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HomeMy WebLinkAbout20170612Ehrbar Direct.pdf DAVID J. MEYER VICE PRESIDENT AND CHIEF COUNSEL FOR REGULATORY & GOVERNMENTAL AFFAIRS AVISTA CORPORATION P.O. BOX 3727 1411 EAST MISSION AVENUE SPOKANE, WASHINGTON 99220-3727 TELEPHONE: (509) 495-4316 FACSIMILE: (509) 495-8851 DAVID.MEYER@AVISTACORP.COM BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-E-17-01 OF AVISTA CORPORATION FOR THE ) CASE NO. AVU-G-17-01 AUTHORITY TO INCREASE ITS RATES ) AND CHARGES FOR ELECTRIC AND ) NATURAL GAS SERVICE TO ELECTRIC ) DIRECT TESTIMONY AND NATURAL GAS CUSTOMERS IN THE ) OF STATE OF IDAHO ) PATRICK D. EHRBAR FOR AVISTA CORPORATION (ELECTRIC AND NATURAL GAS) Ehrbar, Di 1 Avista Corporation I. INTRODUCTION 1 Q. Please state your name, business address and 2 present position with Avista Corporation? 3 A. My name is Patrick D. Ehrbar and my business address is 1411 East Mission Avenue, Spokane, Washington. I am presently assigned to the State and Federal Regulation Department as Senior Manager of Rates and Tariffs. Q. Would you briefly describe your educational 8 background and professional experience? 9 A. Yes. I am a 1995 graduate of Gonzaga University with a Bachelors degree in Business Administration. In 1997 I graduated from Gonzaga University with a Masters degree in Business Administration. I started with Avista in April 1997 as a Resource Management Analyst in the Company’s Demand Side 14 Management (DSM) department. Later, I became a Program Manager, responsible for energy efficiency program offerings for the Company’s educational and governmental customers. In 2000, I was selected to be one of the Company’s key Account 18 Executives. In this role I was responsible for, among other things, being the primary point of contact for numerous commercial and industrial customers, including delivery of the Company’s site specific energy efficiency programs. I joined the State and Federal Regulation Department as a Senior Regulatory Analyst in 2007. Responsibilities in that Ehrbar, Di 2 Avista Corporation role included being the discovery coordinator for the Company’s rate cases, line extension policy tariffs, as well as miscellaneous regulatory issues. In November 2009, I was promoted to Manager of Rates and Tariffs, and later promoted to be Senior Manager of Rates and Tariffs. My primary areas of responsibility include electric and natural gas rate design, decoupling, power cost and natural gas rate adjustments, customer usage and revenue analysis, and tariff administration. Q. What is the scope of your testimony in this 10 proceeding? 11 A. My testimony in this proceeding will cover the spread of the proposed 2018 and 2019 electric and natural gas revenue increases among the Company’s electric and natural gas general service schedules. My testimony will also describe the changes to the rates within the Company’s electric and 16 natural gas service schedules. Q. Would you please provide an overview of the 18 Company’s electric and natural gas rate requests? 19 A. Yes. As discussed by Company witness Mr. Morris, the Company is proposing a Two-Year Rate Plan for calendar years 2018 and 2019, with proposed increases effective January 1 of each year. The Company is proposing a Two-Year Rate Plan, to once again, avoid annual rate cases in its Idaho Ehrbar, Di 3 Avista Corporation jurisdiction, providing benefits to all stakeholders. A Two- Year Rate Plan, with increases in 2018 and 2019, would provide benefits to its customers by providing a level of rate predictability to customers over this two-year period. A two- year window also provides Avista with the opportunity to manage its business in order to achieve a fair rate of return within known price changes. Finally, relief is provided to all stakeholders (customers, the Commission and its Staff, intervenors, and the Company) from the administrative burdens and costs of litigation of annual general rate cases. Accordingly, the Company has filed two sets of tariffs for each of the electric and natural gas service schedules. The first tariff for each rate schedule provides for an effective date of July 9, 2017; however, in the Company’s 14 Application in this case, Avista has requested that the tariffs related to the 2018 rate request be suspended with a proposed effective date of January 1, 2018. The second set of tariffs filed for each of the electric and natural gas service schedules have an effective date of January 1, 2019, consistent with the Company’s second-step increase proposal. Provided below in Table Nos. 1 & 2 is a summary of the proposed increase, by rate schedule, on a billing basis (inclusive of all base and billing rate components, including Ehrbar, Di 4 Avista Corporation Rate Schedule Description 2018 Billing Increase 2019 Billing Increase Residential Service Schedule 1 8.1%4.3% General Service Schedules 11 & 12 7.5%4.0% Large General Service Schedules 21 & 22 8.2%4.4% Extra Large General Service Schedule 25 7.7%4.3% Extra Large General Service 25P Schedule 25P 7.2%4.1% Pumping Service Schedules 31 & 32 8.8%4.6% Street & Area Lights Schedules 41 - 49 7.5%3.8% Total 7.9%4.2% Table 2: 2018 & 2019 Natural Gas Rate Request by Rate Schedule Rate Schedule Description 2018 Billing Increase 2019 Billing Increase General Service Schedule 101 6.6%3.8% Large General Service Schedules 111 & 112 2.2%1.3% Interruptible Service Schedules 131 & 132 0.0%0.0% Transportation Service Schedule 146*9.2%5.0% Total 5.7%3.3% * excludes commodity and interstate pipeline transportation costs the effect of the new and expiring electric rebates discussed later in my testimony): Table No. 1 – 2018 & 2019 Electric Rate Request by Schedule 3 Table No. 2 – 2018 & 2019 Natural Gas Rate Request by Schedule 11 16 17 18 Q. Are you sponsoring any Exhibits that accompany your 19 testimony? A. Yes. I am sponsoring Exhibit No. 16, Schedules 1 through 3 related to the proposed electric increase, and Schedules 4 through 6 related to the proposed natural gas increase. These exhibits were prepared under my supervision. A table of contents for my testimony is as follows: Ehrbar, Di 5 Avista Corporation Table of Contents Page 1 I. Introduction 1 II. Proposed Electric Revenue Increase 5 Summary of Rate Schedules and Tariffs 5 Proposed Rate Spread (Increase by Schedule) 7 Proposed Rate Design (Rates within Schedules) 11 III. Proposed Natural Gas Revenue Increase 24 Summary of Rate Schedules and Tariffs 25 Proposed Rate Spread (Increase by Schedule) 27 Proposed Rate Design (Rates within Schedules) 30 13 II. PROPOSED ELECTRIC REVENUE INCREASE 14 Summary of Electric Rate Schedules and Tariffs 15 Q. Would you please explain what is contained in 16 Schedule 1 of Exhibit No. 16? 17 A. Yes. Schedule 1 is a copy of the Company’s present 18 and proposed electric tariffs for 2018 and 2019, showing the changes (strikeout and underline) proposed in this filing. Q. Would you please describe what is contained in 21 Schedule 2 of Exhibit No. 16? A. Yes. Schedule 2 contains the proposed (clean) electric tariff sheets for 2018 and 2019 incorporating the proposed changes included in this filing. Q. What is contained in Schedule 3 of Exhibit No. 16? A. Schedule 3 contains information regarding the proposed spread of the electric revenue increase among the service schedules and the proposed changes to the rates within the schedules. Page 1 shows the 2018 and 2019 proposed Ehrbar, Di 6 Avista Corporation general revenue and percentage increases by rate schedule compared to the present revenue under base tariff and billing rates. Page 2 shows the rates of return and the relative rates of return for each of the schedules before and after application of the proposed 2018 general increase. Pages 3 and 4 show the present rates under each of the rate schedules, the proposed changes to the rates within the schedules, and the proposed rates after application of the 2018 and 2019 rate changes. These pages will be referred to later in my testimony. Q. Would you please describe the Company's present 11 rate schedules and the types of electric service offered under 12 each? 13 A. Yes. The Company presently provides electric service under Residential Service Schedule 1, General Service Schedules 11 and 12, Large General Service Schedules 21 and 22, Extra Large General Service under Schedule 25 and Schedule 25P (Clearwater Paper’s Lewiston Plant), and Pumping Service Schedules 31 and 32. Additionally, the Company provides Street Lighting Service under Schedules 41-46, and Area Lighting Service under Schedules 47-49. Schedules 12, 22, 32, and 48 cover residential and farm service customers who qualify for the Residential Exchange Program operated by the Bonneville Power Administration. The rates for these Ehrbar, Di 7 Avista Corporation Rate Schedule No. of Customers Residential Schedule 1 105,700 General Service Schedules 11/12 21,114 Large General Service Schedules 21/22 1,125 Extra Large General Service Schedule 25 11 Clearwater Paper Schedule 25P 1 Pumping Service Schedules 31/32 1,403 Table No. 3 - Customers by Service Schedule schedules are identical to the rates for Schedules 11, 21, 31, and 47, respectively, except for the Residential Exchange rate credit. The following table shows the type and number of customers served in Idaho (as of December 2016) under each of the electric service schedules: 12 Proposed Electric Rate Spread 13 Q. For 2018, what is the proposed electric revenue 14 increase, and how is the Company proposing to spread the 15 increase by rate schedule? 16 A. For 2018, the proposed electric increase is $18,571,000, or 7.5% over present base tariff rates in effect. The proposed general increase over present billing rates, including all other rate adjustments (such as DSM and Residential Exchange), is 7.9%. The proposed percentage increase by rate schedule is as follows: Ehrbar, Di 8 Avista Corporation Table No. 4 - Proposed % Electric Increase by Schedule - 2018 Rate Schedule Increase in Base Rates Increase in Billing Rates Residential Schedule 1 7.8%8.1% General Service Schedules 11/12 7.2%7.5% Large General Service Schedules 21/22 7.8%8.2% Extra Large General Service Schedule 25 7.0%7.7% Clearwater Paper Schedule 25P 6.5%7.2% Pumping Service Schedules 31/32 8.5%8.8% Street & Area Lights Schedules 41-48 7.5%7.5% Overall 7.5%7.9% This information is shown with more detail on page 1 of Exhibit No. 16, Schedule 3. Q. What is the Company’s proposal related to the 10 current rebate customers are receiving in 2017? 11 A. Through rate Schedule 97, customers are receiving a rebate of $0.00091 per kWh for 2017 (approximately $2.7 million). This rebate rate was approved in the Company’s 2015 general rate case, Case No. AVU-E-15-05. The rebate was related to Avista’s 2014 electric earnings sharing of 16 approximately $5.6 million, of which approximately one-half was rebated to customers in 2016, and the remaining half rebated in 2017. Avista deferred approximately $1.5 million under the electric earnings sharing for calendar-year 2015. The Company is proposing in this case to use the $1.5 million deferral balance from 2015 to replace approximately one-half of the current rebate in 2018. The Company has filed tariff sheet Ehrbar, Di 9 Avista Corporation Schedule 97 with revised language reflecting the new rebate.1 The net effect for 2018 of the expiring rebate, offset by the new rebate, is an increase in billed revenues (i.e., less of a rebate) of approximately $1.2 million. Q. How did the Company spread the total 2018 general 5 revenue increase request of $18,571,000 among its various rate 6 schedules? 7 A. The Company used the results of the electric cost of service study (sponsored by Company witness Ms. Knox) as a guide to spread the general increase. The spread of the proposed increase generally results in the rates of return for the various electric service schedules moving approximately 15 percent closer to the overall rate of return (unity). While we believe it is reasonable and appropriate to use the cost of service study results as the basis for rate spread, we have tempered the amount of movement toward unity proposed in this case due primarily to the impact such movement would have between the rate schedules. The Company may propose additional movement toward unity in future proceedings. Table No. 5 below shows the relative rates of return before and after application of the proposed general increase: 1 Consistent with the provisions of Schedule 97, any over- or under- amortization of the $1.5 million rebate would be trued up in a future PCA filed by the Company. Ehrbar, Di 10 Avista Corporation Present Proposed Relative Relative Rate Schedule ROR ROR Residential Schedule 1 0.81 0.84 General Service Schedules 11/12 1.47 1.40 Large General Service Schedules 21/22 1.14 1.12 Extra Large General Service Schedule 25 0.96 0.97 Clearwater Paper Schedule 25P 1.06 1.05 Pumping Service Schedules 31/32 0.92 0.93 Street & Area Lights Schedules 1.07 1.00 Overall 1.00 1.00 Table No. 5 - Present & Proposed Relative Rates of Return 2 3 4 5 6 7 This information is shown in detail on Page 2, Schedule 3 of Exhibit No. 16. Q. For 2019, what is the proposed electric revenue 11 increase, and how is the Company proposing to spread the 12 increase by rate schedule? 13 A. For 2019, the proposed electric increase is $9,936,000, or 3.7% over base tariff rates. The proposed general increase over billing rates, including all other rate adjustments (such as DSM and Residential Exchange), is 4.2%. The overall billed increase also reflects the expiration of the 2015 earnings test rebate (proposed to be rebated in 2018) discussed earlier in my testimony. The Company used a pro-rata allocation of the Company’s 21 2018 electric rate spread percentages for purposes of spreading the proposed 2019 electric revenue increase to its electric service schedules. The proposed percentage increase Ehrbar, Di 11 Avista Corporation Table No. 6 - Proposed % Electric Increase by Schedule - 2019 Rate Schedule Increase in Base Rates Increase in Billing Rates Residential Schedule 1 3.9%4.3% General Service Schedules 11/12 3.6%4.0% Large General Service Schedules 21/22 3.9%4.4% Extra Large General Service Schedule 25 3.5%4.3% Clearwater Paper Schedule 25P 3.3%4.1% Pumping Service Schedules 31/32 4.2%4.6% Street & Area Lights Schedules 41-48 3.7%3.8% Overall 3.7%4.2% by rate schedule is as follows: This information is shown with more detail on page 1 of Exhibit No. 16, Schedule 3. Proposed Rate Design 12 Q. Where in your Exhibit do you show a comparison of 13 the present and proposed rates within each of the Company’s 14 electric service schedules? 15 A. Pages 3 (for 2018) and 4 (for 2019) of Schedule 3 in Exhibit No. 16 shows a comparison of the present and proposed rates within each of the schedules, which I will describe below. Column (a) shows the rate/billing components under each of the schedules, column (b) shows the present base tariff rates within each of the schedules, column (c) shows the present rate adjustments applicable under each schedule, and column (d) shows the present billing rates. Column (e) shows the proposed general rate increase to the rate Ehrbar, Di 12 Avista Corporation components within each of the schedules, column (f) shows the proposed revenue changes under Schedule 97, column (g) shows the proposed billing rates and column (h) shows the proposed base tariff rates. Q. Is the Company proposing any changes to the existing 5 rate structures within its rate schedules? 6 A. No. The Company is not proposing any changes to the present rate structures within its electric schedules. Q. Turning to Residential Service Schedule 1, could 9 you please describe the present rate structure under this 10 schedule? 11 A. Yes. Residential Schedule 1 has a present customer or basic charge of $5.75 per month and two energy rate blocks: 0-600 kWhs and over 600 kWhs. The present base tariff rate for the first 600 kWhs per month is 8.449 cents per kWh and 9.434 cents for all kWhs over 600. Q. How does the Company propose to spread Schedule 1’s 17 proposed 2018 general revenue increase of $8,473,000 to the 18 rates within that schedule? 19 A. The Company proposes to increase the monthly customer charge from $5.75 per month to $6.00 per month. The remaining revenue increase for the schedule is proposed to be recovered through a uniform percentage increase of approximately 8.0% applied to the two energy block rates. The Ehrbar, Di 13 Avista Corporation proposed increase for the first 600 kWhs used per month under the schedule is 0.677 cents per kWh, and an increase of 0.757 cents per kWh for usage over 600 kWhs per month. Q. How does the Company propose to spread Schedule 1’s 4 proposed 2019 general revenue increase of $4,536,000 to the 5 rates within that schedule? 6 A. The Company proposes to keep the monthly customer charge at $6.00 per month. The revenue increase for the schedule is proposed to be recovered through a uniform percentage increase of approximately 4.1% applied to the two energy block rates. The proposed increase for the first 600 kWhs used per month under the Schedule is 0.377 cents per kWh, and an increase of 0.420 cents per kWh for usage over 600 kWhs per month. Q. For 2018, what is the proposed increase for a 15 residential electric customer with average consumption? 16 A. The proposed increase for a residential customer using an average of 910 kWhs per month is $7.03 per month, or an 8.1% increase in their electric bill. The present bill for 910 kWhs is $86.39 compared to the proposed level of $93.42, including all rate adjustments. Q. For 2019, what is the proposed increase for a 22 residential electric customer with average consumption? 23 A. The proposed increase for a residential customer Ehrbar, Di 14 Avista Corporation using an average of 910 kWhs per month is $4.02 per month, or a 4.3% increase in their electric bill, resulting in an overall bill of $97.44, including all rate adjustments. Q. Turning to General Service Schedules 11/12, could 4 you please describe the present rate structure and rates under 5 those schedules? 6 A. Yes. General Service Schedules 11/12 are the service schedules typically applicable to customers with an average demand of less than 20 kW per month, such as small retail establishments (Schedule 11), or shops for residential customers which require a separate service (Schedule 12). The present rate structure under the schedules includes a monthly customer charge of $12.00, an energy rate of 9.704 cents per kWh for all usage up to 3,650 kWhs per month, and an energy rate of 7.216 cents per kWh for usage over 3,650 kWhs per month. There is also a demand charge of $5.75 per kW for all demand in excess of 20 kW per month. There is no charge for the first 20 kW of demand. Q. How is the Company proposing to apply Schedule 19 11/12’s proposed 2018 general revenue increase of $2,681,000 20 to the rates within those schedules? 21 A. The Company is proposing that the customer charge increase by $1.00 per month, from $12.00 to $13.00. The Company is also proposing that the variable demand rate Ehrbar, Di 15 Avista Corporation increase from $5.75/kW to $6.00/kW. The remaining revenue increase for those schedules is proposed to be recovered through a 0.785 cent per kWh, or 8.1%, increase to the first energy block (the first 3,650 kWhs used per month), and a 0.293 cent per kWh, or 4.1%, increase to the second energy block. The Company is proposing to increase the second energy block by approximately one-half the percentage increase to the first block in order to provide a more meaningful separation between the blocks, and to ensure that the higher load factor customers served on those schedules do not pay a melded rate per kWh that is higher than customers with poor load factors. Q. How is the Company proposing to apply Schedule 13 11/12’s proposed 2019 general revenue increase of $1,433,000 14 to the rates within those schedules? 15 A. The revenue increase for the schedules is proposed to be recovered through a 0.477 cent per kWh, or 4.6%, increase to the first energy block (the first 3,650 kWhs used per month), and a 0.171 cent per kWh, or 2.3%, increase to the second energy block. Similar to 2018, the Company is proposing to increase the second block by one-half of the proposed percentage increase to the first block in order to provide a more meaningful separation between the blocks, and to ensure that the higher load factor customers served on the Ehrbar, Di 16 Avista Corporation schedules do not pay a melded rate per kWh that is higher than customers with poor load factors. Q. Turning to Large General Service Schedules 21/22, 3 would you please describe the present rate structure under 4 those schedules and how the Company is proposing to apply 5 Schedule 21/22’s 2018 increase of $4,048,000 to the rates 6 within the schedules? A. Yes. Large General Service Schedules 21/22 are the service schedules applicable to customers with monthly demands over 50 kW, but less than 3,000 kW. Typical customers served are grocery stores, schools, and office buildings (Schedule 21) and retirement homes and other qualified residential load (Schedule 22). These schedules consist of a minimum monthly charge of $400.00 for the first 50 kW or less, a demand charge of $5.25 per kW for monthly demand in excess of 50 kW, and two energy block rates: 6.322 cents per kWh for the first 250,000 kWhs per month, and 5.396 cents per kWh for all usage in excess of 250,000 kWhs. The Company is proposing to increase the present minimum demand charge (for the first 50 kW or less) by $25 per month, from $400.00 to $425.00, and increase the demand charge from $5.25/kW to $5.50/kW. The remaining revenue increase for the schedules is proposed to be recovered through a uniform Ehrbar, Di 17 Avista Corporation percentage increase of approximately 8.4% applied to the two energy block rates. The proposed increase for the first 250,000 kWhs used per month under the schedules is 0.533 cents per kWh, and an increase of 0.455 cents per kWh for usage over 250,000 kWhs per month. Q. Would you please describe how the Company is 6 proposing to apply Schedule 21/22’s 2019 increase of 7 $2,165,000 to the rates within the schedule? A. Yes. The revenue increase for the schedules is proposed to be recovered through a uniform percentage increase of approximately 4.9% applied to the two energy block rates. The proposed increase for the first 250,000 kWhs used per month under the schedules is 0.338 cents per kWh, and an increase of 0.289 cents per kWh for usage over 250,000 kWhs per month. Q. Turning to Extra Large General Service Schedule 25, 16 would you please describe the present rate structure under 17 that schedule, and how the Company is proposing to apply 18 Schedule 25’s 2018 increase of $1,391,000 to the rates within 19 the schedule? A. Yes. Schedule 25 is applicable for customers with demands in excess of 3,000 kVa per month, such as large industrial customers and universities. Extra Large General Service Schedule 25 consists of a minimum monthly charge of Ehrbar, Di 18 Avista Corporation $13,500 for the first 3,000 kVa or less, a demand charge of $4.75 per kVa for monthly demand in excess of 3,000 kVa, and two energy block rates: 5.299 cents per kWh for the first 500,000 kWhs per month and 4.487 cents per kWh for all usage in excess of 500,000 kWhs. The Company is proposing that the present minimum demand charge of $13,500 be increased by $500 to $14,000 per month. Further, the Company is proposing to increase the volumetric demand charge from $4.75/kVA to $5.00/kVA. The remaining revenue increase for the schedule is proposed to be recovered through a uniform percentage increase of approximately 7.4% applied to the two energy block rates. The proposed energy rate increase for the first 500,000 kWhs used per month is 0.395 cents per kWh and the increase for usage over 500,000 per month is 0.334 cents per kWh. Q. Would you please describe how the Company is 16 proposing to apply Schedule 25’s 2019 increase of $743,000 to 17 the rates within the schedule? A. Yes. The revenue increase for the schedule is proposed to be recovered through a uniform percentage increase of approximately 4.2% applied to the two energy block rates. The proposed energy rate increase for the first 500,000 kWhs used per month is 0.238 cents per kWh and the increase for usage over 500,000 per month is 0.201 cents per kWh. Ehrbar, Di 19 Avista Corporation Q. Please describe the service the Company provides to 1 Clearwater Paper’s Lewiston Plant under Schedule 25P. A. In Commission Order No. 32841, dated June 28, 2013, the Commission approved a five-year Electric Service Agreement (Agreement) between Avista and Clearwater, applicable to its Lewiston Plant. The Agreement became effective July 1, 2013 and expires June 30, 2021.2 The Agreement provides for Clearwater to use its on-site generation to serve its own load, and for Clearwater to purchase from Avista all of the electric power requirements that exceed the electric power generated by Clearwater. Avista serves Clearwater’s load requirements under Schedule 25P. Q. Please describe the application of the proposed 14 Schedule 25P 2018 increase of $1,238,000 to the rates within 15 the schedule. A. Like Schedule 25, the Company is proposing that the present minimum demand charge of $13,500 be increased by $500 to $14,000 per month. Further, the Company is proposing to increase the volumetric demand charge from $4.75/kVA to $5.00/kVA for all kVA between 3,000 and 55,000, and from 2 On July 30, 2015 the Commission approved (Order No. 33350) a Joint Petition between Avista and Clearwater which, among other things, gave approval of a contract amendment which would extend the length of the original contract from June 30, 2018 to June 30, 2021 (Case No. AVU-E-15- 06). Ehrbar, Di 20 Avista Corporation $2.25/kVA to $2.50/kVA for all kVA over 55,000. The remaining revenue increase for the schedule is proposed to be recovered through an increase of 0.278 cents per kWh to the energy charge. Q. Please describe the application of the proposed 5 Schedule 25P 2019 increase of $663,000 to the rates within 6 the schedule. A. The revenue increase for the schedule is proposed to be recovered through an increase of 0.183 cents per kWh to the energy charge. 10 Q. Turning to Pumping Schedules 31/32, would you 11 please describe how the Company is proposing to apply Schedule 12 31/32’s 2018 increase of $468,000 to the rates within the 13 schedules? A. The Company is proposing that the customer charge of $10.00 per month be increased by $1.00, to $11.00 per month, and that the remaining revenue increase be spread on a uniform percentage basis of approximately 8.5% to the two energy rate blocks under the schedules. The proposed increase in the first block rate is 0.813 cents per kWh and the increase in the second block rate is 0.693 cents per kwh. Q. Please describe how the Company is proposing to 22 apply Schedule 31/32’s 2019 increase of $251,000 to the rates 23 within the schedules. Ehrbar, Di 21 Avista Corporation A. The Company is proposing that the revenue increase be spread on a uniform percentage basis of approximately 4.4% to the two energy rate blocks under the schedules. The proposed increase in the first block rate is 0.454 cents per kWh, and the increase in the second block rate is 0.387 cents per kwh. Q. How is the Company proposing to spread the proposed 7 2018 revenue increase of $272,000 applicable to Street and 8 Area Light (Schedules 41-49)? 9 A. The Company proposes to increase present street and area light (base) rates on a uniform percentage basis. The proposed increase for all lighting rates is 7.5%. The (base tariff) rates are shown in the tariffs for those schedules, in Exhibit No. 16, Schedule 2. Q. How is the Company proposing to spread the proposed 15 2019 revenue increase of $145,000 applicable to Street and 16 Area Light (Schedules 41-49)? 17 A. The Company proposes to increase present street and area light (base) rates on a uniform percentage basis. The proposed increase for all lighting rates is 3.7%. The (base tariff) rates are shown in the tariffs for those schedules, in Exhibit No. 16, Schedule 2. Q. Is the Company proposing any other changes to its 23 Street and Area Light schedules? Ehrbar, Di 22 Avista Corporation A. Yes. For Schedule 42 (Company-owned street lights) and Schedule 49 (Area Lighting), the Company is proposing that High Pressure Sodium Vapor (“HPS”) lights should no longer be 3 made available for new installations. As discussed by Company witness Ms. Rosentrater, the Company is currently converting its Company-owned street and area lights from HPS to LED technology over a five-year period. With a change in the Company’s standards to only support LED street and area light 8 technology, Avista is proposing to remove HPS as an option for new customer installations.3 In addition, in the Company’s 2015 general rate case (Case No. AVU-E-15-05), the Commission approved the Company’s 12 “Custom Street Light Calculation” contained in Schedule 42, 13 “Company Owned Street Light Service – Idaho”. Schedule 42 is 14 applicable to local, state, or federal governments for purposes of lighting public streets and thoroughfares. The Company also provides similar lighting under Schedule 49, “Area Light – Idaho”. Lighting options under this schedule 18 are similar to the lighting options under Schedule 42, with the only exception being that area lights are not used to light streets or thoroughfares, but rather yards, alleys, and parks, for example. As mentioned, Schedule 42 contains a 3 There may be circumstances where an existing customer (an existing street/area light) requires a HPS light and cannot support an LED light. In those circumstances the customer would continue to receive HPS service under Schedule 42 or 49. Ehrbar, Di 23 Avista Corporation “Custom Street Light Calculation”, as customers over time have 1 requested lighting options that in some cases are not in the Company’s tariff. This custom calculation allows Avista to 3 calculate a rate for such a light in between rate cases. In this case, the Company has included the same custom calculation in Schedule 49 for the same reasons the Company added it to Schedule 42 several years ago – i.e., customers have requested lighting options that are not already existing in Schedule 49.4 Q. Turning now to the Company’s Electric Fixed Cost 10 Adjustment Mechanism, how will new baseline information be 11 incorporated into the mechanism? A. As in the prior general rate case, the Company would, as a part of its Compliance Filing, submit the final baseline values for its Fixed Cost Adjustment Mechanism (for both 2018 and 2019) prior to new rates going into effect as a result of this general rate case.5 4 To determine the rate for a new light option, the capital cost, maintenance expense, and energy costs need to be determined. As shown in the proposed revisions to Schedule 47, the capital cost calculation is the same as what is provided for in Schedule 42. The maintenance cost would be based on an engineering estimate of the maintenance cost of a new fixture. Finally, the energy rate calculation is the same as what is provided for in Schedule 46 (the energy-only street light tariff). 5 The Company’s Electric and Natural Gas Fixed Cost Adjustment mechanisms were approved with an initial three year term, which expires December 31, 2018. Per the terms of the mechanisms, the Company may seek to extend the mechanisms prior to their expiration. While the Company would provide the baseline values for the mechanisms for 2019 in any compliance filing in this general rate case, Avista understands that it must receive Commission approval to continue the mechanisms in 2019 and beyond. Ehrbar, Di 24 Avista Corporation III. PROPOSED NATURAL GAS REVENUE INCREASE 1 Q. Would you please explain what is contained in 2 Schedule 4 of Exhibit No. 16? 3 A. Yes. Schedule 4 of Exhibit No. 16 is a copy of the Company’s present and proposed natural gas tariffs for 2018 and 2019, showing the changes (strikeout and underline) proposed in this filing. Q. Would you please describe what is contained in 8 Schedule 5 of Exhibit No. 16? A. Schedule 5 of Exhibit No. 16 contains the proposed (clean) natural gas tariff sheets for 2018 and 2019 incorporating the proposed changes included in this filing. Q. Would you please explain what is contained in 13 Schedule 6 of Exhibit No. 16? A. Schedule 6 of Exhibit No. 16 contains information regarding the proposed spread of the natural gas revenue increase among the service schedules and the proposed changes to the rates within the schedules. Page 1 shows the proposed general revenue and percentage increase by rate schedule. Page 2 shows the rates of return and the relative rates of return for each of the schedules before and after the proposed 2018 increase. Pages 3 and 4 show the present rates under each of the rate schedules, the proposed changes to the rates within the schedules, and the proposed rates after application of Ehrbar, Di 25 Avista Corporation the 2018 and 2019 rate changes. These pages will be referred to later in my testimony. 3 Summary of Natural Gas Rate Schedules and Tariffs 4 Q. Would you please review the Company's present rate 5 schedules and the types of natural gas service offered under 6 each? 7 A. Yes. The Company's present Schedules 101 and 111 offer firm sales service. Schedule 101 generally applies to residential and small commercial customers who use less than 200 therms/month. Schedule 111 is generally for customers who consistently use over 200 therms/month and Schedule 131 provides interruptible sales service to customers whose annual requirements exceed 250,000 therms. Schedule 146 provides transportation/distribution service for customer- owned natural gas for customers whose annual requirements exceed 250,000 therms. Q. The Company also has rate Schedules 112 and 132 on 18 file with the Commission. Would you please explain which 19 customers are eligible for service under these schedules? A. Yes. Schedules 112 and 132 are in place to provide service to customers who at one time were provided service under Transportation Service Schedule 146. The rates under these schedules are the same as those under Schedules 111 and Ehrbar, Di 26 Avista Corporation Rate Schedule No. of Customers General Service Schedule 101 79,729 Large General Service Schedules 111/112 1,408 Interruptible Sales Service Schedules 131/132 0 Transportation Service Schedule 146 6 Table No. 7 - Customers by Service Schedule 131 respectively, except for the application of Temporary Gas Rate Adjustment Schedule 155. Schedule 155 is a temporary rate adjustment used to amortize the deferred natural gas costs approved by the Commission in the prior Purchased Gas Cost Adjustment (“PGA”) filing. Because of their size, transportation service customers are analyzed individually to determine their appropriate share of deferred natural gas costs. If those customers switch back to sales service, the Company continues to analyze those customers individually; otherwise, those customers would receive natural gas cost deferrals which are not due them; thus the need for Schedules 112 and 132. There is only one customer served under these schedules as of December 31, 2016. Q. How many customers does the Company serve under each 14 of its natural gas rate schedules in Idaho? 15 A. As of December 31, 2016, the Company provided service to the following number of customers under each of its schedules in Idaho: 23 24 Ehrbar, Di 27 Avista Corporation Table No. 8 - Proposed % Natural Gas Increase by Schedule - 2018 Increase in Increase in Rate Schedule Margin Rates Billing Rates General Service Schedule 101 9.8%6.6% Large General Service Schedules 111/112 4.1%2.2% Interrupt. Sales Service Schedules 131/132 0.0%0.0% Transportation Service Schedule 146* 8.8%9.2% Overall 8.8%5.7% * excludes commodity and interstate pipeline transportation costs Q. Is the Company proposing any changes to the present 1 rate structures within its natural gas service schedules? 2 A. No. The Company is not proposing any changes to the present rate structures within its natural gas schedules. 5 Proposed Rate Spread 6 Q. For 2018, what is the proposed natural gas revenue 7 increase, and how is the Company proposing to spread the 8 increase by rate schedule? A. For 2018, the proposed base revenue increase is $3,480,000, or 8.8% in base margin6 revenue (on a billed revenue basis, the increase is 5.7%). The proposed percentage increase by rate schedule is as follows: 20 6 Base margin revenue refers to the base revenue associated with the Company’s ownership and operation of its natural gas distribution operations. It is the revenue related to delivering natural gas to customers, and does not include the cost of natural gas, upstream third- party owned transportation, or the effect of other tariffs. Ehrbar, Di 28 Avista Corporation Q. Is the proposed billing percentage increase for 1 Transportation Schedule 146 comparable to the increase for the 2 other service schedules? 3 A. No. The proposed billing percentage increase for Transportation Schedule 146 is not comparable to the proposed increases for the other (sales) service schedules, as Schedule 146 revenue does not include an amount for the cost of natural gas or upstream pipeline transportation. Transportation customers acquire their own natural gas and pipeline transportation. Including an estimate of 35.0 cents per therm for the cost of natural gas and pipeline transportation, the proposed increase to Schedule 146 rates represents an average increase of 2.4% (2018) and 1.4% (2019) in those customers’ 13 total natural gas bill. Q. What information did the Company use to develop the 15 proposed spread of the overall 2018 increase to the various 16 rate schedules? A. The Company used the results of the cost of service study (sponsored by Company witness Mr. Miller) as a guide to spread the natural gas general increase. The spread of the proposed increase generally results in the rates of return for the various service schedules moving approximately one- third closer to the overall rate of return (unity). The relative rates of return before and after application of the Ehrbar, Di 29 Avista Corporation Present Proposed Relative Relative Rate Schedule ROR ROR General Service Schedule 101 0.86 0.91 Large General Service Schedules 111/112 1.71 1.45 Interruptible Sales Service Schedules 131/132 1.00 1.00 Transportation Service Schedule 146 1.17 1.10 Overall 1.00 1.00 Table No. 9 - Present & Proposed Relative Rates of Return proposed 2018 increase by schedule are as follows: Page 2 of Exhibit No. 16, Schedule 6 shows this information in more detail. Q. For 2019, what is the proposed natural gas revenue 10 increase, and how is the Company proposing to spread the 11 increase by rate schedule? 12 A. For 2019, the proposed base revenue increase is $2,137,000, or 5.0% in base margin revenue (on a billed revenue basis, the increase is 3.3%). The Company used a pro-rata allocation of the Company’s 16 2018 natural gas rate spread percentages for purposes of spreading the proposed 2019 natural gas revenue increase to its natural gas service schedules. Below is a table showing the effect of the Company’s 2019 proposed natural gas increase by rate schedule: Ehrbar, Di 30 Avista Corporation Table No. 10 - Proposed % Natural Gas Increase by Schedule - 2019 Increase in Increase in Rate Schedule Margin Rates Billing Rates General Service Schedule 101 5.5%3.8% Large General Service Schedules 111/112 2.4%1.3% Interrupt. Sales Service Schedules 131/132 0.0%0.0% Transportation Service Schedule 146* 4.8%5.0% Overall 5.0%3.3% * excludes commodity and interstate pipeline transportation costs This information is also shown on page 1 of Exhibit No. 16, Schedule 6. 10 Proposed Rate Design 11 Q. Would you please explain the present rate design 12 within each of the Company’s present natural gas service 13 schedules? A. Yes. General Service Schedule 101 generally applies to residential and small commercial customers who use less than 200 therms/month. The schedule contains a single rate per therm for all natural gas usage and a monthly customer/basic charge. Large General Service Schedule 111 has a four-tier declining-block rate structure and is generally for customers who consistently use over 200 therms/month, such as schools, restaurants, and office buildings. The schedule consists of a monthly minimum charge plus a usage charge for the first Ehrbar, Di 31 Avista Corporation 200 therms or less, and block rates for 201-1,000 therms/month, 1001-10,000 therms/month and usage over 10,000 therms/month. Interruptible Sales Service Schedule 131 contains a single rate per therm for all natural gas usage. The schedule also has an annual minimum (deficiency) charge based on a usage requirement of 250,000 therms per year. As required by tariff, customers served on this schedule are required to have standby facilities with an alternate fuel. Transportation Service Schedule 146 contains a $225 per month customer charge and contains a single rate per therm for all natural gas usage. The schedule also has an annual minimum (deficiency) charge based on a usage requirement of 250,000 therms per year. Q. Where in your Exhibit No. 16 do you show the present 15 and proposed rates for the Company’s natural gas service 16 schedules? A. Pages 3 and 4 of Schedule 6 shows the present and proposed rates under each of the rate schedules, including all present rate adjustments (adders) for the 2018 and 2019 rate changes. Column (e) on those pages show the proposed changes to the rates contained in each of the schedules. Q. How does the Company propose to spread Schedule 23 101’s proposed 2018 general revenue increase of $3,166,000 to 24 Ehrbar, Di 32 Avista Corporation the rates within that schedule? 1 A. The Company proposes to increase the monthly customer charge from $5.25 per month to $6.00 per month. The remaining revenue is proposed to be recovered through an increase of 4.293 cents per therm. This is shown in column (e), page 3, Schedule 6 of Exhibit No. 16. Q. How does the Company propose to spread Schedule 7 101’s proposed 2019 general revenue increase of $1,945,000 to 8 the rates within that schedule? 9 A. The Company proposes to keep the monthly customer charge at $6.00 per month. The revenue increase for the schedule would be recovered through a 6.5% increase in the volumetric energy rate. This is shown in column (e), page 4, Schedule 6 of Exhibit No. 16. Q. For 2018, what is the proposed monthly increase for 15 a residential natural gas customer with average usage? 16 A. The increase for a residential customer using an average of 61 therms of natural gas per month would be $3.37 per month, or 6.6%. A bill for 61 therms per month would increase from the present level of $51.10 to a proposed level of $54.47. Q. For 2019, what is the proposed monthly increase for 22 a residential natural gas customer with average usage? 23 A. The increase for a residential customer using an Ehrbar, Di 33 Avista Corporation average of 61 therms of natural gas per month would be $2.07 per month, or 3.8%, resulting in an overall bill of $56.54, including all rate adjustments. 3 Q. Would you please explain the proposed changes in the 4 rates for Large General Service Schedules 111? 5 A. Yes. The present rates for Schedules 101 and 111 provide guidance for customer placement: customers who generally use less than 200 therms/month should be placed on Schedule 101, customers who consistently use over 200 therms per month should be placed on Schedule 111. Not only do the rates provide guidance for customer schedule placement, they provide a reasonable classification of customers for analyzing the costs of providing service. The proposed 2018 increase to the minimum charge for Schedule 111 (for 200 therms or less) of $9.34 per month is a function of the basic charge increase under Schedule 101 as well as the change in the Schedule 101 variable rate. This methodology maintains the present relationship between the schedules, and will minimize customer shifting. The remaining revenue requirement for the schedule is proposed to be recovered through a uniform percentage increase of approximately 2.4% to blocks 2, 3 and 4. The proposed 2019 increase to the Schedule 111 minimum charge for Schedule 111 (for 200 therms or less) is $6.79 per Ehrbar, Di 34 Avista Corporation month. The remaining revenue requirement for the schedule is proposed to be recovered through a uniform percentage increase of approximately 1.1% to blocks 2, 3 and 4. Q. Did the Company propose a revenue increase for 4 Schedules 131/132? 5 A. No customers are presently served on these schedules. However, given that customers could decide to take service on these schedules in the future, the Company does propose to increase the volumetric rates for this schedule by the same overall percentage increases proposed for 2018 and 2019. Proposing to increase the base rates for these schedules will better reflect cost of service should customers decide to choose these rate schedules in the future. Q. How is the Company proposing to spread the proposed 14 2018 increase of $35,000 to the rates under Transportation 15 Schedule 146? 16 A. The Company is proposing to increase monthly Basic Charge from $225 per month to $250 per month. The remaining revenue requirement would be recovered through an increase of 1.111 cents to the per-therm rate. Q. How is the Company proposing to spread the proposed 21 2019 increase of $21,000 to the rates under Transportation 22 Schedule 146? 23 A. The Company is proposing to increase the per therm Ehrbar, Di 35 Avista Corporation charge under the schedule by 0.691 cents per therm. Q. Is the Company proposing any other changes to its 2 natural gas service schedules? 3 A. No, it is not. 4 Q. Turning now to the Company’s Natural Gas Fixed Cost 5 Adjustment Mechanism, how will new baseline information be 6 incorporated into the mechanism? A. As in the prior general rate case, the Company would, as a part of its Compliance Filing, submit the final baseline values for its Fixed Cost Adjustment Mechanism (for both 2018 and 2019) prior to new rates going into effect as a result of this general rate case.7 Q. Does this conclude your pre-filed, direct 13 testimony? 14 A. Yes, it does. 7 The Company’s Electric and Natural Gas Fixed Cost Adjustment mechanisms were approved with an initial three year term, which expires December 31, 2018. Per the terms of the mechanisms, the Company may seek to extend the mechanisms prior to their expiration. While the Company would provide the baseline values for the mechanisms for 2019 in any compliance filing in this general rate case, Avista understands that it must receive Commission approval to continue the mechanisms in 2019 and beyond.