20250131Direct H. Rosentrater_Exhibits.pdf

RECEIVED
Friday, January 31, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
AVID J. MEYER
ICE PRESIDENT AND CHIEF COUNSEL FOR
REGULATORY& GOVERNMENTAL AFFAIRS
VISTA CORPORATION
P.O. BOX 3727
1411 EAST MISSION AVENUE
SPOKANE, WASHINGTON 99220-3727
TELEPHONE: [phone]
[e-mail]
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 ) DIRECT TESTIMONY
AND NATURAL GAS CUSTOMERS IN THE ) OF
STATE OF IDAHO ) HEATHER L. ROSENTRATER
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 Heather L. Rosentrater, and I am employed as the President and
4 Chief Executive Officer of Avista Corporation (Avista or Company). In that role I also serve
5 as a member of Avista's Board of Directors. My business address is 1411 E. Mission Avenue,
6 Spokane, Washington.
7 Q. Would you briefly describe your educational background and professional
8 experience?
9 A. I earned a Bachelor of Science degree in Electrical Engineering from Gonzaga
10 University and hold a Professional Engineer (PE) credential. I joined Avista in 1996 as an
11 electrical engineering student at the Company's former subsidiary, Avista Labs, where I
12 developed electrical systems for fuel cells. I joined Avista Utilities in 2003 and have broad
13 experience on both the electric and natural gas side of the business, having managed
14 departments and projects in electric transmission, distribution, SCADA, supply chain, as well
15 as business process improvement using LEAN and Six Sigma techniques. I was named Vice
16 President of Energy Delivery in December 2015 and was promoted to Senior Vice President
17 of Energy Delivery and Shared Services in October 2019. In August 2022,my responsibilities
18 expanded to Senior Vice President and Chief Operating Officer,and in October 2023 I became
19 President and COO. I became President and Chief Executive Officer on January 1, 2025.
20 I presently serve on the board of directors for the Western Energy Institute and Second
21 Harvest Food Bank in Spokane, Washington. In addition, I am a member of the Gonzaga
22 University School of Engineering and Applied Science Executive Advisory Council.
23 Q. What is the scope of your testimony in this proceeding?
Rosentrater, Di 1
Avista Corporation

I A. In my testimony I provide an overview of the Company's proposal in this filing
2 for a Two-Year Rate Plan. I will start by discussing the overall economic conditions facing
3 Avista, and how those have affected our operations, our cost management, and this general
4 rate case. I will then summarize the Company's proposal in this filing, and address our
5 continuing capital investment,which continues to be the primary driver behind the Company's
6 most recent general rate cases. I will also discuss our continued focus on communicating with
7 customers, our overall customer satisfaction, and our customer support programs. Finally, I
8 introduce the other Company witnesses who support this general rate case filing.
9 A table of contents for my testimony is as follows:
10 Description Page
11 I. Introduction 1
12 II. Overview of Avista 2
13 III. General Comments Regarding Overall Economy 3
14 IV. Summary of General Rate Case &Drivers 12
15 V. Customer Communications, Satisfaction& Support 19
16 VI. Summary of Witnesses 22
17
18 Q. Are you sponsoring exhibits in this proceeding?
19 A. Yes. I am sponsoring Exhibit No. 1, Schedule 1 which provides maps showing
20 Avista's electric and natural gas service areas, including natural gas fields, trading hubs and
21 major pipelines.
22
23 II. OVERVIEW OF AVISTA
24 Q. Please briefly describe Avista Utilities.
25 A. Avista Utilities serves approximately 415,000 retail electric and 379,000 retail
26 natural gas customers in a 30,000 square mile service territory covering portions of Idaho,
27 Washington, and Oregon, as shown in Exhibit No. 1, Schedule 1.As of June 30, 2024(the test
Rosentrater, Di 2
Avista Corporation

I year), Avista had net rate base (electric and natural gas) of approximately $4.6 billion (on a
2 system basis), with electric retail revenues of $988 million (system) and natural gas retail
3 revenues of $498 million (system). Avista Utilities has approximately 1,800 regular and
4 seasonal employees (not including contractors).
5 Q. Please describe Avista's current business focus for its utility operations.
6 A. Our strategy continues to focus on our energy and utility-related businesses,
7 with our primary emphasis on the natural gas and electric utility business. I am proud that in
8 2025 we refreshed our North Star (our aspiration that guides our decisions) and strategies to
9 set the stage for the next decade of providing service to our customers. We are proud to be a
10 community-based,essential energy Company striving to compassionately serve our customers
11 with innovative and sustainable solutions, while delivering competitive returns which allow
12 us to continue to invest in safe and reliable infrastructure. We are focused on (1) ensuring
13 robust energy delivery and supply; (2) partnering in the shared clean energy economy; (3)
14 inspiring engaged and thriving employees; and(4)having a commitment to financial strength.
15
16 III. GENERAL COMMENTS REGARDING OVERALL ECONOMY
17 Q. Absent rate relief, will the Company continue to experience a steady
18 erosion in earnings since its last rate filing?
19 A. Yes, it will. The following illustrations for Idaho electric and natural gas
20 operations, excerpted from Company witness Ms. Schultz's testimony, depict the erosion in
21 earnings, resulting in returns well below the previously authorized levels:
Rosentrater, Di 3
Avista Corporation

I Illustration No. 1: Two-Year Rate Plan—Electric Rates of Return
2 Avista Corp
Idaho Electric Rates of Return*
3 9.00%
8.00%
4 7.00% -----5J9%----------------------------------- ---
6.00%
5 5.00% 4.87%
4.00% 3.94%
6
3.00%
,7 2.00%
1.00%
8 0.00%
Actual RY1 RY2 Requested
(12ME Aug 2026) (12ME Aug 2027)
9 *Current Authorized is 7.19%(---------)
10 Illustration No. 2: Two-Year Rate Plan—Natural Gas Rates of Return
11 Avista Corp
Idaho Natural Gas Rates of Return*
12 9.00%
8.00% 7.68%
--------------
13 --------------------- --------
7.00% --
a
6.00%
14 5.00% 4.76%
4.00%
15 3.00%
2.00%
16 1.00%
0.00% —
17 Actual RY1 RY2 Requested
(12ME Aug 2026) (12ME Aug 2027)
18 *Current Authorized is 7.19%(---------)
19 Ms. Schultz provides more details on actual results of operations and revenue requirement
20 adjustments. But what is clearly visible in the charts above is that Avista is experiencing
21 significant regulatory lag in the State of Idaho, and as I will discuss later, we believe it is
22 important that the Commission, in this case, help reduce that lag through its support of the
23 Company's Pro Forma capital adjustments.
Rosentrater, Di 4
Avista Corporation

I Q. Please provide an overview of Avista's financial situation.
2 A. As Company witness Mr. Christie discusses, the cost pressures from inflation
3 and high interest rates, along with other increased operating expenses, have affected Avista.
4 These pressures have amplified the lag experienced by the Company in terms of cost recovery,
5 negatively impacting the expected return by investors. It has also put additional strain on our
6 credit metrics. Said differently, cost headwinds have caused Avista's financial performance
7 to suffer. That under-performance has caused investor and sell-side analyst sentiment to erode,
8 and in turn, our stock performance has suffered. The rating agency Standard and Poor's(S&P)
9 has placed Avista's credit rating on "negative outlook" due to Avista's weaker financial
10 performance caused by inflation, higher interest rates, and regulatory lag. The Company's
11 weakening financial performance, deterioration in credit metrics, and poor stock performance
12 highlights the challenging environment in which we are operating and the importance of a
13 supportive regulatory environment.
14 Q. Are these conditions unique to Avista?
15 A. In my view,the confluence of pressures are especially acute for Avista. Avista
16 is among the smallest investor-owned utilities. We simply are not large enough to absorb,
17 without rate relief, the operational risks of energy market fluctuations, wildfire risk, and the
18 impact of substantial increases in fixed costs. We are being subjected to similar cost pressures
19 that other utilities are facing but given the lack of growth in our service territories,we need to
20 make filings such as this one. The traditional headwind that Avista faces in terms of earning
21 our authorized rate of return is regulatory lag associated with capital investment timing. We
22 are faced with significant new regulatory and governmental mandates - significant both in
23 terms of numbers and scope. The work associated with these new mandates is layered on top
Rosentrater, Di 5
Avista Corporation

I of our "traditional" work — maintaining and/or upgrading infrastructure, recruiting and
2 retaining strong, qualified employees, and serving our customers in the manner they deserve.
3 As such, in this case the Company is seeking to reflect in rates the level of investment
4 that will be in service in the rate-effective periods. The inability to have timely recovery of
5 capital investment is the major component of regulatory lag and under-performance. As Mr.
6 Christie discusses, Avista is on negative watch from credit rating agencies. This negative
7 sentiment comes at a time when we are financing substantial capital additions on behalf of our
8 customers. As Company witness Dr. Thompson (our cost of capital expert witness) notes,
9 considering capital market expectations, the exposures faced by Avista, and the economic
10 requirements necessary to maintain financial integrity and support additional capital
11 investment even under adverse circumstances, a 10.77 percent return on equity is appropriate.
12 The 10.4 percent ROE requested by the Company represents a conservative estimate of
13 investors' current requirements.1
14 Q. As discussed by Company witnesses Ms. Andrews and Ms. Benjamin, the
15 Company is seeking capital additions on an"average of monthly averages"(AMA)basis
16 in the rate effective period. Does that conflict with the Commission's recent findings in
17 a recent Idaho Power adjudication?
18 A. No. As Ms. Andrews discusses, our requested capital treatment in this case,
19 and the Commission's finding in Idaho Power's 2024 adjudication are not in conflict. As the
20 Commission notes in its Order3, Idaho Power filed a "limited" rate case, seeking to update
21 only a few components of revenue requirement,while leaving all other items "out of scope'.4
'Exhibit 300,p. 14 at 11.20-27
2 Case No.IDC-E-24-07,Order 36438.
3 Ibid.
a Id.p.3.
Rosentrater, Di 6
Avista Corporation

I So, from the start, the two cases are not similar, as Avista has filed - in this rate case -
2 adjustments to all components of revenue requirement — revenues, expenses, and rate base.
3 By doing so, all revenue requirement components are aligned, contrary to the findings of the
4 Commission in Idaho Power's case where it stated:
5 ... and the limited nature of this case presents additional problems as various
6 aspects of a full rate case, non-labor O&M, power cost expense, etc., are
7 considered out-of-scope, further misaligning costs and benefits.s
8
9 In the end, our filing is not subject to the same shortcomings identified by the Commission in
10 Idaho Power's filing.
11 Q. The Commission, in the referenced Idaho Power case, discussed allowing
12 parties "sufficient time" to review capital additions included in rate cases. What is the
13 Company's position on that discussion point?
14 A. We absolutely agree that the Commission, Staff and the parties should have
15 the ability to do a thorough audit and sampling of the capital additions the Company is seeking
16 cost recovery of in this case or any case. That was true in prior Avista rate cases and remains
17 so here. What is also important to note, and we believe should give the Commission some
18 reassurance, is that the vast majority of the capital additions included in this case are
19 programmatic capital additions. These are longstanding programs of regular utility"baskets"
20 of ongoing utility spending that are not new to the parties, only the level of spend changes
21 over time. These are programs such as the investments to connect new customers,replacement
22 of aging poles, transformers, substations, generation assets, road moves, metering
23 infrastructure, and many other customary utility investments.
24 As Ms. Benjamin details in her testimony, Illustration No. 3 below shows overall total
5 Id.p. 6
Rosentrater, Di 7
Avista Corporation

I system capital additions (transfers to plant) for the Pro Forma, RY1 and RY2 periods, of
2 $539.3 million,$443.1 million and$499.8 million,respectively. This illustration distinguishes
3 between what are ongoing projects or programs from the Pro Forma period ending August
4 2025,versus incremental projects that are estimated to transfer-to-plant from September 2025
5 through August 2027, representing $40.8 million in RY1 and $30.5 million in RY2.
6 Illustration No. 3 —Production Plant Investment (System Transfers to Plant)
7
Avista Total Annual Capital Additions
8 $'s in millions(System Transfers to Plant)
$600
9 $30.5(z)
$500 $40.8 11i
10 $400
11 $300
12 $200
13 $100
14 $-
Pro Forma RY1 RY2
15 July 2024-Aug 2025 Sept 2025-Aug 2026 Sept 2026-Aug 2027
$539.3 $443.1 $499.8
16 ■Continuation of Ongoing Business Cases ■Additional Business Cases Initiated in RY1-RY2
(1)The majority of incremental investment in RY1 is associated with Coyote Springs 2(CS2)CT Rotor Replacement and Noxon
17 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
18 Replacement,Central 24 HR Operations Facility,and Energy Trade&Risk Management Implementation,totaling$28.2 million.
19 As can be seen from this illustration,by far the vast majority of the capital investment
20 (91% in RY 1 and 94% in RY2) relate to ongoing, multi-year efforts that continue over time,
21 in areas familiar to the parties. The rationale and justification for these ongoing projects or
22 programs, therefore, does not change over time, only the fundinglevels.evels. Furthermore, many
23 of these ongoing,multi-year Business Cases have previously been reviewed by parties in prior
Rosentrater, Di 8
Avista Corporation

I general rate cases, and the Commission therefore has approved the associated investments as
2 prudently incurred,but at different funding levels. This should facilitate the review of changes
3 in expenditure levels within each Business Case for the Two-Year Rate Plan.
4 Q. The Commission also stated in the Idaho Power order that it is "open to
5 considering requests for additional riders, or other cost recovery mechanisms as may be
6 appropriate".'Is Avista requesting additional mechanisms or riders in this case?
7 A. No, the Company is not forecasting a need for additional riders or mechanisms,
8 because we do not believe that special treatment, such as a new rider or mechanism, is
9 necessary at this time beyond what is already in place. Our primary issue in general rate cases
10 is timely recovery of capital additions and reducing regulatory lag. All of the information
11 necessary to support the Company's timely recovery of capital is presented in this case -
12 detailed in the Company's pro forma capital adjustment and supporting documentation. As
13 discussed earlier, these capital additions, by and large, are additions to continuing programs,
14 programs which the Commission and the parties are already familiar with.
15 Q. If the Company were to propose a mechanism in this case, what would
16 that look like?
17 A. As Ms. Andrews notes in her testimony, such a mechanism would be a capital
18 tracking mechanism, whereby we would request that the Commission authorize in rates the
19 AMA balances for the rate effective periods, and then have a "subject to review and refund"
20 proceeding after the fact to validate the overall level of transfers as compared to those included
21 in rates. This is a "mechanism" that has been authorized in Washington since 2021, and we
22 have now had two rate cases in that jurisdiction where the mechanism has been successfully
6 Case No.IDC-E-24-07,Order 36438,p. 6.
Rosentrater, Di 9
Avista Corporation

I utilized. It has greatly reduced the regulatory lag associated with capital additions, but it has
2 not removed all regulatory lag overall across our system. But again, we believe the
3 information for the Commission to review is presented in this case, and another mechanism
4 (and additional regulatory processes) are not necessary.
5 Q. What else is the Company doing in an effort to solidify its financial
6 situation outside of filing this general rate case?
7 A. First, the Company is seeking timely cost recovery from its other jurisdictions.
8 In Washington, our largest jurisdiction, the Company filed a Two-Year Rate Plan in January
9 2024, and new rates became effective on January 1, 2025. For Oregon, the Company in
10 November filed a general rate case, with new rates going into effect on September 1, 2025.
11 With that filing, Avista has done what it can to bring all cost recovery current in all
12 jurisdictions it covers. Second,the Company is focused on cost management and its effect on
13 our customers' bills. We continue to aggressively manage costs to achieve the appropriate
14 balance of providing safe and reliable service at cost-effective rates, along with a high level
15 of customer satisfaction,while attempting to improve the financial condition of the Company.
16 We are focused on long-term, sustainable savings to continuously improve our service to
17 customers and manage costs into the future.
18 Q. How does Avista encourage employees to focus on its customers?
19 A. All of us at Avista are committed to providing safe, reliable, and affordable
20 natural gas and electric service. One way to keep our employees focused on these goals is to
21 have a portion of their compensation be at-risk, payable only with the achievement of certain
22 customer-centered metrics. This "pay-at-risk" component, in the form of our Short-Term
23 Incentive Plan, keeps our employees focused on:
Rosentrater, Di 10
Avista Corporation

I • O&M Cost-Per-Customer(O&M CPC - The O&M CPC is a measure that
2 focuses on controlling costs and driving efficiencies in order to keep our
3 costs reasonable for our customers. The metric is based on targeted O&M
4 expenses and number of customers. These components are combined to
5 create the O&M CPC metric.
6
7 • Customer Satisfaction - This measure is derived from a Voice-of-the-
8 Customer Survey, which is conducted each quarter by an independent
9 agency. The rating measures the customer's overall satisfaction with the
10 service they received during a recent contact with the Company's contact
11 center and/or service center.
12
13 • Reliability - This measure tracks how quickly the Company restores
14 customer outages, how frequently customers are affected by outages and
15 what percent of customers experience more than three sustained outages per
16 year. The Company combined three common industry indices in order to
17 balance our focus.?
18
19 • Response Time— This measure tracks how quickly the Company responds
20 to dispatched natural gas emergency calls. The primary objective is
21 customer and public safety while consistently treating customers the same
22 throughout our service territory.
23
24 We believe these metrics are intertwined, in that effective cost management aids in
25 keeping our costs reasonable for our customers, which in concert with reliable service and
26 appropriate response to disruptions in service,results in a positive experience for our customers
27 as measured in the Company's Voice-of-the-Customer survey.8 That survey shows a very high
28 level of customer satisfaction. In the end, we were very purposeful in choosing metrics we
29 believe incentivize our employees to diligently execute cost management and efficiencies
30 throughout the organization, while keeping our focus on safe and reliable electric and natural
7 This index combines Customer Average Interruption Duration Index (CAIDI), System Average Interruption
Frequency Index (SAIFI) and Customer Experiencing Multiple Interruptions (CEMI3). CEMI3 measures the
percentage of customers that experience more than three sustained outages in the year.
8 Voice of the Customer(VoC)is Avista Utilities'customer feedback survey. It is administered throughout the
year and results are reported on a monthly and quarterly basis. The customers surveyed for this study have had
contact with Avista regarding their account, service work and/or outages. This contact is generally with a
Customer Service Representative,Crew Representative or Field Personnel.
Rosentrater, Di 11
Avista Corporation

I gas service.
2
3 IV. SUMMARY OF GENERAL RATE CASE & DRIVERS
4 Q. Would you please summarize the Company's Two-Year Rate Plan
5 proposal included in this electric and natural gas general rate case filing?
6 A. Yes. In this filing, the Company is proposing a Two-Year Rate Plan, which
7 would begin with new rates effective September 1, 2025 and September 1, 2026. The
8 Company is proposing a Two-Year Rate Plan to, once again, avoid annual rate cases in its
9 Idaho jurisdiction, providing benefits to all stakeholders. A Two-Year Rate Plan, with base
10 rate increases in 2025 and 2026, would provide benefits to its customers by providing some
11 level of rate certainty over this two-year period; relief to all stakeholders — customers, the
12 Commission and its Staff, intervenors, and the Company - from the administrative burdens
13 and costs of litigation of annual general rate cases; and to Avista by providing a two-year
14 window to manage its business in order to achieve a fair rate of return within known price
15 changes.9 The Company filed for, and the Commission approved through settlement, a Two-
16 Year Rate Plan in its 2023 general rate case. Like in previous rate plans,Avista found that the
17 results would be reasonable, especially because the parties agreed, in settlement, to what we
18 believe would be a reasonable first year revenue requirement. But as you can see from
19 Illustrations No. 1 and 2 above, we quite simply have not been able to overcome increases in
20 costs and capital lag to earn near our authorized rate of return.
9 The Two-Year Rate Plan would not preclude tariff filings authorized by or contemplated by the terms of the
Power Cost Adjustment(PCA),Purchased Gas Adjustment(PGA),Public Purpose Rider Adjustment(DSM)or
similar adjustments. The Company is proposing that the Two-Year Rate Plan also not preclude the Company
from filing for rate relief or accounting treatment for major changes in costs not reflected in this filing, including
but not limited to the potential for changes in corporate tax rates, new corporate initiatives, or new safety or
reliability requirements imposed by regulatory agencies.
Rosentrater, Di 12
Avista Corporation

1 Q. Please elaborate on the benefits of a reasonable first year revenue
2 requirement.
3 A. As the Company has stated in prior rate cases, in any multiyear rate plan, the
4 first-year revenue requirement approved by a commission will persist for each year of the rate
5 plan and is the basis for an additional revenue adjustment in Rate Year 2. If the revenue
6 requirement is sufficient for the first year of the plan, and the next year is built off of that
7 revenue requirement, the utility would have a better opportunity to earn its allowed rate of
8 return. But if the first-year revenue requirement is insufficient,that insufficiency will persist,
9 and the utility may not be able to earn its authorized returns during the plan.
10 Q. Would you please provide an overview of the Company's general rate
11 request?
12 A. Yes. As discussed by Company witnesses Ms. Schultz and Mr. Miller, the
13 Company is requesting a Two-Year Rate Plan with a Rate Year 1 electric base rate relief of
14 $43.0 million(14.4 percent billed)and natural gas base rate relief of$8.8 million(10.3 percent
15 billed), effective September 1, 2025. The Company is also requesting a Rate Year 2 electric
16 base rate relief of$17.7 million (5.2 percent billed) and natural gas base rate relief of$1.0
17 million (1.0 percent billed), effective September 1, 2026.
18 Table No. 1 below provides the billed impact of the Company's electric rate request,
19 by rate schedule, for each of the two years. Table No. 2 provides the billed impact of the
20 Company's natural gas rate request, again, for each of the two years, by rate schedule.
Rosentrater, Di 13
Avista Corporation

I Table No. 1 —2025 and 2026 Electric Billed Percentage Change
2
2025 Billing 2026 Billing
3 Rate Schedule Description Change Change
Residential Service Schedule 1 14.7% 5.3%
4 General Service Schedules 11 & 12 14.2% 5.1%
Large General Service Schedules 21 &22 14.1% 5.1%
5 Extra Large General Service Schedule 25 14.3% 5.2%
Extra Large General Service 25P Schedule 25P 14.4% 5.2%
6 Pumping Service Schedules 31 &32 14.1% 5.1%
Street&Area Lights Schedules 41 - 49 13.4% 4.9%
7 Total 14.4% 5.2%
8 Table No. 2 —2025 and 2026 Natural Gas Billed Percentage Change
9
2025 Billing 2026 Billing
10 Rate Schedule Description Change Change
General Service Schedule 101 10.3% 1.3%
11 Large General Service Schedules 111 & 112 10.30o 0.0%
Interruptible Service Schedules 131 & 132 0.0% 0.0%
12 Transportation Service* Schedule 146 10.3% 0.0%
Total 10.3% 1.0%
13 * excludes commodity and interstate pipeline transportation costs
14 Q. What is the Company's proposed cost of capital?
15 A. The Company's electric and natural gas requests are based on a proposed rate
16 of return of 7.68 percent, with a capital structure comprised of 50 percent equity and 50
17 percent debt,a 4.95 percent cost of debt,and a 10.4 percent return on equity(ROE). Company
18 witnesses Mr. Christie and Dr. Thompson discuss the support for the proposed cost of capital
19 components.
20 Q. Has the Company prepared a simplified summary of the major
21 components driving the revenue requirement in this case?
22 A. Yes. As Ms. Schultz provides in her direct testimony, the following table
23 provides a summary-level breakdown of the revenue requirement components:
Rosentrater, Di 14
Avista Corporation

I Table No. 3 —Revenue Requirement Summary
2 ID Electric Revenue Requirement RY1 Electric RY2 Electric
Capital&Other(Labor, Benefits, O&M, etc.) $ 25,356 $ 11,081
3 Net Power Supply(including Transmission Revenues) $ 7,187 $ 9,020
Updated Baselines
4 Incremental Wildfire Baseline $ 1,103
5 Incremental Insurance Baseline $ 5,547
Regulatory Amortizations $ 3,872
6 Net Colsti*Amortization/Removal $ (114) $ (2,427)
Proposed Revenue Requirement $ 42,951 $ 17,674
7
ID Natural Gas Revenue Requirement RY1 Gas RY2 Gas
8 Capital&Other(Labor, Benefits, O&M, etc.) $ 5,584 $ 983
Updated Insurance Baseline $ 386
9 Regulatory Amortizations $ 2,833
10 Proposed Revenue Requirement $ 8,803 $ 983
11 Q. What is the monthly bill change for a residential electric customer with
12 average consumption, in Year 1?
13 A. The proposed monthly bill change for a residential customer using an average
14 of 939 kWhs per month is $15.36 per month, or a 14.7 percent change in their electric bill.
15 The present monthly bill for 939 kWhs is $104.30, and that would increase to $119.66. This
16 includes a $5 per month proposed increase in the basic charge (to $25 per month from the
17 present$20 per month level), as discussed by Mr. Miller.
18 Q. What is the monthly bill change for a residential electric customer with
19 average consumption, in Year 2?
20 A. The proposed monthly bill change for a residential customer using an average
21 of 939 kWhs per month is $6.36 per month, or a 5.3 percent change in their electric bill. The
22 present monthly bill for 939 kWhs is $119.66, and that would increase to $126.02. The
23 monthly bill increase incorporates a further$5 per month proposed increase in the basic charge
Rosentrater, Di 15
Avista Corporation

I (to $30 per month), as discussed by Mr. Miller.
2 Q. What is the monthly bill change for a residential natural gas customer
3 with average consumption, in Year 1?
4 A. The proposed monthly bill change for a residential customer using an average
5 of 66 therms of natural gas per month would be an increase of $6.29 per month, or 10.4
6 percent. The present monthly bill for 66 therms per month is $60.63, and the proposed bill
7 would be $66.92.
8 Q. What is the monthly bill change for a residential natural gas customer
9 with average consumption, in Year 2?
10 A. The proposed monthly bill change for a residential customer using an average
11 of 66 therms of natural gas per month would be $0.88 per month, or 1.3 percent. The present
12 bill for 66 therms per month is $66.92, and the proposed bill would be $67.80.
13 Q. What are the primary factors driving the Company's requested electric
14 and natural gas revenue increases?
15 A. As discussed by Ms. Schultz (and shown on Table No. 3), the primary factor
16 driving the Company's electric and natural gas revenue requirements in RY1 and RY2 is an
17 increase in net plant investment (including return on investment, depreciation and taxes, and
18 offset by the tax benefit of interest) from that currently authorized. For RY1 and RY2, electric
19 net power supply expenses also contribute to the incremental electric revenue requirement.
20 Company witnesses Mr. Kinney and Mr. Kalich will speak to that. Other changes impacting
21 the Company's revenue requirement requests relate to increases in distribution, operation and
22 maintenance (O&M), and administrative and general (A&G) expenses for both electric and
23 natural gas operations, compared to current authorized levels.
Rosentrater, Di 16
Avista Corporation

I Q. What are the major components of the increased plant investment
2 included in the Company's Rate Year 1 and Rate Year 2 electric and natural gas results?
3 A. Looking at the changes to "gross" plant in service for Rate Year 1, Idaho
4 "gross"plant increases by approximately$115.0 million for electric, and approximately$33.6
5 million for natural gas, as compared to what is currently embedded in base retail rates. For
6 Rate Year 2, "gross" plant increases by approximately $72.6 million for electric, and
7 approximately $11.1 million for natural gas, as compared to Rate Year 1. A breakdown of
8 the incremental electric and natural gas gross plant additions for each year is shown in Table
9 No. 4 as follows:
10 Table No. 4—Gross Plant Additions
11 Gross Plant Additions (000s)
Ele ctric Total Over
12
Investment RY11 RY22 2-YR Plan
13 Generation/Transmission $ 284 $ 21 $ 305
Distribution $ 119,793 $ 65,117 $ 184,910
14 General&Intangible $ 5,096 $ 7,491 $ 2,395
Total Electric Gross Additions $ 114,981 $ 72,6291 $ 187,610
15 Net Plant Additions $ 117,661 $ 72,895 1 $ 190,556
16 Natural Gas Total Over
Investment RY11 RY22 2-YR Plan
17 Distribution $ 27,426 $ 8,611 $ 36,037
General&Underground Storage $ 6,208 $ 2,4421 $ 8,650
18 Total Natural Gas Gross Additions $ 33,634 $ 11,053 $ 44,687
Net Plant Additions $ 21,432 $ 6,443 $ 27,875
19
1RY1-Effective September 1,2025-August 31,2026
20 2RY2-Effective September 1,2026-August 31,2027
TTotal gross plant and accumulated depreciation(net plant)are lower than they otherwise would be based solely
21 on new capital additions,due to the removal of Colstrip effective January 1,2026,impacting both RY1(removal of
8 months)and RY2(removal of 4 months).
22 4General and intangible gross plant additions are impacted by the retirement of shorter lived assets.
23 The specific 2024 through August 2027 pro forma capital investments undertaken by
Rosentrater, Di 17
Avista Corporation

I the Company to expand and replace its generation, transmission, distribution and general
2 facilities are discussed further by Company witnesses Mr. Howell regarding production and
3 environmental investment,Mr. Kinney regarding the Company's investment in Colstrip Units
4 3 and 4, Mr. DiLuciano regarding transmission, distribution and general investment, Mr.
5 Manuel regarding the costs associated with Avista's IS/IT projects, and Mr. Malensky
6 regarding Wildfire Plan investments. Ms. Benjamin sponsors the restating and pro forma
7 capital adjustments which incorporate the effects of these capital investments in the
8 determination of the Company's proposed revenue requirements.10
9 Q. What is driving the need for continued capital investment?
10 A. As discussed by Mr. Christie, there are six drivers of the Company's capital
11 investments:
12 1. Respond to customer requests for new service or service enhancements;
13 2. Meet regulatory and other mandatory obligations;
14 3. Replace equipment that is damaged or fails, and support field operations;
15 4. Replace infrastructure at the end of its useful life based on asset condition;
16 5. Meet our customers' expectations for quality and reliability of service; and
17 6. Address system performance and capacity issues.
18
19 An explanation of each of these drivers is provided by Mr. Christie,who also provides further
20 details on our capital planning process, which is used to identify and prioritize capital
21 investment, in the appropriate time frame, in a manner that best meets the future needs and
22 expectations of our customers.
23 Q. Has Avista proposed to update changes in power supply costs in this case?
24 A. Yes. As discussed in Mr. Kalich's testimony, the level of Idaho's share of
io 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 Ms. Andrews. The Colstrip Unit 3 and 4 generation
capital additions in 2024 and 2025 are sponsored by Mr.Kinney.
Rosentrater, Di 18
Avista Corporation

I power supply expense effective with Rate Year 1 has increased by approximately $12.3
2 million ($29.3 million on a system basis) from the level currently included in base rates. Net
3 power supply expense in Rate Year 2 rises by an additional $9.5 million ($26.8 million on a
4 system basis). Company witness Mr. Dillon discusses modifications to authorized
5 transmission revenues and expenses in his testimony.
6 Q. Please identify the main components of the distribution, O&M and A&G
7 expense changes included in the Company's filing.
8 A. Although the Company has a series of increases in expenses, for electric
9 operations these increases are largely due, in part, to changes in costs associated with the
10 Company's Wildfire Plan expenses and increases in insurance related to higher premiums, as
11 a result of wildfires across the Country,as well as increases in labor and benefits. To recognize
12 these cost changes, the Company, through Ms. Schultz, has included a number of pro forma
13 adjustments for Rate Year 1 and Rate Year 2 to capture the net increases the Company will
14 experience from the June 30,2024 test year.Further,Ms. Andrews provides testimony related
15 to the present Insurance and Wildfire Expense Balancing Accounts, the accounting treatment
16 of Colstrip, and the Company's generation major maintenance deferral mechanism.
17
18 V. CUSTOMER COMMUNICATIONS, SATISFACTION, & SUPPORT
19 Q. How is Avista communicating with its customers to explain what is driving
20 increased costs for the Company?
21 A. The Company proactively communicates with its customers about a range of
22 subjects through a variety of channels: Avista's website www.myavista.com, electronic and
23 print newsletters, Avista Connect www.myavista.com/Connect, social media, customer
Rosentrater, Di 19
Avista Corporation

I forums, one-on-one customer interactions through field personnel and account
2 representatives,bill inserts,direct email,media contacts,group presentations, and through our
3 employees' involvement in community, business and civic organizations. We believe our
4 communications help our customers and the communities we serve to better understand the
5 utility business as well as issues faced by the Company that contribute to their energy rates,
6 such as increased and ongoing infrastructure investment and improvement, commodity cost
7 volatility, and security, among other things.
8 Our employees provide excellent customer service, and this focus on communicating
9 with our customers includes providing our employees messaging and new tools and training
10 to make it easier to communicate effectively with friends, family, and customers. We have
11 found that once a customer talks with our employees and voice their concerns and receive
12 answers to their questions, their satisfaction level increases. We are also continuing our focus
13 on informing customers of the many programs we offer to aid in managing their energy bills
14 and ensuring that our employees are equipped to engage in these conversations.
15 Q. What kind of feedback do you receive from customers related to customer
16 satisfaction?
17 A. Our customer service surveys indicate that customer satisfaction remains high.
18 Our overall customer satisfaction from our Voice-of-the-Customer (VOC) surveys for
19 calendar year 2024 was 97% in our Washington, Idaho, and Oregon operating divisions. The
20 purpose of the VOC Survey is to measure and track customer satisfaction for Avista Utilities'
21 "contact" customers — i.e., customers who have contact with Avista through the Contact
22 Center and/or work performed through an Avista construction office. This rating reflects a
23 positive experience for customers who have contacted Avista related to the customer service
Rosentrater, Di 20
Avista Corporation

I or field service they received. These results can be achieved only with very committed and
2 competent employees.
3 Q. Please briefly summarize the customer support programs that Avista
4 provides for its customers in Idaho.
5 A. Avista Utilities offers a number of programs for its Idaho customers, such as
6 energy efficiency programs, Project Share for emergency assistance to customers, the
7 Customer Assistance Referral and Evaluation Service(CARES)program,level pay plans,and
8 payment arrangements. Some of the key programs that we offer, or support, are as follows:
9 1. Energy Efficiency. Avista began offering energy efficiency programs to its
10 customers in 1978. These programs pursue all cost-effective energy efficiency and
11 operate within the prevailing market and economic conditions. Recent programs
12 with the highest impacts on energy savings include residential and non-residential
13 prescriptive lighting, residential fuel efficiency, site-specific lighting, and small
14 business projects. Avista energy efficiency programs provide conservation and
15 education options to the residential, low income, commercial, and industrial
16 customer segments.Program delivery includes prescriptive, site-specific,regional,
17 upstream,behavioral,market transformation, and third-party direct install options.
18 Prescriptive programs, or standard offerings, provide cash incentives for
19 standardized products such as the installation of qualifying high-efficiency heating
20 equipment. Prescriptive programs work in situations where uniform products or
21 offerings are applicable for large groups of homogeneous customers and primarily
22 occur in programs for residential and small commercial customers.
23
24 2. Project Share. Project Share is a community fuel fund that is supported by a
25 partnership of utilities and community action agencies; it provides "emergency"
26 energy assistance to qualified households that have exhausted all other energy
27 assistance resources.
28
29 3. Customer Assistance Referral Evaluation Services (CARES)
30 Program. Avista's CARES Department works with customers experiencing
31 circumstances such as medical crisis, unemployment, family hardships, or other
32 special conditions that may impact the customer's ability to pay their utility bill.
33 CARES works with the customer to connect them with energy assistance,provide
34 specialized payment arrangements, and often delays disconnect to accommodate
35 this process.
36
37 4. Comfort Level Billing (CLB). The Company offers the option for residential
38 customers to pay the same bill amount each month of the year by averaging their
Rosentrater, Di 21
Avista Corporation

I annual usage. Under this program customers can avoid unpredictable winter
2 heating bills.
3
4 5. Multiple Payment Methods. The Company offers a number of payment
5 methods for residential customers. In addition to making a payment at pay
6 stations, drop boxes, or paying by cash at pay stations or the Company's office,
7 Avista also offers customers online payment options through the
8 Company's website via ACH or credit/debit card. Whether paying
9 online or by telephone, these options post to the customer's account almost
10 immediately and these transactions can be completed without the customer leaving
I I their home.
12
13
14 VI. SUMMARY OF WITNESSES
15 Q. Would you please provide a brief summary of the testimony of the other
16 witnesses representing Avista in this proceeding?
17 A. Yes. The following additional witnesses present direct testimony on behalf of
18 Avista:
19 Mr. Kevin Christie, Senior Vice President, Chief Financial Officer, Treasurer and
20 Regulatory Affairs Officer, will provide a financial overview of Avista Corporation as well
21 as explain our credit ratings and the Company's proposed capital structure and overall rate of
22 return in this case. In brief, he provides information that shows:
23 1. Avista's plans call for a continuation of utility capital investments in generation,
24 transmission, electric and natural gas distribution systems, and technology to
25 preserve and enhance service reliability for our customers,including the continued
26 replacement of aging infrastructure. Capital expenditures, on a system basis, of
27 $515 million (for 2024), $525 million (for 2025), $575 million (for 2026), and
28 $600 million (for 2027) are planned. Avista needs adequate cash flow from
29 operations to fund these requirements,together with access to capital from external
30 sources under reasonable terms, on a sustainable basis.
31
32 2. We are proposing an overall rate of return of 7.68 percent, which includes a 50
33 percent common equity ratio, a 10.40 percent return on equity, and a cost of debt
34 of 4.95 percent. We believe our proposed overall rate of return of 7.68 percent and
35 the proposed capital structure provide a reasonable balance between affordability
36 and reliability.
37 3. Avista's corporate credit rating from Standard & Poor's (S&P) is currently BBB
Rosentrater, Di 22
Avista Corporation

I with a negative outlook and Baa2 with a stable outlook from Moody's Investors
2 Service. Avista must operate at a level that will support a solid investment grade
3 corporate credit rating in order to access capital markets at reasonable rates. A
4 supportive regulatory environment is an important consideration by the rating
5 agencies when reviewing Avista. Maintaining solid credit metrics and credit
6 ratings will also help support a stock price necessary to issue equity under
7 reasonable terms to fund capital requirements.
8
9 Dr. John Thompson, with Financial Concepts and Applications (FINCAP), Inc., has
10 been retained to present testimony with respect to the Company's cost of common equity. He
11 concludes that:
12 • To reflect the risks and prospects associated with Avista's jurisdictional utility
13 operations, his analyses focus on a proxy group of firms in Value Line's "Electric
14 Utility" industry.
15
16 • Because investors'required return on equity is unobservable and no single method
17 should be viewed in isolation, he applied the DCF, CAPM and risk premium
18 methods to estimate a just and reasonable ROE.
19 • Based on the results of these analyses and giving less weight to extremes at the
20 high and low ends of the range, he concludes that the cost of equity for the proxy
21 group of utilities is in the 10.2 percent to 11.2 percent range, or 10.27 percent to
22 11.27 percent after incorporating an adjustment to account for the impact of
23 common equity flotation costs.
24
25 As also reflected in the testimony of Kevin Christie, Avista is requesting a fair
26 ROE of 10.4 percent, which is below the 10.77 percent midpoint of his
27 recommended range. An ROE at the midpoint of his recommended range is fully
28 justified for Avista given the results of his proxy group financial analyses. Based
29 on the results outlined above, he concludes that the 10.4% ROE requested by the
30 Company represents a conservative estimate of investors' current requirements.
31
32 Ms. Kaylene Schultz, Manager of Regulatory Affairs, describes accounting and
33 financial data in support of the Company's Two-Year Rate Plan for the period September 1,
34 2025,through August 31, 2027. She explains pro formed operating results, including expense
35 and rate base adjustments made to actual operating results and rate base. In addition, she
36 incorporates the Idaho-share of the proposed adjustments of other witnesses in this case.
37 Ms. Elizabeth Andrews, Senior Manager of Revenue Requirements, describes various
Rosentrater, Di 23
Avista Corporation

I adjustments included in the electric and natural gas revenue requirement studies prepared for
2 the Company's proposed Two-Year Rate Plan. These adjustments include the following: 1)
3 Pro Forma Wildfire Plan Expenses, 2) Pro Forma Insurance Expense, 3) Pro Forma
4 Miscellaneous Operations and Maintenance (O&M) Expense, 4) Pro Forma Colstrip and
5 Coyote Springs (CS2) Maintenance, 5) Pro Forma Colstrip Regulatory Asset Additions and
6 Amortization Expense, and finally, 6) Pro Forma Colstrip Assets and Depreciation Removal.
7 In addition, she discusses the Company's requests to update its Wildfire and Insurance
8 Balancing Account baselines to match pro formed wildfire plan and insurance expenses.
9 Mr. Scott Kinney, Vice President of Power Supply, provides an overview of Avista's
10 electric and natural gas resource planning and power and natural gas supply operations. This
11 overview includes summaries of the Company's current and future resource plans, as well as
12 an overview of the Company's Energy Resources Risk Policy. He will address the Colstrip
13 Units 3 and 4 plant additions included in this filing, as well as the decision to transfer plant
14 ownership of Colstrip Units 3 and 4 to NorthWestern Energy at the end of 2025 and no longer
15 serve Avista customers with this facility. His testimony will also discuss the Power Purchase
16 Agreements (PPA) from Lancaster, Columbia Basin Hydro and Clearwater Wind. He will
17 discuss the Company's current participation status in the Western Resource Adequacy
18 Program and the Northern Plains Connector Transmission Project. Finally, he discusses the
19 need to move to a single 95% customer / 5% Company (95/5) sharing level applied to the
20 entire difference between actual and authorized power supply costs in the Company's Power
21 Cost Adjustment mechanism.
22 Mr. David Howell, Director of Generation Production and Substation Support,provides
23 an overview of the Company's planned investments in our generating facilities and explains the
Rosentrater, Di 24
Avista Corporation

I factors driving our continuing investment in these assets. Additionally, he will describe our
2 environmental affairs projects that support compliance with, and management of, the licenses
3 issued by the Federal Energy Regulatory Commission authorizing the Company to operate its
4 hydroelectric facilities.
5 Mr. Clint Kalich, Senior Manager of Resource Planning & Power Supply Analyses,
6 includes documentation of the rationale for key inputs and assumptions driving power supply
7 cost values including loads, natural gas and electricity prices, and a comparison to current
8 levels of authorized power supply expense. He will provide an overview of contract changes
9 since our last filing. Finally, he will identify and explain the proposed pro forma adjustments
10 to test period power supply revenues and expenses, including the Retail Revenue Credit used
11 in the Power Cost Adjustment (PCA) over the Two-Year Rate Plan, effective September 1,
12 2025 (Rate Year 1) and September 1, 2026 (Rate Year 2).
13 Mr. Kenneth Dillon, Senior Manager, FERC Policy and Transmission Services,
14 presents Avista's transmission revenues and expenses included in the Company's request for
15 rate relief over the Two-Year Rate Plan, supporting updated transmission revenues effective
16 September 1, 2025 (Rate Year 1) and September 1, 2026 (Rate Year 2).
17 Mr. Joshua DiLuciano, Vice President of Energy Delivery, will provide an overview
18 of the Company's electric and natural gas energy delivery facilities and explain the factors
19 driving our continuing investment in electric distribution infrastructure. He explains how our
20 efforts to maintain the asset health and performance of our electric transmission system,
21 including compliance with mandatory federal standards for transmission planning and
22 operations, is driving a continuing demand for new investment. He will also describe why our
23 investments in natural gas distribution are necessary in the time frames completed, and why
Rosentrater, Di 25
Avista Corporation

I each capital investment in our operations facilities and fleet operations is needed to support
2 the efficient delivery of service to our customers today, and into the future. Furthermore, he
3 will address the electric and natural gas distribution, transmission, general plant, and fleet
4 related capital additions included in the Company's Two-Year Rate Plan filed in this case, for
5 the periods July 1, 2024, through August 31, 2027.
6 Mr. Vern Malensky, Director of Electric Engineering, discusses the status of the
7 Company's Wildfire Resiliency Plan ("Wildfire Plan" or "Plan"), reiterates its goals and
8 objectives, and summarizes the technical and operational aspects of the Plan. Avista's
9 Wildfire Plan reflects the Company's 135-year operating history combined with Avista's
10 efforts to quantify and respond to the financial, safety-related, and service reliability risks
11 associated with wildfires.
12 Mr. Wayne Manuel, Vice President and Chief Information and Security Officer,
13 provides an overview of and discusses capital additions and expenses associated with the
14 Company's Information Service/Information Technology (IS/IT) programs, projects and
15 security included in the Company's filed case over its proposed Two-Year Rate Plan. These
16 costs are comprised of the capital investments for a range of IS/IT projects that support
17 systems used by the Company, as well as cyber and physical security projects and costs. He
18 will explain why our information technology and security investments are necessary in the
19 time frames indicated.
20 Ms. Tia Benjamin, Manager of Regulatory Affairs, describes the Company's restated
21 twelve-months ended June 30, 2024, net plant from average-of-monthly-averages (AMA) to
22 end-of-period (EOP) adjustment, as well as explains how pro forma capital additions for the
23 period of July 1, 2024 through August 31, 2027 are incorporated into the Company's Two-
Rosentrater, Di 26
Avista Corporation

I Year Rate Plan and proposed electric and natural gas revenue requirements sponsored by Ms.
2 Schultz.
3 Mr.Marcus Garbarino,Manager of Regulatory Affairs, covers the Company's electric
4 revenue normalization adjustment to the test year results of operations, the proposed Load
5 Change Adjustment Rate to be used in the Power Cost Adjustment and Fixed Cost Adjustment
6 mechanisms, and the electric cost of service study performed for this proceeding.
7 Mr. Joel Anderson, Regulatory Analyst, covers the Company's natural gas cost-of-
8 service study developed for this proceeding. Additionally, he is sponsoring the natural gas
9 revenue normalization adjustments to the test year results of operations.
10 Mr. Joseph Miller, Senior Manager of Rates and Tariffs, discusses the spread of the
11 proposed 2025 and 2026 electric and natural gas base revenue increases among the
12 Company's electric and natural gas general service schedules.His testimony will also describe
13 the changes to the rates within the Company's electric and natural gas service schedules, and
14 proposed changes to the electric residential basic charge.
15 Q. Does this conclude your pre-filed direct testimony?
16 A. Yes.
Rosentrater, Di 27
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: [phone]
FACSIMILE: [phone]
DAVID.MEYER@AVIS 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 )
NATURAL GAS SERVICE TO ELECTRIC ) EXHIBIT NO. I
AND NATURAL GAS CUSTOMERS IN THE ) OF
STATE OF IDAHO ) HEATHER L. ROSENTRATER
FOR AVISTA CORPORATION
(ELECTRIC AND NATURAL GAS)

Bonners Ferry
Kettle Falls
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Chelan -.Kalispell
Colvill Clark Fork ~
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Seattle Wenatchee Rat `*eur d'Alene iw 1 r"1_0 �I
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rants Pass Electric
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v
9 Electric and Natural Gas
Exhibit No. 1
Case Nos.AVU-E-25-01/AVU-G-25-01
H. Rosentrater,Avista
Schedule 1, Page 1 of 2

WESTERN
CANADIAN
SEDIMENTARY
Station 2 BASIN
Avista Calgary
Natural Gas AECO
Vancouver
Service Areas,
Sumas/Huntingdon
Kingsgate
Gas Fields,
Trading Hubs
Seattle Spoican
• Major IF
Pi • Othello•
Stanfield •Grangeville
•
Portland •La Grande
Avista Service Territory
Williams-Northwest Pipeline ■
En bridge-Westcoast
TC Energy-GTN Boise
•Roseburg
TCEnergy-Foothills 0 ROCKIES
TC Energy-Nova
Grants Pass• Medford• Klamath Falls BASIN
Kinder Morgan-Ruby 0
Malin Opal
Jackson Prairie Storage Project
Trading Hubs p
Exhibit No. 1
Case Nos.AVU-E-25-01/AVU-G-25-01
H.Rosentrater,Avista
Schedule 1, Page 2 of 2