HomeMy WebLinkAbout20250306AVU to Staff 3-4_12-15_18_20-22_24_26_29-40.pdf RECEIVED
2025
AVISTA CORPORATION March 6,Idaho Public
RESPONSE TO REQUEST FOR INFORMATION Utilities Commission
JURISDICTION: IDAHO DATE PREPARED: 2/26/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schulz
REQUESTER: IPUC RESPONDER: D. Deubel/J. Anderson
TYPE: Production Request DEPARTMENT: Executive
REQUEST NO.: Staff-003 TELEPHONE: (509) 495-8638
REQUEST:
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.
RESPONSE:
Please see Avista's response Staff_PR_003C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
Please see Staff_PR_003C Confidential Attachment A which provides a listing of all external
attorneys who performed services for the Company, including Matter Description (see tab
"Pivot"), amounts paid, FERC accounts charged, month of payment and the service and
jurisdiction charged for all legal expenses incurred by the Company during 2023 and 2024,
excluding those charged to Non-Utility.
Total external Utility legal expenses for the twelve-month period ended June 30, 2024 (the
Company's historical test period used in this case)was approximately$3,961,000. Of these totals,
the amounts directly charged to Idaho electric was approximately $65,000 and Idaho natural gas
was $113,000. The remaining balance was allocated to the jurisdictions (Idaho, Washington, and
Oregon) or directly assigned to Avista's other Washington and Oregon jurisdictions as shown in
Staff PR 003C Confidential Attachment A(see tab "12ME 06.2024").
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 2/26/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schulz
REQUESTER: IPUC RESPONDER: D. Deubel/J. Anderson
TYPE: Production Request DEPARTMENT: Executive
REQUEST NO.: Staff-003C TELEPHONE: (509) 495-8638
REQUEST:
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.
RESPONSE:
Avista's response to 003C, contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL
information and are filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho
Code.
Please see Staff_PR_003C Confidential Attachment A which provides a listing of all external
attorneys who performed services for the Company, including Matter Description (see tab
"Pivot"), amounts paid, FERC accounts charged, month of payment and the service and
jurisdiction charged for all legal expenses incurred by the Company during 2023 and 2024,
excluding those charged to Non-Utility.
Total external Utility legal expenses for the twelve-month period ended June 30, 2024 (the
Company's historical test period used in this case)was approximately$3,961,000. Of these totals,
the amounts directly charged to Idaho electric was approximately $65,000 and Idaho natural gas
was $113,000. The remaining balance was allocated to the jurisdictions (Idaho, Washington, and
Oregon) or directly assigned to Avista's other Washington and Oregon jurisdictions as shown in
Staff PR 003C Confidential Attachment A(see tab "12ME 06.2024").
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Makayla Rademacher
TYPE: Production Request DEPARTMENT: Corporate Accounting
REQUEST NO.: Staff-004 TELEPHONE: (509) 495-8486
REQUEST:
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
j. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses
k. All other allocated expenses
RESPONSE:
See Staff PR 004 Attachment A for items a. —k. (Staff PR 004 Attachment B relates to item f.)
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 012 TELEPHONE: (509) 495-7658
REQUEST:
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.
RESPONSE:
Please see Avista's response Staff_PR_012C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
Please see Staff PR 012C Confidential Attachment A for the requested information.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 012C TELEPHONE: (509) 495-7658
REQUEST:
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.
RESPONSE:
Avista's response to 012C, contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL
information and are filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho
Code.
Please see Staff PR 012C Confidential Attachment A for the requested information.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Annie Gannon
TYPE: Production Request DEPARTMENT: Corp. Comm.
REQUEST NO.: Staff-013 TELEPHONE: (509) 495-2515
REQUEST:
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.
RESPONSE:
Cost of Customer Communications/Advertising
Please see Staff PR 013 Attachment A and Attachment B for detail of all advertising
expenses recorded above the line. See the Company's response to Staff PR 014
Attachment A for copies of advertisements.
Description of Customer Advertising
The Company advertises on a variety of topics using a number of mediums to help
inform and educate customers about topics of importance to them. Advertising is
defined by paid media including TV, Radio, digital, print and social. The main
categories of communications include:
DSM Outreach & Advertising
Customers were provided information about energy efficiency tips and Avista's rebate
programs through television, print, and digital advertising as well as our website and
program partners (e.g., contractors and equipment dealers).
Safety Advertising
Safety communication educates customers on various aspects of electric and natural gas
safety, including the importance of calling before they dig, knowing what to do if they
smell natural gas, using common sense around power lines, removing snow off of gas
meters, etc. A variety of advertising methods are used. Communication and outreach
also occurs around Hydro safety above and below our dams as well as awareness
regarding wildfire and what we are doing to keep our communities and system safe.
Bill Assistance
We inform customers about comfort level billing, preferred due date, flexible payment
arrangements, energy assistance programs and energy efficiency programs. Print
advertising and emails were used to educate customers about the many options they
have for managing their energy bill. The Avista website has additional information and
ways that customers can sign up for various bill payment options.
Rates Education
Additionally, we inform customers about the rates process and how their rate money is
utilized to maintain and upgrade the system.
Winter Heating/Summer Cooling
We inform our customers about the effects and impacts cold and hot weather and other
factors have on their energy bill. Providing many resources on our website for
customers to learn about the factors that can contribute to higher bills as well as provide
low-cost tips and rebate offerings to make energy efficient changes in their homes.
Other
Advertisements and customer outreach not covered in other categories are included in
"Other." This includes products and self-serve options such as solar, electric vehicles,
outage communications.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Annie Gannon
TYPE: Production Request DEPARTMENT: Corp. Comm.
REQUEST NO.: Staff-014 TELEPHONE: (509) 495-2515
REQUEST:
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.
RESPONSE:
Please see Staff PR_014 Attachment A for copies of advertisements.
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Annie Gannon
TYPE: Production Request DEPARTMENT: Corp. Comm.
REQUEST NO.: Staff-015 TELEPHONE: (509) 495-2515
REQUEST:
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.
RESPONSE:
Please see Staff PR_015 Attachment A for a listing of billing inserts and the costs associated with
the inserts. Staff PRO 15 Attachment B includes copies of billing inserts labeled by state.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kevin Christie
REQUESTER: IPUC RESPONDER: John Wilcox
TYPE: Production Request DEPARTMENT: Accounting
REQUEST NO.: Staff-018 TELEPHONE: (509) 495-4171
REQUEST:
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.
RESPONSE:
Please see Avista's response to Staff PR_018C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
There were no adjusting entries proposed. Please see Staff_PR_0I8C Confidential Attachments A
and B for the "passed upon" adjustments.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kevin Christie
REQUESTER: IPUC RESPONDER: John Wilcox
TYPE: Production Request DEPARTMENT: Accounting
REQUEST NO.: Staff-018C TELEPHONE: (509) 495-4171
REQUEST:
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.
RESPONSE:
Avista's response to 018C, contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL
information and are filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho
Code.
There were no adjusting entries proposed. Please see Staff_PR_0I8C Confidential Attachments A
and B for the "passed upon" adjustments.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Alan Pan
TYPE: Production Request DEPARTMENT: Utility Accounting
REQUEST NO.: Staff—020 TELEPHONE: (509) 495-8933
REQUEST:
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.
RESPONSE:
Please see Avista's response 020C, which contain TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
Please see Staff_PR_020C Confidential Attachment A for the requested information. In the
beginning of 2025, we entered into agreements that go beyond 12 months regarding prepaid
insurance. We will reclass the long-term portion to account 165115 — MISC LONG TERM
PREPAYMENTS. These policies are highlighted in Staff PR 020C Confidential Attachment A.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS:
REQUESTER: IPUC RESPONDER: Alan Pan
TYPE: Production Request DEPARTMENT: Utility Accounting
REQUEST NO.: Staff—020C TELEPHONE: (509) 495-8933
REQUEST:
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.
RESPONSE:
Please note that the attached document contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
Please see Staff_PR_020 Confidential Attachment A for the requested information. In the
beginning of 2025, we entered into agreements that go beyond 12 months regarding prepaid
insurance. We will reclass the long-term portion to account 165115 — MISC LONG TERM
PREPAYMENTS. These policies are highlighted in Staff PR 020 Confidential Attachment A.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 021 TELEPHONE: (509) 495-4796
REQUEST:
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.
RESPONSE:
Please see Avista's response 021 C, which contain TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
Please see Staff_PR_021 C Confidential Attachment A for total compensation for executive
officers for 2021-2024. Data is provided categorized by FERC account and expenditure type
(regular payroll, paid time off, incentive). Included within the data are charges to non-utility
accounts which are not included in the Company's rates. Benefits and payroll taxes are part of an
overall labor loader and are not tracked at the employee level. Overhead rates are applied to the
general ledger account where the direct labor charges originate. Please see the Company's
response to Staff PR 022 for additional information on incentive compensation.
The Company is not able to forecast and annualize the compensation for executive officers for
2025, as there is no forecast available in the format of the data provided in Staff_PR_21 C
Confidential Attachment A. However, please see update to Ms. Schultz, workpaper
"CONFIDENTIAL 3.02 Forecast Labor Executive (2025 ID GRC)" at Staff_PR_021 C
Confidential Attachment B, which includes the Board approved executive salaries for 2025,
approved February 12, 2025 and effective February 24, 2025. This update resulted in an overall
increase to Adjustment 3.02 for Idaho Electric of$25,000 and an increase to Adjustment 3.02 for
Idaho Gas of$7,000.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 021 C TELEPHONE: (509) 495-4796
REQUEST:
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.
RESPONSE:
Please see the Attachment provided, which contains TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
Please see Staff_PR_021 C Confidential Attachment A for total compensation for executive
officers for 2021-2024. Data is provided categorized by FERC account and expenditure type
(regular payroll, paid time off, incentive). Included within the data are charges to non-utility
accounts which are not included in the Company's rates. Benefits and payroll taxes are part of an
overall labor loader and are not tracked at the employee level. Overhead rates are applied to the
general ledger account where the direct labor charges originate. Please see the Company's
response to Staff PR 022 for additional information on incentive compensation.
The Company is not able to forecast and annualize the compensation for executive officers for
2025, as there is no forecast available in the format of the data provided in Staff_PR_21 C
Confidential Attachment A. However, please see update to Ms. Schultz, workpaper
"CONFIDENTIAL 3.02 Forecast Labor Executive (2025 ID GRC)" at Staff_PR_021 C
Confidential Attachment B, which includes the Board approved executive salaries for 2025,
approved February 12, 2025 and effective February 24, 2025. This update resulted in an overall
increase to Adjustment 3.02 for Idaho Electric of$25,000 and an increase to Adjustment 3.02 for
Idaho Gas of$7,000.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 022 TELEPHONE: (509) 495-7658
REQUEST:
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.
RESPONSE:
Please see Staff_PR_022 Attachment A for 2022-2024 total labor and benefit charges for System
Electric and System natural gas. 1 Data is provided by report category (capital, O&M,
non-operating, etc.), by functional category (Administrative and General, Distribution,
Transmission, etc.)and by expenditure type(loading, overtime,paid time off,regular labor). Data
is not readily available by employee category.
Please see Staff_PR_022 Attachment B for 2022-2023 incentive compensation(actual paid). Data
is provided by report category and employee group (executive, non-executive, exempt, union).
Please note that detailed 2024 incentive compensation data is not yet available and the Company
will provide a supplement to this production request at a later date.
Please see Staff_PR_022 Attachment C for the year-end employees by type, and report category
on a system basis. Please note the Full Time Equivalents(FTE) are calculated based on total hours
for the year divided by 2080. The Company's general ledger system does not track employees by
FTE.
'Please see Ms. Schultz's workpapers(1.00)Results of Operations and Allocation Factors for the Idaho Electric and
Idaho Natural Gas allocation factors.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 024 TELEPHONE: (509) 495-7658
REQUEST:
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.
RESPONSE:
All regular employees, including Executive Officers, are eligible for the Company's Qualified
Defined Benefit plan (hired after 01.01.14 and Local 77 hired after 01.01.2024 — see below), the
Company's 401(k)plan, health and dental coverage, Company-paid term life insurance, disability
insurance, paid time off and paid holidays. This benefit package offers several choices as to the
type of medical plan, dental plan, life insurance, etc. to determine the best fit for the employee's
circumstances. These plans are designed to be competitive with the overall market practices and
are in place to attract and retain the talent needed in the business. As with all portions of the plan,
the Company works with a third-party administrator to determine the annual rates for the
Company and for each individual employee based on their elections.I
Medical - Avista sponsors a self-funded medical benefit plan that provides various levels of
coverage for medical, dental and vision. Avista encourages employees to take responsibility for
their health care decisions and make lifestyle changes to avoid health care issues. The Company
also encourages participants to adopt and maintain healthy lifestyles and use health care wisely.
Proactive programs are set up to help individuals change their behaviors and live a healthier life.
The Company addresses this by using a health continuum; low risk (Wellness), moderate risk
(Wellness, Lifestyle Health Coaching) and high risk(Disease Management, Case Management).
As noted above, Avista provides various wellness programs in an effort to proactively manage
medical expense claims. In addition, the Company has implemented several measures to keep
medical costs down. To keep office visit costs down, we offer access to phone or web-based 24/7
telemedicine services and an on-site clinic. We have limited our exposure to large claims through
an insurance policy with annual stop-loss limits of $300,000 per person. When employees do
require medical care for catastrophic conditions, we have a case management program managed
by a third-party administrator to help manage these costs. To keep prescription drug costs down,
the Company has contracted with specialty pharmacies who help participants determine the most
economic treatment options.
1 The Company also offers Optional and Dependent Life insurance,Voluntary Accidental Death and Dismemberment
Insurance, Group Legal Services, and miscellaneous other benefits. Expenses related to these benefits are borne by
the employee and are not included in the Company's case.For this reason, and the immaterial nature of the cost,we
have not described these benefits in this response.
In addition, the Company implemented the following changes to the medical plan offered to
employees:
• For non-bargaining employees hired or rehired on or after January 1, 2014, and Local
Union 659 employees hired or rehired on or after April 1, 2014, upon retirement the
Company no longer provides a contribution towards his or her medical premiums. The
Company will provide access to the retiree medical plan,but the retiree will pay the full
cost of premiums upon retirement.
• Manage Utilization of Specialty Drugs—The Company reviews measures to lower the
cost of prescription drugs including requiring prior authorization, and implementing
step therapy.
• Beginning January 1, 2020, the method for calculating health insurance premiums for
the following employee groups changed: non-bargaining retirees, Local Union 659,
hired or rehired after April 1, 2014 under age 65, and active non-bargaining employees
hired or rehired after April 1,2014 under age 65. Revisions will result in separate health
insurance premium calculations for retirees and active employees beginning January 1,
2020.
Finally,beginning January 1, 2023, the Company made the following changes to the medical plan
offered to employees:
• Manage Utilization of Prescription Drugs—The Company has implemented a three-tier
formulary to lower the cost of prescription drugs.
• Standardized Rehab Benefit — The consolidating physical therapy, occupational
therapy, speech therapy, and added massage therapy by increasing the number of annual
visits to match the standard plans offered by our TPA, Premera.
• Introduced an Acupuncture Benefit—The limited number of visits is expected to assist
in treatment to prevent or minimize the need for more expensive procedures.
• Local Union 77 employees now have the option to enroll in the HDHP. Avista now
offers a self-insured High Deductible Health Plan ("HDHP") in addition to the current
self-insured plan to all employees. The HDHP requires plan participants to pay all costs
of medical care up to defined deductible limits. This plan enforces the message to
participants to manage their own health with an array of tools to assist them in becoming
better consumers.
Retirement Plans -Retirement programs are crucial to attracting and retaining a skilled workforce
within the utility industry. The Company provides a defined benefit pension plan and a defined
contribution plan (401k) to employees. For all employees hired or rehired on or after January 1,
20142, the Company's defined benefit is closed to all non-bargaining employees. For all Local 77
employees hired or rehired on or after January 1, 2024, the Company's defined benefit is closed.
All actively employed non-bargaining employees that were hired prior to January 1, 2014, and all
actively employed Local 77 employees hired prior to January 1, 2024, were covered under the
defined benefit pension plan at that time, will continue accruing benefits as originally specified in
the plan. A defined contribution 401(k) plan replaced the defined benefit pension plan for all
2 Changes were applicable to Local Union 659(Southeast Oregon)effective April 1,2014.
non-bargaining employees hired or rehired on or after January 1, 2014, and Local 77 hired after
January 1, 2024. Under the defined contribution plan, the Company will provide a non-elective
contribution as a percentage of each employee's pay based on his or her age. This defined
contribution is in addition to the existing 401(k) contribution, where Avista matches a portion of
the pay deferred by each participant. In addition to the above changes, the Company also revised
our lump sum calculation for non-bargaining retirees under the defined benefit pension plan to
provide non-bargaining participants who retire on or after January 1, 2014 with a lump sum
amount equivalent to the present value of the annuity based upon applicable discount rates.
Effective January 1,2024,the defined benefit pension plan closed to any new entrants as a result of
recent negotiations with Local Union 77. At that time the Company will provide a non-elective
contribution as a percentage of each employee's pay based on his or her age plus an additional
non-elective contribution while a member of the Local Union 77 bargaining unit, for new
employees under the Local Union 77 large contract hired after December 31, 20233. This defined
contribution is in addition to the existing 401(k) contribution, where Avista matches a portion of
the pay deferred by each participant. In addition to the above changes, the Company also revised
the lump sum calculation for Local Union 77 retirees under the defined benefit pension plan to
provide Local Union 77 participants who retire on or after July 1, 2022, with a lump sum amount
equivalent to the present value of the annuity based upon applicable discount rates. The Company
also added the service adjustment utilized in the 1.5% formula into the 1.2% formula for all
eligible employees. In addition, all pension eligible employees will have a one-time election
window during Q 12024 to make an irrevocable election to convert from the defined benefit
pension plan to the defined contribution.
Miscellaneous Other Benefits
The Company also offers these miscellaneous other benefits. Overall, costs represented by these
benefits represent less than 2% of overall benefit costs:
• Short and Long Term Disability
• Employee Assistance Plan
• Company Provided Term Life Insurance
• Tuition Assistance program
In addition, executives are offered the following benefits:
1. Supplemental Executive Officer Retirement Plan(SERP)
In addition to the Company's retirement plan for all employees, the Company provides
additional pension benefits through the SERP to executive officers of the Company who
have attained the age of 55 and a minimum of 15 years of credited service with the
Company. The costs associated with SERP are excluded from retail rates.
2. Deferred Compensation
The Executive Officer Deferred Compensation plan provides the opportunity to defer up to
75%of base salary and up to 100%of cash bonuses for payment at a future date. This plan
is competitive in the market and provides eligible employees and executive officers with a
tax-efficient savings method. The costs associated with Deferred Compensation are
excluded from retail rates.
s Changes were applicable to Local 77-B effective January 1,2025.
Avista regularly participates in a comprehensive benefit study, BENVAL, conducted by Willis
Towers Watson which compares the total value of our benefit package to the total benefit value of
our peers. This study is comparable to the peer group benchmarking conducted annually for direct
compensation. See Avista's response to Staff PR 029 for additional information.
The Company actively manages costs associated with the overall compensation package which
includes base salary and pay-at-risk incentive compensation in addition to the benefit package.
Please see the Company's response to Staff_PR_021 and Staff_PR_022 for additional information
on incentive and base pay.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kevin Christie
REQUESTER: IPUC RESPONDER: Jason Lang
TYPE: Production Request DEPARTMENT: Finance
REQUEST NO.: Staff- 026 TELEPHONE: (509) 495-2930
REQUEST:
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.
RESPONSE:
Please see Avista's response 026C, which contain TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
See Staff_PR_026C Confidential Attachments A — C for the 2022-2024 actuarial reports. The
reports contain the calculations, company contributions, balances, and assumptions.
See Staff_PR_026C Confidential Attachment D for the 2025 updated 5-year benefit cost
projections for the Retirement Plan and Retiree Medical based on the year-end 2024 disclosure
results based on market conditions as of February 6, 2024.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kevin Christie
REQUESTER: IPUC RESPONDER: Jason Lang
TYPE: Production Request DEPARTMENT: Finance
REQUEST NO.: Staff- 026C TELEPHONE: (509) 495-2930
REQUEST:
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.
RESPONSE:
Please see the Attachments provided, which contain TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
See Staff_PR_026C Confidential Attachments A — C for the 2022-2024 actuarial reports,
respectively. The reports contain the calculations, company contributions, balances, and
assumptions.
See Staff_PR_026C Confidential Attachment D for the 2025 updated 5-year benefit cost
projections for the Retirement Plan and Retiree Medical based on the year-end 2024 disclosure
results based on market conditions as of February 6, 2024.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 029 TELEPHONE: (509) 495-7658
REQUEST:
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.
RESPONSE:
Please see Avista's response 029C, which contain TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
Please see "Staff_PR_029C Confidential Attachment A"which is a"zip file"that includes salary
studies the Company has participated in for 2022-2024,there is not data readily available for 2025
at this time. These studies include companies such as Willis Towers Watson (formerly Towers
Watson), Mercer', Milliman, World atWork, to name a few. Due to the voluminous nature of the
documents they are being provided in electronic format only.
The Company conducts and participates in numerous salary studies each year to aid in the
determination of salary levels as part of the overall compensation package 2. These studies are
used in various ways depending upon the type of information collected in the study. In addition,
the benchmarking methods and resources used are slightly different for each group or
classification of employee; officer, non-bargaining, and bargaining, as described further below.
Benchmarking may be conducted annually or as needed depending on the group of employees.
The types of resources used may change over the years depending on cost, relevance, and
availability of the resource as well as changes in pay practices.
We use these resources for different purposes, for example we may use a survey to benchmark a
specific position or job type by region,to gather intelligence on overall anticipated salary increases
and pay structure changes, and/or to compare our pay practices to other companies and overall
regional trends.
The Company compiles the results of these surveys and targets overall compensation levels (base
and short-term incentive) to be within+/- 15% of the median. Typically the Company targets the
1 Due to the voluminous amount of documentation from Mercer(100,000 KB),the 2023-2024 IT survey has been
excluded because it was too large to transmit.
2Salary planning studies are also periodically utilized in the evaluation of the non-executive officer short term
incentive plan.No changes to target opportunities have been made in this plan since 2004.
utility industry for merit increases and changes to midpoints. Regional peers are also reviewed in
an effort to obtain intelligence on trends within the region. Ultimately the goal is to appropriately
position the overall compensation package to recruit and retain qualified employees.
While benchmarking is an important component of the setting of overall compensation levels, it is
not the sole criteria. Pay components may vary higher or lower than the median depending on an
individual's role, responsibilities and performance within the Company.
Officers Group
The Compensation Committee of the Board makes all compensation decisions regarding the
executive officers, including the level of cash compensation and equity awards. Each year the
Compensation Committee works with their independent compensation consultant to conduct a
benchmark study on the total compensation program for the officers. The studies typically include
base salaries, short-term cash incentives and long-term incentives. The Compensation Committee
believes it is important to provide a compensation structure that is competitive with compensation
paid to comparable executives of companies within the energy/utility industry to ensure the
Company attracts and retains quality employees in key positions to lead the Company.
Since Avista is an investor-owned utility it is also best practice to benchmark our officers'
compensation against other investor-owned utilities by focusing on compensation as disclosed in
proxy statements. Proxy statements focus on only the top 5 paid positions which means other
sources must be used to benchmark the remaining officers' compensation. The Compensation
Committee uses the Willis Towers Watson Energy Services Executive Compensation database for
additional compensation data.
Benchmarking best practices also suggest narrowing the range of companies to compare to that
which better reflect your own business and size. Avista's Compensation Committee compares
market data from a customized group of utilities we call our Proxy Peer Group. The Proxy Peer
Group better represents our Company's business, size and competitive market for talent. By using
publicly disclosed data from proxy statements, Form 8-Ks, and Form 4s it allows the Company to
maintain a consistent peer group without being restricted by private survey participation which
varies year to year. The Committee uses companies from the S&P 400 Utilities Index in the Proxy
Peer Group. The median revenues and market capitalization of the Proxy Peer Group run between
$1.9 billion and$4.6 billion,respectively. The data is not adjusted to reflect the differences in size
because the Committee generally targets overall compensation within+/- 15%of the median of the
peer group.
As mentioned above, the Committee also uses the Willis Towers Watson Energy Services survey
as a secondary resource for the top 5 but a primary resource for the other officers' compensation.
The survey provides additional compensation data on comparable diversified energy companies
with revenues between$1 billion and$3 billion. The advantage of using a survey is that it provides
competitive data for all of our executive officer positions. The Compensation Committee uses all
of these sources of data to help it make informed decisions about market compensation practices.
The Compensation Committee periodically will have the consultant prepare a special report on
best pay practices for executive officers.
Non-Bargaining Employee Group
The executive officers of the Company in collaboration with management make all compensation
decisions related to the level of cash compensation and equity awards for the non-bargaining
employee population. Our HR staff conducts studies and research related to best pay practices.
Each year Avista staff conducts benchmark and pay practice studies for the non-bargaining
employee group. The studies typically include base salaries, short-term cash incentives and
long-term incentives. The Company believes it is important to provide a compensation structure
that is competitive with compensation paid to comparable positions of companies within the
energy/utility industry as well as regional and local areas in which we compete for talent. By
keeping an eye on the market we ensure the Company attracts and retains quality employees in key
positions to run the business efficiently and within reasonable costs.
The benchmarking process for the non-bargaining employee group is different from the officer
group in that we do not have a specific Peer Group for the entire non-bargaining employee group.
Our definition of market is the organizations in which we compete for labor. For example,we may
use a national utility survey to benchmark an electrical engineer or a local general industry survey
for an administrative assistant position because that is the labor market in which we compete for
talent. Outlined below are the types of labor market competitors we compare ourselves to for the
following job groups.
Management Administrative/ Technical Support
Professional
General General General General
Energy/Utility/Utili Energy/UtilityEnergy/Utility
. National National Regional Local
Re Tonal Regional Local
• $1 - $3 billion All sizes All sizes All sizes
All sizes
And relative to our competitor group, we monitor market rate data as follows:
Base Salary Base Salary Base Salary Base Salary
. . Total Total Total Total
Coin
ensation Compensation Compensation Compensation
. . Median (50th Median Median Median
percentile) 75th percentile 75th percentile 75th percentile
75th percentile
The surveys we select support our philosophy by reporting data in the categories described above.
Outlined below is a list of salary surveys we have participated in over the years as well as their
general focus.
Utility Nation-wide Exec, Mgmt, Prof, Base salary, incentives,
Natural Gas Tech & Craft pay practices
Utility Gas, Nation-wide Exec Base salary, incentives,
Electric & pay practices
Alternative
Utility Gas, Nation-wide Mgmt, Prof, Tech& Base salary, incentives,
Electric & Support pay practices
Alternative
Utility Pacific Mgmt,Prof, Tech & Base salary,pay
Electric Northwest Craft practices
All Pacific Mgmt, Prof, & Tech Base salary, incentives,
: Industries Northwest pay practices
All Spokane & Tech & Support Base salary, incentives,
Industries Kootenai pay practices
Counties
Technology Pacific Mgmt, Prof, Tech& Base salary, incentives,
Northwest Support pay practices
All Pacific Engineering, Base salary, incentives,
Industries Northwest Scientific and Project pay practices
: Management
Technology Nation-wide Mgmt, Prof, Tech& Base salary, incentives,
Support pay practices
Utility Gas Nation wzuc Te t, Craft&
, . � Q. z
Non and Nation-wide Exec, Mgmt, Prof, & Base salary, incentives,
: Regulated Tech pay practices
Utilities
Non and Nation-wide Mgmt, Prof, Base salary,pay
• Regulated Operations, & practices
Utilities Technical
Our benchmarking process is generally done on an annual basis. It starts with completing
questionnaires for the different surveys then analyzing the data when the results are returned to us.
As part of the analysis Avista matches its internal jobs to the jobs in the survey sources to establish
an Estimated Market Value. We try to match our jobs to the jobs in at least two survey sources
which we believe better represents the competitive labor market. When establishing an Estimated
Market Value we use the 501h percentile or median data to better estimate the "typical"pay for the
job. Avista's compensation philosophy for the non-bargaining employee group is to target
compensation levels within+/- 15% of market median.
Avista has a pay structure with established pay ranges that are divided into two sections. The
market section represents the"market"(+/- 15%) and the midpoint is used for market comparison,
compa-ratio calculations and adjusting the structure. Our pay structure is a lead-lag position
relative to the targeted marketplace. A lead-lag philosophy positions our pay structure midpoints
so they match the market in mid-year(July). Basically our midpoints lead the external market for
the first half of the year and lag the market for the second half. This enables us to keep our actual
pay levels directly competitive with our targeted marketplace for each identified job group.
Each survey has its own effective date for the data collected and since we try to use at least two
survey sources for each job in our benchmarking process,we age date or"trend"the survey data to
one point in time which is July 1. As mentioned above we want to lead-lag the market and this
process allows us to make accurate and consistent market comparisons between the market and
internal average pay.
This benchmarking process is time consuming and complex. In order to simplify the process we
currently use a software product called MarketPay. The software is a modeling and reporting tool
that houses employee and survey data. Each year we import specific employee and job data into
the tool as well as survey source data. This software enables us to match an internal job to the
survey job to determine an Estimated Market Value. Once an Estimated Market Value is
determined we can calculate the ratio of internal pay to market by dividing the actual salary by the
market rate. This helps us determine if our current wages are competitive within the labor markets
we compete in for talent. We also calculate the ratio of actual pay to our own pay structure
midpoints. This compa-ratio calculation helps us to determine how much we should adjust our pay
structure to stay competitive.
The benchmarking process described above is one method we use to help control our payroll
growth and individual pay progress. We also participate in salary planning surveys. These surveys
collect data on salary practices such as actual and projected base salary increase budgets, whether
organizations are awarding pay increases or freezing pay, what is the average pay increase for
different job groups and performance levels, what was the actual and projected pay structure
adjustment, what types of incentive plans are being used, and what other pay practices
organizations are considering. These surveys focus on overall changes in employee compensation
for the calendar year and current projections for the following calendar year. We use these studies
to help us make informed decisions on market compensation practices with regards to
compensation spending and budgeting.
Our merit-increase program is a key vehicle through which non-bargaining employee pay is
adjusted on an annual basis. In order to plan and budget for the following calendar year,we collect
the following data from several surveys and compile it into a spreadsheet.Although we collect and
monitor the different markets (national, regional, local,utility), we target the utility industry since
most of our labor is utility specific.
National National National National
' • Regional Regional Regional Regional
Energy/Utility Energy/Utility Energy/Utility Energy/Utility
• Local Local
National National National National
' • Regional Regional Regional Regional
Energy/Utility Energy/Utility Energy/Utility Energy/Utility
• Local Local
Generally, in May of each year, preliminary minimum salary increases are approved for the
following calendar year by the Compensation Committee of the Board of Directors. In November,
salary increases for the following year are finalized and approved by the Board of Directors. The
salary structure adjustment data is reviewed and considered but the actual adjustment is
determined based on the compa-ratio analysis conducted during the benchmarking process
described above.
The processes described above are used to help us control our labor costs and keep them
reasonable for our customers and yet enables us to recruit and retain the labor force we need to run
the business and provide reliable levels of service.
Bargaining Group
The benchmarking process for the bargaining group is again different from the other groups. The
studies are conducted during or before the contract negotiations. They are not done on an annual
basis. The studies typically collect average base rate for lineman from other west-coast utilities
(investor-owned, PUDs, municipalities, Co-ops, etc.) and average increase from other west-coast
IBEW local contracts. All wage rates and increases are negotiated.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 029C TELEPHONE: (509) 495-7658
REQUEST:
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.
RESPONSE:
Please see the Attachments provided, which contain TRADE SECRET, PROPRIETARY or
CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code.
Please see "Staff_PR_029C Confidential Attachment A"which is a"zip file"that includes salary
studies the Company has participated in for 2022-2024,there is not data readily available for 2025
at this time. These studies include companies such as Willis Towers Watson (formerly Towers
Watson), Mercer', Milliman, World atWork, to name a few. Due to the voluminous nature of the
documents they are being provided in electronic format only.
The Company conducts and participates in numerous salary studies each year to aid in the
determination of salary levels as part of the overall compensation package 2. These studies are used
in various ways depending upon the type of information collected in the study. In addition, the
benchmarking methods and resources used are slightly different for each group or classification of
employee; officer, non-bargaining, and bargaining, as described further below. Benchmarking
may be conducted annually or as needed depending on the group of employees. The types of
resources used may change over the years depending on cost, relevance, and availability of the
resource as well as changes in pay practices.
We use these resources for different purposes, for example we may use a survey to benchmark a
specific position or job type by region,to gather intelligence on overall anticipated salary increases
and pay structure changes, and/or to compare our pay practices to other companies and overall
regional trends.
The Company compiles the results of these surveys and targets overall compensation levels (base
and short-term incentive) to be within+/- 15% of the median. Typically the Company targets the
utility industry for merit increases and changes to midpoints. Regional peers are also reviewed in
1 Due to the voluminous amount of documentation from Mercer(100,000 KB),the 2023-2024 IT survey has been
excluded because it was too large to transmit.
2Salary planning studies are also periodically utilized in the evaluation of the non-executive officer short term
incentive plan.No changes to target opportunities have been made in this plan since 2004.
an effort to obtain intelligence on trends within the region. Ultimately the goal is to appropriately
position the overall compensation package to recruit and retain qualified employees.
While benchmarking is an important component of the setting of overall compensation levels, it is
not the sole criteria. Pay components may vary higher or lower than the median depending on an
individual's role, responsibilities, and performance within the Company.
Officer Group
The Compensation Committee of the Board makes all compensation decisions regarding the
executive officers, including the level of cash compensation and equity awards. Each year the
Compensation Committee works with their independent compensation consultant to conduct a
benchmark study on the total compensation program for the officers. The studies typically include
base salaries, short-term cash incentives and long-term incentives. The Compensation Committee
believes it is important to provide a compensation structure that is competitive with compensation
paid to comparable executives of companies within the energy/utility industry to ensure the
Company attracts and retains quality employees in key positions to lead the Company.
Since Avista is an investor-owned utility it is also best practice to benchmark our officers'
compensation against other investor-owned utilities by focusing on compensation as disclosed in
proxy statements. Proxy statements focus on only the top 5 paid positions which means other
sources must be used to benchmark the remaining officers' compensation. The Compensation
Committee uses the Willis Towers Watson Energy Services Executive Compensation database for
additional compensation data.
Benchmarking best practices also suggest narrowing the range of companies to compare to that
which better reflect your own business and size. Avista's Compensation Committee compares
market data from a customized group of utilities we call our Proxy Peer Group. The Proxy Peer
Group better represents our Company's business, size and competitive market for talent. By using
publicly disclosed data from proxy statements, Form 8-Ks, and Form 4s it allows the Company to
maintain a consistent peer group without being restricted by private survey participation which
varies year to year. The Committee uses companies from the S&P 400 Utilities Index in the Proxy
Peer Group. The median revenues and market capitalization of the Proxy Peer Group run between
$1.9 billion and$4.6 billion,respectively. The data is not adjusted to reflect the differences in size
because the Committee generally targets overall compensation within+/- 15%of the median of the
peer group.
As mentioned above, the Committee also uses the Willis Towers Watson Energy Services survey
as a secondary resource for the top 5 but a primary resource for the other officers' compensation.
The survey provides additional compensation data on comparable diversified energy companies
with revenues between$1 billion and$3 billion. The advantage of using a survey is that it provides
competitive data for all of our executive officer positions. The Compensation Committee uses all
of these sources of data to help it make informed decisions about market compensation practices.
The Compensation Committee periodically will have the consultant prepare a special report on
best pay practices for executive officers.
Non-Bargaining Employee Group
The executive officers of the Company in collaboration with management make all compensation
decisions related to the level of cash compensation and equity awards for the non-bargaining
employee population. Our HR staff conducts studies and research related to best pay practices.
Each year Avista staff conducts benchmark and pay practice studies for the non-bargaining
employee group. The studies typically include base salaries, short-term cash incentives and
long-term incentives. The Company believes it is important to provide a compensation structure
that is competitive with compensation paid to comparable positions of companies within the
energy/utility industry as well as regional and local areas in which we compete for talent. By
keeping an eye on the market we ensure the Company attracts and retains quality employees in key
positions to run the business efficiently and within reasonable costs.
The benchmarking process for the non-bargaining employee group is different from the officer
group in that we do not have a specific Peer Group for the entire non-bargaining employee group.
Our definition of market is the organizations in which we compete for labor. For example,we may
use a national utility survey to benchmark an electrical engineer or a local general industry survey
for an administrative assistant position because that is the labor market in which we compete for
talent. Outlined below are the types of labor market competitors we compare ourselves to for the
following job groups.
7National
agement Administrative/ Technical Support
Professional
• ral General General General
Energy/Utility/Utili Energy/UtilityEnergy/Utility
-• . . National Regional Local
nal Re Tonal Local
3 billion All sizes All sizes All sizes
zes
And relative to our competitor group, we monitor market rate data as follows:
X .
.7ensatio7n (Compensation
• .
• Base ase Salary Base Salary Base Salary
Totalotal Total Total
Com Compensation Compensation
. . Median (50th Median Median Median
percentile) 75th percentile 75th percentile 75th percentile
75th percentile
The surveys we select support our philosophy by reporting data in the categories described above.
Outlined below is a list of salary surveys we have participated in over the years as well as their
general focus.
Utility Nation-wide Exec, Mgmt, Prof, Base salary, incentives,
Natural Gas Tech & Craft pay practices
Utility Gas, Nation-wide Exec Base salary, incentives,
Electric & pay practices
Alternative
Utility Gas, Nation-wide Mgmt, Prof, Tech& Base salary, incentives,
Electric & Support pay practices
Alternative
Utility Pacific Mgmt, Prof, Tech& Base salary,pay
Electric Northwest Craft practices
All Pacific Mgmt, Prof, & Tech Base salary, incentives,
: Industries Northwest pay practices
All Spokane & Tech & Support Base salary, incentives,
Industries Kootenai pay practices
Counties
Technology Pacific Mgmt, Prof, Tech& Base salary, incentives,
Northwest Support pay practices
All Pacific Engineering, Base salary, incentives,
Industries Northwest Scientific and Project pay practices
: Management
Technology Nation-wide Mgmt, Prof, Tech& Base salary, incentives,
I If Support pay practices
Utility Gas Nation w Teeh, Craft& Base sala-izy, ineentives,
, . � Q. z
Non and Nation-wide Exec, Mgmt, Prof, & Base salary, incentives,
: Regulated Tech pay practices
Utilities
Non and Nation-wide Mgmt, Prof, Base salary,pay
• Regulated Operations, & practices
Utilities Technical
Our benchmarking process is generally done on an annual basis. It starts with completing
questionnaires for the different surveys then analyzing the data when the results are returned to us.
As part of the analysis Avista matches its internal jobs to the jobs in the survey sources to establish
an Estimated Market Value. We try to match our jobs to the jobs in at least two survey sources
which we believe better represents the competitive labor market. When establishing an Estimated
Market Value we use the 501h percentile or median data to better estimate the "typical"pay for the
job. Avista's compensation philosophy for the non-bargaining employee group is to target
compensation levels within+/- 15% of market median.
Avista has a pay structure with established pay ranges that are divided into two sections. The
market section represents the"market"(+/- 15%) and the midpoint is used for market comparison,
compa-ratio calculations and adjusting the structure. Our pay structure is a lead-lag position
relative to the targeted marketplace. A lead-lag philosophy positions our pay structure midpoints
so they match the market in mid-year(July). Basically our midpoints lead the external market for
the first half of the year and lag the market for the second half. This enables us to keep our actual
pay levels directly competitive with our targeted marketplace for each identified job group.
Each survey has its own effective date for the data collected and since we try to use at least two
survey sources for each job in our benchmarking process,we age date or"trend"the survey data to
one point in time which is July 1. As mentioned above we want to lead-lag the market and this
process allows us to make accurate and consistent market comparisons between the market and
internal average pay.
This benchmarking process is time consuming and complex. In order to simplify the process we
currently use a software product called MarketPay. The software is a modeling and reporting tool
that houses employee and survey data. Each year we import specific employee and job data into
the tool as well as survey source data. This software enables us to match an internal job to the
survey job to determine an Estimated Market Value. Once an Estimated Market Value is
determined we can calculate the ratio of internal pay to market by dividing the actual salary by the
market rate. This helps us determine if our current wages are competitive within the labor markets
we compete in for talent. We also calculate the ratio of actual pay to our own pay structure
midpoints. This compa-ratio calculation helps us to determine how much we should adjust our pay
structure to stay competitive.
The benchmarking process described above is one method we use to help control our payroll
growth and individual pay progress. We also participate in salary planning surveys. These surveys
collect data on salary practices such as actual and projected base salary increase budgets, whether
organizations are awarding pay increases or freezing pay, what is the average pay increase for
different job groups and performance levels, what was the actual and projected pay structure
adjustment, what types of incentive plans are being used, and what other pay practices
organizations are considering. These surveys focus on overall changes in employee compensation
for the calendar year and current projections for the following calendar year. We use these studies
to help us make informed decisions on market compensation practices with regards to
compensation spending and budgeting.
Our merit-increase program is a key vehicle through which non-bargaining employee pay is
adjusted on an annual basis. In order to plan and budget for the following calendar year,we collect
the following data from several surveys and compile it into a spreadsheet.Although we collect and
monitor the different markets (national, regional, local,utility), we target the utility industry since
most of our labor is utility specific.
National National National National
Regional Regional Regional Regional
Energy/Utility Energy/Utility Energy/Utility Energy/Utility
- Local Local
National National National National
' Regional Regional Regional Regional
Energy/Utility Energy/Utility Energy/Utility Energy/Utility
Local Local
Generally, in May of each year, preliminary minimum salary increases are approved for the
following calendar year by the Compensation Committee of the Board of Directors. In November,
salary increases for the following year are finalized and approved by the Board of Directors. The
salary structure adjustment data is reviewed and considered but the actual adjustment is
determined based on the compa-ratio analysis conducted during the benchmarking process
described above.
The processes described above are used to help us control our labor costs and keep them
reasonable for our customers and yet enables us to recruit and retain the labor force we need to run
the business and provide reliable levels of service.
Bargaining Group
The benchmarking process for the bargaining group is again different from the other groups. The
studies are conducted during or before the contract negotiations. They are not done on an annual
basis. The studies typically collect average base rate for lineman from other west-coast utilities
(investor-owned, PUDs, municipalities, Co-ops, etc.) and average increase from other west-coast
IBEW local contracts. All wage rates and increases are negotiated.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 030 TELEPHONE: (509) 495-7658
REQUEST:
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 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.
RESPONSE:
In March 2018, Avista exercised an end of term purchase option as provided in the lease,
effectively purchasing the plane. The Company currently records all costs (excluding the cost of
the hangar, which is discussed further below) in the pooling account, including all depreciation
expense on the plane. The costs associated with each flight are then allocated to specific projects,
as such all plane costs are assigned based on the purpose of the flights.
In addition,during 2018,Avista was notified the leased hangar would no longer be available to the
Company after 2018. Therefore, the Company entered into a land lease and constructed a hangar
that was placed in service in December of 2018. While the land lease is recorded to the pooling
account, the depreciation of the hangar is not, but instead recorded as depreciation expense and
allocated using company allocation methods.
The Company believes it is appropriate to allocate the estimated revenue requirement associated
with owning the plane and hangar to non-utility for the non-utility flights. For this rate case, the
Company estimates the amount to remove from Idaho electric service to be$17,123 and to remove
from Idaho gas service $4,564, for the year ended June 30, 2024. See Company witness Schultz's
Miscellaneous Adjustment 2.08 for calculations showing these amounts to reflect the reallocation
for non-utility.
A summary of the costs on a system basis,Idaho electric basis and Idaho natural gas basis follows:
System
2023 2024
Costs Al I ocated from Pool ingAccount(FERC 184100) Staff PR 030AttachmentA 1,057,275 1,733,828
based on flight time
Costs Recorded in Pool Not Al located Using Mileage Staff_PR_030 Attach ment B 207,912 (588,094)
Depreciation on Hangar(Not included in Pooling Staff PR_030Attachment C 46,402 49,889
Account) —
1,311,589 1,195,622
Page 1 of 2
ID Electric
2023 2024
Costs Allocated from Pooling Account(FERC 184100) Staff PR 030AttachmentA 218,958 296,896
based on fIighttime — —
Costs Recorded in Pool Not Allocated Using Mileage Staff_PR_030Attachment B 45,622 (134,272)
Depreciation on Hangar(Not included in Pooling Staff PR 030Attachment C 10,182 11,391
Account) — —
274,762 174,014
ID Natural Gas
2023 2024
Costs Allocated from Pooling Account(FERC 184100)
Staff_PR_030 Attachment A 64,858 118,782
based onfIighttime
Costs Recorded in Pool Not Allocated Using Mileage Staff_PR_030Attachment B 13,030 (35,600)
Depreciation on Hangar(Not included in Pooling
Staff PR 030AttachmentC 2,908 3,020
Account)
80,795 86,202
Calendar amounts for 2023 and 2024 are include in the tables above. For amounts included for
Idaho electric and natural gas expense per the twelve-months-ended 06.30.2024 historical test
period, see Schultz's workpapers for Miscellaneous Adjustment 2.08.
Page 2 of 2
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Lindsey Thomas
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff- 031 TELEPHONE: (509) 495-7658
REQUEST:
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.
RESPONSE:
Please see the Company's response to Staff_PR_030 for detail of all plane costs for 2023, 2024
and 2025.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/05/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Ian McLelland
TYPE: Production Request DEPARTMENT: Revenue Accounting
REQUEST NO.: Staff-032 TELEPHONE: (509) 495-4868
REQUEST:
Please detail the methodology used to calculating uncollectible debt.
RESPONSE:
Avista Corp. estimates uncollectible debt by first reviewing actual historical write-offs for the
previous 2, 3, 5, and 10 years to identify any trends and estimate the amount of write-off expense
that may occur in the following year. Utilizing these historical write-off amounts,Avista allocates
the estimated expense by month throughout the year to each service and jurisdiction using
historical write-off amounts from prior years.
Each month throughout the year, after the initial estimate of expense has been made, Avista
reviews the aged balances of outstanding accounts receivable(greater than 90 days aged)by credit
code with 0 being the highest risk balances and 3 being the most likely to pay their outstanding
balances.
Avista then applies an estimated write-off percentage to the aged amount outstanding by credit
code. The historical write-off percentages are different for each credit code and vary by
jurisdiction as each jurisdiction and credit code have different historical payment statistics. The
estimated write-off percentages are generally somewhere near the at-risk arrears percentage (90+
days aged / total outstanding accounts receivable) as that is typically the amount of historical
write-offs. Based on the result of this monthly analysis, the bad debt expense amount will be
adjusted up or down.
Even though bad debt expense for the income statement is a function of the above described
analysis,the amount of write-offs that are included in the general rate cases is the actual write-offs,
not necessarily the bad debt expense that was recognized in the income statement. (See Schultz
workpapers for Restating Adjustment 2.02"Uncollectible Expense".)Although over a long period
of time(several years)actual write-offs and bad debt expense should be very close to each other as
Avista bases its bad debt expense on historical write-offs. Also, Avista is required to make an
estimate of bad debt expense in the period of sale occurs or when it becomes clear that a receivable
balance may be uncollectible,whereas actual write-offs can occur several months or a year past the
period of sale. This results in income statement expense and actual write-offs not being a perfect
match. An example uncollectible estimate from December 2024 is included as Staff_PR_032
Attachment A.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kaylene Schultz
REQUESTER: IPUC RESPONDER: Marcus Garbarino
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-033 TELEPHONE: (509) 495-2567
REQUEST:
Please detail the methodology used to calculate working capital. Please also provide any lead-lag
studies used.
RESPONSE:
Working capital represents the funds necessary to cover the lag in time between the collection of
revenues for services rendered, and the necessary outlay of cash by the Company to pay the
expenses of providing those services.
The Company uses the Investor Supplied Working Capital (ISWC) methodology to calculate the
amount of working capital reflected in its actual results of operations. This method is consistent
with that incorporated in the Company's electric and natural gas general rate cases going back to
2015' (AVU-E-15-05 and AVU-G-15-01). The calculations supporting the ISWC amounts are
included in the Schultz workpapers supporting Electric Adjustment (1.03) and Natural Gas
Adjustment(1.03).
Avista does not prepare a lead/lag study for the Company for Idaho. It is a voluminous undertaking
to prepare a Lead Lag Study, therefore preparation of an Idaho specific lead/lag study is not
feasible.
' Minor modifications were made in the Company's electric Case No. AVU-E-19-04 and the methodology has been
consistent since.As discussed in electric Case No. AVU-E-19-04, as a result of the Company's Washington general
rate case(Dockets UE-170485 and UG-170486),the Company agreed to two changes that better reflect the level of
working capital for Avista as follows: 1)reclassified certain interest-bearing accounts to investments and 2)changed
the methodology for allocating certain working capital to non-utility operations. Prior to 2018, the investment in
non-utility property was used to determine the allocation. Beginning in 2018, the updated method uses all non-rate
base investments to determine the allocation. Reflecting these same changes consistently between Idaho and
Washington allows for administrative efficiencies when recording working capital within the Company's
jurisdictional results of operations. This method is consistent with that utilized in the Company's last Idaho electric
and natural gas general rate cases,Case Nos.AVU-E-23-01,and AVU-G-23-01.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Clint Kalich
REQUESTER: IPUC RESPONDER: Clint Kalich
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff-34 TELEPHONE: (509) 495-4532
REQUEST:
Please provide the detailed impacts of the Washington Climate Commitment Act on this case.
RESPONSE:
Please see Avista's response Staff_PR_034C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
Avista did not model any Climate Commitment Act (CCA) costs in its filing. That said, power
supply costs in this filing are likely about$10 million(-14%)lower for Idaho customers than prior
to the enactment of Washington's CCA. Though it is not possible to state this value with absolute
certainty, surplus generation and revenues in this case are greatly elevated relative to values Idaho
customers received prior to passage of Washington's Climate Commitment Act (CCA).
The graphic below details apparent market premiums built into Northwest power markets since
CCA passage using ICE daily index prices for Mid-C power and Malin natural gas. Since the
energy crisis of 2000-01, the implied-market heat rate (IMHR) has never exceeded a value of 13.
Since CCA passed, the IMHR has not been below 15. IMHR provides a good indicator of price
premiums in the market in that it defines the relative value of electricity to natural gas, our thermal
fleet, and surplus sales.
MidC to Malin Annual IMHR
30
CCA
25 Regulation A
24.94
Begins
20 11112023 16.85
15 r�15.00
12.89 12. 15.89
10 It 8.47 10.74 10.04
7.72 9.48
5
2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Rate
Filing
Page 1 of 2
With post-CCA IMHR so high, net surplus sales volumes and revenues are much higher than in
pre-CCA cases. For example, 2023 case surplus sales were 2,404 GWh; surplus sales in this case
are 3,142 GWh, an increase of 31%. While likely under-estimating the actual value to Idaho
customers,an approach to approximate the CCA's impact is calculating its impact on the operating
margins of our Coyote Springs 2 and Lancaster combined-cycle plants. The higher market sales
volumes and IMHR in this case, using these two plants as a proxy for value, would imply a
reduction in net power supply expense of$30.95 million (system). In other words, this estimate
shows net power costs $30.95 million (-14%) lower than they would be absent higher sales
revenues from selling into the CCA-inflated northwest market.
See Staff PR 034C Confidential Attachment A for supporting data.
Page 2 of 2
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Clint Kalich
REQUESTER: IPUC RESPONDER: Clint Kalich
TYPE: Production Request DEPARTMENT: Energy Supply
REQUEST NO.: Staff-34C TELEPHONE: (509) 495-4532
REQUEST:
Please provide the detailed impacts of the Washington Climate Commitment Act on this case.
RESPONSE:
Avista's response to 034C, contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL
information and are filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho
Code.
Avista did not model any Climate Commitment Act (CCA) costs in its filing. That said, power
supply costs in this filing are likely about$10 million(-14%)lower for Idaho customers than prior
to the enactment of Washington's CCA. Though it is not possible to state this value with absolute
certainty, surplus generation and revenues in this case are greatly elevated relative to values Idaho
customers received prior to passage of Washington's Climate Commitment Act (CCA).
The graphic below details apparent market premiums built into Northwest power markets since
CCA passage using ICE daily index prices for Mid-C power and Malin natural gas. Since the
energy crisis of 2000-01, the implied-market heat rate (IMHR) has never exceeded a value of 13.
Since CCA passed, the IMHR has not been below 15. IMHR provides a good indicator of price
premiums in the market in that it defines the relative value of electricity to natural gas, our thermal
fleet, and surplus sales.
MidC to Malin Annual IMHR
SO
CCA
25 Regulation A
24.94
Begins
20 11112023 16.85
15 r�15.00
12.89 12. 15.89
10 8.47 10.74 10.04
7.72 9.48
5
2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Rate
Filing
Page 1 of 2
With post-CCA IMHR so high, net surplus sales volumes and revenues are much higher than in
pre-CCA cases. For example, 2023 case surplus sales were 2,404 GWh; surplus sales in this case
are 3,142 GWh, an increase of 31%. While likely under-estimating the actual value to Idaho
customers,an approach to approximate the CCA's impact is calculating its impact on the operating
margins of our Coyote Springs 2 and Lancaster combined-cycle plants. The higher market sales
volumes and IMHR in this case, using these two plants as a proxy for value, would imply a
reduction in net power supply expense of$30.95 million (system). In other words, this estimate
shows net power costs $30.95 million (-14%) lower than they would be absent higher sales
revenues from selling into the CCA-inflated northwest market.
See Staff PR 034C Confidential Attachment A for supporting data.
Page 2 of 2
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Bob Brandkamp
TYPE: Production Request DEPARTMENT: Risk Management
REQUEST NO.: Staff-PR-035 TELEPHONE: (509) 495- 4924
REQUEST:
Please provide a list of any insurance proceeds received by the Company in 2024. Please include a
narrative of the event initiating the insurance payment.
RESPONSE:
See the table below for total insurance credits received in 2024 and applied as an offset to overall
insurance expense. No other insurance proceeds were received by the Company in 2024.
Avista
Actual Utilities
Date Insurance Type Credit Type (A)/Estimate(E) Gross Al location factor portion 2024portion Comments
Annual continuity
credit deducted from
gross premium at
12/1/2023 Property Oontinuity A $20,031.00 0.794023546 $15,905.09 $14,579.66 ti me of i nvoi ce
Annual continuity
credit deducted from
gross premium at
12/1/2024Property Continuity A $37,065.00 0.79696431 $29,539.48 $2,461.62timeofinvoice
Loss free credit from
London property
1211/20231 Property Loss Free Credit A $71,75.001 0.794023546 $56,991.04 $52,241.79 market
Loss free credit from
London property
12/1/2024 Property Loss Free Credit A $81,722.52 0.79696431 $65,129.93 $5,427.49 market
8/9/2024 Property Loyalty Credit A $8,012.40 0.794023546 $6,362.03 $6,362.03 AEG SLoyalty Credit
Annual continuity
credit deducted from
gross premium at
12/31/2023 Excess C4_ Continuity A $162,902.00 0.8372$136,381.55 $136,381.55 ti me of i nvoi ce.
AB31SLoyalty
8/9/2024 Excess G- Credit A $65,161.00 0.8372 $54,552.79 $54,552.79 AB31 SLoyalty Credit
ASS 2024 portion of AEGS
Continuity Continuity Credit
2/28/2024 D&O Credit A $191,275.00 0.94$179,798.50 $44,949.63 from 3/31/23 renewal
AEGSContinuity
Credit deducted from
gross premium at
3/31/2024 D&O AEGSContinuit A $187,709.00 0.94$176,446.46 $132,334.85 ti me of i nvoice
AE3SLoyalty
8/9/2024 D&O Credit A $75,084.00 0.94 $70,578.96 $70,578.96 AB31 SLoyalty Credit
AEGSContinuity
ASS Credit deducted from
Continuity gross premium at
1/1/2024Workers'Comp Credit A $6,555.00 1 $6,555.00 $6,555.00 ti me of i nvoi ce
AEGISLoyalty
8✓9/2024 Workers'Comp Credit A $2,622.00 1 $2,622.00 $2,622.00 AEGSLoyaltyaedit
AEGSContinuity
At3IS Credit deducted from
Continuity gross premium at
10/17/2023 Ober Credit A $2,700.00 0.982 $2,651.40 $2,106.59 ti me of i nvoi ce
AB31SLoyalty
8/9/2024 Ober Credit A $1,080.00 1 $1,080.00 $1,080.00 AB31 SLoyalty Credit
A1GSContinuity
AEGIS Credit deducted from
Continuity gross premium at
10/17/2024 Ober ICredit I A 1 $22,863.00 0.982 $22,451.47 $4,662.05 timeof invoice
Total Insurance
Credits Applied to
$536,896.02 2024
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 02/27/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Elizabeth Andrews
REQUESTER: IPUC RESPONDER: Bob Brandkamp
TYPE: Production Request DEPARTMENT: Risk Management
REQUEST NO.: Staff-PR-036 TELEPHONE: (509) 495- 4924
REQUEST:
Please provide a list of 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.
RESPONSE:
Please see the list of 2025 and 2026 insurance credits below. These actual or expected insurance
credits have been reflected in the pro forma insurance expense adjustment and levels included in
this case.No other insurance proceeds have been received in 2025, or known to be received at this
time through 2026.
A,Asta Uti I ities2025 Insurance Premium Credits
Auista
Actual Utilities
Date Insurance Type Credit Type (A)/Estimate(E) Gross Allocationfactor portion 2025 portion Comments
Annual continuity
credit deducted from
gross premium at
12/1/2024Property Continuity A $37,065.00 0.79696431 $29,539.481 $27,077.86timeofinvoice
Annual continuity
credit deducted from
gross premium at
12/1/2025Property Continuity E $37,065.00 0.79696431 $29,539.48 $2,461.62timeofinvoice
Loss free credit from
London property
12/1/2025 Property Loss Free Credit E $81,722.52 0.79696431 $65,129.93 $65,129.93 market
Additional London
Loss Free0reditthat
was not processed
withtheinitial batch
totalling$81,722.52.
Addl Loss Free Date of 2025 recei pt
3/1/2025Property Credit from 2024 E $8,400.001 0.79696431 $6,694.501 $6,694.50 is estimated.
Fbsumption of BM
Conti nuity credit that
had been suspended
BMObntinuity in2024.Using2023
305/2025Property Credit E $16,015.01 0.79696431 $12,763.39 $12,763.39 credit as estimate.
AEGSLoyalty
8/9120251 Property Credit E $8,012.40 0.79696431 $6,385.601 $6,385.60 A✓31SLoyaltyCredit
Annual continuity
credit deducted from
gross premium at
ti me of i nwi ce.
Spread over 17
AE3S months as renewal
12/31/2024 Excess CL Continuity A $166,999.001 0.8414$140,512.96 $99,185.62 extended to611/25
BM Conti nuity Credit
reinstated in 2025
B M Continuity after bei ng
3/15/2025 Excess(- Credit E $82,123.60 0.904 $74,239.731 $74,239.73 suspended in 2024.
AMSLoyalty
8/9120256xcessC- Credit E $65,161.00 0.8372 $54,552.79 $54,552.79AMSLoyaltyCredit
AEGIS 2025portion ofAMS
Continuity Loyalty Credit from
2/28/2025 D&O Credit A $187,709.001 0.94$176,446.46 $44,111.62 3/31/24renewal
BMContinuity0redit
reinstated in 2025
BM Continuity after bei ng
3/15r2025 D&O Credit E $17,363.39 1 $17,363.39 $17,363.39 suspended in 2024.
AEGSContinuity
Credit deducted from
gross premium at
3131/2025D&O AMSCbntinui E $187,709.001 0.94$176,446.46 $132,334.85timeofinwice
AE ISLoyalty
8/912M D&O Credit E $75,084.00 0.94 $70,578.961 $70,578.96 AMSLoyalty Credit
AEGIS
Continuity AE3SContinuity
1/1/20251Morkers'Comp Credit A $7,428.00 1 $7,428.00 $7,428.00 Credit
AEGSLoyalty
8/9120251Morkers'Comp Credit E $Z622.00 1 $2,622.00 $2,622.00 AEGSLoyalty Credit
AE31SLoyalty
8/912025 Ober Credit E $1,080.00 1 $1,080.00 $1,080.00 AEGSLoyaltyCredit
AE31SOontinuity
Credit deducted from
gross premium at
ti me of i nwi ce.
AE3S Fbmai nder of credit
Continuity from 10117/24
10/16/2025 Ober Credit A $22,863.00 0.982 $22,451.47 $17,838.15 renewal.
AE ISContinuity
Credit deducted from
gross premium at
AEGS ti me of i nwi ce.
Continuity Portion applied to
10/17/2025 Ober Credit A $22,863.001 0.9821 $22,451.471 $4,674.83 2025.
Total Insurance
Credits Applied to
$646,522.83 2025
Amista Utilities 2026Insurance Premium Credits
A Asta
Actual Utilities
Date Insurance Type Credit Type (A)/Estimate(E) Gross Allocation factor portion 2026portion Comments
Annual continuity
credit deducted from
gross premium at
12J 1/20251 Property Continuity E $37,065.00 0.79696431 $29,539.48 $27,077.86 timeofinwice
Annual continuity
credit deducted from
gross premium at
12/1/2026 Property Continuity E $37,065.00 0.79696431 $29,539.48 $2,461.62 timeofinwice
Loss free credit from
London property
12J 1/2MI Property Loss Free Credit E $81,722.52 0.79696431 $65,129.93 $65,129.93 market
BMContinuity
3/15/2026 Property Credit E $16,015.01 0.796964311 $12,763.39 $12,763.39 BMContinuityCredit
AEGSLoyalty
8/9(2026 Property Credit E $8,012.40 0.79696431 $6,385.60 $6,385.60 AEGSLoyalty Credit
Annual continuity
credit deducted from
gross premium at
timeofinwice.
Spread over 17
AB31S months as renewal
12(31/2024 Excess CL Continuity E $166,999.001 0.8414$140,512.96 $41,327.34 e)tendedto 6/1/26
2026 portion of AEGS
AEGS ContinuityCredit
6/1/2026 Excess GL Continuity E $166,999.00 0.8414$140,512.96 $70,256.48 from 6/1/26 renewal
BMContinuity
3(15/2026 Excess GL Credit E $82,123.60 0.9041 $74,239.73 $74,239.73BMContinuityCredit
AEGSLoyalty
8/9/2026 Excess GL Credit E $65,161.00 0.8372 $54,552.79 $54,552.79 AEG SLoyalty Credit
AB31S 2D26portion ofAB31S
Continuity Loyalty Credit from
2(28(2026 D&O Credit E $187,709.00 0.94$176,446.46 $44,111.62 3/31/25renewal
BMContinuity
3/15/2026 D&O Credit E $17,363.39 1 $17,363.39 $17,363.39 BMContinuityCredit
AEGSCbntinuity
Credit deducted from
gross premium at
3/31/2026 D&O AB3SContinuit E $187,709.00 0.94$176,446.461 $132,334.85 timeofinwice
AEGSLoyalty
8/9/2026 D&O Credit E $75,084.00 0.94 $70,578.96 $70,578.96 AM SLoyalty Credit
AB31S
Continuity AEGSContinuity
1/1/2026 Workers'Comp Credit E $7,428.00 1 $7,428.00 $7,428.00 Credit
AEGISLoyalty
8/9/2026 Workers'Comp Credit E $2,622.00 1 $2,622.00 $2,622.00 AEGSLoyaltyCredit
AEGSLoyalty
8/9/2026 Caber Credit E $1,080.00 1 $1,080.00 $1,080.00 AEGSLoyalty Credit
AJ GSContinuity
Credit deducted from
gross premium at
timeofinwice.
AB31S F bmai nder of credit
Continuity from 10/17/25
10/16/2026 Caber Credit E $22,863.001 0.982 $22,451.47 $17,838.15 renewal.
AB31SContinuity
Credit deducted from
gross premium at
AEGIS timeof invoice.
Continuity Portion applied to
10(17/2026 Caber 10redit E $22,863.00 0.9821 $22,451.471 $4,674.83 2026.
Total Insurance
Credits Applied to
$652,226.53 2026
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Tia Benjamin
REQUESTER: IPUC RESPONDER: Tia Benjamin
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff 037 TELEPHONE: (509) 495-225
REQUEST:
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.
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.
RESPONSE:
Please see Staff_PR_037 Attachment A for a schedule of actual transfers to plant for the period
July 2022 through June 2024 on a system, Idaho electric and Idaho natural gas basis. The
Company does not include "partially completed" plant in it's filing but rather includes capital
investment on a transfers to plant basis. This schedule also includes project details such as the
Business Case name, Expenditure Request (ER)1 number and description, Budget Item (BI)
number and description, service and jurisdiction, identification of project or program and
functional area. As outlined in Ms. Benjamin's testimony, additional description of each business
case can be found in the testimony and attached exhibits of Company witness's Mr. Malensky for
Wildfire Resiliency Program, Mr. Howell for Generation and Environmental Projects/Programs,
'Please refer to
Mr. Manuel for Enterprise Technology related Projects/Programs and Mr. DiLuciano for Electric
and Natural Gas distribution, Transmission General Services Projects/Programs.2
As discussed by Company witness Mr. Christie, the Company plans annual capital investment
through the Capital Planning Group (CPG) on a spend basis. As previously mentioned, the
Company only includes capital investment after it transfers to plant in revenue requirement.
However, to be responsive to the request for budget and capital planning process information, the
Company is providing in Staff-PR-037 Attachment B the following documents provided on a
spend basis:
Staff-PR-037 Attachment B
• 2022 CPG approved capital spend budget
• 2022 CPG approval of in-year capital funding changes
• 2023 CPG approved capital spend budget
• 2023 CPG approval of in-year capital funding changes
• 2024 CPG approved capital spend budget
• 2024 CPG approval of in-year capital funding changes
For those business cases that a business case was not provided in Avista's filed testimony because
there was not planned transfers to plant during the pro forma period July 2024 through August
2027, but are identified in Attachment A as having actual transfers to plant allocated to Idaho
during July 2022 through June 2024, please see Staff_PR_037 Attachment C with the business
case. Additionally,within Staff_PR_037 Attachment A,we have identified for each business case,
the direct testimony reference(Exh., Schedule)or Staff_PR_037 Attachment C where the business
case justification narrative document has been provided.
The Company uses both internal and contracted labor for capital work. However, there is not a
specific "field" that can be pulled to present this data making it overly burdensome to locate and
present on all capital investment. However, the Company is willing to provide additional
information on the use of contractors if a specific one, or a specific subset of projects is selected.
2 Malensky,Exh.Exhibit 11,Schedules 1-8,Howell Exh.7,Schedule 1,Manuel Exh. 12,Schedule 1,DiLuciano Exh.
10, Schedule 3
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Tia Benjamin
REQUESTER: IPUC RESPONDER: Tia Benjamin
TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-038 TELEPHONE: (509) 495-225
REQUEST:
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;
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.
RESPONSE:
Please see Company witness Ms. Benjamin's workpapers, 1.04 - 3.08-3.09 - 26.01-26.02 PF -
CAPITAL ADDITIONS, TTP Detail tab for a sortable spreadsheet listing all capital transfers to
plant the Company expects to place into service between July 2024 and August 2027.
The Company is currently preparing end of year 2024 actuals data to update Ms. Benjamin's
workpapers 1.04 - 3.08-3.09 - 26.01-26.02 PF - CAPITAL ADDITIONS, including actual
transfers to plant for July 2024 through January 2025 and updated expectations through December
2025 and will file an updated model once able to be completed.
Please also see the Company's response to Staff PR 037 for more specific detailed information.
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED: 03/06/2025
CASE NO: AVU-E-25-01 /AVU-G-25-01 WITNESS: Kevin Christie
REQUESTER: IPUC RESPONDER: Adam Munson
TYPE: Production Request DEPARTMENT: Finance
REQUEST NO.: Staff-040 TELEPHONE: (509) 495-2471
REQUEST:
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.
RESPONSE:
When Avista makes any capital investment, there is an obligation to demonstrate that the overall
need, evaluations of alternatives, and planned implementation timing are prudent and in the
customer's best interests. Whether the investment touches the customer directly, such as customer
service or metering systems, or indirectly, such as improving the capability and efficiency of
employees and internal work processes, each dollar invested ultimately supports one purpose: to
provide customers with safe, reliable, and cost-effective energy services that meet their
expectations for quality of service and value. In Mr. Christie's direct testimony (see pages 16-28),
he discusses the six drivers of investment at pages 18-19:
1. To respond to customer requests for new service or service enhancements;
2. To meet regulatory and other mandatory obligations;
3. To replace equipment that is damaged or fails, and support field operations;
4. To replace infrastructure at the end of its useful life based on asset condition;
5. To meet our customers' expectations for quality and reliability of service; and
6. To address system performance and capacity issues.
When evaluating investments, Avista applies a four-part prudency standard:
1. Demonstrated proof of need for a project.
2. Evidence that reasonable alternatives were considered that allowed objectively
selecting the best, most cost-effective alternative.
3. Company awareness of the need for and approval of the project, meaning that
affected employees have been made aware of and are in favor of the project and are
kept informed of any material changes.
4. Documentation is kept throughout the project to ensure that future readers can
understand and reach the same conclusions about key decisions based on the
available information..
Projects are developed through various means, including planning studies, engineering and asset
management analyses, as scheduled upgrades or need for replacements are identified or with
observations made by expert personnel. These projects undergo internal review by multiple
stakeholders within the business units and through a formal review process at the appropriate
business area level, keeping the prudency standard referenced above in mind.
The capital projects are identified in the lower-left portion of Illustration No. 1 below, labeled
"Business Unit Needs," and prioritized within each department. This prioritization occurs with the
Page 1 of 3
knowledge of the continuing constraint on the capital spend level for the Company. At the same
time, the leadership of each department informs senior management of both the near-term and
long-term needs that are being delayed.For the prioritized projects,Business Cases' are developed
for each of the Capital Requests that go to the Capital Planning Group(CPG)2(as illustrated in the
diagram).
The Business Case for each prioritized project serves as the documentation of the justification of
the investment and addresses explicitly the proposed solution to the business problem, why it is
the best and/or least cost alternative and why the investment is considered a prudent investment
(see attached Business Case Justification Template, specifically Section 2, provided as
Staff_PR_040 Attachment A). For the business cases provided in this case in support of our pro
forma capital additions (in addition to other provided support),please see:
• Howell Exhibit 7, Schedule 1 —Pages 2—271
• DiLuciano Exhibit 10, Schedule 3 —Pages 3 —535
• Malensky Exhibit 11, Schedule 8—Pages 1 — 12
• Manuel Exhibit 12, Schedule 1 —Pages 2—351
With regards to management, execution, and completion of the capital projects, as part of the
standard business case templates, there is a section for each business case to identify the "Monitor
and Control" of the business case, see Staff_PR_040 Attachment A, Section 2.8. This section
provides an overview of the governance processes and people that will provide oversight for each
business case, including how decision-making, prioritization, and change requests will be
documented and monitored.
Illustration No. 1 - Identification and Prioritization Process
Board Finance Committee
Senior Management
Ca7RequestsCa ital Plannin GrouB P g p
Overall Infrastructure Priority and Capital
Allocation
Prioritization
Business Unit 1+
Needs
1 A Business Case is a summary document that defines the business problem addressed by a project or program,along
with a proposal and recommended solution. The Business Case explains why the work is necessary, and the risks
associated with not making the investment, as well as the alternatives considered, the selected alternative and the
timeline associated with the project.
z Effective January 1,2025,the Capital Planning Group was renamed Business Performance team.
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The Company procures its materials and services in a disciplined manner that is designed to obtain
the maximum value for each dollar of expenditure. See the Company's Supply Chain Procedures
attached as Staff_PR_040 Attachment B. Specifically,please see "Competitive Bidding," on page
5 of Attachment B and, "Contractor Selection," on page 7, which has the lowest overall cost as a
key factor for supplier selection. The least cost might ultimately mean the lowest life-cycle cost,
not necessarily the lowest upfront cost. Lowest-cost items,upfront,may ultimately lead to a higher
life cycle cost due to future O&M costs to keep an item or project operational.
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