20210129Application.pdf

Janua{y 28,2021
N{s. JanNoriyuki
Commission Secretary
ll33l W. ChindenBlvd
Building 8, Suite 201-A
Boise, D 83714
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RE 28
Case Nos. AVU-E-21-01 and AVII-G-21-01
Enclosed for filing with the Commission are an original and seven copies of anApplication by Avista Corporation, dba Avista Utilities (Avista), dated Jimary 2t,2021 for approval of revised electric and natural gas rates. Avista has also included forfiling eight copies of its prepared direct testimony, and exhibits in support of its revised
rates, as well as three copies of workpapers showing how test period data were adjusted.Finally, the court reporter copy is provided on a thumb drive with all documents in Word
format.
Please note that certain workpapers of Clint G. Kalich and David Howell are beingprovided in electronic format only due to the voluminous nature of these files.Computer-readable copies of the testimony, exhibits, and workpapers, required under
Rule 231.05, are included on the attached thumb drive.
Attached to the Application is the form of Customer Notice and form of press Releaseto be issued by the Company. Additionally, Avista has included the Attorney'sCertificate and Claim of Confidentiality Relating to Portions of Avista's Exhibits andWorkpapers.
Please direct any questions related to the transmittal of this filing to Liz Andrews at509-495- 8601.
Sincerely,
Meyer
Vice President and Chief Counsel
for Regulatory & Governmental Affairs
Enclosures
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 28th day of January, 2021, served the foregoing
application, and Avista's Direct Testimony and Exhibits in Case Nos. AVU-E-21-01and AVU-
G-2 I -0 I , upon the following parties from the last general rate filing, by mailing a copy there o f,
properly addressed with postage prepaidto:
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd
Building 8, Suite 201-A
Boise, lD 83714
jan.noriy uki(Epuc.idaho.sov
Karl Klein
Deputy Attorney s General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
[e-mail]
Lany Crowley
The Energy Strategies Institute, Inc
3738 S. Harris Ranch Ave.
Boise,ID 83716
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dread ins@m indsprin g.com
John Hammond
Deputy Attorney s General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
John.hammond(Epuc.idaho.qov
Brad M. Purdy
Attorney atLaw
2019 N 17th Street
Boise,ID 83702
[e-mail]
Peter J. Richardson
Greg M. Adams
Richardson Adams
515 N. 27th Street
POBox72l8
Boise, ID 83702
peter@ richardsonadam s. com
qree@richardsonsdams. com
Ronald L. Williams
Williams Bradbury, P.C.
P. O. Box 388
802 W. Bannock, Suite Lp 100
Boise,ID 83702
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise,ID 83702
botto @ idahoconservatio n.o rq
Te.ry Borden
Malisa Maynard
Clearwater Paper Corpo ration
601 W. Riverside, Suite I100,
Spokane, WA 99201
Terrv. [e-mail]
m a I isa. mav nard@c learwate rpape r. c
Vicki M Baldwin
Parsons Behle & Latimer
Walmart,Inc.
201 S. Main Street, Suite 1800
Salt Lake Ciry, Utah 84111
v baldwin@.parsonbehle. com
ste pth. chriss@.wa lmart. com
/S/ Paul Kim
PaulKimball
Managerof Compliance & Discovery
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O.BOX3727
141 I EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220 -37 27
TELEPHONE: [phone]
FACSIMILE: (s09) 49s-8851
DAVID. MEYER@AVISTACORP. C OM
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTI{ORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC AND
NATURAL GAS CUSTOMERS IN
)
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CASE NO. AVU-E-2I.OI
CASE NO. AVU-G-2I.O I
APPLICATION OF AVISTA CORPORATION
(ELECTRIC AND NATURAL GAS)
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Application is hereby made to the Idaho Public Utilities Commission for an Order
grantingAvista Corporation (Applicant, Company, orAvista)the authorityto increase its
rates and charges for electic and natural gas service to electric and natural gas customers
in the State of ldaho, to be effective on September l,2al and Septemb er 1,2022.
Inthis filingAvista is requesting a Two-YearRate Plan with a Rate Year I electric
base rate relief of $24.8 million (10.1 percent) and natural gas base rate relief of $0.1
million (0.1 percent), effective September 1,2021. This is before the effect of the Tax
Customer Credit Tariff Schedules 76 (electric) and 176 (natural gas). The Company ls
also requestinga Rate Year 2 electric base rate relief of $8.7 million (3.2percent) and
natural gas base rate relief of $ 1.0 million (2.2 percent), effective September 1,2022.
This is before the effect of the Defened Depreciation Credit Tariff Sche dule 177 (natural
gas).
As discussed further in the Company's filing, Avista separately filed with this
Commission on Octobe r 30, 2020 aTax AccountingApplication requesting authorization
to change its accounting for federal income tax expense from a normalization method to
a flow-through method for certain plant basis adjustments.l Approval of the Company,s
application would provide immediate benefits to customers, which Avista is requesting
approval to defer, and to begin amortization through separate tariff those benefib
concurrent with the effective date of this GRC.2
The proposed amortization by the Company of the electric tax benefits ($31.3
million), beginning September 1,2021through separate "Tax Customer Credif'Tariff
I Case Nos. AYIJ -E-20 -12 and AW-G-20-07.2 On Decemb u3l,Zl2l,CommissionStafffiledcomments supportingtheCompany's applicationas fibd.
Application of Avista Corporation
Case Nos. AVU-E-21-01 & AVU-G-21{l Page 1 of 15
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Schedule 76 (electric) of $24.8 million, offsets the Company's base electic rate relief
requested in its entirety for Rate Year I (September 1,2021) until approximably
November 30,2022. The resultis no billed impactto electric customers forthe Rate year.
I increase. Customers would, however, see a bill increase for Rate year 2, effective
September 1,2022 of 3.5 percentor $8.7 million.
For natural gas customers, the Companyproposes to begin amortizingthe natural
gas tax benefits ($12.1 million) beginning September l,2021 over a l0-vear oeriod.
through separate "Tax Customer Credif' Tariff Schedule 176 (natural gas) of
approximately $1.2 million annually. This would offsetthe slight increase in Rate year
I ($0.1 million) and result in an overall reduction for natural gas customers of
approximately l.Spercentatthattimeonabilledbasis. Inaddition,forRate year2,frte
Company proposes to amortize its "Natural Gas Deferred Depreciation Expense,, balance
of approximately $0.9 million for one-year effective September l,2)22through August
31,2023, offsettingthe proposed $1.0 million increase through Separate ,,Defened
Depreciation Credif' Tariff Schedule 177. Customers would therefore see an overall
slight bill impact effective September 1,2022 of 0. I percent.
In support of this Application, Applicant states as follows:
I.
The name of the Applicant is Avista Corporation, dba Avista Utilities, a
Washington corporation whose principal business office is 141 1 East Mission Avenue,
Spokane, Washington, which is qualified to do business in the State of Idaho. Avista
maintains district offices in Sandpoint, Coeur d'Alene, Moscow, and Lewiston, Idaho.
Communications in reference to this Application should be addressed to the following:
Application of Avista C.orporation
Case Nos. AVU-E-2I-01 & AVU-G-21{ I Page 2 of l5
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David J. Meyer, Esq.
Vice President and Chief Counsel for
Re gu latory & Governmental Affairs
Avista Corporation
P.O.Box3727
l4l1 E. MissionAve
Spokane, WA 99220-3727
Phone: [phone]
David.Mev vistacom.com
Patrick D. Ehrbar
Director of Regulatory Affairs
Avista Utilities
P.O.Box3727
I4ll E. Mission Ave
Spokane, WA 99220-3727
Phone: [phone]
pat. e h rbar@ avistacorp.co m
Electro n ically - Av istaDockets(OAvistacorp.com
Avista is a public utility primarily engaged in the generation, transmission and
distribution of electric power and the distribution of natural gas in certain portions of
eastern and central Washington, northem Idaho, as well as distribution of natural gas in
northeast and southwest Oregon. The Company is subject to the jurisdiction of this
Commission, the Washington Utilities and Transportation Commission, the public Utility
Commission of Oregon,the MontanaFublic Service Commission,andtheFederalEnerg,
Regulatory Commission.
III.
Applicant's existing base rates and charges for electric service were approved as
a result of the Commission's OrderNo.34499,dated November 29,2019, in Case No.
Application of Avista Corporation
Case Nos. AVU-E-21-01 & AVU-G-2I-01 Page 3 of l5
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1 AVU-E-19-04. The existing rates and charges forelectric service on file with the
2 Commission (designated as Applicant's TariffNo. 28) are incorporated herein as thougfr
3 fully attached hereto.
4 IV.
5 Applicant's existing base rates and charges for natural gas service were approved
6 asaresultoftheCommission'sOrderNo.33953,datedDecember28,2017,inCaseNo.
7 AVU-G-17-01. The existing rates and charges for natural gas service on file with the
8 Commission (designated asApplicant's TariffNo.ZT)are incorporatedhereinasthougfr
9 fully attached hereto.
lo v.
I I The electric and natural gas rates and charges which Applicant desires to have tre
12 Commission approve are filed herewith as Exhibit A. Also included in Exhibit A are
l3 copies of the tariff schedules showing the proposed changes by striking over the existing
14 rates and underliningthe proposedrates. Company witness Mr. Miller fully describes in
l5 his testimony and exhibits the proposed changes.
16 vr.
17 The circumstances and conditions relied upon, andjustification for, the approval
l8 of the proposed increase in rates for electric and natural gas service are as follows:
19 Applicant's present electic and natural gas rates will not produce sufficient
20 revenue to provide operating income required to allowthe Applicantthe opportunity to
2l earn the 7 .30% rate of retum being requested and supported in this Application.
22 The Applicant's last electric and natural gas general rate case change (Case Nos.
Application of Avista C.orporation
Case Nos. AVU-E-2I-01 & AVU-G-2141 Page 4 of l5
1 AVU-E-I9-04 and AVU-G-17-01) in Idaho was effective in December20lg andJanuary
2 2019, respectively.
3 The primary factors driving the Company's electric and natural gas revenue
4 requirements in Rate Year I and Rate Year 2 is an increase in net plant investrnent
5 (including return on investment, depreciation and taxes, and offset by the tax benefit of
6 interest) from that currently authorized. For Rate Year l, electric net power supply
7 expenses also contribute significantly to the incremental electric revenue requirement
8 Otherchangesimpactingthe Company'srevenuerequirementrequestsrelateto increases
9 in distibution, operation and maintenance (O&IO, and administative and general
10 (A&G) expenses for both electric and natural gas operations, compared to current
l1 authorized levels. Unless the increased rates as requested in this filing are approved,
12 Applicant's rates will not be fair, just and reasonable and it will not have the opportunity
l3 to realize a fair rate of return on its investment.
14 Applicant's evidence in support of its need for increased electric and natural gas
15 rates is based on a l2-month ended December 31,2019 testyear. Applicant's rate base
16 evidence is presented on an average-monthly-average basis for each respective Rate year.
17 Documentation showing how the test year datawas adjusted is provided in the testimony
l8 and exhibits of Companywitness Ms. Andrews.
19 Applicant provides utility service in states other than Idaho. A jurisdictional
20 separation of all investments, revenues and expenses allocated or assigned in whole or in
2L part to the Idaho utility business regulated by this Commission is described in the
22 testimony and exhibits of Ms. Andrews.
Application of Avista C.orporation
Case Nos. AVU-E-2I-01 & AVU-G-21 4l Page 5 of l5
1 VII.
2 Applicant's evidence will show that an overall rate of retu mof 7 .30o/o is fair, just
3 and reasonable. The Company's exhibits and testimony support an increase in retail
4 electric and natural gas revenue of $24.8 million and $0.1 million, respectively, for Rab
5 Year I (September 2021through August 2022) and $8.7 million and $1.0 million,
6 respectively,forRateYear2(September2022throtghAugust2023). Simultaneouswidt
7 the filing of this Application, Applicant has filed its prepared direct testimony and
8 exhibits in support of its revised rates, as well as workpapers showing how test ye ar dffi,
9 were adjusted.
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I I A complete justification of the proposed increases in electric and natural gas rates
12 is provided in the testimony and exhibits of Company witnesses. These witnesses and a
I 3 brief summary of their testimony are as follows.
14 Mr. Dennis P. Vermillion, President and Chief Executive Officer of Avist4
15 presents the Company's policy testimony and provides an overview of Avista
16 Corporation. HewillprovideanoverviewoftheCompany'sproposalinthisfilingfora
17 Two-Year Rate Plan and address why the Company is filing a general rate case at this
l8 time given the COVID-I9 pandemic. He summarizes the Company's proposal in this
l9 filing, and addresses ourcontinuingcapital inveshnent, which continuesto be the primary
20 driver behind the Company's most recent general rate cases. He also discusses the
2l Company's proposal to offset the revenue requirement approved for Rate year I in this
22 case with a Tax Customer Credig resulting in no bill impact for electic customerg and a
23 reduction in billed rates fornatural gas customers, beginning September l,20Zl . La6;r,
Application of Avista Corporation
Case Nos. AVU-E-2l-01 &AVU-G-2141 Page 6 of l5
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he discusses Avista's ongoing focus on cost management and cost efficiencies which
have been undertakento help mitigate the overall rate reques! as well as our continued
focus on communicating with customers, our overall customer satisfaction, and our
customer supportprograms. Finally, he introduces the other Company witnesses who
support this general rate case filing, which is duplicated below.
Mr. Mark Thies, Executive Vice President, Chief Financial Officerand Treasurer,
will provide a financial overview of Avista Corporation as well as explain our credit
ratings and the Company's proposed capital structure and overall rate of return in this
case. In brief, he provides information that shows:
1. Avista's plans call for a continuation of utility capital investments in
generation, transmission, electric and natural gas distribution systems and
technology to preserve and enhance service reliability for our customers,
including the continued replacement of aging infrastucture. capital
expenditures of approximately $405 million peryear (system) are planned for
the five-yearperiod endingDecember 31,2024. Avista needs adequate cash
flow from operations to fund these requirements, together with access to
capital from external sources underreasonableterms, on a sustainable basis.
2. we are proposing an overall rate of return of 7.30 percent, which includes a
50 percent common equlty ratio, a 9.90percent return on equity, and a cost of
debt of 4.70 percent. We believe our proposed overall rate of return of 7.30
percent and the proposed capital structure provide a reasonable balance
between safety and economy.
3. Avista's corporate credit rating from stand ard & poor's (s&p) is currently
BBB and Baa2 from Moody's Investors Service. Avista must operate a! a
level that will support a solid investnent grade corporate credit rating in orderto access capital markets at reasonable rates. A supportive regulatory
environment is an important consideration by the rating agencies when
reviewingAvista. Maintainingsolid creditmetics and credit ratings will also
help support a stock price necessary to issue equity under reasonable terms to
fund capital requirements.
Application of Avista Corporation
Case Nos. AVU-E-2l-01 & AVU -c-2141 Page 7 of l5
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Mr. Adrien McKenzie. as President of Financial Concepts and Applications
(FINCAP), Inc., has been retained to present testimony with respect to the Company's
costof common equity. He concludesthat:
To reflecttherisksandprospectsassociatedwithAvista'sjurisdictionalutility
operations, his analyses focus on aproxy goup of l8 utilitieswith comparable
invesftnent risks.
Because investors' required return on equity is unobservable and no single
method should be viewed in isolation, he appliesthe DCF, CAPM, ECAPM,
and risk premium methods to estimate a fair ROE for Avista, as well as
referencing the expmted earnings approach.
Based on the results of these analyses and giving less weight to extremes at
the high and low ends of the range, he concludes that the cost of equity for the
proxy goup of utilities is in the 9.4 percent to 10.8 percent range, or 9.5
percent to 10.9 percent after incorporating an adjustment to account for tre
impact of common equlty flotation costs.
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o As reflected in the testimony of Mark T. Thies, Avista is requesting a fair ROE
of 9.9 percent, wh ich is below the 1 0.2 percent midpo int of his recommended
range. Considering capital market expectations, the exposures faced by
Avista, and the economic requirements necessary to maintain financial
integrity and support additional capital investment even under adverse
circumstances, it is his opinion that 9.9 percent represents a reasonable ROE
forAvista.
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Mr. Rvan Krasselt, Vice President, Controller and Principal Accounting Officer,
addresses the Company's application3 filed with the Idaho Public Utilities Commission
("Commission") on October 30,2020 (Case Nos. AVU-E-20-12 and AVU-G-20-07),
requesting authorization to change the Company's accounting for federal income tax
expense from the normalization method to a flow-through method for certain plant basis
3 The Companyhasrequestedin its Tax Accourting Application approval ofthe change in accounting and
thedeferralofbenefits,onorbeforel\4ay l,202l,toensureapprovalfromallthreejurisdictionsisreceived
in time to apply this change andretumthe customerbenefits in each stateeffectivewith eachgenenlmte
case.
Application of Avista Corporation
Case Nos. AVU-E-2I-01 & AW-G-2141 Page 8 of l5
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adjustments, includinglndustry DirectorDirective No. 5 (IDD #5) and meters. He will
specifically address the IRS normalization requirements versus flow-through
requirements related to these plant basis adjusfrnents, also referred to as non-protected
assets. Avista is currently calculating federal income taxes utilizing the normalization
method for the majority of plant-related temporary book-to-tax differences. He will
describe the proposal by Avista to utilize the flow-through method on certain plant basis
adjustnents, which will provide immediate benefits to customers.
Ms. Elizabeth Andrews, Senior Manager of Revenue Requirements, will
generally cover accounting and financial data in support of the Company's Two-Year
Rate Plan for the period September | ,2021 through August 3l ,2023 . She will explain
pro formed operating results, including expense and rate base adjustments made to actral
operating results and rate base. In addition, she incorporates the ldaho-share of the
proposed adjustments of other witnesses in this case. In addition to discussing the
Company's needed rate relief, she will discuss the Company's requests in this case
associated with its Wildfire Resiliency Plan ("Wildfire Plan") and discuss the Company's
proposal to establish a Wildfire expense balancing account to track wildfire expenses
during the 10-year Wildfire Plan. Finally, she will discuss, along with Company witness
Mr. Krasselt, the Company's Tax Accounting Application and proposed Tax Customer
Credit.
Mr. Kellv Maealskv, Director of Products, Services, and Customer Technolory,
will provide an overview of the Company's "Customer at the Center" initiative as
discussed by Mr. Vermillion, and address the rationale for the projects that we have
included in this rate case overthe Two-YearRate Plan.
Application of Avista C.orporation
Case Nos. AVU-E-21-01 & AVU-G-2l{l Page 9 of l5
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Mr. Jason Thackston, Senior Vice President of Energy Resources and
Environmental Compliance Officer, provides an overview of the Company's recently
announced I 00 Percent Clean Electricity goal by 2045, carbon neutral electicrty supply
by the end of 2027, and why it is important to our Company. He will also provide an
overview of Avista's resource planning and power supply operations. This overview
includes summaries of the Company's current and future resource plans, as well as an
overview of the Company's Enerry Resources Risk Policy. He will address the
generation-related capital projects included in this case, including capital additions
associated with the Company's investment in Colstrip Unit Nos. 3 and 4 for the periods
2020 through August 2023. His testimony will conclude with a discussion of the
Rattlesnake Flat Wind Power Purchase Agreement.
Mr. Scott Kinney. Director of Power Supply, provides an overview of Avista's
evaluation and decision to join the Western Energy Imbalance Market (EIM) operated by
the California Independent System Operator (CAISO). He provides an overview of tre
current cost estimates associated with joining the EIM, including a brief description of
Operation and Maintenance Costs (O&M), as well as a detailed description of Capital
costs we have included in this rate case over the Two-Year Rate Plan.
Mr. ClintKalich, Managerof Resource Planning& Power Supply Analyses, will
explain efforts the Companyhas made to simplify its power supply adjustment, providing
for better transparency and easy discovery for the Parties and a reasonable level of
expense in this case. His testimony will include documentation of the rationale for key
inputs and assumptions drivingpower supply cost values including loads, natural gas and
electricity prices, and a comparison to the current level of authorized power supply
Application of Avista Corporation
Case Nos. AVU-E-21-01 & AVU-G-21{1 Page l0 of l5
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expense. Finally, he will identify and explainthe proposed pro formaadjustments to tre
2019 test period power supply revenues and expenses, including the Retail Revenue
Credit used in Power Cost Adjusfrnent (PCA) deferral calculations.
Mr. Jeff Schlect, Senior Manager, FERC Policy and Transmission Servrces,
presents Avista's transmission revenues and expenses included in the Company's request
for rate relief over the Two-Year Rate Plan effective September 1,202I and ending
August 31,2023.
Ms. Heather Rosentrater, Senior Vice President of Enerry Delivery and Shared
Services, will provide an overview of the Company's electric and natural gas enerry
delivery facilities, electric reliability trends and areas of focus, and explain the facton
driving our continuing investnent in electric distribution infrastructure. She will explain
how our efforts to maintain the asset health and performance of our electric transmission
system, including compliance with mandatory federal standards for tansmission
planning and operations, is driving a continuing demand for new investment. Further, she
will describe why our investnents in natural gas distribution are necessary in the time
frames completed and why each capital invesfrnent in our operations facilities and fleet
operations is needed to support the efficient delivery of service to our customers, today
and into the future.
Mr. David Howell, Director of Electric Operations and Asset Maintenance, details
the Company's response to the increasing threat of wildfires within Avista's service
teritories by proactively implementing its Wildfire Resiliency Plan. Avista's Wildfire
Resiliency Plan reflects the Company's 130-year operating history combined with recent
efforts to quantify and respond to the financial, safety-related, and service reliability risks
App lication of Avista C,orporation
Case Nos. AVU-E-21-01 & AVU-G-2141 Page ll of15
I associated with wildfires. Finally, he addresses the incremental costs, both capital and
2 O&M, associated with the Company's Wildfire Plan included in the Company's request
3 for rate relief overthe Two-Year Rate PIan.
4 Mr. James Kensok, Vice President and Chief Information and Security Officea
5 provides an overview of,and discusses costs associated with, the Company's Information
6 Service/Information Technology (IS/IT) programs, projects and security. These cosb are
7 comprised of the capital investments for a range of IS/IT projects that support systems
8 used by the Company, as well as cyber and physical security projects and costs. He
9 explains why our informationtechnology and security investrnents are necessary in the
l0 time frames indicated and why investments in technology are necessary. In addition, he
I I describes the capital additions, and incremental expenses, associatedwith the Company,s
12 IS/IT costs included over the Two-Year Rate plan.
13 Ms. Jodv Morehouse, Director of Gas Supply, discusses Avista's natural gas
14 resource planning and procurement process, as well as provides an overview of the
15 Company's 2018 Natural Gas Integrated Resource plan.
16 Ms. Kavlene Schultz, Manager of Regulatory Affairs, describes the Company,s
17 restated twelve-months ended December 3l,2}lg net plant from average-of-monthly-
l8 averages (AMA) to end-of-period (EOP) adjustment, as well as explain how pro forma
19 capital additions for the period of January 1,2020 through August 31,2023 arc
20 incorporated into the Company's Two-Year Rate Plan and proposed electric and natural
2l gas revenue requirements.
22 Ms. Tara Knox, Manager of Regulatory Accounting Initiatives, covers the
23 Company's electric cost-of-service study performed forthis proceeding. Additionally,
Application of Avista C.orporation
Case Nos. AVU-E-2I -01 & AVU-G-2 I { I Page 12of15
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she is sponsoringthe electric revenue normalization adjusfrnents to the test year results
of operations.
Mr. Joel Anderson Regulatory Analyst covers the Company's natural gas cost-
of-service study performedforthisproceeding. Additionally, he is sponsoringthe natural
gas revenue normalization adjustrnents to the testyear results of operations.
Mr. Joseph Miller, Senior Manager of Rates and Tariffs, discusses the spread of
the proposed20?l and2022 electric and natural gas base revenue increases amongthe
Company's electric and natural gas general service schedules. His testimony will also
describe the changes to the rates within the Company's electric and natural gas service
10 schedules and the implementation of the new Tax Customer Credit Rate Schedules 76
1 1 and 17 6 and the new natural gas Deferred Depreciation Credit Schedule 177 .
T2 IX.
l3 Avista has provided under separate cover an Attornev's Certificate And Claim Of
14 Confidentialitv RelatineTo Portions Of Avista's Exhibits and Workpapers pursuantto
15 Idaho Code Section 9-340D andIDAPA 31.01.01.067 and31.01.01.233.
t6 x.
17 Notice to the public of the proposed rates and charges, pursuant to IDAPA
18 31.01 .01.125, will be given to customers by distributing a customer notice, as a bill
19 stuffer, to each customer over a billing cycle (estimated to run from February 3, 2027
20 through March 3,2021), and by a news release, both of which are attached as Exhibit B.
Application of Av ista C-orporation
Case Nos. AVU-E-21-01 &AVU-G-2141 Page 13 of l5
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Portions of the Company's Application and accompanyingtestimony and exhibib
are based on computer models. Documentation and explanation on some of the models
have already been provided to Commission Staff. Additional documentation and
explanation are provided with testimony, exhibits and workpapers in this filing. Further
information can be provided upon request.
xII.
The Applicant stands ready for immediate consideration of this Application.
WHEREFORE Applicant requests the Commission issue its Order finding the
proposed rates and charges to be fair, just, reasonable and nondiscriminatory. The
Applicant is also requesting that the Commission suspend the Applicant's filing with a
proposed effective date of September 1,2021. Under the Company's Two-Year Rate
Plan proposal, the suspended tariffs for Rate Year2 would go into effect on September
1,2022, as stated on those tariff sheets.
DATED at Spokane, Washington, this 28m day of January 20ZL
AVISTA CORPORATION
By:
DavidJ
Vice President and Chief Counsel for
Regulatory & Govemmental Affairs
Avista Corporation
Application of Avista Corporation
Case Nos. AVU-E-21-01 & AVU-G-21{ I Page 14ofl5
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STATE OF WASHTNGTON )
ss
CountyofSpokane )
David J. Meyer, being duly sworn, on oath deposes and says:
That he is the Vice President and Chief Counsel of Regulatory and Governmental Affairs
of Avista Corporation;
That he has read the foregoing Application, knows the contents thereof, and believes tre
same to be true.
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l3 David J. Meyer
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16 Subscribed and sworn to before me this 28th day of January 2021
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Notary Public in and forthe State
Washington, residing in Spokane
Application of Avista Corporation
Case Nos. AVU-E-2I-01 & AVU-G-2141
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Page 15 of 15
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O.BOX3727
I41I EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220 -37 27
TELEPHONE: (s09) 49s-4316
FACSIMILE: (509) 495-885 I
DAVID. MEYER@AVI S TAC ORP. COM
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN
OF IDAHO
BET'ORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
)
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CASE NO. AVU-E-2I-OI
CASE NO. AVU-G-21.01
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO PORTIONS
OF AVISTA'S EXHIBIT'S
AND WORKPAPERS
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FOR AVISTA CORPORATION
I, David J. Meyer, represent Avista Corporation. I am Vice President and Chief
Counsel for Regulatory and Governmental Affairs for Avista Corporation (Avista or
Company) and I am appearing on its behalf in this proceeding.
I make this certification and claim of confidentiality pursuant to IDAPA 31.01.01
because Avista, through its supporting workpapers, is disclosing certain information that
is CONFIDENTIAL and constitutes TRADE SECRETS as defined by Idatro Code
Section 9-340 and 48-801 and protected under IDAPA 31.01.01.067 and31.01.01.233.
The printed information Avista provides will, as required under IDAPA Rule
3 I .0 1 .01 .067 , be marked as CONFIDENTIAL, will be reproduced on any colored paper
other than white, and will be provided under separate cover. The electronic information
Avista provides will be reproduced separately on a thumb drive and will also be marked
as CONFIDENTIAL.
The confidential information that Avista is disclosing includes, but is not limited
to: 1) certain results providing detailed information on the Company's load and resogrce
positions by month, 2) certain equlty issuances as detailed in the January 1,2021through
December 31,2021 pro forma capital structure, 3) Risk Management Policies which
contain general policies, guidelines, and position limits, and 4) Interest Rate Risk
Management Plan which contains policies and guidelines.
Avista herein asserts that the aforementioned information is confidential in that:
1) making the load and resource information public will give entities access to
competitive information on future operating plans and marketpurchase requirements and
Avista believes the information could be used to disadvantage its customers, 2)
ATTORNEY'S CERTIFICATE - 1
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disclosing planned equlty issuances may financially disadvantage the Company, 3) the
Risk Management Policies and hedging practices, and the Interest Rate Risk
Management Plan, if shared with competitors, could also be used to disadvantage
Avista's customers.
I am of the opinion that this information is CONFIDENTIAL, as defined by
Idatro Code Sections 9-340D and 48-801, should therefore be protected from public
inspection, examination and copying, and should be utilized only in accordance with the
TETMS Of thE PROTECTIVE AGREEMENT BETWEEN AVISTA CORPORATION
AND PARTIES WHO HAVE REQUESTED SUCH AN AGREEMENT.
RESPECTFULLY SUBMITTED this 28tr day of January 2021
David J. Meyer
Vice President and Chief Counsel for
Regulatory & Governmental Affairs
Avista Corporation
ATTORNEY'S CERTIFICATE - 2
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