact statement, a statement on racial equity, if an advisory
committee was appointed and, if not, why, and a request for public comment.5
Analysis
Background
The Commission opened Docket No. UM 2211 on December 14, 2021, to implement
the PUC's new authority to approve differential rates and programs under House Bill
2475. House Bill 2475 expands PUC ratemaking authority regarding low-income
customers and enables groups representing low-income customers and environmental
justice communities to receive intervenor funding assistance. The bill contains three
primary parts:
• Differential rates,
• Intervenor funding, and
• Programs to address energy burden.
O.R.S. § 183.310 to 183.355.
2 O.R.S. § 183.335(1); OAR 860-001-0210(1).
3 Id.
4 OAR 860-001-0210(2).
5 O.R.S. § 183.335(2).
APPENDIX A
Page 2 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 3
Effectively, HB 2475 expands ORS 757.230, giving the PUC new authority in the
classification or schedule of rates applicable to individual customers or groups of
customers to consider differential energy burdens on low-income customers and other
economic, social equity or environmental justice factors that affect affordability for
certain classes of utility customers.
Within Docket No. UM 2211, Staff has two separate workstreams that address different
aspects of the HB 2475 implementation process: the policy workstream and the data
workstream. The remainder of this report summarizes Staff's efforts within the data
workstream.
UM 2211 Data Workstream
The objective of the data workstream is twofold:
1. Develop a utility data collection strategy to enable Commission Staff to:
a. Monitor energy burden;
b. Facilitate the evaluation of rates, programs, and other utility activities;
c. Enhance data transparency and accessibility; and
d. Streamline and reduce duplicative reporting requirements.
2. Revise Division 21 Rule — OAR 860-021-0408 on disconnection reporting to
better align with the data strategy.
Staff engaged with both utility and advocate stakeholders in a working group process to
strategize and work through proposed data collection practices and rule revisions.
Through this process, participants were able to reach agreement on a great number of
technical, policy, and procedural changes, with only a handful of issues requiring further
resolution.
Participants
Discussion in the process has been robust, with individuals representing many
stakeholders. Parties involved include all six investor-owned electric and gas utilities
operating in Oregon; Idaho Power Company, PacifiCorp, Portland General Electric
Company (PGE), Avista Utilities, Cascade Natural Gas, and Northwest Natural (NWN);
collectively, the Joint Utilities (JU). Other groups include the Oregon Citizens' Utility
Board, NW Energy Coalition, Verde, Multnomah County Office of Sustainability,
Coalition of Communities of Color, and Energy Trust of Oregon.
Energy Burden Data
Energy burden data, as defined by Staff for the purposes of this workstream, refers to
metrics that measure the financial strain households face while paying for energy
services. This data is crucial for identifying populations most affected by energy
affordability challenges, particularly low-income households and communities facing
economic or social disparities. By collecting and analyzing energy burden data, Staff
can assess the effectiveness of utility programs, design equitable rate structures, and
address the needs of vulnerable customers. Additionally, energy burden data provides
APPENDIX A
Page 3 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 4
the foundation for evaluating the overall impact of energy policies and interventions on
all residential households.
In April 2024, Staff conducted a survey where we sought feedback from stakeholders on
what metrics would offer the greatest benefit in evaluating the energy-burden landscape
within Oregon. Based on survey feedback key energy-burden related metrics were
identified and categorized into three main categories: energy burden indicators,
customer information, and program performance.
Energy Burden Indicators Customer Information Program Performance
Arrearage Demographics Program Participation
Disconnections Income Program Budgets
Billing and Usage Housing Information Other program metrics (e.g.
energy savings)
These three main areas served as the basis for developing a more detailed and
comprehensive list of reporting requirements for utilities.
Landscape Analysis
On June 10, 2024, Staff presented the results of the data landscape analysis to
UM 2211 stakeholders. The objective of the data landscape analysis was to conduct a
comprehensive inventory of the existing data resources available to the Commission,
determine which relevant key energy burden metrics are currently being reported, and
identify gaps in the collection of these metrics along with any other outstanding issues
with data collection or reporting practices. The results of the analysis would then be
used to inform revised Division 21 rules which will consolidate and enhance energy
burden reporting requirements.
Staff sought to identify:
1. Whether the Commission was already collecting any of the key energy burden
metrics identified by stakeholders in survey feedback,
2. Whether it was feasible to collect this information from utilities, and
3. If the information would be better collected through external data sources.
Through the landscape analysis, Staff ultimately concluded that the energy burden
indicators such as arrears, disconnection, and billing and usage data were best
collected directly from utilities along with utility-specific program data, while customer
APPENDIX A
Page 4 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 5
information such as demographics, income, and housing information was best pursued
through third-party data sources, as utilities often do not have this information.
Existing Utility Data Channels
In addition to identifying specific energy burden metrics, Staff also examined through
which channels data was currently being collected by the Commission.
The Commission collects different types of data from the joint utilities through various
channels. Existing Commission channels for data collection include:
• Reporting Dockets (RE, RG, and RO dockets),
• Standard Data Requests (SDRs) for certain proceedings, such as general rate
cases,
• Discovery, conducted during docket review, and
• Informal requests, outside of a particular docket.
Reporting dockets and SDRs offer data at more consistent and reliable intervals while
data obtained through discovery and informal requests are often one-off requests from
Staff that provide only a static snapshot of information. Staff's focus for the landscape
analysis was primarily on reporting dockets, as these dockets provide data on an
ongoing basis and fulfill the objectives of the data strategy. Ongoing data reporting
requirements can establish a baseline with which to evaluate the impact of policy and
program interventions, such as bill discount programs.
Existing Data Resources — Reporting Dockets
Staff's analysis identified 295 open RE, RG, and RO dockets, of which only 43 are still
actively receiving reports. Among these, there are 15 universal reports, meaning that all
six utilities provide the same report at a consistent interval. Staff identified four reports
as providing relevant energy burden-related metrics:
1. Disconnection Report (Docket No. RO 12) — A quarterly report on residential
disconnections and reconnections, mandated by OAR 860-021-0408. These
reports contain detailed information on residential disconnections broken down at
the zip code level. The data in these reports has been crucial for analyzing
energy burden trends since its collection began in 2018.
2. FERC Form 1 and 2 (Docket Nos. RE 54, RE 68, RE 78, RG 33, RG 35, RG
37) —Annual reports from major electric and gas utilities, providing detailed
financial, operational, and usage data that inform regulatory oversight and rate-
setting. Utilities are required by OAR 860-027-0070 to provide these reports to
the Commission each year. These reports contain relevant residential usage data
but lack granularity and are only available annually, with a significant lag in
reporting.
3. Income-Qualified Bill Discount Reports (Docket Nos. RE 195, RE 197, RG
100, RG 101, RG 102) — Quarterly reports provided by utilities on various
APPENDIX A
Page 5 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 6
aspects of their IQBD programs, such as levels of participation, program costs,
and billing data. Staff has required this reporting from each utility upon the
implementation of their programs but specific metrics being provided vary from
utility to utility. The data being provided in these reports is critical for evaluating
the success of these programs and understanding how low-income customers'
energy burden is evolving.
4. Energy Trust of Oregon (ETO) Metrics (Docket Nos. RE 138, RE 139) —An
annual report provided by Portland General Electric (PGE) and PacifiCorp that
summarizes communication and outreach data related to energy efficiency goals.
Issued Identified from Landscape Analysis
The landscape analysis identified three key issues with the Commission's current data
collection practices.
First, there are significant gaps between what is currently being reported to the
Commission by the joint utilities and what was identified by Staff and stakeholders as
key energy burden related metrics. Utilities are not reporting on arrearages, customer
bills, or usage data at consistent and useful intervals.
Second, there is a lack of standardization in the information that is currently being
provided to the Commission by the utilities. Different utilities collect and report data
using different methodologies and formats, making it difficult to compare key metrics.
This variability complicates Staff's ability to draw accurate and actionable conclusions
from the data.
Lastly, data was dispersed across various dockets, rather than centralized in a single
location. This decentralization makes it more difficult for Staff and stakeholders to
access comprehensive information efficiently, affecting both transparency and the ability
to effectively monitor utility metrics.
Summary of Proposed Rule Changes
Attachment A contains Staff's proposed rule language changes for OAR 860-021-0408.
Throughout the last year Staff has developed and refined this draft rule language
following stakeholder feedback with the following principles from Staff's data strategy in
mind:
1. There is a gap between the data that utilities currently provide to the Commission
and the data that Staff and stakeholders have identified as critical in evaluating
the energy burden landscape within Oregon. Any updates to rule language
should include an expanded list of metrics that seek to close this gap.
2. Standardized definitions and methodologies for metrics are necessary to ensure
equal comparison of data across utilities. Collaboration across utilities is needed
to better align definitions.
APPENDIX A
Page 6 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 7
3. Important data being provided to the Commission is currently scattered across
various dockets which can make accessibility and transparency more difficult.
Updated rule language should consolidate reporting into a single docket to allow
for easier access.
4. Existing Commission data requirements have redundancies. Updated rule
language should consolidate reporting requirements to eliminate duplicative
reporting efforts from utilities.
Staff's current proposal contains the following key features:
1. An expanded list of reporting requirements that address the gaps identified by
Staff and stakeholders. These new reporting requirements include areas such as
arrearages, usage, and billing.
2. Expanded definitions that align metrics across utilities
3. The consolidation of all key energy burden metrics into a single reporting docket.
4. The elimination of duplicative reporting requirements for utilities.
Expanded Reporting Requirements
Staff's draft rule language builds upon existing disconnection reporting mandates in
OAR 860-021-0408, significantly broadening the scope of data utilities must report.
These expanded reporting requirements will enable Staff to conduct a more
comprehensive and granular analysis of energy burden across each utility's Oregon
service territory. Staff believes that by capturing detailed data on arrearages,
disconnections, usage, billing and program participation, the Commission will be able to
gain deeper insights into the financial challenges faced by residential customers,
particularly low-income households. Staff believes this data will serve a critical function
in evaluating necessary policy interventions as well the performance of utility programs.
In addition to these new quarterly reporting requirements for utilities Staff recommends
an annual reporting requirement which includes metrics for high-usage customers
participating in a utility bill discount program. Staff defines high-usage customers as
customers a residential customer participating in a utility-administered bill discount
program whose energy consumption places them in the 90th percentile or above of all
other bill discount program participants.
Arrearages (Quarterly)
• Total Number of Residential Customers with Arrearage Balances segmented into
three groups based on the age of the arrearage including: 31-60 days, 61-90
days, and 91 or more days past the bill issuance date. Each residential customer
should only be counted in one group, based on their oldest arrearage balance;
APPENDIX A
Page 7 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 8
• Total residential arrearage balances segmented into three groups based on the
age of the arrearage, including: 31-60 days, 61-90 days, and 91 or more days
past the bill issuance date;
• Total number of customers enrolled in Time Payment Arrangements (TPA) or
other extended payment plans. This includes all residential customers who are
actively enrolled in a Time Payment Arrangement or any other extended payment
plan offered by the utility as of the reporting period.
Disconnections (Quarterly)
• Total number of active residential accounts;
• Total number of service disconnections for non-payment;
• The total number of 15-day disconnection notices sent to residential customers;
• Percentage of accounts with service disconnections for non-payment. This
includes the proportion of active residential accounts that experienced a service
disconnection for non-payment during the reporting period. This percentage is
determined by dividing the total number of service disconnections for non-
payment by the total number of active residential accounts and multiplying by
100;
• Total number of bill discount recipient service disconnections for non-payment;
• Total number of energy assistance recipient service disconnections for non-
payment;
• Total number of service disconnections for non-payment on medical certificate
holder accounts;
• Number of service reconnections following a service disconnection for non-
payment on the same day or next calendar day following disconnection;
• Number of service reconnections following a service disconnection for non-
payment that occur more than one day and within 7 calendar days following
disconnection;
• Number of days on which the energy utility was required to impose a moratorium
on service disconnection for severe weather as required by OAR 860-021-0407
(Severe Weather Moratorium on Involuntary Disconnection of Residential Electric
or Gas Utility Service).
Usage and Billing (Quarterly)
• Total usage by all of the utility's residential customers during the reporting period;
• Average residential usage during the reporting period. This data point should be
calculated by dividing the "Total Residential Usage" by the total number of
residential customers billed during the same reporting period;
• Average residential bill during the reporting period. This data point should be
calculated by dividing the total amount billed to all residential customers by the
total number of residential customers billed during the same reporting period.
APPENDIX A
Page 8 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 9
Bill Discount Program (Quarterly)
• Total number of residential customers which received a bill discount, by discount
tier;
• Total dollars provided to bill discount program participants, by discount tier;
• Total program costs divided into two distinct categories: incremental
administrative costs and applied credits;
• Total number of new enrollments;
• Total number of disenrollments;
• Average program participant usage categorized by bill discount tier;
• Pre-discount average bill discount program participant bill, categorized by bill
discount tier;
• Post-discount average bill discount program participant bill, categorized by bill
discount by tier;
• The number of bill discount program participants with an arrearage balance
segmented into three groups based on the age of the arrearage: 31-60 days, 61-
90 days, and 91 or more days past the bill issuance date. Each program
participant should only be counted in one group, based on their oldest arrearage
balance.; and
• Total arrears balance of program participants segmented into three groups based
on the age of the arrearage: 31-60 days, 61-90 days, and 91 or more days past
the bill issuance date.
High Usage (Annually)
• The number of high-usage customers;
• Average monthly usage of high-usage customers;
• Average monthly bill of high-usage customers;
• Number of high-usage customers with an arrearage balance at the end of each
month, segmented into three groups based on the age of the arrearage:
31-60 days, 61-90 days, and 91+ days past the bill issuance date. Each
residential customer should only be counted in one group, based on their oldest
arrearage balance.
• Total arrears balance of high-usage customers at the end of each month,
segmented into three groups based on the age of the arrearage: 31-60 days,
61-90 days, and 91+ days past the bill issuance date; and
• Total number of high-usage customers who experienced a service disconnection
for non-payment.
Standardization
A significant barrier to effective analysis of the data provided by utilities has been the
lack of consistent definitions and methodologies across utilities. Discrepancies in how
utilities report key metrics—such as arrearages, disconnections, and bill discount
participation—have hindered the Commission's ability to compare data and identify
APPENDIX A
Page 9 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 10
trends. To address this, Staff's proposed rule language provides detailed definitions for
all reported metrics to ensure equal comparison.
In addition to definitions, the proposal standardizes data collection and calculation
methodologies. Metrics such as the percentage of accounts disconnected for non-
payment and average residential usage will follow prescribed formulas to ensure
consistency. Staff worked closely with stakeholders and utilities during workshops to
identify the most effective approaches for achieving uniformity while acknowledging
operational differences across utilities. This collaboration ensures that the standardized
framework is both practical and equitable, fostering trust in the reported data and
enabling the Commission to draw meaningful comparisons. There are outstanding
technical items which require further discussion among stakeholder groups to ensure
items are standardized across utilities. Staff addresses these ongoing implementation
issues in a section below.
Centralized Reporting, Transparency, and Accessibility
Currently, data critical to understanding energy burden and utility performance is
scattered across multiple dockets, creating barriers to access and reducing
transparency for stakeholders. The proposed rule language addresses this challenge by
consolidating all key energy burden reporting into a single docket. This centralized
docket will act as a comprehensive repository for all quarterly and annual reports,
covering arrearages, disconnections, usage, billing, and program participation metrics.
By bringing all reporting into one location, Staff aims to enhance accessibility,
streamline data analysis, and promote greater transparency.
Centralization also benefits stakeholders who rely on this data for advocacy and
research. A single docket eliminates the need to navigate multiple dockets to compile a
complete picture of utility performance, saving time and resources. Furthermore, the
updated rule language will improve transparency by ensuring that all stakeholders have
equal access to the same comprehensive dataset. This centralized approach also
simplifies the reporting process for utilities.
Remove Duplicative Reporting
Existing reporting requirements often include overlapping or duplicative metrics, placing
unnecessary administrative burdens on utilities and complicating data analysis for Staff
and stakeholders. The proposed rule revisions address this issue by consolidating all
reporting requirements into a streamlined framework that eliminates redundancy without
sacrificing data quality or comprehensiveness. Metrics that are currently scattered
across various reporting mandates will be integrated into a single, cohesive structure
within a single docket. This consolidation reflects Staff's commitment to balancing the
need for robust data with the practical realities of utility operations.
APPENDIX A
Page 10 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 11
Additional Changes
Staff's proposed draft rule language also includes several procedural updates aimed at
increasing accessibility and consistency.
Utilities will now have 45 days after the end of each quarter to submit their quarterly
reports, an increase from the current 20-day deadline. This change is in response to
utility feedback on the operational complexity of gathering large amounts of data and
will allow for more time for utilities to accurately gather information.
Staff's proposed draft rule language requires that utilities must submit their quarterly
reports in both Excel and PDF formats. This requirement allows for easier and more
streamlined analysis for both Staff and stakeholders.
The reporting quarters have been restricted to align with traditional calendar year
quarters (i.e. Q1: January — March, Q2: April — June, Q3: July — September, Q4:
October— December). This adjustment replaces the existing rule's slightly irregular
quarter structure, reducing potential confusion for utilities and stakeholders.
To address inaccuracies, Staff's proposed draft rule language requires utilities to submit
corrected reports within 30 days if errors or omissions are detected after the initial
submission. This provision ensures the integrity of the Commission's data and hold
utilities accountable for providing accurate information.
Staff proposes that the effective date for reporting to begin be April 1, 2025. The utilities
shall provide Staff with both the Q1 2025 report and the Q2 2025 report on the due date
of the Q2 2025 report (August 14, 2025). Individual quarterly reporting will begin
thereafter.
Ongoing Implementation Discussions
As the rule language is formalized with the Commission, Staff will continue to work with
stakeholders on key implementation questions surrounding the reporting requirements.
Resolving these questions is unlikely to impact the rule language but ensure that the
reporting framework in the rules is implemented in the most useful and efficient manner.
First, is the inconsistent treatment of Time Payment Arrangements in arrearage
reporting. Currently, three of the six utilities include customers with TPAs in their total
arrearage calculations, while the remaining three do not. This issue complicates Staff's
ability to accurately assess arrearage trends and compare data equally across all
utilities. Staff is working to establish a uniform approach that ensures the comparability
and consistency of arrearage data.
Second, there are discrepancies in the timelines utilities use to report arrearages. Five
of the six utilities currently report arrearages based on the bill issuance date, rather than
the due date. This creates inconsistency in arrearage data, as the number of days a bill
APPENDIX A
Page 11 of 19

Docket No. UM 2211
ORDER NO. 24-444
December 2, 2024
Page 12
is "past due" at 30 days past the issuance date may vary between utilities. Staff is
working toward identifying a uniform approach to enable accurate comparison and
tracking of customer payment behavior across utilities.
Lastly, to improve data consistency and streamline reporting, Staff is working on the
creation of an identical, standardized form that all utilities will be required to complete
and file. This form will provide predefined fields and formats for each metrics, ensuring
that all utilities report data in a uniform manner. Stakeholder input will be critical in
finalizing the form's design and ensuring that it is practical for utilities to complete.
To address these issues, Staff plans to hold technical workshops with utilities to develop
solutions that will produce standardized and comparable data while still working within
the constraints of each utility's internal data systems.
Conclusion
Staff appreciates all parties' thoughtful participation in a collaborative process to identify
draft rules that reflect key data strategy principles. Staff believes that stakeholders have
made substantial progress and identified consensus solutions for the overarching
framework of data collection practices for the Commission. Staff recommends that the
Commission accept Staff's proposed data collection rules and move UM 2211 to the
formal stage.
PROPOSED COMMISSION MOTION:
Approve Staff's request to open a formal rulemaking on energy burden metric reporting
and issue a notice of proposed rulemaking to adopt permanent rules.
RA2-UM 2211
APPENDIX A
Page 12 of 19

ORDER NO. 24-444
Attachment A
OAR 860-021-0408
Arrearage and Disconnection Reporting Rule
Draft Revision
(1) As used in this rule:
(a) "Administrative costs"means all incremental expenses related to the management
and operation of the bill discount program.This includes,but is not limited to,
incremental costs for program design,staff salaries,data processing,customer
outreach,eligibility verification,compliance,reporting,and any other overhead or
indirect costs necessary to administer the program.
(b) "Applied credits"means the aggregate dollar value of discounts applied to the utility
bills of residential customers that participate in the utility's bill discount program.
(c) "Arrearage balance"means any amount of money that a customer owes to the utility
company for services provided which remain unpaid past the due date.
(d) "Average bill of high-usage customers"means the average monthly dollar amount the
utility billed all high-usage customers.
(e) "Average bill discount program participant usage"means the average monthly usage of
residential customers enrolled in a utility-administered bill discount program.
(f) "Average residential bill"means the average monthly bill for residential utility services
within a utility's Oregon service territory.
(g) "Average residential usage"means the average monthly amount of energy billed per
residential meter within a utility's Oregon service territory.
(h) "Average usage of high use customers"means the average monthly energy
consumption of all customers classified as high usage.
(i) "Disenrollments"means residential customers who were enrolled in a utility's bill
discount program as of the previous reporting period but are no longer participating as
of current the reporting period.This includes customers who were removed from the
program due to ineligibility or non-compliance
(j) "Energy assistance recipient"means a residential customer who has received bill payment
assistance with an energy bill from any federal,state,customer funded bill payment Deleted:ratepayer
assistance fund or program at least once within the past 12 months. F Deleted.,or utility-supported
APPENDIX A
Page 13 of 19

ORDER NO. 24-444
Docket No. UM 2211
December 2, 2024
Page 14
(k) "High-usage customer"means a residential customer participating in a utility-
administered bill discount program whose energy consumption places them in the 90"
percentile or above of all other bill discount program participants within the utility's
service area.
(l) "New enrollments"means residential customers enrolled in a utility's bill discount
program for the first time within the current calendar year.
(m)"Pre-discount average bill discount program participant bill"means the average
monthly utility bill amount for bill discount program participants before the application
of any bill discounts.
(n) "Post-discount average bill discount program participant bill"means the average
monthly utility bill amount for bill discount program participants after the application
of their respective bill discount.
(o) "Residential customer"means any individual or household that receives utility
services for personal,non-commercial use.This includes all customers being served
on a utility's residential service tariff.
(p) "Service disconnection for non-payment"means instances where utility service to a
residential account was terminated due to the customer's failure to pay their utility
bill.
(q) "15-day disconnection notice"means any written or electronic notification issued by a
utility to a customer informing them of the utility's intent to disconnect service due to
non-payment.The notice must be delivered at least 15 calendar days prior to the
scheduled disconnection date.
(r) "Total arrears balance of high-usage customers"means the cumulative dollar amount
of overdue balances for all high-usage customers in arrears during the reporting
period.
(s) "Total arrears balance of bill discount program participants"means the total dollar
amount of outstanding balances owed by residential customers enrolled in a utility-
administered bill discount program on their utility bills.
APPENDIX A
Page 14 of 19

ORDER NO. 24-444
Docket No. UM 2211
December 2, 2024
Page 15
(t) "Total dollars provided to bill discount program participants"means the aggregate
dollar value of discounts applied to the utility bills of residential customers who
participate in the utility's bill discount program.
(u) "Total bill discount program costs"means the total expenditure incurred by a utility in
administering its bill discount program for low-income residential customers.
(v) "Total residential arrearage balances"means the total dollar amount of outstanding
balances owed by residential customers on their utility bills.
(w)"Total residential usage"means the total amount of energy billed for all residential
customers within a utility's Oregon service territory.
(x) "31-60 days in arrears"means a customer who has an arrearage balance that has been
unpaid for a period of between 31 and 60 days from the original bill issuance date.
Deleted:"Companywide"means the geographic area
served by a particular energy utility within the state of
(y) "61-90 days in arrears"means A customer who has an arrearage balance that has been Oregon.
unpaid for a period of between 61 and 90 days from the original bill issuance date.
Deleted:<#>"Local service area"means a smaller
geographic unitwithin an energy utility's companywide
service area,such as zip code,city,county,or other
(z) "91+days in arrears"means a customer who has an arrearage balance that has been similar unit.9
unpaid for a period greater than 90 days from the original bill issuance date. Deleted:(2)Each energy utility must file a quarterly
report with the Commission detailing the number of
residential disconnections for non-payment and
(aa) • subsequent reconnections as prescribed in this rule.An
electronic report must be filed in a text-searchable
Microsoft Word,Microsoft Excel,or.pdf(Adobe Acrobat)
• format.
• Deleted:I
(2) Each energy utility must submit electronic quarterly reports containing the data Deleted:February
described in section(4)of this rule.Electronic reports must be submitted in text-searchable Deleted: April30
excel and PDF formats.Utilities shall include zip-code level data within the accompanying Deleted:May
excel files.ja)For quarterly reporting purposes,the following four time periods apply:January1 to
Deleted:July 31
March 31v April•1 to June 30v July1 to September 30v and October•1 to December•31.
Deleted:August
(b)Each energy utility must file its initial quarterly report following the first full quarter after the Deleted:October 31
effective date of this rule,unless an alternative initial reporting date is set for the utility by Deleted:November
Commission Staff.
• Deleted:January
(c)The energy utility must file a quarterly report as required under this rule within 45•days of the Deleted:the Commission's Consumer Services Section.
end of each reporting period. Deleted.20
APPENDIX A
Page 15 of 19

ORDER NO. 24-444
Docket No. UM 2211
December 2, 2024
Page 16
(3)If errors or omissions are discovered after a report has been submitted,utilities must
submit a revised report within 30 days of identifying the discrepancy.
Deleted:(4)The quarterly report must provide the
following information for each month within the quarter
(4)The quarterly report must provide the following data points for each month within the for an energy utility's residential accounts:
quarter;(a)On an Oregon basis,the: Deleted:11
(A) Total Number of Residential Customers with Arrearage Balances segmented into three Deleted:companywide
groups based on the age of the arrearage including:31-60 days,61-90 days,and 91 or
more days past the bill issuance date.Each residential customer should only be
counted in one group,based on their oldest arrearage balance;
(B) Total residential arrearage balances segmented into three groups based on the age of
the arrearage,including:31-60 days,61-90 days,and 91or more days past the bill
issuance date;
(C)Total number of customers enrolled in Time Payment Arrangements(TPA)or other
extended payment plans.This includes all residential customers who are actively
enrolled in a Time Payment Arrangement or any other extended payment plan offered
by the utility as of the reporting period;
(D) Number of active residential accounts;
(E) Number of service disconnections for non-payment;
(F) The total number of 15-ay disconnection notices sent to residential customers;
(G) Percentage of accounts with service disconnections for non-payment.This includes the
proportion of active residential accounts that experienced a service disconnection for
non-payment duringthe reporting period.This percentage is determined by dividing
the total number of service disconnections for non-payment by the total number of
active residential accounts and multiplying by 100;
(H)Total number of bill discount recipient service disconnections for non-payment;
(1) Total number of service disconnections for non-payment on energy assistance recipient
accounts;
(J) Total number of service disconnections for non-payment on medical certificate holder
accounts;
APPENDIX A
Page 16 of 19

ORDER NO. 24-444
Docket No. UM 2211
December 2, 2024
Page 17
1 Deleted:<#>Number of service disconnections
(K) Number of service reconnections following a disconnection for non-payment on the same reported under both paragraph(D)and paragraph(E)
day or next calendar day following disconnection(Days 0-1);and above,i.e.,disconnections for non-payment on
medical certificate holder accounts that are also
energy assistance recipient accounts;¶
(L) Number of service reconnections following a disconnection for non-payment that occur
more than one day and within 7 calendar days following disconnection(Days 2-7).
(M)Number of days on which the energy utility was required to impose a moratorium on service
disconnection for severe weather per OAR 860-021-0407(Severe Weather Moratorium on
Involuntary Disconnection of Residential Electric or Gas Utility Service).
(N)Total residential usage during the reporting period;
(0)Average residential usage during the reporting period.This data point should be
calculated by dividing the"Total Residential Usage"by the total number of residential
customers billed during the same reporting period;
(P) Average residential bill during the reporting period.This data point should be
calculated by dividing the total amount billed to all residential customers by the total
number of residential customers billed during the same reporting period;
(Q)Total number of residential customers that received a bill discount,by discount tier;
(R) Total dollars provided to bill discount program participants,by discount tier;
(S) Total program costs divided into two distinct categories:incremental administrative
costs and applied credits;
(T) Total number of new enrollments;
(U) Total number of disenrollments;
(V) Average program participant usage categorized by bill discount tier;
(W)Pre-discount average bill discount program participant bill,categorized by bill discount
tier;
(X) Post-discount average bill discount program participant bill,categorized by bill
discount by tier;
APPENDIX A
Page 17 of 19

ORDER NO. 24-444
Docket No. UM 2211
December 2, 2024
Page 18
(Y) The number of bill discount program participants with an arrearage balance
segmented into three groups based on the age of the arrearage:31-60 days,61-90 days,
and 91 or more days past the bill issuance date.Each program participant should only
be counted in one group,based on their oldest arrearage balance.;and
(Z) Total arrears balance of program participants segmented into three groups based on
the age of the arrearage:31-60 days,61-90 days,and 91 or more days past the bill
issuance date.
(1) For annual reporting purposes,the following time period applies:January 1 to
December 31.
(2) The energy utility must file a quarterly report as required under this rule within 60 days
of the end of each reporting period.
(3) Each utility,in addition to the quarterly reporting requirements,shall submit an annual
supplement report which provides the following information for each month within the
year:
(a) The number of high-usage customers;
(b) Average monthly usage of high-usage customers;
(c) Average monthly bill of high-usage customers;
(d) Number of high-usage customers with an arrearage balance at the end of each month,
segmented into three groups based on the age of the arrearage:31-60 days,61-90 days,
and 91+days past the bill issuance date.Each residential customer should only be
counted in one group,based on their oldest arrearage balance;
(a) Total arrears balance of high-usage customers at the end of each month,segmented
into three groups based on the age of the arrearage:31-60 days,61-90 days,and 91+
days past the bill issuance date;and
(f) Total number of high-usage customers who experienced a service disconnection for
non-payment.
(4) Each utility must provide the information in 4A-M,O-R,and T-X by zip code.
APPENDIX A
Page 18 of 19

ORDER NO. 24-444
Docket No. UM 2211
December 2, 2024
Page 19
(5) The Commission will review the reporting metrics outlined in this rule every two years.
In doing so,the Commission may engage stakeholders to ensure the relevance of data
for addressing energy burden.
— Deleted:(b)For each local service area within the
companywide area used for reporting:¶
(A)Number of active residential accounts;¶
(B)Number of service disconnections for non-payment;¶
(C)Number of service disconnections for non-payment
on energy assistance recipient accounts;ll
(D)Number of service disconnections for non-payment
on emergency medical certificate holder accounts;¶
(E)Number of service disconnections reported under
both paragraph(C)and paragraph(D)above,i.e.,
disconnections for non-payment on medical certificate
holder accounts that are also energy assistance recipient
accounts;and¶
(F)Number of days on which the energy utilitywas
required to impose a moratorium on service
disconnection for severe weather per OAR 860-021-0407
(Severe Weather Moratorium on Involuntary
Disconnection of Residential Electric or Gas Utility
Service).¶
(c)Zip codes must be used to identify a local service area
unless a different unit is pre-approved by the
Commission's Consumer Services Section for a utility's
use in its reporting under this rule.¶
(4)Upon request of the Commission's Consumer
Services Section,when made within one year of the date
a quarterly report is filed with the Commission,the
energy utility must provide a breakdown by zip code of
the of service disconnection data reported under section
(3)of this rule.
APPENDIX A
Page 19 of 19

ORDER NO. 24-446
ENTERED Dec 19 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
AR 667
In the Matter of
Rulemaking to Adopt Temporary Rules ORDER
Related to Protections Against
Disconnections.
DISPOSITION: TEMPORARY RULES ADOPTED
This order memorializes our decision, made and effective at our December 17, 2024 Special
Public Meeting, to adopt Staffs recommendation in this matter as modified below. The Staff
Report with the recommendation is attached as Appendix A.
We adopt the proposed temporary rule amendments to OAR 860-021-0407,
OAR 860-021-0330, and additional new temporary rules, OAR 860-021-0630,
OAR 860-021-0640, and OAR 860-021-0650, related to residential customer protections
against disconnection in Attachment A, effective upon filing with the Secretary of State. We
adopt the proposed temporary rules with modifications to provide that the date-based
moratorium will be effective on the effective date of the temporary rules and will extend
through March 31.
We adopt Staffs recommendation and direct that OAR 860-021-0330(4)be implemented via
the lowest cost method for each utility,balancing the savings of waiving fees for fewer
program participants against the administrative cost of restricting the waiver to the lowest
tier.
We adopt Staff s recommendation to direct the utilities to provide a report reflecting the
impacts of these temporary customer protections, which may include the data specified in the
Staff Report. Our intent in modifying Staffs recommendation is to provide Staff with space
to work with the utilities on adjustments to the data needed and available to evaluate the cost
impact of these temporary rules.

ORDER NO. 24-446
We do not adopt the recommendation set forth in the fourth paragraph of Staff s proposed
motions but emphasize that we recognize the value of closing data gaps between expiration
of COVID reporting and initiation of energy burden metrics reporting. Our intention is for
docket AR 668 to address these backward-looking data requirements.
Made, entered, and effective Dec 19 2024
Megan W.Decker Letha Tawney
Chair Commissioner
Les Perkins
�XG`TY °c Commissioner
F; 1�
O�+OREGO�
A person may petition the Public Utility Commission of Oregon for the amendment or repeal of
a rule under ORS 183.390. A person may petition the Oregon Court of Appeals to determine the
validity of a rule under ORS 183.400.
2

ORDER NO. 24-446
ITEM NO. RA1
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
PUBLIC MEETING DATE: December 17, 2024
Upon filing with
REGULAR X CONSENT EFFECTIVE DATE Sec. of State
DATE: December 12, 2024
TO: Public Utility Commission
FROM: Michelle Scala and Kate Ayres
THROUGH: Caroline Moore and Scott Gibbens
SUBJECT: OREGON PUBLIC UTILITY COMMISSION STAFF:
(Docket No. AR 667)
Temporary Rules Related to Protections Against Disconnection
Public Hearing and Commissioner Work Session
Request to adopt temporary rules related to protections against
disconnection.
STAFF RECOMMENDATION:
Staff recommends that the Oregon Public Utility Commission adopt the proposed
temporary rule amendments to OAR 860-021-0407, OAR 860-021-0330, and additional
new temporary rules, OAR 860-021-0630 through OAR 860-021-0650, related to
residential customer protections against disconnection in Attachment A, effective upon
filing with the Secretary of State.
Staff recommends that the Commission direct Portland General Electric and Pacific
Power to implement OAR 860-021-0330(4) with administration of this measure to be
implemented via the lowest cost method for each utility.
Staff also recommends that the Commission direct Portland General Electric, Pacific
Power, Idaho Power Company, Northwest Natural Gas Company, Cascade Natural Gas
Corporations, and Avista Corporation, collectively referred to as the "Utilities", to provide
a report reflecting the impacts of these temporary customer protections. Staff
recommends that the Utilities file a report containing the data outlined in this Staff report
on July 15, 2025.
Lastly, Staff recommends that the Commission direct the Utilities to report the monthly
arrears metrics outlined in the Energy Burden Metrics Report (EMBR) rules from
January 1, 2024 through December 31, 2024 with the submission of its EMBR report on
APPENDIX A
Page 1 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 2
July 15, 2025, or at the time filing its next general rate revision, whichever is sooner.
DISCUSSION:
Issue
Whether the Oregon Public Utility Commission (Commission) should adopt Staff's
proposed temporary rule amendments related to residential customer protections
against disconnection in Attachment A, effective upon filing with the Secretary of State.
Whether the Commission should adopt Staff's recommendation to direct the Utilities to
provide a report at the end of the temporary rules period containing monthly ZIP-code-
level data reflecting impacts of these temporary rules.
Whether the Commission should direct the Utilities to report historical monthly arrears
metrics for 2024 as outlined in the draft EMBR rules.
Applicable Rule or Law
Pursuant to ORS 756.060, the Commission "may adopt and amend reasonable and
proper rules and regulations relative to all statutes administered by the commission..."
The Oregon Administrative Procedures Act sets forth the process for adoption and
amendment of administrative rules and allows for the adoption or amendment of
temporary rules for a period of up to 180 days in appropriate circumstances. Under
ORS 183.335(5), an agency may adopt, amend, or suspend a rule without the notice or
hearing required for a permanent rulemaking if the agency prepares a written statement
that includes:
(a) A statement of its findings that its failure to act promptly will result in
serious prejudice to the public interest or the interest of the parties
concerned and the specific reasons for its findings of prejudice;
(b) A citation of the statutory or other legal authority relied upon and
bearing upon the promulgation of the rule;
(c) A statement of the need for the rule and a statement of how the rule is
intended to meet the need; and
(d) A list of the principal documents, reports or studies, if any, prepared by
or relied upon by the agency in considering the need for and in preparing
the rule, and a statement of the location at which those documents are
available for public inspection.
Pursuant to ORS 756.040, the Commission has the power and duty to ensure safe and
APPENDIX A
Page 2 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 3
adequate service at just and reasonable rates, and is vested with the power and
jurisdiction to supervise and regulate every public utility and telecommunications utility
in Oregon, and to do all things necessary and convenient in the exercise of such power
and jurisdiction.
Pursuant to ORS 757.035, the Commission has the authority to adopt and enforce
safety rules and regulations "...and to require the performance of any other act which
seems to the commission necessary or proper for the protection of the health or safety
of all employees, customers or the public."
ORS 757.230, as amended by HB 2475, provides the Commission authority to take
certain considerations into account when determining a comprehensive classification of
service for each public utility; including, inter alia, differential energy burdens on
low-income customers and other economic, social equity or environmental justice
factors that affect affordability for certain classes of utility customers.'
ORS 757.695, codifying HB 2475's Section (7)(1), provides that the Commission may
address the mitigation of energy burdens through bill reduction measures or programs
that may include, but need not be limited to, demand response or weatherization.
OAR 860-021 outlines the rules governing customer rights and utility responsibilities
related to service disconnections, reconnections, billing, and customer protections in
Oregon. It specifies conditions under which utilities may disconnect service for
nonpayment, establishes timelines and notice requirements, and sets standards for
reconnection, including fee limitations and exceptions. The rule also includes provisions
for severe weather protections.
Analysis
Procedural Background
The current proceeding is the culmination of Staff's arrearage and disconnection
workstream in Phase two of Staff's HB 2475 Implementation docket, UM 2211.
Following concerns with the level of arrearages and disconnections observed in 2024,
Staff sought to propose interim protections that would mitigate customer harms
associated with arrearages and disconnections prior to the 2024-2025 heating season.
Staff utilized feedback collected from stakeholder engagement provided in workshops
and filed comments to refine a set of recommendations that was brought forward at the
The Energy Affordability Act (HB 2475—2021 Regular Session) amended ORS 756.610, ORS 757.230,
and ORS 757.072 and enacted new provisions to address equity in rate setting and participating in PUC
proceedings, effective January 1, 2022. OR Laws 2021 Ch. 90.
APPENDIX A
Page 3 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 4
November 26, 2024, public meeting for Commission decision. In the meeting, the
Commission decided to take action on Staff's recommendation in the form of temporary
rules. In addition to this procedural guidance, the Commission engaged Staff and
stakeholders in significant discussion to refine Staff's recommendations based on the
feasibility of near-term implementation, prioritizing impact and urgency, and the ability to
defer certain proposals to a later permanent rulemaking. The Commission directed Staff
in the public meeting, and memorialized in a Memorandum filed on November 27, 2024,
to bring temporary rules to a near-term public meeting to address the challenges
identified by Staff with the emergency around disconnections for the upcoming winter
heating season for vulnerable populations.
Justification for Temporary Rules
Staff has observed increases in both arrears and disconnections in response to both
seasonal usage spikes and immediately following a rate increase. It is widely known
and evidenced that the health and financial consequence of an energy shut off can be
significant. Research has shown energy insecurity is linked to poor respiratory health,
poor sleep, food insecurity, and adverse mental health outcomes. The economic
impacts of a customer's inability to pay and resulting disconnection can also lead to
evictions, foreclosures, low credit scores, the inability to establish future service
accounts, and children being removed from their parent's care. Further, exposure to
extreme heat or extreme cold, coupled with an underlying vulnerability such as health
conditions, age, or poor housing stock can lead to substantial numbers of deaths during
extreme weather.
Noting this great potential for harm, Staff finds it imperative that temporary rules be
adopted by the Commission in order to minimize exposure to the most unsafe
disconnections and mitigate the cascading effects of energy insecurity on vulnerable
households. Staff has found ample reason for concern and action related to residential
disconnection including through a review of available data in RO 12, the energy utility
disconnection reports, and within PacifiCorp's (UE 433) and PGE's (UE 435) recently
filed rate cases. Altogether, these realities and records have given evidence to
emergency levels of arrears and disconnections on a trajectory toward even greater
crisis and human harms in the colder winter temperatures if not expeditiously mitigated
through the adoption of greater protections for utility customers.
APPENDIX A
Page 4 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 5
Table 1.The Total Number of Residential Disconnections for Non-Payment
Company 2018i 2019 2020ii 2021 2022 2023 2024"'
PGE 574iv 28,006 4,637 2,174 21,299 27,407 32,289
PacifiCorp 6,594 19,368 4,453 1,267" 5,355 7,935 20,662
Idaho 333 852 146 146 346 355 533
Power
NW 2,876 12,151 3,388 2,551 5,071 7,181 8,116
Natural
Avista 842 2,878 602 705 1,900 2,122 1,225
Cascade 346 1,042 92 665 899 1,113 762
Total 11,520 64,243 13,318 7,508 34,870 46,113 63,587
i. Disconnection reporting began in Docket No. RO 12 in August 2018.
ii. The COVID-19 disconnection moratorium began in April 2020 and ended in August 2021. During this time utilities
did not disconnect residential utility customers for non-payment.
iii. Current data is available through October 2024.
iv. Due to modifications to their internal customer systems PGE did not disconnect customers from August 2018 to
November 2018.
v. PacifiCorp did not disconnect residential customer for non-payment for two additional months following the end of
the COVID-19 disconnection moratorium.
APPENDIX A
Page 5 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 6
Figure 1. Residential Disconnection Trends
Percentage of Residential Customer Disconnected
0.45% I
I
0.40% I
I
0.35% I
I
0.30% I
I
0.25% I
I
0.20% I
I
0.15% I
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0.05% I III I I I
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Percentage of Residential Customers Disconnected -3-Month Moving Average
In addition to the rising disconnection numbers observed in utility reporting, Staff has
also grown concerned with significant differences in bill assistance and arrearage
management offerings available across Investor-Owned Utility (IOU) programs, and
how these differences translate to higher disconnection risk and energy insecurity
between utilities. For example, referring to the RO12 table on the previous page, one
can observe that Avista and Cascade Natural Gas are the only two utilities that have not
outpaced 2023 residential disconnection counts in Q3 2024. It should be noted that
these are also the only two utilities that proactively established HB 2475 program
discounts and arrearage forgiveness options aligned to energy burden assessment data
and customer income. This appears to have given these utilities' low-income customers
greater access to energy security and reduced the risk of disconnection. NW Natural
has recently implemented deeper discounts to the lowest income tiers following its 2024
general rate case, with arrearage options expected in 2025; however, PGE and PAC
have yet to do the same absent a Commission order, and the data would show that
these are the utility customers that face the highest risk of disconnection. Staff believes
that utilities failing to provide reasonable safeguards against disconnection should be
directed to adjust their practices and make greater efforts to keep customers connected
such that a customer's service provider is not a defining factor in their ability to access
power.
As such, Staff finds that immediate action is necessary to mitigate the risks of utility
APPENDIX A
Page 6 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 7
disconnections during the upcoming winter heating season. Staff's proposed temporary
rules—outlined in Attachment A—aim to enhance customer protections against
disconnections, provide financial relief measures to mitigate the impacts of arrearages,
while also mandating better and more targeted outreach to customers and community
action agencies regarding enhanced customer protections and utility programs. As
explained above, failure to act promptly would result in serious prejudice to public safety
and welfare, particularly for vulnerable populations. Delays in implementing protections
would leave these customers at risk of losing essential utility services, with significant
adverse consequences, including harm to human life.
Materials relied upon, in compliance with ORS 183.335(5)(d):
• Commission Memorandum from November 27, 2024, directing Staff to propose
the temporary rules in this memo.2
• Stakeholder comments on Staff Report proposing near-term customer
protections against disconnection:
o Community Action Partnership of Oregon (CAPO)3
o Alliance of Western Energy consumers (AWEC)4
o Portland General Electric (PGE)5
o PacifiCorp6
o NW Natural?
• Staff Report for the November 26, 2024, Public Meeting (Item No. RA1).8 This
document proposes near-term customer protections against disconnection,
summarizing the public process in UM 2211 and stakeholder feedback.
• Stakeholder comments on Staff's proposed Phase 2 Arrearage and
Disconnection Action Plan and PUC workshops:
o Energy Justice Advocates9
o NW Natural10
o Idaho Power Company"
o Portland General Electric (PGE)12
2 Docket No. UM 2211, Memorandum, November 27, 2024.
3 Docket No. UM 2211, CAPO's Comments, November 26, 2024.
4 Docket No. UM 2211, AWEC's Comments, November 25, 2024.
5 Docket No. UM 2211, PGE's Final Comments, November 25, 2024.
6 Docket No. UM 2211, PacifiCorp's Reply Comments, November 25, 2024.
Docket No. UM 2211, NW Natural's Comments, November 25, 2024.
8 Docket No. UM 2211, Staff Report, November 20, 2024.
9 Docket No. UM 2211, Energy Justice Advocates Comments, November 18, 2024.
10 Docket No. UM 2211, NW Natural's Comments, November 15, 2024.
11 Docket No. UM 2211, Idaho Power Company's Reply Comments, November 15, 2024.
12 Docket No. UM 2211, PGE's Comments, November 15, 2024.
APPENDIX A
Page 7 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 8
o PacifiCorp13
o Avista Utilities14
o Cascade Natural Gas Corporation (CNGC)15
• Staff's proposed Phase 2 Arrearage and Disconnection Action Plan.16 A public
workshop concerning this Action Plan was held on November 7, 2024.
• Stakeholder comment on Staff's Arrearage and Disconnection Assessment:
o Energy Justice Advocates' Additional Comments 17
o Idaho Power Company18
o NW Natural19
o PacifiCorp20
o Cascade Natural Gas Corporation (CNGC)21
o Joint Utilities22
o Portland General Electric (PGE)23
o Avista Utilities24
o Energy Justice Advocates Initial CommentS25
• Staff's Arrearage and Disconnection Assessment.26 A public workshop was held
on September 17, 2024.
• Staff Announcement in Docket No. UM 2211 communicating the intent to
investigate disconnections and potentially initiate emergency rulemaking to
change Division 21 rules related to residential disconnection protections.27
• Additional disconnection data:
o Staff letter compiling utility disconnection data based on Q3 reports.28
13 Docket No. UM 2211, PacifiCorp's Comments, November 15, 2024.
14 Docket No. UM 2211, Avista Utilities' Comments, November 15, 2024.
15 Docket No. UM 2211, CNGC's Comments, November 15, 2024.
16 Docket No. UM 2211, Staff's Proposed Phase 2 Arrearage and Disconnection Action Plan, October 25,
2024.
17 Docket No. UM 2211, Energy Justice Advocates' Additional Comments, October 18, 2024.
18 Docket No. UM 2211, Idaho Power Company's Supplemental Response, October 9, 2024.
19 Docket No. UM 2211, NW Natural's Comments, October 9, 2024.
20 Docket No. UM 2211, PacifiCorp's Supplemental Comments, October 9, 2024.
21 Docket No. UM 2211, Cascade Natural Gas Corporations Supplemental Comments, October 9, 2024.
22 Docket No. UM 2211, Joint Utility Comments, October 9, 2024.
23 Docket No. UM 2211, PGE's Information in Response, October 9, 2024.
24 Docket No. UM 2211, Avista's Comments, October 9, 2024.
25 Docket No. UM 2211, Energy Justice Advocates' Initial Comments, September 24, 2024.
26 Docket No. UM 2211, Staff Residential Arrearage and Disconnection Assessment, September 16,
2024.
27 Docket No. UM 2211, HB 2475 Implementation of Differential Rates and Programs in Oregon,
August 6, 2024.
28 Docket No. UM 2211, Staff Letter, November 22, 2024.
APPENDIX A
Page 8 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 9
o Quarterly Reports of Residential Disconnections for nonpayment and
subsequent reconnections filed in Docket No. RO 12.29
• Documents in Docket No. AR 653, related to revisions to Division 21 rules to
strengthen customer protections concerning disconnections.31
• Other documents and data sources consulted:
o A 2021 study on how households cope with disconnections.31
o A 2003 Study on the relationship between cold weather, heating
expenses, and nutrition expenses.32
o Oregon Health Authority Dashboard on Emergency Department visits
related to Winter hazards.33
o Oregon Health Authority report on Climate and Health in Oregon.34
o Oregon Health Authority resources on Extreme Heat.35
o Weather outlook for the Winter season 2024/2025.36
Commission Guidance and Summary of Temporary Rules
The Commission issued a Memorandum on November 27, 2024, providing Staff with
clear directives on how to address and modify Staff's arrearage and disconnection
recommendations into temporary rules. Such temporary rules would then be brought
before the Commission at a "near-term public meeting, on a timeframe to address the
emergency around disconnections for the upcoming heating season". Staff's proposed
language converting this guidance into temporary rules is detailed in Attachment 1, and
summarized here:
For Natural Gas Utilities, Northwest Natural, Avista, and Cascade Natural Gas, the
temporary rules would:
• Expand low-temperature-based protections to include the 24-hours before severe
weather.
29 Docket No. RO 12, In the Matter of Energy Utility Quarterly Report of Residential Disconnections for
non-payment and subsequent reconnections per OAR 860-021-0408, the Disconnect Reporting Rule,
November 20, 2024.
30 Docket No. AR 653, In the Matter of Revisions to Division 21 Rules to Strengthen Customer Protections
Concerning Disconnections, April 18, 2023.
31 Diana Hernandez and Jennifer Laird, "Surviving a Shut-Off: U.S. Households at Greatest Risk of Utility
Disconnections and How They Cope," in American Behavioral Scientist, Volume 66 (7), May 8, 2021.
32 Jayanta Bhattacharya et al., "Heat or Eat? Cold-Weather Shocks and Nutrition in Poor American
Families," in American Journal of Public Health, Volume 93 (7), July 2003.
33 Oregon Health Authority, Oregon ESSENCE Winter Hazard Report, December 2, 2024.
34 Oregon Health Authority, Climate and Health in Oregon, 2023.
35 Oregon Health Authority, Extreme Heat, December 2, 2024.
36 Juliana Kim, "NOAA's annual winter forecast is here. These are the weather predictions for your area,"
in OPB, October 18, 2024.
APPENDIX A
Page 9 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 10
For PacifiCorp (PAC) and Portland General Electric, the temporary rules would:
• Expand low-temperature-based protections to include the 24-hours before
severe weather.
• Establish a date-based cold-weather moratorium for income-qualified bill
discount program participants and medical certificate accounts between
December 1 —April 1.
• Require these utilities to offer one-time arrearage forgiveness to households
earning at or below 0-5 percent SMI, up to $1,000.
For Idaho Power Company, the temporary rules would:
• Expand eligibility for the Winter Protection Program (WPP) to the Company's
monthly bill discount program participants.
The temporary rules would require all six investor-owned utilities to:
• Waive all reconnection charges for at least utility monthly bill discount
participants enrolled the lowest percentage of State Median Income (SMI) tier for
the program. Implementation should be done in the least cost way for each
utility.
• Provide sufficient noticing and outreach related to available disconnection and
arrearage protections at critical touch points, to Community Action Agencies; on
the utility's website; and with sufficient Customer Service staff training. Any utility
may proffer an alternative, if comparable plan for noticing touchpoints and CAA
coordination.
Staff circulated draft rules reflecting the Commission's direction with UM 2211
stakeholders. Staff received valuable corrections and clarifications from the utilities and
several stakeholders. Staff's proposed rules in Attachment 1 reflect this feedback.
Qualified Households
Staff's original proposal for near-term actions included several policies that would apply
to "Qualified Households". However, the final set of policies identified by the
Commission do not include any reference to Qualified Households. Therefore, Staff has
not proposed a modified definition of "Qualified Households" to be applied in these
temporary rules as directed by the Commission. The reason for this is to avoid
confusion around eligibility across the different components of the temporary and
existing rules. Staff has specified that the date-based moratorium under
OAR 860-021-0407(2) applies to medical certificate holders and customers that
participate in income-qualified discount programs.
Date-based Moratorium
Upon review of Staff's initial draft rules, PGE asked to set the date-based moratorium
APPENDIX A
Page 10 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 11
from to January 1 to March 31, instead of December 1 to April 1 as directed by the
Commission. PGE makes this proposal to align the start date with the effective date of
these rules, and to align the end date with the current temperature disconnection
moratorium in place November through March. Staff highlights that our recommendation
outlined in the temporary rule language is consistent with the Commission order.
Further, Staff would note that during the November 26 meeting, while the Commission
discussed the possibility of a shorter moratorium timeframe as a means of cost control,
the Commission ultimately narrowed the eligibility pool for the date-based moratorium
and was therefore supportive of maintaining the Staff recommended December 1 to
April 1 moratorium period, expressly choosing not to further restrict the protection by
reducing the window as well.
Reconnection Charges
NW Natural and PacifiCorp flagged questions related to the language prohibiting
reconnection charges in Staff's initial draft rules. NW Natural asked for clarification of
whether the prohibition of reconnection charges applies only for standard reconnection
charges and believes that reconnect fees for after hours and holidays should not be
prohibited. PacifiCorp asked for clarification of whether this applies for customers who
elect to take a non-standard meter.
Staff flags that the proposal brought to the November 27, 2024, public meeting
proposed elimination of all reconnection charges for the outlined subset of customers.
The Commission's order is consistent with Staff's proposal and did not ask Staff to
modify this language further. Staff emphasizes that in these rules, waived reconnections
are afforded only to households earning at or below 0-15 percent SMI, and in reality,
only those in that group who are both aware and capable of notifying the utility that they
are eligible for this protection. Further, Staff is concerned that NW Natural and
PacifiCorp are suggesting the Commission allow the utility to assess the highest of
reconnection charges against these otherwise protected households.
PGE and NW Natural recommended removing the sentence in the draft temporary rule
language in the reconnection fee (4) related to implementing the rule in the least-cost
manner stating that the sentence would be better placed in the Commission order. Staff
flags that this is language that came from the November 27, 2024, public meeting
discussion between Commissioners, but agrees that it can live within the Commission
order rather than in the rule language.
Staff recommendation: Staff removed the language from the proposed rule
and includes a recommendation for the Commission to direct Portland
General Electric and Pacific Power to implement OAR 860-021-0330(4)
with administration of this measure to be implemented via the lowest cost
APPENDIX A
Page 11 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 12
method for each utility.
Lastly, PacifiCorp and PGE asked Staff to clarify the cost recovery mechanism for the
expenses related to the temporary rules identified within the memo. Staff flags that
previous docket processes, namely AR 653, did not include cost recovery. Staff is
interested in learning from the costs associated with the temporary rules. PacifiCorp and
PGE were particularly interested in understanding how to collect costs related to the
one-time arrearage forgiveness grants. Staff believes the best venue for cost recovery
of the arrearage forgiveness grant expenses is the current deferrals for the utilities bill
discount programs for later recovery.
Staff recommendation: Staff does not believe that cost recovery details
need to be specified in the rules or directed by the Commission. However,
Staff suggests that the utilities include the costs of implementing these
rules in their existing deferrals for bill discount programs. Staff asks that
the utilities take steps to isolate these costs from bill discount program
costs to allow better analysis of cost drivers.
Opportunity to Address Reporting Issues
While the main purpose of this Staff report is to address temporary rules, Staff believe
that this public meeting item may offer a venue to efficiently address reporting issues
that have emerged in UM 2211. Staff offers recommendations on data reporting in this
Staff report so that it will be available in the event that the Commission seeks to take
action on these matters at this time.
Through written comments and discussion with the Oregon Citizens' Utility Board (CUB)
at the December 10, 2024, Public Meeting addressing the UM 2211 data workstream,
stakeholders have flagged the importance of transparent data practices to understand
the ratepayer impact of the temporary rules and to identify any additional gaps or
opportunities based on customer reach. While Staff does not wish to overcomplicate the
approval of these essential protections with additional decisions and requirements, Staff
does find value in ensuring the ability to review a set of metrics at the conclusion of the
temporary rule period, particularly given 1) the planned permanent rulemaking process
that will revisit many of these protections and 2) the shared interest of Staff,
stakeholders, and the Commission to evaluate the magnitude of costs associated with
protections of this nature.
As such, Staff would ask the Commission to consider directing each of the utilities to
provide a report at the conclusion of the temporary rules period which contains monthly
data, by zip code for:
• The count of disconnections that were not completed due to revisions to
APPENDIX A
Page 12 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 13
OAR 860-021-0407(1), the addition of OAR 860-021-0407(2), or the addition of
OAR 860-021-0640;
• The count of waived reconnection charges due to OAR 860-021-0330;
• The average amount of reconnection costs waived per waiver due to
OAR 860-021-0330;
• The total dollar amount of reconnection costs waived due to OAR 860-021-0330;
• The count of one-time arrearage forgiveness grants issued due to
OAR 860-021-0630;
• The average dollar amount of one-time arrearage forgiveness grants issued due
to OAR 860-021-0630; and
• The total dollar amount of one-time arrearage forgiveness grants issued due to
OAR 860-021-0630.
Staff also agrees with CUB's request that the Commission require the utilities to provide
retroactive arrears data for 2024 through the first energy burden metrics report (EBMR).
Eliminating gaps in this data is particularly relevant for understanding the impact of
various programs and assistance offerings that have been implemented or expanded in
the last year and as we move through the heating season. To this end, Staff offers the
following recommendation: Direct the Utilities to provide the monthly arrears metrics
specified in the EBMR rules for the time period between January 1, 2024 and
December 31, 2024. Staff recommends that the Utilities submit this data as part of the
submission of the first full EBMR on July 15, 2025. If a utility files a general rate revision
prior to July 15, 2024, Staff recommends the retroactive monthly data be provided at
that time, instead.
Conclusion
Staff finds that the proposed actions provide implementable, strategic, and meaningful
enhancements to arrearage and disconnection protections that will ultimately reduce
both risk and harm for residential customers in the coming months. To this end Staff
recommends that the Commission adopt the proposed temporary rule amendments to
OAR 860-021-0407, OAR 860-021-0330, and additional new temporary rules,
OAR 860-021-0630 through OAR 860-021-0650, related to residential customer
protections against disconnection in Attachment A, effective upon filing with the
Secretary of State. To understand the impacts and costs of the above proposed
temporary rules, Staff recommends the utilities provide some high-level metrics at the
conclusion of the temporary rule period which will also aid the formulation of the
forthcoming permanent rules. Staff also finds it prudent and useful for the Utilities to
provide arrears metrics data as proposed by Staff in this Report
APPENDIX A
Page 13 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 14
PROPOSED COMMISSION MOTION:
Adopt the proposed temporary rule amendments to OAR 860-021-0407,
OAR 860-021-0330, and additional new temporary rules, OAR 860-021-0630,
OAR 860-021-0640, and OAR 860-021-0650, related to residential customer protections
against disconnection in Attachment A, effective upon filing with the Secretary of State.
Adopt Staff's recommendation to direct Portland General Electric and Pacific Power to
implement OAR 860-021-0330(4) with administration of this measure to be implemented
via the lowest cost method for each utility.
Approve Staff's recommendation to direct the Utilities to provide a report reflecting the
impacts of these temporary customer protections. Staff recommends that the Utilities file
a report containing the following data, per month, at the zip-code level:
• The count of disconnections that were not completed due to revisions to
OAR 860-021-0407(1), the addition of OAR 860-021-0407(2), or the addition of
OAR 860-021-0640;
• The count of waived reconnection charges due to OAR 860-021-0330;
• The average amount of reconnection costs waived per waiver due to
OAR 860-021-0330;
• The total dollar amount of reconnection costs waived due to OAR 860-021-0330;
• The count of one-time arrearage forgiveness grants issued due to 860-021-0630;
• The average dollar amount of one-time arrearage forgiveness grants issued due
to OAR 860-021-0630; and
• The total dollar amount of one-time arrearage forgiveness grants issued due to
OAR 860-021-0630.
Approve Staff's recommendation to direct the Utilities to report the monthly arrears
metrics outlined in the Energy Burden Metrics Report (EMBR) rules from January 1,
2024 through December 31, 2024, with the submission of its EMBR report on July 15,
2025, or at the time filing its next general rate revision, whichever is sooner.
APPENDIX A
Page 14 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 15
Attachment 1
OAR 860-021-0407
Severe Weather Moratorium on Involuntary Disconnection of Residential and
Small Commercial
(1) Except as set forth in section (11) of this rule, an energy utility must put into effect a
moratorium on the disconnection of residential service for nonpayment from November
through March during the 24 hours preceding and on any day a temperature of less
than 32 degrees Fahrenheit is forecasted by the applicable weather reporting service or
a winter storm warning indicating weather conditions pose a threat to life or property is
issued by the applicable weather reporting service.
(2) Except as set forth in section (11) of this rule, an electric utility must implement a
date-based moratorium prohibiting the disconnection of service from December 1
through April 1 for households with a customer who:
(a) Is enrolled in the utility's income-qualified bill discount program; or
(b) Is a medical certificate holder under OAR 860-021-0410.
(2 ) An electric utility must put into effect a moratorium on the disconnection of
residential service for nonpayment on any day a local Heat Advisory is issued by the
applicable weather reporting service.
(6 ) An energy utility must put into effect a moratorium on the disconnection of
residential and small commercial service for nonpayment when the Air Quality Index is
at or above 100 as issued on the website AirNow.gov or a similar air quality reporting
service that may be designated by the utility.
(4 ) Any moratorium activated as a result of section (1),(2- ), or (3 ) of this rule must
remain in effect at least through the start of the next business day.
(a ) For purposes of sections (1) and (2 ) of this rule, an energy utility must base the
need for a moratorium on data available from the National Weather Service or another
weather reporting service that may be designated by the utility.
(6 ) An energy utility need only apply a moratorium to the geographic area that meets
the conditions in sections (1) to (3), and (4) of this rule.
(7 ) The energy utility must obtain the required forecast data no later than 8:00 a.m.
each business day.
APPENDIX A
Page 15 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 16
(9 ) Each energy utility must notify the Commission's Consumer Services Section
which weather reporting service and air quality service it will utilize in each geographic
area served by the utility in complying with the requirements of this rule; and the energy
utility must notify the Commission's Consumer Services Section upon choosing a
different weather reporting service.
(9 10) Upon request from a customer who has been disconnected for nonpayment
within the previous 72 hours of a severe weather or air quality condition outlined in
sections (1), (2 ), and (3 ) of this rule, an energy utility must make best efforts to
reconnect service. The energy utility may apply reconnection fees authorized in
OAR 860-021-0330 to any reconnection.
(4-0 )The temperature threshold Spenifierl ir+ g ections (1) and (2) of this rule does not
apply if an energy utility offers a Commission-approved winter protection program.
Statutory/Other Authority: ORS 756.060
Statutes/Other Implemented: ORS 756.040
History:
PUC 10-2022, amend filed 09/30/2022, effective 09/30/2022
PUC 4-2017, f. & cert. eff. 5-30-17
OAR 860-021-0330
Reconnection Fee for Utility Service
When a utility service is disconnected pursuant to OAR 860-021-0305, the energy or
large telecommunications utility may charge the reconnection fee in its tariff, except as
provided below:
(1) For electric utilities that have the ability to perform remote reconnection, the electric
utility may not assess a reconnection fee for low-income residential customers for the
first two reconnections in a calendar year.
(2) For electric utilities that do not have the ability to perform remote reconnection, the
electric utility may not assess a reconnection fee for low-income residential customers
for the first reconnection in a calendar year.
(3) For natural gas utilities, the natural gas utility may not assess a reconnection fee for
a low-income residential customer for the first reconnection in a calendar year.
(4) Energy utilities must not impose any reconnection charge for residential accounts
following disconnection for non-payment provided the customer was enrolled in the
APPENDIX A
Page 16 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 17
lowest tier of the utility's income-qualified bill discount program prior to disconnection.
(4 5) Sections (1), (2), and (3) above do not apply to After Hours Reconnect as
described in OAR 860-021-0328(7)(b).
Statutory/Other Authority: ORS 183, ORS 756, ORS 757, and ORS 759
Statutes/Other Implemented: ORS 756.040 and ORS 757.225
History:
PUC 10-2022, amend filed 09/30/2022, effective 09/30/2022
PUC 16-2001, f. & cert. eff. 6-21-01
PUC 11-1998, f. & cert. eff. 5-7-98
PUC 16-1990, f. 9-28-90, cert. eff. 10-1-90 (Order No. 90-1105)
PUC 5-1983, f. 5-31-83, eff. 6-1-83 (Order No. 83-284)
860-021-0630
Arrearage Forgiveness Grant
(1) Electric utilities must offer a one-time arrearage forgiveness grant of up to $1,000.00
to households with incomes at or below five percent of the Oregon state median
income.
(2) Section (1) of this rule does not apply to electric utilities that offer a
Commission-approved winter protection program.
860-021-0640
Winter Protection Programs
An energy utility that offers a Commission-approved winter protection program must
extend eligibility to include customers enrolled in its income-qualified bill discount
program.
OAR 860-021-0650
Energy Utility Notification of Enhanced Protections
(1) Energy utilities must notify customers of the availability and terms of applicable
enhanced protections and programs under the following circumstances:
(a) Upon customer enrollment in the utility's income-qualified bill discount program.
(b) When the customer contacts the utility regarding bill pay assistance.
(c) Upon issuance of a disconnection notice for nonpayment.
(d) Within 24 hours of a customer being disconnected for nonpayment.
(e) Upon a customer's request for reconnection following a disconnection for
nonpayment.
(2) Energy utilities must:
(a) Notify partnering community action agencies of available protections for qualifying
customers and provide digital or paper reference materials to assist with outreach
APPENDIX A
Page 17 of 18

ORDER NO. 24-446
Docket No. AR 667
December 9, 2024
Page 18
efforts.
(b) Include accessible, up-to-date information on their websites regarding the availability
and terms of disconnection protections and other related programs.
(c) Train its customer service representatives to offer and discuss
applicable programs and provide accurate information on eligibility
and enrollment procedures.
(3) The requirements in sections (1) and (2) of this rule do not apply to
energy utilities with Commission-approved notification and outreach
plans.
APPENDIX A
Page 18 of 18

ORDER NO. 24-459
ENTERED Dec 27,2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
LC 81
In the Matter of
AVISTA CORPORATION, dba AVISTA ORDER
UTILITIES,
2023 Natural Gas Integrated Resource Plan.
DISPOSITION: ISSUE FUND GRANT REQUEST APPROVED
On December 23, 2024, the Oregon Citizens' Utility Board filed a Request for Payment
of its Avista Utilities Issue Fund Grant. The procedures for payment of Issue Fund Grants
are governed by Section 7.3 of the Fifth Amended and Restated Intervenor Funding
Agreement (Agreement), adopted by the Commission in Order No. 22-506. CUB is
automatically precertified to receive Issue Fund Grants under OAR 860-001-0120(3)(a)
and under Section 5.2(a) of the Agreement.
CUB asks for a final payment of$19,000 from the 2023 Avista Utilities Issue Fund and
$10,000 from the 2024 Avista Utilities Issue Fund.
Under the Agreement, the Request for Payment must:
(1) Itemize the expenses,payees and hourly rates of amount to be reimbursed;
(2) Demonstrate that the expenses are reasonable and are directly attributable to
issues and positions pursued on behalf of a particular customer class and
consistent with the intervenor's proposed budget;
(3) Provide information sufficient to show that the intervenor has complied with any
conditions imposed on the Issue Fund Grant; and

ORDER NO. 24-459
(4) Specify whether the request for payment is for a progress payment or a final
payment and indicate whether any approved budget amount may be released back
to the applicable Issue Fund.
Further, under the terms of the Section 7.3 of the Agreement, CUB must establish that it
has used in-house resources or outside funding for at least 20 percent of the Eligible
Expenses for an Eligible Proceeding. CUB provided the required documentation in its
request.
The Agreement provides that the Commission determine in each proceeding how the
participating utilities are to recover the funding grants from the various customer classes.
Under Section 7.7(b), Issue Fund Grants should be allocated to align the costs of the
advocacy with the intended potential beneficiaries of the advocacy. The Commission
considered the intended beneficiaries and finds that the issue fund expenditures should be
allocated to Avista Utilities' residential customers.
The Commission finds that CUB's request meets the requirements of the Agreement, and
its request should be approved. Section 7.8 of the Agreement provides that the utility
must pay the Issue Fund Grant to the requesting intervenor within 30 days after receipt of
Commission directive.
ORDER
IT IS ORDERED that:
1. The Oregon Citizens' Utility Board's request meets the requirements of the Fifth
Amended and Restated Intervenor Funding Agreement, and its request is
approved.
2. Avista Corporation dba Avista Utilities pay $29,000 from the Avista Utilities
Issue Fund to the Oregon Citizens' Utility Board within 30 days after receipt of
this order, and the grant be assessed to Avista Corporation dba Avista Utilities'
residential customers.
Made, entered, and effective Dec 27, 2024
CO,yf'Ir
z Alison Lackey
iE"VON _ : Chief Administrative Law Judge
* Administrative Hearings Division
OREGo
2

ORDER NO. 24-352
ENTERED Oct 16 2024
BEFORE THE PUBLIC UTILITY COMMISSION
OF OREGON
UM 2318
In the Matter of
AVISTA CORPORATION, dba AVISTA ORDER
UTILITIES,
Application for Authorization to Defer
Certain Costs Associated with Energy
Efficiency Services to Natural Gas
Transport Customers.
DISPOSITION: STAFF'S RECOMMENDATION ADOPTED
At its public meeting on October 15, 2024,the Public Utility Commission of Oregon
adopted Staff s recommendation in this matter. The Staff Report with the
recommendation is attached as Appendix A.
BY THE COMMISSION:
tiiTY c
��� ° Alison Lackey
Chief Administrative Law Judge
°F*°REGOls
A party may request rehearing or reconsideration of this order under ORS 756.561. A
request for rehearing or reconsideration must be filed with the Commission within 60 days
of the date of service of this order. The request must comply with the requirements in
OAR 860-001-0720. A copy of the request must also be served on each parry to the
proceedings as provided in OAR 860-001-0180(2).A party may appeal this order by filing
a petition for review with the Circuit Court for Marion County in compliance with
ORS 183.484.

ORDER NO. 24-352
ITEM NO. CA4
PUBLIC UTILITY COMMISSION OF OREGON
STAFF REPORT
PUBLIC MEETING DATE: October 15, 2024
REGULAR CONSENT X EFFECTIVE DATE N/A
DATE: September 25, 2024
TO: Public Utility Commission
FROM: Kathy Zarate
THROUGH: Caroline Moore, Scott Gibens, and Michelle Scala SIGNED
SUBJECT: AVISTA UTILITIES:
(Docket No. UM 2318)
Requests authorization of Deferred Accounting of Costs Associated with
Energy Efficiency Services for Natural Gas Transport Customers
STAFF RECOMMENDATION:
Staff recommends the Commission approve Avista Utilities' (Avista, AVA, or Company)
request for the authorization of deferred accounting for costs associated with Energy
Efficiency Services for Natural Gas Transport Customers, for the 12-month period
beginning on March 11, 2024.
DISCUSSION:
Issue
Whether the Commission should approve the Company's request for authorization of
deferred accounting of costs associated with Climate Protection Program-related energy
efficiency services for Natural Gas Transport Customers for the 12-month period
beginning March 11, 2024.
Applicable Law
In accordance with ORS 757.259 and OAR 860-027-0300, Avista Corporation, dba
Avista Utilities (Avista or Company), hereby submits for electronic filing an Application
for authorization of deferred accounting for all costs associated with energy efficiency
services provided to Natural Gas Transport Customers. The services provided are
directly attributable to the Climate Protection Program (CPP).
APPENDIX A
Page 1 of 5

ORDER NO. 24-352
Docket No. UM 2318
September 25, 2024
Page 2
Pursuant to ORS 757.259(2)(e) and OAR 860-027-0300, the Company hereby applies
to the Public Utility Commission of Oregon for an order authorizing deferred accounting
treatment for all costs associated with the Company's compliance with the Climate
Protection Program (CPP) with respect to acquiring energy efficiency services for
Natural Gas Transport Customers.
The Company respectfully requested that the deferral be effective for the 12-month
period commencing on March 11, 2024.
Analysis
Background
On December 16, 2021, the Oregon Department of Environmental Quality (ODEQ)
adopted the CPP, which are administrative rules that set GHG reduction targets.' The
CPP sets a declining limit, or cap, on greenhouse gas emissions from fossil fuels used
throughout the state of Oregon, including diesel, gasoline, natural gas and propane,
used in transportation, residential, commercial and industrial settings (the program is
not inclusive of fossil fuel used in electric generation).2
The CPP also regulates site-specific greenhouse gas emissions at large stationary
sources, such as emissions from industrial processes.
The Company is a "covered fuel supplier" under the CPP and is the point of regulation
for the emissions associated with natural gas used by its sales and transport customers.
Transport customers purchase the commodity they use directly from marketers and
suppliers and have historically only paid Avista for delivery via the distribution system.
Covered entities' emissions are reported annually through the existing ODEQ
greenhouse gas reporting program and compliance will be demonstrated by each
covered entity at the end of each three-year compliance period.
The Company can work to reduce natural gas usage through efficiency measures,
introduce renewable and low carbon alternative fuels, trade for additional compliance
instruments with other covered entities, or purchase a limited amount of Community
Climate Investments (CCIs).3
On September 13, 2022, Avista's filed an application seeking authorization of deferred
accounting for CPP costs related to energy efficiency measures for Natural Gas
OAR 340-271-0010—9000.
2 OAR 340-271-0110.
3 OAR 340-271-0450.
APPENDIX A
Page 2 of 5

ORDER NO. 24-352
Docket No. UM 2318
September 25, 2024
Page 3
Transport Customers, for the 12-month period beginning on September 13, 2022. On
April 21, 2023, the Commission approved Avista's request per Order No. 23-145.
However, the rules were invalidated by the Oregon Appeals Court (Court) on
December 23, 2023, as the Court found that the rules did not comply with
ORS 468A.315(1). Avista was one of the petitioners in the suit challenging the CPP
administrative rules.4
Nevertheless, in January 22, 2024, ODEQ issued notice that it accepted the Court's
decision, and it will begin the process to reinstate the CPP in the first quarter of 2024,
anticipating the rulemaking process will take about 12 months.
In the first reauthorization request in docket UM 2254, the Company again asked for
these costs associated with the CPP program be deferred. Staff proposed that the
Commission approve the deferral request up to the date the Court invalidated DEQ's
CPP rules. The Commission adopted Staff's recommendation in Order No. 24-228,
issued on July 10, 2024.
In a subsequent filing by Cascade, Docket No. UM 2257(1) a similar issue arose related
to deferral requests for CPP-related costs that included a time period over which the
CPP rules continued to not be in effect having been invalidated by the Court. In the Staff
review of that filing, Staff considered the issue further and recommended a different
approach which is to support the deferral request. The reasoning is provided below and
is taken from the Staff memo adopted by the Commission in Order No. 24-292, issued
on August 28, 2024.
Because the Court of Appeals ruled the CPP rules invalid, Staff
considered whether it was appropriate for Cascade to defer CPP costs
incurred after December 20, 2023. Staff believes that there are compelling
reasons to allow the Company to continue to track costs incurred after the
CPP was invalidated and before the successor rules to the CPP go into
effect. First, Staff notes that DEQ plans to pick the CPP back up as if there
was no delay in implementation and believes that certain actions taken
after the CPP was invalidated on December 20, 2023, may allow the
Company to more cost effectively comply with the successor rules to the
CPP. Second, the Company clarified to Staff that some costs were
committed to prior to when the CPP was invalidated, but not incurred until
after the CPP was invalidated. While Staff makes no determination about
the prudence of these costs or any other costs at this time, Staff believes
that it is reasonable to track these costs for later ratemaking.
4 Docket No. UM 2254.
APPENDIX A
Page 3 of 5

ORDER NO. 24-352
Docket No. UM 2318
September 25, 2024
Page 4
In making this recommendation, Staff notes that a new set of rules to
succeed the CPP is expected to go into effect January 1, 2025. Staff also
highlights that many of the costs that the Company sought to defer in its
application, such as the purchase of CCls, were not needed or incurred
during the deferral period, and other costs, such as EE investments, have
broad benefits that the Company should pursue even without a deferral.
Staff's recommendation to allow the Company to track costs incurred after
December 20, 2023, should not be interpreted as determining that any
particular cost incurred post-invalidation will be determined prudent.
In this filing, dated March 12, 2024, the Company makes two requests. First, the
Company asks for approval to defer costs associated with complying with the CPP with
respect to energy efficiency services provided to Natural Gas Transport Customers
(which is essentially a reauthorization request of UM 2254); and the second request is
to move all of the recorded deferral costs in UM 2254 into this deferral filing.-,
With respect to the first request, Staff believes that similar circumstances arise here as
in the Cascade example cited above. Avista is continuing a program already in
existence and started prior to any Court ruling. With respect to the second request, Staff
supports Avista's reasoning that moving the recorded expenditures will result in
administrate ease.
Reason for Deferral
Under ORS 757.259(2)(e), deferral of utility expenses or revenues is allowed when it
will appropriately match the costs borne and benefits received by customers.
Proposed Accounting
The Company records CPP compliance costs to FERC Account 182.3 (Other
Regulatory Assets), crediting FERC Account 407.4 (Regulatory Credits).
Estimate of Amounts
The current CPP Deferral balance from which the Company is requesting to transfer all
costs already recorded in support of providing energy efficiency services for transport
customers is approximately $266,847.
This amount includes both monthly distributions to Energy Trust for services rendered to
transport customers, as well as approximately $16,847 (included into $266,847)
expended as the transport customers' allocation for a third-party study to verify non-
energy impacts (NEls) for transport customers' avoided costs.
5 Docket No. UM 2318.
APPENDIX A
Page 4 of 5

ORDER NO. 24-352
Docket No. UM 2318
September 25, 2024
Page 5
Information Related to Future Amortization
• Earnings review — Cost recovery for costs associated with the costs of
compliance with the Climate Protection Plan will be subject to an earnings review
in accordance with ORS 757.259(5).
• Prudence Review—A prudence review will be performed by the OPUC Staff no
later than the proceeding to authorize amortization of the costs associated with
the costs of compliance with the CPP.
• Sharing — No Sharing mechanism.
• Rate Spread/Design — The rate spread/rate design will be determined during the
proceeding to authorize amortization of the costs associated with the deferral.
• Three Percent Test (ORS 757.259(6)) — Amortization of the deferred costs will be
subject to a three percent test in accordance with ORS 757.259(7) or possible six
percent test in accordance with ORS 757.259(8) and with Commission
authorization. These tests limit aggregated deferral amortizations during a
12-month period to no more than three or six percent of the utility's gross
revenues for the preceding year.
Conclusion
After Staff's review of Avista's application requesting authorization to defer, because the
application meets the requirements of ORS 757.259 and OAR 860-027-0300, Staff
recommends Avista's application be approved.
The Company has reviewed this memo and agrees with or expresses no objections to
Staff's recommendation.
PROPOSED COMMISSION MOTION:
Approve Avista's application for authorization to use deferred accounting for Climate
Protection Program (CPP) related costs, associated with energy efficiency programs for
Natural Gas Transport Customers, for the 12-month period beginning on
March 11, 2024.
Direct Avista to move to this docket any remaining costs previously deferred under
Docket No. UM 2254.
AVA UM 2318 CPP Deferral
APPENDIX A
Page 5 of 5