20250708Direct D. English .pdf

RECEIVED
July 08, 2025
BEFORE THE IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S APPLICATION ) CASE NOS. AVU-E-25-01 ;
FOR THE AUTHORITY TO ) AVU-G-25-01
INCREASE ITS RATES AND )
CHARGES FOR ELECTRIC AND )
NATURAL GAS SERVICE TO )
ELECTRIC AND NATURAL GAS )
CUSTOMERS IN THE STATE OF )
IDAHO )
DIRECT TESTIMONY OF DONN ENGLISH
IN SUPPORT OF THE STIPULATION
AND SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
JULY 8, 2025

1 Q. Please state your name and business address .
2 A. My name is Donn English. My business address is
3 11331 W. Chinden Blvd. , BLDG 8, STE 201-A, Boise, Idaho
4 83714 .
5 Q. By whom are you employed and in what capacity?
6 A. I am employed by the Idaho Public Utilities
7 Commission ("Commission") as the Deputy Division
8 Administrator for the Utilities Division.
9 Q. Please describe your educational background and
10 professional experience .
11 A. I was hired by the Commission in 2003 and I have
12 provided testimony in numerous proceedings . My educational
13 background and professional experience are provided in more
14 detail in Exhibit No . 101 .
15 Q. What is the purpose of your testimony in this
16 proceeding?
17 A. The purpose of my testimony is to describe the
18 Application filed by Avista Corporation ("Avista" or
19 "Company") to increase its rates and charges for electric
20 and natural gas service in Idaho, describe the proposed
21 comprehensive Stipulation and Settlement ("Stipulation")
22 reached by the signing parties in this case, and explain
23 Staff' s support for the settlement .
24 Q. How is your testimony organized?
25 A. My testimony is subdivided under the following
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 1
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I headings :
2 Background Page 2
3 Staff Investigation Page 3
4 Settlement Evaluation Page 5
5 Settlement Overview Page 6
6 Background
7 Q. Please describe Avista' s original filing.
8 A. Avista filed its Application to increase rates
9 and charges for electric and natural gas service in Idaho
10 on January 31, 2025 . Consistent with its previous general
11 rate case filings, the Company requested a two-year rate
12 plan to increase its revenue . The Company requested
13 authority to increase its electric base revenue in Idaho by
14 $43 . 0 million, or 14 . 0o, effective September 1, 2025 ("Rate
15 Year 1") , and an additional $17 . 7 million, or 5 . 0o,
16 effective September 1, 2026 ("Rate Year 2") . For natural
17 gas service in Idaho, the Company requested an increase in
18 base revenues of $8 . 8 million (17 . 70) for Rate Year 1, and
19 $1 . 0 million (1 . 70) for Rate Year 2 .
20 The Company' s requested increases were based on a
21 historical test period ending June 30, 2024, with pro forma
22 adjustments through August 31, 2026, for the first increase
23 in the two-year plan, and August 31, 2027, for the second
24 increase . Capital additions through August 31, 2026, were
25 included in the Company' s proposed Rate Year 1 and
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 2
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1 calculated on an Average of Monthly Averages ("AMA") basis .
2 For Rate Year 2, capital additions were included through
3 August 31, 2027, and were also calculated on an AMA basis .
4 The Company proposed a hypothetical capital
5 structure consisting of 50o equity and 50o debt, with a
6 return on equity ("ROE") of 10 . 4% for an overall weighted
7 average cost of capital of 7 . 680 .
8 Additionally, the Company requested to increase
9 its monthly Basic Charges . For residential customers, the
10 Company proposed to increase its Basic Charge from $20 . 00
11 per month to $25 . 00 per month effective September 1, 2025,
12 and to $30 . 00 per month effective September 1, 2026 .
13 Q. How was this case processed after the Company' s
14 Application was received?
15 A. The Commission issued a combined Notice of
16 Application and Notice of Intervention Deadline on February
17 19, 2025, establishing an Intervention Deadline of March
18 12, 2025 . Intervenor status was subsequently granted to
19 the Clearwater Paper Corporation ("Clearwater") , Idaho
20 Forest Group LLC ("TFG") , and Walmart Inc. ("Walmart") .
21 The Parties participated in a settlement conference on May
22 22, 2025 . The Stipulation was signed by representatives
23 for Clearwater, IFG, Walmart, and Staff ("Signing
24 Parties") .
25 Staff Investigation
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 3
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1 Q. What type of investigation did Staff conduct to
2 evaluate the Company' s base rate increase request?
3 A. Staff' s approach in any general rate case is to
4 extensively review the Company' s Application and associated
5 testimony and workpapers, identify adjustments to the
6 proposed revenue requirement, evaluate the Company' s class
7 cost of service studies and rate spread, and prepare to
8 file testimony for a fully-litigated proceeding. There
9 were 11 Staff members analyzing this case consisting of
10 auditors, engineers, utility analysts, and consumer
11 investigators . Additionally, five supervisors reviewed the
12 results of all analysis and provided policy direction to
13 the assigned Staff.
14 Staff reviewed the Company' s test year results of
15 operations, capital budgets, capital spending trends,
16 operations and maintenance ("O&M") expenses and trends, and
17 verified all the Company' s calculations and assumptions
18 regarding the overall revenue requirement, cost of service,
19 and rate design. The auditors reviewed thousands of
20 transactions, selected samples, and performed transactional
21 testing in accordance with standard audit procedures . The
22 auditors also reviewed the Company' s labor expense,
23 incentive plans, and employe benefits to ensure the
24 appropriate level of expenditures are included in rates .
25 Staff reviewed both completed and proposed
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 4
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1 capital investments to determine the prudency of capital
2 additions . Expenditures including pension expense,
3 salaries, and 0&M expenses were also examined, along with
4 depreciation expense and taxes . Additionally, Staff
5 investigated the Company' s cost of capital, actual and
6 proposed capital structure, cost of service, and revenue
7 normalization. In total, Staff submitted 169 production
8 requests many of which contained multiple sub-parts,
9 performed an onsite audit of the Company' s books, and held
10 several virtual meetings with Company personnel as a part
11 of its comprehensive investigation.
12 Based on the success of its investigation, Staff
13 proposed approximately 50 separate revenue requirement
14 adjustments during settlement discussions .
15 Settlement Evaluation
16 Q. How did Staff determine that the overall
17 Settlement was reasonable?
18 A. In every settlement evaluation, Staff and other
19 parties must examine the risks of losing positions at
20 hearing and determine if the Settlement is a better overall
21 outcome . Staff must evaluate each individual adjustment
22 and determine the likelihood of the Commission accepting or
23 rejecting Staff' s rationale for the adjustment . All
24 parties must weigh the risks of the Commission decision
25 establishing perceived adverse precedent which creates a
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 5
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1 willingness to negotiate a positive outcome in good faith.
2 Ultimately, Staff' s intent in every settlement conference
3 is to negotiate the best possible outcome for customers .
4 Q. Does Staff support the Settlement as fair, just,
5 and reasonable?
6 A. Yes, after a comprehensive review of the
7 Company' s Application, a thorough audit of the Company' s
8 books and records, an analysis of the Company' s class cost
9 of service study, and extensive negotiations with the
10 parties to the case, Staff supports the proposed
11 Settlement . The Settlement offers a reasonable balance
12 between the Company' s opportunity to earn a reasonable
13 return on its investment and affordable rates for
14 customers . Staff believes the Settlement is in the public
15 interest; is fair, just, and reasonable; and should be
16 approved by the Commission .
17 Settlement Overview
18 Q. Would you please describe the terms of the
19 proposed Settlement?
20 A. The proposed Settlement provides a reduction in
21 the Company' s requested revenue requirement . Instead of
22 the Company' s proposed electric base rate increase of $43 . 0
23 million (14 . 40) and natural gas base rate increase of $8 . 8
24 million (17 . 70) for Rate Year 1, electric base rates under
25 the proposed Settlement for Idaho customers will increase
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 6
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1 by approximately $19 . 5 million, or 6 . 30, and natural gas
2 base rates will increase by approximately $4 . 6 million, or
3 9 .2% effective September 1, 2025 . On September 1, 2026,
4 Idaho electric customers' base rates under the proposed
5 Settlement will increase by approximately $14 . 7 million
6 (4 . 50) compared to the requested $17 . 7 million (5 . 0o) . For
7 natural gas customers in Idaho, base rates will decrease by
8 $209, 000, or 0 . 4%, for the second year of the two-year rate
9 plan compared to the Company' s request of a $1 million
10 increase .
11 Q. How was the stipulated revenue requirement
12 derived?
13 A. For Rate Year 1, the stipulated revenue
14 requirement was calculated by starting with the Company' s
15 proposed revenue requirement and subtracting the agreed
16 upon adjustments proposed by Staff and the other Signing
17 Parties . While not all proposed adjustments were accepted
18 by the Company, concessions were made by each of the
19 Parties to arrive at a final revenue increase that was
20 deemed acceptable to all Signing Parties . The calculation
21 of the stipulated revenue requirement is shown on Table No .
22 1 (electric) and Table No . 3 (natural gas) of the signed
23 Settlement . Table No . 2 (electric) and Table No . 4
24 (natural gas) illustrate the additional pro forma
25 adjustments accepted by the Signing Parties to achieve a
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 7
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1 fair and reasonable revenue requirement for Rate Year 2 .
2 Several agreed upon adjustments to the Company' s revenue
3 requirement include timing differences based on when
4 capital investments would be included for recovery or
5 amortization periods that were extended, while other
6 adjustments were based on different calculation methods or
7 the removal of expenses for recovery. Rather than discuss
8 every adjustment that was proposed and agreed upon, I will
9 highlight the adjustments that had a significant impact to
10 the revenue requirement .
11 Q. Please explain the cost of capital and return on
12 equity components of the Settlement .
13 A. In its Application, Avista proposed a 50o common
14 equity ratio and a 10 . 4% ROE . The Signing Parties agreed
15 to maintain the hypothetical 50o common equity ratio and
16 increase the ROE from the currently authorized 9 . 4% to
17 9 . 60 . A 9 . 6% ROE reduces the Company' s requested first-
18 year electric revenue requirement by approximately $6 . 1
19 million and requested first-year natural gas revenue
20 requirement by approximately $1 .2 million.
21 Q. How does the Stipulation account for the
22 Company' s capital investments included in net rate base?
23 A. In its Application, the Company proposed to
24 include capital investments through August 31, 2026, in its
25 calculation of net rate base for Rate Year 1 . Consistent
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 8
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1 with prior Commission orders, the Signing Parties agree
2 that only capital investments scheduled to be placed in
3 service before August 31, 2025, will be included in the
4 Rate Year 1 revenue requirement . The included capital for
5 Rate Year 1 will be in service and benefiting customers
6 when new rates are effective on September 1, 2025 .
7 For Rate Year 2, the Company proposed capital
8 additions through August 31, 2027, to be included in the
9 calculation of net rate base . The Signing Parties agreed
10 that any capital investment scheduled to be included and
11 placed in service after August 31, 2026, would be excluded,
12 and the net rate base for Rate Year 2 would be calculated
13 using the AMA basis . Additional adjustments were made to
14 capital projects that were either removed from the
15 Company' s forecasts or delayed beyond the Rate Year, in
16 which it was included in the Company' s Application.
17 Additionally, the Parties agree that all capital
18 projects that have transferred to plant as of January 31,
19 2025, are deemed prudent . Any capital additions
20 transferred to plant after January 31, 2025, may still be
21 reviewed for prudence in the Company' s next general rate
22 case .
23 Q. Please describe the removal of 2026 revenue and
24 expense offsets .
25 A. The Settlement removes capital additions placed
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 9
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1 in service after August 31, 2025 . In its Application, the
2 Company' s requested revenue requirement included 0&M
3 savings and revenue offsets associated with 2026 capital .
4 Because the Settlement removes 2026 capital additions, the
5 0&M expense savings and revenue offsets were removed.
6 Q. Please describe how the regulatory amortizations
7 are accounted for in the Settlement .
8 A. With the exception of Wildfire Expense Balance
9 Account Deferral, the Insurance Balancing Account Deferral,
10 and the Williams Pipeline Outage Deferral, the Parties
11 agreed to the regulatory amortizations as filed by the
12 Company. The deferrals called out in Sections 7 (e) , 7 (f) ,
13 and 9 (e) of the Settlement will be revised from a two-year
14 amortization to a four-year amortization.
15 Q. Will you please explain the Escalated
16 Miscellaneous 0&M Expense Adjustment .
17 A. The Company applied a 5 .28% escalation factor to
18 certain 0&M expenses beyond the historical June 30, 2024,
19 test year end (Base Year) . Staff and this Commission have
20 historically opposed escalation factors as they are not
21 known and measurable . This adjustment reduces the
22 Company' s Idaho electric and natural gas revenue
23 requirement by $3 . 4 million and $708, 000, respectively.
24 Q. Please describe the Net Power Supply Expense
25 ("NPSE") Adjustment .
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 10
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1 A. The Parties agreed to reflect corrections to the
2 NPSE, from that filed by the Company, which reduces system
3 NPSE by $11 .2 million, an Idaho allocated NPSE by $4 . 0
4 million. Additionally, the Parties agreed to remove the
5 cost of Palouse Wind Power Purchase Agreement for base NPSE
6 and replace it with the optimized cost of the Company' s
7 other resources to determine the Company' s NPSE both in
8 base rates and in the Power Cost Adjustment ("PCA")
9 mechanism. The Palouse Wind adjustment reduces system NPSE
10 by $1 . 7 million and Idaho' s share by $605, 000 in base rates
11 and in actual cost in the PCA.
12 Q. Please explain how the Settlement accounts for
13 the recovery and collection of property taxes .
14 A. On March 27, 2025, Governor Little signed House
15 Bill 329 ("HB 329") . HB 329 replaces the tax on rate-
16 regulated electric and natural gas utilities with a tax
17 based on kilowatt hours ("kWh") or therms sold effective
18 January 1, 2026 . Beginning in 2027, regulated utilities
19 must include the kWh or thermal energy tax on bills to
20 Idaho customers, which removes recovery of property taxes
21 that has historically been embedded in base rates . The
22 Settlement phases out the Company' s collection of property
23 taxes over the two-year rate plan.
24 Q. Are there any other adjustments that should be
25 explained?
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 11
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1 A. There are numerous other revenue requirement
2 adjustments detailed in the Settlement . The remaining
3 adjustments not discussed in my testimony are adjustments
4 that I would consider self-explanatory, standard, and
5 consistent with previous Commission orders and general rate
6 case settlements .
7 Q. How does the Settlement allocate the revenue
8 requirement among the different customers classes?
9 A. While the Parties did not agree to a specific
10 cost of service study or methodology, there was a general
11 recognition that certain customer classes were paying more
12 than their relative cost of service . For electric
13 customers, the Parties agreed that Schedule 25P
14 (Clearwater) should receive 250 of the overall percentage
15 base rate increase each year, while Street and Area
16 Lighting customers should receive 750 of the overall
17 percentage base rate increase . The customer classes that
18 were considered to be paying less than their relative cost
19 of service, Schedules 21/22 (Large General Service) and
20 Schedules 31/32 (Pumping Services) will receive 1250 of the
21 percentage of base rate increase, while Schedules 11/12
22 (General Service) will receive 1050 . Residential customers
23 receiving service under Schedule 1, and Extra-Large General
24 Service customers on Schedule 25 will receive an increase
25 equal to the overall percentage base rate increase .
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 12
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1 For Natural Gas, the Parties agreed to apply the
2 margin increase on September 1, 2025, to Schedule 101
3 (Residential) . The margin decrease on September 1, 2026
4 will be applied evenly to Schedule 111/112 (Large General
5 Service) and Schedule 146 (Transportation Service) . The
6 percentage increase for each customer class is presented in
7 the tables in Section 27 of the Settlement .
8 Q. Please address the monthly Basic Charge .
9 A. The Parties agree that the month Basic Charges
10 will not increase throughout the two-year rate plan.
11 Appendix F to the Settlement provides a summary of the
12 current and revised rates and charges for electric and
13 natural gas service .
14 Q. Do you have any other comments on the Settlement?
15 A. Yes . Staff believes that an important aspect of
16 a two-year rate plan is to provide rate stability and
17 certainty to customers . Staff believes that multi-year
18 rate plans, especially during a time of increased capital
19 spending and inflationary pressures, are an optimal method
20 to provide certainty to customers while maintaining the
21 financial viability of utilities . The rate stability and
22 certainty included in this current settlement, along with
23 the reduced revenue increase agreed upon by the Parties,
24 represent a fair, just, and reasonable compromise of the
25 positions put forth by the Parties and is in the public
CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 13
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1 interest . Therefore, Staff recommends that the Commission
2 approve the Settlement, inclusive of all attachments,
3 without material changes or modifications .
4 Q. Does this conclude your testimony in this
5 proceeding?
6 A. Yes, it does .
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CASE NOS . AVU-E-25-01/AVU-G-25-01 ENGLISH, D. (Stip) 14
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Professional Qualifications
of
Donn English
Program Manager - Accounting and Finance
Idaho Public Utilities Commission
EDUCATION
Mr. English graduated from Boise State University in 1998 with a
Bachelor of Business Administration degree in Accounting. His
studies concentrated on corporate finance and taxation. He was
a member of the Alpha Beta Psi honor society for Accounting
students . He completed the Annual Regulatory Studies Program,
the Advanced Regulatory Studies Program, and the Accounting and
Ratemaking Course offered through the Institute of Public
Utilities at Michigan State University. Additionally, he
regularly attends meetings and conferences sponsored by the
National Association of Regulatory Commissioners (NARUC) and the
Society of Utility and Regulatory Financial Analysts .
In 2001, Mr. English became a designated member of the American
Society of Pension Professionals and Actuaries (ASPPA) and was
awarded the professional designation of Qualified Pension
Administrator (QPA) and Qualified 401 (k) Administrator (QKA) .
Mr. English was also a member of the Association of Certified
Fraud Examinators .
BUSINESS EXPERIENCE
Prior to joining the Idaho Public Utilities Commission (IPUC) ,
Mr. English was a Trust Accountant with a pension
administration, actuarial, and consulting firm in Boise, Idaho .
In 1999, he was promoted to Pension Administrator, and in 2001
he was promoted to Pension Consultant . In that capacity, Mr.
English performed actuarial calculations and the required non-
discrimination calculations for hundreds of qualified retirement
plans . He completed and filed Form 5500s and represented
clients during audits by the Department of Labor and the
Internal Revenue Service . He also participated in the task
force that wrote questions for the ASPPA administrator and
actuarial exams .
Exhibit No. 101
Case Nos . AVU-E-25-01/AVU-G-25-01
D. English, Staff
7/08/25 Page 1 of 2

Mr. English joined the IPUC in 2003 as a Staff Auditor. In
2016, he was promoted to Audit Team Lead, and in 2018 he became
the Program Manager for the Accounting and Finance Department
within the Utilities Division. From September 2020 - March
2022, Mr. English also accepted the responsibility of
supervising the Technical Analysis and Energy Efficiency team
and was the Program Manager for that team until 2022 . In 2025,
Mr. English was appointed to Deputy Division Administrator of
the Utilities Division at the IPUC, where he oversees a highly-
skilled professional staff consisting of Auditors, Engineers,
Utility Analysts, and Compliance Investigators . At the
Commission, Mr. English has audited numerous utilities including
electric, water, and natural gas companies, and provided
comments and testimony in numerous cases that dealt with general
rates, tax issues, pension issues, depreciation and other
accounting issues, and other regulatory policy decisions . Mr.
English participates in the Energy Efficiency Advisory Groups
and External Stakeholder Advisory Committees for Idaho Power,
Avista Utilities, Rocky Mountain Power, and Intermountain Gas
Company. He is a member of several of the National Association
of Regulatory Utility Commissioners (NARUC) working groups
including the NARUC State Working Group on Performance-Based
Regulation, the NARUC State Working Group on Electric Vehicles,
and the NARUC State Working Group on Grid-Interactive Efficient
Buildings in collaboration with the National Association of
State Energy Officials (NASEO) . Mr. English is the Chair of the
NARUC Staff Subcommittee on Education and Research and the Vice
Chair of the NARUC Staff Subcommittee of Accounting and Finance .
Mr. English is also a faculty member of NARUC Rate School .
Exhibit No. 101
Case Nos . AVU-E-25-01/AVU-G-25-01
D. English, Staff
7/08/25 Page 2 of 2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF JULY 2025,
SERVED THE FOREGOING DIRECT TESTIMONY F DONN ENGLISH IN SUPPORT
OF THE STIPULATION AND SETTLEMENT , IN CASE NO. AVU-E-25-01/AVU-G-
25-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP & CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: [e-mail] E-mail: david.meyergavistacorp.com
avistadockets@avistaco!p.com
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 6070 HILL ROAD
515 N 27TH ST BOISE ID 83703
BOISE ID 83702 E-mail: [e-mail]
E-mail: [e-mail]
ELECTRONIC ONLY Andrew P. Moratzka
[e-mail] Eden A. Faure
Jamie.mcdonald(kclearwaterpaper.com Stoel Rives LLP
33 South 61h Street
Minneapolis, MN 55402
E-MAIL: andrew.moratzka(kstoel.com
[e-mail]
Jennifer S. Palmer Dr. Jaime McGovern, Sr. Mgr.
Stoel Rives LLP Utility Partnerships
101 S. Capitol Blvd., Ste. 1900 Walmart Inc.
Boise, ID 83702 2608 Southeast"J" Street
E-MAIL: jenny.palmergstoel.com Bentonville, AR 72716
E-MAIL: jaime.mc og [e-mail]
Justina A. Caviglia Norman M. Semanko
Parsons Behle & Latimer Parsons Behle & Latimer
50 West Liberty St., Ste. 750 800 West Main St., Ste. 1300
Reno, NV 89502 Boise, ID 83702
E-MAIL: jcavi lg [e-mail] E-MAIL: nsemanko(kparsonsbehle.com
[e-mail]
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE