20220906Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
TDAHO BAR NO. 9917
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION'S REQUEST TO
DECREASE ITS ENERGY EFFICIENCY RIDER
ADJUSTMENT SCHEDULE 91
CASE NO. AVU-E-22-09
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attomey of
record, Dayn Hardie, Deputy Attorney General, submits the following comments.
BACKGROUND
On July 29,2022, Avista Corporation dba Avista Utilities ("Company") applied for
authorization to decrease its electric Schedule 9l "Energy Efficiency Rider Adjustment"
("Schedule 91") rates. The Company proposes to decrease the rates and charges collected
through Schedule 91 by $3.6 million annually, or l.4Yo.
The Company requested that its Application be processed under Modified Procedure with
an effective date of October 1,2022.
The Company's Schedule 9l is used to collect funds that are allocated through Schedule
90 to fund energy efficiency services to customers. The Company's programs are built to provide
a financial incentive-rebate-to help customers cover the cost of energy efficiency measures.
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1STAFF COMMENTS SEPTEMBER6,2022
The Company uses several measures to determine the true costs and benefits of its offerings under
Schedule 90, including the Total Resource Cost Test and the Utility Cost Test.
STAFF ANALYSIS
Staff reviewed the Company's Application and workpapers and supports the
Company's request to decrease the Schedule 9l Energy Efficiency Rider electric rates by 1.4%.
If approved, a residential customer using 892 kilowatt-hours per month would see their monthly
bill decrease from $86.00 to $84.82, or $1.17 per month. Staff determined the Company properly
applied the new rate adjustment to customer classes as shown in Table No. I below:
Table No. 1: Schedule 91 Rates
SCHEDULE
EXISTING
RATE
PROPOSED
RATE
Residential Customers - Sch. I .395p per kWh .263p per kWh
General Service - Sch. ll&12 .427(, per kWh 23lp per kWh
Large General Service - Sch. 2l&22 .340i, per kWh 255p per kWh
Extra Large Customers - Sch. 25 .219p per kWh l47p per kWh
Clearwater Paper - Sch. 25P .203A per kWh l32l per kWh
Pumping Service - Sch. 3l&32 .396(, per kWh .256(, per kWh
Street Light Service - Sch. 4l-49 1.340i, per kWh l.$9A per kWh
As of June 30,2022, the Company's Schedule 91 was approximately $4.9 million
overfunded-meaning Schedule 9l has been collecting more revenues than what is being
distributed through Schedule 90. The Company describes two main factors that contributed to
the overfunded balance. First, current rates were set to recover a large, turderfunded balance
after customers in 2016 and2017 achieved far more energy efficiency savings than contemplated
in the Integrated Resource Plan ("IRP").t k Order No. 33897, the Commission increased the
Schedule 91 collection to recover $3.9 million underfunded balance over approximately 3 years.
Second, Covid-l9 altered the participation in the programs offered in Schedule 90. The
I During 2016 and 2017 customers achieved 88,3 19 megawatt-hours of energy savings, which was 394% of the IRP
target. Application at 3. This caused Schedule 9l to be underfunded by about $9.6 million. /d
2STAFF COMMENTS SEPTEMBER 6,2022
proposed rate adjustment is projected to bring the overfunded balance of Schedule 91 to $0 by
September 30,2025. By extending the collection period over a longer period, the Company is
attempting to align the collection of revenue in Schedule 91 more closely with the annual Energy
Efficiency Program budget, thus minimizing the future rate impact to customers.
Cost-effective Demand Side Management ("DSM"), including energy efficiency and load
management programs, is a significant resource that helps customers better control their utility
bills, reduces the need for higher-cost supply-side resources, and increases system reliability.
Staff assumes the Company's DSM program costs will continue to be prudently incurred and that
the programs will remain cost-effective. It is not Staff s intent to either validate or question the
Company's DSM prudency or its actual cost-effectiveness calculations for any of its energy
efficiency programs at this time. Such validation and additional review was not requested in this
case and is occurring in Case No. AVU-E-22-13 which is subsequently before the Commission.
CUSTOMER NOTICE AND PRESS RELEASE
The Company's press release and customer notice were included with its Application.
Each document addresses the following cases: the electric FCA (AVU-E-22-12), the gas FCA
(AVU-G-22-04), the Power Cost Adjustment (AVU-E-22-11), the BPA Residential and Small
Farm Credit (AVU-E-22-10) and the Electric Energy Effrciency Adjustment (AVE-E-22-09).
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 between August 11,2022, and September 9, 2022. Customers who
receive the notice near the end of the billing cycle will not have the opportunity to file timely
comments with the Commission by the September 6,2022, deadline. Because some customers
will not have been notified, Staff recommends the Commission consider any late filed
comments. As of September 5,2022, no customer comments had been filed.
Overall Impact of Four Filings Effective October 1,2022
The Company proposed four electric rate adjustments effective October 1,2022. In this
case, the EE Rider adjustment, if approved, will decrease the Company's electric revenues by
$3.6 million(1.4%). The Company's proposed Power Cost Adjustment ("PCA") filing, AVU-E-
22-lI, if approved, will decrease electric revenues by about $3.1 million(1.2% decrease). The
JSTAFF COMMENTS SEPTEMBER6,2022
proposed Residential and Farm Energy Rate Adjustment or Residential Exchange Program
("ResEx"), AVU-E-22-10, if approved, will decrease electric revenues by $0.1 million (0.1%
decrease). The Company's proposed Schedule 75 Fixed Cost Adjustment ("FCA") Mechanism -
Electric, AYU-E-22-72,if approved, will decrease electric revenues an additional $5.1 million
(2.0% decrease). The net effect of Company's four filings (EE Rider, PCA, ResEx, and FCA)
will decrease electric revenues by nearly $12.0 million (4.7% decrease). The average residential
electric customer's monthly bill may decrease by $4.10 or 4.8Yo. Table No. 2 summarizes the
overall impact to electric revenues of the four filings.
Table No. 2: Summarv of Overall Impact to Electric Revenues
Filing Change in Revenues 7o Change
EE fuder (s3,626,534)-1.4%
PCA ($3,099,000)-1.2%
ResEx Credit ($ 129,655)-0.1%
FCA ($5,122,171)-2.0%
Total ($11,977,360)-4.7o/o
STAFF RECOMMENDATION
Staff recommends approval of the Company's Application to decrease the Schedule 9l
Customer Efficiency Services Rate by l.4Yo and the proposed Schedule 91 tariffs as filed.
Additionally, Staff recommends the Commission consider any late filed customer comments.
Respectfully submitted this 6rH day of Septemb er 2022.
Dayn
Deputy Attorney General
Technical Staff: Latra Conilogue
Jason Talford
i : umisc/comments/avu922.9dhlcjjt comments
4STAFF COMMENTS SEPTEMBER 6,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAvE THIS 6TH DAY oF SEPTEMBER 2022,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. AVU-E-22.09, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
PATRICK EHRBAR
DIRECTOR REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail : [e-mail]
dockets@avi stacorp.com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA COPJORATION
PO BOX3727
SPOKANE WA99220-3727
E-mail: [e-mail]
J. 1,r,,-r\
SECRETARY I
CERTIFICATE OF SERVICE