20260518Reply Comments.pdf

' 11
Avista Corp. RECEIVED
1411 East Mission P.O. Box 3727 MAY 18, 2026
Spokane, Washington 99220-0500 IDAHO PUBLIC
Telephone [phone] UTILITIES COMMISSION
Toll Free 800-727-9170
May 18, 2026
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. AVU-E-26-03 —Reply Comments of Avista Utilities
Dear Commission Secretary:
In accordance with the Notice of Application and Notice of Modified Procedure issued by
the Idaho Public Utilities Commission(IPUC or Commission) on April 20,2026,1 and in response
to the written comments of Commission Staff(Staff) filed on May 11, 2026, Avista Corporation,
dba Avista Utilities(Avista or the Company),respectfully submits the following Reply Comments.
Regarding Staff s recommendations one through three, Avista agrees with said
recommendations and will implement the changes into an amended agreement on compliance with
the final order issued in this case.
Regarding Staff s fourth recommendation of adopting market prices without the impact of
Washington's Climate Commitment Act (CCA), the Company does not support addressing this
recommendation within this case as the PURPA agreement at hand is very small and any decision
made related to this agreement does not need to be precedential for future agreements or decisions.
Under the PURPA agreement subject to approval in this case, the Surrogate Avoided Resource
(SAR) rates are the primary rates used to compensate the Qualifying Facility (QF). The 90/110
provision and the associated 85% Powerdex adjustment, while a long-standing provision in
PURPA agreements, are unlikely, if at all, to be used to calculate payments to Ford Hydro, rather
1 Order No.37009.

the payments will likely only be calculated using the IPUC published SAR rates. As a result, the
Company believes Idaho customers are unlikely to incur incremental costs attributable to CCA
impacts embedded in market prices within this agreement.
In general, Avista understands Staff s concern of Idaho customers not bearing any costs
related to the CCA, including market prices that may include CCA impacts. However, the
Company believes that this issue has potentially broad implications that should be carefully
considered. As such, this issue should be addressed in a future general rate case or broad QF
proceeding where a full record can be developed and all interested parties can weigh in. Further,
any such adjustments to market prices should be applied holistically across the Company's
resource portfolio, which may result in a reduction in value for the portfolio. Such a reduction in
value that reflects lower prices for non-CCA power will have the effect of diminishing surplus
sales revenues and a commensurate increase in Idaho customer rates. Hence the reason this should
be contemplated in a broader proceeding.
For the reasons mentioned above, the Company requests that the Commission issue an
order approving the agreement with Ford Hydro, subject to Staffs recommendations one through
three. If you have any questions regarding these Reply Comments,please contact me at(509)495-
2782 or shawn.bonfield(&,avistacorp.com.
Sincerely,
lsl,S" Far &,W
Shawn Bonfield
Sr. Manager, Regulatory Policy& Strategy