20241108Staff 14-18 to AVU.pdf

RECEIVED
Friday, November 8, 2024 9.41:06 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 ) THIRD 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 FRIDAY, NOVEMBER 29, 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.
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 1 NOVEMBER 8, 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. 14: Please indicate the IRP year used to provide avoided cost forecasts
in the Company's 2023 electric and natural gas cost-effectiveness workpapers provided in
Response to Production Request No. 8.
REQUEST NO. 15: Please describe the Company's processes and controls for
maintaining workpaper versioning.
REQUEST NO. 16: The Cost-effectiveness workpapers provided as Attachments B and
C to the Company's response to Production Request No. 8 differ significantly from previous
years. Please explain the need to revise the workpapers and provide a changelog of
improvements made to the workpaper.
REQUEST NO. 17: Please provide a breakdown of all 2023 third-party costs by fuel
type showing cost allocation by sector and program.
REQUEST NO. 18: Please reconcile the non-incentive utility costs ("NIUC") in the
NIUC tab with program and measure level NIUC column of the Residential CE tab of
Attachment B of the response to Production Request No. 8. Please provide updated workpapers
with the reconciled measure level cost-effectiveness calculations.
DATED at Boise, Idaho, this 8th day of November 2024.
K._7tZ4-`tA
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\AVU-E-24-09 and AVU-G-24-03 PR#3.docx
THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 2 NOVEMBER 8, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF AUGUST 2024,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION , IN CASE NO. AVU-G-24-03
AND CASE NO. AVU-E-24-09, 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.meyergavistacorp.com E-mail: shawn.bonfieldgavistacorp.com
avi stadocketsnavi stacorp.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE