20220729Application.pdf

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Avista Corp.
141I East Mission P.O.Box3727
Spokane. Washington 99220-37 27
Telephone [phone]
Toll Free 800-727-9170
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July 29,2022
State of Idaho
Idaho Public Utilities Commission
11331W. ChindenBlvd
Bldg 8 Suite 201-A
Boise,ID 83714
Case No. AW-G-22-g[t
Natural Gas Fixed Cost Adjustment Annual Rate Filing of Avista Corporation
Dear Commission Secretary:
Enclosed for electronic filing with the Commission is Avista's natural gas Fixed Cost Adjustnent
(FCA) annual rate adjustment filing. This filing consists of Avista's Application, Exhibit A (the
Company's proposed tariffs), Exhibit B (rate calculation), Exhibit C (12 months ended June 30,
2022 deferral), and Exhibit D (customer communications) in support of the Application. The
Company requests that the proposed tariff sheets be made effective November 1,2022.
Electonic versions ofthe Company's filing were emailed to the Commission, and the Service List,
onJuly 29,2022.
Please direct any questions on this matter to me at [phone] or Joel Anderson at (509) 495-
281 l.
Sincerely,
/s/ Patrick Ehrber
Patrick D. Ehrbar
Director of Regulatory Affairs
Enclosures
I DAVID J. MEYER2 VICE PRESIDENT AND CHIEF COUNSEL FOR3 REGULATORY AND GOVERNMENTAL AFFAIRS4 AVISTA CORPORATION5 I4II E. MISSION AVENUE6 P . O. BOX 37277 SPOKANE, WASHINGTON 992208 PHONE: (509) 49s-4316, FAX: (509) 49s-88s1
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE FIXED COST )
ADruSTMENT MECHANISM (FCA) )
ANNUAL RATE ADruSTMENT FILING )
oF AVTSTA CORPORATION )
CASE NO. AVU-G-zz- 9+
APPLICATION OF AVISTA
CORPORATION
18 I.INTRODUCTION
lg ln accordance with ,*noffiission order No. 33437, and Rp
20 052, Avista Corporation, doing business as Avista Utilities (hereinafter "Avista" or
2l "Company"), at l4ll East Mission Avenue, Spokane, Washington, respectfully makes
22 application to the Idaho Public Utilities Commission ("Commission") for an order
23 approving the level of natural gas Fixed Cost Adjustment Mechanism (FCA) revenue
24 deferred during 12 months ended June 30, 2022 and authorizing FCA rates for natural gas
25 service from November l, 2022 tbrough October 31,'2023. The FCA rate for the
26 Residential Group (Schedule 101) is proposed to change from a present rebate rate of
27 0.4939 to a proposed rebate rate of 1.0201 per therm. The FCA rate for the Non-Residential
28 Group (Schedules 111 and 112) is proposed to change from a present rebate rate of 0.490$,
29 to a proposed surcharge rate of 0.3811 per therm. The Residential Group rate change
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 1
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I represents a $0.3 million, or 0.5o/o decrease, to Schedule 101 customers, and the Non-
2 Residential Group rate change represents a $0.1 million, or l.2Yo, incease. The combined
3 effect of expiring FCA rates and the proposed rates are shown on the table below.
Expiring Present
FCA Revenue
Proposed FCA
Revenue
Proposed FCA
Increase
Residential $ (346.68s)$ (717.280)$ (370.59s)
Non-Residential s fl32.961)$ 103,384 s 236.34
7 T\e Company has requested a November 1,2022 effective date.
8 The Company requests that this filing be processed under the Commission's
9 Modified Procedure Rules (RP 201-204). Communications referencing this Application
l0 should be addressedto:
David J. Meyer, Esq.
Vice President and Chief Counsel for
Regulatory & Governmental Affairs
Avista Corporation
P.O.Box3727
MSC.IO
l4l I E. Mission Ave
Spokane, WA 99220-3727
Phone: [phone]
David. Meyer@avistacorp. com
Patrick D. Ehrbar
Director of Regulatory Affairs
Avista utilities
P.O.Box3727
MSC-27
1411 E. Mission Ave
Spokane, WA 99220-3727
Phone: [phone]
pahick. ehrb ar @av istacorp. com
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AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 2
1 II. BACKGROT]NI)
2 The purpose of the natural gas FCA is to adjust the Company's Commission-
3 authorized revenues from therm sales, such that the Company's revenues will be
4 recognized based on the number of customers served under the applicable natural gas
5 service schedules. The FCA allows the Company to: I ) defer the difference between actual
6 FCA-related revenue received from customers through volumetric rates, and the FCA-
7 related revenue approved for recovery in the Company's last general rate case on a per-
8 customer basis; and2) file a tariffto surcharge or rebate, by rate group, the total deferred
9 amount accumulated in the defened revenue accounts for the prior January through
l0 December time period.
1l In Case Nos. AW-E-15-05 and AW-G-15-01, the Commission in Order No.
12 33437 approved for Avista a Fixed Cost Adjustnent Mechanism. On page l0 of Order
13 No. 33437, the Commission stated:
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The parties have also agreed upon a three-yearl FCA pilot for electric and natural
gas operations. The FCA will compare actual FCA revenues to allowed FCA
revenues determined on a per-customer basis. Any differences will be deferred for
a rebate or surcharge. There are a number of customer safeguards, including that an
FCA surcharge cannot exceed a 3o/o annuial rate adjustrnent. Any unrecovered
balances will be carried forward to recover in futrue years. Further, there is no limit
to the level of the FCA rebate. As part of the Stipulation, Staffand other interested
parties, will review the efficacy of the FCA after its second full year to ensure it is
functioning as intended. Fixed cost adjustnent mechanisms are intended to
encourage conservation and allow customers more control over their bills. Further,
the proposed FCA will remove any financial disincentive of the Company to
encourage energy conservation.
27 The Section 13 of the Stipulation and Settlement, as amended by Addendum to the
On June 15, 2018, the Idaho Public Utilities Commission approved an Addendum to the Stipulation
which extended the term of the pilot for an additional year by Order No. 34085.
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 3
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1 Stipulation approved by the Commission in Order No. 34085 on June 15, 2018, provided
2 further details, reproduced below, regarding the mechanics of the fixed cost adjustment
3 mechanism.
A. 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
B. Rate Groups. There will be two rate grcups established for both the electric
FCA and natural gas FCA:
Electric Customer Rate Groups:l. Residential - Schedule I2. Commercial - Schedules 11, 12,21,22,31,32
Natural Gas Rate Groups:l. Residential - Schedule 1012. Commercial-Schedules 111 and l12
C. Existing Customers and New Customers. The Parties have agreed that revenue
related to certain items discussed below would not be included in the FCA for new
customers. The result is that the Fixed Cost Adjustnent Revenue-Per-Customer
for new customers will be less than the Fixed Cost Adjustment Revenue-Per-
Customer for existing customers. For new electic customers added after the test
period, recovery of incremental revenue related to fixed production and
transmission costs would be excluded from the electric FCA. For new natural gas
customers added after the test period, recovery of incremental revenue related to
fixed production and underground storage facility costs would be excluded. These
modifications are included in Appendices B and C to the Stipulation.
D. Quarterly Reporting. Avista will file, within 45 days of the end of each quarter,
a report detailing the FCA activity by month.3 The reporting will also include
information related to the deferrals by rate group, what the deferrals would have
been if tracked by rate schedule, use and revenue-per-customer for existing and
new customers, and other summary furancial infonnation. Avista will provide such
2 Review of the mechanisms took place at a workshop March 27 , 2019, and the Company filed a separate
application with the Commission which extended the term of the FCA Mechanisms through March 31,2025.
See also discussion starting atpage 6 ofthis application.3 As stated in Order No. 34502 Case No. AW-G-19-03, the Company altered its quarterly reporting from
45 days to 60 days from the end ofeach quarter.
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 4
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other infonnation as may be reasonably requested from time to time, in the future
quarterly reports.
E. Annual Filings. On or before July l, the Company will frle a proposed rate
adjustnent surcharge or rebate based on the amount ofdeferred revenue recorded
for the prior January through December time period.4 The rate adjustment would
be calculated separately for each Rate Group, with the applicable surcharge or
rebate recovered from each group on a uniform cents per kWh or per therm basis.
The proposed tariff (Schedule 75 for electric, Schedule 175 for natural gas)
included with that filing would include a rate adjustment that recovers/rebates the
appropriate deferred revenue amount over a twelve-month period effective on
October I for electric (to match with Power Cost Adjustnent and Residential
Exchange annual rate adjustnents time period) and November lst for natural gas
(to match with the annual Purchased Gas Cost Adjustment rate adjusfrnent time
period). The deferred revenue amount approved for recovery or rebate would be
transferred to a balancing account and the revenue surcharged or rebated during the
period would reduce the deferred revenue in the balancing account. After
detennining the amount of deferred revenue that can be recovered through a
surcharge (or refunded through a rebate) by Rate Group, the proposed rates under
Schedules 75 and 175 would be determined by dividing the deferred revenue to be
recovered by Rate Group by the estimated kWh sales (Electric FCA) or therm sales
(Natural Gas FCA) for each Rate Group during the twelve-month recovery period.
Any deferred revenue remaining in the balancing account at the end of the
amortization period would be added to the new revenue deferrals to determine the
amount of the proposed surcharge/rebate for the following year.
F. lnterest. lnterest will be accrued on the unamortized balance in the FCA
balancing accounts at the Customer Deposit Rate.
G. Accounting. Avista will record the deferral in account 186 - Miscellaneous
Deferred Debits. The amount approved for recovery or rebate would then be
transferred into a Regulatory Asset or Regulatory Liability account for
amortization. On the income statement, the Company would record both the
deferred revenue and the amortization of the deferred revenue through Account 456
(Other Electric Revenue), or Account 495 (Other Gas Revenue), in separate sub-
accounts. The Company would file quarterly reports with the Commission showing
pertinent inforrnation regarding the status ofthe current deferral. This report would
include a spreadsheet showing the monthly revenue deferral calculation for each
month of the deferral period (January - December), as well as the current and
historical monthly balance in the deferral account.
4 As stated in OrderNo. 34502 Case No. AVU-G-19-03, The company altered the deferral period of its
FCA extension to July through June by using a one-time l8-month deferral period of January 1,2020
through June 30, 2021. See also discussion starting at page 6 ofthis application.
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 5
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H. 3% Rate Increase Cap. An FCA surcharge, by rate Broup, cannot exceed a3o/o
annual rate adjusfrnent, and any unrecovered balances will be carried forward to
future years for recovery. There is no limit to the level of the FCA rebate.
III. DRIVERS OF NATURAL GAS FCA REBATES
The FCA deferral for Residential customers for 12 months ended Jvrc 30,2022
was the result of higher monthly use-per-customer and the deferral for Non-Reside,ntial
customers was the result of slightly lower use-per-customer than the use-per-customer that
was embedded in the 2019 test year (i.e., the FCA base). Residential average monthly
use-per-customer was higher by 2 therms, and non-residential averuge monthly use-per
customer was lower by 8 therms. The Company has identified the primary drivers for the
change in use-per-customer.
First, weather was wanner than normal for 12 months ended June 30, 2022, givng
rise to a weather normalization adjustnent5 that required the addition of 0.3 million therms
to residential usage (0.3 therms per customer) and 0.1 million therms (4 therms per
customer) to non-residential usage. The estimated FCA revenue short fall associated with
weather was approximately $131 thousand residential and $15 thousand non-residential.
Since the 2019 test yearused to set 2021 rates,Idaho customers have achieved
energy efficiency savings from participation in the Company's Demand Side Management
programs. Estimated cumulative savings since the test year (derived from the Idaho 2017,
2018,2019,2020 and202l DSM Annual Reports) reduced residential usage for 12 months
ended June 30, 2022 approximately 125 thousand therms and non-residential usage
approximately 19 thousand thenns. The estimated FCA revenue shortfall associated with
5 T\e2020 weather normalization adjustment was included in the Company's WA Commission Basis Filing
and the same process was applied to year-to-date June 2021.
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 6
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energy efficiency programmatic savings is $0.8 million residential and $0.1 million non-
residential.
The "other" drivers are related to items not easily quantifiable, such as the effects
of non-programmatic energy efficiency, changes in business cycles, etc. The following
table summarizes the impact of these drivers on the FCA Revenues received from
customers in the deferral period.
Driver
Residential Group
Use-per- FCA
Customer Revenue
rlon-Residential Groul
Use-per-
Customer
FCA
Revenue
Weather
Energy Efficiency
Other
Total
(0,3)
(0.1)
2.7
1.7
(So.11
(So.r1
$1.9
So.e
(3,s)
(1.0)
(2.s)
(7.81
(So.o1
(So.o1
(So.r1
(so.1l
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T2 IV. RESIDENTIAL GROUP RATE DETERMINATION
l3 The Company recorded $743,688 in the rebate direction in deferred revenue for the
14 natural gas residential customer group for 12 months ended June 30, 2022. The proposed
l5 rate of 1.020 cents per therm is designed to rebate $717,280 to the Company's residential
16 natural gas customers served under rate Schedule 101. The following table summarizes
17 the components of the Company's request to rebate:
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Summary
07.2021 - 06.2022 Defe rred Reve n ue
Add PriorYear Residual Balance
Add lnterest through L0l3y2O23
Add Revenue Related Expense Adj.
Total Requested Recovery
'Customer Rebate Revenue
Carryove r Deferred Reve nue
(s743,688)
53p',7.22
(s+,ass;
(s3,419)
l57L7,28f.l
(s7L7,2801
So18
19 Exhibit B, page 1 shows the derivation of the proposed rate to rebate revenue of
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 7
| $717,280 based on projected sales volumes for Schedule 101 customers during the
2 amortizationperiod (November 2022throngh October 2023). As identified on tariffSheet
3 l75B under Step 6 of "Calculation of Monthly FCA Deferral", interest on the deferred
4 balance accrues at the Customer Deposit Interest Rate.6 tf the proposed rebate is approved
5 by the Commission, the 12 months ended June 30, 2022 defenal balance, plus interest
6 through October, will be transferred into the regulatory liability balancing account. The
7 balance in the liability account will be reduced each month by the rebate received from
8 customers under the tariff.
9 V. NON.RESIDENTIAL GROUP RATE DETERMINATION
l0 The Company recorded $99,328 in the surcharge direction in deferred revenue for
l1 the natural gas Non-Residential Group for 12 months ended June 30, 2022. The proposed
12 surcharge rate of 0.381 cents per thenn is designed to recover $103,384 from the
l3 Company's commercial and industrial customers served under rate Schedules I I I andll2.
14 The following table summarizes the components of the Company's request for rebate:
Summary
07.2021 - 06.2022 Defe rred Reve n ue
Add PriorYear Residual Balance
Add lnterest through 7Ol3L/2023
Add Revenue Related Expense Adj.
Total Requested Recovery
Customer Surcharge Revenue
Carryover Deferred Revenue
S99,328
s2,930
574L
Sges
5103,384
s103,384
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Exhibit B, page 3 shows the derivation of the proposed rate to surcharge revenue
of $103,384 based on projected sales volumes for Schedules 111 and 112 during the
6 The Customer Deposit Interest Rate was 1.00% beginning January 2021. T\e current rate of 1.00% has
been used as an estimate for purposes of this rate determination.
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 8
1 amortization.period (November 2022 throryh October 2023). As identified on the tariff
2 Sheet l75B under Step 6 of "Calculation of Monthly FCA Deferral", interest on the
3 deferred balance accrues at the Customer Deposit lnterest Rate. If the proposed rebate is
4 approved by the Commission, the deferral balance, plus interest through October will be
5 transferred into the regulatory liability balancing account. The balance in the liability
6 account will be reduced each month by the rebate received by customers under the tariff.
7 Support showing the monthly calculation of the 12 months ended Jlumie 30, 2022
8 defenal balances for both the Residential and Non-Residential Groups is provided as
9 Exhibit C. These calculations were also provided to the Commission in quarterly reports
10 (except April through June 2022 which will be provided in the Q2 report by the end of
11 August).
12 VI.3% AI\NUAL RATE INCREASE TEST
13 FCA rate adjustment surcharges are subject to a3o/o annual rate increase limitation.
14 There is no limit to rebate rate adjustnents. As described in tariff Schedule 175, the 3o/o
15 annual rate increase limitation will be determined by dividing the incremental annual
16 revenue to be collected (proposed surchargerevenue less present surcharge revenue) under
17 this Schedule by the total "normalized" revenue forthe two Rate Groups forthe most recent
l8 January through Decernber time period. Normalized revenue is determined by multiplying
19 the weather-corrected usage for the period by the present rates in effect. If the incremental
20 amount of the proposed surcharge exceeds 3o/o, only a 3olo incremental rate increase will be
2l proposed, and any remaining deferred balance will be carried over to the following year.
22 Exhibit B, page 6 shows the 3o/o test for the two rate groups. The incremental
23 change from the existing rebate to the proposed rebate for the residential group is a decrease
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 9
1 of $0.4 million or approximately 0.5o/o. For the Non-Residential group, the incremental
2 change from the existing rebate to the proposed surcharge is an increase of $0.2 million or
3 approximately 1.2%o. As both the Residential deferral and the Non-Residential deferral are
4 less than 3o/o, they are not subject to the 3Yo incremental surcharge test. There is no
5 proposed carry over for either rate class.
6 VII. EXISTING CUSTOMERS AND NEW CUSTOMERS
7 The Settlement Stipulation approved by the Commission requires that natural gas
8 customers that have been added since the test year are subject to an FCA Revenue-Per-
9 Customer that excludes incremental revenue related to fixed production and underground
l0 storage facility costs. Separate calculations for new versus existing customers are clearly
I I identified in the FCA base that was approved in Case No. AW-G-17-01 OrderNo. 33953
12 as adjusted by tax reform Case No. GNR-U-18-01 Order No. 34070 for natural gas rates
13 effective since January 1,2019 and Case No. AW-G-01 OrderNo. 35156 for natural gas
14 rates effective since September 1,2021(included in this filing as Attachment C, pages 6
15 through 10).
16 Due to this segregation, Avista tracks the usage of new customers since January 1,
17 2017 as compared with existing customers.T In general, the average usage of new natural
18 gas customers is comparable to the average usage of existing customers. Avista will
19 continue to track the usage of new customers over the Fixed Cost Adjustrnent term.
7 "Existing customers" were part of the test year used to set the January 1 , 2020 rates (20 1 6 calendar year).
"New customers" consist of all new hookups after the test year.
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADJUSTMENT FILING PAGE IO
1 YIU. PROPOSED RATES TO BE EFFECTIYE NOVEMBER 1.2022
2 The Company is proposing a per therm FCA rebate rate of L.020$ for the
3 Residential Group, and a per therm FCA surcharge rate of 0.3811 for the Non-Residential
4 Group, bothto become effectiveNovember 1,2022. Exhibit B to this Applicationprovides
5 the Residential and Non-Residential Rate Calculatioru and Exhibit C provides the support
6 for the deferrals for the July 1, 2021 through June 30, 2022 defenal period. Exhibit A is a
7 copy of the proposed tariff, Schedule 175, which contains the proposed FCA rates. Exhibit
8 A also includes the proposed changes to Schedule 175 in strike/underline fonnat.
9 Residential customers using an average of 63 therms per month would see their
l0 monthly bills decrease from $62.06 to $61.73, a decrease of $0.33 per month, or 0.5%.
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12 IX. COMMT]MCATIONS AI\D SERVICE OF APPLICATION
13 In conformance with RP 125, this Application will be brought to the attention of
14 the Company's customers. First, the Company has served a copy of this Application upon
15 the service list in Case Nos. AVU-E-15-05 and AVU-G-I5-01, the cases that gave rise to
16 the FCA mechanisms. Second, a copy of Company's news release and customer notice is
17 provided as Attachment D. The news release will be issued in July and the customer notice
18 will be inserted in customer bills starting in August and run for a full billing cycle.
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20 X. REOTTEST FOR RELIEF
2l The Company requests that the Commission issue an order approving recovery of
22 FCA deferrals for the period July 1, 2021 through June 30, 2022 and approve a per therm
23 FCA rebate rate of 1.020i for the Residential Group, and a per therm FCA surcharee rate
AVISTA'S NATURAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE II
I of 0.381f for the Non-Residential Group, both to become effective November 1,2022.
2 The Residential Group rebate represents a $0.4 million, or 0.5Yo incremental decrease to
3 schedule 101 customers, and the Non-Residential Group surcharge represents a $0.1
4 million, or l.2o/o incremental increase to Schedule l l l and 112 customers. The Company
5 requests that the matter be processed under the Commission's Modified Procedure rules
6 through use of written comments.
7 Dated at Spokane, Washington this 2fth day of July 2022.
8 AVISTA CORPORATION
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BY /s/ Patrick Ehrbar
Patrick D. Ehrbar
Director of Regulatory Affairs
AVISTA'S NATI.'RAL GAS FCA ANNUAL RATE ADruSTMENT FILING PAGE 12
CERTIFICATE OF SERYICE
I HEREBY CERTIFY that I have this 29ft day of J:uly 2022, served the Application of Avista
Corporation - Fixed Cost Rate Adjustment, upon the following parties, by mailing a copy
thereof, properly addressed with postage prepaid to:
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
I1331 W. Chinden Blvd
Bldg 8 Suite 201-A
Boise,ID 83714
i [e-mail]. gov
Peter J. Richardson
Greg M. Adams
Richardson Adams
515 N.27ft Steet
PO Box 7218
Boise,ID 83702
peter(Erichardsonadam s. com
gree@richardsonsdams. com
Karl Klein
Brandon Karpen
Deputy Attorneys General
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-0659
[e-mail]
[e-mail]. qov
Marv Lewallen
28530 SW Canyon Creek Rd. - South
Wilsonville, OR 97070
[e-mail]
Larry A. Crowley
The Energy Strategies Institute, Inc.
5549 S. Cliffsedge Ave
Boise, ID 83716
crowleyla(daol.com
Wendy Wilsons
Clean Energy Program Director
Snake River Alliance
223 N 6th Street, Suite 317
Boise, lD 83702
wwi I s on (a) snakeri veral I i ance. ore
Dean J. Miller, Lawyer
36208. Warm Springs
Boise,ID 83716
deanj miller@ cableone.net
Benjamin J. Otto
Idaho Conservation League
710 N.6th St.
Boise, ID83702
botto@ idahoconservation.ore
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreadine(Dmindsprin e. com
/s/ Patrick Ehrbar
Patrick Ehrbar
Director of Regulatory Affairs