20210908Comments.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5214
-.r{
Street Address for Express Mail:
1 I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S ANNUAL APPLICATION
TO ADJUST RESIDENTIAL AND SMALL
FARM ENERGY RATES
CASE NO. AVU.E.2I-IO
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its attorney of record,
Erick Shaner, Deputy Attorney General, submits the following comments:
BACKGROUND
On July 30,2021, Avista Corporation dba Avista Utilities ("Company") applied to the
Commission for authority to implement a 0.319 cents per kilowatt-hour ("kWh") Residential and
Small Farm Energy Rate Adjustment credit for rate schedules l,12,22,32, and 48. Application
at l. The Company states this proposed rate credit would increase qualifuing customers' rates by
$0.1 million, with the average monthly bill for a residential customer increasing from $85.63 to
$85.78. This is an increase of $0.15 per month or 0.2o/o for customers using an average of 892
kilowatt-hours per month. Id. The Company requests that the Application be processed under
Modified Procedure, and that the proposed rates take effect October 1,2021. Id. at4-5.
)
)
)
)
)
)
)
ISTAFF COMMENTS SEPTEMBER 8,202I
The current Residential and Small Farm Energy Adjustment Rate credit is 0.336 cents per
kWh and was designed to pass about $4.2 million in Bonneville Power Administration ("BPA")
benefits to customers through a credit to their energy rates. This was approved by the
Commission in Order No. 34795. The proposed credit of 0.319 cents per kWh would pass about
$4.1 million to customers. Id.
Customers who receive this year's proposed credit would see their energy rates increase
by about $0.1 million, or 0. l%. Id. The rate increase reflects that this year's $4. I million credit
is about $0.2 million less than last year's $4.2 million credit. Id. In other words, this year's rate
increase would reflect that the Company over-refunded about $0.06 million to customers through
last year's credit. Id. The Company explains the proposed rate credit would not affect its net
income. Id. The Company indicates it will noti$ customers about the Application via a news
release and a customer notice billing-insert explaining the rate credit. Id. at 4.
STAFF ANALYSIS
On August 31,2021, in a supplemental response to Staff s Production Request No. 4,
Avista notified Staff that the BPA made an error in the calculation of the rate adjustment credit
of 0.319 cents per kWh, and that the correct rate should be 0.370 cents per kwh. The proposed
new rate credit of 0.370 cents per kWh is designed to pass through approximately $4.7 million,
which represents the Idaho portion of the annual level of BPA benefits and the over-refunded
balance from the prior year, starting in October 2021. An average residential customer using 892
kWh per month would see their present monthly bill decrease from $85.63 to $85.33 cents. This
is a decrease of $0.30, or 0.4o/o. Avista provided updated tariffs reflecting the correct rates which
are included as Attachment A.
Avista informed Staff that it received notification of the above-mentioned error from the
BPA on August 26,2021. The error was caused by an updated Priority Firm Exchange ("PFx")
rate due to an error in the exchange loads that was used to implement the Residential Exchange
Program ("REP"). On August 12,2021, a participating utility informed BPA that the exchange
load reported to BPA for calendar year 2020 was incorrect. That utility had found an error which
resulted in double counting of the Company's residential exchange load. The error has since
been corrected. BPA used the erroneous exchange load to set the PFx rates to allocate REP
benefits for rate period which were used in Avista's initial filing.
2STAFF COMMENTS SEPTEMBER 8,2021
Staff reviewed the methodology and calculation of the proposed Residential and Small
Farm Energy Adjustment credit rate and confirmed the approach is consistent with the terms and
conditions of Schedule 59. Staff recommends the Commission approve the Company's proposed
revision to Schedule 59 to implement a credit rate of 0.370 cents per kilowatt-hour.
The Residential and Small Farm Energy Rate Adjustment credit results from Avista's
agreement with the BPA regarding the REP. The REP allows residential and small-farm
customers of six Pacific Northwest utilities, including Avista, to benefit from the federal
Columbia River power system through a credit to their rates.
Two components are used for the calculation of the BPA benefit for residential and small
farm customers. The first component is the annualized electricity usage by the residential and
small farm customers calculated over the two previous years-2018 and 2019. The second
component is the difference between two variables calculated by BPA every two years: Avista's
Average System Cost rate and the PFx rate. The difference between these two rates is then
multiplied by the annualized electricity usage to generate the BPA benefit to be passed on to
qualifring customers for each of the next two years. The Company allocates the BPA credit
between Washington and Idaho based on the actual usage in each jurisdiction.
Overall Impact of Three Filines Effective October 1. 2021
The Company has made two other rate adjustment filings, also effective October 1,2021.
The Company's proposed Power Cost Adjustment ("PCA") filing (AVU-E-21-09), if approved,
will increase Idaho electric revenues by approximately $7.2 million or 2.8Yo increase and its
proposed Fixed Cost Adjustment ("FCA") filing (AVU-E-2I-08), if approved, will decrease
electric revenues by approximately $0.7 million or 0.3% decrease. With the correction to the
proposed Residential and Small Farm Energy Rate Adjustment as discussed above, the Company
will see an approximate $0.5 million decrease in electric revenues. When combined and if
approved, the net effect of the three requests (PCA, FCA and BPA) is an increase in the overall
Company's electric revenue by approximately $5.9 million, effective October 1,2021, as shown
in Table No. 1 below.
aJSTAFF COMMENTS SEPTEMBER 8,202I
Table No. 1: Summary of Overall Impact to ldaho Electric Revenue
Filing 2020 2021 Net Effect 7o Change
PCA 459,391 7,646,804 7,187,413 2.8%
BPA*-4,188,620 -4,711,060 -522,440 -0.4%
FCA 458,638 -274,078 -732,716 -0.2%
Total -3,270,591 2,661,666 5,932,257 2.1"h
*Includes the correction in the rate adjustment credit from BPA
CUSTOMER NOTICE AND PRESS RELEASE
The Company's press release and customer notice were included with its Application.
Each document addresses the following cases: this case (AVU-E-21-10), the natural gas Fixed
Cost Adjustment (AVU-G-21-06), the electric Fixed Cost Adjustment (AVU-E-21-08), the
Power Cost Adjustment (AVU-E-2I-09), and the Electric Energy Efficiency adjustment (AVE-
E-21-11). Staff reviewed the documents and determined both meet the requirements of Rule 125
of the Commission's Rules of Procedure. See IDAPA 31.01.01 .125. The notice was included
with bills mailed to customers beginning August 12,2021, and ending September 9,2021.
The Commission set a comment deadline of September 8, 2021. Some customers in the
last billing cycles will not have received/and or had adequate time to submit comments before
the deadline. Customers must have the opportunity to file comments and have those comments
considered by the Commission. Staff recommends that the Commission accept late filed
comments from customers. As of September 7,2021, no customer comments had been filed.
STAFF RECOMMENDATION
Staff recommends that the Commission:
1. Approve the Company's proposed tariff revisions to its Residential and Farm
Energy Rate-Schedule 59 as reflected in Attachment A. The new tariff will
implement an Energy Rate Adjustment credit of 0.370 cents per kilowatt-hour,
effective October 1,2021, through September 30,2022; and
2. Accept late filed comments from customers.
4STAFF COMMENTS SEPTEMBER 8,2021
Respectfully submitted this gsL
day of September 2A21.
4
Erick Shaner
Deputy Attomey General
Technical Staff: Johan IGlala-Kasanda
Kevin Keyt
Curtis Thaden
i:umiso:r:oimmens/avue2l. lOesjh&cy cmments
5STAFF COMMENTS SEPTEMBER 8,202I
l.P.U.C. No. 28
Twenty-First Revision Sheet 59
Canceling
Twentieth Revision Sheet 59
AVISTA CORPORATION
dba Avista Utilities
SCHEDULE 59
RESIDENTIALAND FARM ENERGY RATE ADJUSTMENT - IDAHO
APPLICABLE:
To Residential Customers in the State of ldahowhere Company has electric
service available. This rate adjustment results from an Agreement between the
Company an d Bon n evi I le Power Admi n istration (BPA) coveri n g Residential
Exchange Program benefits. The rate adjustment in this schedule shall be
applicable to customers served u nder Schedu les 1 , 1 2, 22, 32 and 48.
MONTHLY RATE:
The energy charges for all blocks of electric Schedu les 1 ,12, 22 and 32 and
the charges for area lights based on the energy usages of the lights on Schedule
48 are to be reduced by 0.3700 per k\lVh.
SPECIAL TERMS AND CONDITIONS:
The rate adjustment underthis schedule is subjectto revision to reflect the
true up from estimated to actual benefits and to reflect projected future benefits. ln
the eventthe credits applied underthis schedule exceed the benefits, the
Compan y wi! I adju st th e rate on th is sch edu le to recover th at differen ce.
The energy credit applied to Schedule 32 forfarm irrigation and pumping
load, for each billing period, shall notexceed the amountof energy determined by
the following formula:
400 x 0.746 x days in the billing period x 24
ln no instance shall any qualiffing irrigation and pumping load for any month
exceed 222,000 kwh.
Service underthis schedule is subjectto the Rules and Regulations
contained in th is tariff.
The above rate is subject to the provisions of Tax Adjustment Schedule 58
lssued: August 31,2021 Effective: October1,2021
lssued by
By Patrick Ehrbar - Director of Regulatorv Af fairc
Attachment A
Case No. AVU-E-21-10
Staff Comments
09108121 Page I of 3
Avista Utilities
AVISTA CORPORATION
dbaAvista Utilities
Eff ective: October '1, 2020lssued: August 31, 2020
l.P.U.C. No.28
Twentieth Revision Sheet 59
Canceling
Nineteenth Revision Sheet 59
SCHEDULE 59
RESIDENTIALAND FARM ENERGY RATE ADJUSTMENT - IDAHO
APPLICABLE:
To Residential Customers in the State of ldaho where Company has electric
service available. This rate adjustment results from an Agreement between the
Compan y an d Bon n evil le Power Admi n istration (BPA) coveri n g Residentia!
Exchange Program benefits. The rate adjustment in this schedule shall be
applicable to customers served underSchedules 1, 12, 22, 32and 48.
MONTHLY RATE:- The energy charges for all blocks of electric Schedules 1,12,22 and 32 and
the charges for area lights based on the energy usages of the lights on Schedu le
48 are to be reduced by 03361 per k\A/h.
SPECIAL TERMS AND CONDITIONS:
The rate adjustment underthis schedule is subjectto revision to reflect the
true up from estimated to actual benefits and to reflect projected future benefits. ln
the eventthe credits applied underthis schedule exceed the benefits, the
Company wil I adju st th e rate on th is sch edu le to recover th at d ifferen ce.
The energycredit appliedto Schedule 32forfarm irrigation and pumping
load, foreach billing period,shallnotexceed the amountof energydetermined by
the following formula:
400 x 0.746 x days in the billing period x 24
ln no instance shall any qualiffing irrigation and pumping load for any month
exceed 222,000 klVh.
Service underthis schedule is subjectto the Rules and Regulations
contained in th is tariff.
The above rate is subject to the provisions of Tax Adjustment Schedule 58.
lssued by
By Patrick Ehrbar - Director of Regulatory Affairc
Attachment A
Case No. AVU-E-21-10
Staff Comments
09108121 Page 2 of 3
Avista Utilities
AVISTA CORPORATION
dba Avista Utilities
lssued: August 31,2021 Effective: October 1, 2021
l.P.U.C. No. 28
Twenty-First Revision Sheet 59
Canceling
Twentieth Revision Sheet 59
SCHEDULE 59
RESIDENTIALAND FARM ENERGY RATE ADJUSTMENT - IDAHO
APPLICABLE:
To Residential Customers in the State of ldaho where Company has electric
service available. This rate adjustment results from an Agreement between the
Compan y an d Bon n evi lle Power Admi n istration (BPA) coveri n g Residential
Exchange Program benefits. The rate adjustment in this schedule shall be
applicable to customers served underSchedules 1, 1 2, 22, 32 and 48.
MONTHLY RATE:
The energy charges for al! blocks of electric Schedules 1,12,22 and32 and
the charges for area lights based on the energy usages of the lights on Schedule
48 are to be reduced by 0.3700 per k\Nh.
SPECIAL TERMS AND CONDITIONS:
The rate adjustment underthis schedule is subjectto revision to reflect the
true up from estimated to actual benefits and to reflect projected future benefits. ln
the eventthe credits applied underthis schedule exceed the benefits, the
Compan y wi I ! adju st th e rate on th is sch edu le to recover th at differen ce.
The energy credit applied to Schedule 32 forfarm irrigation and pumping
Ioad, for each billing period, shall notexceed the amountof energydetermined by
the following formula:
400 x 0.746 x days in the billing periodx24
ln no instance shal! any qualiffing inigation and pumping load for any month
exceed 222,000 k\ /h.
Service underthis schedule is subjectto the Rules and Regulations
contained in this tariff.
The above rate is subject to the provisions of Tax Adjustment Schedule 58
lssued by Avista Utilities
By Patrick Ehrbar - Director of Regulatory Affairs
Attachment A
Case No. AVU-E-21-10
StaffComments
09108121 Page 3 of 3
CERTIFICATE OF SERVICE
I HEREBy cERTIFy rHAT I HAvE THIS 86 olv oF SEpTEMBER 202r,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAf,'F, IN
CASE NO. AVU-8.21-IO, BY E.MAILING A COPY THEREOF, TO THE
FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
POBOX3727
SPOKANE WA99220-3727
E-MAIL : [e-mail]
dockets@avistacorp. com
DAVID J MEYER
VP & CHIEF COLINSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE