20180410Motion for Approval of Addendum to Stipulation.pdf

David J. Meyer, Esq.
Vice President and Chief Counsel of
Regulatory and Governmental Affairs
Avista Corporation
141I E. Mission Avenue
P.O.Box3727
Spokane, Washington 99220
Phone: [phone], Fax: [phone]
Karl Klein
Brandon Karpen
Deputy Attorneys General
Idaho Public Utilities Commission Staff
P.O. Box 83720
Boise, ID 83720-0074
Phone: [phone]l2,Fax: [phone]
IN THE MATTER OF THE APPLICATION )
oF AVTSTA CORPORATION DBA )
AVISTA UTILITIES FOR AUTHORITY TO )
INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC AND NATURAL GAS )
SERVICE IN IDAHO )
RECE IVED
?il18 APR l0 Al,l 9: 05
1il,1,i-13 rLlBLiC
iiT r I-l'i i i: :l COitll lSSl0N
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NOS. AVU-E-I5-05
AVU-G-15-0r
MOTION FOR APPROVAL OF
ADDENDUM TO THE STIPULATION
AND USE OF MODIFIED
PROCEDURE
COMES NOW, Avista Corporation ("Avista" or "Company"), and hereby moves the
Commission for an Order approving the Addendum to the Stipulation. RP 56;272;274. This
Motion is based on the following:
l. On December 18,2015, the Idaho Public Utilities Commission approved a
Settlement Stipulation ("Stipulation") in Avista's 2015 general rate case. Included in the
approved Stipulation were electric and natural gas Fixed Cost Adjustment ("FCA")
Mechanisms, which went into effect on January 1,2016.
Motion for Approval of Addendum to the Stipulation - AVU-E-I5-05 & AVU-G-I5-01 Page I
2. Paragraph l3A of the Stipulation states "The Pafties agree to an initial FCA
term of 3 years, with a review of how the mechanisms have functioned conducted by Avista,
Staff, and other interested parties following the end of the second full-year. Avista may seek to
extend the term of the mechanism prior to its expiration." The term of 3 years expires
December 31,2018.
3. On March 13,2018, Avista reached out via email to all of the parties in these
cases requesting a one-year extension of the FCA Mechanisms in order to benefit from a third-
party study presently being conducted in the State of Washington of the Company's decoupling
mechanisms (similar in most ways to the FCA Mechanisms in Idaho). That study would assist
with the "review" following the "end of the second full-year".
4. All of the parties in these cases agreed to the extension, either in writing or
through telephonic communications, with one exception. Clearwater Paper Corporation chose
not to take a position on this issue.
5. Based on those discussions, the Parties whose signatures appear on the
Addendum to the Stipulation have agreed to resolve and settle the additional issue in the case
(hereinafter "Parties"). A copy of the signed Addendum to the Stipulation evidencing that
agreement is enclosed as Attachment 1.
6. The Parties recommend that the Commission grant this Motion and approve the
Addendum to the Stipulation in its entirety, without material change or condition, pursuant to
RP 274. The Company requests that the matter be processed under the Commission's Modified
Procedure rules through the use of written comments.
Motion for Approval of Addendum to the Stipulation - AW-E-15-05 & AVU-G-15-01 Page2
NOW, I'HEREFORE, the Parties respectfully request that the Commission issue an
order in Case Nos. AVU-E-I5-05 and AVU-G-15-01 granting this Motion and accepting the
Addendum to the Stipulation (Attachment 1), in its entirety, without material change or
condition.
Respectfully submitted this Jday of April,2018
. Meyer
Attorney for Avista Corporation
Motion for Approval of Addendum to the Stipulation - AVU-E-15-05 & AVU-G-15-01 Page 3
David J. Meyer, Esq.
Vice President and Chief Counsel of
Regulatory and Govemmental Affairs
Avista Corporation
l41l E. Mission Avenue
P.O.Box3727
Spokane, Washington 99220
Phone: [phone], Fax: [phone]
KarlKlein
Brandon Karpen
Deputy Attorneys General
Idaho Public Utilities Commission Staff
P.O. Box 83720
Boise, ID 83720-0074
Phone: [phone],Fax: [phone]
IN THE MATTER OF THE APPLICATION )
oF AVTSTA CORPORATION DBA )
AVISTA UTILITIES FOR AUTHORITY TO )
TNCREASE ITS RATES AND CHARGES )
FOR ELECTRIC AND NATURAL GAS )
SERVICE IN IDAHO )
BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NOS. AVU-E-I5-05
AVU-G-15-01
ADDENDUM TO THE STIPULATION
This Addendum to the Stipulation is entered into by and among Avista Corporation, doing
business as Avista Utilities ("Avista" or "Company"), the Staff of the Idaho Public Utilities
Commission ("Staff), Idaho Forest Group, LLC ("ldaho Forest"), the Community Action
Partnership Association of ldaho ("CAPAI"), the Idaho Conservation League ("lCL"), and the
Snake River Alliance ("Snake River"). These entities are collectively referred to as the "Parties,"
and represent all of the parties in the above-referenced cases.l The Parties understand this
Addendum to the Stipulation is subject to approval by the Idaho Public Utilities Commission
("IPUC" or the "Commission").
I Clearwater Paper Corporation ("Clearwater") was a party in the above referenced cases. In an email to the Parties
on March 16,2018, Clearwater stated that it "doesn't have a position on this issue and hence will not vote one way or
the other" when asked for their support ofthis Addendum.
ADDENDUM TO THE STIPULATION - AVU-E-15-05 & AVU-G-15-01 Page I
l. The purpose of the Addendum to the Stipulation is to modify the condition within
paragraph 13, sub-section a, related to the stated term of the Fixed Cost Adjustment (FCA)
mechanism approved by the Commission in Order No. 33437 in Case Nos. AVU-E-I5-05 and
AW-G-ls-01.
a. The present Stipulation laneuage as described in paragraph 13. sub-section a" is as
follows:
FCA Mechanisms Term. The Parties agree to an initial FCA term of 3 years, with
a review of how the mechanisms have functioned conducted by Avista, Staff, and
other interested parties following the end of the second full-year. Avista may
seek to extend the term of the mechanism prior to its expiration.
b. The Parties agree to amend the Stipulation language as follows:
FCA Mechanisms Term. The Parties agree to an initial FCA term of 4 years, with
a review of how the mechanisms have functioned conducted by Avista, Staff, and
other interested parties following the end of the third full-year. Avista may seek
to extend the term of the mechanism prior to its expiration
2. The Parties agree that the Addendum to the Stipulation is in the public interest and
that all of its terms and conditions are fair, just and reasonable. The obligations of the Parties
under this Addendum to the Stipulation are subject to the Commission's approval of this
Addendum to the Stipulation in accordance with its terms and conditions and upon such approval
being upheld on appeal, if any, by a court of competent jurisdiction. This Addendum to the
Stipulation may be executed in counterparts and each signed counterpart shall constitute an
original document.
ADDENDUM TO THE STIPULATION _AVU-E-I5-05 & AVU-G-I5-OI Page2
-ta'/r\
DATED thisd I dayof March,20l8.
Avista Corporation Idaho Public Utilities Commission Staff
B
Corporation Deputy Attorney General
Community Action Partnership Association
of Idaho
Idaho Forest Group
By:
By Attorney for Idaho Forest Group LLC
Attomey for CAPAI
Idaho Conservation League Snake River Alliance
By By:
Attorney for ICL Attorney for Snake River Alliance
ADDENDUM TO THE STIPULATION - AVU-E-15-05 & AVU-G-l5-OI Page 3
I
DATED thisffiday of March, 2018.
Avista Corporation Staff
B
Attorney for Avista Corporation
Community Action Partnership Association
of Idaho
ldaho Forest Croup
B
By:Attorney for ldaho Forest Group LLC
Attorney for CAPAI
Idaho Conservation League Snake River Alliance
B
Attorney for ICL Attorney for Snake River Alliance
ADDENDUM TO THE STTPULATION - AVU-E-I5.05 & AVU.G.Is.OI Page 3
1v
1t {DATED this " " day of March, 2018.
Avista Corporation
By:
Attomey for Avista Corporation
Idaho Public Utilities Commission Staff
By:
Deputy Attorney General
Attomey for ldaho Forest Group LLC
Community Action Partnership Association Idaho Forest Group
ofldaho -
Attornev''2L--' t ;
for CAP
cl /vl ,
AI
li-"" r a,
Idaho Conservation League Snake River Alliance
B
Attomey for ICL Attorney for Snake River Alliance
ADDENDUM TO THE STIPULATION _ AVU-E-I5-05 & AVU-G-l5-OI Page 3
,4
DATED this _ day of Marclr, 20lll.
Avista Corporation
llv:
Attorncy for Avistir CrlrJloration
Conuuunity Action Partncrship Association
of ldaho
Idaho Public Utilitics ('onrnrission .Stal'l'
B
Deputy Altorncy Ge'lrcral
Forest Groun \
K,^Vt*-ldaho
I]Attorncy lbr ldaho Forcst Group LLC
Attorncy for CAPAI
Idaho Consen'ution I-eaguc Snakc River Alliance
B),:
Attorncy for ICL Attorney for Snake Rivcr Alliance
ADDENDUM 'I'O TI.IE S]'IPLILATION _ AVI"J-E- I5.0.5 & AVT'-C;- I5-O I Pagc 3
DATED this 1, day of March,2018.
Avista Corporation Idaho Public Utilities Commission Stafl'
By
Attorney fbr Avista Corporation Deputy Attorney General
Community Action Partnership Association
of ldaho
Idaho Forest Group
By
B)':Attorney for Idaho Forest Group LLC
Attorney for CAPAI
ldaho League Snake River Alliance
By:By
Attorney fbr ICL Attorney for Snake River Alliance
ADDENDUM TO THE STIPULATION _ AVU-E-15-05 & AVU-G-I5-01 Page 3
')
By:
DATED tnisb day of March,20l8.
Avista Corporation
By:
Attorney for Avista Corporation
Community Action Partnership Association
of Idaho
Attorney for CAPAI
Idaho Conservation League
Attorney for ICL
Idaho Public Utilities Commission Staff
By:
Deputy Attorney General
Idaho Forest Group
Attorney for Idaho Forest Group LLC
Snake
lmrnfor Snake River AllianceE7ecufiqllirecgr'rk^"(1 il;lt,
ADDENDUM TO THE STIPULATION _ AVU-E-I5.05 & AVU-G-15.01 Page 3