20250829APPLICATION.pdf

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Avista Corp. RECEIVED
1411 East Mission P.O. Box 3727 August 29, 2025
IDAHO PUBLIC
Spokane, Washington 99220-0500 UTILITIES COMMISSION
Telephone [phone]
Toll Free 800-727-9170
August 29, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Suite 201-A
Boise, Idaho 83714
Re: Avista Corporation Application for Determination of 2024 Electric Energy Efficiency
Expenses as Prudently Incurred
Dear Commission Secretary:
Enclosed for filing with the Commission is the Application of Avista Corporation, dba
Avista Utilities (Avista or "the Company"), requesting a determination of prudence for the
Company's electric energy efficiency expenditures from January 1, 2024 through December 31,
2024. In support of its Application, Avista has provided Exhibit No. 1, which contains the
Company's 2024 Annual Conservation Report(ACR).
If you have any questions regarding this filing, please Kim Boynton, Manager, Energy
Efficiency Analytics, at [phone] or kim.bo. ntongavistacorp.com.
Sincerely,
/0,/ �4� st. ;Deal
Jaime St. Peter
Regulatory Affairs Manager
Enclosures
cc: Avista Energy Efficiency Advisory Group

DAVID J. MEYER, Esq.
Vice President and Chief Counsel
Regulatory & Governmental Affairs
Avista Corporation
1411 E. Mission Avenue, MSC 27
P. O. Box 3727
Spokane, Washington 99220
Telephone: [phone]
david.me er&avistacorp.com
Attorney for Avista Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
AVISTA CORPORATION FOR A ) CASE NO. AVU-E-25-_
DETERMINATION OF 2024 ELECTRIC )
ENERGY EFFICIENCY EXPENSES AS ) APPLICATION OF
PRUDENTLY INCURRED ) AVISTA CORPORATION
In accordance with IDAPA 31.01.01 (Rules of Procedure, or RP), RP 052 and RP 201, et
seq., Avista Corporation, dba Avista Utilities (Avista or the Company), at 1411 East Mission
Avenue, Spokane, Washington, hereby applies to the Idaho Public Utilities Commission
(Commission) for an order designating Avista's electric energy efficiency expenditures from
January 1, 2024 through December 31, 2024, funded through the Company's Schedule 91 Energy
Efficiency Rider Adjustment in the amount of $17,276,972, as prudently incurred (hereinafter
Application).
The Company also requests that this filing be processed under the Commission's Modified
Procedure Rules (RP 201-204) through the use of written comments.
APPLICATION OF AVISTA- 1

All communications,pleadings, and orders with respect to this Application should be directed to:
David J. Meyer, Esq. Shawn J. Bonfield
Vice President and Chief Counsel Senior Manager, Regulatory Policy& Strategy
Regulatory& Governmental Affairs Avista Corporation
Avista Corporation P. O. Box 3727
P. O. Box 3727 1411 E. Mission Avenue, MSC 27
1411 E. Mission Avenue, MSC 27 Spokane, Washington 99220-3727
Spokane, Washington 99220-3727 Telephone: [phone]
Telephone: [phone] E-mail: shawn.bonfield(d),avistacorp.com
E-mail: david.me er&avistacorp.com
Avista Dockets (Electronic Only) - AvistaDocketsgavistacorp.com
Avista has included the following attachment in support of this filing, which is also
referenced throughout the Application below:
a) Exhibit No. 1 —Avista 2024 Idaho Annual Conservation Report
I. BACKGROUND
Avista has continuously offered energy efficiency services since 1978. Through these
offerings, the Company seeks to provide customers with programs and information that may help
them manage their energy use and to utilize cost-effective energy efficiency resources to meet the
energy and demand needs of the Company's electrical and natural gas systems. These efforts are
funded through Avista's Electric and Natural Gas Energy Efficiency Rider Adjustments(Schedule
91 and Schedule 191, respectively), or tariff riders.
The Company's Energy Efficiency Program (Program) consist of options for residential,
non-residential and low-income customer segments. The Program includes offerings through
traditional prescriptive channels along with site-specific projects and upstream buy-down
programs. Additionally, Avista introduced a midstream program in 2023, as well as a small
business direct install lighting program, both of which continue to be leaders in kWh savings
achievements for the 2024 Program year. Each program within the Company's electric Energy
APPLICATION OF AVISTA-2

Efficiency Portfolio (Portfolio) is designed to meet cost-effectiveness requirements and is
evaluated by a third-party evaluator each year(with the exception of low-income program, which
is on a 2-year evaluation cycle). The results of both the Company's and the third-party evaluator's
annual assessments of the Program are contained within Avista's Annual Conservation Report
(ACR). The list below provides a more comprehensive summary of all Appendices and
Supplements included within the 2024 ACR:
1) Appendix A—2024 Electric Impact Evaluation Report
2) Appendix B—2024 Natural Gas Impact Evaluation Report
3) Appendix C—2024 Cost-Effectiveness Tables
4) Appendix D—2024 Expenditures by Program
5) Appendix E—2024 Energy Efficiency Activity by Program
6) Appendix F—NEEA 2024 Annual Savings Report—Electric
7) Appendix G—NEEA 2024 Annual Savings Report—Natural Gas
8) Appendix H—Idaho Furnace Billing Analysis Memorandum
II. ELECTRIC PROGRAM EXPENDITURES
The Company requests Commission determination that the expenditures incurred during the
2024 Program year, totaling $17,276,972 for its electric Program, were prudent and in the public
interest. It should be noted that this amount is comprised of the $17,316,094 in expenditures noted
within the 2024 ACR, minus additional adjustments in the amount of$39,122. These adjustments
were made in accordance with the Company's 2022-2023 prudence determination, Final Order No.
36462 in the Case Nos. AVU-E-24-09 and AVU-G-24-03, and the resulting compliance filing
submitted by Avista on August 25, 2025 in those cases. Of the total amount spent, $13,643,398, or
79%, of total expenditures were paid out to customers in direct incentives. This percentage does not
include additional benefits such as technical analyses provided to customers by the Company's
APPLICATION OF AVISTA-3

Energy Efficiency engineering staff or regional market transformation efforts through the Northwest
Energy Efficiency Alliance (NEEA).
The Company reports the Schedule 91 balance on a quarterly basis to Commission Staff
and its Energy Efficiency Advisory Group (EEAG or Advisory Group). While 2024 began with
an overfunded electric tariff rider balance (by approximately $4.36 million)—meaning that more
tariff rider funding was being collected than actually needed to fund the ongoing Program
operations—the decreased collection rate made effective October 1,2023,in addition to the higher-
than-anticipated throughput for Avista's electric Program (around 3.5 times the planned spend),
culminated to result in an$8.82 million underfunded balance by the end of 2024. On July 31,2025,
the Company filed to true-up this balance with new rates requested effective October 1, 2025 (see
Case No. AVU-E-25-10). Table No. 1 below illustrates the balances for the 2024 Program year on
a monthly basis.
Table No. 1 — Schedule 91 Tariff Balances By Month, January 2024-December 2024
Accounting Period Beginning Balance Program Expenditures Tariff Collections Ending Balance
Jan-24 $ (4,363,646) $ 1,036,161 $ 437,718 $ (3,765,202)
Feb-24 $ (3,765,202) $ 1,042,048 $ 400,447 $ (3,123,601)
Mar-24 $ (3,123,601) $ 1,172,849 $ 357,802 $ (2,308,553)
Apr-24 $ (2,308,553) $ 1,093,587 $ 330,972 $ (1,545,938)
May-24 $ (1,545,938) $ 1,366,343 $ 290,759 $ (470,355)
Jun-24 $ (470,355) $ 1,300,309 $ 288,896 $ 541,058
Jul-24 $ 541,058 $ 2,190,630 $ 325,352 $ 2,406,336
Aug-24 $ 2,406,336 $ 1,094,120 $ 352,765 $ 3,147,690
Sep-24 $ 3,147,690 $ 1,104,307 $ 317,355 $ 3,934,642
Oct-24 $ 3,934,642 $ 1,864,349 $ 278,327 $ 5,520,665
Nov-24 $ 5,520,665 $ 727,908 $ 313,994 $ 5,934,579
Dec-24 $ 5,934,579 $ 3,255,053 $ 397,178 $ 8,792,454
2024 Adjustments (Completed) $ 8,792,454 $ 68,430 $ - $ 8,860,884
2024 Adjustments(Pending) $ 8,860,884 $ (39,122) $ - $ 8,821,762
APPLICATION OF AVISTA-4

III. 2024 PROGRAM PERFORMANCE
The Company's energy efficiency targets are established on an annual basis through the
process of developing its electric Integrated Resource Plan (IRP). The targets derived through the
resource planning efforts provide a starting point for Program planning, which is accomplished
through the annual business planning process where Program offerings are optimized for the
Company's service territory based on current economic and market conditions. Program savings
for 2024 were 30,150,532 kWh, which surpassed the electric savings target of 8,960,566 kWh,
achieving 336%of the target. Savings from NEEA's programs added an additional 6,952,342 kWh
in 2024, increasing the overall savings achieved from 30,150,532 kWh to 37,102,874 kWh. Table
No. 2 below details the electric savings by residential, non-residential and low-income sectors,
which make up the Company's electric Portfolio (not including NEEA).
Table No. 2 —2024 Electric Savings by Program Sector
Planned Savings Achieved Savings % of Planned
(kWh) (kWh) Savings Achieved
Commercial/Industrial 7,215,555 27,694,876 384%
Residential 1,623,462 2,390,778 147%
Low-Income 121,549 64,878 53%
Total 8,960,566 30,150,532 336%
Avista evaluates the effectiveness of its electric Portfolio based upon a number of metrics,
including analyses utilizing four specific measurements to evaluate the cost-effectiveness of a
given program from both the Company's and from customers' perspectives: the Utility Cost Test
(UCT),' the Total Resource Cost (TRC), the Participant Cost Test (PCT), and the Ratepayer
Impact Test (RIM). The most commonly applied metrics to provide insight into the net value to
'Also known as the Program Administer Cost(PAC)test.
APPLICATION OF AVISTA-5

all customers are the UCTa benefit-to-cost test from the utility perspective that includes
incentives and excludes net costs and non-energy benefits (NEBs)—and the TRC, which
represents the customer perspective by including all measure costs and NEBs, excluding
incentives. Per Commission Staff recommendations in previous prudence reviews, Avista has
shifted, in recent years, to conducting its own cost-effectiveness calculations in-house,rather than
relying on a third party. Avista's calculations are based on values within the Company's reporting
structure — specifically, units installed, unit energy savings, and per-unit incentives. Avista has
also improved its quality control process for cost-effectiveness calculations and for overall
accuracy of the Company's work papers by developing cost-effective workbooks that utilize active
formulas, implementing peer reviews and reconciling Portfolio savings totals against the systems
of record. The Company will continue to refine its processes, as needed, to ensure the appropriate
and concise reporting of its Program. For 2024, the overall Portfolio achieved a UCT ratio of 1.41
and a TRC ratio of 0.82 based on verified savings. These cost-effectiveness metrics are included
in Table No. 3 below:
Table No. 3—2024 Electric Cost-Effectiveness
Cost-Effectiveness Test 2024
AL
Utility Cost Test (UCT) 1.41
Total Resource Cost TRC 0.82
IV. PROGRAM EVALUATION
In addition to the cost-effectiveness analyses conducted for the Program, Avista also
contracts with independent, third-party consultants to provide program Evaluation, Measurement,
and Verification (EM&V) activities each year. These EM&V activities are used to validate and
report verified energy savings related to the Company's energy efficiency measures and Program
APPLICATION OF AVISTA-6

offerings, as well as provide viable recommendations to improve Program performance, enact
changes to Program components, and decide whether and when to phase out measures.
For the 2024 Program year, ADM and Associates, Inc. (ADM) was retained by Avista to
perform the impact evaluation for Avista's electric Program, inclusive of the residential, non-
residential, and low-income components of the Program. The primary goal of the impact
evaluations is to provide an accurate summary of the gross electric and demand savings attributable
to Avista's Portfolio, while the main purpose of a process evaluation is to identify any
improvements needed at the Program level to increase Program effectiveness, and efficiency while
improving the participation experience for customers.
As part of its 2024 evaluation, the evaluator concluded that Avista's electric Program
achieved a 98% realization rate and 30,150,532 kWh in annual verified savings.
V. ADDITIONAL PROGRAM ACTIVITIES
Commercial/Industrial Sector
Avista achieved higher-than-anticipated electric energy savings in 2024 due to continued
participation in the Midstream,Prescriptive, and Small Business Direct-Install Lighting Programs.
The Midstream Program offers incentives to distributors and trade allies, rather than directly to
customers, ensuring that the mix of HVAC, hot water, and foodservice equipment offered to
customers is in stock and energy efficient. Prescriptive measures offer customers a simple
approach for lighting, shell,variable frequency drive(VFD), and grocer-related improvements. As
a complement to the Midstream and Prescriptive options,the Site-Specific Program is designed to
assist unique or complex projects that require energy savings calculations or technical assistance
directly from Avista's energy engineering team. Examples include compressed air, process
equipment and controls, and comprehensive lighting retrofits.
APPLICATION OF AVISTA-7

The Small Business Direct-Install Lighting Program continued to be extremely popular
with small businesses in 2024 as well, because it offers low- to no-cost lighting upgrades for
Schedule 11 and Schedule 12 customers.Under this offering,trade allies conduct outreach to small
businesses, conduct eligibility checks, visit facilities to create project scope and cost estimates,
and install lighting. Small business customers are often channeled into this program through
Avista's Business Partner Program, an outreach effort to help customers in the Company's rural
areas of the service territory become aware of efficiency opportunities. This enables the Company
to prioritize outreach to specific geographic areas,which in turn allows trade allies to batch projects
by geographic areas, resulting in an efficient installation model. As previously noted, the electric
Portfolio achieved nearly four times its 2024 savings goal, with over half of savings coming from
the Small Business Direct-Install Lighting Program.
Residential Sector
Over $1.5 million in rebates and direct benefits went to Idaho residential customers in
2024, due in large part to the success of the Midstream and Appliances Programs. The Midstream
Program incentivizes the purchase of high-efficiency residential HVAC and water-heating systems
and works to ensure these products are in stock for customers. The program works directly with
distributors,who influence equipment sales in the region. The Midstream Program over-performed
at six-and-a-half times higher than its planned savings, with a total of 1,891,168 kWh saved.
Additionally, the Appliances Program over-performed at 145 percent of planned savings
for 2024,with a total of 94,924 kWh saved. Avista has long offered incentives for highly efficient
appliances such as residential washers, dryers, and refrigerators through point-of-sale programs
and Prescriptive paths, including rebates for ENERGY STAR-certified appliances; these options
APPLICATION OF AVISTA-8

continue to be popular choices for customers, contributing to the high performance of this offering
for 2024.
VL REOUEST FOR RELIEF
As described in greater detail above and within its 2024 ACR,Avista respectfully requests
that the Commission issue an Order designating Avista's 2024 total electric Energy Efficiency
Program expenditures of$17,276,972 as prudently incurred,with this Application being processed
under Modified Procedure through the use of written comments.
DATED this 291h day of August 2025.
Respectfully submitted,
Avista Utilities
By: /s/David Meyer
David J. Meyer, Vice President and Chief
Counsel for Regulatory and Governmental Affairs
APPLICATION OF AVISTA-9