20200113Reply Comments.pdf

Avirta Corp.
14l I East Mission P.O. Box 3727
Spokane. Washingon 99220-0500
Telephone 5094E9-0500
Toll Free 800-727-9170
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January 13,2020
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
ll33l WChindenBlvd.
Boise, ID 83714
Re: Avista Application No. AVU-E-I9-12
Dear Ms. Ilanian:
Avista Corporation, doing business as Avista Utilities (hereinafter Avista or Company),
respectfully submits the attached "Reply Comments" in response to the Idaho Conservation
Leagues comments filed on January 7,2020. Please direct any questions on this matter to myself
at(509) 495-4975.
Sincerely,
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Scnior Manager, Regulatory Policy & Strategy
Avista Utilities
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I DAVID J. MEYER2 VICE PRESIDEN'I'AND CHIEF COUNSEL FOR
3 REGULATORY AND GOVERNMENTAL AFFAIRS
4 AVIS'I'A CORPORATIONs P.o. BOX37276 I41I EAST MISSION AVENUE7 SPOKANE, WASHINGTON 99220.3'1278 TELEPHONE: [phone]
9 [e-mail]
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lt BIiFORE TI{E IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTEROF THE APPLICATION )
OF AVISTA CORPORATION R-EQUESTING )
TO MODII,'Y SCHEDULE 95 TO REVISE )
THE COMPANY'S VOLLTNTARY )RENEWABLEENERGYPROGRAM )
CASE NO. AVU-E-19-I2
REPLY COMMEN'TS OF
AVISTA CORPORATION
19 Avista Corporation ("Avista" or "Company'') hereby submits reply comments in response
20 to the ldaho Conservation League ("lCL") commenls dated January 7,2020, on the Company's
2l request to modify its voluntaxy renewable energy program ("Program"), Schedule 95 "Optional
22 Renewable Power Rate" in an effort to effectively manage costs, provide customers with greater
23 choice, and to support renewable energy within our region.
24 The Company notcs that sevcral of the issues raised by the ICL were regarding Avista's
25 energy mix which are directly related to the Company's Integratcd Resource Planning (lRP)
26 process and are separate and distinct from the Company's Schedule 95 filing. Therefore, the
27 Company will not be addressing those issues in these reply comments. The Company appreciates
28 the review of Avista's proposed revision by ICL. The Company initiated a conference call with
29 ICL on Friday, January 10, 2020 to discuss their comments and will continue to work with ICL to
30 address their concems related to Avista's fuel mix and how it is presented to Idaho customers.
AVISTA REPLY COMMENTS PAGE I
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First, ICL would like Avista to "simply state to its Idaho customers the percent of elechicity
they receive that comes from fossil fuels and the percent that comes from renewable resources."
Avista, per Commission rule,l already provides on an arurual basis its fuel mix which can
be found on the Avista webpage: htlos://mvavista.com/about-uVour-conroanv/about-our-eneruv-
mix, and a reference to the percent ofelectricity that comes from renewable resources can be found
on the Programs webpage : https://www.myavista.cetn/encrqy-savings/Rreen-optittlrs/rny-clean-
7 enerqy.
8 Avista believes this level ofdetail is sufficient for customers to enroll in the Program. The
9 intent ofthe value calculator is to help customers understand and translate abstract measuremcnts
10 into relatable terms, such as the annual emissions from cars, households, or carbon dioxide
I 1 avoided. 'lhe calculator leverages the EPA's greenhouse gas equivalencies calculator to determine
12 the level emissions avoided by the customer's participation in the Program.
l3 Sccond, ICL requested that Avista "source its Regional Blocks with a preference for RECs
l4 sourced fiom Idaho. We also request that whatever Regional Blocks cannot be sourced from Idaho
15 be sourced from the Northwest Region of the United States, excluding California and British
l6 Columbia."
l'l Avista's process tbr purchasing RECs has been to obtain RECs that satisfy the locational
l8 and generation requirements set forth in the Company's tarift and the then evaluate the cost in
19 order to offer the Program participants the greatest value lbr their subscription dollars. RECs are
20 purchased for the entire Program, not sepaxatcly for Idaho and Washington. This provides Avista
2l the ability to source the lowest cost resources within these confines. In order to provide the
22 participants the most value, it is the Company's intent to continue purchasing RECs in this manner.
I IDAPA 31.8 | .01 - Energy Consumption Reponing Rules
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AVISTA RIJPLY COMMEN'|S PAGI] 2
I Third, ICL stated that they "would be interested to leam more about and to comment on
2 Avista's specific proposals for modifring the language it uses to describe and markel the
3 Program."
4 Avista has an interest in deriving maximum value out of this Program on behalf of all
5 customer participants. Prior to proposing any revisions, Avista conducted customer interviews,
6 surveys and usability studies with current Program participants as well as customers who are not
7 currently participating, in order to assess and inform the Company's communications and
8 outreach.
9 Finally, ICL requested that "Avista indicate the total amount of funding it has awarded in
10 solar grants from the Program's surplus funds, since 2002, to Idaho-based projects as compared to
I I Washington State-based projects. We also request Avista explain the process by which it
12 determines how much of the surplus funding Avista's Idaho service territory is entitled to as
I 3 oompared to Avista's Washington service territory."
14 Avista has awarded $346,722.80 in grants, $60,81 I .80 of which were awarded to Idaho
15 projects. Minimum Program eligibility criteria for grant recipients include new installations on
l6 non-residential building sites with a preference given to educational institutions and./or non-profit
17 buildings in Avista's electric service terrilory. ln addition to the minimum criteria, Avista at its
l8 sole discretion, evaluates applications based on: project feasibility and readiness, installation cost
19 and financing, geographic distribution throughout Avista's service territory, community exposure,
20 and educational benefits. Customers may apply for a grant to cover all or a portion of the cost of
2l the project and must meet the criteria outlined in the Company's tariff.
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AVISTA REPLY COMMENTS PAGE 3
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The Company apprcciates the opportunity to respond to the comments filed by ICL in this
casc.
DATED at Spokane, Washington" this 13th day ofJanuary, 2020.
AVISTA CORPORATION
{By
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David J. Meyer,
Vice President and Chief Counsel of
Regulatory & Goverrunental Affairs
AVISTA REPLY COMMENTS PAGE 4