20230731Application_Cover Letter.pdf

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

July 31, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714

RE: Avista Utilities Request To Decrease Schedule 91, Energy Efficiency Rider
Adjustment

Dear Ms. Noriyuki:

In accordance with Idaho Code §§ 61-501 and -507, and pursuant to Rule of Procedure
(RP) 53 (IDAPA 31.01.01.53), Avista Corporation, dba Avista Utilities (“Avista” or “Company”),
hereby submits for electronic filing with the Idaho Public Utilities Commission (“Commission”)
its Application requesting approval to decrease its electric tariff Schedule 91, “Energy Efficiency
Rider Adjustment” rates, effective October 1, 2023.
If you have any questions regarding this filing, please contact Kim Boynton, Manager of
Energy Efficiency Analytics, at [phone] or [e-mail].

Sincerely,
/s/ Jaime Majure
Jaime Majure
Regulatory Affairs Manager

CASE NO. AVU-E-23-10
RECEIVED
Monday, July 31, 2023 12:53:49 PM
IDAHO PUBLIC
UTILITIES COMMISSION

APPLICATION OF AVISTA - 1
DAVID J. MEYER, Esq.
Vice President and Chief Counsel
Regulatory & Governmental Affairs
Avista Corporation
1411 E. Mission Avenue, MSC 27
P. O. Box 3727
Spokane, Washington 99220
Telephone: [phone]
[e-mail]

Attorney for Avista Corporation

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR
APPROVAL TO DECREASE ITS ENERGY
EFFICIENCY TARIFF RIDER
ADJUSTMENT SCHEDULE 91

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CASE NO. AVU-E-23-__

APPLICATION OF AVISTA

In accordance with Idaho Code §61-502 and RP 052, Avista Corporation, dba Avista
Utilities (“Avista” or “Company”), at 1411 East Mission Avenue, Spokane, Washington, hereby
respectfully applies to the Idaho Public Utilities Commission (“Commission”) for an order
authorizing Avista to decrease to its electric tariff, I.P.U.C. No. 28, Schedule 91, “Energy
Efficiency Rider Adjustment” rates, effective October 1, 2023.
Avista’s Schedule 91 is tariff rider rate adjustment is designed to recover costs incurred
by the Company associated with providing energy efficiency services and programs to
customers. The tariff rider mechanism is intended to match future revenue with budgeted
expenditures; to ensure appropriate recovery, the mechanism includes a true-up feature that
reconciles the previous periods’ actual expenditures and collections. The purpose of this filing is
to establish tariff riders that are sufficient to fund the following twelve months’ expenditures of
the Company’s Electric Energy Efficiency Program, as well as amortize any tariff rider

APPLICATION OF AVISTA - 2
imbalance, thus minimizing the amount of future under- or over-collections. In this filing, Avista
proposes to decrease billed electric rates by approximately 1.2% through proposed revisions in
Schedule 91, with a requested effective date of October 1, 2023. The Company also requests that
this filing be processed under the Commission’s Modified Procedure Rules (RP 201-204).
All communications, pleadings, and orders with respect to this Application should be
directed to:
David J. Meyer, Esq. Patrick Ehrbar
Vice President and Chief Counsel Director of Regulatory Affairs
Regulatory & Governmental Affairs Avista Corp.
Avista Corp. P. O. Box 3727
P. O. Box 3727 1411 E. Mission Avenue, MSC 27
1411 E. Mission Avenue, MSC 27 Spokane, Washington 99220-3727
Spokane, Washington 99220-3727 Telephone: [phone]
Telephone: [phone] E-mail: [e-mail]
E-mail: [e-mail]
Avista Dockets (Electronic Only) - [e-mail]
I. BACKGROUND
Avista’s Schedule 91 funds the Electric Energy Efficiency Programs as described in the
Company’s Schedule 90. All revenue derived through Schedule 91 is applied only to the
provision of electric efficiency services including programs offered by the Company directly,
through designated contractors, or as part of regional electric programs as well as evaluation,
measurement, and verification (“EM&V”). These programs include, but are not limited to,
behavioral programs, low-income weatherization, Northwest Energy Efficiency Alliance
(NEEA) participation, and provision of incentives for various energy efficiency measures such as
appliances, compressed air, HVAC, industrial, lighting, maintenance, motors, shell, and
sustainable buildings. The Company’s programs are based on providing a financial incentive, or
“rebate,” for cost-effective efficiency measures. While several metrics are applied to determine

APPLICATION OF AVISTA - 3
the costs and benefits of these programs, the Utility Cost Test (UCT) and Total Resource Cost
(TRC) test and are most often utilized for purposes of determining cost-effectiveness and to
provide insights into program efficacy.1 Ratios over 1.0 illustrate that benefits exceed costs.
As of June 30, 2023, the current Schedule 91 (electric) tariff rider balance was over $7.3
million overfunded. Overfunded balances indicate that more tariff rider funding was collected
than actually needed to fund the ongoing Energy Efficiency Program operations. This
overfunded balance was driven by two main factors, as described below.
First, from October 2017 to October 2022, the Schedule 91 adjustment rate was designed
to recover a significant underfunded balance resulting from the 2016 and 2017 program years.
During this period, the Company’s Energy Efficiency Program achieved conservation savings of
88,319 MWh, which exceeded its Integrated Resource Plan (IRP) target of 22,399 MWh by
394%. This overachievement resulted in an underfunded balance of approximately $9.6 million
by December 31, 2017. To remedy this deficit, Avista increased its Schedule 91 adjustment
effective October 1, 2017.2 The new rate was successful at recovering the underfunded balance
caused by the 2016-2017 program years, so much so that the Company then decreased this rate
in 2022.3 This Application is intended to further decrease the existing rate, as the current rate
remains inconsistent with the forecasted funding needs of Avista’s Energy Efficiency Program
due, in part, to the residual impacts of the COVID-19 pandemic as noted below.
Second, the effects of COVID-19 continues to permeate utility efficiency programs, with

1 The Total Resource Cost test measures the net costs of an energy efficiency program as a resource option based on
the total costs of the program, including both the participants' and the utility's costs. Further, it includes the impact of
any quantifiable non-energy impacts that may be associated with the equipment installed. In comparison, the Utility
Cost Test measures the net costs of an energy efficiency program as a resource option based on the costs incurred
only by the program administrator (including incentive costs) and excluding any net costs incurred by the
participant. The benefits are similar to the TRC benefits, however, exclude non-energy impacts; costs are therefore
defined more narrowly.
2 Case No. AVU-E-17-06, Final Order No. 33897.
3 Case No. AVU-E-22-09, Final Order No. 35545.

APPLICATION OF AVISTA - 4
lower levels of throughput lingering in the majority of Avista’s Energy Efficiency Program
offerings. In 2020 and 2021, business closures and social distancing requirements resulted in
less-than-anticipated Energy Efficiency Program expenditures. In its 2022 rate adjustment filing,
the Company noted, “While Avista expects its throughput and associated expenditures to
increase in the future, it remains unseen if the lost participation from customers in Energy
Efficiency Programs during 2020-22 will be realized in later years.”4 Avista has continued to
encounter lower customer throughput and barriers to the provision of efficiency services – such
as supply chain issues, higher interest rates, and staff and labor shortages experienced for
contractors as well as partner Community Action Partnership Agencies (CAP Agencies)
administering these services.
Therefore, the Company is proposing to decrease rates collected in Schedule 91 to bring
the forecasted tariff balance close to $0 by September 30, 2026; this approach will provide an
appropriate level of funding for Avista’s Energy Efficiency Program for the next thirty-six
months and minimize the continued overcollection of tariff rider funds over this three-year
period. By extending the collection period over a longer period of time, 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.
IV. REQUEST FOR APPROVAL
Avista is proposing a decrease in the rates and charges in Schedule 91, to become
effective October 1, 2023. The estimated annual revenue change associated with this filing is an
annual decrease of approximately $3.1 million for electric Schedule 91, or a decrease of 1.2% in
overall billed rates. Residential customers using an average of 927 kilowatt-hours per month

4 Case No. AVU-E-22-09, Application at page 4.

APPLICATION OF AVISTA - 5
would see their monthly bills decrease from $85.40 to $84.43, a decrease of $0.97 per month, or
1.1%. Attachment A to this Application provides the corresponding workpapers and rate
calculations for the revisions to the Energy Efficiency Rider Adjustment described herein.
Additionally, the proposed revisions to tariff Schedule 91 are provided as Attachment B to this
filing, including the proposed revisions in legislative format per RP 121.
V. CUSTOMER NOTIFICATION
In conformance with RP 125, this Application will be brought to the attention of
the Company’s customers by way of a Customer Notice, provided as Attachment C to this filing,
which will be included in customer’s bills beginning in early August 2023 and run for a full
billing cycle. Notice will also be given simultaneously with the filing, by posting of the
Application to the Company’s website at myavista.com.
VI. CONCLUSION
Avista hereby respectfully requests the Commission issue its Order finding the proposed
rates and charges in Schedule 91, attached to this Application as Attachment B, to be fair, just,
reasonable and nondiscriminatory, and effective for electric service rendered on and after
October 1, 2023, with this Application processed under the Commission’s Modified Procedure
rules through the use of written comments.
DATED this 31st day of July 2023.
Respectfully submitted,
Avista Utilities
By: ___ /s/ David Meyer______________
David J. Meyer, Vice President and Chief
Counsel for Regulatory and Governmental Affairs