6.5.20 - Ameren and Avista
Updated: Aug 31, 2020
Washington State - Avista Commits to offer an On-bill Repayment/Financing; Advocates want PAYS
On March 25, 2020 The Washington Utilities Transportation Commission Issued Final Order 09 for Dockets UE-190334, UG-190335, and UE-190222 (Consolidated) that Approved and Adopted a Partial Multiparty Settlement Stipulation including the section in which “the Parties have agreed to a plan for the development of an on-bill repayment or financing program for residential and small business customers.”
Avista will work with its Energy Efficiency Advisory Group (EEAG) to develop this program to be filed with the Commission for implementation by September 30, 2021.
The agreement is consistent with PAYS but does not specify or require PAYS or tariff on-bill. Officially, “The Parties agreed that the recovery of development costs for any on-bill repayment or financing program will be recoverable from customers, but not on the method of recovery.”
The NW Efficiency Coalition is a member of the EEAG and proposed PAYS by name as the preferred on-bill repayment or financing method in its testimony (See PAYS Pals 3.27.20).
The EEAG has not met since the Commission approval, due to COVID 19 related delays.
LibertyHomes will be speaking today to NW Energy Coalitions representative on the EEAG, Amy Wheeless, to discuss strategy and get her thoughts on what types of PAYS materials would be most helpful to her and the EEAG as they advocate for PAYS. We have also referred her to a list of PAYS champions that can make a persuasive case for PAYS over other on-bill solutions; Clean Energy Works has indicated that they will be reaching out to offer support to the NW Energy Coalition and rest of the EEAG.
In this settlement, Avista also committed to a disconnection reduction plan of which the PAYS program could be a key component.
"The Parties agree that Avista will gather data on disconnections, as provided in testimony by The Energy Project’s witness Collins. Avista agrees to collect and report the disconnection data annually to the Commission and Public Counsel. Avista also agrees to develop a Disconnection Reduction Plan that will limit disconnections prospectively. This plan will be developed with the Energy Assistance Advisory Group, which will deliver a recommendation to the Commission within one year of the date of this Order.”
There has been increasing attention to the poor data on disconnections, although the scale of the problem even prior to COVID-19 was very serious as detailed in the NAACP’s Environmental and Climate Justice Project 2017 report “Lights Out In the Cold Report: Reforming Utility Shutoff Policiesas If a Human Rights Matter” (Attached); NAACP reports that an update is in the works.
Ameren Missouri Files for PAYS Pilot!
On May 13, Ameren Missouri filed its model PAYS tariff with the Missouri Public Service Commission. (Officially: File No. EO-2018-0211: In the Matter of Union Electric Company d/b/a Ameren Missouri’s 3rd Filing to Implement Regulatory Changes in Furtherance of Energy Efficiency as Allowed by MEEIA [Missouri Energy Efficiency Investment Act]: APPLICATION FOR MODIFICATION OF DEMAND-SIDE MANAGEMENT PLAN, APPROVAL OF ASSOCIATED VARIANCES, AND ADOPTION OF A PROCEDURAL SCHEDULE).
The pilot references PAYS and Pay As You Save by name and the Exemplar Tariff closely follows EEI’s model PAYS tariff in language and structure!
We’ve attached the filing and relevant attachments to this email for your convenience See Attachment 8, pp 5-9 for the language of the Exemplar PAYS Tariff). If you want to point someone to the materials on the official site send them to www.efis.psc.mo.gov under case number EO-2018-0211. They will need to register if you haven’t been to the site before you can access the files.
The Tariff is part of a request for a one year extension (for 2022) to their MEEIA Cycle III programs and are proposing to implement their PAYS pilot in the extension year. There’s a lengthy process still to come (Rebuttal Testimony will be filed by June 30 with the process of subrebuttal, cross-subrebuttal, discovery, listing of issues and witnesses, cross examination, and position statements continuing through July 22. Evidentiary hearings will be held on July 27-28, with final Reply Briefs submitted on August 20.) culminating with The Requested Order on September 17.
We hope that in the negotiation process the PAYS pilot start date will be moved forward to 2021, even if the extension is granted. Part of the purpose of the pilot is to provide data that would allow Ameren to decide whether to expand the pilot into a full scale program in the next MEEIA cycle, which would be difficult to do if it was underway and not yet evaluated during the period Ameren would have to be filing their plan.
Ameren is investing its own capital and has proposed to earn a 5% return ($250K). The expected profit from the MWh and MW savings from the program (4445 MWH, and 2.08, MW, respectively) will generate another $257K for a total of $507k. Ameren is projecting it will complete 926 upgrades for an average profit of $548/home.
Total program cost is $2.26M (excluding earnings) of which $1M is incentives and $1M is program operation and EM&V.
We’ll keep you posted as the process unfolds but we are VERY EXCITED.