20250108 AVU Reply Comments .pdf

11
RECEIVED
Avista Corp. Wednesday, January 8, 2025 10:38 AM
1411 East Mission P.O. Box 3727 IDAHO PUBLIC
Spokane, Washington 99220-0500 UTILITIES COMMISSION
Telephone [phone]
Toll Free 800-727-9170
January 8, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Suite 201-A
Boise, Idaho 83714
Re: Case Nos.AVU-E-24-09 and AVU-G-24-03—Reply Comments of Avista Utilities
Dear Commission Secretary:
Pursuant to the Notice of Modified Procedure issued by the Idaho Public Utilities
Commission (IPUC or Commission) on October 30, 2024,1 Avista Corporation, dba Avista
Utilities (Avista or the Company), respectfully submits the following reply comments in response
to the written comments of Commission Staff(Staff), as filed on December 19, 2024.
Avista appreciates Staff's thorough review of its 2022-2023 Energy Efficiency Program
(Program)and the findings that nearly all of the Company's expenses were prudent. The Company
find Staff s comments to be comprehensive, reasonable, and articulate, and is grateful for the
continued collaboration and oversight provided by Staff. The Company acknowledges the
recommendations provided by Staff will only serve to further strengthen Avista's Program,
particularly to provide an additional compliance filing to report on the results of the corrective
actions taken because of Staff s recommendations. The Company also agrees with Staff s
recommendation to continuously improve the workpapers utilized in the calculation of cost-
effectiveness and looks forward to sharing those improvements as they are developed.
Staffs audit of Avista's Program uncovered discrepancies in the allocation of a handful of
invoices; upon investigation of these errors, the Company determined that the majority of them
were related to an inconsistent application of the Company's general ledger coding rules by a select
number of newer employees. In response to this discovery, the Company undertook several
' Order No. 36365.

remedial actions. First, the Energy Efficiency team reviewed all 2022-2023 invoices related to
vendors from which initial errors were discovered. Management also reviewed the existing
authorization and approval rights within its invoicing system to ensure proper oversight and
approval of invoices, and modified these approvals as needed to add an extra layer of control to
such authorizations and provide further insulation against potential coding errors. Mandatory
training for all individuals that deal directly with energy efficiency tariff funds was also developed.
Finally, a request for an audit of general ledger transactions impacting the energy efficiency tariff
funds for program year 2024 was requested of Avista's Internal Audit department. The results of
such an audit will be provided, along with program years 2022 and 2023, within the Company's
compliance filing as requested within Staff's comments and described below.
Further, as a result of this research and analysis, Avista identified an additional $2,901 in
electric expenditures and $1,431 in natural gas expenses — both related to funds paid to the
Northwest Energy Efficiency Alliance (NEEA) — that required reallocation. Avista respectfully
requests that these amounts be removed from the $15,866,304 (electric) and $4,146,586 (natural
gas) in prudent expenditures recommended within Staffs comments, for a total of$15,863,403
and$4,145,155, respectively, to be approved instead.
Overall, Avista supports Staffs conclusion that "...based on Staffs audit findings in its
samples of program years 2022 and 2023, Staff believes an internal audit must also be conducted
for the program years 2022 and 2023. Staff recommends the Company provide a report when the
steps outlined above are completed. The report should include a copy of the employee training
curriculum, the internal audit report and findings for program years 2022-2024, and outline any
changes made to the authorization levels in the accounting system. Staff further recommends the
Commission reserve the right to make further adjustments to the rider account balances in the next
DSM prudence filing based on the findings of the Company's internal audit."2 The Company looks
forward to providing this compliance filing and to continue further improving its processes and
procedures based on Staff s recommendations.
If you have any questions regarding this filing, please Kim Boynton, Manager, Energy
Efficiency Analytics, at(509) 495-4744 or kim.boynton(d),avistacorp.com.
2 Staff Comments,pg.4. 41

Sincerely,
Jaime Majure
Regulatory Affairs Manager