20180511Comments.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
RECEIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES F'OR ELECTRIC
AND NATURAL GAS SERVICE IN IDAHO COMMENTS OF THE
COMMISSION STAFF TO AN
ADDENDUM TO STIPULATION
The Staff of the Idaho Public Utilities Commission submits the following comments in
the above captioned matter.
BACKGROUND
On April 10, 2018, Avista filed a Motion to approve an addendum to the approved
stipulation in the above-captioned matter.
On December 18, 2015, the Idaho Public Utilities Commission approved a Settlement
Stipulation in Avista's 2015 generalrate case. Therein, the Commission approved an electric
and natural gas Fixed Cost Adjustment ("FCA") Mechanism that went into effect on January l,
2016. The FCA is a rate adjustment mechanism designed to break the link between the amount
of energy a utility sells and the revenue it collects to recover the fixed costs of providing service
to customers.
The Commission approved "an initial FCA term of 3 years, with a review of how the
mechanisms have functioned conducted by Avista, Staff, and other interested parties following
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CASE NO. AVU.E.15-05
AVU-G-15-01
ISTAFF COMMENTS MAY I l, 201 8
the end of the second full-year." Order No. 33437 at 5. The approved Stipulation contained a
provision that the Company "may seek to extend the term of the mechanism prior to its
expiration." Stipulation at 10. With the agreement of all the partiesr participating in the
underlying rate case, the Company now seeks to extend the FCA mechanism one year.
The Company stated that it is requesting the extension to better sync the Idaho
Commission's review of the mechanism with a review being conducted by an independent third-
party of the Company's decoupling mechanism in Washington State. The parties have agreed
that Idaho Parties and this Commission will benefit from the results of the third-party study, and
likewise agree to extend the terms of the approved settlement by one year.
The Addendum to the Stipulation proposes the following:
The approved Stipulation as described in paragraph 13, sub-section a, is as follows:
FCA Mechanisms Term. The Parties agree to an initial FCA term of 3
years, with a review of how the mechanisms have functioned conducted
by Avista, Staff, and other interested parties following the end of the
second full-year. Avista may seek to extend the term of the mechanism
prior to its expiration.
The Parties agree to amend the Stipulation language as follows:
FCA Mechanisms Term. The Parties agree to an initial FCA term of 4
years, with a review of how the mechanisms have functioned conducted
by Avista, Staff, and other interested parties following the end of the
third full-year. Avista may seek to extend the term of the mechanism
prior to its expiration.
Proposed Addendum to the Stipulation at 2 (emphasis supplied).
The Commission will review the proposed settlement consistent with Commission Rules
27t-280.
The Commission is not bound by the agreement of the signing parties. The Commission
will independently review the proposed settlement to decide whether to approve it, reject it, or
state conditions under which to accept it. The proposed settlement's proponents ultimately bear
t Although Clearwater Paper was a party to the underlying rate case, Clearwater Paper does not participate in the FCA
mechanism, and takes no position here.
STAFF COMMENTS MAY 11, 20182
the burden to prove that it is just, fair, and reasonable, in the public interest, or otherwise in
accordance with law or regulatory policy.
STAFF RECOMMENDATIONS
Staff recommends that the Commission approve the addendum to the stipulation
approved in Case Nos. AVU-E-15-05 and AVU-G-15-01. Extending the FCA pilot program by
one year will provide Staff and interested parties additional information and recommendations
from the third-party evaluation of Avista's FCA mechanism in Washington along with an
additional year of data. Staff will work with Avista and interested parties in2019, following the
third full year of the pilot, to determine if the mechanism is functioning as anticipated and to
recommend any changes to the mechanism, up to and including termination.
Respectfully submitted this tty day of May 2018.
Deputy Attorney General
Technical Staff: Donn English
i:umisc/comments/avuel 5.5_avugl 5. I bkde addendum to stip comments
JSTAFF COMMENTS MAY 11, 2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l ITH DAY OF MAY 2018,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TO AN
ADDENDUM TO STIPULATION, IN CASE NOS. AVU-E-I5-05/AVU-G.15.01, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
PATRICK EHRBAR
AVISTA CORPORATION
PO BOX3727
SPOKANE W A 99220-3727
E-mail : [e-mail]
RONALD L. WILLIAMS
WILLIAMS BRADBURY, P.C.
PO BOX 388
BOISE, IDAHO 83701
E-Mail : [e-mail]
CLEARWATER PAPER CORP
C/O PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE TD 83702
E-mail : peter@richardsonadams. com
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N 17TH STREET
BOISE ID 83702
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES
INSTITUTE INC
5549 S CLIFFSEDGE AVE
BOISE ID 837I6
E-mail : [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail : [e-mail]
SNAKE RIVER ALLIANCE
BOX l73l
BOISE ID 8370I
E-mail: [e-mail]
kmiller@ snakeriveral liance. org
SECRETAR
CERTIFICATE OF SERVICE
t