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HomeMy WebLinkAbout20250131Direct T. Benjamin_Exhibits.pdf RECEIVED Friday, January 31, 2025 IDAHO PUBLIC UTILITIES COMMISSION DAVID J. MEYER VICE PRESIDENT AND CHIEF COUNSEL FOR REGULATORY& GOVERNMENTAL AFFAIRS AVISTA CORPORATION P.O. BOX 3727 1411 EAST MISSION AVENUE SPOKANE, WASHINGTON 99220-3727 TELEPHONE: (509) 495-4316 DAV ID.MEYER@AVI S TACORP.COM BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-E-25-01 OF AVISTA CORPORATION FOR THE ) CASE NO. AVU-G-25-01 AUTHORITY TO INCREASE ITS RATES ) AND CHARGES FOR ELECTRIC AND ) DIRECT TESTIMONY NATURAL GAS SERVICE TO ELECTRIC ) OF AND NATURAL GAS CUSTOMERS IN THE ) TIA C. BENJAMIN STATE OF IDAHO ) FOR AVISTA CORPORATION (ELECTRIC AND NATURAL GAS) 1 I. INTRODUCTION 2 Q. Please state your name, employer and business address. 3 A. My name is Tia C. Benjamin. I am employed by Avista Corporation as 4 Manager of Regulatory Affairs in the Regulatory Affairs Department. My business address is 5 1411 East Mission, Spokane, Washington. 6 Q. Please briefly describe your educational background and professional 7 experience. 8 A. I am a graduate of the University of Idaho with a Bachelor of Science degree, 9 majoring in Accounting. After spending nearly four years in financial services in the public 10 school system,I joined Avista in July 2011 where I have since served in several roles including 11 an Analyst on our Asset Management team and several years on our Budget and Forecasting 12 team before joining the Regulatory Affairs Department in September 2020. In my current role 13 as Manager of Regulatory Affairs, I am responsible for, among other things, preparing the 14 capital additions pro forma adjustments in determination of the revenue requirement for all 15 jurisdictions in which the Company provides utility services. 16 Q. What is the scope of your testimony? 17 A. My testimony and exhibit in this proceeding will describe the Company's 18 restated twelve-months ended (12ME) June 30, 2024 net plant from average-of-monthly- 19 averages (AMA) to an end-of-period (EOP) adjustment, as well as explain how pro forma 20 capital additions for the period of July 1, 2024, through August 31, 2027, are incorporated 21 into the Company's Two-Year Rate Plan' and proposed electric and natural gas revenue 'The Company is proposing a Two-Year Rate Plan for the period September 1,2025,through August 31,2027. For both electric and natural gas,the Company is proposing an increase for Rate Year 1 effective September 1, 2025 (hereafter"RY1"),and Rate Year 2 effective September 1,2026(hereafter"RY2"). Benjamin, Di 1 Avista Corporation I requirements sponsored by Company witness Ms. Schultz. A table of contents for my 2 testimony is as follows: 3 TABLE OF CONTENTS 4 Description Page 5 I. INTRODUCTION............................................................................ 1 6 II. CAPITAL ADDITIONS WITNESSES..........................................2 7 III. SUMMARY OF CAPITAL ADJUSTMENTS ............................. 8 8 9 Q. Are you sponsoring any exhibits? 10 A. Yes. I am sponsoring Exhibit No. 13, Schedule 1, which provides a summary 11 of the capital additions included in each of the capital witnesses' testimonies by project 12 (Business Case) for the period of July 1, 2024, through August 31, 20272, broken out by pro 13 forma period, July 2024 through August 2025 (pro forma prior to the rate effective period), 14 Rate Year 1 (RY1) September 2025 through August 2026, and Rate Year 2 (RY2) September 15 2026 through August 2027. 16 17 II. CAPITAL ADDITIONS WITNESSES 18 Q. Would you please provide a brief summary of the witnesses who provide 19 testimony related to capital additions in this proceeding? 20 A. Yes. Other capital witnesses, besides Ms. Schultz and myself who support the 21 capital-related adjustments,provide more detailed information on certain capital projects and 22 describe the need for and timing of these capital projects. The following witnesses are 23 presenting direct testimony supporting the capital additions adjustments I sponsor3 as outlined z Company witnesses Mr.DiLuciano,Mr.Howell,Mr.Manuel and Mr.Malensky sponsor testimony explaining the Company's capital additions for the Pro Forma adjustments I sponsor. 3 With the exception of the Pro Forma Colstrip Unit 3 and 4 investment and regulatory amortization included in Pro Forma Adjustments 3.15 discussed and sponsored by Company witness Ms.Andrews. Benjamin, Di 2 Avista Corporation I in Section III below: 2 Mr. David Howell, Director of Generation Production and Substation Support, will 3 address the generation production and environmental capital Business Cases described 4 in this case. 5 6 Mr. Josh DiLuciano,Vice President of Energy Delivery,will explain capital additions 7 related to electric transmission and distribution, natural gas delivery, facilities, fleet, 8 and general plant. 9 10 Mr. Wayne Manuel, Vice President and Chief Information and Security Officer, will 11 provide an overview of Avista's Information Service/Information Technology(IS/IT) 12 programs and projects. This includes summaries of the Company's capital additions 13 for a range of IS/IT systems used by the Company, many representing short-lived 14 assets. 15 16 Mr. Vern Malensky, Director of Electrical Engineering, will discuss the strategy and 17 actions comprising the Company's Wildfire Resiliency Plan. 18 19 Q. How have capital witnesses presented the transfers-to-plant information 20 in their testimony? 21 A. Mr. Howell, Mr. DiLuciano, Mr. Manuel and Mr. Malensky present capital 22 transfers-to-plant (gross plant additions) for the pro forma period on a system basis (Idaho, 23 Washington, and Oregon jurisdictions).4 Each witness's testimony discusses capital additions 24 from July 1, 2024, to August 31, 2027, on a system basis. A detailed listing of Business Case 25 (project) names and totals for the pro forma adjustment period July 2024—August 2027 can 26 be found in my Exhibit No. 13, Schedule 1. Table No. 1 below also reflects the pro forma 27 period broken out by July 1, 2024 —August 31, 2025, RY1 September 1, 2025 —August 31, 28 2026 and RY2 September 1,2026—August 31,2027 transfers-to-plant(TTP)for projects that 29 are discussed in each witness's testimony, on a system basis: 4 The Company has excluded Business Cases which have transfers to plant that exclusively occur in Washington or Oregon and therefore do not impact Idaho. Benjamin, Di 3 Avista Corporation I Table No. 1: Pro Forma Capital Additions 2 Capital Additions(System),S in(0001s) Exhibit Rate Year 1 Rate Year 2 3 Juh•2024- Sept 2025- Sept 2026- Functional Area witness NO August 2025 August 2026 August 2027 4 Electric Transmission&Distribution Mr.DiLuciano 10 $ 204.646 $ 162.688 $ 201.435 Natural Gas Distribution Mr.DiLuciano 10 $ 95.873 $ 81.971 $ 83.886 5 General Plant&Fleet Investments Mr.DiLuciano 10 $ 21.957 $ 13.877 $ 17.087 Generation Production&Environmental Mr.Howell 7 $ 66.166 $ 66.733 $ 54.000 6 Wildfire Resiliency Plus Mr.Malensky 11 $ 40.834 $ 51.500 $ 60.250 Enterprise Technology Mr.Manuel 12 $ 109.776 $ 66.340 $ 83.140 7 Total S 539,253 S 443.109 S 499,798 8 Q. Referring to Table No. 1 above, reflecting system level capital projects 9 transferring to plant by Witness, what is the overall level of system capital additions 10 included by the Company in this case, and how does this capital investment compare 11 between the pro forma periods,July 2024—August 2025, RY1 and RY2? 12 A. Illustration No. 1 below shows overall total system capital additions for pro 13 forma July 2024—August 2025,RY1 and RY2 periods,of$539.3 million, $443.1 million and 14 $499.8 million, respectively. As also noted in the illustration, the "Pro Forma" period 15 represents 14 months (July 1, 2024—August 31, 2025). Finally, this illustration distinguishes 16 between what are ongoing projects or programs from the pro forma period ending August 17 2025, versus incremental projects that are expected to transfer-to-plant between September 18 2025 through August 2027, representing $40.8 million in RY1 and $30.5 million in RY2.5 19 5 Witnesses Mr. Howell, Mr. DiLuciano, and Mr. Manuel, who address most of the capital projects,have also included similar bar charts for the transfers to plant represented by the Business Cases in each of their respective areas by period, Pro Forma, RY1 and RY2. Each depicts transfers to plant of existing Business Cases versus transfers-to-plant associated with entirely new Business Cases in RY1 and RY2. Benjamin, Di 4 Avista Corporation I Illustration No. 1—System Total Capital Additions Plant Investment 2 Avista Total Annual Capital Additions $'s in millions (System Transfers to Plant) 3 $600 (l) $30.5(2) 4 $500 $40.8 $400 5 $300 6 $200 7 $100 S- 8 Pro Forma RY1 RY2 July 2024-Aug 2025 Sept 2025-Aug 2026 Sept 2026-Aug 2027 9 $539.3 $443.1 $499.8 ■Continuation of Ongoing Business Cases ■Additional Business Cases Initiated in RYl-RY2 10 w The majority of incremental investment in RY1 is associated with Coyote Springs 2(CS2)CT Rotor Replacement and Noxon Rapids Gantry Crane Modernization,totaling$39.1 million. (2)The majority of incremental investment in RY2 is associated with KF Ash Landfill Expansion,CS2 Low Pressure Evaporator 11 Replacement,Central 24 HR Operations Facility,and Energy Trade&Risk Management Implementation,totaling$28.2 million. 12 Notably, as can be seen from this illustration, the vast majority of the capital 13 investment (91% in RY1 and 94% in RY2) relate to ongoing, multi-year efforts that continue 14 over time, in areas already familiar to the parties. The rationale and justification for these 15 ongoing projects or programs do not change over time, only the funding1 . Furthermore, 16 many of these ongoing, multi-year Business Cases have been reviewed by parties in prior 17 general rate cases, and the Commission therefore has approved the associated investments as 18 prudently incurred,but at different funding levels. This should facilitate the review of changes 19 in expenditure levels for the Business Cases in this Two-Year Rate Plan. 20 Specific to the incremental projects of$40.8 million (system) in RY1, these projects 21 relate to the Coyote Springs 2 (CS2) CT Rotor Replacement ($19.6 million), the Noxon 22 Rapids Gantry Crane Modernization ($19.5 million), the Noxon Rapids Unit 5 Turbine Benjamin, Di 5 Avista Corporation I Runner Replacement ($0.5 million)', and the Ambient-Adjusted Transmission Line Ratings 2 ($1.2 million). The incremental Business Cases of$30.5 million in RY2 relate to the Kettle 3 Falls (KF) Ash Landfill Expansion ($10.2 million), the CS2 Low Pressure Evaporator 4 Replacement($3.8 million), the Automation Replacement($2.2 million)', the Central 24 HR 5 Operations Facility($3.3 million)9 and the Energy Trade&Risk Management Implementation 6 ($10.9 million)10. Each of these Business Cases are discussed individually within the 7 testimonies of witnesses Mr. Howell, Mr. DiLuciano, and Mr. Manuel. 8 Q. Company witness Mr. Christie identifies and briefly explains the six 9 "Investment Drivers" or classifications of Avista's infrastructure projects and 10 programs. How then do these "drivers" translate to the capital additions that are 11 represented in each capital witness's testimony? 12 A. Mr. Christie provides an overview of our capital investment prioritization 13 process and the six key "Investment Drivers". The Company's six Investment Drivers are 14 briefly described as follows: 15 1. Customer Requested — Respond to customer requests for new service or 16 service enhancements required for connecting new distribution customers or 17 large transmission-direct customers. 18 6 A short description of the Coyote Springs 2 CT Rotor Replacement, the Noxon Rapids Gantry Crane Modernization, and the Noxon Rapids Unit 5 Turbine Runner Replacement projects has been provided in Mr. Howell's direct testimony and the full Business Case justification narrative for each has been provided in Mr. Howell's Exhibit No.7, Schedule 1. 7 A short description of the Ambient-Adjusted Transmission Line Ratings project is provided in Mr.DiLuciano's direct testimony. The full Business Case justification narrative has been provided in Mr. DiLuciano's Exhibit No. 10, Schedule 3. 'A short description of the Kettle Falls Ash Landfill Expansion,the CS2 Low Pressure Evaporator Replacement projects,and the Automation Replacement program has been provided in Mr.Howell's direct testimony and the full Business Case justification narrative for each has been provided in Mr.Howell's Exhibit No. 7,Schedule 1. 9 A short description of the Central 24 HR Operations Facility project is provided in Mr. DiLuciano's direct testimony. The full Business Case justification narrative has been provided in Mr.DiLuciano's Exhibit No. 10, Schedule 3. 10 A short description of the Energy Trade & Risk Management Implementation project is provided in Mr. Manuel's direct testimony. The full Business Case justification narrative has been provided in Mr. Manuel's Exhibit No. 12, Schedule 1. Benjamin, Di 6 Avista Corporation 1 2. Mandatory and Compliance — These investment drivers are compelled by 2 regulation or contract and are generally beyond the Company's control as they 3 are a direct result of compliance with laws, regulations and agreements, 4 including projects related to dam safety upgrades, public safety, air and water 5 quality, and equipment essential to legally operate within the interconnected 6 grid, among others. 7 8 3. Failed Plant and Operations — This investment driver includes the 9 replacement of equipment that is damaged or fails due to an accident,or normal 10 wearing out requiring periodic replacement. The large, massive rotating 11 equipment and associated support machinery used for electric generation, for 12 example, can experience sudden mechanical failures or electrical insulation 13 breakdowns even with the benefit of ongoing maintenance and preventive 14 maintenance programs. 15 16 4. Asset Condition—Replace infrastructure assets or portions of assets at the end 17 of their functional service life based on asset condition due to age, 18 obsolescence and parts availability,and degradation of the asset. This category 19 includes replacement of critical parts requiring replacement prior to failure, as 20 well as replacing or overhauling older equipment to bring it up to meet current 21 codes and standards. 22 23 5. Customer Service Ouality and Reliability — Meet our customers' 24 expectations for quality and reliability of service, as well as increasing the 25 reliability of operating assets. 26 27 6. Performance and Capacity — Programs and projects to address system 28 performance and capacity issues so Company assets can continue to satisfy 29 business needs and meet performance standards to support the interconnected 30 grid and to ensure the ability to participate in the regional wholesale energy 31 market. 32 33 Each of the Company's capital witnesses outlined above provide additional detail as 34 well as the main drivers for capital investments under their area of responsibility. 35 Q. Mr. Christie refers to planned capital expenditures of $500 million in 36 2024, $525 million in 2025 and $575 million in 2026. Why do the totals in Table No. 1 37 differ from the planned expenditures Mr. Christie discusses? 38 A. There are two primary reasons, first the totals in Table No. 1 above differ from 39 Mr. Christie's $500 million, $525 million and $575 million plan because Table No. 1 40 represents transfers-to-plant,whereas Mr. Christie's plan represents capital expenditures(i.e., Benjamin, Di 7 Avista Corporation I spend). There is a timing difference between when dollars are spent, and when the capital 2 projects are completed, become used and useful and are transferred to plant-in-service. 3 Second, Mr. Christie's capital expenditure plan is outlined on a calendar basis while Table 4 No. 1 displays transfers to plant aligned with the pro forma capital adjustment periods, July 5 2024—August 2025,RY 1 September 2025—August 2026 and RY2 September 2026—August 6 2027. 7 8 III. SUMMARY OF CAPITAL ADJUSTMENTS 9 Q. Would you please summarize the adjustments included in the Company's 10 Two-Year Rate Plan as it relates to new additions in utility plant to serve customers? 11 A. Yes. The Company is proposing a Two-Year Rate Plan for the period 12 September 1, 2025, through August 31, 2027. For both electric and natural gas, the Company 13 is proposing an increase for RY1 effective September 1, 2025, and RY2 effective September 14 1,2026.As discussed by Ms. Schultz,the Electric and Natural Gas Pro Forma Studies include 15 restating and pro forma adjustments beyond the historical test year (12ME June 30, 2024). 16 The Company started with utility plant rate base balances from historical accounting 17 information, which for this case consists of the actual AMA balances for the 12ME June 30, 18 2024, and made the following adjustments: 19 Rate Year 1 20 21 (1) Adjustment (1.01) — Deferred FIT Rate Base: This adjustment adjusts the 22 electric and natural gas accumulated deferred federal income tax (ADFIT) rate 23 base balance included in the Results of Operations to the adjusted ADFIT balance 24 reflected on an AMA basis. ADFIT reflects the deferred tax balances arising from 25 timing differences between book recognition and tax recognition of certain income 26 and deductions.The primary deductions that have timing differences,and therefore 27 associated ADFIT, are accelerated tax depreciation over book depreciation and the 28 repairs deduction. 29 Benjamin, Di 8 Avista Corporation 1 (2) Adjustment(1.04)-Restate 06.2024 AMA Rate Base to EOP: This adjustment 2 adjusts plant-in-service, accumulated depreciation(A/D)and ADFIT to restate the 3 June 30, 2024 AMA rate base to June 30, 2024 EOP balances. The impacts of 4 retirements through June 30, 2024, are included in the test year. 5 6 (3) Pro Forma Adjustment(3.08)-August 2025 Pro Forma EOP: This adjustment 7 includes three components. The first component adjusts EOP June 30, 2024 rate 8 base to EOP August 31, 2025 rate base by extending A/D and ADFIT balances on 9 utility plant-in-service from June 30, 2024 EOP balances to August 31, 2025 EOP 10 balances. The second component reflects the impact of retirements from July 1, 11 2024, through August 31, 2025. The third component reflects additions to plant- 12 in-service, inclusive of new growth capital", between July 1, 2024, and August 13 31, 2025, on an EOP basis, inclusive of the A/D, depreciation expense, and 14 ADFIT12 associated with these additions for the period. This adjustment also 15 adjusts depreciation expense to reflect the appropriate level of expense at August 16 31, 2025. 17 18 (4) Pro Forma Adjustment (3.09) - August 2026 Pro Forma AMA: This 19 adjustment includes three components. The first component adjusts plant-in- 20 service at August 31, 2025 EOP balances to August 31, 2026 AMA balances by 21 extending A/D and ADFIT balances. The second component reflects the impact of 22 retirements from August 31, 2025 EOP balances to August 31, 2026 AMA 23 balances. The third component reflects additions to plant-in-service, inclusive of 24 new growth capital, between August 31, 2025 on an EOP basis and August 31, 25 2026 on an AMA basis, inclusive of the A/D, depreciation expense, and ADFIT 26 associated with these additions for the period. This adjustment also adjusts 27 depreciation expense to reflect the appropriate level of expense at August 31,2026. 28 29 Rate Year 2 30 31 (5) Pro Forma Adjustment(26.01)-August 2026 AMA to August 2026 EOP: This 32 adjustment includes two components. The first component adjusts plant-in-service 33 at August 31, 2026 AMA balances to August 31,2026 EOP balances by extending 34 A/D and ADFIT balances. Since this adjustment is only pro forming the change 35 from August 31, 2026, from an AMA to EOP basis, there is no impact to 36 depreciation expense on the capital additions and retirements because the impact 37 was recorded in PF Adj. 3.09 - August 2026 Pro Forma AMA. The second 38 component reflects the impact of retirements from August 31,2026 AMA balances 39 to August 31, 2026 EOP balances. 40 " For the period July 1, 2024, through August 31, 2027, capital additions associated with connecting new customers to the Company's system(New Revenue-Growth Business Case)were included. As discussed by Ms.Schultz in her testimony,an increase in revenues from growth in the number of customers from the historical test year to the RY1 and RY2 rate periods are included, offsetting the impact of growth in plant investment associated with customer growth. 12 For each of the Pro Forma rate base adjustments for the period June 30,2024 EOP through August 31,2027 AMA,the associated ADFIT includes an estimated basis deduction(repairs expense),where applicable. Benjamin, Di 9 Avista Corporation 1 (6) Pro Forma Adjustment(26.02)—August 2026 EOP to August 2027 AMA: This 2 adjustment includes three components. The first component adjusts plant-in- 3 service at August 31, 2026 EOP balances to August 31, 2027 AMA balances by 4 extending A/D and ADFIT balances. The second component reflects the impact of 5 retirements from August 31, 2026 EOP balances to August 31, 2027 AMA 6 balances. The third component reflects additions to plant-in-service, inclusive of 7 new growth capital, between August 31, 2026, on an EOP basis and August 31, 8 2027, on an AMA basis, inclusive of the A/D, depreciation expense, and ADFIT 9 associated with these additions for the period. This adjustment also adjusts 10 depreciation expense to reflect the appropriate level of expense at August 31,2027. 11 12 An overall summary of the change in rate base associated with the adjustments 13 outlined above is included as Table No. 2 (electric) and Table No. 3 (natural gas) below. 14 Detailed calculations for each adjustment that I sponsor have been provided in my workpapers 15 filed with the Company's case. Please note, however, that Ms. Andrews discusses and 16 sponsors the pro forma capital additions adjustment (3.15) related to Colstrip Units 3 and 4. 17 These capital additions are included in Ms. Schultz's Electric and Natural Gas Pro Forma 18 Studies but are not included in my summary tables below. 19 Q. What is the change in electric and natural gas net plant for the capital 20 adjustments included in this testimony? 21 A. The results of the Electric and Natural Gas Pro Forma Studies reflect the net 22 plant that will be in service serving customers during RY1 and RY2. Prior to reflecting the 23 additional projects sponsored by Ms. Andrews (Colstrip Units 3 and 4), for RY1, Electric net 24 plant,after ADFIT,increases$116,419,000 from the June 30,2024 AMA results of operations 25 balance of$1,020,673,000 to the August 31,2026 AMA balance of$1,137,091,000. For RY2, 26 Electric net plant, after ADFIT, increases $73,572,000 from the August 31, 2026 AMA 27 balance of$1,137,091,000 to the August 31, 2027 AMA balance of$1,210,663,000. Table 28 No. 2 below summarizes the adjustments for electric capital additions included in this 29 testimony and sponsored by me. 30 Benjamin, Di 10 Avista Corporation I Table No. 2: Idaho Electric Adiustments Summary by Year 2 Idaho Electric Adjustments in$(000's) Plant in Accumulated Accumulated 3 Adj# Service Depreciation DFIT Net Plant Rate Year 1 (September 1,2025-August 31,2026) 4 June 2024 AMA Results $ 1,987,790 $ (771,087) $ (196,030) $ 1,020,673 Deferred FIT Rate Base 1.01 3,022 3,022 Restate 12 ME 06.2024 AMA to EOP Adj 1.04 479474 (20,171) 427 27,730 5 July 1,2024 to August 31,2025 Pro Forma EOP Adj 3.08 1039214 (49,757) (19946) 51,511 August 31,2025 FOP to August 31 2026 AMA Ad' 3.09 47,840 11,386 2,298 34,156 6 Rate Year 1 Total $ 2,186,318 $ 852,401 $ 196,825 $ 1,137,091 7 Rate Year 2(September 1,2026-August 31,2027) August 31,2026 AMA Balance 2,186,318 (852,401) (196,825) 1,137,091 8 August 31,2026 AMA to August 31,2026 EOP Adj 26.01 50,832 (21,924) (2,786) 26,122 August 31,2026 EOP to August 31,2027 AMA Ad' 26.02 57,978 8,223 2,305 47,450 9 Rate Year 2 Total $ 2,295,128 $ 882,549 $ (2QL9161 $ 1,210,663 *Electric Pro Forma Rate Year 1 totalbalances exclude the effect ofadditional Pro Forma Adjustments sponsored by Ms.Andrews for Colstrip Units 3 and 4 investments. 10 11 For RY1, Natural Gas net plant, after ADFIT, increases $16,329,000 from the June 12 30, 2024 AMA balance of $215,298,000 to the August 31, 2026 AMA balance of 13 $231,627,000. For RY2, Natural Gas net plant, after ADFIT, increases $6,589,000 from the 14 August 31, 2026 AMA balance of $231,627,000 to the August 31, 2027 AMA balance of 15 $238,216,000.Table No. 3 below summarizes the adjustments for natural gas capital additions 16 included in this testimony and sponsored by me. Benjamin, Di 11 Avista Corporation I Table No. 3: Idaho Natural Gas Adiustments Summary by Year Idaho Natural Gas Adjustments in$(000's) 2 Plant in Accumulated Accumulated Adj# Service Depreciation DFIT Net Plant 3 Rate Year 1 (September 1,2025-August 31,2026) June 2024 AMA Results $ 387,073 $ (138,287) $ (33,488) $ 215,298 4 Deferred FIT Rate Base 1.01 589 589 Restate 12 ME 06.2024 AMA to EOP Adj 1.04 8,612 (3,775) 136 4,974 5 July 1,2024 to August 31,2025 Pro Forma EOP Adj 3.08 14,707 (8,753) 635 6,589 August 31,2025 EOP to August 31,2026 AMA Ad' 3.09 4,869 812 121 4,178 6 Rate Year 1 Total $ 415,261 $ 151,627 $ 32,007 $ 231,627 7 Rate Year 2(September 1,2026-August 31,2027) August 31,2026 AMA Balance 415,261 (151,627) (32,007) 231,627 August 31,2026 AMA to August 31,2026 EOP Adj 26.01 4,833 (4,263) 60 630 8 August 31 2026 EOP to August 31,2027 AMA Ad' 26.02 6,230 357 85 5,958 Rate Year 2 Total $ 426,324 $ 156,246 $ 31,862 $ 238,216 9 10 Q. Please describe how the capital additions included in the pro forma 11 adjustments described above are derived. 12 A. The Company directly assigns costs when appropriate. Costs not specifically 13 identifiable to a specific jurisdiction are allocated in accordance with an approved allocation 14 procedure. Costs that are not directly assigned to electric or natural gas projects specific to 15 our Idaho jurisdiction,are allocated to Idaho as part of an allocation process,which designates 16 costs as common to all services and jurisdictions (CD.AA), common to electric operations 17 only (ED.AN) or common to natural gas operations only (GD.AA). 18 Q. Please explain what offsets have been included within the pro forma 19 capital additions adjustments. 20 A. First, for each of the pro forma capital adjustments described in my testimony, 21 I have included the reduction in depreciation expense related to plant retirements. The overall 22 effect of reflecting retirements from June 30, 2024 plant-in-service to August 31, 2027 AMA 23 reduces the incremental depreciation expense pro formed in these adjustments by $11.8 24 million(or a reduction of 69%)for electric and$2.6 million(or a reduction of 85%)for natural Benjamin, Di 12 Avista Corporation I gas. 2 In addition, each pro forma capital project included in the pro forma capital 3 adjustments was also analyzed to determine if any additional offsets (e.g., reduced O&M 4 costs)were probable. For example,maintenance records were reviewed to determine whether 5 any specific maintenance costs were incurred in the test period that would be reduced or 6 eliminated by the investment at the facility. When reviewing project offsets,typically projects 7 may have two types of offsets. The first type of offset is a redeployment of costs or efficiency 8 gains, that do not generally allow for an offset to its O&M costs, as there are no changes to 9 the total level of expense that the Company will incur during the rate year. The second type 10 of offset includes actual or "hard" incremental savings expected beyond the historical test 11 period, that will occur during the rate-effective period, as a result of the capital investment. 12 These offsets result in an overall reduction in the level of expense the Company will incur, 13 such as a reduction in workforce or energy savings. 14 After review of the capital projects included in this case during RY1, September 1, 15 2025, through August 31, 2026, quantifiable savings included as a reduction to O&M in 16 Adjustment 3.10 — Pro Forma Revenue and O&M Offsets are approximately $469,000 for 17 electric operations and $117,000 for natural gas operations. For RY2, September 1, 2026, 18 through August 31, 2027, incremental quantifiable savings above RY1 levels, included as a 19 reduction to O&M in Adjustment 26.05 — Pro Forma Revenue and O&M Offsets are 20 approximately $93,000 for electric operations and $15,000 for natural gas. Refer to 21 Adjustments 3.12 and 26.05 — Pro Forma Revenue and O&M Offsets workpapers for more 22 information on the specific Business Cases included in this adjustment. 23 In addition, the increase in electric and natural gas revenue, due to the growth in the 24 number of customers from the historical test year to RY1 and RY2 (new growth revenue Benjamin, Di 13 Avista Corporation I capital additions associated with connecting new customers to the Company's system, i.e., 2 New Revenue — Growth Business Case) are also included. These revenues, totaling $3.3 3 million in RY 1 and$1.7 million in RY2 for electric, and$1.4 million in RY 1 and$0.7 million 4 in RY2 for natural gas, are included as "Other Revenue" within Adjustments 3.10 and 26.05 5 —Pro Forma Revenue and O&M Offsets,respectively,reducing the overall requested revenue 6 requirement over the Company's Two-Year Rate Plan, as discussed by Ms. Schultz. 7 Q. What conclusions have you drawn regarding the increased capital 8 additions included in this case? 9 A. The Company is making substantial levels of capital additions in its electric 10 and natural gas system infrastructure to address customer growth, replacement and 11 maintenance of Avista's aging system, and to sustain reliability and safety. As soon as this 12 new plant is placed in service, the Company must start depreciating the new plant and incur 13 other costs related to the addition. Unless these capital additions are reflected in retail rates 14 in a timely manner,it has a negative impact on Avista's earnings,particularly because the new 15 plant is typically far more costly to install than the cost of similar plant that was embedded in 16 rates decades earlier. As plant is completed and is providing service to customers, it is 17 appropriate for the Company to receive timely recovery of the costs associated with that plant. 18 Q. Does this conclude your pre-filed direct testimony? 19 A. Yes, it does. Benjamin, Di 14 Avista Corporation DAVID J. MEYER VICE PRESIDENT AND CHIEF COUNSEL FOR REGULATORY & GOVERNMENTAL AFFAIRS AVISTA CORPORATION P.O. BOX 3727 1411 EAST MISSION AVENUE SPOKANE, WASHINGTON 99220-3727 TELEPHONE: (509)495-4316 DAVID.MEYER@AVISTACORP.COM BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) CASE NO. AVU-E-25-01 OF AVISTA CORPORATION FOR THE ) CASE NO. AVU-G-25-01 AUTHORITY TO INCREASE ITS RATES ) AND CHARGES FOR ELECTRIC AND ) NATURAL GAS SERVICE TO ELECTRIC ) EXHIBIT NO. 13 AND NATURAL GAS CUSTOMERS IN THE ) STATE OF IDAHO ) TIA C. BENJAMIN 1 FOR AVISTA CORPORATION (ELECTRIC AND NATURAL GAS) Avista Capital Additions Detail July 1,2024-August 31,2027 Transfers-to-Plant (System)In$(000's) July 2024- Rate Year 1 Rate Year 2 Business Case Name Investment Driver August 2025 Sept 2025-Aug 2026 Sept 2026-Aug 2027 Witness:Josh DiLuciano-Exhibit 10,Schedule 3 Electric Distribution Capital Projects Distribution Grid Modernization Asset Condition $ 451 $ 799 $ 1,411 Distribution Minor Rebuild Asset Condition 14,562 13,833 14,657 Distribution System Enhancements Performance&Capacity 11,399 10,063 10,719 East CDA Lake Reinforcement Program Performance&Capacity 243 694 - Elec Relocation and Replacement Program Mandatory&Compliance 9,968 6,960 7,020 Electric Storm Failed Plant&Operations 2,836 2,529 2,529 Joint Use Mandatory&Compliance 4,530 4,167 3,667 Meter Minor Blanket Failed Plant&Operations 274 250 250 Metro 115kV Substation Asset Condition 3,990 - 9,315 New Revenue-Growth Customer Requested 78,190 62,629 66,746 Substation-Asset Condition Asset Condition 26,781 19,003 6,895 Substation-Performance and Capacity Performance&Capacity 15,594 11,517 14,660 Substation Failed Plant Failed Plant&Operations 1,000 1,500 1,500 Wood Pole Management Asset Condition 8,797 11,573 12,577 Total Planned Electric Distribution Capital Projects $ 178,616 $ 145,517 $ 151,946 Electric Transmission Capital Projects Ambient-Adjusted Transmission Line Ratings Mandatory&Compliance $ - $ 1,200 $ - Colstrip Transmission Mandatory&Compliance 1,251 1,094 588 Electric Storm Failed Plant&Operations 1,931 1,471 1,471 SCADA-SOO and BuCC Asset Condition 960 1,011 1,148 Substation-West Plains System Reinforcement Project Mandatory&Compliance 1,667 3,592 37,992 Transmission-Minor Rebuild Asset Condition 5,494 4,000 4,000 Transmission Construction-Compliance Mandatory&Compliance 382 500 500 Transmission Critical Crossing Reinforcement Asset Condition 500 - - Transmission Major Rebuild-Asset Condition Asset Condition 7,817 4,303 3,789 Transmission NERC Low-Risk Priority Lines Mitigation Mandatory&Compliance 3,051 - - Westside 230/115kV Station Brownfield Rebuild Project Mandatory&Compliance 2,978 - - Total Planned Electric Transmission Capital Projects $ 26,030 $ 17,171 $ 49,489 Natural Gas Distribution Capital Projects Gas Above Grade Pipe Remediation Program Mandatory&Compliance $ 738 $ 657 $ 643 Gas Cathodic Protection Program Mandatory&Compliance 757 1,002 600 Exhibit No. 13 Case Nos.AVU-E-25-01/AVU-G-25-01 T.Benjamin,Avista Schedule 1,Page 1 of July 2024- Rate Year 1 Rate Year 2 Business Case Name Investment Driver August 2025 Sept 2025-Aug 2026 Sept 2026-Aug 2027 Gas Facility Replacement Program(GFRP)Aldyl A Pipe Replacement Mandatory&Compliance 30,530 28,265 29,682 Gas Isolated Steel Replacement Program Mandatory&Compliance 2,440 2,000 2,000 Gas Non-Revenue Program Failed Plant&Operations 11,419 10,850 11,437 Gas PMC Program Mandatory&Compliance 4,205 3,810 3,670 Gas Regulator Station Replacement Program Asset Condition 1,094 1,051 1,050 Gas Reinforcement Program Performance&Capacity 5,020 1,115 1,025 Gas Replacement Street and Highway Program Mandatory&Compliance 5,427 5,665 5,757 Gas Telemetry Program Performance&Capacity 98 - - Gas Transient Voltage Mitigation Program Mandatory&Compliance 1,165 154 313 Jackson Prairie Natural Gas Storage Facility Performance&Capacity 2,256 2,386 2,376 New Revenue-Growth Customer Requested 30,723 25,016 25,333 Total Planned Natural Gas Distribution Capital Projects $ 95,873 $ 81,971 $ 83,886 General Plant&Fleet Investments Capital Projects Capital Equipment Program Asset Condition $ 2,486 $ 2,084 $ 2,090 Central 24 HR Operations Facility Performance&Capacity - - 3,339 Fleet Services Capital Plan Asset Condition 9,259 5,257 5,695 Palouse Service Center Asset Condition 750 750 - Right-of-Way Use Permits Mandatory&Compliance 337 243 243 Sandpoint Service Center Performance&Capacity 1,250 - - Structures and Improvements/Furniture Asset Condition 7,197 5,494 5,670 Telematics 2025 Asset Condition 495 - - Total Planned General Plant&Fleet Investment Capital Projects $ 21,774 $ 13,827 $ 17,037 Misc.accrual reversals,corrections or additional TTP $ 183 $ 50 $ 50 Total Distribution,Transmission,Natural Gas and General Plant Capital Projects $ 322,476 $ 258,536 $ 302,408 Witness:Wayne Manuel-Exhibit 12,Schedule 1 Enterprise Technology Capital Projects Customer Experience Platform Program Customer Service Quality&Reliability $ 2,699 $ 740 $ - Customer Facing Technology Program Customer Service Quality&Reliability $ 4,825 $ 5,455 $ 5,419 Customer Transactional Systems Customer Service Quality&Reliability 4,535 4,750 5,450 Energy Delivery Modernization&Operational Efficiency Performance&Capacity 7,105 6,147 10,648 Energy Market Modernization&Operational Efficiency Performance&Capacity 260 - - Energy Resources Modernization&Operational Efficiency Performance&Capacity 4,533 2,881 2,842 Energy Trade&Risk Management Implementation Performance&Capacity - - 10,900 Financial&Accounting Technology Performance&Capacity 3,383 2,344 4,555 Human Resources Technology Performance&Capacity 250 486 340 Exhibit No. 13 Case Nos.AVU-E-25-01/AVU-G-25-01 T. Benjamin,Avista Schedule 1,Page 2 of 4 July 2024- Rate Year 1 Rate Year 2 Business Case Name Investment Driver August 2025 Sept 2025-Aug 2026 Sept 2026-Aug 2027 Legal&Compliance Technology Performance&Capacity 656 117 450 Outage Management System&Advanced Distribution Manages Asset Condition 18,656 6,731 6,511 Basic Workplace Technology Delivery Performance&Capacity 1,944 810 795 Control and Safety Network Infrastructure Performance&Capacity 2,443 457 2,108 Data Center Compute and Storage Systems Performance&Capacity 3,098 1,367 4,415 Digital Grid Network Performance&Capacity 4,130 2,692 2,674 Dynamic Infrastructure Platform Enhancements Performance&Capacity 881 262 1,002 Endpoint Compute and Productivity Systems Performance&Capacity 4,197 5,436 6,646 Enterprise Communication Systems Performance&Capacity 1,672 2,109 1,822 Enterprise Network Infrastructure Performance&Capacity 5,376 2,725 1,905 Environmental Control&Monitoring Systems Performance&Capacity 1,563 872 782 ET Modernization&Operational Efficiency-Technology Performance&Capacity 7,008 1,338 3,123 Fiber Network Lease Service Replacement Performance&Capacity 1,157 2,339 1,314 Land Mobile Radio&Real Time Communication Systems Performance&Capacity 3,674 2,180 1,052 Network Backbone Performance&Capacity 5,322 1,585 2,901 NexGen Control System Networks Performance&Capacity 6,649 7,305 1,760 Technology Failed Assets Failed Plant&Operations 1,041 1,019 1,023 Disaster Resiliency Customer Service Quality&Reliability 142 9 198 Enterprise Security Customer Service Quality&Reliability 3,660 1,986 980 Facilities and Storage Location Security Customer Service Quality&Reliability 2,003 362 179 Generation,Substation&Gas Location Security Customer Service Quality&Reliability 6,305 1,334 1,045 Identity and Access Governance Mandatory&Compliance 558 451 201 Security Compliance Mandatory&Compliance 47 53 100 Misc.accrual reversals,corrections or additional TTP 2 - - Total Planned Enterprise Technology Capital Projects $ 109,776 $ 66,340 $ 83,140 Witness:David Howell-Exhibit 7,Schedule 1 Generation Production and Environmental Capital Projects Cabinet Gorge Dam Fishway Mandatory&Compliance $ 537 $ - $ - Clark Fork Settlement Agreement Mandatory&Compliance 2,938 2,664 3,122 Hydro Safety Minor Blanket Mandatory&Compliance 230 - - Spokane River License Implementation Mandatory&Compliance 896 1,040 973 Asset Lifecycle Management Asset Condition 2,538 3,628 5,440 Automation Replacement Customer Service Quality&Reliability - - 2,250 Boulder Park Engine Controls Upgrade Asset Condition 2,500 2,790 - Cabinet Gorge HVAC Replacement Asset Condition 2,981 - - Cabinet Gorge Station Service Asset Condition 18,190 171 - Cabinet Gorge Stop Log Replacement Asset Condition 1,980 - - Exhibit No. 13 Case Nos.AVU-E-25-01/AVU-G-25-01 T. Benjamin,Avista Schedule 1,Page 3 of 4 July 2024- Rate Year 1 Rate Year 2 Business Case Name Investment Driver August 2025 Sept 2025-Aug 2026 Sept 2026-Aug 2027 Coyote Springs 2 CT Rotor Replacement Failed Plant&Operations - 19,583 - CS2 Low Pressure Evaporator Replacement Asset Condition - - 3,799 HMI Control Software Asset Condition 3,276 3,650 5,554 KF 4160 V Station Service Replacement Asset Condition 722 1,541 - KF Secondary Superheater Replacement Asset Condition 3,401 - - KF Ash Landfill Expansion Mandatory&Compliance - - 10,189 KF_ID Fan&Motor Replacement Asset Condition 3,360 - - Little Falls Plant Upgrade Asset Condition 566 - - Long Lake Plant Upgrade Asset Condition 300 - - Nine Mile Unit 3 Mechanical Overhaul Asset Condition 6,903 - - Nine Mile Units 3&4 Control Upgrade Asset Condition 2,200 - 5,122 Noxon Rapids Gantry Crane Modernization Asset Condition - 19,494 - Noxon Rapids Unit 5 Turbine Runner Replacement Asset Condition - 499 - Operational Safety and Compliance Mandatory&Compliance 3,837 2,907 1,267 Operational Sustainment Performance&Capacity 6,126 8,066 16,283 Peaking Generation Business Case Failed Plant&Operations 372 - - Post Street Substation Crane Rehab Asset Condition 1,080 702 - Regulating Hydro Asset Condition 1,235 - - Total Planned Generation Production and Environmental Capital Projects $ 66,166 $ 66,733 $ 54,000 Witness:Vern Malensky Wildfire Resiliency Plan Capital Projects Wildfire Resiliency Plan Customer Service Quality&Reliability $ 40,834 $ 51,500 $ 60,250 Total Planned Wildfire Resiliency Capital Projects $ 40,834 $ 51,500 $ 60,250 Total Pro Forma Capital Additions(System)' $539,253 $443,109 $499,798 Excludes Colstrip capital and projects assigned directly to Washington or Oregon only. Exhibit No. 13 Case Nos.AVU-E-25-01/AVU-G-25-01 T. Benjamin,Avista Schedule 1,Page 4 of 4