20220907Comments.pdf

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RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITTES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
: f-tl i " /: -i i:;.i.d.+
Street Address for Express Mail:
1 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA
CORPORATION'S ANNUAL FILING TO
ADJUST RESIDENTIAL AND SMALL T'ARM
ENERGY RATES
CASE NO. AW-E-22-IO
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Riley Newton, Deputy Attorney General, submits the following comments.
BACKGROUND
On July 29,2022, Avista Corporation dlblaAvista Utilities ("Company" or 'oAvista"),
filed its annual Residential and Small Farm Adjustment Filing ("Application"). The Company
requested that the Commission issue an order approving a per kilowatt-hour ("kwh") Residential
and Small Farm Energy credit rate of 0.380 cents for rate schedules l, 12,22, 32, and 48 to
become effective October 1,2022. The Company calculates that a residential customer using an
average of 892 kWh of electricity per month will see a decrease in their monthly bill from $86.29
to $86.20, or $0.09. Application at 4.
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STAFF COMMENTS SEPTEMBER7,2022
STAFF REVIEW
The Residential and Small Farm Energy Rate Adjustment credit results from the
Company's agreement with the Bonneville Power Administration ("BPA") regarding the
Residential Exchange Program. The Residential Exchange Program 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. The rate credit reflects
Idaho's share of BPA benefits through the Residential Exchange Program, as offset by any over-
refunded balance from the prior year.
The current Residential and Small Farm Energy Adjustment Rate credit is 0.370 cents per
kWh. The rate was designed to give customers approximately $4.7 million in BPA benefits
through a credit to their energy rates. The proposed credit of 0.380 cents per kWh is designed to
give customers about $4.9 million, representing the Idaho portion of the annual BPA benefits,
offset by the over-refunded balance from the prior year. The over-refunded balance from the
prior year is due to actual usage being higher than projected in the Company's 2021 filing.
Using the current rate multiplied by the projected kWh for October 2022 through September
2023, and compared to the proposed rate for that same time period, the Company's proposal is an
overall decrease of $129,665 or 0.lYo for quali$ing customers.
The calculation of the BPA benefit for residential and small farm customers has two
inputs. The first input is the usage of Avista's residential and small farm customers over the
previous two years, in this case, 2019 and2020, which is averaged to create an annualized usage.
The second input is the difference between two variables calculated by BPA. Avista's Average
System Cost rate and the Priority Firm Exchange Rate. BPA calculates these variables every two
years. The difference between these two rates is multiplied by the annualized usage to calculate
the BPA benefit to be passed to qualifuing customers for the next two years. Currently, the
Company is in year 2 of the current credit. The BPA credit is allocated between Washington and
ldaho based on the actual usage in each jurisdiction.
Avista's Residential and Small Farm credit is calculated by taking the projected
remaining balance of the BPA benefit from the previous year and adding the BPA benefit for the
following year. The prior year's amount was over-refunded because customers used more
electricity than projected. To calculate the rate, the total credit is divided by the projected annual
kWh sales to residential and small farm customers.
2STAFF COMMENTS SEPTEMBER 7 ,2022
Staff reviewed the methodology and calculation of the proposed Residential and Small
Farm credit rate, and the approach is consistent with the terms and conditions of Schedule 59 -
Residential and Farm Energy Rate Adjustment - Idaho. Staffaudited the inputs and
independently recalculated the rate. Staff recommends that the proposed rate of 0.380 cents per
kilowatt-hour be approved.
Overall Impact of Four Filings Effective October 1,2022
The Company proposed four electric rate adjustments effective October 1,2022. In this
case, the BPA Credit, if approved, will decrease the Company's electric revenues by $0.1 million
(0)%). The Company's proposed Power Cost Adjustment ("PCA") filing, AVU.E-22-I l, if
approved, will decrease electric revenues by about $3.1 million(1.2% decrease). The third
proposed filing, Fixed Cost Adjustment ("FCA"), AYU-E-22-12, if approved, will decrease
electric revenues by $5.1 million (2.0% decrease). The final proposed filing, Schedule 91,
Energy Efficiency Rider Adjustment ("EE Rider"), AVU-E-22-09, if approved, will decrease
electric revenues for participants by $3.6 million(1.4% decrease). The net effect of the
Company's four filings (BPA Credit, PCA, FCA, and EE Rider) will decrease electric revenues
by approximately $12.0 million (4.7% decrease). The average residential electric customer's
monthly bill may decrease by $4.10 or 4.8%o. Table No. I summaizes the overall impact to
electric revenues of the four filings.
Table No. l: Summarv of Overall Impact to Electric Revenues
Filing Change in Revenues o/" Change
PCA ($3,099,000)-t.2%
FCA ($5,122,171)-2.0%
BPA Credit ($129,655)-0.1%
EE Rider ($3,626,534)-1.4o/o
Total ($11,977,360)-4.7"
CUSTOMER NOTICE AIID PRESS RELEASE
The Company's press release and customer notice were included with its Application and
addressed different topics in the following cases:
3STAFF COMMENTS SEPTEMBER7,2022
o this case (AVU-E-22-10),
o the natural gas Fixed Cost Adjustment (AVU-G-22-04),
o the electric FCA (AVU-E-22-12),
o the PCA (AVU-E-22-ll), and
o the Electric Energy Efficiency Adjustment (AW-E-22-09).
Staff reviewed the documents and determined that both meet the requirements of Rule 125 of the
Commission's Rules of Procedure, IDAPA 31.01.01.125. The notice was included with bills
mailed to customers beginning August 11,2022, and ending September 9,2022.
The Commission set a comment deadline of September 7,2022. Some customers in the
last billing cycles will not have received 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. Staffrecommends that the Commission accept late-filed
comments from customers. As of September 6,2022, no customer comments had been filed.
STAFF RECOMMENDATION
Staff recommends that the Commission:
l. Approve the Company's Application and proposed Residential and Farm Energy
Rate Schedule 59, as filed, which establishes credit rate of 0.038 cents per
kilowatt-hour, effective October 1,2022 through September 30,2023; and
2. Accept and consider any late filed comments from customers.
Respecttully submittea tnis I
tu day of September 2022.
Riley Newton
Deputy Attomey General
Technical Staff: Kathy Stockton
Curtis Thaden
i:umisc/comments/avue22. l0mklsct commen6
4STAFF COMMENTS SEPTEMBER7,2022
CERTIFICATE OF SERVICE
I TIEREBY CERTIFY THAT I HAVE T}IIS 7th DAY OF SEPTEMBER 2022,
SERVED THE FOREGOING COMMENTS OX' THE COMMISSION STAFF, IN
CASE NO. AVU.E-22-IO, 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]
[e-mail]
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE W499220-3727
E'mail: [e-mail]
CERTIFICATE OF SERVICE