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HomeMy WebLinkAbout20160915Comments.pdfBRANDON KARPEN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0357 IDAHO BAR NO. 7956 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5918 Attorney for the Commission Staff r_ • c <'.':-::;) I ~ p ' I' CJ ·-·'--• ;) I I 12 'r· ~ • t I '01 -l : ;'.! f ! i' ' .•. J , : ·, .. .-d0S,ON BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ) A VISTA CORPORATION FOR AUTHORITY ) TO AMEND ITS ANNUAL POWER COST ) ADJUSTMENT (PCA) RA TES. ) ) ___________________ ) CASE NO. AVU-E-16-05 COMMENTS OF THE COMMISSION STAFF COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Brandon Karpen, Deputy Attorney General, and in response to the Notice of Application and Notice of Modified Procedure issued in Order No . 33571 on August 17, 2016, in Case No. AVU-E-16-05, submits the following comments. OVERVIEW OF COMPANY APPLICATION The PCA is an annual cost adjustment mechanism that tracks changes in the Company's hydroelectric generation, secondary prices, thermal fuel costs, and changes in power contract revenue and expenses ensuring that customers do not pay more or less than the Company's actual power supply expense (minus sharing). A vista's annual cost of providing electricity (i.e., its power supply costs) vary from year-to-year depending on changes in streamflow, thermal fuel costs, the market price of power, and changes in power contract revenue and expenses. If the cost of providing electricity is greater than that recovered through base rates, customers are surcharged the difference. If the cost is less, customers receive a rebate. The annual PCA rate is combined with the Company's "base rates" to produce a customer's overall energy rate. STAFF COMMENTS SEPTEMBER 15, 2016 The Company reports that lower power supply costs than expected were due primarily to favorable natural gas and wholesale power prices as well as lower net expense for Colstrip and Kettle Falls generation. Offsetting some of the lower expenses was lower generation from hydro, Palouse Wind, and Clearwater paper than those reflected in base rates. The Company asks the Commission to approve a PCA rebate of 0.017¢ per kWh to be effective October 1, 2016, in place of the 0.032¢ per kWh rebate approved by Order No. 33389. Under the Company's proposal, the PCA rate for all customers, including residential customers, would change from a rebate rate of 0.032¢ per kWh to a rebate rate of 0.017¢ per kWh-an increase in the billing rate of 0.015¢ per kWh. Since PCA rate adjustments are spread on a uniform cents per kWh basis, the resulting percentage increase varies by rate schedule. The overall increase is 0.2%. The table below shows the percentage change on billed revenue for each customer group. Percent Change on Billed Revenue for Each Type of Service Types of Service Schedule Numbers Percent Change on Billed Revenue Residential 1 0.17% General Service 11 , 12 0.15% Large General Service 21 ,22 0.19% Extra Large General Service 25 0.28% Clearwater 25P 0.29% Pumping Service 31 ,32 0.15% Street and Area Lights 41-49 0.06% Total 0.19% STAFF REVIEW Staff has thoroughly examined the Company's PCA Application by reviewing: (1) actual and authorized expenses making up the deferral; (2) the calculation method of the deferral; (3) the prudency of actual NPSE incurred during the deferral period ; ( 4) the calculation of balancing accounts and interest used to determine the final PCA rate; and (5) the calculation of the PCA rate. The results of Staffs review are summarized below. Audit of Actual and Authorized Amounts Staff conducted an onsite audit during the week of August 22, 2016. Staff reviewed and audited the deferred balance amounts included in the current filing. Additionally, Staff reviewed STAFF COMMENTS 2 SEPTEMBER 15, 2016 and audited the amounts from the prior PCA deferral that is currently being amortized, and finds the amortization of the prior year's PCA deferral to be correct. Staffs review of the deferral balance covered expenses incurred for the period of July 2015 through June 2016. Staff examined a representative cross section of transactions included in the Purchased Power account (FERC 555), Thermal Fuel account (FERC 501), Combustion Turbine Fuel account (FERC 54 7), and the Sales for Resale account (FERC 44 7). Based on its review of these transactions, Staff concludes that the various power cost transactions are reasonable and were prudently incurred at the time they were made. Staff confirmed that all transactions comply with A vista Utilities Energy Resources Risk Policy. Staff also verified that A vista's booked amounts and other calculations have been correctly reflected. Staff checked authorized amounts used to calculate the deferral and confirmed that they were the same used to determine base rates that were authorized during the deferral period. Base rates that were in effect during the deferral period were authorized in Case Nos. AVU-E-12-08 for July 1, 2015 through December 31 , 2015, and A VU-E-15-05 for January 1, 2016 through June 30, 2016. Staff recommends in future PCA filings that the Company separate authorized and actual net power costs (NPC) in the workpapers detailing the calculation of the deferral instead of only providing the actual less authorized difference . This will facilitate a more efficient Staff review. Staff has provided an example in Attachment A to these comments. Calculation of the Deferral The deferral captures the difference between actual power supply expense and the revenue that recovers power supply expense through base rates for the twelve months ending June 30, 2016. It is composed of two components: (1) the difference between actual power supply expense and the authorized power supply expense; and (2) the load change adjustment (LCA). The total deferral including interest of $5,054 for the period from July 1, 2015 through June 30, 2016, is $478,103 and is a rebate to customers. Of this amount (minus interest), $1 ,232,245 is a result of the LCA, which is a surcharge due to the Company, and the remaining STAFF COMMENTS 3 SEPTEMBER 15, 2016 is due to the actual versus authorized NPC difference of $1,676,422 which is a credit to customers. 1 Staff examined each account and item that contributes to the deferral, and also reviewed the method used in the Company's calculations. Staff believes that the $478,103 deferral balance is accurate and the method used to derive it complies with past Commission orders. The amount represents the over-recovery of actual power supply costs through base rates during the deferral period and is a refund to customers. The table below shows the accounts and items contributing to the deferral. Positive values represent a cost to customers, while negative values represent a benefit to customers. Deferral Activity Number Accounts and Items Amount 1 FERC Account 555 -Purchased Power with Palouse $20,316,973 2 FERC Account 447 -Sale for Resale (17,957,124) 3 FERC Account 501-Thermal Fuel (1,318,531) 4 FERC Account 54 7 -CT Fuel 170,598 5 Net Transmission Revenue and Expense 3,312 6 FERC Account 557 -Resource Optimization and REC Revenue (4,159,091) 7 Idaho Load Change Adjustment 1,232,245 8 All Clearwater Revenues and Expenses 1,267,440 Net Power Cost Increase (Decrease) $ (444,178) 9 REC Revenue Credit for Washington RPS (38,978) Net Deferral Balance $ (483,157) 10 Interest on the Deferral Balance 5 054 Deferral Balance with Interest $ (478 103) 1. FERC Account 555 -Purchased Power. Purchased Power costs reflect 90% of the Idaho jurisdictional share of the difference in costs the Company incurred for power purchases in the review period compared to authorized purchased power costs included in base rates. In the review period, the Company incurred more purchased power costs than are included in base rates. The positive amount is a cost to customers. Palouse Wind expenses are included in the Purchased Power costs. In the past two general rate cases, Palouse Wind has been removed from base rates and the expenses have been required to flow through the PCA accounting mechanism. This expense treatment requires 1 There was an additional $38,978 credit due to Idaho customers for the use of renewable energy credits to meet Washington's renewable portfolio standards. STAFF COMMENTS 4 SEPTEMBER 15, 2016 A vista to share 10% of the Idaho jurisdictional costs of Palouse. Had the costs been included in base rates, customers would have paid 100% of the costs associated with the Palouse Wind Project. 2. FERC Account 447 -Sale for Resale. Sales for Resale are long-term and short-term off-system sales. The amount represents 90% of the Idaho jurisdictional share of the difference between the actual off-system sale revenues and off-system sale revenues included in base rates. The negative amount in the Company's Application reflects an increase in sales for resale revenues and is a benefit to customers. 3. FERC Account 501 -Thermal Fuel. Thermal Fuel, primarily coal, is used to produce electricity. The amount represents 90% of the Idaho jurisdictional share of the difference in costs the Company incurred for thermal fuel compared to the normalized amount included in base rates. During the review period, the Company actually incurred lower coal costs than are currently included in base rates. The negative amount in the Application is a benefit to customers. 4. FERC Account 547 -CT Fuel. Combustion Turbine (CT) Fuel is natural gas burned in the Company's gas-fired generators. This amount represents 90% of the Idaho jurisdictional share of the difference in costs the Company actually incurred for gas generator fuel compared to the amount included in normalized base rates. In the review period, the Company incurred more natural gas cost than is currently included in base rates. The positive amount here is an additional cost to customers. 5. Net Transmission Revenue and Expense. In Case No. AVU-E-09-01 , the Commission approved a multi-party settlement that authorized the Company to include transmission revenues and expenses in the PCA. A vista incurs third party transmission costs when it purchases power and has it wheeled or delivered to its service area by a third party. Avista also incurs third party transmission costs when it sells power and pays a third party to deliver it. Third party transmission revenues occur when A vista is the third party and is delivering power for others. Including transmission revenues and expenses in the PCA tracks the variability of these items. In the review period, the transmission revenues were less than what is included in base rates by $76,211. Transmission expenses were less than what is included in base rates by $72,899. Although the Company paid less for transmission expenses, the shortfall in transmission revenues was larger than the difference in transmission expenses. The net transmission revenue and expense of $3 ,312 is positive and is an additional cost to customers. STAFF COMMENTS 5 SEPTEMBER 15, 2016 6. Resource Optimization. Resource Optimization results in a cost or a benefit to customers when natural gas purchased in advance for use in generating plants is later sold because it is more cost effective to sell the gas and purchase electricity than it is to generate electricity with the gas. Ninety percent of the Idaho jurisdictional share of the gain or loss on the sale of the gas transactions resulting from optimizing Company resources is included in the PCA. The gain during the review period, shown as a negative amount, is a benefit to Idaho customers. Staff notes that this line item only shows one side of the transaction, when the Company utilizes its power plants for economic dispatch, and should not be looked at independently from the entire optimization of Company resources. Generally, when the Company purchases natural gas, there is a corresponding sale of electricity and the spread between the cost to produce electricity with the natural gas purchased and the price that the electricity is sold for (the spark spread) is a benefit to customers. Staff has verified that when the Company initially purchased gas, the cost of producing electricity at A vista's natural gas plants (primarily the Coyote Springs and Lancaster facilities) was less expensive than purchasing electricity on the open market to meet its native load. Staff further verified that when the Company resold gas and purchased electricity to meet native load, the resale and corresponding purchased electricity was the least expensive and most cost­ effective alternative. Also included in the Resource Optimization amount is REC Revenue. On a system basis, REC revenue was greater than the amounts authorized in base rates by $2,758,725, and Idaho's portion, before sharing, is $966,031 . Staff recommends that the Company break out and show separately the REC revenues and expenses as a line item outside of the Resource Optimization line item in future PCA filings. 7. Idaho Load Change Adjustment. This adjustment captures the over or under recovery of net power supply expense through base rates attributable to the difference between actual sales and sales used to set base rates. The Load Change Adjustment Rate is $26.97/MWh for July 2015 through December 2015, and $22.68/MWh for January 2016 through June 2016. During the review period, the Company experienced less sales than what was used to set base rates. This results in a positive adjustment and a cost to customers. The amount is subject to 90% sharing. 8. All Clearwater Revenues and Expenses. The Clearwater revenue and expense components are directly assigned to Idaho, and are not subject to sharing. They are based on the STAFF COMMENTS 6 SEPTEMBER 15, 2016 difference in Clearwater costs and revenues (for its Lewiston facility) relative to the normalized Clearwater costs and revenues established in the Company's last general rate case. A contract that expired prior to the beginning of the deferral period (July 2015 -June 2016) is included in base rates, and it is these base rate costs that are still reflected in the PCA. This contract included A vista's purchase of Clearwater self-generation at PURP A avoided cost rates. Clearwater is currently a Schedule 25P customer; however, the revenues and expenses for the expired Clearwater contract are still included in base rates through December 2015. New base rates went into effect on January 1, 2016, and this line item will no longer be in the deferral balance calculation going forward. In the review period, the Company recorded base revenues and expenses, with no offsetting Clearwater revenue and expenses separately stated. The net amount of Clearwater revenue and expenses included in base rates is $1,267,440. This positive amount is an increased cost to customers. 9. REC Revenue Credit for Washington Renewable Portfolio Standards. This credit is based on the Idaho allocation of RECs that were retired to meet Washington Renewable Portfolio Standards that would have otherwise been sold. The Company uses the average amount per REC received for the sale of RECs to value the revenue credit for the RECs retired to meet the RPS for Washington. This amount is a benefit to customers. 10. Interest during Deferral Period. The Company calculates interest on the deferral balance using the methodology authorized in Order No. 29323. Staff reviewed the Company's interest calculation and verified that the amounts included in the deferral balance are correct. The Company uses the Customer Deposit Rate to calculate interest on current year deferrals and on carryover balances from one year to the next. The Customer Deposit Rate for 2015 and 2016 is 1%. Although the overall deferral balance results in a credit to customers, due to timing, interest during the review period is a cost to customers. Net Power Cost Analysis Staff performed an analysis of Avista's actual net power costs by comparing the unit cost and amount of each supply source used during the deferral period with the amounts authorized in base rates. This provides Staff with a determination of the Company's operational prudence by examining the utilization of specific resources and long-term contracts that were in place to meet STAFF COMMENTS 7 SEPTEMBER 15, 2016 customer load during the deferral period. Based on this analysis, Staff concludes that the Company's actual power supply costs were reasonably incurred. As illustrated by the table below, the reduction in the amount of hydro generation and lower gas prices were the biggest factors contributing to differences between actual generation and generation assumed in base rates. Lower precipitation and hydro generation availability during the first half of the deferral period required the Company to dispatch the next lowest cost resources to meet customer load. As a result, the Company increased the amount of Kettle Falls and natural gas-fired generation. While generation at these plants was higher than expected, the unit price for gas was lower than assumed in base rates. Given that market electric prices have also declined, the Company was able to utilize significantly more market purchases to make up for any shortfalls. Resources aMW Percent Unit Cost Percent Change Change Difference ($/MWh) Change Hydro Generation -71.1 -13.1 % n/a n/a Gas-fired 21.7 5.8% -2.65 -9.8% Colstrip Generation -5.0 -2.8% -1.06 -7.2% Kettle Falls 3.1 9.2% -7.45 -27% Analysis of PCA Rates As a result of its analysis, Staff believes the Company's proposed rates are accurate and will fairly reimburse customers for over collection of actual net power cost (minus sharing) embedded in base rates. Staff identified an error in the Company's rate impact calculation that has no effect on the Company's proposed rates, but is highlighted for reporting purposes. Staff also proposes simplifications in the calculation of interest that will add greater consistency, transparency, and accuracy in the development of rates and PCA filings in the future. Each of these items is discussed in more detail below. The PCA rate is calculated by dividing the PCA revenue requirement by the forecasted Idaho electricity usage during the next PCA billing period. The revenue requirement includes the ending balances from the previous year's PCA, the current PCA deferrals and amortizations, and a projected amortization for the time period after the Company submitted its Application but prior to when rates become effective on October 1, 2016. Interest is calculated based on the authorized customer deposit rate currently set at 1 % for actuals through the end of June 2016 and STAFF COMMENTS 8 SEPTEMBER 15, 2016 estimated for future periods. All estimates and projections are replaced with actuals and trued up in next year's PCA. The sum of these components is subject to a conversion rate adjusting for Commission fees and uncollectibles to arrive at the PCA revenue requirement. Staff verified the components of the revenue requirement which currently includes the amounts shown in the table below. The $519,030 decrease in revenue requirement results in a proposed 0.017¢ per kWh PCA rebate rate to customers. Based on its analysis, Staff believes the Company calculated the PCA rate correctly. PCA Rate Calculation 2014-15 PCA Ending Balance 2015-16 Incremental Deferral 2015-16 Interest on Deferral 2015-16 Amortization 2015-16 Interest on Amortization Subtotal Jul-Sept 2016 Projected Amortization Jul-Sept 2016 Projected Interest Subtotal Oct '15-Sept '17 Projected Interest Grand Total Conversion Factor PCA Revenue Requirement Forecast Sales during Collection Period (MWh) Final PCA Rate ($/kwh) Amount (483,157) 5,054 (1,438,429) (3,591) (1,920, 123) 258,788 (1,909) 256,879 (2,560) Total 1,149,773 (770,350) (513,471) (516,031) 0.994222 (519,030) 3,049,359 (0.00017) Staff found an error in the Company's residential rate impact calculation. Using 918 kWhs for average customer usage, the Company calculated a 0.16% increase in the customer's bill from $84.72 to $84.86 using the new PCA rate. Staff believes the Company used incorrect residential base rates to calculate the average bill impact. Using current residential base rates, Staff calculates the impact to be an increase from $83.80 to $83 .93 , also a 0.16% difference. In reviewing the Company's amortization and deferral balancing accounts, Staff observed that the Company is using two methods for calculating interest. The amortization accounts use compound interest while the deferral account uses a simple interest method. Staff proposes that the Company change the interest calculation in the deferral account to the same method used in the amortization accounts starting with the July 2016 through June 2017 deferral period. Staff believes this is beneficial for several reasons. First, the interest calculation method used in Idaho STAFF COMMENTS 9 SEPTEMBER 15, 2016 Power's PCA and PacifiCorp's ECAM both use compound interest calculations exclusively in their PCA balancing accounts. Implementing the change will provide consistency in the methods by all three ofldaho's regulated electric utilities. This consistency will eliminate complexity for the Company, Staff, and interveners as they evaluate the Company's accounting methods. A single interest calculation method will also enable deferral and amortization amounts to be combined into a single balance, allowing balancing account information to be included and linked with the deferral calculations on a single page (see Attachment A) and simplify the rate impact sheet the Company includes in its filing (see Attachment B). Finally, simplification would be more transparent and could reduce potential errors. For example, it could potentially eliminate the need for complicated interest adjustment entries when deferral amounts are posted incorrectly. If the change in interest calculation method were made for this year's PCA it would result in less than a $200 difference supporting the recommended prospective change. The difference could be larger with larger deferrals and customer discount rates in future PCAs. However, the impact of the change is symmetrical depending on whether deferral balances are a credit or a surcharge to customers. CUSTOMER NOTICE AND PRESS RELEASE The Company's press release and customer notice were included with its Application. Staff reviewed the documents and determined that both comply with Rule 125 of the Commission's Rules of Procedure, IDAPA 31.01.01.125. The customer notice was included with bills mailed beginning August 3, 2016, and ending September 1, 2016. Customers have the opportunity to file comments on or before September 15, 2016. CUSTOMER COMMENTS As of September 15, 2016, no comments have been filed with the Commission. STAFF RECOMMENDATIONS Staff recommends that the Commission authorize the total deferral balance with interest in the amount of $478,103 be refunded to ratepayers and approve Schedule 66 as filed in Exhibit A of the Company's Application to go into effect on October 1, 2015. STAFF COMMENTS 10 SEPTEMBER 15, 2016 Staff also recommends the following in future PCA filings: 1. The Company calculate interest on its monthly deferral balances using the same compound interest method used to calculate its monthly amortization balances beginning July 2016. 2. The Company show a breakdown of authorized and actual net power expenses instead of just the actual versus authorized differences on its deferral calculation worksheet. 3. The Company include the calculation of the balancing accounts on the deferral calculation worksheet. 4. The Company break out and show separate line items for actual and authorized REC Revenue and Resource Optimization. Respectfully submitted this Technical Staff: Mike Louis Daniel Klein Mark Rogers Kathy Stockton Yao Yin i :umisc/comments/avue 16.Sbkmlklsmrdkyy comments STAFF COMMENTS day of September 2016. 11 SEPTEMBER 15, 2016 0 C/) (') > ~Er"' ::i ~~~~ :::::: (') z ::r 0\ 0 0 3 3 . 0 3 > ~ o<> ~c "' ' tn ' 0\ ' 0 Vl Avista Corporation PCA July 2015 through June 2016 IPUC Deferral Analysis 1'1:~~f.~J;::-~1;._~~~e1M~ BASE RATE RECOVERY · LOAD CHANGE ADJUSTMENT Idaho Actual Sales Idaho Base Sales Acutal -Base Sales LCAR Retail Revenue Adjustment -Under(+)/Over(-) Base-to-Actual Percent Difference NET POWER SUPPLY EXPENSE Actual Ex . 555 Ptxchased Power 44 7 Sales for Resale 501 Thermal Fuel 547 CT Fuel 456 Transmission Revenue Sale Idaho Actual Net Expense Clearwater Purchase Clearwater Revenue Clearwater Net Revenue Authorized Net Ex nse 555 Purchased Power 555 Exclucde Palouse 44 7 Sales for Resale 501 Thermal Fuel 547 CT Fuel 456 Transmission Revenue 565 Transmission E nse Authorized Net Expense Idaho Alocation Factor Idaho Authorized Net Expense Clearwater Ptxchase Clearwater Revenue Clearwater Net Revenue RENEWABLE ENERGY CREDIT REVENUE Actual REC Revenue Authorized REC Revenue Actual -Authorized REC Revenue Idaho Anocation Factor Actual -Autohrized 1daho REC Revenue COST RECOVERY SUBJECT TO SHARING Actual -Authorized Net Expense (Idaho share) Retail Revenue Adjustment REC Revenue Total Cost (Subject to Sharing) Sharin Percenta Total Cost Recovery Subject to Sharing COST RECOVERY NOT SUBJECT TO SHARING Clearwater Actual 4 Authorized Net Revenue Total Cost Recovery Not Subject to Sharing Total Power Cost Deferral wrth Ad"ustments PCA Deferral Balance Monthly Interest Rate 2014-15 PCA Ending Balances Account 182386 June 2015 Ending Balance Account 182387 June 2015 Endin Balance 2015-2016 Be . Balance 2015-2016 Incremental Deferral RPS Compliance Adjustment Amortization -Account 182386 Amortization -Account 182387 201 S-16 Ending Balance w/out Previous Month Interest Interest 2015-16 Encf Balance DehrTal Balance Jul-15 ~ MWh 259,631 267,056 MWh 242,247 2396-41 MWh 17,384 27,415 SIMWh 26.97 26.97 s (468,846) (739,383) % 7.18% 11.44% s 13,032,881 15,967,109 s (6,398,663) (8,995,718) s 2,423,826 2,729,503 s 8,992,329 9,090,520 s (1,569,451) {1,433,184) s 1,678,«2 1,420,148 s (1,619,642) (1 ,969,918) s s 16,539,722 16,808,460 s 34.76% 34.76% s 5,749,207 5,842,621 s 0 0 s 0 0 s 0 0 s 5,648,618 7,939,502 s (6,033,100) (3,115,032) s 2,715,972 2,948,383 s 6,893,937 8,303,984 s (1,563,830) (1 ,439,516) s 1432251 1 480 124 s 9,093,848 16,117,445 s 34.76% 34.76% s l,161,022 5,602,424 s 1,665,897 1,673,537 s 1 875,474 1 884 078 s (209,577) (210,541) s 0 0 s 0 0 s 0 0 s 34.76% 34.76% s 0 0 s 2,588,185 240,197 s (468,846) (739,383) s 0 0 s 2,119,339 (499,186) " 90% 90% s 1,907,405 (449,267) s 209 577 210 541 s 209,577 210,541 s 2116982 238 726 J!!!:1.§ ~ % 0.0833% 0.0833% s 2,352,377 s 1202604 s 1 149 773 2 578 420 s 2,116,982 (238,726) s (38,978) s (650,315) (659,235) s s 2,577,462 1,680,459 s 958 2148 $ 2 578 420 1682607 s s s s 0 0 I ~ Oct-15 I ~ Dec-15 211,4 .. 5 227,4-41 248,786 302,427 218 705 210 03-4 262 809 299 304 (7,260) 17,407 (14,023) 3,123 26.97 26.97 26.97 26.97 195,802 (469,467) 378,200 (84,227) -3.32% 8.29% -5.34% 1.04% 11,448,945 11,753,765 14,963,692 16,760,121 (9,044,467) (10,680,728) (12,102,755) (12,494,264) 2,755,735 2,870,435 2,162,141 2,565,011 8,385,184 9,119,087 8,760,178 8,725,707 (1,480,437} (1,486,322) (1 ,395,586) (1,271,979) 1,417,125 1,443,829 1,406,502 1,462,172 (1 ,305,599) (714,081) (738,921) (390,259) 12,176,486 12,305,985 13,055,251 15,356,509 34.76% 34.76% 34.76% 34.76% 4,232,547 4,277,560 4,538,005 5,337,923 0 0 0 0 0 0 0 0 0 0 0 0 5,551,282 5,789,904 8,437,276 8,726,282 (4,649,875) (4,672,288) (5,573,841) (6,089,913) 2,925,528 3,051,784 2,909,636 3,002,771 8,561,441 9,099,171 9,713,701 10,900,577 (1 ,361,638) (1,498,286) (1 ,294,553) (1,278,524) 1 483 239 1 547 809 1 665 262 1635447 12,509,977 13,318,094 15,857,481 16,896,640 34.76% 34.76% 34.76% 34.76% 4,348,468 4,629,369 5,512,060 5,873,272 1,533,746 1,650,145 1,669,545 1,770,021 1 733 585 1 857 742 1 886 753 1 992 699 (199,839) (207,597) (217,208) (222,678) 0 0 0 0 0 0 0 0 0 0 0 0 34.76% 34.76% 34.76% 34.76% 0 0 0 0 (115,921) (351,809) (974,055) (535,349) 195,802 (469,467) 378,200 (84,227) 0 0 0 0 79,881 (821,276) (595,855) (619,576) 90% 90% 90% 90% 71,893 (739,148) (536,270) (557,618) 199 839 207 597 217 208 222 678 199,839 207,597 217,208 222,678 271 732 531 551 319 062 334 940 I ~ ~ I ~ ~ 0.0833% 0.0833% 0.0833% 0.0833% 1682607 1 366 648 666 170 419 580 271,732 (531,551) (319,062) (334,940) (589,093) (170,065) 71 917 92 918 1,365,246 665,032 419,025 177,558 1 402 1138 555 350 1366S.S 666170 419 580 177 908 0 0 0 0 Ju4-1Sthru Jan-16 Felr16 I Mar-16 ~ I May-16 Jun-16 J~16 287,600 247,551 242,490 21s.s•• 211,312 218,387 2,942,770 299 392 263 761 268 236 243 401 23-4 981 228 959 3 011 470 (11,792) (16,210) (25,746) (24,757) (23,669) (10,572) (68,700) 22.68 22.68 22.68 22.68 22.68 22.68 267,443 367,643 583,919 561,489 536,813 239,773 1,369,159 -3.94% -6.15% ·9.60% -10.17% -10.07% -'1.62% ·2.3% 13,649,153 13,452,207 13,762,455 11,810,638 10,399,522 10,545,763 157,546,251 (10,291,009) (10,637,878) (11,228,965) {9,817,050) (10,187,127) (9,220,527) {121,099,151) 2,753,922 2,300,883 2,083,055 2,266,480 662,548 1,809,764 27,383,303 9,063,065 6,579,384 5,500,996 3,000,674 3,859,806 3,886,295 84,963,225 (1,324,359) (1,112,794) (1.154,350) (1,298,500) (1,403,137) (1,567,883) (16,.497,982) 1,376,369 1,599,865 1,438,139 1,405,327 1,375,315 1,371,935 17,395,168 (1,971,230) (531,977) (926,365) (1,090,951) (1,719,080) (1,604,664) (14,582.687) 13,255,911 11,649,690 9,474,965 6,276,618 2,987,847 5,220,683 135,108,127 35.29% 35.29% 35.29% 35.29% 35.29% 35.29% 4,678,011 4,111,176 3,343,715 2,215,018 1,054,411 1,842,379 47,222,573 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 12,161,272 11,404,620 9,963,402 8,809,523 6,740,586 6,706,571 97,878,838 (821,526) (821,526) (821,526) (821,526) (821,526) (821 ,526) (5,920,050) (4,854,311) (5,165,161) (6,554,606) (6,515,727) (4,972,680) (64,116,584) 2,775,328 2,612,937 2,619,359 2,265,736 2,033,267 1,704,765 31,565,466 8,051,247 7,027,863 6,561,435 4,369,417 2,748,054 2,201 ,271 84,432,098 (1,405,733) (1,166,326) (1 ,222,888) (1,264,428) (1,579,616) (1,659,588) (16,734,926) 1 452 738 1 372 806 1 509 572 1 336,193 1 369 317 1 346 174 17 630 932 16,293,276 15,576,063 13,444,193 8,140,309 3,974,355 4,504,987 145,726,668 3529% 35.29% 35.29% 3529% 35.29% 35.29% 5,749,897 5,496,793 4,744,456 2,872,715 1,402,550 1,589,810 50,982,836 9,962,891 11230331 0 0 0 0 0 0 (1,267,440) 0 0 0 0 0 0 0 236 220 220 980 236 220 228 283 236 220 228 600 1 386 523 236,220 220,980 236,220 228,283 236,220 228,600 1,386,523 35.29% 35.29% 35.29% 35.29% 35.29% 35.29% 83,362 77,984 83,362 80,561 83,362 80,673 489,304 (1,071,886) (1,385,617) (1,400,741) (657,697) (348,139) 252,569 (3,760,263) 267,443 367,643 583,919 561,489 536,813 239,773 1,369,159 _Lill.ill 83 362 77 964 83 362 80 561 83 362 80673 489 304 (721 ,081) (939,990) (733,460) (15,647) 272,036 573,015 (1,901,800) 90% 90% 90% 90% 90% 90% (648,973) (845,991) (660,114) (14,082) 244,832 515,714 (1,711,619) 0 0 0 0 0 0 1 267 440 0 0 0 0 0 0 1,267,440 648 973 845 991 660 114 14 082 244 832 515 714 444179 (1676422\ ~ Feb-16 I M!ill ~ I M!ill ~ Ml§ ~ I ~ 0.0833% 0.0833% 0.0833% 0.0833% 0.0833% 0.0833% 0.0833% 0.0833% 0.0833% 2,352,377 1 202 604 177 908 374 583 1137 409 1 722 495 1 665 056 1 354 680 (648,973) (845,991) (660,114) (14,082) 244,832 (444,179) (38,978) (2,068,708) 96 334 83 477 75 975 72 956 66 931 630 279 (374,731) (1,137,097) (1,721,548) (1,663,621) (1,353,293) (769,195) 148 312 947 1 435 1 387 1 490 374 583 1137409 1722495 1 665 056 1354680 70323 739 207 660 433 582 780 582 780 79,390 78,203 69,339 258,048 616 550 485 1 651 0 0 0 0 0 39,20 660433 582 780 513 926 513 926 (OOOs of Dollars) (OOOs of kWh) Line Type of No. Service (a) 1 Residential 2 General Service 3 Large General Service 4 Extra Large General Service 5 Clearwater 6 Pumping Service 7 Street & Area Lights AVISTA UTILITIES IDAHO ELECTRIC IMPACT OF PROJECTED SCHEDULE 66 PCA DECREASE PROPOSED RATE TO BE EFFECTIVE OCTOBER 1. 2016 Schedule Forecasted Number Kilowatt-hours (b) (c)(1) 1 1,186,226 11, 12 366,159 21 ,22 651,417 25 368,180 25P 405,418 31 ,32 58,273 41-49 13,686 $ $ $ $ $ $ $ 8 Total 3,049,359 $ 9 Proposed rate 10 Present rate 11 Rate Change Pro.12.osed rate 12 Total Amortization and Deferral Balance including interest thru 9/30/16 Forecasted Interest (Deferral and Amert )10/1/16-9/30/17 Total Balance with Forecasted Interest 13 Conversion factor 14 Revenue requirement 15 kWh's from above Proposed rate: $ (0.00017) $ $ (0.00032) $ $ 0.00015 $ $ $ $ $ $ (1) Source: Calendar Load forecast for the twelve month period October 1, 2016 -September 30, 2017 ocnn:i> ~ S""' ;:I: ~~~~ ---n z ::r a: 0 0 3 3 . (1) ;3 > ;:;. (1) < t:O ;:;. s=: en tTl ' °' b Ul (518) (979) 461 (513.926000) (2.569630) (516.495630) 0.994222 (516.912722) 3,049,359 (0.000170) Total Billed Percent Revenue Proposed change at Present Sch.66 on Billed Rates Change Revenue (d) (e) (f) 106,676 $ 178 0.17% 36,545 $ 55 0.15% 52,697 $ 98 0.19% 19,487 $ 55 0.28% 21 ,280 $ 61 0.29% 5,817 $ 9 0.15% 3,592 $ 2 0.06% 246,094 $ 458 0.19% CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF SEPTEMBER 2016, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. AVU-E-16-05 , BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: KELLY NORWOOD VP-STATE & FED REG AVISTA CORPORATION PO BOX 3727 SPOKANE WA 99220-3727 E-mail: kelly.norwood@avistacorp.com PETER J RICHARDSON GREGORY MADAMS RICHARDSON ADAMS PLLC PO BOX 7218 BOISE ID 83702 E-mail: peter@richardsonadams.com greg@richardsonadams.com DAVID J MEYER VP & CHIEF COUNSEL AVISTA CORPORATION PO BOX 3727 SPOKANE WA 99220-3727 E-mail: david.meyer(a),avistacorp.com DR DON READING 6070 HILL ROAD BOISE ID 83703 E-mail: dreading@mindspring.com CERTIFICATE OF SERVICE