20260908Staff Comments.pdf

RECEIVED
September 08, 2026
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11560
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S RESIDENTIAL AND ) CASE NO. AVU-E-26-07
SMALL FARM ANNUAL RATE )
ADJUSTMENT FILING )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On July 31, 2026,Avista Corporation("Company") applied to the Commission requesting
authorization to implement a proposed increase to the Schedule 59, Residential and Small Farm
Energy Rate Adjustment ("Schedule 59") credit rate for electric service for qualifying customers
on Schedules 1, 12, 22, 32, and 48, from October 1, 2026, through September 30, 2027
("Application").
The Company represents that the Residential and Small Farm Energy Rate Adjustment
results from an agreement between the Company and Bonneville Power Administration (`BPA")
that provides a share of the benefits of the federal Columbia River power system to the residential
and small farm customers of the six investor-owned utilities of the Pacific Northwest.
The Company proposes to increase the Residential and Small Farm Energy Rate
Adjustment credit rate for qualifying customers on rate Schedules 1, 12,22,32,and 48 from 0.2330
STAFF COMMENTS 1 SEPTEMBER 8, 2026

per kilowatt-hour("kWh")to 0.2520 per kWh, effective October 1, 2026. The proposed increase
in the credit rate would result in an approximately $0.3 million, or 0.1%, decrease in revenue
collected from qualifying customers. Application at 2-3.
Currently, approximately $3.3 million in benefits are being passed through to Idaho
customers. Id. at 3. The proposed Schedule 59 credit of 0.2520 per kWh would provide Idaho
customers with approximately $3.6 million in benefits. Id.
The Company anticipates that a residential customer using an average of 939 kWh per
month would see a monthly bill decrease of$0.19, or 0.15%. Id.
STAFF ANALYSIS
Staff reviewed the methodology and calculation of the proposed Residential and Small
Farm Energy Rate credit rate and confirmed that the approach is consistent with the terms and
conditions of Schedule 59. Staff reviewed the inputs and independently recalculated the rate.
Based on its review, Staff recommends that the Commission approve the proposed rate of 0.2520
per kWh effective October 1, 2026. Application at 1.
The Residential and Small Farm Energy Rate Adjustment credit reflects benefits the
Company receives from the BPA through the Residential Exchange Program. The program
provides residential and small farm customers of participating Pacific Northwest utilities,
including the Company, with benefits from the federal Columbia River power system through a
rate credit. Idaho's share of the BPA benefit is included in the credit and adjusted for any
remaining over-or under-refunded balance from the prior period.
The current Residential and Small Farm Energy Adjustment Rate credit is 0.2330 per kWh,
providing customers with approximately $3.3 million in BPA benefits. Id at 2. The proposed
credit of 0.2520 per kWh would provide approximately$3.6 million in benefits to qualifying Idaho
customers, including an adjustment for the remaining balance from the prior year. Id. at 3. The
overall increase in the credit rate would result in an overall decrease in revenue of approximately
$0.3 million, or 0.1 percent, from qualifying customers. Id. at 3.
The BPA benefit calculation is based on two primary inputs: (1) the average qualifying
residential and small farm customer usage for 2023 and 2024, and (2) the difference between the
Company Average System Cost ("ASC") rate and BPA's Priority Firm Exchange Rate ("PF
Exchange Rate"), which BPA updates every two years. For the October 2026 through September
STAFF COMMENTS 2 SEPTEMBER 8, 2026

2027 benefit period, the Company's ASC rate is $67.29 per megawatt-hour("MWh"), and the PF
Exchange Rate is $65.09 per MWh, resulting in a $2.20 per MWh benefit. Applying this rate
difference to the projected qualifying load of 4.210 billion kWh results in a total projected BPA
benefit of approximately $9.26 million. The benefit is allocated between Idaho and Washington
based on each state's share of the average 2023 and 2024 qualifying usage, with 33.75%, or
approximately $3.13 million, allocated to Idaho. BPA ResEx Workpapers, "Projected Benefits"
tab.
The Company calculates the proposed BPA credit rate by combining Idaho's approximate
$3.13 million BPA benefit with the projected $414,729 under-refunded balance, resulting in a
$3.54 million net benefit. After applying the revenue conversion factor, the amount increases to
approximately $3.56 million. This amount is divided by projected sales of 1.413 billion kWh for
October 2026 through September 2027, resulting in a proposed credit rate of 0.2520 per kWh.
CUSTOMER NOTICE AND PRESS RELEASE
The Company's press release and customer notice were included with its Application.
Staff reviewed the documents and determined both met the requirements of Rule 125 of the
Commission's Rules of Procedure', IDAPA 31. 01. 01. 125. The notice was included with billing
statements mailed to customers from August 4 through September 1,2026. For customers enrolled
in paperless billing, the notice was e-mailed during the same period and included a link to the
digital version of the notice.
The Commission set a public comment deadline of September 8, 2026. As of September
8, 2026, no customer comments have been submitted to the Commission. Customers in the later
part of the billing cycle may not have received their notices or had adequate time to submit
comments before the comment deadline. Staff believes customers should have the opportunity to
file comments and have those comments considered by the Commission. Staff recommends that
the Commission consider late-filed customer comments.
1 The press release and customer notice addressed the following cases. Electric: AVU-E-26-05 Power Cost
Adjustment (PCA), AVU-E-26-06 Fixed Cost Adjustment (FCA), and AVU-E-26-07 Bonneville Power
Administration Residential Exchange (ResEx). Natural Gas: AVU-G-26-02 Fixed Cost Adjustment(FCA),AVU-
G-26-05 Energy Efficiency,and AVU-G-26-03 Purchased Gas Cost(PGA).
STAFF COMMENTS 3 SEPTEMBER 8, 2026

STAFF RECOMMENDATION
Staff recommends that the Commission:
1. approve the Company's Application and proposed Residential and Farm Energy Rate
Adjustment credit of 0.2520 per kWh under Schedule 59, effective October 1, 2026, as
filed; and
2. accept and consider any late-filed comments from customers.
Respectfully submitted this 8th day of September 2026.
Erika K. Melanson
Deputy Attorney General
Technical Staff: Ty Johnson
I:\Utility\UMISC\COMMENTS\AVU-E-26-07 Comments.docx
STAFF COMMENTS 4 SEPTEMBER 8, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 81h DAY OF SEPTEMBER 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF , IN CASE
NO. AVU-E-26-07, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
ANNI GLOGOVAC, COUNSEL FOR REGULATORY AFFAIRS
PATRICK EHRBAR, DIRECTOR OF REGULATORY AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 E. MISSION AVENUE, MSC 27
SPOKANE WA 99220
E-mail: anni.glo og vac(cavistacorp.com
Patrick.ehrbar&avi stacorp.com
avi stadockets(cry avistacorp.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE