20110922Comments.pdf

RECEI DBenjamin J. Otto (ISB # 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto(Pidahoconservation.org
20n SEP 22 PH 3: i.6
UTI
Attorney for Idao Conservtion Lee
BEFORE TI IDAHO PUBLIC UTILITIES i COMMISSION
IN THE MA TIER OF THE )¡
APPLICATION OF AVISTA )CASE NO. AVU-E-ll-02
CORPORATION REQUESTING )A vU-G-II-03
APPROVAL TO DECREASE ITS )!
ENERGY EFFICIENCY PUBLIC )COMMENirS OF THE IDAHOiPURPOSE RIDERSECHEDULES 91
~
CONSER~A nON LEAGUE
AND 191
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¡The Idaho Conservation League ("ICL") asks the Commis~ion to deny Avista's
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application to reduce the natual gas Energy Efficiency Rider Sch~dule 191. Avista asks this
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Commission to not just reduce the rider level, but actually retu t~ customers more money than
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the rider even collects. The request fles in the face of this Commi~sion's repeated instrctions
Ito acquire all available cost effective energy effciency. Instead, HCL urges the Commission to
¡
maintain fuding for natual gas DSM programs because they are 'rpowerful tools customers can
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use to mitigate the impact of rate increases." Order No. 29026, p. ~O, ipC- 02-2 and IPC- 02-3
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(May 13, 2002). In the face of rising utilty rates, including the pe~ding increase in the general
Irates and the Purchased Gas Cost rate, customers need access to thtse powerfl tools now more
Ithan ever. I
IAvista's stated reason for this request is that the curent rider account is overfded by
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$ 1.1 milion and the reduction "is to reduce the overfded balanct but should leave enough
fuding to cover operations even with increasing natual gas tagets." See Exhibit 1. However,
Avista asks to reduce the rider fuding by $2.9 milion while in 2010 the rider only collected
ICL COMMENTS 1 September 22, 201 1
$2,769,022. Application at 6; 2010 DSM Annual Report at 26, table 25. Meanwhile, in 2010
Avista spent $1,957,130 on natual gas effciency in Idao. 2010 DSM Report at 26, table 25.
The math simply does not make sense. A vista asks the Commission to approve a rider level of
essentially negative $130,978 to pay for programs costing at least $1,900,000.
Avista's own analysis reveals that significant cost effective potential for natul gas
effciencies exists in Idaho. The 2009 Natul Gas IR concludes that at a levelized anual cost
per therm of$0.5, the potential effciencies exceed 2,000,000 therms for the nortern division,
Washington and Idaho. Avista 2009 Natural Gas IRP at 6.9, figue 6.8. While natul gas prices
have changed since this IRP, Avista's recent Purchased Gas Cost adjustment case shows the
change is not significant enough to substantially reduce this level of potentiaL. Staffs recent
assessment of the forecasted cost of natual gas affrms Avista's weighted average cost of gas of
$0.4 1 797. Staff Comments at 6, A VU-G- 11 -04. Even at this lower price, Avista's IRP
documents potential gas efficiencies around 1,500,000 therms. IRP at 6.9, figue 6.8.
In 2010, Avista only achieved 85% of the goal they established in the 2009 IRP of
2,193,338 terms. App at 2; IRP at 4.9, table 4.3. The Idao service terrtory is roughly 33.47% of
this total, or 734,110 therms. IRP at 2.1 i But in Idao A vista only acquired 472,417 therms, or
64.35% of the goaL. 2010 DSM Report at 18-24.i Even assuming a lower cost effective potential
of 1,500,000 therms, Avista should have acquired 502,050 therms in 2010. Moreover, Avista
stated in the 2009 IRP that anual energy effciency savings should grow by 6.5% in order to
acquire all cost effective effciency they determined is available over the next ten years. IRP at
4.8 - 4.9,6.17. In this application Avista asks the Commission to virtally eliminate natual gas
i Table showing 145,600 Washington gas customers and 73,250 Idaho gas customers for a total
of218,850 customers in the nortern division as of December 31, 2008.
2 The per sector savings were: residential 330,629 therms, p. 18, table 18; low income 15,286
therms, p. 20, table 20; and non-residential 156,502 therms, p. 24, table 22.
ICL COMMNTS 2 September 22, 201 1
effciency fuding despite not acquiring all cost effective effciencies to date and apparently
hobbling its effort to acquire effciencies in futue years.
A vista has a very cost effective portfolio of measures to achieve these goals. The
application states the natual gas portfolio Total Resource Cost ratio is 1.62 and the Program
Administrator Cost ratio is 3.60. App at 6. These scores are even better in the 2010 DSM
Anual Report. In Idaho, the Total Resource Cost ratio is 2.80, the Program Administrator ratio
is 5.48, the Paricipant Cost ratio is 1.59, and the Ratepayer Impact Measure is 2.26. 2010 DSM
Report at 32-33. This last ratio is the most tellng because a positive number under the
Ratepayer Impact Measure means that investments in effciency will not just benefit paricipants,
but wil reduce rates for all natual gas customers. See NAPEE, Understanding Cost-
Effectiveness of Energy Effciency Programs, at 6-4. Avista's own documents reveal that
substantial potential effciencies are available and the portfolio to achieve their own goals is cost
effective from every possible perspective.
Based on the above, ICL believes the application does not present substatial evidence
upon which to approve virtally eliminating natual gas effciency fuding. Instead, the
evidence supports maintaining curent fuding so that Idahoans have powerfl tools to mitigate
the fort-coming rate increases.
WHEREFORE, ICL respectfully requests the Commission consider the foregoing comments.
DATED this 21 st day of September 2011.
Respectfully submitted,~~
Benjamin J. Otto
On behalf of the Idao Conservtion League
ICL COMMENTS 3 September 22, 201 1
Benjamin J. Otto (ISB # 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto(Pidaoconservation.org
Attorney for Idao Conservtion League
BEFORE THE IDAHO PUBLIC UTILITIS COMMISSION
IN THE MA TIER OF THE )
APPUCATION OF AVISTA )CASE NO. AVU-E-ll-02
CORPORATION REQUESTING )A VU-G-ll-03
APPROVAL TO DECREASE ITS )
ENERGY EFFICIENCY PUBUC )COMMENTS OF THE IDAHO
PURPOSE RIDER SECHEDULES 91 )CONSERVATION LEAGUE
AND 191 )
Exhbit 1
Disovery Respnses 6 and 3 from Avisa to ICL
Exhibit 1
A VU-E-l 1-02/A VU-E-II-03
ICL Comments
9/22/11 Page 4 of 6
JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
REQUEST:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO
A VU-E-ll-02 1 A VU-G-ll-03
Idaho Conservation League
Production Request
ICL-006
DATE PREPARD:
WITNESS:
RESPONDER:
DEPARTMENT:
TELEPHONE:
09/0112011
N/A
Lori Hermanson
DSM
[phone]
Please explain why Avista proposes to reduce fuding for DSM when the Company's portfolios
are cost effective.
RESPONSE:
Please refer to the response included for Product Request No. ICL-003.
JUSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
REQUEST:
A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
IDAHO DATE PREPARD:
A VU-E- 11 -02 1 A VU-G-l 1 -03 WITNSS:
Idaho Conservation League RESPONDER:
Production Request DEPARTMENT:ICL-003 TELEPHONE:
09/0112011
N/A
Lori Hermanson
DSM
[phone]
The Application states, on page 2, A vista achieved 105% of the IR goal for electrcity, but only
85% of the IRP goal for natual gas. Please explain why this record of achievement support a
larger reduction in the gas rider tariff than the electrc rider taff.
RESPONSE:
The increase in Idaho Schedule 191, effective October 1, 2010, was to cover the operations of
Idaho natual gas energy effciency programs as well as to reduce the underfuded balance of
over $1.3 milion (balance at effective date). To date, we have a overfuded balance of $1.1
millon for Idaho natul gas so the proposed reduction is to reduce the overfuded balance but
should leave enough fuding to cover operations even with increasing natual gas tagets.
Exhibit 1
A VU-E-l 1 -021 A VU-E-II-03
ICL Comments
9/22/1 1 Page 5 of 6
CERTIFICATE OF SERVICE
I hereby certify that on this 22nd day of September, 2010 I delivered true and
correct copies of the foregoing COMMENTS OF THE IDAHO CONSERVATION
LEAGUE to the followig persons via the method of servce noted:
Hand delivery
Jean Jewell
Commission Secretar (Origial and seven copies provided)
Idao Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
Electronic Mail:
David J. Meyer, Esq.
Vice President & Chief Counsel, Reguatory and Government Affairs
A vista Corpration
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
David.meyer(avistacorp.com
Bruce Folsom
Senior Manager, Energy Efficiency
_A vista Corporation
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
Bruce. Folsom(P A vistacorp.com
!l ~
Benjamin J. Otto
Idao Conservation League