20251006Staff 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 )
APPLICATION TO DECREASE ITS ENERGY ) CASE NO. AVU-G-25-06
EFFICIENCY TARIFF RIDER ADJUSTMENT )
SCHEDULE 191 )
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 the
Commission for authorization to decrease its natural gas Schedule 191, "Energy Efficiency Rider
Adjustment"rates. The Company proposed decreasing billed natural gas rates by 3.5%through
its proposed revision of Schedule 191. The Company requested an effective date of November
1, 2025.
Schedule 191 funds the Company's Natural Gas Efficiency Program as described in the
Company's Schedule 190, which includes,but is not limited to, behavioral programs, low-
STAFF COMMENTS 1 OCTOBER 6, 2025

income weatherization, Northwest Energy Efficiency Alliance participation, and provision of
incentives for various energy efficiency (`BE")measures such as appliances, compressed air,
heating, ventilation, and air conditioning ("HVAC"), industrial, lighting, maintenance, motors,
shell, and sustainable buildings.
The Company represents that as of June 20, 2025, the current Schedule 191 tariff rider
balance was approximately $2.9 million overfunded.
The Company proposes to decrease billed natural gas rates by 3.5%through proposed
revisions of Schedule 191, with a requested effective date of November 1, 2025.
The Company sent a Customer Notice, which was included in customer's bills beginning
in early August 2025 and ran for a full billing cycle. The Company also posted the Application
to the Company's website at myavista.com.
STAFF ANALYSIS
Staff reviewed the Application and supporting workpapers. Staff supports the
Company's request to decrease Schedule 191 rates by 3.5%. Staff anticipates that the new rate
will align Schedule 191 revenues with the Company's projected Demand Side Management
("DSM") expenditures and reduce the overfunded balance.
The Company provided workpapers which included a forecast of the Schedule 191
revenues and DSM expenditures for the next three years (2025-2028). Staff reviewed the
Company's forecasts and associated rates to confirm they have been calculated correctly. The
Company workpapers suggest the proposed Schedule 191 rates will provide sufficient revenue to
cover the Company's forecasted expenses while also returning the balance to $0 by the end of
October 2028. Staff believes the new rate is reasonable.
As of June 30, 2025, the Company's Schedule 191 was overfunded by approximately
$2.9 million. Application at 3. An overfunded balance indicates that the current Schedule 191
rate is collecting more than is needed to cover annual expenses. The Company explains that the
primary reason for the increased balance is due to lower than anticipated participation levels in
commercial and residential programs. Id. at 3-4.
The Company attributed the decline in participation primarily to a substantial decrease in
its avoided costs for 2024, which limited its capacity to offer incentives large enough to keep
customers engaged. Id. at 3-4.
STAFF COMMENTS 2 OCTOBER 6, 2025

The proposed rate adjustment is projected to bring the overfunded balance of Schedule
191 to $0 by October 30, 2028. Id. at 4. By extending the collection period over a longer period,
the Company is attempting to align the collection of revenue in Schedule 191 more closely with
the annual EE Program budget, thus minimizing the future rate impact to customers. Id. at 4.
If approved, a residential customer using an average of 64 therms per month would see
their monthly bill decrease from $64.74 to $62.54, a decrease of$2.20 per month. Id. at 4. Staff
believes the Company properly applied the new rate adjustment to customer classes as shown in
Table No. 1 below.
Table No. 1: Schedule 191 Rates
Schedule Existing Rate Proposed Rate
General Service— Sch. 101 $0.04903 per Therm $0.01568 per Therm
Large General Service— Sch. 111 & 112 $0.02626 per Therm $0.00711 per Therm
Interruptible Sales Service— Sch. 131 & 132 $0.02626 per Therm $0.00711 per Therm
Cost-effective DSM, including EE 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 believes 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 EE programs at this time. Such validation
and additional review were not requested in this case, but is occurring in Case No. AVU-G-25-
09.
Overall Impact of Three Filings (EE Rider, PCA, and FCA)Effective November 1, 2025
The Company filed two other applications with rate adjustments and requested effective
dates of November 1, 2025. The Company's natural gas Purchased Gas Cost Adjustment
("PGA"), Case No. AVU-G-25-07, was filed on July 31, 2025, and requests a decrease in natural
gas revenues of approximately $6.5 million, or 7.2%. The Company's Fixed Cost Adjustment
STAFF COMMENTS 3 OCTOBER 6, 2025

("FCA"), Case No. AVU-G-25-05, was filed on July 31, 2025, and requests an increase in the
Company's overall natural gas revenues by $80,000, or 0.1%. Avista Customer Notice at 1.
The net effect of Company's three filings (EE Rider, PCA, and FCA) will decrease
natural gas revenues by about $9.5 million (10.6% decrease). The average residential natural gas
customer's monthly bill may decrease by$6.18 or 9.5%. Id. at 2. Table No. 2 summarizes the
overall impact to electric revenues of the four filings.
Table No. 2 below shows the effect of all three cases if approved as filed.
Table No. 2: Summary of Overall Impact to Electric Revenues
Case $ Revenue Change %Revenue Change
EE Tariff ($3.1 million) (3.5%)
PGA ($6.5 million) (7.2%)
FCA $80,000 0.1%
Total ($9.5 million) (10.6%)
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.
As of October 6, 2025, no customer comments had been filed. The Commission set a
comment deadline of October 6, 2025,providing customers with a reasonable opportunity to file
timely comments.
STAFF RECOMMENDATION
Staff recommends approval of the Company's Application to decrease the Schedule 191
Customer Efficiency Services Rate by 3.5% and the proposed Schedule 191 tariffs as filed.
Additionally, Staff recommends the Commission consider any late filed customer comments.
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 OCTOBER 6, 2025

Respectfully submitted this 6th day of October 2025.
Adam Triplett
Deputy Attorney General
Technical Staff: Laura Conilogue
1:\Utility\UMISC\COMMENTS\AVU-G-25-06 Comments.doex
STAFF COMMENTS 5 OCTOBER 6, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF OCTOBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. AVU-G-25-06, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
DAVID J MEYER PATRICK D. EHRBAR
VP & CHIEF COUNSEL DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: [e-mail] E-mail: Patrick.ehrba0_i),avistacorp.com
[e-mail]
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PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE