20240826Staff 1-12 to AVU.pdf

RECEIVED
Monday, August 26, 2024 11.39.53 AM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATIONS )
OF AVISTA CORPORATION FOR A ) CASE NO. AVU-E-24-09 AND
DETERMINATION OF 2022-2023 ELECTRIC ) CASE NO. AVU-G-24-03
AND NATURAL GAS ENERGY EFFICIENCY )
EXPENSES AS PRUDENTLY INCURRED ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Avista Corporation, doing business as
Avista Utilities, ("Company")provide the following documents and information as soon as
possible,but no later than MONDAY, SEPTEMBER 16, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 AUGUST 26, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide a list in Excel format showing all expenses charged
to the electric and gas Demand Side Management ("DSM")riders in 2022 and 2023. Please
include the following information for each expense: the date, vendor, amount, program, task
number, and account to which the charges were assigned. Please include and identify any
adjustments made in 2022 and 2023 to previously incurred expenses. Please also separate all
expenses by program. If any amounts were allocated to multiple programs and/or jurisdictions,
please describe the allocation method. Please identify whether each expense is an incentive
payment,purchase, service, labor/admin, materials, or any other classification of expense.
REQUEST NO. 2: Please provide copies of all internal audit reports for audits
completed on the Company's electric and gas DSM processes and expenses from 2022 to 2023.
Please list the scope of any internal audits in progress on the Company's electric and gas DSM
processes and expenses.
REQUEST NO. 3: Please provide the electric and gas tariff rider revenue by month and
by class for 2022 and 2023.
REQUEST NO. 4: Please provide the calculation of any monthly carrying charge or
interest on the electric and gas rider balances during 2022 and 2023.
REQUEST NO. 5: Please provide the amount of labor expenses charged to the Idaho
electric and gas DSM tariff riders for the years 2022 and 2023. For each year,please include the
number of full-time equivalent positions funded by the rider. Please also provide the general
wage adjustment percentage for non-union personnel approved by the Compensation Committee
of the Board of Directors for each year.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 AUGUST 26, 2024

REQUEST NO. 6: Please provide a current organizational chart by title and name
showing all Avista employees who charge time to the electric and gas DSM riders. Please
include complete job descriptions, required qualifications, salary ranges, bonus opportunities,
and total compensation ranges, including benefits, for all employees identified in this request.
REQUEST NO. 7: Please provide a listing of all legal and consulting fees, including,
but not limited to Evaluation, Measurement and Verification, charged to the Idaho electric and
gas DSM tariff rider during 2022 and 2023.
REQUEST NO. 8: Please provide cost-effectiveness workpapers and calculations for all
DSM programs and measures by year(2022 and 2023) in Excel format with formulas intact and
all assumptions clearly defined. Please include savings per unit and assumption source for each
measure.
REQUEST NO. 9: For each recommendation from the evaluation of the Company's
NEEA program,please explain if the Company has requested the recommended action from
NEEA for the 2025-2029 Business Cycle.
REQUEST NO. 10: Please describe any changes made to the NEEA business plan in
response to the Evaluation recommendations.
REQUEST NO. 11: Please provide any communication between the Company and
NEEA related to the Evaluation or implementation of Evaluation recommendations.
REQUEST NO. 12: For NEEA's 2025-2029 Business Cycle, please provide the
expected cost for the Company and how that funding amount was determined. Additionally,
please identify any cost associated with ad hoc requests (i.e., cost to implement
recommendations or measures for Avista specifically) and provide a breakdown of costs
associated with the Business Plan to the greatest extent possible (i.e., administration, codes,
standard changes, measure support, etc.).
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 AUGUST 26, 2024

DATED at Boise, Idaho, this 26th day of August 2024.
n -L,
r
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\AVU-E-24-09 and AVU-G-24-03 PR#l.docx
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 AUGUST 26, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 261h DAY OF AUGUST 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NO. AVU-E-24-
09/AVU-G-24-03, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
DAVID J MEYER SHAWN J BONFIELD
VP & CHIEF COUNSEL SR MGR REGULATORY POLICY
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: david.mgyergavistacorp.com E-mail: shawn.bonfield(cr�,avistacorp.com
avistadocketskavistacorp.com
PATRICIA JORDAN, CRETARY
CERTIFICATE OF SERVICE