20260825Staff Comments.pdf

RECEIVED
August 25, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
KELSEA E. ROSS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO STATE BAR NO. 12050
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S APPLICATION FOR AN ) CASE NO. AVU-G-26-01
ORDER AUTHORIZING TEMPORARY )
SUSPENSION OF ITS NATURAL GAS )
DEMAND SIDE MANAGEMENT ) COMMENTS OF THE
PROGRAMS -REVISIONS TO SCHEDULE ) COMMISSION STAFF
190 )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"),by and through its attorney of record,Kelsea E. Ross,Deputy Attorney General,
submits the following comments.
BACKGROUND
On June 12, 2026, Avista Corporation, doing business as Avista Utilities, ("Company")
applied to the Commission requesting an order permitting the Company's proposed revisions to
its Schedule 190, "Natural Gas Efficiency Programs," which would temporarily suspend the
Company's natural gas demand-side management("DSM")programs effective September 1,2026
("Application"). Application at 1.
On July 21, 2026, the Commission issued a Notice of Application and Notice of Modified
Procedure establishing written comment deadlines. Order No. 37105. Also on July 21, 2026, the
Company filed a revised Application ("Revised Application"), correcting and modifying the
expiration date of its Community Action Partnership ("CAP") contracts. Revised Application at
9. The Company represented it would submit a separate filing to the Commission, concurrent
with the Revised Application, for approval to modify to its DSM Rider Schedule 191 ("Rider"),
STAFF COMMENTS 1 AUGUST 25, 2026

which the Company represented is used to collect money for natural gas DSM programs, to
"$0.00/therm for every rate class, during the third quarter of 2026." Id. at 10. The Company
proposed a September 1, 2026, effective date in both its Application and Revised Application.
At the Commission's August 4, 2026, Decision Meeting,upon further consideration of the
procedural schedule, the Revised Application, and the Company's responses in discovery, Staff
recommended the Commission vacate and reset comment deadlines to provide additional time for
public input.
On August 41h, 2026, the Commission issued Order No. 37121. In Order No. 37121 the
Commission vacated the comment deadlines established Order No. 37105, suspended the proposed
effective date until October 1, 2026, or until the Commission enters an order accepting, rejecting,
or modifying the proposed revisions to the Company's Schedule 190, whichever comes first, and
established revised written comment deadlines. Order No. 37121 at 5.
STAFF ANALYSIS
Staff has reviewed the Company's Revised Application, workpapers, responses to
production requests, and forecasts regarding the Company's request to suspend its natural gas
DSM programs. Based on its investigation, Staff recommends that the Commission:
1. approve the Company's request to suspend its natural gas DSM programs;
2. approve the continuation of funding for the Company's Northwest Energy Efficiency
Alliance ("NEEA") and low-income contracts through the end of 2027 or until the
natural gas rider balance reaches $0, whichever occurs first; and
3. direct the Company to file to reinstate its natural gas DSM programs when they become
cost-effective in the future.
Staff Comments below address the Company's rationale for the proposed program
suspension, proposed program transition, program financials, and future program reintroduction.
The absence of discussion of other matters should not be construed as Staff s support for, or
endorsement of, the Company's position. Staff may evaluate additional issues in future filings.
Justification for Program Suspension
The Company explained in its Revised Application that the main driver for its decision to
suspend its natural gas DSM programs was the anticipated low cost-effectiveness resulting from
STAFF COMMENTS 2 AUGUST 25, 2026

reduced avoided costs. Revised Application at 1. DSM offerings are evaluated before, during,
and after implementation using a Utility Cost Test("UCT")to determine whether a program's load
reduction benefits outweigh the utility costs of administering the program. The UCT is a
benefit/cost ratio that divides the value of energy and capacity savings by total program
administration costs. A DSM program with a UCT of less than 1.0 indicates that the supply-side
costs avoided by the Company through the program are lower than the costs incurred to administer
it. The goal of DSM is to reduce costs passed to customers through rates by meeting demand with
lower cost demand-side resources. As both supply and demand-side resource costs are ultimately
passed to customers through rates, administering a DSM program that is not cost-effective carries
the risk of passing the costs of resources that are not least-cost onto customers. To estimate the
monetary value of program savings, a utility biennially produces a forecast of avoided costs, or
the estimated costs of serving the next incremental unit of demand with a supply-side resource that
the utility avoids by lowering demand on the system.
The Company first observed a decline in the avoided costs of natural gas in its 2023 Natural
Gas Integrated Resource Plan ("IRP") and saw lower-than-expected cost-effectiveness starting in
2024. Id. at 2-3. In Staff s Comments on the Company's 2022-2023 natural gas DSM prudence
filing, Staff stated that it expected the Company to file to suspend its natural gas programs if they
could not be planned as cost-effective. Staff Comments (Case No. AVU-E-24-09) at 7. The
Company's 2025 IRP showed a further reduction in avoided costs. Revised Application at 4. After
comparing the avoided costs used for the 2025 planning period with those used for the 2026
planning period, the Company found that the 2026 planning period simple average avoided cost
was about 14 percent lower. Response to Staff Production Request No. 8.
In Staff s Comments on the Company's 2024 prudence filing, Staff recommended that the
Company adjust its evaluation method for the furnace measure to more accurately reflect historical
evaluations and baseline sources. Staff Comments (Case No. AVU-G-25-09) at 10. Furnace
measure savings have historically had a significant impact on portfolio performance, accounting
for over 63 percent of the total natural gas therm savings in 2024. Response to Staff Production
Request No. 8 Attachment A (Case No. AVU-G-24-09). After recalculating furnace measure
savings forecasts using a regression model that aligned with Staff s recommendation,the Company
determined that it could no longer plan a cost-effective portfolio with a UCT of 1.0 or greater.
Revised Application at 6.
STAFF COMMENTS 3 AUGUST 25, 2026

Staff compared the 2025 IRP winter Preferred Resource Scenario ("PRS") avoided costs
with the 2023 IRP winter PRS avoided costs. Staff s calculations are shown in Table Nos. 1-3
below.
Table No. 1: 2025 vs. 2023 Winter PRS Residential Avoided Costs
Year 2025 IRP 2023 IRP Difference % Difference
2025 $3.38 $4.58 -$1.20 -26%
2026 $3.94 $4.25 -$0.31 -7%
2027 $4.08 $4.44 -$0.36 -8%
2028 $4.16 $4.18 -$0.02 0%
2029 $4.03 $4.65 -$0.62 -13%
2030 $4.00 $4.96 -$0.96 -19%
2031 $4.15 $5.34 -$1.19 -22%
2032 $4.45 $5.73 -$1.28 -22%
2033 $4.64 $5.91 -$1.27 -21%
2034 $4.79 $6.14 -$1.35 -22%
2035 $4.89 $6.53 -$1.64 -25%
2036 $5.08 $6.72 -$1.64 -24%
2037 $5.23 $7.12 -$1.89 -27%
2038 $5.43 $7.34 -$1.91 -26%
2039 $5.65 $7.65 -$2.00 -26%
2040 $5.91 $8.12 -$2.21 -27%
2041 $6.10 $8.31 -$2.21 -27%
2042 $6.24 $8.57 -$2.33 -27%
2043 $6.44 $8.87 -$2.43 -27%
2044 $6.68 $9.09 -$2.41 -27%
2045 $6.84 $9.32 -$2.48 -27%
2025 IRP, Appendix 2.1; 2023 IRP, Appendix 6.4.
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STAFF COMMENTS 4 AUGUST 25, 2026

Table No. 2: 2025 vs. 2023 Winter PRS Commercial Avoided Costs
Year 2025 IRP 2023 IRP Difference % Difference
2025 $3.37 $4.54 -$1.17 -26%
2026 $3.91 $4.21 40.30 -7%
2027 $4.03 $4.40 -$0.37 -8%
2028 $4.11 $4.14 40.03 -1%
2029 $3.99 $4.62 40.63 -14%
2030 $3.95 $4.94 40.99 -20%
2031 $4.09 $5.32 -$1.23 -23%
2032 $4.39 $5.70 41.31 -23%
2033 $4.58 $5.88 41.30 -22%
2034 $4.73 $6.14 -$1.41 -23%
2035 $4.84 $6.53 41.69 -26%
2036 $5.04 $6.72 41.68 -25%
2037 $5.20 $7.12 -$1.92 -27%
2038 $5.40 $7.34 41.94 -26%
2039 $5.62 $7.65 -$2.03 -27%
2040 $5.88 $8.12 -$2.24 -28%
2041 $6.06 $8.31 42.25 -27%
2042 $6.20 $8.57 42.37 -28%
2043 $6.41 $8.87 -$2.46 -28%
2044 $6.63 $9.09 42.46 -27%
2045 $6.79 $9.32 42.53 -27%
Id.
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STAFF COMMENTS 5 AUGUST 25, 2026

Table No. 3: 2025 vs. 2023 Winter PRS Industrial Avoided Costs
Year 2025 IRP 2023 IRP Difference % Difference
2025 $3.35 $4.41 -$1.06 -24%
2026 $3.88 $4.09 -$0.21 -5%
2027 $4.00 $4.25 -$0.25 -6%
2028 $4.08 $4.03 $0.05 1%
2029 $4.01 $4.53 -$0.52 -11%
2030 $3.99 $4.85 -$0.86 -18%
2031 $4.13 $5.23 -$1.10 -21%
2032 $4.42 $5.60 -$1.18 -21%
2033 $4.60 $5.79 -$1.19 -21%
2034 $4.75 $6.05 -$1.30 -21%
2035 $4.86 $6.44 -$1.58 -25%
2036 $5.05 $6.65 -$1.60 -24%
2037 $5.21 $7.03 -$1.82 -26%
2038 $5.42 $7.25 -$1.83 -25%
2039 $5.64 $7.58 -$1.94 -26%
2040 $5.90 $8.05 -$2.15 -27%
2041 $6.08 $8.25 -$2.17 -26%
2042 $6.22 $8.53 -$2.31 -27%
2043 $6.43 $8.85 -$2.42 -27%
2044 $6.65 $9.08 -$2.43 -27%
2045 $6.81 $9.32 -$2.51 -27%
Id.
After inputting updated avoided costs and adjusting the evaluation methodology for the
furnace measure, the Company represented that the best-case scenario it was able to generate
resulted in a UCT of 0.91 in 2026 and 0.94 in 2027. Response to Staff Production Request No. 1.
After reviewing the Company's avoided costs and cost-effectiveness forecasts, Staff believes that
the decrease in avoided costs prevents the natural gas portfolio from being cost-effective under the
UCT. Staff discussed in a meeting with the Company the potential to reduce the number of
measures and offer a more restricted portfolio, such as a portfolio only consisting of the furnace
STAFF COMMENTS 6 AUGUST 25, 2026

measure. However, the Company explained to Staff that this would further reduce portfolio cost-
effectiveness as it would result in the fixed administration costs being spread over a much smaller
portfolio. The Company also stated in its Revised Application that to plan a cost-effective
portfolio,it would have to assume anomalous participant behavior or maintain current participation
rates while offering "virtually zero incentive." Revised Application at 6.
Staff considered whether the Company could maintain its programs if the reduction in
avoided costs was expected to be short-term. In its Response to Staff Production Request No. 2,
the Company stated using the current avoided costs forecast,the programs are not forecasted to be
cost-effective until 2036. Due to the portfolio's lack of cost-effectiveness that is currently
projected to last up to ten years, Staff supports the Company's request to suspend its natural gas
DSM programs.
Proposed Program Transition
In its Revised Application, the Company described a transition period to manage its
existing contractual obligations and ramp down its programs while reducing the impact on the
market. Revised Application at 6-7. Staff reviewed the Company's proposed transition plans
regarding each of its natural gas DSM programs. Staff believes that the Company's proposed
schedule for ramping down its programs gives stakeholders sufficient time to plan accordingly
while balancing the need to prudently spend the remaining rider balance. All programs, excluding
NEEA and low-income programs,will be suspended effective December 31,2026,with exceptions
specified in the Company's revised Schedule 190 tariff. Revised Application at 7-9.
The Company will implement a coordinated communications strategy to notify
participating trade allies, customers,and other affected stakeholders of its program suspension. Id.
at 8. This will provide information regarding program suspension timelines, project completion
and application deadlines, and limitations on incentive eligibility following the suspension date.
Id. at 8. Customers will be notified of the program suspensions via the Company's website
beginning 120 days prior to the suspension date.Id.
For site-specific and Pay-for-Performance programs,Account Executives will serve as the
primary customer contacts. Id. They will proactively communicate with customers who are
considering or developing new natural gas DSM projects to inform them of the program sunset
and applicable deadlines. Id. For residential and nonresidential prescriptive programs, the
STAFF COMMENTS 7 AUGUST 25, 2026

Company will provide program suspension information on rebate forms beginning in September,
will implement direct email notification to participating trade allies and contractors, and provide a
summary notification letter issued no later than 90 days before the anticipated December 31,2026,
suspension date. Id. at 9. Contractors and distributors participating in the midstream program will
be notified in September 2026 through in-person visits, email, and the Company's website. Id.
For low-income weatherization offerings, the Company will work with the CAP agency to
determine the best method for notifying qualifying customers of the suspension of those offerings
at the end of the 2027 contract period. Id.
NEEA Funding
As part of its transition plan, the Company has proposed to continue participation in
NEEA's market transformation efforts until its existing overfunded rider balance is exhausted.
Response to Staff Production Request No. 7. The Company's participation in NEEA's market
transformation efforts allows it to work with other regional utilities to accelerate the adoption of
energy-efficiency measures throughout its service territory. 2024 Annual Conservation Report at
51. According to the Company, pausing its NEEA program incentives could produce significant
negative effects on NEEA's market transformation activities that may last for several years.
Revised Application at 8. The Company stated,
In instances where utility incentive programs like Avista's are expected to support
these market strategies, disruption or discontinuation of these programs can
materially affect planning assumptions, increase market uncertainty, or alter
product mix decisions.
Id.
Further, NEEA stated that if Avista withdraws its Cycle 7 funding, the benefits of Idaho
specific testing for demonstration projects or pilot market transformation efforts, including the
development and introduction of additional technologies expected to come to the market shortly
such as dual-fuel residential water heaters, will not be available. Response to Staff Production
Request No. 11 Attachment A at 3. Additionally, any savings associated with initiatives moved
into market development in Cycle 7 or advanced after the Company's funding withdrawal would
be ineligible for reporting within the Company's Idaho service territory. Id. at 2.
In April 2023, the Company, in cooperation with Idaho Power Company, conducted a
detailed impact evaluation("Evaluation")of NEEA market transformation initiatives to verify the
STAFF COMMENTS 8 AUGUST 25, 2026

accuracy of NEEA's claimed savings. Application (AVU-G-24-03) at 8. The Evaluation
concluded that the Company's NEEA natural gas portfolio was cost-effective with an overall UCT
of 6.24 between 2019 and 2021. Evaluation at 14. The program is expected to remain cost-
effective throughout its 2025-2029 funding cycle, even as a standalone program,with a forecasted
UCT of 2.70 in 2027 and 2.84 in 2028. Response to Staff Production Request No. 9. To forecast
cost-effectiveness, the Company stated that it used a conservative measure life estimate of five
years, and the lowest annual winter avoided cost forecast between 2025 and 2029. Id. Staff
reviewed NEEA's forecasted savings and the Company's cost-effectiveness forecasts. Staff
believes that the forecasts are reasonable and that the NEEA natural gas portfolio is likely to remain
cost-effective throughout the current funding cycle.
The Evaluation also made several recommendations for program improvements.
Evaluation at 18. In Staff s Comments in Case No. AVU-G-24-03, Staff raised concerns that
NEEA's regional focus could deviate from benefiting Idaho specifically and that the third-party
influence evaluations conducted for federal standards changes may lack independence. Staff
Comments (Case No. AVU-G-24-03) at 10. To address these concerns, NEEA is working to
implement new methods of measuring and testing whether market transformation work is reaching
all Northwest consumers, including rural and urban communities and climate regions. Response
to Staff Production Request No. 11 Attachment A at 3. NEEA is also addressing the Evaluation
recommendations by updating its next market progress evaluation reporting process to align with
recommendations provided by two independent third-party evaluations regarding its influence on
code outcomes. Id. at 4. These updates were reviewed with stakeholders through the Cost
Effectiveness and Evaluation Advisory Committee and include changes to baseline assumptions
and documentation of state-specific code influence strategies. Id. Staff believes that these changes
demonstrate a reasonable effort by NEEA to address Staffs concerns and will review further
changes when the Company files to reinstate its natural gas portfolio.
Staff believes that the historical and forecasted cost-effectiveness of the Company's NEEA
natural gas portfolio demonstrates continued benefit to Idaho customers and therefore supports the
Company's request to continue funding the program. However, as detailed in the sections below,
the Company's forecasted rider balance, including the continuation of NEEA funding, is expected
to become underfunded by February 2028. Due to the uncertainty regarding whether the Company
will be able to reinstate its programs and the risk of maintaining an underfunded rider balance
STAFF COMMENTS 9 AUGUST 25, 2026

throughout the program suspension, Staff recommends that the Commission approve the
Company's continuation of NEEA funding through the end of 2027 or until the natural gas rider
balance reaches $0, whichever occurs first.
Low Income Weatherization
Staff is concerned about the potential impact of the natural gas DSM program suspension
on the Company's low-income customers. The Company emphasized in its Application that its
low-income program provides benefits to its low-income customers by stabilizing energy bills and
enhancing housing security. Application at 8. According to the Company, 48 percent of homes
weatherized under its low-income program in 2025 were funded through the natural gas portfolio.
Id. Staff interprets this to indicate that discontinuation of natural gas low-income funding could
reduce the number of homes that benefit from these services by almost half. When it filed its
Application,the Company planned to discontinue its low-income program effective December 31,
2026. Id. However, after further consideration, the Company requested authorization to use its
existing overfunded rider balance to honor the remainder of its low-income CAP contract, which
expires December 31, 2027. Revised Application at 8.
Unlike the Company's NEEA natural gas portfolio, the low-income program is not
projected to be cost-effective in 2027 or 2028, with a forecasted UCT of 0.08 in both years.
Response to Staff Production Request No. 1 Attachments A and B. However, after combining the
costs and benefits of the low-income and NEEA programs, Staff determined that the programs are
forecasted to remain cost-effective overall in 2027. Table No. 4 below shows the breakdown of
forecasted 2027 costs and benefits for the two programs.
Table No. 4: 2027 Program Cost-Effectiveness
Program Expenses Therm Savings Total Avoided Costs UCT
Low-Income $400,000 1,330 $11,987 0.08
NEEA $270,000 393,336 $730,215 2.70
Total $670,000 394,666 $742,202 1.11
Response to Production Request No. 1 Attachment A; Response to Staff Production Request No.
10 Attachment A.
Staff also believes that the cost implications to customers of honoring the remainder of the
Company's contract would be minimal. According to the Company's rider balance forecasts, the
STAFF COMMENTS 10 AUGUST 25, 2026

total 2027 cost of continuing the low-income program would be $400,000. Response to Staff
Production Request No. 6 Attachment A. Using the Company's actual customer usage between
July 2025 and June 2026 as reported in its most recently filed Fixed Cost Adjustment ("FCA"),
Staff calculated that the cost per kWh for funding this amount by distributing it evenly among all
customers. Recovering it would cost customers using an average of 66 therms approximately 2.5
cents per month or about 30 cents per year. FCA Workpapers (Case No. AVU-E-26-02).
The Company stated in discussions with Staff that honoring the remainder of its low-
income contract would allow the CAP agency to shift from a dual-fuel to a single-fuel program to
scale it down appropriately, finish current projects, address customer emergencies, and manage
staffing changes that may affect the electric program. Staff recognizes the difficulties that ending
the low-income contract early could pose to both the CAP agency and the customers who rely on
these services. The overall continuation of NEEA and low-income funding as a whole is forecasted
to be cost-effective and Staff believes the rate impacts on customers of honoring the remainder of
the contract would be minimal. Thus Staff supports the Company's request to suspend funding
the program through the end of the 2027 or until the overfunded rider balance is exhausted,
whichever occurs first.
Rider Balance
Staff reviewed the Company's Revised Application, responses to Staff Production
Requests, and supporting workpapers to evaluate the Company's rider balance and forecasts. As
of June 30, 2026, the Company's rider balance was overfunded by $2,289,385, according to its
Response to Staff Production Request No. 6 Attachment A.Based on its review, Staff believes that
the Company's rider balance forecasts are reasonable.
In conjunction with its request to temporarily suspend its natural gas DSM programs, the
Company requested that the Schedule 191 rate be decreased to$0.00 per therm effective November
1, 2026, in Case No. AVU-G-26-05. Until the Schedule 191 rate is reduced, the Company will
continue to collect rider revenue and incur expenses associated with its existing terms, conditions,
and contracts. Revised Application at 7-10. The Company forecasts Schedule 191 to collect
approximately $201,641 in revenue through October 31, 2026. Response to Staff Production
Request No. 6 Attachment A. The Company also forecasts approximately $1,011,273 in
STAFF COMMENTS 11 AUGUST 25, 2026

expenditures through October 31, 2026, resulting in an estimated Schedule 191 balance of
approximately $1,479,753 as of November 1, 2026. Id.
The Company proposed to honor its existing DSM program commitments and contracts
for the residential, non-residential, and midstream programs end December 31, 2026. Revised
Application at 7-10. However, the Company may continue to incur site-specific program costs
through 2027, and potentially into 2028, for projects accepted under the program through
December 31, 2026. Schedule 190 Tariff. The low-income program has contracts with CAP
agencies through December 31, 2027. Revised Application at 8. The Company's contract with
NEEA includes a funding cycle extending through 2029.
The Company provided three scenarios showing the impact of its remaining DSM program
costs on the Schedule 191 rider balance. Response to Staff Production Request No. 6 Attachment
A. If the Company continues funding NEEA through 2029 and the low-income program through
December 2027, the Company forecasts that Schedule 191 will be underfunded by approximately
$495,871 by December 2029. Id. If the Company continues funding NEEA through 2029 but
does not continue funding the low-income program after December 2026, the Company forecasts
that Schedule 191 will be underfunded by approximately $95,871 by December 2029. Id. This
scenario also includes costs for the midstream and residential programs through December 2026
and the site-specific programs through 2027. Id. Alternatively, if the Company continues funding
the low-income program and site-specific programs through 2027 but discontinues funding NEEA
after December 2026, the Company forecasts that Schedule 191 will remain overfunded by
approximately $314,158 as of December 31, 2027. Id.
The following table summarizes the Company's forecast of the rider balance if funding for
NEEA and the low-income program continues, as discussed above.
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STAFF COMMENTS 12 AUGUST 25, 2026

Table No. 5: Company Rider Balance Estimates
Natural Gas DSM Rider Balance as of 6/30/26 - Overfunded $ 2,289,385
Estimated Total Natural Gas DSM Rider Revenue July-October $ 201,641
Estimated NEEA Expenditures for July 2026—December 2029 $ ( 945,034)
Estimated Low-Income Expenditures through December 2027 $ (459,132)
Estimated expenses to close out all other programs through December $ (1,582,732)
2027
Estimated Remaining Rider Balance—(Underfunded) $ (495,872)'
1 Comments state $495,871 which is due to rounding.
In its response to Staff Production Request No. 7, the Company clarified that its intention
is to cease funding of its NEEA and low-income programs once the rider balance reaches $0.
According to the Company's forecasts, if the Company continues funding its NEEA and low-
income programs through December 2027,the rider balance will become underfunded by February
1, 2028. Response to Staff Production Request No. 6 Attachment A.
Program Reintroduction
Staff expects that, as forecasted avoided costs trend upward over time, the potential cost-
effectiveness of the Company's DSM programs could improve. The current avoided cost forecast
suggests that the programs may become cost-effective in 2036. Response to Staff Production
Request No. 2. However, the Company is expected to produce an updated avoided cost forecast
as part of its 2027 IRP, which may provide a different timeline. Response to Staff Production
Request No. 1. According to the Company, it will begin its initial review of potential program
reintroduction using these preliminary avoided costs, with updates expected during the 2027 and
2028 planning cycle. Response to Staff Production Request No. 3. Should cost-effective
opportunities materialize as a result of updated gas costs, technologies, or delivery methods, the
Company will begin planning to reinstate its natural gas portfolio for the next available program
year. Id. At such time, Staff recommends that the Company file an application with the
Commission to reinstate its natural gas DSM programs, along with any adjustments necessary to
achieve cost-effective natural gas savings.
STAFF COMMENTS 13 AUGUST 25, 2026

STAFF RECOMMENDATION
Based on its review, Staff recommends that the Commission:
1. approve the Company's request to suspend its natural gas DSM programs;
2. approve the continuation of funding for the Company's NEEA and low-income
contracts through the end of 2027 or until the natural gas rider balance reaches $0,
whichever occurs first; and
3. direct the Company to file to reinstate its natural gas DSM programs when they become
cost-effective in the future.
Respectfully submitted this 25th day of August 2026.
Kelsea E. Ross
Deputy Attorney General
Technical Staff: Rebecca Cottrell, Laura Conilogue
I:\Utility\UMISC\COMMENTS\AVU-G-26-01 Comments.docx
STAFF COMMENTS 14 AUGUST 25, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 251h DAY OF AUGUST 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF , IN CASE
NO. AVU-G-26-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
ANNI GLOGOVAC SHAWN J. BONFIELD
COUNSEL FOR REGULATORY SR. MGR., REGULATORY POLICY& STRATEGY
AFFAIRS AVISTA CORPORATION
AVISTA CORPORATION PO BOX 3727
PO BOX 3727 SPOKANE WA 99220-3727
SPOKANE WA 99220-3727 E-mail: shawn.bonfieldkavistacorp.com
E-mail: anni.glo og vac(cavistacorp.com
avistadocketskavistacorp.com
4
PATRICIA JORDA1q, SECRETARY
CERTIFICATE OF SERVICE