20250904Staff Comments.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA'S )
RESIDENTIAL SMALL FARM ANNUAL ) CASE NO. AVU-E-25-09
RATE ADJUSTMENT FILING )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Adam Triplett, Deputy Attorney General,
submits the following comments.
BACKGROUND
On July 31, 2025, Avista Corporation, dba Avista Utilities ("Company"), applied for
authorization to implement Residential and Small Farm Energy rates for certain electric service
schedules from October 1, 2025, through September 30, 2026. The Company requests the
processing of this matter via modified procedure with an October 1, 2025, effective date.
The Company represents that the electric Residential and Farm Energy Rate Adjustment
results from an agreement between the Company and Bonneville Power Administration (`BPA")
STAFF COMMENTS 1 SEPTEMBER 4, 2025

that provides a share of the benefits of the federal Columbia River power system to the
residential and small-farm customers of the six investor-owned utilities of the Pacific Northwest.
The Company proposes a Residential and Small Farm Energy Rate Adjustment credit rate
for rate schedules 1, 12, 22, 32, and 48 of 0.2330 per kilowatt-hour("kWh"), which represents a
$1.9 million, or 0.6%, increase to qualifying customers.
The Company represents under the current Residential Exchange rate adjustment,
approximately $5.1 million is being passed through to applicable Idaho customers through a
uniform 0.3660 per kWh rate credit.
The Company represents that the proposed rate credit of 0.2330 per kWh is designed to
pass through approximately $3.3 million, which represents the Idaho portion of the annual BPA
benefits, offset by an over-refunded balance from last year. The Company provides the
following table detailing the differences between the current benefits and the proposed benefits.
C utge III 11ene111
Proposcd Prescme
Idaho portiou of bcncfit amount S (3.258.527) S (5.118.545) S 1.860.018
The Company stated that residential customers using an average of 939 kWhs per month
would see their monthly bills increase from $104.30 to $105.55, an increase of$1.25 per month,
or 1.2%.
STAFF ANALYSIS
Staff reviewed the methodology and calculation of the proposed Residential and Small
Farm credit rate and confirmed that the approach is consistent with the terms and conditions of
Schedule 59—Residential and Farm Energy Rate Adjustment, Idaho. Staff audited the inputs,
independently recalculated the rate, and recommends that the Commission approve the proposed
rate of 0.2330 per kWh, with an effective date October 1, 2025.
The Residential and Small Farm Energy Rate Adjustment credit results from the
Company's agreement with the Bonneville Power Administration(BPA)under the Residential
Exchange Program. This program allows residential and small-farm customers of six Pacific
Northwest utilities, including Avista, to benefit from the federal Columbia River power system
STAFF COMMENTS 2 SEPTEMBER 4, 2025

through a rate credit. Idaho's share of BPA benefits are reflected in the credit, adjusted for any
over-refunded balance from the prior year.
The current Residential and Small Farm Energy Adjustment Rate credit is 0.3660 per
kWh,providing customers with approximately $5.1 million in BPA benefits. The proposed credit
of 0.2330 per kWh would deliver about $3.3 million—Idaho's portion of BPA's annual
benefits—reduced by the prior year's over-refunded balance. The over-refund occurred because
actual usage exceeded the projections in the Company's 2024 filing. Comparing projected sales
at the current and proposed rates for October 2025 through September 2026, the Company's
proposal would result in an overall increase of$1.9 million, or 0.6%, for qualifying customers.
The BPA benefit calculation for residential and small-farm customers relies on two
inputs: (1)the average usage of Avista's customers over the prior two years (2023 and 2024), and
(2)the difference between Avista's Average System Cost rate and BPA's Priority Firm Exchange
Rate, which BPA updates every two years. Multiplying this difference by the annualized usage
determines the BPA benefit passed on to customers. The current credit is in its second year, and
the BPA benefit is allocated between Washington and Idaho based on each state's actual usage.
In practice,Avista sets the rate by combining the projected remaining BPA balance from
the prior year with the new year's BPA benefit and dividing the total by projected annual kWh
sales.
CUSTOMER NOTICE AND PRESS RELEASE
The Company's press release and customer notice were included with its Application.
Staff reviewed the documents and determined both met the requirements of Rule 125 of the
Commission's Rules of Procedure'. See IDAPA 31.01.01 .125. The notice was included with
bills mailed to customers beginning August 1, 2025, and ending August 29, 2025.
As of September 4, 2025, no customer comments had been filed. The Commission set a
comment deadline of September 4, 2025. Some customers in the last billing cycles will not have
received or had adequate time to submit comments before the deadline. Customers should have
1 The press release and customer notice addressed the following cases. Electric:AVU-E-25-07 Power Cost
Adjustment(PCA),AVU-E-25-08 Fixed Cost Adjustment(FCA),AVU-E-25-09 Bonneville Power Administration
Residential Exchange(ResEx),and AVU-E-25-10 Energy Efficiency. Natural Gas:AVU-G-25-05 Fixed Cost
Adjustment(FCA),AVU-G-25-06 Energy Efficiency,and AVU-G-25-07 Purchased Gas Cost(PGA).
STAFF COMMENTS 3 SEPTEMBER 4, 2025

the opportunity to file comments and have those comments considered by the Commission. Staff
recommends that the Commission consider late filed comments from customers.
STAFF RECOMMENDATION
Staff recommends that the Commission:
1. Approve the Company's Application and proposed Residential and Farm Energy
Rate Schedule 59 as filed; and
2. Accept and consider any late filed comments from customers.
Respectfully submitted this 4th day of September 2025.
Adam Triplett
Deputy Attorney General
Technical Staff. Ty Johnson
1:\Utility\UMISC\COMMENTS\AVU-E-25-09 Comments.docx
STAFF COMMENTS 4 SEPTEMBER 4, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS _q_��DAY OF SEPTEMBER
2025, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. AVU-E-25-09, 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, MSC-27 PO BOX 3727, MSC-10
1411 E. MISSION AVE 1411 E. MISSION AVE
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: [e-mail] E-mail: [e-mail]
e,avistacorp.com
[e-mail]
PATRICIA JORDAN, SE TARY
CERTIFICATE OF SERVICE