20260123Staff Comments.pdf

RECEIVED
January 23, 2026
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11560
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION AND THE REGENTS OF ) CASE NO. AVU-E-25-16
THE UNIVERSITY OF IDAHO'S JOINT )
PETITION FOR THE APPROVAL OF A )
POWER PURCHASE AGREEMENT ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On December 9,2025,Avista Corporation("Company")and the Regents of the University
of Idaho ("University" or "Seller") (jointly, the "Parties") filed a joint petition requesting the
Commission approve of the Power Purchase Agreement ("PPA") between the Company and the
University for its 132.32-kilowatt solar facility. The solar facility is a qualifying facility ("QF")
under the Public Utility Regulatory Policies of Act of 1978. The proposed PPA would replace the
current contract that will expire on February 16, 2026. The energy generated by the QF will first
be used to serve the University's load, and then the surplus energy, if any, will be sold to the
Company on an as-available basis.
STAFF COMMENTS 1 JANUARY 23, 2026

STAFF ANALYSIS
Staff reviewed the proposed avoided cost rates, the arrangement of sharing renewable
energy credits ("RECs"), and Section 9.6 (Modification). Staff recommends that the Commission
approve the proposed PPA.
Avoided Cost Rates
The Parties proposed to use the same avoided cost rates as those contained in the current
contract, which are 85% of the PowerDex hourly Mid-Columbia index ("Mid-C Index") prices.
Staff believes the proposed avoided cost rates are reasonable. Traditionally, 85% of non-firm
market index has been used to price as-available energy from QFs. For example, Idaho Power's
Schedule 86 prices as-available energy at 85%of non-firm market prices. The specific PowerDex
hourly Mid-C Index was allowed to represent a non-firm market index in Order No. 33048.
Renewable Energy Credits
The parties propose to share the RECs equally in the PPA, which is the same arrangement
under the current contract. Because the PPA uses neither published avoided cost rates nor
Integrated Resource Plan ("IRP")-based avoided cost rates, Staff believes the arrangement is in
the discretion of the Parties.
Order No. 32697 states that QFs that use published avoided cost rates will retain all the
RECs, and QFs that use IRP-based avoided cost rates will share the RECs with the utility equally.
Section 9.6 (Modifications)
Staff reviewed Section 9.6(Modification)in the PPA that addresses potential modifications
to the Facility and believes the language complies with Order No. 35705.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the proposed PPA and declare the
Company's payments to University of Idaho for the purchase of energy from the QF under the
PPA be allowed as prudently incurred expenses for ratemaking purposes.
STAFF COMMENTS 2 JANUARY 23, 2026

Respectfully submitted this 23rd day of January 2026.
Erika K. Melanson
Deputy Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\AVU-E-25-16 Comments.docx
STAFF COMMENTS 3 JANUARY 23, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23rd DAY OF JANUARY 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF , IN CASE
NO. AVU-E-25-16, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
Company The Regents of the University of Idaho
Chris Drake Edith Pacillo
Manager Resource Optimization Senior Associate General Counsel
Greg Hesler 322 E. Front Street, 324 D
Senior VP General Counsel Boise, ID 83702
1411 E. Mission Ave., MSC-7 elpacilloguidaho.edu
Spokane, WA 99202 counsel(d),uidaho.edu
chris.drakegavistacorp.com
gre .hg esler(aavistacorp.com Gregory Adams
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83702
greg(a,richardsonadams.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE