20260807Reply Comments.pdf

' 11
Avista Corp. RECEIVED
1411 East Mission P.O. Box 3727 AUGUST 7, 2026
Spokane, Washington 99220-0500 IDAHO PUBLIC
Telephone [phone] UTILITIES COMMISSION
Toll Free 800-727-9170
August 7, 2026
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. AVU-E-26-08 and AVU-G-26-04 —Reply Comments of Avista Utilities
Dear Commission Secretary:
In accordance with the Notice of Application and Notice of Modified Procedure Order
issued by the Idaho Public Utilities Commission(IPUC or Commission) on July 14, 2026,1 and in
response to the written comments of Commission Staff(Staff), Avista Corporation, dba Avista
Utilities (Avista or the Company), respectfully submits the following Reply Comments.
Avista appreciates Staff s review of its Application for an Accounting Order Authorizing
a Carrying Charge on Balances Associated with the Company's Demand Side Management
Program(Application)and their recommendation that the Company's request should be approved,
although with a different effective date for incorporating a carrying charge than that proposed by
the Company. The Company continues to request the Commission allow the Company to
incorporate a carrying charge effective January 1, 2026, at the Commission-approved annual
Customer Deposit Rate, rather than the Final Order date as recommended by Staff.
As discussed in Staffs comments, the Commission has previously approved a carrying
charge on energy efficiency(EE)balances for both Idaho Power and Rocky Mountain Power. For
Idaho Power, it has been allowed to include a carrying charge on deferred balances since 1998,
per Order No. 27660 referenced by Staff. With Avista being the only electric utility not currently
allowed to incorporate a carrying charge on its EE balances, it is fair and equitable to allow the
1 Order No. 37098.

carrying charge to take effect on January 1,2026,such that all the utilities receive similar treatment
for the full calendar year. This decision would promote "regulatory consistency among Idaho's
investor-owned electric utilities" [emphasis added], as noted by Staff in their comments.
Regarding the amount of the carrying charge, Avista proposed the Commission-approved
Customer Deposit Rate as it has been approved for other deferral mechanisms. Per Staff s
comments,"Staff believes this approach is reasonable because it relies on an existing Commission-
approved rate, is administratively simple, provides a conservative measure of the financing costs
associated with deferred recovery..." [emphasis added]. With the proposed carrying charge
already being conservative as compared to the actual financing costs, it further supports the
Commission allowing the Company to incorporate the carrying charge effective January 1, 2026.
Staff s rationale for why the Company's requested effective date to incorporate a carrying
charge should not be retroactively established back to January 1, 2026,relies on Order No. 37047,
which approved of the Company's most recent electric Schedule 91 rate adjustment going into
effect on May 1, 2026. The Commission's order denied timely recovery of the Company's EE
expenses and further increased the deferred balances. However, the balances on January 1st were
already significant.The Company does not agree that the date of the most recent rate change should
be the determining factor for when it is allowed to incorporate a carrying charge. However, if the
Commission agrees with Staffs perspective, May 1st would serve as a reasonable middle ground
between the Company's original proposal and Staffs recommendation that the Company be
allowed to incorporate a carrying-charge effective as of the date of the Final Order in this case.
Ultimately, the Commission's decision on the date which the Company is allowed to
incorporate a carrying charge is material. The following table demonstrates the amount of the
carrying charge the Company would potentially record for its electric and natural gas operations
in 2026 based on the Customer Deposit Rate of 4%, actual EE deferral balances through June, and
forecasted amounts through year end.
2026 # of Months Carrying Charge
January—December 12 Months $1,048,000
May—December 8 Months $701,000
September—December 4 Months $346,000

Based on the data used to calculate the carrying charge in the table, the difference between the
Company's proposal and Staff s recommendation (assuming a September 1 st Final Order date) is
$702,000. Because the proposed interest rate used is already conservative, other Idaho utilities
have such treatment for 2026, and the Company has historically not had approval to incorporate a
carrying charge (like other Idaho utilities), it is reasonable for the Commission to approve the
Company's original proposal as it has not been recovering its actual financing costs for EE
expenditures. Alternatively, allowing an effective date of May 1st would minimize the difference
between the perspectives of the Company and Staff.
In conclusion, the Company requests that the Commission approve of its Application as
originally submitted, such that it is allowed to incorporate a carrying charge at the Commission-
approved Customer Deposit rate effective January 1, 2026. If you have any questions regarding
this filing, please contact me at(509)495-2782 or shawn.bonfieldgavistacorp.com.
Sincerely,
lsl $" Far &,W
Shawn Bonfield
Sr. Manager, Regulatory Policy & Strategy