20230913Comments of the Commission Staff.pdf

RECEIVED
2023 September 13 3:33PM
IDAHO PUBLIC
UTILITIES COMMISSIONCHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE RESIDENTIAL
AND SMALL FARM ANNUAL RATE
ADJUSTMENT FILING OF AVISTA
CORPORATION
)
) CASE NO. AVU-E-23-11
)
)
) COMMENTS OF THE
) COMMISSION STAFF __________________ )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Chris Burdin, Deputy Attorney General, submits the following
comments.
BACKGROUND
On July 31, 2023, Avista Corporation d/b/a/ Avista Utilities ("Company") filed an
application ("Application") with the Idaho Public Utilities Commission ("Commission")
requesting an order authorizing the Company to implement Residential and Small Farm Energy
rates for electric service from October 1, 2023, through September 30, 2024. The Company
requests an October 1, 2023 , effective date. Application at 1.
The Company represents that the electric Residential and Farm Energy Rate Adjustment
results from an agreement between the Company and Bonneville Power Administration ("BP A")
that provides a share of the benefits of the federal Columbia River power system to the
STAFF COMMENTS 1 SEPTEMBER 13, 2023
residential and small-farm customers of the six investor-owned utilities of the Pacific Northwest.
Id. at 2.
The Company proposes a Residential and Small Farm Energy Rate Adjustment credit rate
for rate schedules 1, 12, 22, 32, and 48 of 0.366¢ per kilowatt-hour, which represents a $0.2
million, or 0.1 %, increase to qualifying customers. Id. at 1.
The Company represents that under the current Residential Exchange rate adjustment,
approximately $4.93 million annually is being passed through to applicable Idaho customers
through a uniform 0.380¢ per kilowatt-hour ("kWh") rate credit. Id. at 2-3.
The Company represents that the proposed rate credit of 0.366¢ per kWh is designed to
pass through approximately $4.9 million, which represents the Idaho portion of the annual level
of BPA benefits, offset by an over-refunded balance from the prior year, starting in October
2023. Id. at 3. The Company provides the following table detailing the differences between the
current benefits and the proposed benefits.
____________________ Cban___.g.._e_in_Bt_en_efi_t ________ ----------1
Id.
2023 2022
Proposed Prtsent
Idaho poroon of benefit amount S 5,363.249 $ 5.205,238
Load Difference -----------------------
PtOJtc!td kWh 10 1•23 · 9 30 ~4
lute
2023 2022
Propostd Pr=t
1,335,411 ,6-44 1,296,551,531
S (0.00366) S (0.00380)
S (4,887,607) S (4,926,896)
O\"er-refuoded Balance
s 158.011
38,860,114 s U7,668
0.00014
s ! ...... J
s ~18?.321)
The Company represents that residential customers using an average of 927 kWh per
month would see their monthly bills increase from $85.40 to $85.53, an increase of $0.13 per
month, or 0.2%. Id. at 4.
The Company represents that the Application will be brought to the attention of the
Company's customers through a Press Release, as well as Customer Notices that will be included
in customer's bills beginning in early August 2023 and will run for a full billing cycle. Id.
STAFF COMMENTS 2 SEPTEMBER 13, 2023
STAFF ANALYSIS
The Residential and Small Farm Energy Rate Adjustment credit results from the
Company's agreement with BPA regarding the Residential Exchange Program. The Residential
Exchange Program allows residential and small-farm customers of six Pacific Northwest utilities,
including A vista, to benefit from the federal Columbia River power system through a credit to
their rates. The rate credit reflects Idaho's share of BP A 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 0.380 cents per
kWh. The rate was designed to give customers approximately $4.93 million in BPA benefits
through a credit to their energy rates. The proposed rate credit of 0.366 cents per kWh is
designed to pass through approximately $4.9 million which represents the Idaho portion of the
annual level of BP A 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 what was projected
in the Company's 2022 filing. Using the current rate multiplied by the projected kWh for
October 2023 through September 2024, and compared to the proposed rate for that same period,
the Company's proposal is an overall increase of $0.2 million or 0.1 % for qualifying customers.
The calculation of the BP A benefit for residential and small farm customers has two
inputs. The first input is the usage of A vista's residential and small farm customers over the
previous two years, in this case, 2021 and 2022, which is averaged to create an annualized usage.
The second input is the difference between two variables calculated by the BP A every two years,
A vista's Average System Cost rate, and the Priority Firm Exchange Rate. The difference
between these two rates is multiplied by the annualized usage to calculate the BP A benefit to be
passed to qualifying customers for the next two years. Currently, the Company is in year 2 of the
current credit. The BP A credit is allocated between Washington and Idaho based on the actual
usage in each jurisdiction.
A vista's Residential and Small Farm credit is calculated by taking the projected
remaining balance of the BP A benefit from the previous year and adding the BP A 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.
STAFF C OMMENTS 3 SEPTEMBER 13, 2023
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. Staff audited the inputs and
independently recalculated the rate. Staff recommends that the proposed rate of 0.366 cents per
kWh be approved, effective October 1, 2023.
Overall Impact of Four Proposed Filings Effective October 1, 2023
The Company proposed four electric rate adjustments effective October 1, 2023. In this
case, the proposed BPA Residential and Farm Energy Rate Adjustment ("ResEx"), if approved,
will increase the Company's electric revenues by approximately $200,000, 0.1 % increase. The
Company's Power Cost Adjustment ("PCA"), if approved, will increase the Company's electric
revenues by approximately $10.9 million, 4.3% increase. The third proposed filing, the annual
Fixed Cost Adjustment ("FCA"), if approved, will decrease electric revenues by approximately
$1. 9 million, 0. 7% decrease. The final proposed filing, Schedule 91 Energy Efficiency Rider
Adjustment ("EE Rider"), if approved, will decrease electric revenues by $3.1 million, 1.2%
decrease. The net effect of the Company's four filings will increase electric revenues by about
$6.1 million, or 2.4%. The average residential electric customer's monthly bill will increase by
$1.14 or 1.3%. Table No. 1 summarizes the overall impact to electric revenues from the four
filings.
Table No. 1: Summary of Overall Impact to Electric Revenues
Filing Change in Revenues % Change
PCA $10.9 Million 4.30%
FCA ($1.9 Million) (0.70%)
EEE Rider ($3.1 Million) {1.20%)
BPA ResEx $0.2 Million 0.10%
Total $ 6.1 Million 2.40%
STAFF COMMENTS 4 SEPTEMBER 13, 2023
CUSTOMER NOTICE AND PRESS RELEASE
The Company's press release and customer notice were included with its Application.
Staff reviewed the documents and determined both meet the requirements of Rule 125 of the
Commission's Rules of Procedure. See ID APA 31.01.01.125. The notice was included with bills
mailed to customers beginning August 7, 2023, and ending September 7, 2023. The Commission
set a comment deadline of September 13, 2023. 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. Staff recommends that the Commission consider late filed
comments from customers. As of September 12, 2023, no customer comments had been filed.
STAFF RECOMMENDATIONS
Staff recommends that the Commission:
1. Approve the Company's Application and proposed Residential and Farm Energy
Rate Schedule 59 as filed; and
2. Accept and consider any late filed comments from customers.
Respectfully submitted this 13th day of September 2023.
~~~for
Deputy Attorney General
Technical Staff: Ty Johnson
i:umisc/comments/ avue23. l l comments
STAFF COMMENTS 5 SEPTEMBER 13, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF SEPTEMBER 2023,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TO AVISTA
CORPORATION, IN CASE NO. AVU-E-23-11, BY E-MAILING A COPY THEREOF
TO THE FOLLOWING:
PA TRICK EHRBAR
DIR OF REGULA TORY AFFAIRS
AVISTA CORPORATION
PO BOX 3727
SPOKANE WA 99220-3727
E-mail: [e-mail]
[e-mail]
DA YID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPOKANE WA 99220-3 727
E-mail: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE