20250228AVU to Staff 5 Attachment A - 2024 WA 1st Qtr - Combined.pdf

Service Date March 14,2024
BEFORE THE WASHINGTON
UTILITIES AND TRANSPORTATION COMMISSION
In the Matter of DOCKET U-210151
Reducing the Administrative Burden in ORDER 01
Support of the Commission's Ongoing
Inquiry into the Adequacy of the Current AMENDING FILING REQUIREMENTS
Regulatory Framework FOR AVISTA CORPORATION d/b/a
AVISTA UTILITIES, CASCADE
NATURAL GAS CORPORATION,
NORTHWEST NATURAL GAS
COMPANY d/b/a NW NATURAL,
PACIFICORP d/b/a PACIFIC POWER&
LIGHT COMPANY, AND PUGET
SOUND ENERGY
BACKGROUND
I On March 4, 2021, the Washington Utilities and Transportation Commission
(Commission) initiated an inquiry into reducing the administrative burden to review the
recurring filings utilities are obligated to make with the Commission by statute, rule, or
order. The purpose of the inquiry is to determine which filings are no longer necessary or
could be consolidated.
2 On March 15, 2021, the Commission issued a Notice of Opportunity to File Written
Comments asking investor-owned utilities to complete a template with information
regarding recurring filings required by statute, rule, or Commission order and to
recommend an action for each filing. By April 15, 2021, the Commission received
responses from each of its regulated utilities.'
3 On April 27, 2021, the Commission issued a Notice of Opportunity to File Written
Comments inviting parties to respond to each utility's recommended modifications to the
reporting requirements identified in the utility responses to the Notice dated March 15,
2021.
1 On May 14, 2021, Cascade filed a revised version of the comments it filed on April 7, 2021.

DOCKET U-210151 PAGE 2
ORDER 01
4 On May 25, 2021, the Commission received written comments from The Energy Project,
Public Counsel, and Northwest Energy Coalition. Commission Staff(Staff) filed
comments on May 28, 2021. Staff reviewed the utility recommendations and interested
party responses to the Notice dated April 27, 2021. Staff compiled a list of filings that
appeared to Staff to be the best candidates for elimination or a reduction in filing
frequency. Staff then decided to offer its proposed modifications to filings required by
order as a first step before moving on to filings required by rule.
5 On May 9, 2023, the Commission issued a Notice of Opportunity to File Written
Comments inviting interested parties to respond to Staff's proposed modifications to
filings required by order. Staff's proposed modifications were provided as Appendix A to
the Notice. On or by June 15, 2023, the Commission received responses from Avista
Corporation d/b/a Avista Utilities(Avista), Puget Sound Energy, Northwest Natural Gas
Company d/b/a NW Natural (NW Natural), and PacifiCorp d/b/a Pacific Power&Light
Company (PacifiCorp).
6 Through this effort, Staff has identified approximately 80 utility filings that are required
by order. Of those 80 filings, Staff has proposed modifications to only seven.According
to Staff, the initial list of 80 filings was reduced to seven for a variety of reasons. Staff
excludes some filings as candidates for elimination or consolidation because those filings
were no longer required, either because the filing requirement expired or because it was
eliminated by order in another proceeding.2 Staff excludes other filings because it is
unclear how(or whether) the report would be used within the evolving context of utility
performance metrics. However, Staff excludes most filings as candidates because the
information they contain continues to be used for specific regulatory purposes or because
most of the commenting parties recommended that the filing requirement be maintained.
7 The seven modifications Staff proposes—which were provided as Appendix A to the
Commission's May 9, 2023, Notice of Opportunity to File Written Comments—are
summarized in Table 1 below.
2 See, e.g., WUTC v Puget Sound Energy, Dockets UE-220066,UG-220067, and UG-210918
(consolidated), Order 24/10,Appendix A, 28¶56 (December 22, 2022).

DOCKET U-210151 PAGE 3
ORDER 01
TABLE 1. Summary of Staff's Proposed Modifications to Utility Filings Required
by Order
STAFF
REPORT COMPANY RECOMMENDS REASON
Annual Report of PacifiCorp Eliminate Reporting Information is not used;
Permanent Requirement report is not required for any
Disconnections and other utility.
Removal of Facilities3
Annual Environmental PacifiCorp Eliminate Reporting Not useful as a standalone
Remediation Deferral Requirementreport; information provided
Report4 upon request for cost
ecove
Biennial Pipeline NW Natural Eliminate Reporting Plan is unnecessary for
Replacement P1an5 Requirement itilities that do not have
i h-risk pipe.
Updates to Annual Cascade Eliminate Required Unnecessary to provide cost
Pipeline Replacement Updates updates after initial filing
CRM Tariff Revision Oven the true-up function of
he CRM.
PCAM Quarterly PSE Modify Frequency CAM deferrals are
Report to Annual -eviewed annually; quarterly
eporting is unnecessary.
Decoupling Avista Modify Frequency Decoupling review is
Mechanism Quarterly to Annualannual; quarterly reporting
Report is unnecessary.
ERM Deferral Avista Modify Frequency ERM deferrals are reviewed
Monthly Report9 to Annualannually; monthly reporting
's unnecessary.
3 Docket UE-001734, 8th Suppl. Order, 30¶95 (approving Modified Tariff Proposal). See also 8th
Suppl. Order at 7¶¶22-23 (referencing McIntosh Exh. 301T at 8:8-13), identifying that this
reporting requirement is a condition of the Modified Tariff proposal.
4 Docket UE-031658, Order 03, 3¶ 11,modifying the frequency of the reporting requirement
established by Docket UE-031658, Order 01, from semi-annual to annual.
5 Docket UG-120715, Commission Policy on Accelerated Replacement of Pipeline Facilities with
Elevated Risk, 11 ¶¶41-43 (December 31, 2012).
6 Docket UG-120715, Commission Policy on Accelerated Replacement of Pipeline Facilities with
Elevated Risk, 17¶69 (December 31, 2012).
Docket UE-130617, Order 11, approving settlement at¶¶38-39. This reporting requirement was
established by the Settlement Stipulation,Attachment A at 2¶3c.
8 Dockets UE-140188 and UG-140189, Order 05, approving settlement at 24¶74. The Settlement
adopted Avista's proposal on decoupling, including quarterly reporting, as discussed in Ehrbar
Exh. PBE-1 T at 67:12-16 and 73:8-9.
9 Docket UE-011595, 5th Suppl. Order, approving settlement at 22¶67. The Settlement
Stipulation identifies this reporting requirement at 6¶4a.

DOCKET U-210151 PAGE 4
ORDER 01
8 In response to the Commission's May 9, 2023,Notice for Opportunity to File Written
Comments, the Commission received comment from four parties:Avista, PSE,NW
Natural, and PacifiCorp. The Commission did not receive comment from Cascade or any
non-company party. No party responded in opposition to Staff's proposed modifications
to the filing requirements in Appendix A.
9 Given that no party commented in opposition to Staff's proposed modifications, Staff
recommends that the Commission enter an order adopting those modifications.
DISCUSSION
10 The Commission agrees with Staff that Staff s proposed modifications to the filing
requirements of Avista, PSE,NW Natural, PacifiCorp, and Cascade contained in
Appendix A to the Commission's Notice dated May 9, 2023, should be adopted as
proposed.
11 Considering the comments received from Avista, PSE,NW Natural, and PacifiCorp, in
response to the Notice dated May 9, 2023, and considering none of the interested parties
filed comments in opposition to Appendix A, the Commission agrees with Staff s
recommendations to:
(1) Eliminate the requirement, established in the 8ffi Supplemental Order of Docket
UE-001734 (approving the Modified Tariff Proposal in that docket), that
PacifiCorp file annually a Report of Permanent Disconnections and Removals of
Facilities;
(2) Eliminate the requirement, established in Order 03 of Docket UE-031658, that
PacifiCorp file annually a Report of Environmental Remediation Cost Deferrals;
(3) Modify the requirement that natural gas utilities must file a pipe replacement
program plan every two years, established in the Commission Policy on
Accelerated Replacement of Pipeline Facilities with Elevated Risk in Docket UG-
120715, to pertain only to natural gas utilities that own pipeline identified as
having an elevated risk of failure.
(4) Eliminate the requirement, established in the Commission Policy on Accelerated
Replacement of Pipeline Facilities with Elevated Risk in Docket UG-120715, that

DOCKET U-210151 PAGE 5
ORDER 01
utilities filing an annual cost recovery mechanism tariff filing must update
projected costs twice between the initial filing and the rate-effective date;
(5) Modify the requirement that Puget Sound Energy file quarterly a PCA Report,
established in Order 11 of Docket UE-130617 (approving the Settlement
Stipulation in that docket), from a quarterly filing frequency to an annual filing
frequency;
(6) Modify the requirement that Avista file a monthly ERM Deferral Report,
established in the 5th Supplemental Order of Docket UE-011595 (approving the
Settlement Stipulation in that docket), from a monthly filing frequency to an
annual filing frequency; and
(7) Modify the requirement that Avista file a Decoupling Mechanism Quarterly
Report, established in Order 05 of Dockets UE-140188 and UG-140189
(approving the Settlement Stipulation in that docket), from a quarterly filing
frequency to an annual filing frequency.
We find that Staff s proposed revisions are reasonable and will reduce administrative
burden. Accordingly, we determine that it is in the public interest to amend the filing
requirements as set forth above.
FINDINGS AND CONCLUSIONS
12 (1) The Commission is an agency of the State of Washington vested by statute with
the authority to regulate the rates, regulations,practices, accounts, and affiliated
interests of public service companies, including electric companies and natural
gas companies.
13 (2) Avista Corporation d/b/a Avista Utilities is engaged in the business of providing
electric and natural gas services within the state of Washington and is a public
service company subject to Commission jurisdiction.
14 (3) Cascade Natural Gas Corporation is engaged in the business of providing natural
gas services within the state of Washington and is a public service company
subject to Commission jurisdiction.

DOCKET U-210151 PAGE 6
ORDER 01
15 (4) Northwest Natural Gas Company d/b/a NW Natural is engaged in the business of
providing natural gas services within the state of Washington and is a public
service company subject to Commission jurisdiction.
16 (5) PacifiCorp d/b/a Pacific Power&Light Company is engaged in the business of
providing electric services within the state of Washington and is a public service
company subject to Commission jurisdiction.
17 (6) Puget Sound Energy is engaged in the business of providing electric and natural
gas services within the state of Washington and is a public service company
subject to Commission jurisdiction.
18 (7) This matter came before the Commission at its regularly scheduled meeting on
March 14, 2024.
19 (8) After review of the Notices of Opportunity to File Written Comments, filed on
March 15, 2021,April 27, 2021, and May 9, 2023, and subsequently filed
comments and giving due consideration, the Commission adopts Commission
Staff's recommendations as follows:
(1) Eliminate the requirement, established in the 8t' Supplemental Order of
Docket UE-001734 (approving the Modified Tariff Proposal in that
docket), that PacifiCorp file annually a Report of Permanent
Disconnections and Removals of Facilities;
(2) Eliminate the requirement, established in Order 03 of Docket UE-031658,
that PacifiCorp file annually a Report of Environmental Remediation Cost
Deferrals;
(3) Modify the requirement that natural gas utilities must file a pipe
replacement program plan every two years, established in the Commission
Policy on Accelerated Replacement of Pipeline Facilities with Elevated
Risk in Docket UG-120715, to pertain only to natural gas utilities that own
pipeline identified as having an elevated risk of failure.
(4) Eliminate the requirement, established in the Commission Policy on
Accelerated Replacement of Pipeline Facilities with Elevated Risk in
Docket UG-120715, that utilities filing an annual cost recovery

DOCKET U-210151 PAGE 7
ORDER 01
mechanism tariff filing must update projected costs twice between the
initial filing and the rate-effective date;
(5) Modify the requirement that Puget Sound Energy file quarterly a PCA
Report, established in Order 11 of Docket UE-130617 (approving the
Settlement Stipulation in that docket), from a quarterly filing frequency to
an annual filing frequency;
(6) Modify the requirement that Avista file a monthly ERM Deferral Report,
established in the 5th Supplemental Order of Docket UE-011595
(approving the Settlement Stipulation in that docket), from a monthly
filing frequency to an annual filing frequency; and
(7) Modify the requirement that Avista file a Decoupling Mechanism
Quarterly Report, established in Order 05 of Dockets UE-140188 and UG-
140189 (approving the Settlement Stipulation in that docket), from a
quarterly filing frequency to an annual filing frequency.
ORDER
THE COMMISSION ORDERS:
20 (1) The recommendations to eliminate or consolidate reporting requirements as
proposed in Appendix A to the Commission's May 9, 2023,Notice for
Opportunity to File Written Comments, and contained in paragraph 19 of this
Order, are reasonable and will reduce administrative burden and may go into
effect on March 14, 2024.
21 (2) The Commission authorizes the Commission Secretary to accept by letter a filing
that complies with the requirements of this Order.

DOCKET U-210151 PAGE 8
ORDER 01
22 (3) The Commission retains jurisdiction over the subject matter and the utilities listed
in this Order to effectuate the provisions of this Order.
DATED at Lacey, Washington, and effective March 14, 2024.
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION
DAVID W. DANNER, Chair
ANN E. RENDAHL, Commissioner
MILTON H. DOUMIT, Commissioner

Service Date: March 22,2024
BEFORE THE WASHINGTON
UTILITIES AND TRANSPORTATION COMMISSION
In the Matter of DOCKET UE-210628
AVISTA UTILITIES d/b/a AVISTA ORDER 02
CORPORATION'S
Clean Energy Implementation Plan CONDITIONS ADOPTED BY THE
COMMISSION IN ORDER 02
Appendix A
Avista 2023 Biennial Update to the Clean Energy Implementation Plan
List of Conditions
Revised Condition 5:
In future CEIPs, and in Biennial CEIP Updates if Avista proposes to modify its approved interim
targets, it will include descriptions of quantitative (i.e., cost based) and qualitative (e.g., equity
considerations) analyses that support interim targets to comply with the Clean Energy
Transformation Act's (CETA) 2030 and 2045 clean energy standards.
New Condition 39:
In its 2025 CEIP, Avista will include a description of the work it completed between its 2021
CEIP and 2025 CEIP to expand its Vulnerable Populations, including an overview of all actions
and evaluations completed, as well as summaries of discussion and input from its advisory
groups. Further, it will specify the methodology used to identify Vulnerable Populations in its
2025 CEIP and a comparison of Vulnerable Populations between the 2021 and 2025 CEIP.

Service Date: March 22,2024
BEFORE THE WASHINGTON
UTILITIES AND TRANSPORTATION COMMISSION
In the Matter of DOCKET UE-210628
AVISTA CORPORATION d/b/a ORDER 02
AVISTA UTILITIES
Clean Energy Implementation Plan APPROVING CEIP BIENNIAL UPDATE
SUBJECT TO CONDITIONS
BACKGROUND
1 Revised Code of Washington (RCW) 19.405, Washington's Clean Energy Transformation
Act(CETA), and Washington Administrative Code (WAC)480-100-640(l) direct electric
investor-owned utilities to develop a clean energy implementation plan(CEIP or Plan)
every four years. The passage of CETA during the 2019 Washington Legislative Session
requires that CEIPs be informed by both a utility's clean energy action plan and its long-
term integrated resource plan.'
2 On October 1, 2021,Avista Corporation d/b/a Avista Utilities (Avista or Company) filed
the Company's first CEIP, as required by WAC 480-100-640. This CEIP was approved by
the Commission in Docket UE-210628 Order 01 subject to 37 conditions, referenced
herein by Order 01 or by condition number. The conditions in Order 01 are to be met
throughout the compliance period covering 2022-2025, some of which are relevant to this
Biennial Update.
3 On November 1, 2023,Avista filed its first Biennial Update to the 2021 CEIP with the
Washington Utilities and Transportation Commission(Commission). The Biennial
Update is required by Commission rules implementing the Clean Energy Transformation
Act(CETA).2
1 In re Adopting Rules Relating to Clean Energy Implementation Plans and Compliance with the
Clean Energy Transformation Act and Amending or Adopting rules relating to WAC 480-100-238,
Relating to Integrated Resource Planning, Dockets UE-191023 &UE-109698 (Consolidated),
General Order 601,p. 24,¶59 (Dec. 28, 2020) (General Order R-601).
2 WAC 480-100-640(11),see also WAC 480-109-120(1).

DOCKET UE-210628 PAGE 2
ORDER 02
4 On January 11, 2024, Commission Staff(Staff), Public Counsel, and the Northwest
Energy Coalition(NWEC) submitted responsive comments on the Biennial Update.
5 On January 26, 2024,Avista filed reply comments in which the Company proposed one
new condition and one revision to an existing condition.
6 On March 11, 2024, at the request of several parties,Avista filed a corrected revised
Biennial Update to include information from its reply comments in the Biennial Update
itself.
7 Staff notes that Avista did not propose any modifications to its interim targets, clean
energy, or demand response targets in the Biennial Update. Since there don't appear to be
circumstances that would warrant modifying the targets, Staff supports the Company
continuing with the existing targets.
8 Avista did propose reductions to the energy efficiency(EE)target based upon changes to
its 2024-2025 Biennial Conservation Plan(BCP), which was filed concurrently with the
Biennial Update. Staff filed more extensive comments relating to the 2024-2025 BCP and
its targets and programs in Docket UE-230897. For the purposes of the Biennial Update,
Staff does not oppose these reduced EE targets at this time.
9 Staff submits that since Avista did not propose changes to its interim targets and because
there were no significant changes from the 2021 CEIP, the content of the comments from
Staff and other interested parties was primarily focused on evaluating how well Avista
complied with the various conditions from Order 01.As such, Staff, Public Counsel,
NWEC, and other interested parties to the 2021 CEIP swiftly reached consensus on the
one additional condition and one revised condition that Avista proposed.
10 In comments filed on January 11, 2024, Staff expressed concern with what appeared to be
only partial compliance with condition 5 of Order 01.3 Staff discussed with the Company
that to fully comply with this condition as written,Avista needed to have provided
qualitative and quantitative analysis that supported its interim targets in this Biennial
Update. Public Counsel and NWEC shared similar concerns in their filed comments. In
its reply comments,Avista explained that the interim targets didn't change in this
Biennial Update from the negotiations following the 2021 CEIP. The Company also
3 In re Avista Corporation's 2021 Clean Energy Implementation Plan, Docket UE-210628,
Commission Staff comments regarding Avista Utilities'2021 Clean Energy Implementation Plan
Biennial Update at 7-8 (Jan. 11,2024).

DOCKET UE-210628 PAGE 3
ORDER 02
explained that because the targets were negotiated with other Parties as opposed to
resultant from modeling or internal decision-making, the Company does not have such
analysis to support the approved targets.4
11 In discussions with the Company since it filed the Biennial Update, Staff and other
interested parties have agreed that the best solution to this concern is to make a revision
to the original condition 5. The following is revised condition 5 language:
In future CEIPs, and in Biennial CEIP Updates if Avista proposes to modify its
approved interim targets, it will include descriptions of quantitative (i.e., cost-
based) and qualitative (e.g., equity considerations) analyses that support interim
targets to comply with the Clean Energy Transformation Act's (CETA) 20230 and
2045 clean energy standards.
12 Staff supports this revision because it requires Avista to provide the desired analysis in
support of its interim targets if they change but does not put the Company in the position
of trying to retroactively provide analysis for negotiated targets, or targets that have not
changed since last review. Staff believes other interested parties are in support of this
revision.
13 In comments, Staff detailed how it was concerned with what appeared to be only partial
compliance with condition 9.5 Staff detailed that to fully comply with this condition as
written,Avista needed to have submitted clearly updated and expanded Vulnerable
Population areas in this Biennial Update. Public Counsel and NWEC shared similar
concerns in their filed comments. In its reply comments,Avista explained that while they
did extensive work on this condition, the Company was admittedly not clear in its
Biennial Update about everything it has been doing to fulfill this condition.'
4 In re Avista Corporation's 2021 Clean Energy Implementation Plan, Docket UE-210628,Avista
Reply Comments at 2 (Jan. 26,2024).
5 In re Avista Corporation's 2021 Clean Energy Implementation Plan, Docket UE-210628,
Commission Staff comments regarding Avista Utilities'2021 Clean Energy Implementation Plan
Biennial Update at 9 (Jan. 11,2024).
6"`Vulnerable populations'means communities that experience a disproportionate cumulative
risk from environmental burdens due to: (a)Adverse socioeconomic factors, including
unemployment,high housing, and transportation costs relative to income,access to food and
health care, and linguistic isolation; and(b) Sensitivity factors, such as low birth weight and
higher rates of hospitalization."RCW 19.405.020(40).
7 In re Avista Corporation's 2021 Clean Energy Implementation Plan, Docket UE-210628,Avista
Reply Comments at 3-5 (Jan. 26,2024).

DOCKET UE-210628 PAGE 4
ORDER 02
14 To remedy the lack of clarity,Avista offered the following new condition:
In its 2025 CEIP,Avista will include a description of the work it completed
between its 2021 CEIP and 2025 CEIP to expand its Vulnerable Populations,
including an overview of all actions and evaluations completed, as well as
summaries of discussion and input from its advisory groups. Further, it will
specify the methodology used to identify Vulnerable Populations in its 2025 CEIP
and a comparison of Vulnerable Populations between the 2021 and 2025 CEIP.
15 Staff supports this new condition because Staff believes that what Avista submitted for
this condition in the Biennial Update was lacking in clarity.Avista's reply comments help
to detail more of the work the Company has done ahead of this filing,but Staff agrees
with the Company that to satisfy Staff and other Parties'concerns, the Company should
provide this additional information in the 2025 CEIP. The other Parties have indicated
they are in support of this new condition.
16 This condition would be in addition to the 38 conditions approved in Order 01.
17 Due to the lack of modifications, and because Staff supports the revision to condition 5
and Avista's proposed new condition, Staff recommends the Commission issue an order
in Docket UE-210628 approving Avista's Biennial Update to its CEIP, subject to the
conditions in Appendix A.
DISCUSSION
18 We approve Avista's Biennial Update, subject to the conditions to which the Parties
agree contained in Appendix A.
19 RCW 19.405.060(1)requires electric utilities to develop and submit to the Commission
CEIPs every four years. The CEIPs must meet specific criteria. WAC 480-100-640 sets
out the targets, data, and narrative information that must be included in those plans. WAC
480-100-640(11)requires the utilities to make a biennial CEIP update filing on or before
November 1 st of each odd-numbered year that the utility does not file a CEIP.
20 We are pleased that the discussions between the Parties resulted in agreement regarding
Avista's interim targets and additional changes and additions to conditions.

DOCKET UE-210628 PAGE 5
ORDER 02
21 We agree with Staff that condition 5 should be amended, requiring Avista to provide the
desired analysis in support of its interim targets if they change. This revision, as Staff
notes, avoids putting the Company in the position of retroactively providing analysis for
negotiated targets, or targets that have not changed since the last review.
22 We also agree with Staff and the Parties in adding a new condition requiring Avista to
detail efforts made to expand its Vulnerable Populations and provide its methodology
used to identify Vulnerable Populations in its 2025 CEIP. We believe this condition will
address the concerns of the Parties and provide further clarity moving forward.
23 Avista's CEIP was the first the Commission considered, and we are now considering
biennial updates from electric utilities for the first time. We commend the Company,
Staff, Public Counsel, and NWEC for working collaboratively to improve Avista's CEIP,
reviewing Avista's performance with the conditions placed on the Company with the
approval of the 2021 CEIP, and for working to clarify and add conditions to benefit all
customers. Accordingly, we approve of Avista's CEIP subject to the conditions set out in
Appendix A to this Order which includes Staff s recommended conditions of revising one
condition and adding one condition.
FINDINGS AND CONCLUSIONS
24 (1) The Commission is an agency of the State of Washington vested by statute with
the authority to regulate the rates, regulations,practices, accounts, and affiliated
interests of public service companies and electric companies.
25 (2) Avista is engaged in the business of providing electric and natural gas services
within the state of Washington and is a public service company subject to
Commission jurisdiction.
26 (3) This matter came before the Commission at its regularly scheduled meeting on
March 22, 2024.
27 (4) Avista is required to make a biennial CEIP update filing on or before November
1 st of each odd-numbered year that the utility does not file a CEIP.
28 (5) After review of the Biennial Update, filed on November 1, 2023, and
subsequently filed comments and giving due consideration, the Commission finds
that Avista's CEIP Biennial Update is consistent with the public interest,

DOCKET UE-210628 PAGE 6
ORDER 02
consistent with the requirements of WAC 480-100-640(11), and that it should be
approved subject to the conditions set out in Appendix A to this Order.
ORDER
THE COMMISSION ORDERS:
29 (1) Avista Corporation d/b/a Avista Utilities' Clean Energy Implementation Plan
Biennial Update meets the requirements of WAC 480-100-640(11) and should be
approved subject to the conditions set out in Appendix A to this Order.
30 (2) The Commission retains jurisdiction over the subject matter and Avista Utilities
d/b/a Avista Corporation to effectuate the provisions of this Order.
DATED at Lacey, Washington, and effective March 22, 2024.
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION
DAVID W. DANNER, Chair
ANN E. RENDAHL, Commissioner
MILTON H. DOUMIT, Commissioner

Service Date: February 22, 2024
BEFORE THE WASHINGTON
UTILITIES AND TRANSPORTATION COMMISSION
In the Matter of the Petition of the DOCKET UE-230345
AVISTA CORPORATION d/b/a AVISTA ORDER 01
UTILITIES,
Petitioner, GRANTING ACCOUNTING
PETITION
For an Order Authorizing Accounting
Deferral of Electric Costs Related to
Compliance with the Climate Commitment
Act and including FERC Account 509 in
the Energy Recovery Mechanism.
BACKGROUND
1 On May 10, 2023,Avista Corporation d/b/a Avista Utilities (Avista or Company) filed
with the Washington Utilities and Transportation Commission(Commission) a petition in
Docket UE-230345 (Petition) seeking an accounting order under WAC 480-07-370
authorizing Avista to (1) defer certain electric costs associated with the Company's
compliance with the Washington Climate Commitment Act(CCA), and(2) to include in
its Energy Recovery Mechanism (ERM) Federal Energy Regulatory Commission
(FERC)Account 509.X,Allowances, due to uncertainty if Avista must purchase carbon
allowances to cover Washington's share of surplus sales delivered to the Mid-Columbia
(Mid-C) trading hub that require an associated carbon allowance per the CCA.
2 In 2021, the Washington State Legislature passed the CCA through Engrossed Substitute
Senate Bill 5126 into law, codified as RCW 70A.65. Washington State Department of
Ecology (Ecology) was directed to develop and implement rules for a cap-and-invest
program, referred as the CCA, which is designed to meet emission reduction targets and
reduce emissions by 95 percent of 1990 levels by 2050.' On September 29, 2022,
Ecology issued their final rules to require all Washington-based electric utilities to secure
enough allowances to cover the carbon emissions of imported power and generation from
Washington based sources emitting 25,000 metric tons or more annually.
' See Climate Commitment Act-Washington State Department of Ecology.

DOCKET UE-230345 PAGE 2
ORDER 01
3 According to WAC 173-446-230, "Allowances will be allocated to qualifying electric
utilities for the purposes of mitigating the cost burden of the program based on the cost
burden effect of the program."Under the CCA and Washington Clean Energy
Transformation Act(CETA),Avista is qualified to receive no-cost allowances from
Ecology. Ecology uses a forecast of supply and demand approved by the Commission to
calculate the amount of no-cost allowances for all Washington-based electric utilities.
4 In late April, Ecology calculated Avista's no-cost allowance for 2023 to 2026, which was
lower than Avista's expectation from the forecast approved by the Commission in
January 2023.As a result, in June 2023,Avista filed a revised forecast, approved by the
Commission in July 2023, which increased the amount of no-cost allowances the
Company would receive from Ecology. Due to ongoing uncertainty over the amount of
no-cost allowances Avista will ultimately receive for its Washington generation,
particularly for surplus sales that are made to lower power supply costs for its customers,
Avista may need to procure allowances to cover its surplus sales, which would have a
cost impact to its Washington electric customers.
5 In the Petition,Avista requests approval for electric costs related to carbon allowance
expense incurred to be deferred to account 182.3, starting January 1, 2023, when the
CCA program began, through June 30, 2023, or until the Commission issues an order on
this matter.
6 In addition to the deferral, the Company requests to record the emission expenses related
to Washington's carbon allowance obligation to account 509.X and include that account
in the Company's ERM calculation. In June 2023, FERC issued an order approving the
final rules in Docket RM21-11-000, which provides guidance on the accounting
treatment for renewable energy credits and emission allowances. In the guidance, 509.X
was the recommended expense FERC account for emission allowances.
7 Commission Staff(Staff) recommends that the Commission grant the request. Staff
believes deferred accounting treatment is reasonable because CCA costs are likely to be
uncertain.
8 Staff approached other interested parties for comments on this accounting petition. No
comment was raised.

DOCKET UE-230345 PAGE 3
ORDER 01
DISCUSSION
9 We grant Avista's Petition. We agree that the requirements of the CCA create an
extraordinary and uncertain circumstance as this is a cost beyond the Company's control.
We believe that deferred accounting treatment is appropriate.
10 We find it appropriate for the Company to track its CCA compliance costs in FERC
account 182.3.
11 We therefore grant the Petition that the Company must: (1) defer certain electric costs
associated with the Company's compliance with the Washington Climate Commitment
Act(CCA), and(2) to include in its Energy Recovery Mechanism (ERM) FERC Account
509.X,Allowances, due to uncertainty if Avista must purchase carbon allowances to
cover Washington's share of surplus sales delivered to the Mid-Columbia(Mid-C)
trading hub that require an associated carbon allowance according to the CCA.
FINDINGS AND CONCLUSIONS
12 (1) The Commission is an agency of the State of Washington vested by statute with
the authority to regulate the rates, rules, regulations, practices, accounts,
securities, transfers of property and affiliated interests of public service
companies, including electric and natural gas companies.
13 (2) Avista is a public service company regulated by the Commission, providing
service as an electric and natural gas company.
14 (3) The Commission has jurisdiction over the subject matter of this proceeding and
over Avista.
15 (4) WAC 480-07-370(3) allows companies to file petitions including that for which
Avista seeks approval.
16 (5) Staff has reviewed the Petition in Docket UE-230345 including related work
papers.
17 (6) Staff recommends the Commission grant the Petition.

DOCKET UE-230345 PAGE 4
ORDER 01
18 (7) This matter came before the Commission at its regularly scheduled meeting on
February 22, 2024.
19 (8) After reviewing Avista's Petition filed in Docket UE-230345 on May 10, 2023,
and giving due consideration to all relevant matters and for good cause shown,
the Commission finds that the Petition should be granted.
ORDER
THE COMMISSION ORDERS:
20 (1) Avista Corporation d/b/a Avista Utilities'Petition for an Order Authorizing
Accounting Petition is granted, that the Company must: (1) defer certain electric
costs associated with the Company's compliance with the Washington Climate
Commitment Act(CCA), and(2) to include in its Energy Recovery Mechanism
FERC Account 509.X,Allowances, due to uncertainty if Avista Corporation d/b/a
Avista Utilities must purchase carbon allowances to cover Washington's share of
surplus sales delivered to the Mid-Columbia trading hub that require an
associated carbon allowance according to the CCA.
21 (2) This Order shall not affect the Commission's authority over rates, services,
accounts, valuations, estimates, or determination of costs, on any matters that
may come before it. Nor shall this Order granting Petition be construed as an
agreement to any estimate or determination of costs, or any valuation of property
claimed or asserted.
22 (3) The Commission retains jurisdiction over the subject matter and Avista
Corporation d/b/a Avista Utilities to effectuate the provisions of this Order.

DOCKET UE-230345 PAGE 5
ORDER 01
23 The Commissioners, having determined this Order to be consistent with the public
interest, directed the Secretary to enter this Order.
DATED at Lacey, Washington, and effective February 22, 2024.
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION
Jeff Killip
Executive Director and Secretary

Service Date: February 22, 2024
BEFORE THE WASHINGTON
UTILITIES AND TRANSPORTATION COMMISSION
In the Matter of the Petition of the DOCKET UE-230681
AVISTA CORPORATION d/b/a AVISTA ORDER 01
UTILITIES,
Petitioner, GRANTING ACCOUNTING
PETITION
For an Order Authorizing Recording of
incremental costs of the Chelan PPA above
the current MWh threshold in FERC
Account 555, Power Supply Expense.
BACKGROUND
1 On December 1, 2023 Avista Corporation d/b/a Avista Utilities (Avista or Company) filed
with the Washington Utilities and Transportation Commission (Commission) an
Amended Petition (Petition) for an Accounting Order in Docket UE-230681 to request to
record the incremental cost of the Chelan power purchase agreement (PPA) above the
$40.87/MWH threshold in Federal Energy Regulatory Commission (FERC)Account
555, Power Supply Expense, in accordance with RCW 80.28.410.
2 In Avista's 2006 Order 03 under Docket UE-060181, for continuation of the Company's
Energy Recovery Mechanism (ERM), with Certain Modifications, excluded costs of new
Power Supply Contracts in excess of the average embedded cost of power supply from
inclusion in power supply costs until such time as the contract is incorporated in base
rates pursuant to a general rate case.
3 RCW 80.28.410 allows electrical companies to defer for later consideration costs
associated with power purchase agreements from the effective date of the agreement until
the effective date of a general rate case or other proceeding incorporates costs into base
rates as long as the costs are incurred in connection with the Company's clean energy
action plan.
4 Avista's 2020 Integrated Resource Plan identified the need for additional renewable
resources in order to meet the Company's clean energy goals and the Clean Energy

DOCKET UG-230681 PAGE 2
ORDER 01
Transformation Act requirements of carbon neutrality by 2027 and 100 percent clean
electricity by 2045.
5 On June 26, 2020,Avista issued a Request for Proposals (RFP) which resulted in bids
from over 20 interested parties for over 40 renewable projects located throughout the
Pacific Northwest.
6 The Company closed out the 2020 RFP with several new contracts with Chelan. One of
which is effective January 1, 2024, and priced at $45.67 per MWh, while the allowable
amount to be included in the ERM is currently only $40.87 per MWh.
7 Commission Staff(Staff) recommends that the Commission grant the request. Staff
believes recording of incremental costs of the Chelan PPA above the current MWh
threshold is reasonable given the current language of RCW 80.28.410 allowing utilities
to account for and defer for recovery costs of contracts secured in connection with its
clean energy action plan.
8 Staff approached other interested parties for comments on this accounting petition. No
comment was raised.
DISCUSSION
9 We grant Avista's Petition. We agree that RCW 80.28.410 allows for utilities to account
for and defer costs of contracts secured in connection with its clean energy action plan.
We believe that recording of the incremental costs of the Chelan PPA above the current
MWh threshold is appropriate.
10 We find it appropriate for the Company to record the incremental costs in FERC account
555.
11 We therefore grant the Petition that the Company must: record and defer the incremental
cost of the Chelan PPA above the $40.87/MWH threshold in Federal Energy Regulatory
Commission Account 555, Power Supply Expense, in accordance with RCW 80.28.410,
beginning January 1, 2024, and ending on the effective date of the Company's next
general rate case.

DOCKET UG-230681 PAGE 3
ORDER 01
FINDINGS AND CONCLUSIONS
12 (1) The Commission is an agency of the State of Washington vested by statute with
the authority to regulate the rates, rules, regulations, practices, accounts,
securities, transfers of property and affiliated interests of public service
companies, including electric and natural gas companies.
13 (2) Avista is a public service company regulated by the Commission, providing
service as an electric and natural gas company.
14 (3) The Commission has jurisdiction over the subject matter of this proceeding and
over Avista.
15 (4) WAC 480-07-370(3) allows companies to file petitions including that for which
Avista seeks approval.
16 (5) Staff has reviewed the Petition in Docket UE-230681 including related work
papers.
17 (6) Staff recommends the Commission grant the Petition.
18 (7) This matter came before the Commission at its regularly scheduled meeting on
February 22, 2024.
19 (8) After reviewing Avista's Petition filed in Docket UE-230681 on December 1,
2023, and giving due consideration to all relevant matters and for good cause
shown, the Commission finds that the Petition should be granted.
ORDER
THE COMMISSION ORDERS:
20 (1) Avista Corporation d/b/a Avista Utilities'Petition for an Order Authorizing
Accounting Petition is granted, that the Company must record and defer the
incremental cost of the Chelan PPA above the $40.87/MWh threshold in FERC
Account 555, Power Supply Expense, in accordance with RCW 80.28.410,
beginning January 1, 2024, and ending on the effective date of the Company's
next general rate case.

DOCKET UG-230681 PAGE 4
ORDER 01
21 (2) This Order shall not affect the Commission's authority over rates, services,
accounts, valuations, estimates, or determination of costs, on any matters that
may come before it. Nor shall this Order granting Petition be construed as an
agreement to any estimate or determination of costs, or any valuation of property
claimed or asserted.
22 (3) The Commission retains jurisdiction over the subject matter and Avista
Corporation d/b/a Avista Utilities to effectuate the provisions of this Order.
23 The Commissioners, having determined this Order to be consistent with the public
interest, directed the Secretary to enter this Order.
DATED at Lacey, Washington, and effective February 22, 2024.
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION
Jeff Killip
Executive Director and Secretary

Service Date: March 28,2024
BEFORE THE WASHINGTON
UTILITIES AND TRANSPORTATION COMMISSION
In the Matter of the Petition of DOCKET UG-231044
AVISTA CORPORATION d/b/a ORDER 01
AVISTA UTILITIES,
Petitioner, ALLOWING TARIFF TO GO INTO
To Approve Tariff Revisions Regarding EFFECT, SUBJECT TO CONDITIONS
Climate Commitment Act
BACKGROUND
1 On December 22, 2023, in Docket UG-231044, Avista Corporation d/b/a Avista Utilities
(Avista or Company) filed with the Washington Utilities and Transportation Commission
(Commission), proposed revisions to rates under natural gas Tariff WN U-29, Schedule
162, Climate Commitment Act(CCA) Temporary Schedule.
2 On February 22, 2024, Avista filed with the Commission substitute tariff pages extending
the effective date of the tariff revisions to April 1, 2024.
3 On February 22, 2024, this docket was discussed during the Commission's regularly
scheduled Open Meeting.
4 At the February 22, 2024, Open Meeting, the Commissioners were generally supportive
of Avista's proposed tariff, but expressed concern with Avista's proposal to establish a
nonvolumetric charge rate for its Schedule 101 customers. As a result, that same day
Avista filed substitute tariff pages with the Commission. The substitute tariff pages
extend the effective date of the tariff revisions to April 1, 2024.
5 On March 4, 2024, Avista filed additional substitute tariff pages reflecting modifications
to the proposed tariff that Avista made in response to Commissioner feedback during the
February 22, 2024, Open Meeting. The March 4, 2024, revised tariff pages include a
volumetric rate for all customers, including Schedule 101 customers.
6 With this filing, Avista seeks to establish a new, temporary tariff schedule to pass on to
customers CCA compliance costs and auction proceeds that the Company recorded in

DOCKET UG-231044 PAGE 2
ORDER 01
calendar year 2023 and deferred per Order 01 of Docket UG-220803. Avista is proposing
Schedule 162 as a temporary schedule that would be set to expire on March 31, 2025,
after the 12-month amortization of the 2023 deferral balances.
7 Avista's proposed Schedule 162 would establish a volumetric charge rate to recover $46
million in deferred expenses for allowance purchases and establish a seasonal,
nonvolumetric credit to return to customers $37.2 million in deferred revenues from no-
cost allowances consigned to auction. The net effect of the proposed revisions is a $10.3
million increase in annual revenues, or a 4.1 percent increase. A typical residential
customer using an average of 64 therms per month would see an increase of$1.33 per
month in summer months' and an increase of$5.45 per month in winter months,2
equating to an average increase over the year of approximately $3.06 per month, or 3.3
percent.3 Known low-income (KLI) customers would receive a credit that fully offsets
the increase in the CCA charge rate, resulting in a$0.00 change in rates for those
customers.
8 Commission staff(Staff) has reviewed the substitute tariff pages filed by the Company on
February 22, 2024, and March 4, 2024, as well as the Company's earlier filings prior to
the February 22, 2024, Open Meeting. Staff observes that Avista has appropriately
modified its proposed Schedule 162 in response to the Commissioners' concerns,
replacing the nonvolumetric charge for its Schedule 101 customers with a volumetric
charge rate. Staff supports Avista's movement to a volumetric charge. As Staff has
previously noted, a nonvolumetric charge rate does not follow fundamental cost-of-
service principles and unfairly requires lower-usage customers to subsidize the carbon
emissions costs of higher-usage customers.
9 As noted in Staff s February 22, 2024, Open Meeting Memo, on February 8, 2024,
Northwest Energy Coalition(NWEC) filed comments expressing opposition to the
nonvolumetric charge that Avista initially proposed for its Schedule 101 customers.
Avista is no longer proposing a nonvolumetric charge for its Schedule 101 customers, so
Staff submits that this issue has been resolved. No additional comments were filed.
1 Defined as April through October.
2 Defined as November through March.
'A typical residential customer with a premise connected to the system after July 25, 2021, and
using an average of 64 therms per month would see an increase of$14.96 per month, or 16.1
percent.

DOCKET UG-231044 PAGE 3
ORDER 01
10 In the substitute tariff pages, Avista also replaced the nonseasonal nonvolumetric credit
for Schedule 101 customers with a seasonal nonvolumetric credit. Staff is supportive of
this change. As Staff explained in its February 22, 2024, memo, a seasonal credit rate is
appropriate when the charge rate is volumetric as it provides customers with a larger
credit during months of higher usage. Given that Avista is now proposing a volumetric
charge rate for its Schedule 101 customers, Staff believes it is appropriate for Avista to
also propose a seasonal credit for those customers.
11 Staff also notes that Avista revised its proposed cap on the volumetric credits from 75
percent of the monthly charge to 80 percent of the monthly charge. Staff supports
implementing a credit cap and finds Avista's revised cap of 80 percent to be appropriate
given that 80 percent more closely reflects the ratio of CCA benefits to costs in 2023.
12 Also discussed during the February 22, 2024, Open Meeting was Avista's proposal to not
include a line-item charge or credit on bills for Schedule 101 customers. Avista continues
to propose that it would not identify the CCA charge or CCA credit for those customers
and continues to propose both the CCA charge and CCA credit would appear as line
items on bills for all other customers.
13 Staff notes that, given that Avista's proposed Schedule 162 is a temporary schedule, and
that it pertains to 2023 deferral balances, Staff does not believe that it is necessary to
establish policy on this issue at this time. Staff comments that whether CCA charges and
credits should be shown on customer bills remains an open policy question for the
Commission, but Staff does not oppose Avista's proposal for this filing.
14 Staff finally provides comments on prudency. Staff notes that, in Avista's initial filing on
December 22, 2023, the proposed tariff rates were based on dollar amounts that contained
forecasted amounts for December 2023. Given that the proposed rates included
forecasted costs, there would have been a need for a tracking and true-up deferral
mechanism so that forecasted amounts could later be trued up to actuals. With such
mechanisms, actual costs are reviewed retrospectively and, accordingly, the
Commission's prudency standard is also applied retrospectively.
15 However, in the replacement tariff pages filed March 4, 2024, the Company updated the
December forecasts to actuals such that the proposed tariff rates are now based on known
actuals for calendar year 2023. Given that the proposed rates are now actuals, Staff
submits that there is no longer a need for a true-up at the end of the rate year. Yet without

DOCKET UG-231044 PAGE 4
ORDER 01
an annual true-up filing, absent Commission action here in this docket, there will not be
another opportunity to retrospectively examine these costs or assess their prudence.
16 To preserve its ability to examine the prudence of the costs at issue in this filing, Staff
recommends that the Commission authorize Avista's Schedule 162 rates subject to later
review and possible refund. As Staff has previously indicated, Staff believes that the
prudence of CCA compliance costs should be examined across the full, four-year
compliance window (2023-2026) and in a rigorous dedicated proceeding of sufficient
length to allow Staff and other parties to perform a rigorous examination of prudence.
17 Staff has not received any comments from the public on this filing.
DISCUSSION
18 The Commission agrees with Staff that the Company's tariff revisions, as revised on
March 4, 2024, should be approved subject to the condition that Schedule 162 rates will
be approved subject to later review and possible refund, giving the Commission an
opportunity to review the prudency of compliance costs throughout the compliance
period at a later time.
19 We are appreciative of Avista and Staff for working to review and respond to feedback
throughout this process.
20 We agree with Staff and find that a volumetric charge for all customers—including
Schedule 101 customers—follows fundamental cost-of-service principles and more fairly
distributes CCA charges and CCA credits amongst customers based on their usage. We
also agree with Staff and find that because all customers will be charged volumetrically,
that a seasonal credit rate is appropriate. We further agree that increasing the cap on
nonvolumetric credits to 80 percent from 75 percent of the monthly charge is appropriate
as it better reflects the benefits to costs ratio for Avista's CCA compliance in 2023.
21 Regarding line-item charges, we agree with Staff that the question of whether CCA
charges and CCA credits should be shown as a line item on customer bills remains an
open one. We further agree with Staff that deciding the issue is not necessary in this
docket. We will allow Avista's proposal to include line-item charges and credits for non-
Schedule 101 customers and to not include line-item charges or credits for Schedule 101
customers for this temporary Schedule 162, which will expire in a year. This decision

DOCKET UG-231044 PAGE 5
ORDER 01
should not be considered precedential for future dockets involving CCA costs and CCA
credits for Avista or other regulated utilities.
22 Finally, we agree with Staff that the Schedule 162 charge and credit rates that the
Company proposes in this docket should be authorized. However, we make no finding
regarding the prudence of these charges and credits at this time. Instead, we authorize the
proposed rates on a provisional basis, subject to later review and possible refund. The
prudency of the rates will be examined in a dedicated proceeding at a later date when
CCA compliance costs over the full, four-year compliance period may be reviewed.
FINDINGS AND CONCLUSIONS
23 (1) The Commission is an agency of the State of Washington vested by statute with
the authority to regulate the rates, regulations,practices, accounts, and affiliated
interests of public service companies.
24 (2) Avista is engaged in the business of providing electric and natural gas services
within the state of Washington and is a public service company subject to
Commission jurisdiction.
25 (3) This matter came before the Commission at its regularly scheduled meeting on
March 28, 2024.
26 (4) After review of the tariff revisions filed in Docket UG-231044 by Avista on
December 22, 2023, as revised on March 4, 2024, and giving due consideration,
the Commission finds that the tariff revisions should be authorized on a
provisional basis, subject to the condition that the prudency of the rates will be
reviewed at a later date.
ORDER
THE COMMISSION ORDERS:
27 (1) The tariff revisions filed by Avista Corporation d/b/a Avista Utilities filed
December 22, 2023, as revised on March 4, 2024,may go into effect on April 1,
2024, subject to the condition set forth in paragraph 26 of this Order.
28 (2) The Commission authorizes the Commission Secretary to accept by letter a filing
that complies with the requirements of this Order.

DOCKET UG-231044 PAGE 6
ORDER 01
29 (3) The Commission retains jurisdiction over the subject matter and Avista
Corporation d/b/a Avista Utilities to effectuate the provisions of this Order.
DATED at Lacey, Washington, and effective March 28, 2024.
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION
DAVID W. DANNER, Chair
ANN E. RENDAHL, Commissioner
MILTON H. DOUMIT, Commissioner