20210218Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BAR NO. 9917
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Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S FILING PROPOSING
MODIFICATIONS TO TARIFF SCHEDULE NO.
95
CASE NO. AVU.E,-20.I4
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Dayn Hardie, Deputy Attorney General, submits the following comments.
BACKGROUND
On December 4,2020, Avista Corporation dba Avista Utilities ("Company") submitted a
Tariff Advice requesting to modiff Electric Service Schedule No. 95-My Clean Energy
Program ("schedule No. 95" or o'Program"). The Company requests an effective date of
February 15,2021.
At the Commission's January 26,2021decision meeting, the Commission's Staff
recommended the Commission suspend the proposed effective date and process the Tariff
Advice as a formal case because the Tariff Advice would make programmatic changes that
warrant public comment. The Commission found it appropriate to process this Tariff Advice as
an application (the "Application") using Modified Procedure. See Rule I34.l2,IPUC Rules of
Procedure.
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ISTAFF COMMENTS FEBRUARY I8,2O2I
The Company seeks to modi$ Schedule No. 95 to offer customers in the My Clean
Energy Program a third option to purchase clean energy. The Company proposes to add a l00Yo
Renewable Option which would allow customers to purchase I kilowatt-hour ("kWh") of
renewable power from a regional source in the Western Interconnection to offset each kWh
billed to the customer's selected meter. Each kWh purchased under this option would cost $0.01
in addition to the customer's regular bill. The number of kWhs purchased each month would
correspond directly to a customer's actual usage each month.
STAFF ANALYSN
The Company continuously evaluates its voluntary renewable My Clean Energy
Program. Through customer feedback, an additional opportunity to align Program options with
customer sentiment was identified. Staff supports the Company's request to expand the Program
offering to include a 100%o Renewable Option, which eliminates the need for customers to
estimate monthly block purchases from existing block options and simplifies the buying process
to match monthly energy consumption. Staff confirmed that costs of participation in My Clean
Energy are contained within the Program and tracked separately to avoid cost shifts to non-
participants. The Company expects the billing system that can support the 100% match option to
be complete by the end of March2l2l.
STAFF RECOMMENDATION
Staff recommends the Commission approve changes to the My Clean Energy Program to
include the proposed 100% Renewable Option.
Respectfully submitted this tS lt-
day of Feb ruary 2021.
Deputy Attorney General
Technical Staff: Rachelle Farnsworth
i :umisc/comments/avue20. l4dhrf comments
STAFF COMMENTS FEBRUARY I8,2O2I2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I8d' DAY OF FEBRUARY 2021,
SERVED THE FOREGOING COMMENTS OF TI|E COMMISSION STAFF, IN
CASE NO. AVU-E-20-14, BY E-MAILING A COPY THEREOF TO THE
FOLLOWING:
SHAWN BONFIELD
SR MGR/REGULATORY POLICY
AVISTA CORPORATION
PO BO){ 3727
SPoKANE WA99220-3727
E-MAIL : [e-mail]
avi stadockets@ avi stacorp. com
CERTIFICATE OF SERVICE