20140815CAPAI Comments.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17ft St.
Boise,lD. 83702
[phone] (Land)
[phone] (Fax)
bmn Lrrc'lr, (/ill-rotma i l. co nr
Attomey for Petitioner
Community Action Partnership
Association of Idaho
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION TO INITIATE
DISCUSSIONS WITH INTERESTED
PARTIES ON AN EXTENSION OF THE
EXISTNG RATE PLAN AND AVOID A
GENERAL RATE CASE
Fl,L:0['i1't {ii-'
201\ AUG I 5 P}{ l: 5lr
','rALi ,'i r:;l '..,.
uT t/lti'i$'ioHr ;"i t ss tc r't
BEF'ORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
CASE NOS. AVU-E-14-05
AVU-G-14-01
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S COMMENTS
)
)
)
)
)
COMES NOW, the Communication Action Parurership Association of Idaho (CAPAD
and in accordance with Commission OrderNo. 33080, issued July 23,2014, submits comments
in support of the Settlement Stipulation executed by, among others, CAPAI and filed with this
Commission.
I. Background:
CAPAI notes that Avista went to considerable lengths to involve and inform all potential
stakeholders, including CAPAI, well in advance of the filing of the Settlement Stipulation now
pending approval, and met individually with each interested stakeholder before the first
settlement conference and before circulating its initial draft of the stipulation to allow for an
open discussion of the Company's objectives and the procedural options for pursuing those
objectives. These meetings were face to face with each stakeholder group and allowed for a
COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO'S COMMENTS
thorough discussion of the Company's proposal as well as questions and concerns posed and held
by stakeholders. The Company met far enough in advance with each stakeholder to allow for
informal discovery, the refinement of stakeholder issues and concerns, and discussions regarding
how to address those issues and concerns in a final, written settlement. In this regard, CAPAI
appreciates Avista's openness and diligent attempts to involve all interested stakeholders from
the outset of this case.
il. CAPAI's Issues and Concerns:
A. Procedure of Settlement Discussions.
With respect to Avista, and at this point in time, CAPAI's primary areas of interest
involve the current status and future of low income weatherization assistance ("LIWA"-both
electric and the possible reinstatement of the natural gas progftrm) and aU related issues as well
as continuing to obtain a better understanding of how many low income customers Avista
actually serves, regardless of whether they receive any form of assistance, as well as those
customers'consumption characteristics and the manner in which their monthly bills are affected
by varying residential rate design possibilities including altering the amount of the customers'
monthly basic service charge, the inverted, tiered rates structure of the residential class and
variations within that latter characteristic and other possibilities.
Pursuant to Order No.32788, issued in Case No. GNR-E-12-01, funding for Avista's low
income weatherization program (LIWA) is no longer necessarily frozen at existing levels. See,
Order No. 32788, p.I3 In addition, CAPAI has had the opportunity over the past two years to
gain a better understanding of low-income consumption pattems that make the impact of
residential rate design less uncertain. Thus, from a procedural standpoint, CAPAI was initially
hesitant to allow the deferral of another general rate case in which it could raise and address
COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO'S COMMENTS
these issues and areas of concern. To its credit, however, Avista made its personnel available to
respond to informal and expedited discovery requests which helped enable CAPAI to determine
the potential negative consequences of forgoing an opportunity to raise its aforementioned
interests and concerns at this time and in this case, balanced against the overall beneficial rate
consequences of the Company's proposal. CAPAI, therefore, had the opportunity to engage in an
expeditious back-and-forth process of advancing its knowledge of the subject matter involved
and make the ultimate determination of whether the proposed settlement was in the best interests
of the Company's low income customers, as well as the general body of ratepayers.
CAPAI also wishes to acknowledge and express its appreciation for the fact that the
Commission Staff made its personnel available for face-to-face meetings as well as numerous
telephone conversations to engage in discussions of LIWA progftlms in general, and Avista's
program in particular, in light of the fact that any suspension of reconsideration of such programs
has expired. It is CAPAI's perception that these meetings and discussions were of considerable
value in terms of understanding numerous aspects of LIWA progftrms, their operation and value
as important resources, and the evaluation of their cost-effectiveness. CAPAI has taken careful
note of Staffs thoughts and suggestions regarding potential means of increasing the cost-
effectiveness of Avista's (and other utilities') LIWA progrcm and has already begun to assess and
potentially apply certain of those thoughts and suggestions and will continue to do so. In that
respect, the Settlement Stipulation was worded such that the benefits of this interaction with
Staffand Avista will continue after this case is closed.
B. Low Income Provision of Settlement Stipulation.
The following language contained in Section IV(F) of the Settlement Stipulation reflects
the involvement of CAPAI in this proceeding and of CAPAI's collaboration with Avista and
COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF TDAHO'S COMMENTS
Staff to continue discussion and assessment of LIWA programs and the analysis of rate design
impacts on low income customers into the near future:
F. Meet and Confer Regarding Low fncome Issues - On or before
October 14,2014, Avista will meet with Commission Staff and other
interested Parties to this case to review the following issues:
1. Cost-effectiveness and appropriate funding of natural gas and electric
demand-side management ("DSM") programs for low-income customers:
Prior to the meeting, Avista will provide the parties with the 2013 DSM
Impact Evaluation prepared by its consultant, Cadmus, as well as current
information pertaining to the cost-effectiveness of its low-income progftrms
in Idaho. In additiorq Avista will provide its analysis of when and under
what conditions natural gas DSM programs will become cost-effective
and program funding resumes.
2. Electri,c and natural gas usage by low-income customers in Avista's
Idaho service territory and potential rate-design implications for such
customers: Prior to the meeting, Avista will provide usage data for its
Idaho residential customers for 20ll-2013. Avista will consult with the
parties to identifr their specific data requirements.
3. No later than December 1,2014, the Parties will determine if a formal
filing with the Commission is warranted based upon review of low-
income DSM progfttm cost-effectiveness and low-income usage.
The foregoing settlement provision was specifically crafted in a collaborative fashion
between CAPAI, Avista and Staff and reflects the general course of action that the parties agreed
was the most effrcacious in terms of moving forward with the operation and evaluation of LIWA
programs to enhance their cost-effective manner without holding up the proposed overall
settlement yet still incorporating timelines to ensure that these issues will be timely addressed.
The low income provision also provides CAPAI with ample opportunity to continue
working with Avista and Staff in better defining and calculating the number of Avista's low
income customers and how differing residential rate design impacts those customers.
COMMTINITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO'S COMMENTS
UI. Conclusion:
Though CAPAI believes that the time is appropriate to reassess ail LIWA progriams,
including Avista's, and though CAPAI believes that there exist inherent dangers in avoiding
general rate cases through ratemaking mechanisms designed solely for that purpose, it is
CAPAI's position that, under the circumstances, the settlemcnt reached by the parties to this case
is fair, just and reasonable and in the best interests of all ratepayers, including low income
customers. CAPAI submits that the time-table outlined in the Settlement Stipulation for
addressing low income issues is reasonable, realistic and will allow for a thorough discussion of
the low income issues outlind in these comments and, therefore, recommends that the
Commission approve the Settlement Stipulation as submitted.
DATED, this l5th day of August,2014
l
COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO'S COMMENTS
CERTIFICATE OT' SERVICE
I hereby certify that I caused to be served the foregoing docume,nt on the following by
either hand delivery or U.S. Mail, first class, and via email:
KellyNorwood
David Meyer
Avista Corporation
P.O.Box3727
Spokane, WA 99220-3727
kelly-norwood@Evistaco{p. com
david. [e-mail]
Dean J. Miller
McDevitt & Miller, LLP
420W. Bannock St.
Boise,lD 83702
j oe@mcdwitt-miller. com
Peter J. Richmdson
Gregory M. Adams
515 N. 27th St.
Boise,ID 83702
[e-mail]
[e-mail]
Benjamin Q6s
710 N. Sixth Stneet
Boise, D 83702
[e-mail]
Ken Miller
P.O. Box 1731
Boise,ID 83701
kmiller@snakeriveralliance. org
Date4 this 15th Day of August,2014
6COMMTJMTY ACTION PARTNERSHIP ASSOCIATION OF IDAHO'S COMMENTS