20251029Staff Comments REDACTED.pdf

RECEIVED
October 29, 2025
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S PROPOSED TARIFF ) CASE NO. AVU-G-25-08
SCHEDULE 195—OPTIONAL RENEWABLE )
NATURAL GAS )
REDACTED COMMENTS OF
THE COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney
General, submits the following comments.
BACKGROUND
On August 29, 2025, Avista Corporation dba Avista Utilities ("Company") applied for
authority to revise tariff Schedule 195 - Optional Renewable Gas ("Application"). The Company
proposes modifications to the voluntary Renewable Natural Gas ("RNG")program ("RNG
Program") that provides customers an opportunity to purchase RNG renewable thermal
certificate ("RTC") attributes as part of their regular monthly service. The proposed
modifications would increase the therm attributes provided to program participants from 1.5
therms to 2 therms per$5.00 block. The Company requests a January 1, 2026, effective date.
In Order No. 35520, the Commission approved the Company's request to implement
Schedule 195. The tariff sheets approved in Order No. 35549 provide customers with an
opportunity to purchase blocks of RNG in addition to the customer's regular natural gas charges
STAFF COMMENTS 1 OCTOBER 29, 2025

to help offset their carbon emissions. Each block includes environmental attributes represented
by the equivalent to 1.5 therms of RNG for$5.00 per block.
The Company states that after its original contract to acquire RNG for its RNG Program
expired in December 2024, the Company was able to secure a more favorable price in its new
RNG RTC supplier agreement. Application at 2. The Company proposes to pass the savings
from the new agreement onto customers participating in the RNG Program. Id.
The Company seeks to update its RNG Program by increasing each block of RNG RTC
attributes by 0.5 therms. With this change each RNG block would represent the environmental
benefit equivalent of 2 therms of RNG. The Company believes that preserving the original $5.00
cost per block provides consistency and additional benefits to participating customers without an
added bill impact. Id. at 3.
STAFF ANALYSIS
Staff evaluated the Company's filing to determine if the proposed RNG Program
modifications provide benefit to Idaho customers and that non-participants will not bear the costs
of the program. Staff recommends the Commission approve the requested RNG Program
modification to increase the therms provided per block from 1.5 therms to 2 therms.
Staff reviewed the Company's proposed Schedule 195 tariff documents and discovered a
few small discrepancies. If the Company's proposed RNG Program modification is approved,
Staff recommends that the Company file corrected"TRF SCH 195-08-29-25 CLEAN" and"TRF
SCH 195-08-29-25 LEGISLATIVE" which have the appropriate version information, issued
date, and effective date.
Staff examined the 3 previous years RNG Program Annual Reports to confirm that all
RNG Program costs are isolated and completely funded from within the program itself. During
this review Staff identified inconsistencies within the RNG Program Annual Reports, which the
Company indicated a willingness to improve.
RNG Program
The existing program provides natural gas customers the opportunity to purchase blocks
of RNG, at a price of$5.00 per block. Each block consists of RTC attributes representing the
environmental benefit equivalent of 1.5 therms of RNG. Application at 2. For program
STAFF COMMENTS 2 OCTOBER 29, 2025

participants, all purchased RNG Program block charges are included on their monthly bills.
"TRF SCH 195-08-29-25 CLEAN" at 1. The proposed change to the RNG Program provides
participants with 2 therms per block instead of the current 1.5 therms per block with no change in
the $5.00 per block cost. Application at 1.
RTC Supply
The Company executed a 15-year contract with Pine Creek im to obtain RTCs.
Response to Production Request No. 1. The Second Amendment to this contract, executed in
2025, identifies a commitment to provide. of the RNG RTCs originating from their facility
beginning . Id. Staff believes this provides the means necessary for the Company
to avoid supply deficiencies and appropriately support this RNG Program and enhances the
Company's ability to support their system wide renewable goals and programs.
RTC Management
The Company indicates that it will continue to use the Midwest Renewable Energy
Tracking System ("M-RETS") for the program. M-RETS is an online platform that issues RTCs
for fuel producers and provides certificate management, authentication, and retirement for
companies which have acquired the RTCs. 1
Program Costs
Staff reviewed the Company's RNG Program actual expenses and revenues since the
program began in Idaho in 2022, as well as a forecasted budget provided in Attachment A. The
Company's forecast shows that the proposed modification will maintain an operating surplus
sufficient to support the program and will not result in a significant amount of program income.
Based upon this information, Staff is confident that all costs of the Program are supported
internally and will avoid cost shifts to non-participants.
Tariff
Staff examined the Company's proposed Schedule 195 tariff revision and identified an
'https:Hcleancounts.oriz/subscription-costs/thermal-pricing-and-registry-documents/
STAFF COMMENTS 3 OCTOBER 29, 2025

issue with the version information, issued date, and effective date provided on page 2 of both
"TRF SCH 195-08-29-25 CLEAN" and"TRF SCH 195-08-29-25 LEGISLATIVE." Staff
recommends the proposed tariff revision be approved, provided the dates and version
information are corrected in both documents.
Annual Reporting
In Order No. 35520, the Company was ordered to file Annual RNG Program reports with
Idaho-specific details of specific metrics and the status of program income, expenses, and
operating reserves. While the required reports have been filed each year in a timely manner, the
content of those reports is inconsistent and, in some cases, lacking required information. Staff
believes there are opportunities for the Company and Staff to collaborate to improve existing
reporting requirements and track cost allocations and data points. Staff appreciates and supports
the Company's desire to provide meaningful reports relative to program outcomes and that
comply with Commission orders.
STAFF RECOMMENDATION
Staff recommends the Commission:
1) Approve the Company's Application which will increase the RNG Program per block
RTC attribute rate from 1.5 therms to 2 therms while maintaining the original per
block cost of$5.00; and
2) Direct the Company to file modified Tariff Rate Schedule "TRF SCH 195-08-29-25
CLEAN" and "TRF SCH 195-08-29-25 LEGISLATIVE", consistent with changes
outlined above.
Respectfully submitted this 29th day of October 2025.
)ffff*rR. oll
Deputy Attorney General
Technical Staff. Vicki Stephens
L\Utility\UMISC\COMMENTS\AVU-G-25-08 Comments-Redacted.doex
STAFF COMMENTS 4 OCTOBER 29, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS � DAY OF OCTOBER 2025,
SERVED THE FOREGOING REDACTED COMMENTS OF THE COMMISSION
STAFF , IN CASE NO. AVU-G-25-08, BY E-MAILING A COPY THEREOF TO THE
FOLLOWING:
AMANDA GHERING
REGULATORY AFFAIRS MANAGER
AVISTA CORP.
1411 E. MISSION AVE
SPOKANE WA 99220-3727
E-mail:amanda.i;herint,,@avistacoM.com
PA RICIA JORD4eN, SECRETARY
CERTIFICATE OF SERVICE