20191101Andrews Direct.pdf

Avista Corp.
14l l East Mission P-O. Box 3727
Spokane. Washington 992204500
Telephone [phone]
Toll Free 800-727-9170
RECEIVED
lllgHOY-l Altll: l5 frinstt
Corp.
FILED ELECTRONICALLY AND VIA OVERNICHT MAIL
October 31, 2019
Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
Re Case No. AVU-E-I9-04
Testimony in Support of Stipulation and Settlement
Enclosed for filing with the Commission in the above-referenced docket are the original
and nine copies of the Company's direct Testimony in Support of Stipulation and
Settlement of witnesses Ms. Andrews and Mr. Miller. Please direct any questions related
to this filing to Liz Andrews at 509.495.8601.
Sincerely,
J. Meyer
Vice President, Chief Counsel lbr Regulatory
& Govemmental Affairs
Enclosures
cc: Service List
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 31ft day of October,20l9, served the Direct Testimony in
Support of the Settlement and Stipulation in Case No. AVU-E-19-04, by electronic transmission
to the email address(es) or by mailing a true and corect copy, postage prepaid, to each party or
party representative listed below.
Diane Hanian, Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd
Building 8, Suite 201 -A
Boise, ID 83714
[e-mail]
John Hammond
Deputy Attomeys General
Idaho Public Utilities Commission
I 133 I W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
Peter J. Richardson
Greg M. Adams
Richardson Adams
515 N. 27s Street
PO Box 721 8
Boise, ID 83702
[e-mail] nuc.idaho.sov
[e-mail]
Ronald L. Williams
Williams Bradbury, P.C.
P. O. Box 388
802 W. Bannock, Suite LP 100
Boise, ID 83702
ron@rvil liamsbradbun,.com
Benjamin J. Otto
Idaho Conservation League
7l0N.6th st.
Boise, ID 83702
botto@ idahoconservation.orq
Vicki M Baldwin
Parsons Behle & Latimer
Walmart, Inc.
201 S. Main Street, Suite 1800
Salt Lake City, Utah 841 I l
v ba I dw i n (d parson beh I e. com
stepth.ch ri ss(rlwal nrart.com
.-2
Paul Kimball
Manager of Compliance & Discovery
Larry Crowley
The Energy Strategies Institute, Inc.
3738 S. Hanis Ranch Ave.
Boise, ID 83716
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
dreadin g(Dm indsoring.com
Brad M. Purdy
Attomey at Law
2019 N I 7th Street
Boise, ID 83702
[e-mail]
F.ECEIVED
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COL]NSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220.37 27
TELEPHONE: [phone]FACSIMILE: [phone]
[e-mail]
" "rt^'r-l lt!ll. Iriit'.-l | ,llll'I
C
$s
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CI]ARGES FOR DLECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE
STATE OF IDAI{O
)
)
)
)
)
)
CASE NO. AVU-E.I9-04
DIRECT TESTIMONY
OF ELIZABETH M ANDREWS
IN SUPPORT OF
STIPULATION
FOR AVISTA CORPORATION
(ELECTRIC)
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Avista Corporation
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I. INTRODUCTION
a. Please state your name, employer and business address.
A. My name is Elizabeth M. Andrews and I am employed by Avista
Corporation ("Company" or "Avista") as Senior Manager of Revenue Requirements
in the State and Federal Regulation Department, at l4l I East Mission Avenue,
Spokane, Washington.
O. Have you previously provided direct testimony in this Case?
A. Yes. My previous direct testimony in this proceeding covered
accounting and financial data in support of the Company's need for the proposed
electric increase effective January l, 2020. I explained pro formed operating results
including expense and rate base adjustments made to actual operating results and
rate base lor the 2020 rate period.
a. What is the scope of this testimony?
A. The purpose of this testimony is to describe and support the electric
revenue requirement elements of the Stipulation and Settlement ("Stipulation") filed
on October 11,2019, as well as explain why the Stipulation is in the public interest.
The parties to the Stipulation include the Stafl of the Idaho Public Utilities
Commission ("Staff'), Clearwater Paper Corporation ("Clearwater"), Idaho Forest
Group, LLC ("ldaho Forest"), the Community Action Partnership Association of
Idaho, Inc. ("CAPAI"), the Idaho Conservation League ("lCL"), and Walmart, Inc,
("Walmart"). These entities are collectively referred to as the "Parties" and
singularly as a "Party", and represent all who have appeared in these proceedings.
AII Parties to this case are in support of this Settlement.
I Company witness Mr. Miller discusses the non-revenue related elements ol
the Stipulation agreed to by the Parties, such as electric Cost of Service, Rate Spread
and Rate Design, as well as other Stipulation components related to the Power Cost
Adjustment (PCA) and Fixed Cost Adjustment Mechanism authorized levels and
customer service-related initiatives and programs.
a. Are you sponsoring any exhibits?
A. Yes. I am sponsoring Exhibit No. 13, which is a copy of the
Stipulation and Settlement filed on October 11,2019, with the Commission.
a. Did the Company submit a corrected page to the Stipulation?
A. Yes, on October 25,2019, the Company filed a revised page 9 to the
Stipulation that removed an inadvertent reference to "natural gas" at paragraph 11. At
the same time, it filed certain appendices that were previously agreed-upon by the
Parties and referenced in the Stipulation, but never actually filed. No party to the
Stipulation objected to the filing of this revision or the provision of missing
appendices. The error was on the part of the Company, and we apologize. Exhibit
No. 13 includes the revised page 9 to the Stipulation, as well as the required
appendices (Appendices A - C).
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l9 II. SUMMARY OF ORICINAL FILING
20 a. Please describe the Company's general rate case request, as filcd,
A. On June ,l0,2019, Avista filed an Application with the Commission
lbr authority to increase revenue effective January 1,2020, lor electric service in
Idaho. The Company proposed an increase in electric base revenue of$5.255 million
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Avista Corporation
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or z.lYo for 2020. By Order No. 34368, dated July l, 2019, the Commission
suspended the proposed schedules ofrates and charges for electric service. By Order
No. 34368, dated July 1,2019, the Commission suspended the proposed schedules of
rates and charges for electric service.
The Company used the results of the electric cost ofservice study (sponsored
by Ms. Knox) as a guide to spread the general increase. The spread of the proposed
increase generally resulted in the rates of retum for the various electric service
schedules moving 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 tempered the amount of movement toward unity proposed in this case due
primarily to the impact such movement would have between the rate schedules.
a. What are the primary factors driving the Company's need for an
electric change in rates?
A. The primary factor driving the Company's electric revenue
requirements proposed change in 2020 is an increase in net plant investment
(including retum on investmenl, depreciation and taxes, and offset by the tax benefit
of interest) from that currently authorized. In addition, net power supply expense is
reduced from that currently authorized level, offsetting the Company's overall
increase as originally requested.
Electric specific capital investments for the 2019 period include, among other
things, upgrades to certain major generating facilities, such as the Little Falls
Powerhouse Redevelopment, Noxon Rapids HED Spillgate Refurbishment, as well
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Avista Corporation
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as capital investment associated with the Clark Fork and Spokane River License
agreements, discussed by Company witness Mr. Thackston.
For power supply, as discussed by Company witness Mr. Kalich, the level of
Idaho's share of power supply expense for rate year 2020 pro formed into this case
has decreased by approximately $3.8 million ($11 million on a system basis), from
the level currently included in base rates.
III. SUMMARY OF SET'ILEMENT STIPULATION
a. Would you briefly summarize the Stipulation?
A. Yes. Under the terms of the Stipulation, as discussed further by Mr.
Miller, Avista would implement revised tariff schedules designed to reduce annual
electric revenues by $7.188 million or 2.8% (billed basis is also a decrease of 2.8%),
effective December l, 2019. This rate changes is designed to provide retail revenues
necessary to allow the Company the opportunity to eam the rate ofretum agreed to in
the Stipulation lor the 2020 rate period.
As noted by Mr. Miller, a residential customer using an average of 900
kilowatt hours per month would see a $0.86, or l.lVo, decrease per month for a
revised monthly bill of $84.45. (See also Exhibit No. 13, Paragraph 14, for the
December 1,2019 electric percentage changes in rates by rate schedule.)
In determining this revenue decrease, the Parties have agreed to various
adjustments to the Company's original filing, which are summarized in the
Stipulation, and described further in the testimony below.
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Avista Corporation
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The Stipulation calls for an overall rate of retum of 7 .35%, determined using
a capital structure consisting of 5070 common stock equity and 50% debt, an
authorized retum on equity of 9.5% and cost oldebt of 5.20%o.
Lastly, the Parties agreed to certain rate spread and rate design changes as
described by Mr. Miller in his supporting testimony as well as customer service-
related initiatives and programs.
a. Please explain how the Parties arrived at the Stipulation in this
proceeding.
A. The Stipulation is the product of settlement discussions held in the
Commission offices on October 1,2019. It represents a compromise among differing
points of view, with concessions made by the Parties, to reach a balancing of
interests. As will be explained in the Company's testimony, the Stipulation
represents a fair, just and reasonable compromise of the issues and is in the public
interest. In addition, the Stipulation is the end result ol extensive audit work
conducted through the discovery processr, including various on-site audit visits by
Commission Staff, and hard bargaining by the Parties in this proceeding.
The Stipulation resolves all issues among the Parties associated with the
calculation of the Company's requested cost of capital, including capital structure
and cost components, and resolves all revenue requirement issues. As discussed by
Mr. Miller, the Stipulation also includes agreement regarding certain rate spread and
rate design as well as well as other Stipulation components related to the Power Cost
I Avista responded to over 194 production and audit requests (including sub-parts) from IPUC Staff
and other interuening parties.
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III. ELECTRIC REVENUE REOUIREMENT ELEMENTS
OF THN, STIPULATION
a. Please explain the derivation of the Electric Revenue Requirement
outlined in the Stipulation.
A. The Parties agreed that an electric revenue decrease is necessary,
effective December 1, 2019, While Avista's filing requested an electric revenue
requirement increase of $5.3 million eff'ective January l, 2020, the Parties agreed-
upon adjustments, including the agreed-upon rate of retum, result in recommended
electric revenue decrease of $7.2 million. This decrease is designed to provide
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Avista Corporation
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Adjustment (PCA) and Fixed Cost Adjustment Mechanism authorized levels and
customer service-related initiatives and programs.
a. Why is the Stipulation in the public interest?
A. The Stipulation is in the "public interest" for several reasons. The
Stipulation was the product of the give-and+ake of negotiation that produced an
"end result" that is just and reasonable. In addition, it is supported by the evidence,
demonstrating the need for rate adjustments to provide recovery of necessary
expenditures and investment, the costs of which are not offset by a growth in sales
margins. The Settlement enjoys broad-based support liom a variety of
constituencies, including CAPAI, Clearwater, Idaho Forest Group, Walmart, Inc.
and the Staff ofthe Commission.
In addition, the Settlement provides a base rate reduction by December l,
2019, which would benefit all customers, as they plan and budget for their 2019-
2020 winter heating season needs.
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sufficient retail revenues for the 2020 rate period, and would provide the Company
with the opporflrnity to eam the retum agreed to in the Stipulation.
a. Please explain the Parties' agreement with regard to an
Authorized Rate of Return, including the Return on Equity.
A. The Parties have agreed to an overall rate of retum of 7.35%, based on
a retum on equity of 9.5%, an equity component at 50%o and cost of debt of 5.20o/o.
By comparison, the Company's original filing requested an overall rate of return of
7 .55Vo, a retum on equity of 9.9%, an equity component of 50% and cost of debt of
s.20%.
a, Please provide an overview of the electric revenue requirement
adjustments agreed to by the Parties for rates effective December 1,2019.
A. The Parties agreed to an electric revenue requirement effective
December 1,2019, that reflects the adjustments shown below in the excerpted table
from the Stipulation:
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a.)
b.)
c.)
c.)
h.)
i.)
j.)
k.)
r.)
m.)
SUMMARY TABLE OF ADJUSTMENTS TO ELECTRIC REITNUE REQUIREMENT
EFFECTIVE DECEMBER I, 20I9
(000s of Dollan)
Revenue
Requir€ment Rate Base
Amount as Filed:
Adjustments:
Cost of Capital
Company 2019 Net Rate Base UpJates
l\'!isccllaneous Company Updatcs: Reduce Prope(y Taxes,
Cobtrip/C52 Ma_ix Maintenance Expense, Colstrip Regulatory
Amonization and remove non-recuring AFUDC DFIT Experse.
Removc Officer lncentives and Reduce Non-Olllcers Incentives
Reducc Officer labor Expenses
Adjust Employcc Benelns
Removc Ccrtain 2019 Capital Projects
Rcvisc Fce Freg Amortization and Annual Hxpense
Reslate trncollcctibles
Wcathcr N onnaliration Adjustment
Update Net Pro Forma Porvcr Supply Expcnsc and Tmnsmission
I{evenucs
Update Pro Forma Cas Prices
Include Palouse and Rsttlesnake Wind PPA Contracls in PCA
Revise Transmission Rcvenucs
Rcmovc 2020 Expense
2020 Non-tlnion Labor Incrcasc
2020 Remove MT 2020 lixpense
Misccllaneous Adjustments: Rechssifration of non-utifry flights
and fl\cd costs. as well as expired leasc experlse ass@iated with
thc airphne; rechssification of othcr administratile and gcneral
expcnscs; adjust intervenor funding and an agreed upon overal
cxpcnse adjustment to rerlect lev€l ofapproved expenses
Adjust€d Amounts Effective December 1,2019
5,255 $ 836,820
(7,7r3)
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
(2.2r)
(3r7) $
(eeo) $
( r 2ee)
(58)
d.)
e.)
f.)
(438)
(32J
86
(1,215) $
(370)
( t63)
(2871
i.)
ii.)
iii.)
i.)
ii.)
( 1,620)
(4,288)
(520)
(2',74)
(255)
451
s (7,188) $ 827,7s0
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l7 As can be seen by a review ofthe individual line descriptions provided within
the summary table above, the adjustments accepted for settlement purposes cover a
broad range of revenue and cost categories, including the authorized rate of retum.
The individual adjustments should not be viewed in isolation; rather, they should be
viewed in total as part of the entire Stipulation, and are the result of hard bargaining
and compromise.
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Table No. l: Electric Revenue Requirement
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0. Would you please elaborate on the individual line items contained
2 within Table No. I ?
A. Yes. A description ofthe adjustments resulting in the electric revenue
requirement, effective December 1, 201 9, follows.
Cost of Canital -(line a.) The overall revenue requirement reduction related
to the cost of capital reduces the overall revenue requirement for electric by $2.211
million. The agreed-upon cost ofcapital components are shown in the table below:
Compone nt
Capital
Structure Cost
Wcighted
Cost
Debt
Corrrnn Equity
Total
s0.00%
50.00%
2.60%
4.75%
100.00%7 .3504
Company 2019 Net Rate Base Updates -(line b.)'l'he 2019 filed electric
capital additions were updated by Avista to reflect adjustments for updated
information, including related depreciation expense, accumulated depreciation (A/D)
and accumulated deferred federal income taxes (ADFIT) associated with these
adjustments to reflect balances as ofDecember 31,2019. This adjustment resulted in
an overall reduction to rate base of $1.299 million, and a decreased revenue
requirement of $3 I 7,000.
Miscellaneous Company Updates - (line c.) This adjustment Reflects
adjustments for updated information, including: removal ol certain 201 8 AFUDC
DFIT2 expense as non-recurring, major maintenance expense associated with the
Company's Colstrip generation plant, property taxes, and conection of DFIT within
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2 Allowance for Funds Used Under Construction C'AFUDC"); Defened Federal Income Taxes
C'DFIT)
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the Colstrip regulatory amortization adjustment3. This adjustment decreases the
overall revenue requirement by $990,000 and reduces net rate base by $58,000.
Remove Ofllcer Incentives and Reduce Non-Officer Incentives - (line d.)
This adjustment reflects the removal of all officer incentives. This adjustment also
reduces incentives for non-officers to 2018 target versus the Company's 6-year
average. This adjustment decreases the overall revenue requirement by $438,000.
Reduce Olficer Labor Expenses -(line e.) This adjustment reduces officer
labor expenses to 2018 test period levels allocated 90% utility / l0% non-utility.
This adjustment decreases the overall revenue requirement by $32,000.
lJpdate Pension and Medical Exrrenses -(line f.) This adjustment Rel'lects
updated information related to incremental pension and medical expenses in 2019,
and includes 401K expense based on 2018 test period levels adjusted for 370 labor
increases. This adjustment increases the overall revenue requirement by $86,000.
Remove 2019 Canital Additions -(line g.) This adjustment removes capital
investments related to: l) Digital Crid Network project; 2) Rattlesnake Flats
Interconnection and Transmission/Substation projects; 3) Distribution asset project
(Metro Line); 4) IS/IT Mobile Application and Customer Facing Technology
projects; and 5) Transmission/Substation upgrade project, all originally planned for
2019.1 The projects have been removed for review in the Company's next general
r The Parties otherwise accept the Colst p Regulatory Amortization adjustment as filed by the
Company, inc)uding approval of the Colstrip capital additions included in the Regulatory Asset
through 2019, The resulting regulatory amortization beginning December l, 2019 totals $863,000
annually.{ Each ofthe identified projects were described in the direct testimonies ofCompany witnesses Ms,
Rosentrater and Mr. Kensok.
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rate case due to timing of completion of projects. This adjustment decreases the
overall revenue requirement by $1,215,000 and reduces net rate base by $7,713,000.
Revise Fee Free Amortization and Annual Expense -(line h.) This
adjustment adjusts the annual Fee Free5 expense to approximately $311,000 and Fee
Free deferral balance to approximately $696,000, to reflect actual amounts through
April 2019 and estimated balances for the remainder of the year. This adjustment
also revises the amortization expense of the Fee Free deferral balance ($696,000) to
rellect a three-year amortization beginning December 1, 2019 of $232,000. This
adjustment decreases the overall revenue requirement by $370,000.6
Restate Uncollectibles -(line i.) This adjustment restates uncollectible
expense based on the 12 month actual expense balance as of June of 2019. This
adjustment decreases the overall revenue requirement by $163,000.
Weather Normalization Adiustment -(line j.) This adjustment reflects higher
normalized load revenues net of power supply expense from that included in the
Company's original filing. This adjustment decreases the overall revenue
requirement by $287,000.
Power Supply and Transmission Related Net Expenses - Update Net Pro
l8 Forma Power Supply Expense and Transmission Revenues -(line k.)
l9 Undate Pro Forma Gas Prices -(line i.) This adjustment restates pro
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5 The Fee Free program allows customers to make payments by credit or debit card without paying a
service fee. This program was approved in Commission Order No. 33494, case Nos. AVU-E-16-01
and AVU-G- l6-01 and implemented in February 2017.
6 The Company will update the defenal balance in its next general rate case to reflect actual
expenses defened through November 2019 and true-up any remaining amounts to amortize up or
down for the remainder ofthe three-year amortization.
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forward prices for January 2020 through December 2020 contract
months based on the most recent one-month settlement period for the
transactions. This adjustment decreases the overall revenue
requirement by $ 1,620,000.
Include Palouse Wind and Rattlesnake Flats Wind PPAs in PCA -
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(line ii.) This adjustment reflects the removal of the Palouse Wind and
Rattlesnake Wind Power Purchase Agreements ('PPA) net expenses
from base power supply expense. This adjustment decreases the
overall revenue requirement by $4,288,000. See further discussion at
Exhibit No. I 3, Paragraphs 8 (Palouse) and 9 (Rattlesnake) for further
information.lt
t2 Revise Transmission RevenuEs -(line iii.) This adjustment revises
l3 2018 actual transmission revenues to reflect a three year prior average
for each month of November and December, to normalize those
months to remove the impact of the October 2018 Enbridge pipeline
rupture on Company transmission revenues. This adjustment
decreases the overall revenue requirement by $520,000. The resulting
annual transmission revenues will also be reflected in the PCA
authorized base effective December I , 2019.
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20 Remove 2020 Expense - (line l.)
21 2020 Labor lncrease - (line i.) This adjustment removes the 2020
incremental non-executive, non-union labor increases. 2020 union
labor increases, however were included based on union contract
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I increases for 2020. This adjustment decreases the overall revenue
requirement by $274,000.
Reduce 2020 I S/lT Expenses -(line ii.) This adjustment reduces 2020
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IS/IT expense included by the Company by 50%. Incremental IS/IT
expense included lor 2020 reflect actual contractual obligations. This
adjustment decreases the overall revenue requirement by $255,000.
Miscellaneous Adiustments - (line m.) This adjustment rellects the net
change in operating expenses related to: 1) reclassification of non-utility flights and
fixed costs, as well as expired lease expense associated with the ailplane ($93,000);
2) amortization of 2018 intervenor funding over two-year period ($20,000); 3)
removal of miscellaneous A&G expenses (accounts 912, 921, and 923, totaling
$36,000); and 4) an agreed upon increase to overall expense to reflect a level of
approved expenses ($600,000). The net effect of this adj ustment increases the
overall revenue requirement by $451,000.
a. Please summarize the impact of these adjustments on the electric
revenue requirement agreed to by the Parties effective December l,2019.
A. The adjustments discussed above, and agreed to by the Parties, reduce
Avista's proposed 2020 rate year electric revenue requirement increase of $5.255
million to an electric revenue requirement reduction of $7.188 million, resulting in a
2.840/o electric base rate decrease (on a billed basis the decrease is 2.80%), eftbctive
December 1,2019. The net rate base agreed to by the Parties lor electric services is
$827.8 million.
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I V. CONCLUSION
a. In conclusion, why is this Stipulation in the public interest?
A. This Stipulation strikes a reasonable balance between the interests of
the Company and its customers, including its low-income customers. As such, it
represents a reasonable compromise among differing interests and points of view.
The terms ofthe Stipulation represent an electric base rate decrease, but will
still provide necessary retail revenues for t}re rate-effective period beginning
December l, 2019. The Parties have agreed that the Company has demonstrated the
need for the revenue decrease for its electric operations.
In the final analysis, any seftlement reflects a compromise in the give-and-
take of negotiations. The Commission has before it a Stipulation that is supported by
sound analysis and supporting evidence, the approval of which is in the public
interest.
a. Does this conclude your direct testimony?
A. Yes, it does.
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