20250303Staff 41-68 to AVU.pdf

RECEIVED
Monday, March 3, 2025 10:33:33 AM
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 ) SECOND 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 MONDAY,
MARCH 24, 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.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 1 MARCH 3, 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. 41: Please provide the Company's performance objectives for handling
incoming calls.
REQUEST NO. 42: What steps does the Company take if it fails to meet its
performance objectives for handling incoming calls?
REQUEST NO. 43: Please provide the service level for the Contact Centers by month
for each of the past three years (2022, 2023, and 2024). "Service Level"is the percentage of
calls answered within a certain number of seconds, e.g., 80% of calls answered within 60
seconds.
REQUEST NO. 44: Please provide the number of incoming calls handled by the
Contact Centers for each of the past three years (2022, 2023, and 2024).
REQUEST NO. 45: Please provide the number of abandoned calls to the Contact
Centers for each of the past three years (2022, 2023, and 2024). "Abandoned calls" are calls that
reach the Company's incoming telephone system, but the calling party terminates the call before
speaking with a customer service representative.
REQUEST NO. 46: Please provide the average speed of answer for the Contact Centers
for each of the past three years (2022, 2023, and 2024). "Average speed of answer" is the
interval (typically measured in seconds)between when a call reaches the Company's incoming
telephone system and when the call is picked up by a customer service representative.
REQUEST NO. 47: Please provide the average handling time for the Contact Centers
for each of the past three years (2022, 2023, and 2024). "Average handling time" is the average
amount of time (usually expressed in minutes) it takes for a customer service representative to
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MARCH 3, 2025

talk with a customer plus and additional "off-line"time it takes to complete the transaction or
fully resolve the customer's issue(s).
REQUEST NO. 48: Please provide the first call resolution rate for Contact Centers for
each of the past three years (2022, 2023, and 2024). "First call resolution rate" is the percentage
of calls where the transaction, inquiry, or complaint is resolved upon initial contact with the
Company.
REQUEST NO. 49: Please provide the average response time for email transactions for
the Contact Centers for each of the past three years (2022, 2023, and 2024). "Average response
time"is the average number of hours from receipt of an e-mail by the Company to sending a
substantive response; auto-response acknowledgements do not count as a substantive response.
REQUEST NO. 50: Please provide copies of the monthly bills for all Schedule 23
customers from 4/1/2024 through 12/31/2024.
REQUEST NO. 51: Please provide the billing determinants and monthly revenue for all
Schedule 23 customers from 4/l/2024 through 12/31/2024 as if they had been served under tariff
Schedule 11 and Schedule 21.
REQUEST NO. 52: Please provide monthly actual usage data for all Direct Current
Fast Charging ("DCFC") customers in 2024, including energy (kWh) and demand(kW).
REQUEST NO. 53: Please provide the number of Idaho DCFC customers currently
served by the Company and the number of these customers taking service under Schedule 11, 21,
and 23.
REQUEST NO. 54: Please refer to Joseph Miller's Workpapers and the file "Electric
Workpapers 2024 (AVU-E-25-01) RS RY1"provided with the Company's Application. Please
provide a bill impact analysis for all other electric rate schedules besides Schedule 1 that the
Company has performed.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 3 MARCH 3, 2025

REQUEST NO. 55: Please explain how the Company assigns the demand classified
costs to its rates for all electric rate Schedules. Please include the amounts and percentages of
these costs that are assigned to the customer charge, demand charge, and energy charge. For any
amounts assigned to the energy charge,please specify the amounts assigned to Block 1 and
Block 2.
REQUEST NO. 56: Please provide the Company's actual insurance expenses for 2023-
2025 and the estimated insurance expenses through 2027. Please provide supporting
documentation of actual expenses, including work papers, and any documentation of expected
increased expenses (i.e., emails, invoices, memos) for 2023 through 2025.
REQUEST NO. 57: The Company proposed a new rate adjustment tariff for insurance.
Miller Direct at 34. Please provide the proposed tariff schedule for Schedule 67/167 Insurance.
REQUEST NO. 58: Please provide an excel worksheet of each Idaho program category
for Wildfire Mitigation("WM") operational and maintenance ("O&M") expenses for 2023
through 2027 similar to the Company's 2024 Wildfire Resiliency Plan("WRP") - Table Nos. 6,
9, 11, and 14. For 2023 and 2024,please provide the forecasted costs from the 2023 WRP and
actual cost of each program category. Please identify any proforma adjustments for 2024 and
any amount deferred. Additionally, please explain any discrepancies between the forecasted
costs estimate and the actual expenses that are over or under 10%.
REQUEST NO. 59: Please provide an excel worksheet of each Idaho program category
for all WM capital expenses for 2023 through 2024. For 2023 and 2024, please provide the
forecasted cost and actual cost of each program category. Please identify any proforma
adjustments for 2024. Additionally,please explain any discrepancies between the forecasted
cost estimate and the actual expenses that are over or under by 10%.
REQUEST NO. 60: Please provide an excel worksheet that details any capital project
that replaced existing plant that was in-service and not fully depreciated at the time of
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 4 MARCH 3, 2025

replacement. Please explain the rationale for replacement of each and any supporting cost-
benefit analysis supporting retirement.
REQUEST NO. 61: Please provide all funding sources that the Company has explored
and received for its WM capital projects and O&M projects since the last rate case. Please
provide supporting documentation including applications, funding award notifications,
disbursement, and demonstrate where funds were applied to in this rate case.
REQUEST NO. 62: Page 36 of the WRP discusses a grant process with UMS
Consulting Group for wildfire detection cameras. Please answer the following:
a. Please explain if the Company received any of the grant money from the federal
grant under the DOE GRIP;
b. Please explain if the Company paid out any of the matching funds required under
the grant; and
c. Please clarify if the Company did not accept any grant money for wildfire
detection cameras.
REQUEST NO. 63: The Parties agreed to the Company developing a formal process for
undergrounding distribution lines related to the WRP prior to the next general rate case. AVU-
E-23-01 &AVU-G-23-01 Settlement and Stipulation at 15. Please answer the following:
a. Please provide the Company's undergrounding project criteria and the selection
process;
b. Please describe any occurrences where the Company undergrounded any
transmission and/or Idaho distribution lines for WM since the last rate case; and
c. For each completed undergrounding project,please provide a supporting
worksheet detailing the initial budget, the actual cost, project start date, in-service
date, location(inside or outside of a high fire risk zone), and a cost-benefit
analysis.
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 5 MARCH 3, 2025

REQUEST NO. 64: Please describe any occurrences where the Company installed
covered conductor lines for WM in Idaho. Please answer the following:
a. Please provide the Company's covered conductor project guidelines;
b. Please explain the location selection process for installing covered conductor; and
c. For any completed covered conductor projects, please explain the need, location
installed (inside or outside of a high fire risk zone), the need, the actual cost, the
total miles installed, and any cost-benefit analysis completed prior to installation.
REQUEST NO. 65: Please explain how the Company's wildfire mitigation efforts are
focusing on keeping rates affordable.
REQUEST NO. 66: Malensky's Schedule 7 states, "Avista estimates that the expected
useful life of the undergrounding projects is 98 years, while the economic book life is 55 years."
Schedule 7 at 49. Please provide the supporting data verifying that Avista's expected useful life
is 98 years.
REQUEST NO. 67: Please explain how the Company plans to use the results of"Cost-
Benefit Analysis for Avista Undergrounding Projects" study within its wildfire mitigation
efforts.
REQUEST NO. 68: Please explain what categories of the WRP expenses the Company
proposes to include for recovery in the proposed Schedule 87 —Wildfire Rate Adjustment.
Additionally, please provide the proposed tariff schedule.
DATED at Boise, Idaho, this 3rd day of March 2025.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\AVU-E-25-01;AVU-G-25-01 PR#2.docx
SECOND PRODUCTION REQUEST
TO AVISTA CORPORATION 6 MARCH 3, 2025

CERTIFICATE OF SERVICE
f'k"--
I HEREBY CERTIFY THAT I HAVE THIS DAY OF MARCH 2O25,
SERVED THE FOREGOING SECOND 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.ehrbarkavistacorp.com E-mail: david.meyer avistacorp.com
avistadocketsgavistacorp.com
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 6070 HILL ROAD
515 N 27TH ST BOISE ID 83703
BOISE ID 83702 E-mail: dreading(kmindspring com
E-mail: petergrichardsonadams.com
ELECTRONIC ONLY
carol.haugenkclearwaterpaper.com
Jamie.mcdonald a,clearwaterpaper.com
PATRICIA JORDAN ECRETARY
CERTIFICATE OF SERVICE