20250916Staff Comments.pdf

RECEIVED
September 16, 2025
ADAM TRIPLETT IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
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 )
APPLICATION TO INCREASE ITS ENERGY ) CASE NO. AVU-E-25-10
EFFICIENCY TARIFF RIDER ADJUSTMENT )
SCHEDULE 91 )
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 to
increase its I.P.U.C. No. 28, Schedule 91, "Energy Efficiency Rider Adjustment" (`BE Rider")
rates, effective October 1, 2025.
The Company represents that Schedule 91 is designed to recover costs of energy
efficiency services and programs offered to customers, and that Schedule 91 provides customers
with financial incentives or rebates for participating in electric energy efficiency programs, such
STAFF COMMENTS 1 SEPTEMBER 16, 2025

as behavioral programs, low-income weatherization, and energy efficiency measures.
Application at 1-2.
The Company is seeking to establish tariff riders that are sufficient to fund the following
twelve (12) months' expenditures for the Company's Electric Energy Efficiency Program while
also minimizing the amount of future under- or over-collections. Id at 1-2.
The Company states that, as of June 30, 2025, the current Schedule 91 (electric) tariff
rider balance was approximately $17 million underfunded. To address this, the Company
proposes an increase in the Schedule 91 rates over the next thirty-six months. Id at 3-4.
If the Application is approved as filed, the Company estimates an annual revenue
increase of approximately $3.6 million in Schedule 91, or 1.2% in overall billed rates. The
Company indicated that residential customers using an average of 939 kilowatt hours per month
would see a bill increase of$1.32, or 1.1%under the Company's proposal. Id at 4.
The Company stated that a Customer Notice will be included in customer's bills in early
August 2025, and will run for a full billing cycle. The Company will also post the Customer
Notice to the Company's website. Id at 5.
STAFF ANALYSIS
Staff reviewed the Application and supporting workpapers. Based on its review, Staff
supports the Company's request to increase the Schedule 91 rates by 1.2%. Staff anticipates that
the new increase will align the Schedule 91 revenues with the Company's projected Demand
Side Management ("DSM") expenditures and reduce the underfunded balance.
The Company provided a forecast of the Schedule 91 revenues and DSM expenditures
for the next three years (2025-2028), which Staff reviewed along with the associated rates to
confirm they have been calculated correctly by the Company. Company workpapers show the
proposed Schedule 91 rates will provide sufficient revenue to cover the Company's forecasted
expenses of its existing programs while also slowly returning the balance to $0 by the end of
September 2028. Staff believes the new charge is reasonable.
If approved, a residential customer using an average of 939 kilowatt hours per month
would see their monthly bill increase from $116.71 to $118.03, an increase of$1.32 per month.
Staff determined the Company properly applied the new rate adjustment to customer classes as
shown in Table No. I below.
STAFF COMMENTS 2 SEPTEMBER 16, 2025

Table No. 1: Schedule 91 Rates
SCHEDULE EXISTING RATE PROPOSED RATE
Residential Customers - Sch. 1 0.158¢ per kWh 0.298¢ per kWh
General Service - Sch. 11 & 12 0.129¢ per kWh 0.156¢ per kWh
Large General Service - Sch. 21 &22 0.130¢ per kWh 0.824¢ per kWh
Extra Large Customers - Sch. 25 0.084¢ per kWh 0.151¢ per kWh
Clearwater Paper- Sch. 25P 0.067¢ per kWh 0.123¢ per kWh
Pumping Service - Sch. 31 & 32 0.146¢ per kWh 0.287¢ per kWh
Street Light Service - Sch. 41-49 0.555¢ per kWh 1.097¢ per kWh
As of June 30, 2022, the Company's Schedule 91 was underfunded by approximately $17
million. An underfunded balance indicates that the current tariff rider rate is not sufficient to
cover all the yearly expenses of the program. The primary reason was higher than anticipated
participation levels, which achieved a greater amount of conservation savings in Idaho.
The Company describes two main factors that contributed to the underfunded balance.
First, the Company has seen an unanticipated level of customer participation in the Company's
Small Business Lighting direct-install program with participation much higher than forecasted.
Second, the Company's Midstream program has also seen higher than expected customer
participation. Id at 3.
The proposed rate adjustment is projected to bring the underfunded balance of Schedule
91 to $0 by September 30, 2028. By extending the collection period over a longer period, the
Company is attempting to align the collection of revenue in Schedule 91 more closely with the
annual Energy Efficiency Program budget, thus minimizing the future rate impact to customers.
Id at 4.
Cost-effective DSM, including energy efficiency and load management programs, is a
significant resource that helps customers better control their utility bills, reduces the need for
higher-cost supply-side resources, and increases system reliability. Staff assumes the
Company's DSM program costs will continue to be prudently incurred and that the programs
will remain cost-effective.
It is not Staff s intent to either validate or question the Company's DSM prudency or its
actual cost-effectiveness calculations for any of its energy efficiency programs at this time. Such
validation and additional review were not requested in this case and is occurring in Case No.
AVU-E-25-12.
STAFF COMMENTS 3 SEPTEMBER 16, 2025

Overall Impact of Four Filings (EE Rider, PCA,ResEx, and FCA)Effective October 1, 2025
The Company proposed four electric rate adjustments effective October 1, 2025. If
approved as filed, the proposed Schedule 91, EE Rider, AVU-E-25-10, will increase electric
revenues for participants by$3.6 million(1.2% increase). The Company's Power Cost
Adjustment("PCA"), AVU-E-25-07, if approved, will decrease the Company's electric revenues
by $1.8 million(0.6% decrease). The third proposed filing, Bonneville Power Administration
Residential Exchange Program ("ResEx"), AVU-E-25-09, if approved, will increase electric
revenues by $1.9 million (0.6% increase). The final proposed filing, Fixed Cost Adjustment
("FCA") filing, AVU-E-25-08, if approved, will increase electric revenues by about $2.6 million
(0.6% increase). Avista Customer Notice at 1.
The net effect of Company's four filings (EE Rider, PCA, ResEx, and FCA) will increase
electric revenues by about $6.3 million (2.0% increase). The average residential electric
customer's monthly bill may increase by$3.43 or 3.3%. Id. Table No. 2 summarizes the overall
impact to electric revenues of the four filings.
Table No. 2: Summary of Overall Impact to Electric Revenues
Filing Change in Revenues % Change
EE Rider $3.6 million 1.2%
PCA ($1.8 million) -0.6%
ResEx Credit $1.9 million 0.6%
FCA $2.6 million 0.8%
Total $6.3 million 2.0%
CUSTOMER NOTICE AND PRESS RELEASE
The Company's press release and customer notice were included with the Application.
Staff reviewed the documents and determined both met the requirements stated in 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.
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 4 SEPTEMBER 16, 2025

The Commission set a comment deadline of September 16, 2025. Some customers in the
last billing cycles may not have received or had adequate time to submit comments before the
deadline. Customers should have the opportunity to file comments and have those comments
considered by the Commission. Staff recommends that the Commission consider late filed
comments from customers. As of September 16, 2025, no customer comments had been filed.
STAFF RECOMMENDATION
Staff recommends approval of the Company's Application to increase the Schedule 91
Customer Efficiency Services Rate by 1.2% and the proposed Schedule 91 tariffs as filed.
Additionally, Staff recommends the Commission consider any late filed customer comments.
Respectfully submitted this 16th day of September 2025.
Adam Triplett
Deputy Attorney General
Technical Staff. Laura Conilogue, Jason Talford
1:\Utility\UM1SC\COMMENTS\AVU-E-25-10 Comments.docx
STAFF COMMENTS 5 SEPTEMBER 16, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF SEPTEMBER
2025, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF , IN
CASE NO. AVU-E-25-10, 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: patrick.ehrbarkavistacorp.com E-mail: david.meyergavistacorp.com
avistadocketsgavistacorp.com
PATRICIA JORDAN, CRETARY
CERTIFICATE OF SERVICE