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HomeMy WebLinkAbout20260612APPLICATION.pdf RECEIVED 1 ANNI GLOGOVAC June 12, 2026 2 ISB #13010 IDAHO PUBLIC 3 COUNSEL, LEGAL DEPARTMENT UTILITIES COMMISSION 4 AVISTA CORPORATION 5 P.O. BOX 3727, MSC 33 6 1411 EAST MISSION AVENUE 7 SPOKANE, WASHINGTON 99220-3727 8 TELEPHONE: (509) 495-7341 9 EMAIL: ANNI.GLOGOVAC@AVISTACORP.COM 10 11 12 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION 13 14 ) 15 IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-G-26-01 16 OF AVISTA CORPORATION FOR AN ) 17 ORDER AUTHORIZING TEMPORARY ) APPLICATION OF AVISTA 18 SUSPENSION OF ITS NATURAL GAS ) CORPORATION FOR CHANGES 19 DEMAND SIDE MANAGEMENT PROGRAMS ) TO SCHEDULE 190 20 ) 21 22 I. INTRODUCTION 23 Avista Corporation, doing business as Avista Utilities ("Avista" or the "Company"), 24 at 1411 East Mission Avenue, Spokane, Washington, pursuant to Idaho Code § 61-524 25 and IDAPA 31.01.01, Rules of Procedure (RP), Rule 52 et. seq., of the Idaho Public 26 Utilities Commission ( PUC or "Commission"), hereby respectfully requests that the 27 Commission issue an order authorizing the proposed revisions to the Company's Schedule 28 190, "Natural Gas Efficiency Programs". The purpose of these tariff revisions is to 29 suspend the Company's natural gas demand-side management (DSM) programs due 30 to anticipated low cost-effectiveness resulting from natural gas avoided costs projected 31 within Avista's Integrated Resource Plan (IRP) process. This filing will hereafter be 32 referred to as the "Application". 33 Avista is a utility that provides service to approximately 423,000 retail 34 electric customers and 383,000 natural gas customers in a 30,000 square-mile service territory covering portions of northern Idaho, eastern Washington, and Oregon. The largest Application of Avista Corporation Page 1 C 4ftAgki4ybTv d26-01 I by Avista is Spokane, Washington, which is the location of its corporate headquarters. The 2 Company requests that all correspondence related to this Application be directed to: 3 Anni Glogovac Shawn Bonfield 4 Counsel for Regulatory Affairs Sr. Manager, Regulatory Policy& Strategy 5 Avista Corporation Avista Corporation 6 P.O. Box 3727 P.O. Box 3727 7 1411 E. Mission Avenue, MSC 27 1411 E. Mission Avenue, MSC 27 8 Spokane, Washington 99220-3727 Spokane, Washington 99220-3727 9 Telephone: (509) 495-7341 Telephone: (509) 495-2782 10 E-mail: anni.glo og vac(kavistacorp.com E-mail: shawn.bonfield(a),avistacorp.com 11 12 Avista Dockets (Electronic Only) -AvistaDocketskavistacorp.com 13 14 II. BACKGROUND 15 As part of its annual DSM business planning process, Avista looks to its IRP to 16 establish a suite of measures with conservation potential for future years, and to provide the 17 Company with insights into avoided costs for the establishment of cost-effectiveness within its 18 DSM programs. The Company monitors these natural gas avoided costs to optimize and 19 maintain the cost-effectiveness of its natural gas DSM portfolio. 20 In 2023, the Company's 2023 Natural Gas IRP provided early indications of limited 21 cost-effectiveness flexibility into 2024-2025 due to lower avoided costs. While the decline of 22 natural gas avoided costs may mean lower gas supply prices and therefore be good news for 23 consumers of natural gas, these lower avoided costs add complex challenges to a utility's 24 ability to offer a comprehensive natural gas DSM portfolio while still remaining cost effective. 25 In an effort to offset these changes in avoided costs while planning its 2024 DSM efforts, and 26 because the Company's commercial natural gas efficiency programs were experiencing lower- 27 than-expected throughput,Avista focused its natural gas portfolio on residential sector savings 28 and was able to plan for a 2024 program year that would remain cost effective. As savings 29 achievements began to be realized during 2024, however, the Company observed a trajectory Application of Avista Corporation Page 2 Case No. AVU-G-26-01 I of lower-than-expected cost effectiveness and began discussions with PUC Staff to signal 2 concerns regarding the ability to continue delivering cost-effective natural gas DSM offerings. 3 On August 1, 2024, the Company filed its request for a determination of prudence of its 2022 4 and 2023 natural gas DSM expenses;' Avista's natural gas portfolio received a Utility Cost 5 Test(UCT)ratio of 1.37 for 2022 and 1.01 for 2023, based on verified savings.2 6 In October 2024, Avista again analyzed the cost effectiveness of its natural gas 7 portfolio and observed yet another decline in cost effectiveness. This equated to an 8 approximate 20 percent decrease in the cost effectiveness for the Company's gas portfolio. 9 Based on this examination, the Company took immediate actions to tighten various offerings 10 within the natural gas portfolio in an effort to preserve cost effectiveness despite the reduction 11 in avoided cost and lack of site-specific project throughput becoming increasingly prevalent 12 throughout 2023 and 2024.3 The Company made immediate reductions in the natural gas 13 incentives of several measures and eliminated measures that were no longer cost effective in 14 order to improve the cost effectiveness of its 2025 program year.4 Simultaneously, the 15 Company's Account Executive team pursued outreach efforts to encourage engagement in, and 16 completion of, site-specific projects. 17 As part of Avista's 2022-2023 prudence case, PUC Staff noted within their filed 18 Comments an expectation to halt natural gas DSM programs if Avista finds they cannot be 19 planned as cost-effective, stating that"Staff expects the Company to file to suspend its natural 20 gas programs if the Company believes that it cannot implement cost-effective programs at the ' See Case No.AVU-G-24-03. 2 Ibid,Application at pg.7. 3 See respective Annual Conservation Reports (ACRs)within Case Nos. AVU-G-24-03 for 2023 and AVU-G- 25-09 for 2024. 4 Insulation rebate measures and thermostats were eliminated; window incentives and furnace incentives were reduced to cost-effective thresholds;non-cost effective measures within Midstream were reduced or eliminated; and new cost-effective measures were added to midstream,including conveyor broilers and pasta cookers. Application of Avista Corporation Page 3 Case No. AVU-G-26-01 I time of program planning."' By this time, Avista had already planned a cost-effective DSM 2 portfolio for 2025,and was pursuing further analysis to improve its potential cost-effectiveness 3 for future planning years. This analysis, which utilized billing analyses as a means to estimate 4 furnace measure savings for future cost-effective planning instead of Regional Technical 5 Forum (RTF) baselines, was presented to Commission Staff in June 2025. Avista's 2024 6 prudence application was filed shortly thereafter on August 29, 2025 (Case No. AVU-G-25- 7 09), in which the Company's natural gas program reported a UTC ratio of 1.05.E During the 8 pendency of its 2024 prudence case, the Company continued its planning cycle for the 2026 9 program year, again reducing or eliminating measures that could harm potential cost- 10 effectiveness.7 As part of this planning,Avista incorporated the new natural gas avoided costs 11 from the 2025 IRP, which showed reduced values in avoided costs per therm—in some cases 12 as high as 69% less,with an overall average of 14%less. Even with these lower avoided costs, 13 Avista was hopeful that it could appropriately plan for a cost-effective natural gas program for 14 2026,using the billing analysis methodology noted above. 15 Then, in its final order regarding Avista's 2024 prudence determination, the 16 Commission directed the Company to "make necessary adjustments to the evaluation method 17 of the natural gas furnace measure consistent with the Order to reflect the evaluation history 18 and other baseline sources", and encouraged the Company to"explore possible revisions to its 19 natural gas EE program with its Energy Efficiency Advisory Group to ensure it maintains cost- 20 effectiveness considering the necessary adjustments to the evaluation method for the furnace 21 measure prior to filing to suspend its natural gas program." 8 With this directive, and the 5 Case No.AVU-G-24-03, Comments of the Commission Staff,December 19,2024,pg. 7. 6 See Case No.AVU-G-25-09. 7 Incentives for residential shell measures, such as windows and doors,were reduced;home energy audits were eliminated;and gas furnace incentives were significantly reduced. a Case No.AVU-G-25-09,Order No. 36975,pg.4. Application of Avista Corporation Page 4 Case No. AVU-G-26-01 I associated reduction in potential planned furnace savings (from around 80-85 therms per 2 furnace to approximately 65 therms per furnace, as described below) resulting from the 3 required change in methodology, Avista confirmed that cost-effectiveness could no longer be 4 adequately planned for until such time that avoided costs increased. 5 The Company, having provided updates and/or discussed the issue of natural gas cost 6 effectiveness and the potential need for temporary suspension of its natural gas DSM programs 7 in Idaho with its Energy Efficiency Advisory Group (EEAG) since the issue was initially 8 discovered,9 again brought this subject to the EEAG on May 19, 2026. At that time, Avista 9 informed its EEAG of the final decision to file for suspension of its Idaho residential and 10 commercial natural gas DSM programs in June 2026, and to concurrently set the associated 11 Schedule 191 "Energy Efficiency Rider Adjustment" (DSM Rider) collection rate to 12 $0.00/therm for every rate class. This Application is being made in accordance with that 13 decision. 14 15 III. COST TEST ANALYSIS 16 Avista,in its initial planning for 2026,conducted an optimization analysis on its natural 17 gas efficiency portfolio to create a best-case scenario for cost effectiveness (i.e., maximize 18 UCT). In this analysis, the outcome was dependent on several assumptions, including the per- 19 unit therm savings for various measures. The best case scenario Avista was able to generate 20 with this analysis was a UCT ratio of 1.07;this scenario,however,required a standard per-unit 21 therm savings of 80 therms per natural gas furnace. While this aligned with the billing analysis 22 methodology previously recommended by the Company and its third-party implementor,lo 9 The EEAG discussed this topic in October 2024,March 2025,June 2025,and August 2025. 10 Qualus;this implementor is that same that provided the prior billing analysis evaluation methodology proposed to PUC Staff during 2025-2026. Application of Avista Corporation Page 5 Case No. AVU-G-26-01 I after having been directed by the Commission to plan for furnace measures utilizing baseline 2 sources,the implementor recalculated anticipated therm savings for Avista's natural gas DSM 3 program using the Post-Program Regression (PPR) and propensity score matching sampling 4 evaluation methodology recommend by PUC Staff." This change in evaluation methodology 5 lowered the per-unit savings to approximately 65 therms, which forced the optimal case for 6 the portfolio to a maximum of 0.94 UCT. Under these current conditions, barring anomalous 7 participant behavior or the ability to maintain current adoption rates while offering virtually 8 zero incentive, a UCT of one or greater is not possible for Avista to plan, for the remainder of 9 2026 or into the foreseeable future (at minimum, through 2027). 10 The Company remains committed to a continual re-evaluation of the prospects for its 11 natural gas DSM portfolio. Should natural gas costs,technologies or delivery methods change 12 in such a manner to allow for cost-effective opportunities in the future,the Company will move 13 to return all or portions of the natural gas DSM portfolio to the Company's overall energy- 14 efficiency strategy. As provided to its EEAG at its May 19, 2026 meeting, Avista plans to 15 evaluate updated avoided costs from its IRP in 2027 to determine if 2028-2029 program years 16 can be planned as cost-effective with relative certainty. Based on these analyses,the Company 17 will decide if/when to request reinstatement of its natural gas DSM programs. 18 19 IV. PROPOSED TRANSITION OF PROGRAMS 20 Regarding the procedure for temporarily discontinuing these programs, Avista looked 21 to its prior suspension of its natural gas DSM programs — which occurred in 2012, with 22 reinstatement of these programs in 2015 — as precedent.12 As part of this program transition, 11 Case No.AVU-G-25-09, Comments of the Commission Staff,December 19,2024,pgs. 6-10. 12 See Case Nos.AVU-G-12-03 and AVU-G-12-06 for suspension and AVU-G-15-03 for reinstatement. Application of Avista Corporation Page 6 Case No. AVU-G-26-01 I the Company must manage outstanding contractual obligations, and existing rebate offers in 2 the marketplace while ramping programs down in a way that allows the market to absorb these 3 changes. Additionally, while a notable difference in the temporary suspension of natural gas 4 programs that occurred over a decade ago, the Company sees value for Idaho customers in 5 maintaining its connection to the regional market transformation efforts of the Northwest 6 Energy Efficiency Alliance (NEEA)while the rest of Avista's natural gas efficiency offerings 7 are paused. Below is a summary of the transitional changes to the natural gas DSM portfolio, 8 which are captured at a high level within the tariff modifications proposed. 9 Site Specific Programs 10 Avista will honor all terms and conditions of contracts and agreements that are fully 11 executed prior to December 31,2026; exceptions to this date are further detailed within 12 the proposed Schedule 190 modifications. 13 14 Residential and Non-Residential Prescriptive Rebate and Bid Programs 15 Customers seeking a rebate for qualified residential and nonresidential equipment may 16 submit rebate applications for equipment purchased on or before December 31, 2026. 17 Customers must send to Avista all required rebate forms and other required 18 documentation for qualifying projects postmarked by January 15, 2027 to be eligible 19 for payment; any requests postmarked after January 15, 2027 will be denied payment. 20 Bids offered through the Business Partner Program must be completed before 21 December 31, 2026. 22 23 Midstream Rebate Program 24 Participating distributors may submit invoices to the program implementer for natural 25 gas equipment purchased on or before December 31, 2026. Final payment to the 26 midstream vendor for any Idaho gas equipment with a 2026 distributor invoice will be 27 made on or before May 15, 2027. 28 29 NEEA 30 The Company proposes to continue participation in NEEA's natural gas portfolio during 31 the time the remainder of its natural gas portfolio is suspended. Avista's participation in 32 NEEA's market transformation efforts has proven to be a highly cost-effective addition to 33 Avista's natural gas portfolio. The Company believes it to be in Idaho customers' best 34 interest to remain in the partnership due not only to the cost-effective nature of this 35 partnership but also given the longer term development timing of market transformation 36 activities. As part of its EEAG collaboration regarding the suspension of its natural gas 37 programs, NEEA representation noted an observation that longer planning cycles are a 38 recognized feature of upstream market development, meaning that Avista's pause in 39 natural gas incentives could have lasting impacts for NEEA. More specifically, Application of Avista Corporation Page 7 Case No. AVU-G-26-01 I manufacturers and other upstream market actors often plan production facilities, supply 2 chains, and product offerings on a two- to five- year horizon. In instances where utility 3 incentive programs like Avista's are expected to support these market strategies,disruption 4 or discontinuation of these programs can materially affect planning assumptions, increase 5 market uncertainty,or alter product mix decisions.Resultingly,discontinuation of program 6 support may produce effects that persist for several years before adjustments or 7 reestablishment of prior activity levels is possible. With these insights in mind, Avista is 8 proposing within this Application to continue funding NEEA while the rest of its natural 9 gas energy efficiency offerings are paused. Given the currently overfunded DSM Rider 10 balance13 and the contracted amount of annual NEEA expenditures,14 existing balances 11 are sufficient to cover this continuation. 12 Limited Income Program 13 All existing 2026 Community Action Partnership (CAP) contracts with natural gas 14 incentives will be honored. The program will be suspended on December 31, 2026, and all 15 invoices for work completed on or before December 31, 2026 shall be submitted to the 16 Company by January 31, 2027. 17 18 Due solely to its lack of cost-effectiveness under the UCT, the Company is not requesting 19 to retain its low-income weatherization program throughout its natural gas program 20 suspension timeframe. However, Avista would like to emphasize the incredibly positive 21 impact of its weatherization program on some of Idaho's most vulnerable customers. 22 Although limited income programs are not cost effective by the three of four cost tests 23 (TRC, UCT, RIM), the program had a strong Participant Cost Test (PCT) ratio of 1.26 in 24 2025. The program therefore holds significant benefits for customers who participate in the 25 program by stabilizing energy bills and enhancing housing security. The Company also 26 recognizes that suspension of its natural gas weatherization funding will have a significant 27 and negative impact on the program overall. In 2025, $476,684 (36%) of the $1,318,685 in 28 incentives paid through the program were spent on natural gas low income weatherization. 29 Of the 100 homes weatherized that year, 48 homed (48%) were funded under the natural 30 gas portfolio. Given the heavy participation last year and the clear benefits of the program 31 for the most vulnerable individuals and families in Idaho, the Company considered 32 proposing to continue to operate its weatherization program on a limited basis in 2027 and 33 2028. However,the current DSM Rider balance would not be high enough to support both 34 NEEA and weatherization through 2027 (in addition to the costs incurred throughout the 35 remainder of 2026 and into 2027 as Avista's natural gas DSM programs conclude) and 36 Avista could not justify the continuation of a non-cost effective offering which would 37 ultimately result in an underfunded DSM Rider balance. 38 39 Avista will implement a coordinated and timely communications strategy to notify 40 participating trade allies, customers, and other affected stakeholders of the discontinuation of 13 DSM Rider balance at the end of April was nearly$2.3 million overfunded. 14 The NEEA contracted funding share for Avista is approximately$1.3 million for the 2025-2029 funding cycle, or$270,010 annualized. Application of Avista Corporation Page 8 Case No. AVU-G-26-01 I Idaho gas-only offerings described above. The Company is cognizant of the need to 2 communicate this information in a manner that, to the extent possible, maintains trust in the 3 market while balancing timely and prudent expenditures of the remaining tariff balance. 4 Communications will be designed to provide clear notice of program suspension timelines, 5 applicable project completion and application deadlines,and limitations on incentive eligibility 6 following the effective suspension date. All program-specific information related to natural 7 gas efficiency on Avista's website and related marketing collateral will be updated, as 8 appropriate, in coordination with the sunsetting of applicable gas program measures. 9 For site-specific and Pay-for-Performance(P4P)programs,Avista Account Executives 10 (AEs) will serve as the primary customer contacts during the transition period. AEs will 11 proactively communicate with customers who are considering or developing new natural gas 12 efficiency projects to ensure such customers are informed of the applicable program sunset 13 provisions, including the requirement that all site-specific projects must be contracted no later 14 than December 31, 2026. Upon Commission approval for the September 1,2026 effective date 15 proposed within this filing, customers will be notified through a message on the Company 16 website beginning 120 days prior to the anticipated program suspension date of December 31, 17 2026. 18 For residential and nonresidential prescriptive programs, the same website notice 19 described above will be utilized.Program suspension information will also appear on all rebate 20 forms beginning in September. Avista will notify all participating trade allies, including 21 contractors participating in Idaho residential and commercial natural gas efficiency programs, 22 through direct electronic mail (email) communication. Such notice will advise that all Idaho 23 residential and commercial gas-only rebate programs will sunset and identify all applicable 24 program deadlines and transition requirements. Avista anticipates issuing a summary Application of Avista Corporation Page 9 Case No. AVU-G-26-01 I notification letter no later than ninety (90) days prior to the anticipated December 31, 2026 2 suspension date. Additional program guidance and implementation updates may be provided 3 as necessary to ensure consistent administration of the program wind-down. 4 Honoring the same 120-day notification timeline proposed for all other programs, 5 contractors and distributors will be notified of the temporary discontinuation of Avista's 6 midstream program in September. This information will be shared through in-person visits, 7 email and the website. 8 Lastly,the Company will notify CAP Lewiston of this Application concurrent with the 9 date of filing. The Company will work closely with CAP to determine the best method for 10 notifying qualifying customers of the decision to suspend natural gas weatherization offerings 11 through Avista. 12 13 V. SCHEDULE 191 RATE ADJUSTMENT 14 In alignment with these requested revisions to its Schedule 190 to suspend its natural 15 gas DSM programs, the Company will seek modifications to its DSM Rider Schedule 191, to 16 decrease the collection rate of the funds collected in support of natural gas DSM programs to 17 $0.00/therm for every rate class, during the third quarter of 2026. To allow for more 18 streamlined alignment of customer noticing procedures (and therefore less confusion for 19 customers),this rate adjustment request is not being made concurrently with this Application, 20 and will instead be filed simultaneously with the annual rate adjustments for several other 21 tariffs, which Avista files each year with a requested November 1, 2026 effective date. 22 23 24 Application of Avista Corporation Page 10 Case No. AVU-G-26-01 I VI. CUSTOMER NOTIFICATION OF TARIFF REVISIONS 2 Notice to the public of the proposed revisions, pursuant to IDAPA 31.21.02.102, will 3 be given simultaneously with the filing, by posting of the Application to the Company's 4 website. 5 6 VII. CONCLUSION AND REOUEST FOR RELIEF 7 In conclusion, Avista respectfully requests that the Commission approve its proposed 8 revisions to the Company's DSM Schedule 190, resulting in the temporary suspension of 9 Avista's natural gas energy efficiency programs, with an effective date of September 1,2026. 10 If approved as requested, the Company will then be able to provide adequate notice to its 11 customers of the impending suspension of programs by the end of 2026. Avista also requests 12 this Application be processed under the Commission's Modified Procedure Rules through the 13 use of written comments. 14 Dated this 12th day of June 2026. 15 AVISTA CORPORATION 16 17 By 18 Patrick Ehrbar 19 Director of Regulatory Affairs 20 Avista Corporation Application of Avista Corporation Page 11 Case No. AVU-G-26-01 Fourth Revision Sheet 190 Canceling I.P.U.C. No.27 Third Revision Sheet 190 AVISTA CORPORATION dba Avista Utilities SCHEDULE 190 NATURAL GAS EFFICIENCY PROGRAMS IDAHO 1. AVAILABILITY The services described herein are available to qualifying residential, commercial, and industrial, retail natural gas distribution customers of Avista Corporation for the purpose of promoting the efficient use of natural gas. Customers receiving natural gas distribution service provided under special contract and/or customers receiving natural gas services not specified under Tariff Schedule 191 (Natural Gas Efficiency Rider Adjustment)are not eligible for services contained in this schedule unless specifically stated in such contract or other service agreement. The Company may provide partial funding for the installation of natural gas efficiency measures and may provide other services to customers for the purpose of identification and implementation of cost effective natural gas efficiency measures as described in this schedule. Facilities-based services are available to owners of facilities and also may be provided to tenants who have obtained appropriate owner consent. Assistance provided under this schedule is limited to end uses where natural gas is or would be the energy source and to measures which increase the efficient use of natural gas. Assistance may take the form of monetary incentives or non-monetary incentives, as further defined within this tariff. The acquisition of resources is cost-effective as defined by a Utility Cost Test (UCT) as a portfolio. Customer participation under this schedule shall be based on eligibility requirements contained herein. Effective December 31, 2026, natural gas efficiency programs, incentives and rebates are available only for projects that meet the following conditions: A. Site Specific Programs 1) The Company will honor all terms and conditions of contracts and agreements that are fully executed prior to December 31, 2026. Such contracts and agreements must be signed by both the Company and the Customer. 2) Natural gas energy efficiency projects, proposed by the customer to Avista prior to December 31, 2026, but without fully executed contracts, will be honored by the Company under the following conditions: i. The Company has already conducted an analysis of a proposed natural gas energy efficiency measure. If the Company has not already conducted an analysis of a proposed natural gas energy efficiency measure, customers seeking incentive funding will submit on overview of their proposed natural gas energy efficiency project to the Company in writing or via email by December 31, 2026. Issued June 12, 2026 Effective September 1, 2026 Issued by Avista Corporation By Patrick Ehrbar, Director of Regulatory Affairs �J) -U4 - Seventh Revision Sheet 190A Canceling I.P.U.C. No.27 Sixth Revision Sheet 190A AVISTA CORPORATION dba Avista Utilities SCHEDULE 190 — continued NATURAL GAS EFFICIENCY PROGRAMS - IDAHO ii. All material documentation required for Avista to conduct an analysis to determine energy efficiency savings and potential incentive funding must be received by the Company by January 15, 2027. The Company has the sole discretion to determine if such documentation is sufficient for analysis, and if the documentation is not sufficient, will reject the project from incentive funding consideration. iii. Customers who wish to proceed with any natural gas energy efficiency measure which has been evaluated by the Company subject to the terms and conditions of this tariff must sign an energy efficiency agreement with the Company by January 15, 2027. iv. Customers must complete any contracted projects by January 15, 2028, unless otherwise agreed to in certain contracts executed prior to December 31, 2026. B. Residential and Non-Residential Prescriptive Rebate or Bid Programs 1) Customers seeking a rebate for qualified residential and nonresidential equipment may submit rebate applications for equipment purchased on or before December 31, 2026. Customers must send to Avista all required rebate forms and other required documentation for qualifying projects postmarked by January 15, 2027 to be eligible for payment; any requests postmarked after January 15, 2027 will not be eligible for payment. 2) The business partner program will end on December 31. 2026. Customers will no longer be able to schedule appointments nor receive bids from contractors after that date. C. Midstream Rebate Program 1) Participating distributors may submit invoices to the program implementer for natural gas equipment purchased on or before December 31, 2026. Final payment to the midstream vendor for any Idaho gas equipment with a 2026 distributor invoice will be made on or before May 15, 2027. D. Limited Income Program 1) All existing 2026 Community Action Partnership contracts with natural gas incentives will be honored. The program will be suspended on December 31, 2026, and all invoices for work completed on or before December 31, 2026 shall be submitted to the Company by January 31, 2027. E. Market Transformation 1) The Company will continue to fund programs or services supporting or enhancing local, regional or national natural gas efficiency market transformation efforts, as described within this tariff. Issued June 12, 2026 Effective September 1, 2026 Issued by Avista Corporation By Patrick Ehrbar, Director of Regulatory Affairs �J) -U4 - Fifth Revision Sheet 190B Canceling I.P.U.C. No.27 Fourth Revision Sheet 190B AVISTA CORPORATION d/b/a Avista Utilities SCHEDULE 190 — continued NATURAL GAS EFFICIENCY PROGRAMS — IDAHO 2. ELIGIBLE CUSTOMER SEGMENTS All customers in all customer segments to whom this tariff is available are eligible for participation in natural gas efficiency programs developed in compliance with this tariff. 3. MEASURES Only natural gas efficiency measures with verifiable energy savings are eligible for assistance. Measure eligibility may not necessarily apply to all customer segments. Final determination of applicable measures will be made by the Company 4. FUNDING AND NONMONETARY ASSISTANCE 4.1 Funding The Company shall offer incentives for projects based upon the incremental capital cost associated with the energy efficiency of the project. Energy savings are calculated using the current energy rates. The Company shall pay an incentive up to a maximum of the incremental measure cost. The Company shall make adjustments to the percent of incremental cost paid to attempt to obtain the greatest energy savings at the lowest cost. Low income measures that have a Total Resource Cost (TRC) of 1.0 or higher are incentivized at 100% of the project cost. For measures that have a TRC of less than 1, the project is incentivized at an amount equal to the present value of avoided cost. Incentives for efficiency measures within the following categories shall not exceed 100% of the project cost: 4.1.1 Energy efficiency programs delivered by community action agencies contracted by the Company to serve Low Income or vulnerable customer segments including agency administrative fees and health and human safety measures; 4.1.2 Low-cost natural gas efficiency measures with demonstrable energy savings (e.g. rooftop unit service); 4.1.3 Programs or services supporting or enhancing local, regional or national natural gas efficiency market transformation efforts. 4.1.4 Prescriptive programs are guided by the typical application of that measure in accordance with the previously defined incentive structure. Incentive levels for these programs are based on market conditions at the time of the program design and are not dependent on actual project cost relative to incentive caps. Incentives shall not exceed project costs. Issued June 12, 2026 Effective September 1, 2026 Issued by Avista Corporation By Patrick Ehrbar, Director of Regulatory Affairs �J) -U4 - I.P.U.C. No.27 Original Sheet 190C AVISTA CORPORATION d/b/a Avista Utilities SCHEDULE 190 — continued NATURAL GAS EFFICIENCY PROGRAMS — IDAHO Avista Corporation will actively pursue natural gas efficiency opportunities that may not fit within the prescribed services and simple pay-back periods described in this tariff. In these circumstances the customer and Avista Corporation will enter into a site specific services agreement. 5. BUDGET & REPORTING The natural gas efficiency programs defined within this tariff will be funded by surcharges levied within Schedule 191. The Company will manage these programs to obtain resources that are cost-effective and achievable through utility intervention. Schedule 191 will be reviewed annually and revised as necessary to provide adequate funding for natural gas efficiency efforts. 6. GENERAL RULES AND PROVISIONS Service under this schedule is subject to the General Rules and Provisions contained in this tariff and is limited to facilities receiving natural gas service from the Company. All installations and equipment must comply with all local code and permit requirements applicable and be properly inspected, if required, by appropriate agencies. The Company may establish specifications regarding any natural gas efficiency measures and modifications to be effected under this schedule and may conduct inspections to insure that such specifications are met. Issued June 12, 2026 Effective September 1, 2026 Issued by Avista Corporation By Patrick Ehrbar, Director of Regulatory Affairs �J) -U4 - Fourth Revision Sheet 190 Canceling I.P.U.C. No.27 Third Revision Sheet 190 AVISTA CORPORATION dba Avista Utilities SCHEDULE 190 NATURAL GAS EFFICIENCY PROGRAMS IDAHO 1. AVAILABILITY The services described herein are available to qualifying residential, commercial, and industrial, retail natural gas distribution customers of Avista Corporation for the purpose of promoting the efficient use of natural gas. Customers receiving natural gas distribution service provided under special contract and/or customers receiving natural gas services not specified under Tariff Schedule 191 (Natural Gas Efficiency Rider Adjustment) are not eligible for services contained in this schedule unless specifically stated in such contract or other service agreement. The Company may provide partial funding for the installation of natural gas efficiency measures and may provide other services to customers for the purpose of identification and implementation of cost effective natural gas efficiency measures as described in this schedule. Facilities-based services are available to owners of facilities, and also may be provided to tenants who have obtained appropriate owner consent. Assistance provided under this schedule is limited to end uses where natural gas is or would be the energy source and to measures which increase the efficient use of natural gas. Assistance may take the form of monetary incentives or non-monetary incentives, as further defined within this tariff. The acquisition of resources is cost-effective as defined by a Utility Cost Test (UCT) as a portfolio. Customer participation under this schedule shall be based on eligibility requirements contained herein. Effective December 31, 2026, natural gas efficiency programs, incentives and rebates are available only for projects that meet the following conditions: A. Site Specific Programs 1) The Company will honor all terms and conditions of contracts and agreements that are fully executed prior to December 31, 2026. Such contracts and agreements must be signed by both the Company and the Customer. 2) Natural gas energy efficiency protects, proposed by the customer to Avista prior to December 31, 2026, but without fully executed contracts, will be honored by the Company under the following conditions: i. The Company has already conducted an analysis of a proposed natural gas energy efficiency measure. If the Company has not already conducted an analysis of a proposed natural gas energy efficiency measure, customers seeking incentive funding will submit on overview of their proposed natural gas energy efficiency project to the Company in writing or via email by December 31, 2026. Issued June 12, 2026 Effective September 1, 2026 Issued by Avista Corporation By Patrick Ehrbar, Director of Regulatory Affairs Seventh Revision Sheet 190A Canceling I.P.U.C. No.27 Sixth Revision Sheet 190A AVISTA CORPORATION dba Avista Utilities SCHEDULE 190 — continued NATURAL GAS EFFICIENCY PROGRAMS - IDAHO ii. All material documentation required for Avista to conduct an analysis to determine energy efficiency savings and potential incentive fundinq must be received by the Company by January 15, 2027. The Company has the sole discretion to determine if such documentation is sufficient for analysis, and if the documentation is not sufficient, will reiect the proiect from incentive funding consideration. iii. Customers who wish to proceed with any natural gas energv efficiency measure which has been evaluated by the Company subject to the terms and conditions of this tariff must sign an energy efficiency greement with the Company by January 15, 2027. iv. Customers must complete any contracted proiects by January 15, 2028, unless otherwise agreed to in certain contracts executed prior to December 31, 2026. B. Residential and Non-Residential Prescriptive Rebate or Bid Programs 1) Customers seeking a rebate for qualified residential and nonresidential equipment may submit rebate applications for equipment purchased on or before December 31, 2026. Customers must send to Avista all required rebate forms and other required documentation for qualifying proiects postmarked by January 15, 2027 to be eligible for payment; any requests postmarked after January 15, 2027 will not be eligible for payment. 2) The business partner program will end on December 31. 2026. Customers will no longer be able to schedule appointments nor receive bids from contractors after that date. C. Midstream Rebate Program 1) Participating distributors may submit invoices to the program implementer for natural gas equipment purchased on or before December 31, 2026. Final payment to the midstream vendor for any Idaho gas equipment with a 2026 distributor invoice will be made on or before May 15, 2027. D. Limited Income Program 1) All existing 2026 Community Action Partnership contracts with natural gas incentives will be honored. The program will be suspended on December 31, 2026, and all invoices for work completed on or before December 31, 2026 shall be submitted to the Company by January 31, 2027. E. Market Transformation 1) The Company will continue to fund programs or services supporting or enhancing local, regional or national natural gas efficiency market transformation efforts, as described within this tariff. Issued June 12, 2026 Effective September 1, 2026 Issued by Avista Corporation By Patrick Ehrbar, Director of Regulatory Affairs Third Revision Chen+ 49O .P.I I Za �esen,�--Rev cina,vn-Srhree T9A dh.; Avist.; I Ifili+ins SCHEDULE 190 —continued NATURAL GAS EFFICIENCY PROGRAMS — IDAHO 2. ELIGIBLE CUSTOMER SEGMENTS All customers in all customer segments to whom this tariff is available are eligible for participation in natural gas efficiency programs developed in compliance with this tariff. 3. MEASURES Only natural gas efficiency measures with verifiable energy savings are eligible for assistance. Measure eligibility may not necessarily apply to all customer segments. Final determination of applicable measures will be made by the Company: issued QGte;er26, 204 5 €ffestive january 4, 201 issuer! by A"ista Gor oratio B , Kell ,Ner w eed \/ine_President, State and Federal Re letin Sixth Revision Sheet -90 'kf�:'e.2a 1=-ffifth Revision 90 d/h/e Avmsta Utilities GHEDULi E non—€@"*' "^d nnl�iTUonI�, ECCI Enlry PROGR MS IDAHO 4. FUNDING AND NONMONETARY ASSISTANCE 4.1 Funding The Company shall offer incentives for projects based upon the incremental capital cost associated with the energy efficiency of the project. Energy savings are calculated using the current energy rates. The Company shall pay an incentive up to a maximum of the incremental measure cost. The Company shall make adjustments to the percent of incremental cost paid to attempt to obtain the greatest energy savings at the lowest cost. Low income measures that have a Total Resource Cost (TRC) of 1.0 or higher are incentivized at 100% of the project cost. For measures that have a TRC of less than 1, the project is incentivized at an amount equal to the present value of avoided cost. Incentives for efficiency measures within the following categories shall not exceed 100% of the project cost: 4.1.1 Energy efficiency programs delivered by community action agencies contracted by the Company to serve Low Income or vulnerable customer segments including agency administrative fees and health and human safety measures; 4.1.2 Low-cost natural gas efficiency measures with demonstrable energy savings (e.g. rooftop unit service); issued ju,=e 182019 EffeGtwve Augz;stTLy7TJ issued by Avmsta LAR'es- R DatrinL Ehrbar, Dmrentnr of Re u late nff�irc Fifth Revision Sheet 190B Canceling I.P.U.C. No.27 Fourth Revision Sheet 190B AVISTA CORPORATION d/b/a Avista Utilities u�ni i1 WW €� IAIAT' IRnl (`_nC ECCIEAI(`V o�n(_onnne in4�1-18n 4.1.3 Programs or services supporting or enhancing local, regional or national natural gas efficiency market transformation efforts. 4.i.4 Prescriptive programs are guided by the typical application of that measure in accordance with the previously defined incentive structure. Incentive levels for these programs are based on market conditions at the time of the program design and are not dependent on actual project cost relative to incentive caps. Incentives shall not exceed project costs. SCHEDULE 190 — continued NATURAL GAS EFFICIENCY PROGRAMS — IDAHO Avista Corporation will actively pursue natural gas efficiency opportunities that may not fit within the prescribed services and simple pay-back periods described in this tariff. In these circumstances the customer and Avista Corporation will enter into a site specific services agreement. 5. BUDGET & REPORTING The natural gas efficiency programs defined within this tariff will be funded by surcharges levied within Schedule 191. The Company will manage these programs to obtain resources that are cost-effective and achievable through utility intervention. Schedule 191 will be reviewed annually and revised as necessary to provide adequate funding for natural gas efficiency efforts. 6. GENERAL RULES AND PROVISIONS Service under this schedule is subject to the General Rules and Provisions contained in this tariff and is limited to facilities receiving natural gas service from the Company. All installations and equipment must comply with all local code and permit requirements applicable and be properly inspected, if required, by appropriate agencies. The Company may establish specifications regarding any natural gas efficiency measures and modifications to be effected under this schedule and may conduct inspections to insure that such specifications are met. issued IsQsabmbAir22,12Q2026 er 1, 2026 issued by y*st ^*i"0eEation By BY Kelly Nerweed VoGe D and F&Mr;a.LCTdr.L.MnFQirector of Regulatory Affairs