20211215Comments.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
'1 ,- -'r;!tl--:..'r;lY'-LJ
Street Address for Express Mail:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA UTILITIES'
APPLICATION FOR PROPOSED CHANGES
TO SCHEDULE 95 "MY CLEAN ENERGY
PROGRAM"
CASE NO. AVU.E-21-15
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Jr., Deputy Attorney General, submits the following comments.
BACKGROUND
On October 18,2021, Avista Corporation dba Avista Utilities' ("Company") proposed
modifications to its Tariff Schedule 95, "My Clean Energy Program" (o'Program").
Currently, the Program includes three options: 1) a National Block option where
customers can purchase 300 kilowatt hour ("kWh") blocks for $l per block, per month with
Renewable Energy Credits ("RECs") sourced from anywhere in the United States; 2) a Regional
Block option where customers can purchase 100 kWh blocks for $l per block, per month for
RECs procured in the Westem Interconnection, with preference given to the Northwest region
including Washington, Idaho, Oregon, California, Montana, and British Columbia; and 3) a l00oh
Renewable Energy option charged per kWh rather than by block and is priced at $0.01/kWh. The
amount of kWhs purchased will vary each month to match the customers actual kWh usage.
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ISTAFF COMMENTS DECEMBER 15,2O2I
The Company proposes to modifr the Program pricing as the price for RECs has increased
and to meet the legislative requirement of all costs and benefits being confined to the Program,
while optimizing value for Program participants. To prevent loss of revenue within the Program,
the Company is proposing revisions to the pricing structure.
National Blocks - Participants can purchase 100 kwh "blocks" for $1.
RECs procured under this option will be sourced from renewable generation
anywhere in the United States. This provides customers a low-cost option
to continue supporting renewable energy.
Resional Blocks - Participants can purchase 100 kWh "blocks" for $1.30.
RECs procured under this option will be sourced from generation in the
Western Interconnection, with preference given to the Northwest region
including Washington, Idaho, Oregon, California, Montana, and British
Columbia. This option provides customers an opportunity to support
regional renewable energy at a price point that is more reflective of the REC
market.
100% Renewable Ootion - One (l) kwh of renewable power from a regional
source in the Western Interconnection, with preference given to the
Northwest region including Washington, Idaho, Oregon, Califomia,
Montana, and British Columbia will offset every kWh used at the customer
selected meter. Each kWh is priced at $0.013 /kwh and the amount of kWhs
purchased will vary each month to match the customers actual kWh usage.
The Company will provide notice of the proposed Program changes to participants
through email and direct mail communications.
The Company requested that the Commission issue an order approving the proposed
modifications to the Program effective January 1,2022.
STAFF ANALYSIS
The Program is a voluntary option for customers who want to reduce the environmental
impact of their electric use through block purchases of bundled RECs. The Company continues
to evaluate its voluntary renewable Program. Program participation and the evidence of rising
REC prices has prompted the Company to make Program updates that include revisions to the
pricing structure.
Through production requests and evaluation of the Application, Staff confirmed that costs
of participation in the Program are tracked separately to avoid cost shifts to nonparticipants, and
2STAFF COMMENTS DECEMBER 15,2O2I
that the tariff changes are necessary to maintain the Program. Thus, Staffrecommends approval
of the Application as filed.
Currently, the Program lets customers buy National, Regional and 100% Renewable kWh
block of renewable energy. The Company is proposing a price change to all block options for
participants of the Program. See Application at 4. The National Blocks option will have a200o/o
price increase that will allow participants to purchase 100 kWh blocks for $1.00. This option is
sourced from renewable generation throughout the United States and may provide a better
opportunity to purchase RECs at the most competitive price.
Regional block options will have a30%o price increase that will allow participants to
purchase 100 kWh for $1.30. The Regional Blocks purchase option sources RECs from the
Northwest region. The 100% Renewable Energy/Clean Option will also see a30o/o price increase.
See Table No. 1.
The Company asserts the pricing was informed using an analysis of the current and
forecasted Program budget, expecting the 2021 market price for RECs continuing to increase into
the next calendar year. The Company ensures that all costs are covered by expected revenues
while setting the pricing at a point that will continue to attract participants. The Company alleges
this pricing should tolerate REC market price volatility and that may lead to a budget surplus that
may fund non-profit community solar installations. The surplus budget has not funded solar
installations in Idaho during 2020 and202l.
Table No. I - Pricing Structure per Option
Current Proposed oZ Increase Participation
National Block 300 kwh for $1.00 100 kwh for $1.00 200%-950
Resional Block 100 kwh for $1.00 100 kwh for $1.30 30%-50
100% Renewable/Clean
Ootion oer kWh used
$0.01 per kWh $0.013 per kWh 30%
With the majority of the Company's customers participating in the National Block option,
customers will see a200Yo increase in price, which could potentially impact customer
participation. Staff encourages the Company to monitor participation in the Program as the
Company transitions to the proposed pricing structure.
The Company currently reports Program data in its an annual My Clean Energy Report
filed with the Commission and the Program is certified through the Center for Resource
JSTAFF COMMENTS DECEMBER 15,2O2I
Solutions. Staff recommends that the Company continue to file the annual report with data that
includes, but not limited to:
(l) Annual and cumulative ldaho participation data;
(2) A detailed breakdown of monthlylyearly Program budget and expenses;
(3) A list of customers participating, with the amount of blocks purchased per customer;
(4) A REC detail report that includes: year the energy was generated, the location, the
quantity, total annual RECs purchased, the price per REC, REC's retired and year
retired for, the weighted average price by year, and any RECs resold previously for the
Program;
(5) A summary of efforts made to promote the Program initiatives by education and
outreach;
(6) The Program content label associated with meeting environmental and consumer-
protection standards set forth by the nonprofit Center for Resource Solutions; and,
(7) Detailed grant project information that includes implementation dates and costs.
STAFF RECOMMENDATION
Staff recommends the Commission approve the new pricing structure as filed in the
Company's Application. Staff also recommends the Company continue to file its arurual My
Clean Energy Report that includes the information listed in the body of the comments above.
fL
Respecttully submitted this /5 day of December 2021
R. Hammond, Jr.
Attorney General
Technical Staff: Travis Culbertson
Taylor Thomas
i:umisc/comments/avue2l. l5jhtnctt comments
4STAFF COMMENTS DECEMBER 15,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF DECEMBER 2021,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. AVU.E-21-15, BY E.MAILING A COPY THEREOF, TO THE
FOLLOWING:
SHAWN BONFIELD
SR MGR REGULATORY POLICY
AVISTA CORPORATION
POBO)(3727
SPOKANE WA99220-3727
E-MAIL: [e-mail]
dockets @avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
POBOX3727
SPoKANE WA99220-3727
E-mail: [e-mail]
-b42,*,
SECRETARY T/
CERTIFICATE OF SERVICE