20100805Comments on Stipulation and Settlement.pdf

Ken Miler
SNAKE RIVER ALLIANCE
Box 1731
Boise, 10 83701
Ph: [phone]
km i Iler(g sna kerivera Ilia nce .org
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UTILITiES COMMISSiON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. AVU- E-10-01; AVU-G-10-01
OF AVISTA CORPORATION FOR )
AUTHORITY TO INCREASE ITS RATES )
FOR ELECTRIC AND NATURAL GAS )
SERVICE IN THE STATE OF IDAHO )
SNAKE RIVER ALLIANCE COMMENTS ON STIPULATION AND SETILEMENT
COMES NOW, Snake River Allance r'Alliance") with the following comments regarding the
proposed Stipulation and Settlement in the above-referenced dockets. The Alliance signed and
supports the Stipulation and appreciates the efforts by all parties to reach settlement terms.
We offer the following comments on particular components of the Stipulation.
Rate Design
The Alliance appreciates the willngness of interested parties to convene a workshop prior to
the next Avista general rate case to consider possible changes to the existing structure of tiered
energy blocks. Given that the company wil likely commence work on its next general rate case
in the coming months, the Alliance hopes that such a workshop can be convened at least three
months prior to the filing of the next rate case in order to avoid trying to process such a
potentially complex set of issues during the rate case itself. We are interested in exploring not
only the size and parameters of the tiered blocks, but also in exploring whether another block
should be created and the sizes of the existing blocks adjusted accordingly. We believe strongly
in the need to send appropriate price signals to electric consumers, and we are also keenly
aware of the need to structure rates in such a way as to minimize the impacts of future increase
on lower-income customers. As such we believe that, given adequate time, a workshop to
explore these issues in advance of the next rate case wil be productive.
Prudency Determination of DSM Spending
The Alliance supports the Settlement's approach to approval of Avista's DSM spending for 2008
and 2009. As with all of Idaho's regulated electric utilities, we trust that future determinations
of prudency reviews will reflect the commitments made by those utilties and PUC staff in their
Memorandum of Understanding for Prudency Determination of DSM Expenditures, signed by
all parties in December 2009. For the benefit of utilty customers and their confidence in such
regulatory matters, a thorough evaluation, measurement, and verification mechanism to
determine prudency of DSM expenditures is important.
As Avista's laudable DSM upward trend in DSM expenditures continues, the Alliance wants to
ensure the company's ability to raise funds for its efficiency programs is not overtaken by the
demand for new efficiency measures. In the event the existing energy efficiency tariff rider is
inadequate to meet the company's needs, the Allance proposes an examination of whether the
rider amount should be raised or whether an alternative method (such as capitalization of some
costs) be employed to ensure all cost-effective DSM programs are fully funded.
Customer Service-Related Issues
The Alliance is gratified that Avista acknowledges the imperative of increased funding for low-
income weatherization programs and for outreach and education efforts. Increased funding for
these programs is commendable. To the extent that further increases in these important
programs are hindered by funds available in DSM accounts, the Allance suggests for future rate
cases that the company consider proposing funding for these programs either through a tariff
rider increase or through an alternative funding mechanism as referenced above.
As for other customer service-related issues, the Alliance welcomes the company's
commitments on meeting suggestions proposed by PUC staff. The Allance also appreciates
Avista's commitment to hold at least five Senor Energy Conservation workshops in different
Idaho communities.
As is our policy, the Allance believes that utility policies with regard to customer deposits,
credit issues, collection activities and service disconnects-reconnects must continue to be a
priority to ensure such policies to not pose undue burdens on certain customer classes.
WHEREFORE, the Allance respectfully requests the Commission consider the above comments
as it considers the above referenced dockets and the instant Stipulation and Settlement.
Respectfully submitted,£~
Ken Miller
Clean Energy Program Director
Snake River Alliance
Boise, 10
[phone]
km iller(g sna kerivera Ilia nce .org