20250314Staff 91-107 to AVU.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL RECEIVED
MARCH 14, 2025
IDAHO PUBLIC UTILITIES COMMISSION IDAHO PUBLIC
PO BOX 83720 UTILITIES COMMISSION
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AVISTA )
CORPORATION'S APPLICATION FOR THE ) CASE NOS. AVU-E-25-01; AVU-
AUTHORITY TO INCREASE ITS RATE AND ) G-25-01
CHARGES FOR ELECTRIC AND NATURAL )
GAS SERVICE TO ELECTRIC AND )
NATURAL GAS CUSTOMERS IN THE ) FOURTH PRODUCTION
STATE OF IDAHO ) REQUEST OF THE
COMMISSION STAFF
TO AVISTA CORPORATION
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Avista Corporation("Company")provide
the following documents and information as soon as possible,but no later than FRIDAY,
APRIL 4, 2025.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 1 MARCH 14, 2025

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 91: Please provide calculations of all regulatory deferral balances "as
of 8/31/25"included in Schultz workpaper"3.11 Reg Deferral Amortizations", tabs "Accts 182
& 254" and"Accts 186353-Williams"). This should include details of every transaction
including date, amount, description, and any other useful information.
REQUEST NO. 92: Please explain if economic damages caused by other parties in the
Williams outage of 2023 were explored. Please provide information regarding the current status
or final results of any legal proceedings.
REQUEST NO. 93: Please provide a calculation of annual depreciation expense and
accumulated depreciation for the most current month available. Please list the total system
amounts, Idaho allocated total, and Idaho allocation percentages, and any other useful
information. Please supplement this response as additional month-end balances become
available.
REQUEST NO. 94: Please provide a 13-month average of monthly averages rate base
calculation through the most current month available. Please distinguish between system
amounts and Idaho allocated amounts. Please supplement this response as additional month-end
balances become available.
REQUEST NO. 95: Please provide a list of land owned in which intended projects on
the land have not been completely finished. For each instance, please provide the date the land
was purchased, amount of the purchased land, Idaho allocated amount, Idaho allocated
percentage, description of the intended use, if the Company has included the land in the current
case, and any other useful information.
REQUEST NO. 96: Please respond to the following regarding Confidential Workpaper
"Term Deals.xlsx".
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 2 MARCH 14, 2025

a. Please explain what the positive numbers represent in Column I and Column K on
Tab "to AURORA".
b. Please explain what negative numbers represent in Column I and Column K on Tab
"to AURORA".
c. Please explain why Cell L9 is zero on Tab "to AURORA".
d. Please explain how the values in Column L on Tab "to—AURORA" are determined.
e. Please explain what "Lancaster heat rate transaction"means on Tab
"Power Physical".
f. Please explain what "[s]old power and bought gas at $XX"means on Tab
"to AURORA".
g. Page 14 of Mr. Kalich's Direct Testimony states that"because these are financial
hedges, they are not modeled within Aurora." However, Tab "to—AURORA" shows
financial deals are modeled in Aurora. Please reconcile this contradiction.
REQUEST NO. 97: Please provide evidence showing the hedging deals included in this
case have followed the Company's hedging policy.
REQUEST NO. 98: Please respond to the following regarding Clearwater Paper:
a. Please explain how Clearwater Paper's energy costs are treated in Net Power Costs
and justify the treatment;
b. Please explain how Clearwater Paper's transmission costs are treated in Net Power
Costs and justify the treatment; and
c. Please explain how Clearwater Paper's Renewable Energy Credits revenues are
treated in the Net Power Costs and justify the treatment.
REQUEST NO. 99: Please explain whether transmission revenues are trued-up based
on the actual Open Access Transmission Tariff rates in the Power Cost Adjustment.
REQUEST NO. 100: Order No. 36189 encouraged Avista to meet with Staff before the
Company's next general rate case (this case)to explore the possible development of a tariff
schedule for the recovery of use-of-facilities related costs. The Company and the Staff met last
year to discuss this topic. Subsequently, the Company indicated that it was planning on
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 3 MARCH 14, 2025

providing a"Q and A"within the next general rate case (this case) to address Order No. 36189.
Please explain where the "Q and A" information is located in this case. If not provided,please
provide it in response to this request.
REQUEST NO. 101: Page 19 of Mr. Kalich's Direct Testimony states that after the
Model dispatches Colstrip, the coal supply contract prices are applied to that dispatch. Please
respond to the following:
a. Please list the coal supply contract prices of Colstrip assumed in the Model and
explain how these prices were determined.
b. Please list the contract prices calculated based on the dispatch and explain how these
prices were determined.
c. Do the first set of contract prices assumed in the Model before the dispatch and the
second set of contract prices calculated based on the dispatch converge?
d. If so,please explain how the Company makes sure they converge.
e. If they diverge,please explain the difference between the two sets of contract prices
and quantify the impacts of the difference on Net Power Costs.
REQUEST NO. 102: Please respond to the following regarding Risk Management
Policy:
a. Please explain whether the Company proposes a new Risk Management Policy in this
case.
b. If so,please explain where it is located in the Application.
c. If not, please provide a copy of the current Risk Management Policy and whether it
was approved by the Commission.
d. Please explain the difference between the old and new versions.
e. Please explain whether the financial hedging deals modeled in Aurora are based on
the newly proposed Risk Management Policy or the current Risk Management Policy.
REQUEST NO. 103: Please respond to the following regarding Tab "Conf Fuel Costs"
of Confidential Exhibit No. 8:
a. Please list all the expenses in Net Power Cost determined by Tab "Conf Fuel Costs".
b. Please describe the overall methodology used on Tab "Conf Fuel Costs".
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 4 MARCH 14, 2025

c. Please list major steps in the methodology.
d. Please explain where on Tab "Conf Fuel Costs" each step is reflected.
REQUEST NO. 104: Please respond to the following regarding Schedule 2 of
Confidential Exhibit No. 8.
a. Please define "WPW Ancillary Services"in Line 16 and explain why its value is zero
in the Pro Forma period.
b. Please define "Non-Mon. Accruals" in Line 17 and explain why its value is zero in
the Pro Forma period.
c. Please define "Other Resource Costs" in Line 22 and explain why its value is zero in
the Pro Forma period.
d. Please define "Natural Gas Fuel Purchases" in Line 23 and explain why its value is
zero in the Pro Forma period. Also,please explain the difference between this item
and fuel expenses in Account 547.
e. Please define "Merchant Ancillary Services" in Line 67 and explain why its value is
zero in the Pro Forma period.
f. Please define "Non-WA EIA REC" in Line 71 and explain why its value is zero in the
Pro Forma period.
g. Please define "Natural Gas Liquids" in Line 72 and explain major steps used to
calculate each year's credits in File "Natural Gas Liquids.xlsx".
h. Please define "Surplus AECO to Malin Transportation" in Line 73 and explain the
rationale behind the formula that calculates its values.
REQUEST NO. 105: Please respond to the following regarding Tab "Conf Colstrip
Fuel Model" in Confidential Exhibit No. 8.
a. Please define "Base Price", "Tier Price", "Incremental Fuel Price", "Invoice
Price/ton", and"Incremental Fuel Price (mmBTU)".
b. Please explain the relationship between these items.
REQUEST NO. 106: Please refer to the Direct Testimony of Joseph D. Miller. On page
27, lines 2-3, Mr. Miller states "The Company is not proposing to change the total revenue
collected for Schedule I I 1 in either 2025 or 2026." Please explain how total revenue collected
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 5 MARCH 14, 2025

for Schedule I I I in 2025 does not change under the Company's proposal when compared to
Miller's Exhibit No. 16, Schedule 6, page 1, line No. 2 that shows an increase of$1,745,000?
REQUEST NO. 107: For Schedule No. 1 Residential Service, please provide a table
that displays the number of customers during the test year whose average monthly usage in kWh
falls within each of the 100 kWh increments starting at 0-100 kWh and ending at the highest
monthly user.
DATED at Boise, Idaho, this 141h day of March 2025.
Adam Triplett
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\AVU-E-25-01;AVU-G-25-01 PR#4.docx
FOURTH PRODUCTION REQUEST
TO AVISTA CORPORATION 6 MARCH 14, 2025

CERTIFICATE OF SERVICE
. 2t�
I HEREBY CERTIFY THAT 1 HAVE THIS DAY OF MARCH 2O25,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION , IN CASE NO. AVU-E-25-01/
AVU-G-25-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP & CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail: patrick ehrbar(a avistacorp.com E-mail: david meyrgavistacorp.com
avistadocketsgavistacorp.com
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 6070 HILL ROAD
515 N 27TH ST BOISE ID 83703
BOISE ID 83702 E-mail: dreadingkmindspring.com
E-mail: peter richardsonadams.com
ELECTRONIC ONLY Andrew P. Moratzka
carol haugengclearwaterpaper.com Eden A. Faure
Jamie mcdonaldgclearwaterpaper.com Stoel Rives LLP
33 South 6th Street
Minneapolis, MN 55402
E-MAIL: andrew moratzkagstoel.com
eden.fauregstoel.com
Jennifer S. Palmer
Stoel Rives LLP
101 S. Capitol Blvd., Ste. 1900
Boise, ID 83702
E-MAIL: jenny palmerga stoel.com
PATRICIA JORDAN, ETARY
CERTIFICATE OF SERVICE