20210816Reply Comments.pdf

Avista Corp.
1411 East Mission P.O.Box3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
August 16,2021
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Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W Chinden Blvd. Building 8, Suite 201-A
Boise, D 83714
RE: Avista Utilities Reply Comments to Staff Comments in Case AVU-E-21-06 and
AVU-G-21-05.
Dear Ms. Noriyuki:
Avista Corporation, doing business as Avista Utilities, submits these Reply Comments
regarding comments submitted by the Staff of the Idaho Public Utilities Commission regarding
Avista's application for an accounting order for approval of accounting and ratemaking treatment
of AFUDC.
Please direct questions on this matter to me at [phone].
Sincerely,
/s/Elizabeth Andrews
Senior Manager, Revenue Requirernents
Regulatory Affairs
liz. andrews@ avistacorp. com
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COLINSEL FOR
REGULATORY AND GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220.37 27
TELEPHONE: (509) 49s-43t6
david.meyer@ avi stacorp. com
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION, DIBIA AVISTA
UTILITIES FOR AN ACCOUNTING ORDER
AUTHORZING ACCOUNTING AND
RATEMAKING TREATMENT OF AFUDC
(ALLOWANCE FOR FUNDS USED DURING
CONSTRUCTION)
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
CASE NO. AW-E-21-06
CASE NO. AW-G-21-05
REPLY COMMENTS OF
AVISTA CORPORATION
I. INTRODUCTION
Avista Corporation, doing business as Avista Utilities (hereinafter "Avista" or
"Company"), submits these Reply Comments regarding comments submitted by the Staffof the Idaho
Public Utilities Commission ("Staff') regarding the above referenced case.
II. BACKGROT]ND
On July 6,2021, Avista Corporation dba Avista Utilities ("Company") applied to the
Commission for authoizationof accounting and ratemaking treatment related to Allowance for Funds
Used During Construction ("AFUDC").
Reply Comments of Avista Corporation
Case Nos. AW-E-21-06 and AVU-G-21-05
Page I
The Company seeks authority to amortize the regulatory assetr using the approved depreciation
rate by Federal Energy Regulatory Commission ("FERC") plant account approved by the Commission
in the most recent depreciation study and to be able to update the amortization rate with each
depreciation study going forward. For the AFUDC capitalized to plant-in-service, the depreciation
rate is determined by a depreciation study at the individual plant account level that is performed
periodically.2
The Company has received approval from the Washington Utilities and Transportation
Commission ("WUTC') and has requested approval from the Oregon Public Utility Commission of
(.OPUC.) to use the same method of amortization of the deferred AFUDC costs it seeks approval to
use in Idaho. The Company believes it is critical to maintain uniform utility accounts and AFUDC
methods for common plant among the Company's regulatory jurisdictions.
III. AVISTA'S REPLY COMMENTS
Avista appreciates and thanks Stafffor their filed comments and agrees with their position,
i.e., approve Avista's application allowing the Company to amortize the AFUDC regulatory asset over
the depreciation life for each FERC plant account using the Company's current depreciation rates as
approved in Order No. 34276 and allow Avista to periodically update the amortization rate as the
Company receives approval of new depreciation rates.
ry. CONCLUSION
Avista respectfully requests the Commission approve the Company's Application allowing the
Company to amortize the AFUDC regulatory asset over the depreciation life for each FERC plant
I Th" Co*p*y was authorized to defer the difference calculated between the state regulatory AFUDC rate
and the FERC AFUDC rate and amortize the balance over the composite remaining life of the plant-in-
service in Case Nos. AVU-E-19-02 and AVU-G-19-01. See Order No.34326.
2 The Company's last depreciation study was approved March 19,2019, in Case Nos. AW-E-18-03 and
AW-G-I 8-02. See Order No. 3427
Reply Comments of Avista Corporation
Case Nos. AW-E-21-06 and AW-G-21-05
Page2
account using the Company's current depreciation rates as approved in Order No. 34276 and allow
Avista to periodically update the amortization rate as the Company receives approval of new
depreciation rates.
DATED at Spokane, Washington, this l6e day of August 2021.
AVISTA COPJORATION
By
Paftick Ehrbar
Director of Regulatory Aflairs - Avista
Reply Comments of Avista Corporation
Case Nos. AW-E-21-06 and AW-G-21-05
Page 3