20191209Comments.pdf

EDWARD JEWELL
MATT HUNTER
DEPUTY ATTORNEY GENERALS
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]/ [phone]
IDAHO BARNOS. 10446/ 10655
Street Address for Express Mail
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Conrmission Staff
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2016-2017 ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRET)
CASE NO. AVU.E.I8.I2
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR A
DETERMINATION OF 2OI 4-2017 NATURAL
GAS ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED
CASE NO. AVU.G-I8-08
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attomeys of
record, Edward J. Jewell and Matt Hunter, Deputies Attorney General, submits the following
comments.
BACKGROUND
On November 16, 2018, Avista Corporation ("Company") filed two Applications with
the Commission. The first Application, Case No. AVU-G-18-08, requested the Commission
determine whether the Company prudently incurred $2,899,525 in natural gas energy efficiency
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STAFF COMMENTS DECEMBITR 9. 2019
RECEIVED
,il9 0EC -9 Pl{ l: 0l
,, 'i;::iiJ$?'hlEsrox
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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expenses from January l, 2014 through December 31,2017. The second Application, Case
No. AVU-E-18-12, requested the Commission determine whether the Company prudently
incurred $22,719,204 in electric energy efficiency expenses in2016 and 2017 .
The Commission issued Notices of Application and set intervention deadlines for both
cases in December20l8. Order Nos. 342l0 and 34222. Over the next nine months,
Commission Staffworked closely with the Company to determine whether the Company's
energy efficiency expenses were prudently incurred. Staff performed two on-site audits and filed
multiple rounds of production requests.
On September l'7,2019, the Commission issued Notices of'Modified Procedure for Case
Nos. AVU-E-I8-12 and AVU-G-18-08, setting identical deadlines for comments and reply
comments in both cases. The comment deadline was Novembcr 18, 2019, and the reply
comment deadline was December 3, 2019. Order Nos.34444 and 34446.
On November 5, 2019, Commission Staff began settlement negotiations with the
Company at the Company's request. Staff notified the Commission Secretary of the settlement
negotiations, as required by Commission Procedural Rule 272, IDAPA 31.01.01 .272, md
requested the Commission extend the deadlines fbr an additional three weeks to facilitate the
settlement negotiations. On November 18,2019, the Commission issued two Notices of
Comment Deadlines, setting a December 9,2019 comment deadline and a December 23,2019
reply comment deadlinc in both cases. Order Nos. 34489 and 34487.
STAFF ANALYSIS
Staffand the Company have reached a settlement in principle, and Stalf believes the
settlement will be ready to file soon. Staff believes a settlement with the Company will
potentially address reporting and program management problems that have made the Company's
prudency cases challenging for a number ofyears. StalFwill scek ajust and reasonable
settlement and, if reached, request the Commission set new comment deadlines lbr the panies
and the public to provide feedback on the proposed settlement.
STAFF RXCOMMENDATION
Staff recommends the Commission authorize a sccond round of comments alier a
settlement with the Company has been reached and presented to the Commission.
2STA}.'I'COMMENI'S DECEMBER 9, 20I9
- t<*
Respectfu lly submitted this day of December 2019.
e-la*
Edrvard Jr Jelvell
f)eputy Atib ney General
Matt Hunter
Deputy Attomey General
i:umisc:comments/a!'ue I 8. l2_avug l8.8e imh comments
JSTAFF COMMENTS DECEMBER 9,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9th DAY OF DECEMBER 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NOS. AVU.E.I8.I2 AND AVU.G.I8.O8, BY MAILINC A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
E-MAIL: I avistaco .com
LINDA GERVAIS
MGR REGULATORY POLICY
AVISTA CORPORATION
POBOX3727
SPoKANE WA.99220-3727
DAVID J MEYER
VP & CHIEF COLTNSEL
AVISTA CORPORATION
PO BOX 3727
SPoKANE WA99220-3727
E-MAIL: clavid.mcvcrtiiar.istacorp.cout
RE Y
S
avi stadockets(D4vistacojp.corn
CERTIFICAl'L OF SERVICE