20260410Exhibit 1.pdf

I Peter J. Richardson
515 N. 271" Street
2 Boise, Idaho 83702
3 [phone] Office
[phone] Mobile
4 peter(d)richardsonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF THE APPLICATION CASE No.: AVU-E-26-01
9 OF AVISTA CORPORATION FOR
APPROVAL TO INCREASE ITS ENERGY
to EFFICIENCY TARIFF RIDER COMMENTS IN OPPOSITION TO
11 ADJUSTMENT SCHEDULE 91 MODIFIED PROCEDURE BY
CLEARWATER PAPER CORPORATION
12 CASE NO. AVU-E-26-01; and
13 IN THE MATTER OF AVISTA
CASE No.: AVU-E-25-12
CORPORATION'S APPLICATIONS FORA
14 DETERMINATION OF 2024 ELECTRIC CLEARWATER PAPER CORPORATION'S
15 AND NATURAL GAS ENERGY PETITION FOR RECONSIDERATION OF
EFFICIENCY EXPENSES AS PRUDENTLY ORDER NO. 36975 IN DOCKET NO. AVU-
16 INCURRED E-25-12.
17
18
19
Exhibit One
Avista Response to Clearwater Paper Production
Request No. 4.
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AVISTA CORP.
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 04/02/2026
CASE NO.: AVU-E-26-01 WITNESS: Nicole Hydzik
REQUESTER: Clearwater Paper RESPONDER: Meghan Pinch
TYPE: Production Request DEPT: Energy Efficiency
REQUEST NO.: Clearwater- 04 TELEPHONE: [phone]
EMAIL: [e-mail]
REQUEST:
Please explain and document whether and why the Company believes its expenditures for the Small
Business Lighting direct-install program are cost effective — please respond generically and specifically
for each measure offered under said program.
RESPONSE:
Please refer to the Company's most recent Annual Conservation Report in Case No. AVU-E-25-12 for
further details regarding the cost effectiveness of Avista's energy efficiency portfolio, including the UCT
for the commercial/industrial sector (of which SBL is a large contributor) and for additional information
regarding SBL program performance.
The Company is continuously adapting its SBL program to ensure cost effective benefits for its
customers. Between 2025 and 2026, the SBL program underwent substantial eligibility tightening,
product standard updates, incentive limitations, and cost effectiveness mandates to slow the overall pace
of program spending, increase cost-effectiveness, and align with evolving efficiency standards.
Collectively, these changes have materially reduced program spending, ensured compliance with evolving
efficiency standards, and improved the targeting of incentives to small commercial customers with the
highest energy savings potential and financial need.
The Environmental Protection Agency (EPA) finalized the sunset of the Energy Star specifications for
lamps and luminaires in December 2024. As a result, these product categories, including common lamp
types such as screw base LED lamps and other previously qualified decorative fixtures, were no longer
covered under an active Energy Star specification effective January 2025 and therefore became ineligible
for participation in the SBL program. Recessed downlights also transitioned to a new specification in
January 2025, which introduced more stringent performance requirements and resulted in many
downlights becoming ineligible for the program.
Effective February 2025, municipalities, universities, schools, and hospitals (MUSH) became ineligible
for participation in the SBL program. These customers were added to the original group of customer types
that have been ineligible since program launch, which includes big-box retailer, large corporations and
national chains. These eligibility restrictions are intended to ensure that SBL program funding remains
focused on small commercial customers who generally have limited access to capital and fewer resources
to pursue energy-efficiency investments absent program support.
Also, effective February 2025 was the cost effectiveness threshold requirement that all projects must meet
a cost-effectiveness requirement of$0.72/kWh or lower, based on the cost per kilowatt-hour saved. This
calculation is assessed using total installed project cost (labor + materials) and estimated annual kWh
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savings. This requirement ensures SBL incentives are directed toward the most cost-effective projects and
reduces the likelihood of overspending on low-savings or high-cost installations.
In mid-June 2025, additional limitations were implemented to further refine program eligibility and
exclude customer segments that did not align with the SBL program's intent to serve small commercial
customers. The following customer types became ineligible:
• Franchise businesses with more than five locations
• Landlords with vacant tenant spaces, unless the space:
o Is expected to be occupied within 90 days, and
o Has written confirmation of future occupancy and expected operating hours
• Parking lots
These changes were designed to reduce participation from multi-site customers and from applications
characterized by higher installation costs, thereby ensuring that program funds remain focused on the
small business segment the SBL program was established to serve.
In November 2025, Design Lights Consortium (DLC) Solid-State Lighting (SSL) Version 6.0
requirements introduced higher-efficiency standards, and since only products meeting current DLC or
Energy Star listing remain eligible for the SBL program, narrowing the pool of qualifying equipment and
reducing total SBL incentives.
Beginning January 2026, a maximum total incentive amount per SBL project in Idaho was set, not to
exceed $50,000.
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