20260417Reply Comments.pdf

' 11
Avista Corp.
1411 East Mission P.O. Box 3727
Spokane, Washington 99220-0500
Telephone [phone] APRIRECEIVED
2026
Toll Free 800-727-9170 IDAH 17,DAHO PUBLIC
UTILITIES COMMISSION
April 17, 2026
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. AVU-E-26-01 —Reply Comments of Avista Utilities
Dear Commission Secretary:
In accordance with the Order Vacating Comment Deadlines and Amended Notice of
Modified Procedure, issued by the Idaho Public Utilities Commission (IPUC or Commission) on
March 16, 2026,1 and in response to the written comments of Commission Staff (Staff) and
Clearwater Paper Corporation(Clearwater)filed on April 10,2026,Avista Corporation,dba Avista
Utilities (Avista or the Company), respectfully submits the following Reply Comments.
Avista appreciates Staff s thorough and thoughtful review of its Application to Increase its
Energy Efficiency Tariff Rider Adjustment Schedule 91 (Application), including all subsequent
production requests and discussions that ultimately led to Staff s comprehensive written analysis
and comment summary contained within the aforementioned Staff comments in this case. The
Company supports Staffs recommended modification to adopt a 36-month forecast and recovery
period to better improve consistency and lessen the rate impact of the filing. In furtherance of this
requested change, Avista has provided updated tariff sheets,reflective of the extended forecasting
timeframe (36 months), as Exhibit No. 1 to this filing, and the workpapers supporting the tariff
sheets as Exhibit No. 2 to this filing.2
' Order No. 36964.
2 Tariff Schedule 91, "Energy Efficiency Rider Adjustment — Idaho" has been provided in both proposed and
legislative format per Idaho Rules of Procedure(RP 121).

With regard to Clearwater's filed "Comments in Opposition" to the Company's
Application, the Company acknowledges the concerns regarding the rate impact of this filing and
reiterates that the purpose of this tariff rider increase is to ensure appropriate recovery of expenses
required to maintain a cost-effective energy efficiency portfolio—one that provides benefits to all
Avista customers in Idaho,including Clearwater.In fact,Clearwater has received over$2.9 million
in direct incentives from the Company's energy efficiency programs since 2021 and is saving
approximately 14.2 million kWh in energy usage per year as a result of these efficiency upgrades.
This rate adjustment filing is intended to not only reconcile previous periods' actual expenditures
and collections but also establish a collection rate within the rider that is sufficient to fund the
Company's energy efficiency programs into the future. Therefore, incorporation of prudently
incurred historical costs is just one component of what makes up the Schedule 91 tariff rider rate.
An equally important component is the forward-looking projection of the anticipated budget
needed to support the Company's future cost-effective energy efficiency portfolio offerings.
Importantly, this rate adjustment is in alignment with utilities' historical practices of truing up
prior periods and forecasting the need for future periods; as such, the Company has not set a new
precedent or proposed any new types of ratemaking treatment or rate designs with this filing.
Further, it is worth noting that as responsible stewards of this customer-funded program,
the prudency of Avista's energy efficiency programs are subject to an extensive and highly
scrutinized Commission approval process, which includes a continuous cycle of planning,
reporting, third-party evaluation and verification, ongoing collaboration with the Company's
Energy Efficiency Advisory Group (EEAG), and annual prudence auditing from Commission
Staff. Much of this cycle is a public process, and one which Clearwater has the opportunity to
participate in should it so choose. Clearwater's assertion that Avista's Application should be
denied based on their brief and incorrect conclusions of imprudence, as further detailed within the
accompanying Petition for Reconsideration of Order No. 36975 in Docket No. AVU-E-25-12
(Petition), are addressed fully within the Company's answer to their Petition, which was filed in
Docket No. AVU-E-25-12 coincident with the filing of these comments.
In conclusion, the Company requests that the Commission approve of its Application, and
associated tariff sheets, as modified based on Staffs recommendation, effective May 1, 2026. If

you have any questions regarding this filing, please contact me at (509) 495-7839 or
j aime.stpeter&avistacorp.com.
Sincerely,
1s1 Pime .5I! ;Ve&i
Jaime St Peter
Regulatory Affairs Manager