20231107Reply Comments.pdf

Avista Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170

November 7, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A
Boise, Idaho 83714

RE: Case No. AVU-E-23-07 and AVU-G-23-04 - Avista’s Reply Comments Regarding “In
the Matter of Avista’s Application for an Accounting Order Authorizing Accounting
and Ratemaking Treatment of Costs Associated with the Company’s Investment in
AMI (Advanced Metering Infrastructure)

Dear Ms. Noriyuki:

Avista Corporation dba Avista Utilities (Avista or the Company) hereby provides these
Reply Comments in accordance with Commission Order No. 35885, Notice of Modified
Procedure, which established a reply comment deadline for the Company of November 8, 2023.
These Reply Comments address the comments of Commission Staff (Staff) dated November 1,
2023, who was the only party who submitted comments on this matter. Avista appreciates the
thorough review of this matter conducted by Staff and its preliminary support for the need for this
important, multi-year project.
There are many areas of agreement between Staff and the Company. We appreciate Staff’s
support of Avista’s request to defer as a regulatory asset the undepreciated net book value of
exiting meters, natural gas communicating modules (ERTs), and AMR communication equipment,
to be amortized over the remaining depreciable life of the removed equipment. (Staff
Recommendation #1). The same is true for Staff’s support of the proposed depreciation rates for
AMI equipment (Staff Recommendation #3).
With that, there are two issues remaining between Staff and the Company. The first issue
relates to Staff Recommendation # 4 in Staff’s recommendations – denying Avista’s proposal to
defer depreciation expense and earn a return on the installation of the AMI system. Having
RECEIVED
Tuesday, November 7, 2023 9:39:39 AM
IDAHO PUBLIC
UTILITIES COMMISSION

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reviewed Staff’s comments, we can agree to Staff’s position, as it is not ripe for determination at
this time. The Company’s next general rate case is the more appropriate venue for a determination
if such a deferral is appropriate.
The final issue relates to Staff’s Recommendation #2, Staff’s proposed denial of a return
on the AMR deferral account effective with Avista’s next general rate case. To the extent that
Avista places unamortized balances into the proposed deferral account and a return component is
not included, that would result in a potential write-off in the current period of such unrecovered
return. We don’t necessarily think that this is an intended consequence of Staff, nor of the
Commission if it adopts Staff’s position. As such, because the project is in its development stage,
Avista proposes a middle ground for the Commission whereby it can simply state the
determination of whether or not a return component is appropriate is not ripe for determination in
this proceeding, but the issue should be taken up in the Company’s next general rate case. This
would allow time for Avista, Staff, and other interested parties to have more discussions, and a
record, regarding Avista’s AMI project, AMR deferred balances, and other related issues.
Again, the Company thanks Staff for their review of its request in the above referenced
matter. Please direct any questions regarding these comments to me at
[e-mail] or 509-495-8620.

Sincerely,
/s/Patrick D. Ehrbar

Patrick Ehrbar
Director of Regulatory Affairs