20200107Idaho Conservation League Comments.pdf

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IDAHO
CONSERVATI
LEAGUE
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208.265.9555 . PO Box 2108 Sandpornt lD 81864 . wwwdaho(onservation.org
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720
Submifted via email to: [e-mail], [e-mail], arul
I i nda. ge rv a i s@gv is tac o rp. co m
January 6,2020
RE: Case No. AVU-E-19-12
Dear Ms. Hanian:
Since 1973, the Idaho Conservation League ("ICL") has been ldaho's leading voice for
clean water, clean air, and wildemess - values that are the foundation for ldaho's extraordinary
quality of life. As a 501(cX3) nonprofit organization, ICL works to protect these values through
public education, outreach, advocacy, and policy development. ICL is Idaho's largest state-based
conservation organization and represents over 35,000 supporters, many ofwhom have a deep
personal interest in protecting ldaho's human health and environment.
Attached, please find my comments on behalfofthe Idaho Conservation League
regarding Avista Corporation's Application Requesting to Modifr Schedule 95 to Revise the
Company's Voluntary Renewable Energy Program.
Please do not hesitate to contact m e * [phone] or
rnnr-kiel(J)idahoconscrl ation.org if you have any questions regarding our comments or if we can
provide you with any additional information on this matter.
Sincelely,
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RECEIVED
:i20 JAN -? Alt I0: 28
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Thank you for your time and consideration.
Matthew Nykiel
Conservation Associate
ldalro ( orrsen atron Lcr-!uc ( o rlenls
AVU-E- l9- t 2
Customer Education
To improve Avista's proposed "My Clean Energy Program" ("Program"), we request
Avista provide and more accessible and understandable information to its Idaho customers
specifically explaining what portion of Avista's distributed electicity is produced from
renewable sources and what portion is produced from fossil fuel sources. Idaho customers need
this information to determine how much to pay into the Program to correctly offset their fossil
fuel emissions. We request Avista make this information easily accessible within Avista's
materials that explain and describe the Program. Unfortunately, the information Avista currently
provides about its energy mix is three years out-of-date and is not specific to its Idaho customers
See https://www.myavista.com/about-us/our-comoany/about-our-energy-mix. We request Avista
simply state to its Idaho customers the percent of electricity they receive that comes I'rom lbssil
fuels and the percent that comes from renewable resources.
Information about how much renewable versus fossil fuel electricity Avista distributes to
its Idaho customers should also be updated according to changes to Avista's portfolio ofelectric
generating resources and differences in how Avista dispatches these resources between its Idaho
customers and Washington customers.
For example, as Avista proceeds to produce more clean energy according to Avista's
corporate climate change commitment and according to Washington State law, Idaho customers
need to understand whether or not that additional clean energy is being distributed to and paid for
by Idaho custom€rs. If Idahoans share ownership in or use of the clean energy resource
additions, Idaho customers could reduce their investment into the Program, But, if the costs of
Avista's clean energy resource additions are not incorporated into Idaho customer rates or if the
clean energy is not distributed to ldaho customers, then Idahoans will need to pay more to the
Program to correctly offset their fossil fuel use. The share of clean energy that is distributed to
ldaho customers as distinguished from Washinglon State customers is necessary for Idahoans to
make informed, consumer-driven decisions, especially when participating in the Program. We
hope that the intention behind Avista's proposed "value calculator" is to function to help
customer determine exactly how much they must pay into the Program to conectly offset their
fossil fuel use.
Similarly, Avista's ldaho customers must understand how Avista accounts for and
manages the Renewable Energy Credits (RECs) produced by Avista's renewable energy
resources. We request that in Avista's materials describing the Program, Avista explain how it
manages ldaho's share ofRECs produced from Avista-owned energy resources. For example,
according to information provided during Avista's 2019 Intergrated Resources Plan development
process, Avista's Idaho customers have a stake in approximately 200 average megawatts of
hydro-electric RECs every year. See https://www.myavista.com/-/media/myavista/content-
docunrents/about-us/our-comDany/irp-documents/2020-electric-i rp-tac-5-presentations.pdfJla=en
at pdfpage 43. But, if Avista chooses to sell those RECs to Washington customers or over the
open market, Avista's Idaho customers would have to pay more into the Program to correctly
offset their fossil fuel emissions.
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ldaho ('olrservatio,r Leaguc Conrnlents
AVt i-E- t9- t:
We are not aware ofany public materials that adequately inform ldaho customers how
Avista accounts for and manages the RECs that are produced as a result ofthe energy generated
to meet the demand in Avista's ldaho service territory. We request Avista make this information
easily accessible within Avista's materials that describe and explain the Program. This
information is also necessary for Idaho customers to make informed, consumer-driven decisions.
Regional REC Preference
We request Avista source its Regional Blocks with a preference for RECs sourced from
Idaho. We also request that whatever Regional Blocks cannot be sourced from Idaho be sourced
from the Northwest Region of the United States, excluding California and British Columbia. As
Avista's Idaho customers participate in the Program, the benefits of supporting renewable energy
development (ob growth, air quality. etc.) based on their contributions will better accrue to
Idahoan customers the closer those RECs are sourced.
Implementation
In Avista's application at page 6, Avista states:
"ln order to successfully implement the proposed changes and deliver on
customer expectations, Avista will modifu the language and positioning on the
Company's website to better illustrate the value ofthe program. This includes the
addition ofa value calculator, modifications to the online enrollment process to
illustrate the program's options, and back-end system changes... Avista also plans
on distributing ongoing communications to our customers in order to promote
b[ro]ader awareness ofthe program, as well as regular communications to current
program participants that will include information about the renewable projects
they help support."
We support Avista's intention to improve its communications. education, and facilitation
ofthe Program, but Avista only provides a vague idea ofhow it intends to do all this, which
prevents the public, the Idaho Public Utilities Commission ("IPUC), and IPUC Staff from
providing helpful comments and feedback. In particular. we would be interested to leam more
about and to comment on Avista's specific proposals for modifting the language it uses to
describe and market the Program. It seems to us that the absence ofthese details in Avista's
application, risks Avista missing an important opportunity to get customer input before it
implements the Ianguage changes.
We would welcome an opportunity to learn more about how Avista proposes to better
illustrate the value ofthe Program and an opportunity to comment on a nrore fully presented
proposal.
J
ldaho (lonservatirrrr l,easu€ ('onrnents
AVL.I-E-19- l2
Surplus Revenue
We request Avista indicate the total amount of funding it has awarded in solar grants
liom the Program's surplus f'unds, since 2002, to ldaho-based projects as compared to
Washington State-based projects. We also request Avista explain the process by which it
determines how much ofthe surplus funding Avista's ldaho service territory is entitled to as
compared to Avista's Washington service territory.
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