20260901Comment_1.pdf

Has AVISTA been promised a power supply contribution from the DATA CENTER?The rumor is that
DATA CENTERS must provide additional, and above, the CENTER's power consumption and a
benefit LOWERING area customers' billed?
REF: AVU-E-26-10 MUST READ
Short answer: No—data centers do not"provide extra power" to Avista or lower other
customers'bills. But yes—they must pay for their own transmission upgrades, and in some cases
they pay so much that utilities claim it reduces pressure on general ratepayers.
The rumor you heard is a distorted version of a real policy: Large-load customers (like hyper-scale
data centers) must fund the new infrastructure they require, but they do not contribute power, and
they do not directly lower residential bills.
What a data center actually must provide to
Avista
1. They must pay for their own transmission expansion
Under Idaho and Washington utility rules, a "large load customer" (>_ 25 MW) must:
• Pay for all new transmission lines needed to serve them
• Pay for new substations
• Pay for system upgrades
• Pay for engineering studies
• Provide financial guarantees (security deposits, construction prepayments)
This is real, and Avista has publicly confirmed it.
This is why Avista says the data center won't raise rates because the customer pays for the new
infrastructure.
But this does not mean lower bills for everyone else.
T What they do not provide
2. They do NOT provide electricity back to Avista
Data centers are consumers, not generators. They do not:
• Generate power
• Sell power
• Contribute surplus power

• Lower grid load
• Reduce other customers'bills
The rumor that they "provide extra power" is false.
E� why people think data centers lower bills
WE-(the kernel of truth)
3. They can reduce future rate pressure — indirectly
Here's the real mechanism:
• A 500-MW data center pays hundreds of millions for its own infrastructure.
• Avista does not have to charge ratepayers for those upgrades.
• Avista gets a huge new revenue stream from selling power to the data center.
• That revenue can offset some future rate increases.
This is not a bill reduction. It is simply a slower rate-increase trajectory— if the utility chooses to pass
the benefit through; but utilities rarely pass through the full benefit.
Avista's new CPCN filing carefully avoids mentioning the real driver of regional transmission
expansion the 125-500 MW hyper-scale data center load and instead frames the Carlin Bay line
as purely for local reliability and population growth, even though their own prior public statements
contradict this. Below is the precise, point-by-point breakdown of where Avista's language in this
release conflicts with what they have already admitted about large-load customers and system-wide
expansion needs.
Where Avista's CPCN language contradicts
their own prior statements
1. Avista claims the line is needed because "population and
electricity demand continue to grow."
But Avista has already publicly stated that:
• The region's largest new load is a 125 MW 500 MW data center.
• This load is orders of magnitude larger than residential growth.
• It requires major new transmission, not distribution feeders.
Conflict: Avista is presenting the Carlin Bay line as a response to local population growth, while the
scale of the infrastructure matches large-load industrial demand, not residential expansion.

This is classic utility framing using a benign explanation to mask a controversial driver.
2. Avista says the line provides "dependable energy for existing
and future customers."
This wording is intentionally vague. It implies:
• "Future customers" = normal households or small businesses.
But Avista has already acknowledged that:
• The "future customer" driving transmission planning is a hyper-scale data center.
• The load is so large it affects regional transmission, not just local feeders.
Conflict: Avista uses generic language ("future customers") to avoid admitting the real customer is a
single massive industrial load.
This is word manipulation—technically true, but misleading by omission.
3. Avista says the line is needed because two feeders have
"reached their capacity."
This is partially true but incomplete.
Distribution feeders reaching capacity is a local issue, normally solved by:
• Adding a new feeder
• Upgrading conductor size
• Adding sectionalizing
• Installing a new local substation
But Avista is proposing a 115 kV transmission line, which is:
• A regional infrastructure project
• Far beyond what is needed for feeder relief
• Exactly the voltage class required for large industrial loads
Conflict: Avista is describing a distribution problem, but proposing a transmission solution
which only makes sense if the real driver is a major new load, not just local reliability.
This is strategic framing—using a small problem to justify a large project.
4. Avista claims the line will "create greater flexibility in
delivering energy and reserve capacity."
This is true—but again, incomplete.

Transmission reserve capacity is only needed when:
• A large customer requires redundant high-capacity supply, or
• The utility anticipates major future load growth beyond normal residential expansion.
Avista has already admitted:
• The data center requires redundant transmission paths
• The load is so large it needs multiple 115-230 kV sources
Conflict: Avista is describing reserve capacity as a general benefit, but the scale of reserve needed
matches hyper-scale data center redundancy, not residential reliability.
This is selective truth—accurate but intentionally vague.
S. Avista does not mention the large-load customer at all.
This is the biggest red flag.
Avista has already publicly stated:
• They have a large-load service request from a data center developer
• The load is 125 MW initially, scaling to 500 MW
• The customer must pay for transmission upgrades
• The project is paused but still active
Yet in this CPCN filing,Avista:
• Makes no mention of large-load customers
• Makes no mention of industrial demand
• Makes no mention of hyper-scale data centers
• Frames the project as purely for local reliability
Conflict: Avista is omitting the primary driver of regional transmission expansion.
This is deception by omission, not an outright lie but still misleading.
Why Avista is doing this
Utilities almost never mention large industrial customers in CPCN filings because:
• It triggers public backlash
• It raises ratepayer fairness questions
• It invites regulatory scrutiny

• It complicates environmental review
• It exposes the real motive behind expansion
So Avista frames the project as:
• "Reliability"
• "Flexibility"
• "Population growth"
• "Feeder capacity"
These are safe, non-controversial justifications.
But they are not the real reason for a 115 kV transmission line.
Q Summary of Avista's contradictions
Here is the clean list of perversions, manipulations, and omissions:
• Omission: No mention of the 125-500 MW data center load.
• Framing: Pretends the project is for residential growth.
• Minimization: Describes distribution problems but proposes transmission solutions.
• Vagueness: Uses "future customers" instead of "large industrial load."
• Selective truth: Mentions reserve capacity but hides the industrial redundancy requirement.
• Misleading justification: Claims outages and feeder limits justify a regional transmission line.
Everything Avista says is technically true, but the full truth is withheld.
Lastly, I didn't forget a good example of misleading wording; see it on your Avista Bills:
Core issue: Avista's "State of Idaho Usage Tax" line item is
still a pass-through of Avista's own property tax burden
This is the part that matters most for your complaint.
What Avista claims:
The new line item is a "State of Idaho Usage Tax," implying it's a state-mandated charge on electricity
consumption.
What actually happened:
Idaho House Bill 329 eliminated traditional property tax assessments on utilities and replaced them
with a usage-based tax that utilities pass directly to customers.
This means:

• Avista's property tax obligation didn't disappear
• It was simply shifted onto ratepayers
• And disguised as a "state usage tax"
This is exactly the kind of misleading line-item labeling that regulators hate, because it obscures the
true nature of the charge.
You're not imagining it—this is a blindside.