20250213Staff 1-40 to AVU.pdf

RECEIVED
Thursday, February 13, 2025 1:23:04 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S APPLICATION FOR THE ) CASE NOS. AVU-E-25-01; AVU-
AUTHORITY TO INCREASE ITS RATE AND ) G-25-01
CHARGES FOR ELECTRIC AND NATURAL )
GAS SERVICE TO ELECTRIC AND )
NATURAL GAS CUSTOMERS IN THE ) FIRST PRODUCTION
STATE OF IDAHO ) REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Avista Corporation("Company")provide
the following documents and information as soon as possible,but no later than THURSDAY,
MARCH 6, 2025.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 1 FEBRUARY 13, 2025

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide copies of the monthly trial balances from January
2023 through the most current month available. Please supplement your response when
additional months become available throughout 2025.
REQUEST NO. 2: Please provide a copy of the Company Chart of Accounts.
REQUEST NO. 3: Please provide a list of all external attorneys who performed services
for the Company or who were paid by the Company for services during 2023 and 2024. Please
list the amounts paid, accounts charged, and dates of payment. Please also provide a brief
summary of the services performed. If services were performed in support of a docketed
federal/state court or regulatory action,please identify the case name, case number, and
jurisdiction. For each expense,please list whether the expense is included in this case and also
illustrate how the charge was allocated to the Company's jurisdictions.
REQUEST NO. 4: Please provide the total amount that the Company spent on the
following activities for 2023 and 2024 and show how the Company allocated the amounts
between the Avista Utilities operating division and the rest of the Company and its subsidiaries.
For each expense, please also indicate whether the expense is included in this case.
a. Internal auditing expenses;
b. The Company's annual report;
c. Deloitte & Touche and Deloitte Consulting;
d. Rating agencies;
e. All software or information system-related issues;
f. The Company's Board of Directors ("Board of Directors") compensation, travel
expenses, and meeting expenses;
g. Corporate or chartered aircraft;
h. Travel and training for all shared executives of Avista Utilities and affiliates;
i. Insurance coverage;
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 2 FEBRUARY l 3, 2025

j. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses; and
k. All other allocated expenses.
REQUEST NO. 5: Please provide a copy of all regulatory orders relating to Avista
Utilities or its subsidiaries issued by state agencies in Oregon, Washington, Alaska, or the
Federal Energy Regulatory Commission in 2023 through 2025 to date.
REQUEST NO. 6: Please summarize all of the Company's environmental cleanup costs
during 2023 and 2024. Please show all account numbers and the amount booked to each
subaccount. Please also indicate whether each expense is included in this case.
REQUEST NO. 7: Please provide access to all employee newsletters issued in 2023 and
2024.
REQUEST NO. 8: Please provide a matrix identifying the major capital expenditure
approval levels that includes the dollar level of authorization by employee title, division, and
company. Please include within your response the dollar level at which the individual capital
expenditures require approval by the Board of Directors.
REQUEST NO. 9: Please provide an analysis of any sales of land and/or plant for the
years 2023 through 2025 to date, if any. Please show gains, losses, and supporting
documentation including accounting entries for removal of items from rate base.
REQUEST NO. 10: Please provide the details of any planned sales of land and/or plant
for the remainder of 2025 through 2026. Please include within your response the estimated date
of these sales and planned accounting treatment.
REQUEST NO. 11: Please provide a list of"out-of-period adjustments" and
"extraordinary items" for the years 2023 through 2025 to date.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 3 FEBRUARY 13, 2025

REQUEST NO. 12: Please provide a schedule showing injuries and damages claims
over$1,000 for the years 2018 through 2025 to date. Please include within your response the
description of each item, the amount for each item, the account charged, and whether the expense
is included in this case.
REQUEST NO. 13: Please provide the details of all advertising expenses recorded
above the line including account and subaccounts where posted, dates posted, vendor names,
explanations, and amounts posted during 2023 and 2024.
REQUEST NO. 14: Please provide copies of all advertisements used during 2023 and
2024 and correlate the advertisement with the specific detail provided in the Company's
response to Request No. 13.
REQUEST NO. 15: Please provide copies of all billing inserts for 2023 and 2024.
Please indicate the states where they were sent. Please also provide a schedule showing the
amount and account numbers charged for all costs to produce, print, and distribute the inserts and
indicate if the expense is included in this case.
REQUEST NO. 16: Please provide data regarding the Company's credit card usage
during the test year. This should include date, amount, employee number, description of
purchase, whether the expense is included in this case, and any other useful information.
REQUEST NO. 17: Please provide copies of all Audit Reports issued by the
Company's internal auditors for all audits completed during 2023 through 2025 to date.
REQUEST NO. 18: Please provide a copy of each adjusting journal entry proposed by
the Company's independent auditors in the two most recent audits of the Company. Please
include within your response the documentation supporting these adjustments, and the
documentation supporting any items that the Company decided not to adjust that are not reflected
in the Company's financial records and/or financial statements.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 4 FEBRUARY 13, 2025

REQUEST NO. 19: Please provide a list of all leased items from 2023 through 2025 to
date. Please separate capital leases from operating leases and show the dates, terms, amounts,
and accounts used for each lease.
REQUEST NO. 20: Please provide a schedule of prepaid items for 2023 through 2025
to date showing amounts posted, vendor names, explanations, and accounts to which these items
were booked. Please include within your response any significant changes to prepaid items
occurring or planned to occur in 2025 and 2026. Please indicate which prepaid items are
included in this case.
REQUEST NO. 21: For each officer of the Company, please provide the total dollar
amount of remuneration for 2021 through 2024. Please also provide the annualized amount for
2025 after any increases expected to occur during 2025. Please separate by year, salary,
incentive pay, options,benefits, and other. For each officer,please provide the percentages of
his or her total remuneration that is allocated to other subsidiaries each year along with the basis
for that
allocation.
REQUEST NO. 22: Please provide the following monthly direct labor related
information as recorded for 2022 through 2024. Information, where applicable, should be listed
by O&M expense, other expense, construction and other account groups (listed by functional
categories, i.e., generation, transmission, distribution, customer, A&G, etc.). Please provide the
information on a system-wide basis, and on an Idaho electric and Idaho gas jurisdiction basis.
The response should include wages and salaries for each employee category(officer, exempt,
non-exempt, and union), paid time-off, overtime,bonuses, incentive pay, and overheads for
pension, benefits, and payroll taxes. Please also include average and year-end number of
employees by employee category. Include part-time and temporary employees as full-time
equivalents.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 5 FEBRUARY 13, 2025

REQUEST NO. 23: Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years. Please provide any additional workforce
reduction programs planned for 2025 through 2026.
REQUEST NO. 24: Please summarize all benefit and retirement plans provided to any
classification of Company employees. Please also include any changes that have occurred to the
benefits/accruals during the past five years.
REQUEST NO. 25: Please provide the amount of Supplemental Executive Retirement
Plan expense, if any, which is included in the test year.
REQUEST NO. 26: Please provide copies of the Company's pension and actuarial
reports for the years 2022 through 2025. Also, please provide any actuarial calculations and
documentation that shows the development of FAS 87 expenses (ASC 715 Compensation-
Retirement Benefits as codified), Company contributions, balances, and assumptions.
REQUEST NO. 27: Please provide access to the Board of Directors meeting minutes
for each meeting in 2023 through 2025 to date.
REQUEST NO. 28: Please provide copies of the Board of Directors materials
distributed for/at meetings from 2023 through 2025 to date. Please also include the same for the
Compensation Committee.
REQUEST NO. 29: To the extent not previously included in the Company's response to
Request No. 28, please provide access to copies of all studies used to determine employee
compensation, including executive compensation, and explanations of how the Company applied
them in the years 2022 through 2025 to date.
REQUEST NO. 30: Please provide the fixed costs associated with the use of the
Company-owned aircraft, such as pilot salaries, hangar fees, etc. Please provide the total dollar
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 6 FEBRUARY 13, 2025

amount posted in 2023 and 2024 at the system level, the account(s)posted, and how those costs
were allocated or assigned to the Idaho electric and gas operations.
REQUEST NO. 31: Please provide the variable costs associated with the use of the
Company-owned aircraft. Please provide dollar amounts posted in 2023, 2024, and 2025 to date,
at the system level, the account(s)posted, and how those costs were allocated or assigned to the
Idaho electric and gas operations.
REQUEST NO. 32: Please detail the methodology used to calculating uncollectible
debt.
REQUEST NO. 33: Please detail the methodology used to calculate working capital.
Please also provide any lead-lag studies used.
REQUEST NO. 34: Please provide the detailed impacts of the Washington Climate
Commitment Act on this case.
REQUEST NO. 35: Please provide a list of any insurance proceeds received by the
Company in 2024. Please include a detailed narrative of the event initiating the insurance
payment.
REQUEST NO. 36: Please provide any potential insurance proceeds expected to be
received by the Company in 2025 and 2026. Please provide a detailed narrative of the events for
which an insurance payment may be received.
REQUEST NO. 37: Please provide a sortable spreadsheet listing all fully completed
capital projects (separated by electric and natural gas)placed in service since the end of test
period in the last general rate case (June 30, 2022) and the last actual plant-in-service date as
included in the Company's Application(end of the Company's Historic Test Year on June 30,
2024). Projects that are partially placed in service during the Historic Test Year or estimated for
completion during the proforma period SHOULD NOT be included on this list.
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 7 FEBRUARY 13, 2025

Additionally,please identify which projects are unique one-time projects and which are
"blanket"projects that capture multiple recurring smaller projects such as vehicle replacements
or O&M type of projects that are capitalized.
The list should contain the following minimum information for each project:
a. The project unique identification number;
b. The project title;
c. A short description of the project scope;
d. Classification as "one-time" or"blanket"project;
e. The project's primary function(based on standard accounting practices);
f. The initial approved budget for the project;
g. The latest approved budget for the project;
h. The actual expenditures for the project;
i. The final in-service date for the project;
j. Yes or no: the Company solicited contractors to execute some or all of the project;
and
k. The number of change orders.
REQUEST NO. 38: Please provide a sortable spreadsheet listing all capital projects
(separated by electric and natural gas) that the Company expects to be placed in service between
the last actual plant-in-service date included in the Company's Application (end of the
Company's Historic Test Year on June 30, 2024) and the end of the Company's proforma period
(end of the Company's Adjusted Test Year on August 31, 2027). Projects that are partially
placed in service during the Historic Test Year or estimated for completion during the proforma
period SHOULD be included on this list.
Additionally,please identify which projects are unique, one-time projects and which are
"blanket"projects that capture multiple recurring smaller projects such as vehicle replacements
or O&M type of projects that are capitalized.
The list should contain the following minimum information for each project:
a. The project unique identification number;
b. The project title;
c. A short description of the project scope;
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 8 FEBRUARY 13, 2025

d. Classification as "one-time" or"blanket"project;
e. The project's primary function(based on standard accounting practices);
f. The initial approved budget for the project;
g. The latest approved budget for the project;
h. The actual expenditures to date for the project;
i. The estimated in-service date for the project;
j. Yes or no: the Company is soliciting contractors to execute some or all of the project;
k. The number of change orders; and
1. The total cost of the change orders.
REQUEST NO. 39: Please provide a copy of the Company's policy for main
extensions.
REQUEST NO. 40: Please describe the Company's methodology for developing,
contracting, managing, executing, and completing Capital Projects in a least cost manner. Please
provide a copy of all Company policies and procedures documenting the process.
DATED at Boise, Idaho, this 131h day of February 2025.
(n r,— j)C
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\AVU-E-25-01;AVU-G-25-01 PR#l.docx
FIRST PRODUCTION REQUEST
TO AVISTA CORPORATION 9 FEBRUARY 13, 2025

CERTIFICATE OF SERVICE
t:
I HEREBY CERTIFY THAT I HAVE THIS DAY OF FEBRUARY 2025� ,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO AVISTA CORPORATION , IN CASE NO. AVU-E-25-01/AVU-G-25-01, BY
E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP & CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: patrick.ehrbargavistacorp.com E-mail: david.meye_r_gavistacorp.com
avistadocketskavistacorp.com
PATRICIA JORDAN, StCRETARY
CERTIFICATE OF SERVICE