20230104Reply Comments.pdf

Avista Corp. 1411 East Mission P.O. Box 3727 Spokane. Washington 99220-0500 Telephone [phone]
Toll Free 800-727-9170
January 4, 2023
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A Boise, Idaho 83714
RE: Case Nos. AVU-E-22-13 and AVU-G-22-05 – Reply Comments of Avista Utilities
Dear Ms. Noriyuki:
Pursuant to the Notice of Modified Procedure issued by the Idaho Public Utilities Commission (IPUC or Commission) on November 4, 2022,1 Avista Corporation, dba Avista Utilities (Avista
or Company), respectfully submits the following reply comments in response to the written
comments of Commission Staff (Staff), as filed on December 20, 2022.
Avista appreciates Staff’s review of its 2020-2021 Energy Efficiency Program (Program) and the finding that nearly all of the Company’s expenses were prudent. In general, the Company finds
Staff’s comments to be reasonable and serve to further strengthen Avista’s Program. We appreciate
Staff recognizing the cohesiveness of Avista’s Cost-Effectiveness (CE) model, which was created and designed to provide more clarity and transparency on cost-effectiveness analysis. We look forward to further improving our process based on Staff’s recommendations.
Staff noted issues with the Company’s contracted CE analysis, specific to errors in both the third-
party and in-house workpapers. Staff has recommended an adjustment of $38,883 of expenses related to the contracted Cost-Effectiveness Analysis. This total is comprised of $29,524 related to the CE analysis for the electric program and $9,359 related to the natural gas program, as shown in Table No. 1 below.
Table No. 1 – CE Analysis Costs by Evaluator
Evaluator 1 Non-Residential/MFDI $27,998 $7,251 $35,249
Evaluator 2 Residential/Low Income $1,526 $2,108 $3,634
1 Order No. 35587.
RECEIVED
Wednesday, January 4, 2023 4:58:09 PM
IDAHO PUBLIC
UTILITIES COMMISSION

2 | P a g e

Avista acknowledges Staff’s comments regarding the third-party CE analysis and that errors were not discovered ahead of time. However, Avista believes that the third-party CE analysis provided
the Company with useful feedback regarding the assessment of its Program design, in addition to
providing key insights used in making Program adjustments, therefore meeting the requirements of being used and useful. Yes, the Company understands that no errors in any work is the gold standard, and we strive for that in our work and in the work of outside vendors. That said, it is our view that the issues of the third-party consultant did not affect the ultimate results. For example,
the proposed disallowance of $27,998 in electric DSM costs results from one error by that
particular consultant, an overestimation of $176,477 of costs out of a universe of $3.6 million of reviewed costs. Again, we do appreciate Staff’s thorough review in this matter. The Company however does not
think it is appropriate to disallow these third-party costs, given the majority of the disallowance is
due to a single error that ultimately did not affect the overall cost-effectiveness results of our programs. Please direct any questions regarding this filing to Ryan Finesilver at [phone].

Sincerely,
/s/ Patrick Ehrbar
Patrick Ehrbar
Director of Regulatory Affairs