20230829Reply Comments.pdf

RECEIVED
Tuesday, August 29, 2023 4:46:54 PM
IDAHO PUBLIC
UTILITIES COMMISSION

Reply Comments of Avista Corporation Page 1
Case No. AVU-E-23-06

DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY AND GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
[e-mail]

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR AN
ACCOUNTING ORDER AUTHORIZING
DEFERRAL OF CERTAIN COSTS
ASSOCIATED WITH THE MONTANA
REVIERBED LEASE AGREEMENT

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CASE NO. AVU-E-23-06

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 Staff
of the Idaho Public Utilities Commission (“Staff”) regarding the above referenced case.
On June 30, 2023, Avista applied for an order requesting authorization to utilize
deferred accounting for Idaho’s share of the estimated interest costs of approximately $1.3
million ($3.8 million electric system) associated with the Montana Riverbed Lease
Agreement (“Lease”) due to the State of Montana (State) in the third quarter of 2023.
Avista also proposed to record Idaho's share of the interest costs as a regulatory asset in
FERC Account 182.3-Other Regulator Assets, with a carrying cost equal to Avista’s

Reply Comments of Avista Corporation Page 2
Case No. AVU-E-23-06
authorized cost of debt set in Case No. AVU-E-23-01 (pending Commission approval at
4.97%), and to seek recovery of these costs in its next general rate case.
On August 23, 2023, Staff filed comments stating that it reviewed the Application
for an accounting order authorizing Avista to defer certain costs associated with the Lease
and is generally supportive of the Company's request. With regard to the Company’s
request for a carrying cost on the Idaho share of the deferral at the Company's authorized
cost of debt established in its pending general rate case, Staff stated it does not support a
carrying charge, as granting the Company deferral of expenses that would likely otherwise
be unrecoverable is sufficient relief to the Company.
II. AVISTA’S REPLY COMMENTS
Avista appreciates the comments provided by Staff and support their
recommendation to permit the Company authority to defer Idaho's share of the interest
payments on the Lease, without a carrying charge.
III. CONCLUSION
Avista respectfully requests the Commission approve the Company’s Application
for an accounting order authorizing Avista to defer certain costs associated with the Lease,
to record them in a subaccount of FERC Account No. 182.3-Other Regulatory Assets, with
recovery of the deferred interest payments to be determined in the Company's next general
rate case, without a carrying charge on the deferred balance, consistent with Staff’s
comments.
DATED at Spokane, Washington, this 29th day of August 2023.
AVISTA CORPORATION

By
Patrick Ehrbar, Director of Regulatory Affairs