20251015Comment_1.pdf

The following comment was submitted via PUCWeb:
Name: Sean Holm
Submission Time: Oct 15 2025 1:15AM
Email: glass.torchCabyahoo.com
Telephone: [phone]
Address: 1469 S Fairmont Loop
Coeur D Alene, ID 83814
Name of Utility Company: Avista
Case ID: AVU-E-25-13
Comment: "Dear Idaho Public Utilities Commission Members,
As a concerned ratepayer in northern Idaho served byAvista Utilities, I am submittingthis
written comment in response to Avista's September 15, 2025, compliance filing to update
its load forecast, natural gas price forecast, and PURPA contract information for the
incremental cost Integrated Resource Plan (IRP) avoided cost model. This filing, with an
effective date of January 1, 2026, raises significant concerns about transparency,
methodology, and its impact on ratepayers. I urge the Commission to reject or substantially
revise the filing and convene a formal hearing to allow for expert testimony and public
scrutiny.
1. Overly Pessimistic and Inflated Natural Gas Price Forecast
Avista's natural gas price forecast projects Henry Hub prices starting at$4.16/MMBtu in
2026 and escalatingto $8.23/MMBtu by 2045—a more than 98% increase overtwo
decades. This is based on a "blend" of the U.S. Energy Information Administration's (EIA)
Annual Energy Outlook(AEO) 2025, two unnamed national price forecasting consultants,
and forward market prices as of June 20, 2025. However, this forecast appears alarmingly
high compared to independent analyses, potentially inflating avoided costs and
discouraging cost-effective energy options.
For context:
The EIA's AEO 2025 reference case projects Henry Hub prices at just$3.80/MMBtu by 2030
and $4.20/MMBtu by 2040—less than half of Avista's 2030 ($4.12/MMBtu) and 2040
($6.80/MMBtu) figures.
The EIA's Short-Term Energy Outlook(STEO)from October 2025 forecasts an average of
$3.67/MMBtu for all of 2025, rising modestly to around $4.10/MMBtu in early 2026—not the
steep climb Avista assumes.
Conservative estimates, like those from Deloitte, project$6.50/MMBtu by 2041—still far
below Avista's trajectory.
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The reliance on unnamed consultants raises transparency concerns. Why blend in such
aggressive projections when official EIA data shows stability?This could artificially boost
avoided costs, increasing rates for ratepayers. I request the Commission demand Avista
disclose the specific consultant forecasts and justify the blend methodology, or adopt the
EIA's reference case as the baseline.
2. Load Forecast Fails to Adequately Account for Energy Efficiency Trends
The proposed energy load forecast shows steady growth from 1,169 average megawatts
(aMW) in 2026 to 1,424 aMW in 2045—an annual increase of about 0.6%. While Avista
notes this forecast is "net" of energy efficiency savings, it doesn't demonstrate how
aggressive conservation programs (e.g., rebates for efficient appliances) are factored in
beyond a basic subtraction. Idaho's voluntary energy goals and federal incentives
encourage efficiency to keep rates low,yet this filing lacks detail on demand-side
management.
Recent rate cases show Avista seeking a 2% electric rate hike for 2025, partly tied to load-
related investments—growth that could be mitigated with better efficiency measures. The
forecast underplays conservation's potential,justifying more infrastructure costs that
burden fixed-income households.The Commission should require sensitivity analyses
showing efficiency-driven scenarios and tie approval to enhanced rebate programs.
3. Lack of Transparency on PURPA Contract Extensions
Avista reports no new long-term PURPA contracts or Power Purchase Agreements since
2024 but plans to extend two expiring ones: Meyers Falls and Sheep Creek hydro facilities,
with details in a "confidential attachment:'These small hydro projects provide valuable
Local energy,yet Avista offers no public insight into extension terms or pricing, raising
concerns about fairness in PURPA negotiations.
With Idaho's clean energy landscape evolving, extending these contracts without scrutiny
misses opportunities for other local resources. Ratepayers deserve to know if these
extensions lock in above-market rates, especially amid past PURPA disputes where utilities
retained renewable credits. I challenge the Commission to unredact key details or require
public hearings on these extensions to ensure they benefit ratepayers.
Broader Impacts on Ratepayers and Recommendation
These issues compound in Avista's recent multi-year rate plan filing(AVU-E-25-01),
proposing up to 14.7% residential bill increases by September 2025 for infrastructure—
costs inflated by questionable forecasts here. Idaho ratepayers, many on tight budgets in
rural areas, can't afford plans that prioritize utility profits over transparency and
affordability.
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In summary, Avista's filing is challengeable on grounds of inflated gas prices, inadequate
load mitigation, and secretive contracts—all risking higher rates without commensurate
benefits. I strongly oppose approval as-is and request a formal hearing for cross-
examination. Please consider this input to protect ratepayers and ensure fair energy
policies.
Thank you for your service.
All the best,
Sean Holm
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