20151218Reply Comments.pdf

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DAVID J. MEYER
VICE PRESIDENT AND CHIEF COLINSEL FOR
REGULATORY AND GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O.BOX3727
I4I I EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220.37 27
TELEPHONE: (s09)495-4316
david. meyer@ avistacorp. com
IN THE MATTER OF THE APPLICATION )
oF AVISTA CORPORATTON FOR THE )
REQUEST TO RESUME NATURAL GAS )
EFFICIENCY PROGRAMS SCHEDULE 190 & )
INCREASE ITS ENERGY EFFICIENCY RIDER )
ADJUSTMENT SCHEDULE I9I )
RE0ilv!i L)
?01[ DEC lB frl{ l0: 32
u T r Jfi Hs0Cd'r,i'fi i 5 s r o r,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. AVU.G.I5.O3
REPLY COMMENTS
OF
AVISTA UTILITIES
The Company appreciates the thorough review by the Commission Staff of Avista's
proposed revisions to Schedule 190, 'Natural Gas Efficiency Programs" to resume natural gas
energy efficiency programs, and to increase Schedule 191 rates "Energy Effrciency Rider
Adjustment." Avista Corporation ("Avista" or "Company") hereby submits reply comments in
response to the Idaho Public Utilities Commission StafPs ("Staff') comments dated December
10,2015 and from public commentsl.
The Company appreciates the long-standing collaborative working relationship with the
Commission, its Staff and other stakeholders.
The Company has remained committed to a continual re-evaluation of the prospects for
the naflnal gas DSM portfolio and the Company looks forward to reengaging the Idaho natural
I Additional comments filed include one Idaho natural gas customer in support of the Company's application, and
two individuals who are not Avista Idaho natural gas customers, and are therefore not affected by the Company's
application.
AVISTA REPLY COMMENTS PAGE I
gas customers and encouraging them to choose energy efficient options.
2 The Company concurs with the Commission Staff and will implement the following
3 specific recommendations resulting from their review:
4 1. analyze the benefits of natural gas DSM programs defening distribution costs;
5 2. apply a mid-year discount rate to program benefits; and
6 3. strike "from a Total Resource Cost perspective" under "5. Budget & Reporting"
7 in Schedule 190, which Staff has confirmed is acceptable with the Company.
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9 We appreciate the public participation and the comments received in this case. Avista
l0 worked with Commission Staff over the past six months and reached agreement related to the
11 new philosophy around the avoided costs used in the Company's filing. The Company also
12 evaluated peer utilities for best practices in cost-effectiveness testing, and believe our approach is
13 in-line with the practices of others. This new approach was reviewed, vetted and received
14 acceptance from Avista's Energy Efficiency Advisory Group prior to filing with the
15 Commission.
16 The Company is not proposing to do away with the Total Resource Cost (TRC) test; we
17 are simply taking a more balanced, tandem approach to measuring cost-effectiveness of our
18 natural gas portfolio. As provided in the Company's filing, we evaluate our programs under both
19 the TRC and the Utility Cost Test (UCT) and will continue to do so. The Company will continue
20 to report the multiple cost-effectiveness tests (TRC, UCT, Participant Cost Test & Ratepayer
2l Impact Measurement) to demonstrate prudence.
In addition, the Company believes net-to-gross studies can be a useful tool to help
influence program design to ensure that ratepayer funds are being spent prudently on measures
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AVISTA REPLY COMMENTS PAGE 2
I that require utility intervention. Net-to-Gross studies should not be used after the fact to reduce
2 cost-effectiveness. The Company is currently performing surveys with both participants and
3 non-participants in its natural gas progrirms in Washington and the results will be included in
4 future reporting. The Company continues to be committed to work closely with its Advisory
5 Group on how any net-to-gross study influences future natural gas program design.
6 Again, the Company appreciates the long-standing collaborative working relationship
7 with the Commission, its Staff and other stakeholders. We believe these relationships have
8 benefited our customers and all of our stakeholders and have been constructive in refining
9 Avista's DSM programs.
DATED at Spokane, Washington, this lTth day of December 2015.
AVISTA CORPORATION
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By
Kelly O. Norwood,
Vice President, State and Federal Regulation
AVISTA REPLY COMMENTS PAGE 3
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VERIFICATION
STATE OF WASHINGTON
County of Spokane
Kelly Norwood, being first duly sworn, on oath deposes and says: that he is the
Vice President of State and Federal Regulation for Avista Utilities; that he has read the above
and foregoing Application, knows the contents thereoe and believes the
SIGNED AND SWORN to before me this 17tr day of December 2015, by Kelly
Norwood.
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.-.i..$....,,ff&zi i"Elgei ==
?- o.\. PUBLIC ,, S
'a#r;rt
Washington, residing at Spokane.
Commission Expires:
IC in and for the State of
AVISTA REPLY COMMENTS PAGE 4