20110725SRA Comments.pdf

Jean Jewell
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Sent:
To:
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kmiller~snakeriveralliance.org
Tuesday, July 19, 2011 10:39 AM
Jean Jewell; Beverly Barker; Gene Fadness
PUC Comment Form
A Comment from Ken Miller follows:
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Case Number: AVU-E-11-02j AVU-G-11-03
Name: Ken Miller
Address: Box 1731
City: Boise
State: ID
Zip: 83701
Daytime Telephone:
Contact E-Mail: kmiller~snakeri veralliance. org Name of Utility Company:
Acknowledge: acknowledge
Please describe your comment briefly:
Comments of the Snake River Alliance
On the Matter of the Application of Avista Corporation Requesting Approval to Decrease Its
Energy Efficiency Public Purpose Rider Schedules 91 and 191
Case Nos. AVU-E-11-02 and AVU-G-11-03
Submi tted by
Ken Miller, Clean Energy Program Director, Snake River Alliance
July 19, 2011
The Snake River Alliance ("Alliance") appreciates the opportunity to provide comments
relating to the application by Avista Corporation ("Avista") to decrease its Energy
Efficiency Public Purpose Rider for electric and gas service, Schedules 91 and 191, filed
with the Idaho Public Utilities Commission on June 13, 2011.
The Alliance has long been interested in promoting energy efficiency and demand response
energy policies as an alternative to conventional fossil fuel-based energy resources in
Idaho. As such, the Alliance is interested in encouraging local, state, and federal policies
that promote energy efficiency policies and programs at Idaho's regulated electric utilities
to slow the growth of base load and peak energy demands among those utilities. The Alliance
has participated regularly before the Idaho Public Utili ties Commission in furtherance of
these goals. The Alliance submits these comments on behalf of its members, many of whom are
Avista customers who believe that their electric and gas utility should be expanding rather
than potentially contracting its demand side management program funding.
Avista's Application to Decrease its Energy Efficiency Public Purpose Riders is Premature
The Alliance commends Avista's efforts in deploying energy efficiency programs across its
service territory and for achieving significant electricity and natural gas savings. We
support the efforts by all Idaho utilities to maximize their demand side management programs
and to explore new ways to achieve new efficiencies and energy savings, as called for by the
Commission and also by the Idaho Energy Plan, which was adopted by the Idaho Legislature in
its 2007 session.
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However, we believe it is premature for Avista to propose a decrease in its electric and gas
riders, particularly in light of the dearth of supporting information to justify such a
significant move and also Avista's acknowledgment that the current efficiency rider
underfunded DSM programs by nearly $12 million as recently as the beginning of 2010. Each
Idaho electric utility is under a Commission order to pursue "all cost effective" energy
efficiency. Reducing the rider collections at this point, and without sufficient
documentation to show rider funds are being collected at levels in excess of the programmatic
need, appears to be a step backward in Idaho's overdue push to accelerate the deployment of
new energy efficiency and conservation measures.
If granted by the Commission, Avista's requested reduction in its electric Schedule 91 tariff
would lead to a decrease of $750,000 in revenues for DSM programs (Application, P. 6), which
would lead to an anticipated average monthly bill decrease of just six cents. On the gas
side, Commission approval of this application would lead to a decrease of $2.9 million in
rider collections.
Other than noting the under-collections and over-collections for electric and gas efficiency
programs in the past two years, Avista's seven-page application to the Commission fails to
provide evidence that the utility has exhausted its pursuit of all cost-effective energy
efficiency in its electric and gas programs. The application also fails to provide details as
to whether efficiency programs that might survive Commission prudency review have been
considered but not implemented. The application further fails to provide adequate supporting
historic rider data to determine whether the request is warranted. It is simply impossible to
assess the full merits of Avista's request based on two years of rider collection information
and only a cursory review of Avista's DSM programs' performance. The application does not
indicate whether existing programs could be expanded or whether customer participation in
those programs could be increased beyond current levels, nor does it state what the current
participation levels are. The Alliance believes some energy efficiency programs provided by
Idaho utilities might be ripe for expansion in the number of participants, yet a review of
this application does not allow for conclusions as to the successes and potential for
Avista's DSM programs.
Avista Can Minimize the Amounts of Future Under- or Over-Collections
In proposing its rider decrease, Avista says (Application, P. 1) that "The purpose of this
filing is to establish tariff riders that are sufficient to fund the following twelve months
of DSM as well as amortize any tariff rider imbalance, thus minimizing the amount of future
under- or over-collections." Avista says further (Application, P. 2) that "The revenue
expected to be generated by the schedule 91 and 191 surcharges, at their present levels,
would exceed the requirements necessary to fund the DSM task during the next twelve month
cycle, including adjustments for the disposition of tariff rider imbalances. As of the close
of April 2011, Avista's Idaho electric DSM tariff rider balance is $723,240 (Company owes
ratepayer) and the Idaho natural gas DSM tariff rider balance is $897,808 (Company owes
ratepayer) ."
The Alliance agrees that the amounts collected through utility efficiency riders should be
sufficient to cover the expenses of their DSM programs while not rolling up large positive or
negati ve balances in rider accounts. Effective DSM program management should help utili ties
achieve these goals. We question the wisdom of seeking to reduce the funds collected through
the efficiency rider just one year after Avista reported a significant deficiency in its
rider account: "Because customer demand for our energy efficiency services had outstripped
our tariff rider funding, at the beginning of 2010 the tariff riders were underfunded by
$11.9 million (i.e., the Company had fpre-funded' energy efficiency services in advance of
receiving tariff rider funding). In the past year, however, increases to the tariff riders
have allowed for adequate revenue to both fund current energy efficiency operations and to
reduce the underfunded balance to the point where the balances need to be adjusted through a
decrease in the tariff rates."
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We disagree. We are further concerned that rider collections are sensitive to, among other
things, energy consumption, which in turn can vary year-to-year with such circumstances as
weather and economic conditions. Given that it is impossible to know with precision what the
collections will be from one year to the next, a reduction in the rider should only be
considered in the event the rider account has risen to excessive balances over consecutive
years, and that doesn't appear to be the case here. In fact, as mentioned above the
application does not include enough historic efficiency rider account balance information to
determine how the current rider rate has performed over time.
Finally, the Alliance notes that subsequent to the Commission's order establishing the July
19 comment deadline in this case (PUC News Release, July 7, 2011), Avista has filed a motion
for extension with the Commission. That motion cites apparent ongoing discussions between
Avista and Commission staff regarding this case. Inasmuch as Avista has asked for additional
time for these discussions and that it is supported by Commission staff (Avista Motion for
Extension, P. 2), Avista has asked the Commission to delay the expiring comment period in
this case and an extension of the proposed effective dates of Avista's requested electric and
gas rider decreases. We are unsure how those developments might impact the expiring public
comment period established by Commission Order 32278.
The Alliance once again appreciates the opportunity to provide its comments in Case Nos. AVU-
E-11-02 and AVU-G-11-03 and looks forward to engaging in future discussions on how Avista _
and all Idaho electric utili ties - can achieve even greater energy efficiencies than they
currently are.
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ID 83701
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[phone] (c)kmille~snakeri veralliance. org
ww. snakeri veralliance. org
The form submitted on http://www . puc. idaho. gov /forms/ipuc1/ipuc. html
IP address is 70.102.111.178
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