20240820AVU to Staff 1-8.pdf

RECEIVED
2024 August 20
AVISTA CORPORATION IDAHO PUBLIC
RESPONSE TO REQUEST FOR INFORMATION UTILITIES COMMISSION
JURISDICTION: IDAHO DATE PREPARED: 08/20/2024
CASE NO: AVU-E-24-07 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Janice Gibler
TYPE: Production Request DEPARTMENT: Internal Audit
REQUEST NO.: Staff- 001 TELEPHONE: [phone]
REQUEST:
Please provide copies or access to workpapers, memorandums, and reports that document any
external and internal reviews performed on any PCA components for the PCA test year,July 2023
through June 2024 (power supply costs, including coal and gas burn expense, coal contracts, coal
reports, coal inventories,wheeling expense, and PCA deferral accounting, as an example). Please
include within your response any documentation prepared for Sarbanes-Oxley (SOX), internal
audit, external audit, other jurisdictional inquiries, and communications (including but not limited
to data requests, comments, memoranda, reports, and orders).
RESPONSE:
Please see Avista's response Staff_PR_001C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
Please see Staff-PR-001 C Confidential Attachment A for the internal audit report related to the
Colstrip Power Plan Audit for the two years-ended December 31, 2022 and issued in December
2023. This was the only internal audit report that relates to a component of the PCA test year
requested.
See Staff-PR-001 Attachment A for a listing of SOX controls in effect as of December 31, 2023,
including whether they were tested by Internal Audit for operating effectiveness and the results.
Additionally, see Staff-PR-001 Attachment B for a copy of the unqualified opinion on the
Company's internal control over financial reporting from Deloitte & Touche LLP from the 2023
1 OK.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/20/2024
CASE NO: AVU-E-24-07 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Janice Gibler
TYPE: Production Request DEPARTMENT: Internal Audit
REQUEST NO.: Staff—001C TELEPHONE: [phone]
REQUEST:
Please provide copies or access to workpapers, memorandums, and reports that document any
external and internal reviews performed on any PCA components for the PCA test year,July 2023
through June 2024 (power supply costs, including coal and gas burn expense, coal contracts, coal
reports, coal inventories,wheeling expense, and PCA deferral accounting, as an example). Please
include within your response any documentation prepared for Sarbanes-Oxley (SOX), internal
audit, external audit, other jurisdictional inquiries, and communications (including but not limited
to data requests, comments, memoranda, reports, and orders).
RESPONSE:
Please note an attachment to this response contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are filed under IDAPA 31.01.01, Rule 067 and 233, and
Section 9-340D, Idaho Code.
Please see Staff-PR-001 C Confidential Attachment A for the internal audit report related to the
Colstrip Power Plan Audit for the two years-ended December 31, 2022 and issued in December
2023. This was the only internal audit report that relates to a component of the PCA test year
requested.
See Staff-PR-001 Attachment A for a listing of SOX controls in effect as of December 31, 2023,
including whether they were tested by Internal Audit for operating effectiveness and the results.
Additionally, see Staff-PR-001 Attachment B for a copy of the unqualified opinion on the
Company's internal control over financial reporting from Deloitte & Touche LLP from the 2023
1 OK.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/20/2024
CASE NO: AVU-E-24-07 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Janice Gibler
TYPE: Production Request DEPARTMENT: Internal Audit
REQUEST NO.: Staff- 002 TELEPHONE: [phone]
REQUEST:
To the extent not previously provided, please provide a list of all Internal audit department audits
and reviews that were performed within the last three years or are planned to be performed
associated with all components of the PCA: the activities of commercial and trading,coal expense,
coal management, coal operations/plant management,joint and affiliate transactions, natural gas
expense, wheeling expense and revenues, PCA deferral accounting, and so forth. Please include
within your response a contact name to obtain copies and discuss the audits.
RESPONSE:
Below is a listing of audits and reviews performed within the last three years or are planned to be
performed associated with the PCA:
2022—
No audits performed.
2023-
2021-2022 Colstrip Units 3 and 4 Operations Audit (Two years ended 12/31/22) — see Staff-PR-
001 C Confidential Attachment A for a copy of the internal audit report.
2024-
No audits performed.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/20/2024
CASE NO: AVU-E-24-07 WITNESS: K. Schultz/K. Holland
REQUESTER: IPUC RESPONDER: J. Hossack/C. Kettner/
K. Meister
TYPE: Production Request DEPARTMENT: Resource Accounting
REQUEST NO.: Staff-003 TELEPHONE: [phone]
REQUEST:
For the PCA year(July 2023 to June 2024),please provide the following:
a. A spreadsheet containing all entries by month pertaining to the following actual
expenses:
i. 555 Purchased Power;
ii. 447 Sale for Resale;
iii. 501 Thermal Fuel;
iv. 547 CT Fuel;
V. 456 Transmission Rev;
vi. 565 Transmission Exp;
vii. 557 Expenses;
viii. 537 MT. Invasive Species;
ix. 557 Expense Broker Fees;
X. 557 Resource Optimization; and
xi. Actual REC Revenue.
b. Include within your response sufficient detail from which to select the transactions for
testing such as the transaction description, vendor name,posting month, MWhs,
sequence number, dollar amount, and account number where posted; and
c. Reconcile the data provided to the actual net power expense categories included
within the Company's PCA Report and forthcoming PCA Application.
RESPONSE:
Please see Avista's response Staff-PR-003C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
For parts a through c, please see Staff-PR-003C Confidential Attachment A for the requested
information.
Page 1 of 1

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/20/2024
CASE NO: AVU-E-24-07 WITNESS: K. Schultz/K. Holland
REQUESTER: IPUC RESPONDER: J. Hossack/C. Kettner/
K. Meister
TYPE: Production Request DEPARTMENT: Resource Accounting
REQUEST NO.: Staff-003C TELEPHONE: [phone]
REQUEST:
For the PCA year(July 2023 to June 2024),please provide the following:
a. A spreadsheet containing all entries by month pertaining to the following actual
expenses:
i. 555 Purchased Power;
ii. 447 Sale for Resale;
iii. 501 Thermal Fuel;
iv. 547 CT Fuel;
V. 456 Transmission Rev;
vi. 565 Transmission Exp;
vii. 557 Expenses;
viii. 537 MT. Invasive Species;
ix. 557 Expense Broker Fees;
X. 557 Resource Optimization; and
xi. Actual REC Revenue.
b. Include within your response sufficient detail from which to select the transactions for
testing such as the transaction description, vendor name,posting month, MWhs,
sequence number, dollar amount, and account number where posted; and
c. Reconcile the data provided to the actual net power expense categories included
within the Company's PCA Report and forthcoming PCA Application.
RESPONSE:
Please note this response contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL
information and are filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho
Code.
For parts a through c, please see Staff-PR-003C Confidential Attachment A for the requested
information.
Page 1 of 1

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/14/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 004 TELEPHONE: [phone]
REQUEST:
Please provide a copy of the Company's hourly generation logs by plant for the PCA year (July
2023 to June 2024).
RESPONSE:
For the requested information,please see Staff-PR-004 Attachment A.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/14/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff—005C TELEPHONE: [phone]
REQUEST:
Please provide a copy of all reports that discuss operational problems with any component of the
Company's generation fleet during the PCA test year.
RESPONSE:
Please note this response contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL
information and exempt from public view and is separately filed under IDAPA 31.01.01,Rule 067
and 233, and Section 9-340D, Idaho Code.
The Company experienced forced outages exceeding 24 hours' at several thermal and hydro
facilities during the PCA review period of July 2023 through June 2024. Please see the following
attachments for further explanation:
All Facilities Excluding Colstrip and Lancaster2
Avista has provided two GADS spreadsheets, one for July 1, 2023 through December 31, 2023
(Staff-PR-005C Confidential Attachment A), and one for January 1, 2024 through June 30, 2024
(Staff-PR-005C Confidential Attachment B). These confidential spreadsheets detail all outages of
any kind for all of Avista's facilities except for Colstrip and Lancaster. For ease of reference, the
tab labeled "Summary" in each of these excel files shows those facilities that had forced outages
(Event Type codes Ul, U2, U3, or SF) in excess of 24 hours during the PCA review period.
Colstrip
Staff-PR-005C Confidential Attachment C contains the Owner Summary Event log for July 2023
—June 2024 for Colstrip. The confidential attachment provides a brief summary for the reason for
the various outages.
1 The Company is defining"operational problems"as forced outages exceeding 24 hours.
2 There were no forced outages exceeding 24 hours at Lancaster during the PCA review period(July 1,2023—June 30,
2024).

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/14/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Ryan Finesilver
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff- 006 TELEPHONE: [phone]
REQUEST:
Please provide supporting documentation as well as a narrative on how the Idaho actual sales were
calculated, along with any safeguards or internal controls to ensure its accuracy.
RESPONSE:
In the case of Idaho actual sales utilized in the calculation of the Idaho PCA amortization,
Resource Accounting runs a report out of Cognos which provides the total volume and dollars
associated with the PCA (Schedule 66) at the revenue level. A calculation is made which
multiplies the PCA revenue times the revenue conversion factor in order to convert it to the
expense level for monthly journal recording. These reports are within the journals provided as part
of the quarterly PCA report. For ease of reference, the quarterly reports were also provided in the
Annual PCA Filing on July 31, 2024. These journals are verified by the Resource Accounting
Manager and are subject to internal and external audit controls.

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/16/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Megan Thilo
TYPE: Production Request DEPARTMENT: Risk Management
REQUEST NO.: Staff—007C TELEPHONE: [phone]
REQUEST:
Please provide the Company's most recent risk management policy. Please include within your
response any changes made since January 1, 2023 to date and the underlying reasons for those
changes.
RESPONSE:
Please note this response contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL
information and exempt from public view and is separately filed under IDAPA 31.01.01,Rule 067
and 233, and Section 9-340D, Idaho Code.
The most recent version of the Risk Management Policy is attached at Staff-PR-007C Confidential
Attachment A.
The following changes were made to the Risk Management Policy since January 1, 2023:
• January 23, 2023 — changes were made to the Risk Management Policy to add language
around the trading of Environmental Attributes (physical carbon allowance contracts,
carbon allowance futures contracts and renewable energy contracts). A redline version
showing the changes is included at Staff-PR-007C Confidential Attachment B.
• September 18, 2023 — changes were made to Exhibit 2 Power Supply Hedging Plan
(PSHP)of the Risk Management Policy to add language around the hedging of thermal gas
associated with serving customer load. A redline version showing the changes is included
at Staff-PR-007C Confidential Attachment C.
In December 2022 and January 2023, western US electric and natural gas markets experienced
extremely high prices. As a result,the Risk Management Committee approved three exceptions to
the Risk Management Policy. These exceptions are temporary in duration and, as such,no formal
changes were made to the Risk Management Policy itself. The exceptions were documented
separately, as described below:
• February 20, 2023—This exception allows for the increased purchase of natural gas to fuel
the thermal plants prior to the delivery period. For most forward periods, Avista was
financially long.Avista's electric hedging program rolls the power and gas position up into
a single combined financial position. For many of the periods where the combined position
is financially long,the Company is technically long power and short gas.For those periods,
if Avista were to go into the futures market and purchase natural gas without selling the
power, it would push the financial position even longer (from a combined perspective),
which was in opposition to the Risk Management Policy (trading away from a zero

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 08/16/2024
CASE NO: AVU-E-24-07 WITNESS: Kevin Holland
REQUESTER: IPUC RESPONDER: Megan Thilo
TYPE: Production Request DEPARTMENT: Risk Management
REQUEST NO.: Staff- 008 TELEPHONE: [phone]
REQUEST:
Please identify any changes to the risk management policy that are under consideration or on the
horizon. Please include within your response the underlying reasons for those changes.
RESPONSE:
We are continually monitoring and evaluating the Risk Management Policy and associated
hedging models. The Risk Management Committee has not approved any recent or future changes
to the Risk Management Policy.
Please see the Company's response to Staff-PR-007C.

financial position). This exception temporarily amended the Risk Policy requirement that
prohibits trading away from a zero financial position,when financially long. A copy of the
exception is included at Staff-PR-007C Confidential Attachment D.
• May 15, 2023 — This exception temporarily increases the target hedge percentage for
winter 2023/2024 from 40-60% to 60-75%, within the Natural Gas Hedging program. It
also discusses scaling back the storage optimization program, limiting it to the current
season. A copy of the exception is included at Staff-PR-007C Confidential Attachment E.
• March 18, 2024—This exception incorporated a temporary increase to forecasted load for
the months of December 2024, and January and February 2025 within the Natural Gas
Hedging program. A copy of the exception is included at Staff-PR-007C Confidential
Attachment F.
Additionally, transaction authority at Exhibit 5 was updated on the below listed dates to reflect
updated personnel changes only:
• March 1, 2023
• May 22, 2023
• June 13, 2023
• July 10, 2023
• August 28, 2023
• November 6, 2023
• December 1, 2023
• January 8, 2024
These changes are considered minor and have not been included as an attachment to this
production request.