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Home My WebLink About20100802Comments on Stipulation and Settlement.pdfBenjamin Otto ISB No. 8292 710 N 6th Street PO Box 844 Boise,ID 83701 Ph: (208) 345-6933 x 12 Fax: (208) 344-0344 botto~idahoconservation .org RECEIVED 2016 AUG -2 PH 4: 36 frl.~LJrl UTflilíËs\; Attorney for Idao Conservtion Legue BEFORE TH IDAHO PUBLIC UTITIES COMMISSION IN THE MATTER OF THE APPLICATION OF AVISTA CORPORATION DBA AVISTA UTILIES FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC AND NATURAL GAS SERVICE IN IDAHO ) ) ) ) ) CASE NO. AVU-E-1O-01 A VU -G-lO-Q 1 COMMENTS ON TH STIPUlATION AND SETTMENT COMES NOW Idao Conservtion League (((ICL") with the followig comments regardig the proposed Stipulation and Settlement. Whle ICL signed the stipulation and appreciates the effort and compromises that are contained therein, we offer the followig comments on some specific provisions. Prudency of DSM Spending for 2008 and 2009 The stipulation deems prudent Avista's DSM spendig for 2008 and 2009. ICL accepts this provision with the understandig that future DSM reviews wil be more robust. Mr. Folsom's testimony describes an effort curently underway in Washington to devise a more robust evaluation, measurement, and verification report for Avista's DSM portfolio. Folsom at 14-18. We look forward to reviewig the results of both this effort, and the DSM evaluations that arse from it, to furher improve the Company's DSM portfolio. ICL COMMENTS ON STIPULATION 1 August 2, 2010 DSM spndig continues to outpace the funds generated by Avita's curent Energy Efficiency Tarff Rider. On the electric side, the unrecovered back balance for Idao now stands at $2,008,944. Folsom at 18. Whe progr paricipation continues to exceed estimates, the company expects the curent tarf rider to fully fund DSM progrs and retire the back balance. ¡d., at 9, 18-20. ICL is concerned that the curent tarff rider wi not provide sufficient funds to both retire this balance and maitai the solid gais in effciency made over the past few years. As DSM progr spndig continues to rise, and continues to be the most cost effective means to meet energy demand, ICL encourges the Company and the Commission to pursue a more sustaiable funding mechanism. Ths may include movig some of the more robus and verifiable progrs into rates and out of tarff fundig. Rate Design and Cost of Servce leL is encourged the paries commit to holdig a public workshop to discuss and resolve issues with a revised cost of servce model and residential rate design. Ths stipulation changes one aspect of the previous cost of servce model by allocating 100% of trsmission costs to demand. Wh.e ICL accepts this for the purses of this case, we look forward to the opportunity to fuly analyze this issue. Turing to rate design, the stipulation includes an increase in the residential basic chage of $0.40. Avista asked to increas the basic charge by $2.15. In the absence of a revenue decoupling mechaism, ICL supports increasing the monthly cusomer chae to retur more of the entire fixed cost. We believe that separating fixed cost recovery from volumetric sales is critical to ensurg utilties wi actively pursue all cost effective energy efficiency whie maitaiing acceptable levels of cost recovery risk. However, we also acknowledge that increasing the customer chare may not send the appropriate price signals to reduce energy consumption. In ICL COMMENTS ON STIPULATION 2 August 2, 2010 the upcoming rate design workshop the paries commit to in this stipulation, ICL believes the issue of fixed cost recovery must be addressd. The residential rate design is based on a first block of 600 kwh and a higher chare for use above this leveL. ICL believes the size of this block needs to be more fully analyzed to determine if it captures an appropriate basic level of energy consumption. bur ultimate goal is to reduce overall energy consumption whie maintaining comfort and servces. But ICL is concerned about sendig price signals that fal disproportionately on low income, high electric us customers. We are encouraged the Company committed to increasing fundig for low-income weatheriation and education programs. We believe that when sending price signals, the Company, interested paries, and the Commission must work together to help people access the resources to actualy respond to these signals. In the upcoming workshop the paries commit to in this stipulation, ICL believes all paries should explore options for increasing the access to capital for residential customers who wish to make energ efficiency investments. In closing, we appreciate the effort and concessions made by all sides to reach this agreement. We look forward to a more robust discusion of future DSM programs, a resed cost of servce methodology, and rate design issues. With those caveats, ICL supports the proposed Stipulation and Settlement. DATED this 2nd day of Augt 2010. Respectfuly submitted,~6? Benjamin J. Otto Idaho Conservtion League ICL COMMENTS ON STIPULATION 3 Augut 2,2010 CERTIFICATE OF SERVICE I hereQY certif that on this 2nd day of Augt, 2010, true and correct copies of the foregoing COMMENTS ON THE STIPUlATION AND SETTLMENT were delivered to the following persons via the method of servce noted: Hand delivery Jean Jewell Commission Secretary (Original and nine copies) Idao Public Utilties Commision 427 W. Washigton St. Boise, ID 83702-5983 Boise, ID 83716 crowleyla~aoLcom Brad M. Purdy Attorney at Law 2019 N 17 TH ST Bois ID 83702 bmpurd~hotmai.com Electronic Mai: David Meyer Kelly Norwood A vista Corpration PO Box 3727 Spokane, WA 99220-3727 davidmeye~avistacorp.com kelly.norwood~avistacorp.com Rowena Pineda Idao Community Action Netwrok 3450 Hil Rd. Boise,ID 83703-4715 Rowena~idaocan.org Donald L. Howell, II Kristine A. Sassr Idao Public Utilties Commission 472 W. Washigton St. Boise,lD 83702 LeeAnn Hal 3518 S. Edmunds St. Seattle, WA 98118 leann~nwfco.org Ken Miler PO Box 1731 Boise,lD 83701 kmile~snakeriveraiance.org Peter J. Richardsn Greg M. Adas 515 N. 27th St. PO Box 7218 Boise, ID 83702 Pete~richadsonandolear.com greg(richardsonandolear .com Rob Pluid North Idao Energ Logs PO Box 571 Moyie Springs, ID 83845 energyogs~gmai.com Howard Ray PO Box 1126 Lewiston, ID 83501 howard.ra~clearaterpaper .com Clark Faichid PO Box 571 Moyie Sprigs, ID 83845 Energogs~gmai.com Dean J. Miler 420 W. Bannock St. Boise, ID 83702 ioe~mcdevitt -miler. com TOM OXFORD SECRETARY TREASURER NORTH IDAHO ENERGY LOGS oxford~meadowcrk.com Larr A. Crowley 5549 S. Cliffsedge Ave. f1~ Benjamin J. Otto -- ICL COMMENTS ON STIPULATION 4 August 2, 2010