20231219Reply Comments.pdf

Avista Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170

December 19, 2023

Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714

RE: AVU-G-23-08 - Application of Avista Corporation for an Order Authorizing Deferred
Accounting for Costs Related to the November 2023 Williams Northwest Pipeline Outage.

Commission Secretary,

Enclosed for electronic filing with the Commission is Avista’s reply comments in case AVU-G-23-
08.

Please direct any question regarding this filing to me at [phone] or
[e-mail].

Sincerely,
Patrick Ehrbar
Director of Regulatory Affairs

Enclosures

RECEIVED
Tuesday, December 19, 2023 1:53:32 PM
IDAHO PUBLIC
UTILITIES COMMISSION

Page 1 of 2 REPLY COMMENTS OF AVISTA CORPORATION (CASE AVU-G-23-08)
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY AND GOVERNMENTAL AFFAIRS
AVISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
[e-mail]

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF AVISTA
CORPORATION’S APPLICATION FOR AN
ORDER AUTHORIZING DEFERRED
ACCOUNTING FOR COSTS RELATED TO
NOVEMBER 2023 WILLIAMS
NORTHWEST PIPELINE OUTAGE
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CASE NO. AVU-G-23-08

REPLY COMMENTS OF AVISTA
CORPORATION

Avista Corporation (“Avista”) respectfully submits the following reply comments in
response to the comments of Idaho Public Utility Commission (“Commission”) Staff (“Staff”)
submitted on December 18, 2023 (“Staff Comments”) on Avista’s request to defer the costs
associated with the November 8, 2023 Williams Northwest Pipeline outage. At the outset, Avista
appreciates Staff’s review of the Company’s request, it’s diligence in the discovery process, and
its support of Avista’s request for deferred accounting.
There is, however, one remaining area of disagreement between Staff and Avista. In Staff’s
Comments, they do not support a level of interest accruing on the deferred balance. Avista
understands Staff’s reluctance to support the accrual of interest on deferrals of expense items,
where those items relate to matters that the Company can reasonably expect and plan for. This
incident was unexpected and entirely out of Avista’s control. No amount of planning and foresight

Page 2 of 2 REPLY COMMENTS OF AVISTA CORPORATION (CASE AVU-G-23-08)
could have avoided or mitigate these costs. The resources and costs that were required to restore
service to approximately 38,000 customers over a six-day period were unprecedented. The
Company is relying directly on its credit facility to pay what is estimated to be approximately $8-
$10 million of costs associated with the outage; this includes extra Avista labor costs, mutual aid
invoices for the hundreds of regional resources that helped restore service, hotels, food, and other
equipment. The present interest rate for our credit facility is 6.4%, and again it is that facility that
we are directly relying on to fund the costs associated with the restoration of natural gas service to
customers, inasmuch as we need to draw on that facility to pay expenses in the near term. The
Commission should exercise its discretion to allow for a carrying cost under these specific
circumstances involving a significant event, entirely beyond the Company’s control, and including
substantial payment of expenses, the recovery of which will have to await the outcome of Avista’s
next general rate case in August 2025, at the earliest.1
DATED this 19th day of December, 2023.

/s/ David Meyer
David Meyer
Attorney for Avista Corporation

1 The carrying cost on $10 million over a two-year period, at 6.4%, reflects the cost of short-term borrowing under the
credit facility is approximately $1.3 million, all of which would otherwise have to be absorbed by the Company,
through no fault of its own.