20221006Comments.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 98IO
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Street Address for Express Mail:
1I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTTLITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR
APPROVAL TO INCREASE ITS ENERGY
EFFICIENCY TARIFF RIDER ADJUSTMENT
SCHEDULE 191
CASE NO. AVU-G.22-07
COMMENTS OF THE
COMMISSION STAF'F'
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its Attorney of
record, Chris Burdin, Deputy Attorney General, submits the following comments.
BACKGROUND
On September 2,2022, Avista Corporation, dba Avista Utilities ("Company" or "Avista")
applied to the Idaho Public Utilities Commission ("Commission") for authorization to increase its
natural gas Schedule 191 - Energy Efficiency Rider Adjustment rates. Schedule 191 funds the
Natural Gas Energy Effrciency Program ("Program") as described in the Company's Schedule 190
including, but not limited to, behavioral programs, low-income weatherization, Northwest Energy
Efficiency Alliance ("NEEA") participation, and provision of incentives for various energy
effrciency measures such as appliances, compressed air, HVAC, industrial, lighting, maintenance,
motors, shell, and sustainable buildings.
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STAFF COMMENTS OCTOBER 6,2022
Avista's Schedule l9l tariff rider rate adjustment is designed to recover costs incurred by
the Company associated with providing energy efficiency services and programs to customers.
The tariff rider mechanism is intended to match future revenue with budgeted expenditures.
The Company proposed to increase billed natural gas rates by 3.0% through proposed
revisions in Schedule l9l, with a requested effective date of November 1,2022. The Company is
filing another Application simultaneously with this Application related to purchased gas costs that
would increase natural gas revenues by approximately $11.2 million, or l2.7Yo, effective
November 1,2022.If both Applications are approved, the net change to natural gas revenue would
be an increase of $13.8 million, or l5.7o/o, effective November 1,2022.
The Company represented that this Application will be brought to the attention of the
Company's customers by way of a Customer Notice, which will be included in customer's bills
beginning in early September 2022, running for a full billing cycle, and by posting the Application
to the Company's website at myavista.com.
STAFF ANALYSIS
Staff reviewed the Company's Application and workpapers. Staff supports the Company's
request to increase the Schedule l9l - Energy Efficiency Rider Adjustment, which would increase
the Company's natural gas revenues in Idaho by 3.0%. If approved, a residential customer using
an average of 63 therms per month would see their monthly bill increase from $62.06 to $64.01,
an increase of $ 1.95 per month, or 3.lYo. Staff believes the Company properly applied the new
rate adjustment to customer classes as shown in Table No. I below:
Table No. 1: Schedule 191 Rates
SCHEDULE
EXISTING
RATE
PROPOSED
RATE
General Service - Sch. l0l $.01818 per Therm $.04903 per Therm
Large General Service - Sch. lll &. ll2 $.00978 per Therm 5.02626 per Therm
Intemrptible Sales Service - Sch. l3l & 132 $.00978 per Therm 5.02626 per Therm
As of July 31,2022,the current Schedule 191 tariff rider balance was approximately $2.1
million underfunded. An underfunded balance indicates that the current tariff rider rate is not
sufficient to cover all the yearly expenses of the program. While the current rate is designed to
2STAFF COMMENTS OCTOBER 6,2022
fund the Program at approximately $ 1.4 million annually, the actual expenses incurred during 2020
and 2021 were $2.4 million per year, a 53Yo increase as compared to the 2019 Program year. The
primary reason for this increase was due to a higher than anticipated participation level which
achieved a greater amount of conservation savings in ldaho.
The proposed rate adjustment is projected to bring the underfunded balance of Schedule
l9l to $0 by September 30,2025. Staff reviewed Avista's forecasted natural gas energy efficiency
expenses and has confirmed that Schedule 191 is projected to be balanced by October 2025. By
extending the collection period over three years, the Company will attempt to align the collection
of revenue in Schedule 191 more closely with the annual Energy Efficiency Program budget, while
minimizing the future rate impact to customers.
Cost-effective Demand Side Management ("DSM"), including energy efficiency programs
and load management programs, is a significant resource that helps customers control their utility
bills, reduces the need for higher-cost supply-side resources, and increases system reliability. Staff
expects that Avista's DSM program costs will continue to be prudently incurred and that the
programs will remain cost-effective.
It is not Staffls intent to either validate or question the Company's DSM prudency or its
actual cost-effectiveness calculations for any of its programs. Such validation and additional
review was not requested in this case and is occurring in Case No. AVU-G-22-05, which is
currently pending before the Commission.
ACCOMPANYING CASES
The Company filed two other applications with rate adjustments and requested effective
dates ofNovember 1,2022. The Company's natural gas Purchased Gas Cost Adjustment ("PGA"),
Case No. AYU-G-22-06, was filed simultaneously with this Application and requests an increase
in natural gas revenues of approximately $11.2 million, or 12.7oh. The Company's Fixed Cost
Adjustment ("FCA"), Case No. AYU-G-22-04, was filed on July 29,2022, and requests a decrease
in the Company's overall natural gas revenues by $0.1 million, or 0.2oh. Table No. 3 below shows
the effect of all three cases if approved as filed.
JSTAFF COMMENTS OCTOBER 6,2022
Table No. 2: Impact of the Three Natural Gas Filings:
CASE
$ REVENUE
CHANGE
% REVENUE
CHANGE
EE Tariff $ 2.6 Million 3.0%
PGA $ 11.2 Million 12.7%
FCA $ (0.1 Million)(0.2%)
TOTAL S 13.7 Million 15.5"h
CUSTOMER NOTICE
The Company's press release and customer notice included with its Application address
the natural gas Energy Efficiency Charge in this case and the PGA filing. Staff reviewed the
documents and believes that both meet the requirements of Rule 125 of the Commission's Rules
of Procedure. IDAPA 31.01.01.125. The notice was included with bills mailed to customers
beginning September 12,2022, and ending October 10,2022. The Commission set a comment
deadline of October 6,2022. It is possible that some customers will not have received their notices
or had adequate time to submit comments before the comment deadline. All customers should
have the opportunity to file comments and have those comments considered by the Commission.
Staff recommends that the Commission consider late filed comments by customers. As of October
5,2022, no customer comments had been filed.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's Application to increase
the Schedule l9l Customer Efficiency Services Rate and approve the proposed Schedule 191
tariffs as filed. Additionally, Staff recommends the Commission consider late filed comments
from customers.
Respectfully submitted this day of October 2022.bt\
ALI-'L
Chris Burdin
Deputy Attorney General
Technical Staff: Laura Conilogue
i : umisc/comments/ av ug22.7 cblc comments
4STAFF COMMENTS OCTOBER 6,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY oF oCToBER 2022,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. AVU.G-22.07, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
dockets@avistacom. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL : [e-mail]
b /l"Z-"!
SECRETARY/
CERTIFICATE OF SERVICE