20200302Final_Order_No_34566.pdf

Office of the Secretary
Service Date
March 2,2020
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.AVU-E-19-12
OF AVISTA CORPORATION REQUESTING )
TO MODIFY SCHEDULE 95 TO REVISE THE )COMPANY'S VOLUNTARY RENEWABLE )ORDER NO.34566
ENERGY PROGRAM )
On November 12,2019,Avista Corporation dba Avista Utilities ("Avista"or
"Company")applied for approval to modify its voluntaryrenewable energy program ("Program"),
Schedule 95 "Optional Renewable Power Rate."The Company requested its Application be
reviewed under Modified Procedure and that the Program modifications become effective on
January 1,2020.Application at 7.
On December 16,2019,the Commission issued its Notice of Application,Notice of
Modified Procedure and Order.See Order No 34505.The Commission also suspended the
Company's proposed effective date for the modified Program.Id.at 4.The Commission Staff
("Staff')and the Idaho Conservation League ("ICL")filed written comments on January 6 and 7,
2020,respectively.Avista submitted reply comments on January 13,2020.
Having reviewed the record,the Commission enters this Order approving the
Company's Application.
THE APPLICATION
Avista seeks to modify the Program so it can effectively manage costs,provide
customers with greater choice,and support renewable energy within its region.Application at 1.
Starting in 2002,Avista began offering its electric customers the opportunity to voluntarilysupport
renewable energy development by participating in the Company's "Buck-a-Block"option under
Tariff Schedule 95 "Optional Wind Power Rate."Id.at 2;see also Order No.28948.Avista
represents its wind power option was priced in $1 increments,or "blocks."Id.Each $1 block of
wind purchased by customers equaled 55 kilowatt-hours ("kWhs").Id.
In 2004,the Company modified the Program from an Optional "Wind"Power Rate to
an Optional "Renewable"Power Rate.Id.;see also Avista TariffAdvice No.04-02-E (approved
July 28,2004).The modified Program included the cost of renewableenergy certificates ("RECs")
associated with the renewable resource.Id.The RECs were primarily from wind power generated
ORDER NO.34566 1
at the Stateline Wind Energy Center,and could also come from other "green-e certified"
resources.'Id.The Program continued to include voluntaryparticipation in $1 block increments.
Id.However,the blocks were modified to represent 300 kWhs of renewable energy instead of 55
kWhs due to lower wholesale costs of wind power to Avista.Id.
In 2014,the Commission approved additional Program modifications that allowed
Avista to use surplus funds from it for grants that would provide funding for installing rooftop
solar generation on commercial buildings in the Company's service territories in Idaho and
Washington.Id.;see also Order No.33218 at 2.The Company represents it awarded $346,722.80
in grants to fund nine projects in Idaho and Washington.Id.at 3.
Avista states that,in 2019,it conducted customer research to better inform revisions to
the Program.2 Id.at 3.Avista states its customer feedback demonstrated:1)the Company's
customers are most likelyto participate in the Program instead of other possible offerings,and 2)
the information about the Program and what value it provides is not being communicated
effectivelyto customers.Id.Avista represents only one percent of its Idaho customers participate
in the Program.Id.Further,in recent years,the cost of RECs has increased while Program
participation has decreased to a point where the Program now only has about $38,000 in operating
reserves.Id at 4.The Company expressed the Program may not cover its costs if these trends
continue.Id.As a result,Avista believes it must educate customers on the Program's benefits.
Id.at 3.Further,Avista proposes to modify the Program to provide customers with additional
participation options that the Company hopes will provide for its sustainability.Id.at 5.Last,the
Company proposed to rename the Program "My Clean Energy."Id.
COMMENTS OF THE PARTIES
1.Staff Comments
According to Staff,Avista's customers can use the Program to reduce the
environmental impact of their electric power consumption by purchasing blocks of bundled RECs.
StaffComments at 3.However,Staff notes that Program participation has declined,and the price
of RECs has increased.Id.at 4-5.
I The Company represents the Green-e Renewable Electricity CertificationProgram is administered by the non-profit
Center for Resource Solutions based in San Francisco,California.See Application at 2,footnote 1;see also
httys;Uwww.green-e.org.
2 The Company asserts it conducted a residential customer research project in 2016 using the Shelton Group,and an
internal research project in 2019 regarding the Buck-a-Block program.See Applicationat 3,footnote 2.
ORDER NO.34566 2
Staff supports the Company's proposed modifications to the Program.Id.First,Staff
agrees the Company should provide additional participant education,outreach,and customer
choices to ensure the Program remains sustainable.Id.Second,Staff believes the two proposed
block purchase options and REC pricing are reasonable steps to increase customer choices for
Program participation.Id.The "National Blocks"purchase option would continue to let
participants buy 300 kWh blocks for $1 that are sourced from renewable generation throughout
the United States.Purchasing RECs throughout the United States throughthe National Blocks
option could provide more opportunities to buy RECs at the most competitive price.Id.The
"Regional Blocks"purchase option would be sourced with RECs from the northwest,but at smaller
100 kWh blocks for $1.Id.These purchase options would still fund solar grants in Idaho and
Washington when Program revenues exceed costs.Id.Staff notes that the Company will ask
participants to choose which block they wish to participate in.Those who do not respond will be
assigned to the National Blocks option.Id.Staff believes this is reasonable because it allows
current participants to buy blocks at their present Program rate and kWh selection.Id.Third,Staff
supports the Company's proposal to change the Program's name to "My Clean Energy."Id.
Staff believes the proposed 2020 Program budget is reasonable and includes surplus
funds that could support solar grants or cover higher costs for RECs or operating expenses if
necessary.Id.Staff notes the Company files an annual report with the Commission that should
disclose the Program's results in February of each year and recognizes the Program is certified
through the Center for Resource Solutions.Id.Staff also supports the Company's proposal to
track Program performance to determine customer satisfaction,awareness,and participation.Id.
Staff recommends the Company continue to file a Renewable Energy Program report
each year that includes:(1)annual and cumulative subscription data;(2)REC purchase detail with
generator,location,quantity,price per REC,year,total annual purchase,and weighted average
price by year;(3)a detailed breakdown of administrative and marketing costs;(4)a summary of
Program marketing efforts and communityeducation and outreach;(5)surplus fund balance and
detailed account information;(6)carbon offset content label,and;(7)detailed grant project
information that includes implementation dates and costs.
ORDER NO.34566 3
In summary,Staff recommends the Commission:
1.Authorize the Company to create the National Blocks purchase option of
300 kWhs for $1 in the Program,to become effective on the service date
of the Commission's Final Order;
2.Authorize the Company to create the Regional Blocks purchase option of
100 kWhs for $1 in the Program,to become effective on the service date
of the Commission's Final Order;
3.Authorize the Company to rename the "Buck-a-Block"program to "My
Clean Energy;"and
4.Direct the Company to file the annual report with Program data and work
with Staff to evaluate yearlyProgram performance.
Id.at 6.
2.ICL Comments
ICL requests that Avista provide clearer and more accessible information to its Idaho
customers about what portion of the Company's distributed electricity is produced from renewable
versus fossil fuel sources.ICL Comments at 2.ICL believes customers need this information to
determine how much to pay into the Program to correctly offset their fossil fuel emissions.Id.
ICL also asserts the information Avista provides about its energy mix is three years out-of-date
and not specific to Idaho customers.Id.ICL believes Idaho customers must understand how
Avista accounts for and manages RECs produced by Avista's renewable energy resources.Id.
Further,ICL asserts Avista should explain how it manages Idaho's share of RECs produced from
Avista-owned energy resources.Id.
ICL requests that Avista source its Regional Blocks with RECs coming from Idaho.
Id.at 3.If RECs from Idaho are not available then they should be sourced from the northwest
region of the United States,excluding California,and not from British Columbia.Id.ICL believes
RECs sourced from Idaho,or secondarily from the northwest United States,will improve the
likelihood that Idaho customers would benefit from participating in the Program.Id.
ICL also supports Avista's intention to improve its communications,education and
facilitation of the Program but believes the Company only vaguely describes how this will be
accomplished.Id.ICL also requests that Avista report how much solar grant funding it has
awarded from the Program's surplus funds to Idaho-basedprojects compared to Washington-based
ORDER NO.34566 4
projects since 2002.Id.at 4.Finally,ICL requests that Avista explain how it determines the
amount of surplus funding to be allocated between its Idaho and Washington service territories.
Id
3.Avista's Reply Comments
Avista contends several ICL concerns regarding the Company's energy mix are directly
relatedto the Company's Integrated Resource Planning process and are distinct from the issues in
this case.Reply Comments ofAvistaCorporation at 1.Despite this,the Company states it called
ICL to discuss its comments to find ways to address those concerns.Id
Regarding ICL's other suggestions,Avista first asserts it already provides the
Company's fuel mix annually on its webpage as required by the Commission's Energy
Consumption Reporting Rules.Id at 2;see also IDAPA 31.81.01.001 et seq.This information
also references the percent of the electricity that comes from renewable resources.Id.Avista
asserts this level of detail is "sufficient"for customers who enroll in the Program.Id
Second,Avista represents it obtains RECs that satisfy the locational and generation
requirements in the Company's tariff and then reviews the RECs'cost to ensure Program
participants are offered the greatest value for their subscription dollars.Id.at 2.Avista states
RECs are purchased for the entire Program,not separately for Idaho and Washington.Id.This
provides Avista the ability to source the lowest-cost resources in the Program.Id.The Company
states it will continue purchasing RECs in this manner to provide participants the most value.Id.
Third,Avista expressed interest in deriving the maximum value out of the Program on
behalf of all participants.Id.at 3.Avista represents it did not propose revisions until it had
conducted customer interviews,surveys and usability studies to assess and inform the Company's
communications and outreach.Id.
Lastly,Avista asserts it has awarded $346,722.80 in grants,including $60,811.80 of
grants to Idaho projects.Id.Minimum Program eligibility criteria for grant recipients includes
new installations on non-residential building sites with a preference given to educational
institutions and/or non-profit buildings in Avista's electric service territory.Id.Avista also
contends that,in its sole discretion,it evaluates applications based on project feasibility and
readiness,installation cost and financing,geographic distribution throughoutAvista's service
territory,communityexposure,and educational benefits.Id.Avista states customers can apply
ORDER NO.34566 5
for a grant to cover all or part of a project's cost and must meet the criteria outlined in the
Company's tariff.Id.
COMMISSION FINDINGS AND DECISION
Avista is an electric corporation and public utility pursuant to Idaho Code §§61-119
and 61-129.The Commission has jurisdiction over this matter under Idaho Code §§61-502 and
61-503.The Commission is empowered to investigaterates,charges,rules,regulations,practices,
and contracts of public utilities and to determine whether they are just,reasonable,preferential,
discriminatory,or in violation of any provision of law,and to fix the same by order.Idaho Code §§
61-502 and 61-503.
Based on our review of the record,we fmd that it is just,reasonable and in the public
interest to approve Avista's Application and proposal to modify its Schedule 95.We find that the
Company's creation of the National and Regional Blocks purchase options will provide additional
opportunities for customers to participate in the Program.We also find it appropriate for the
Company to change the Program's name to "My Clean Energy."
The Company represents the "'lack of information'is a problem and [its customers]
don't understand the [P]rogram's value.There is clearly a need to further educate customers on
the benefits of the [P]rogram."Application at 3.The Company explains its proposed efforts to
promote and educate its customers about the Program.See Application at 6.We support the
Company's commitment to increase and improve upon the information and education it provides
its customers about the Program.The Company's future outreach to its customers about the
Program will be essential for its sustainability.Such efforts will be reviewed as part of the yearly
Program evaluation with Staff,as set forth below.
We find it reasonable and in the public interest to direct the Company to continue filing
a Renewable Energy Program annual report ("Annual Report")with Program data that includes:
(1)annual and cumulative subscription data;(2)REC purchase detail with generator,location,
quantity,price per REC,year,total annual purchase,and weighted average by year;(3)detailed
breakdown of administrative and marketing costs;(4)summary of Program marketing efforts and
community education and outreach;(5)surplus fund balance and detailed account information;(6)
carbon offset content label;and (7)detailed grant project information that includes implementation
dates and costs.We further find it reasonable to direct the Company to work with Staff to evaluate
the yearly Program performance after the Company files its Annual Report.
ORDER NO.34566 6
Finally,consistent with our findings in Order No.33218,the Company remains
authorized to use the Program's surplus funds to support grants for rooftop solar installations on
commercial buildings.
ORDER
IT IS HEREBY ORDERED that Avista's Application requesting authorization to
modify its Schedule 95 is approved.The modified Schedule 95 shall take effect on the service
date of this Order.The Company is directed to file the modified Schedule 95,within ten (10)days
of the service date of this Order.
IT IS FURTHER ORDERED that the Commission approves the Company's request to
change the Program's name to "My Clean Energy."
IT IS FURTHER ORDERED that the Company submit an Annual Report at the end of
each year on the Program offered through Schedule 95 Optional Renewable Power Rate,as
described above.We direct the Company to work with Staff to evaluate the yearly Program
performance after the Company files its Annual Report.
IT IS FURTHER ORDERED that the Company may use surplus funds from the
Program to pay for grants for rooftop solar installations on commercial buildings consistent with
our decision in Order No.33218.
THIS IS A FINAL ORDER.Any person interested in this Order may petition for
reconsideration within twenty-one (21)days of the service date of this Order.Within seven (7)
days after any person has petitioned for reconsideration,any other person may cross-petition for
reconsideration.See Idaho Code §61-626.
ORDER NO.34566 7
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this day of
March 2020.
PAUL K ,PRESIDENT
KRISÝINE RAPER,CO ISSIONER
ERIC ANDERSON,COMMISSIONER
Diane M.Hanian
Commission Secretary
1.\Legal\ELECTRIC\AVU-E-19-12\AVUEl912_jh.docx
ORDER NO.34566 8