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HomeMy WebLinkAbout20190625Avista to Staff 1-35.pdfAvista Corp. 1411 East Mission P.O.Box3727 Spokane. Washington 99220-0500 Telephone 509-489-0500TollFree 800-727-9170 ldaho Public Utilities Commission Office ol the Secretary RECEIVED iuN 2 5 2019 Aftinsrfr Corp. Boisc, ldaho June25,2019 Idaho Public Utilities Commission 472W. Washington St. Boise, ID 83702-0074 Attn: Edward Jewell Deputy Attorney General Re: Production Request of the Commission Staff in Case Nos. AVU-E-19-04 Dear Mr. Jewell, Enclosed are Avista's responses to IPUC Staffs production requests in the above referenced dockets. Included in this mailing are the original and two paper copies of Avista's responses to production requests: Staff No. 4, 5, 8, ll,12, 19r23,25r27-30, and 33. Also enclosed on three separate CD's are copies of Avista's responses to the production requests. The electronic versions of the responses were emailed on 06125119. Also included both on paper and on a separate CD are Avista's CONFIDENTIAL responses to PR 012C, 019C, 025C, 030C & 033C. These responses contain TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and is separately filed under IDAPA 31.01.01, Rule 067 and233, and Section 9-340D, Idaho Code. It is being provided under a sealed separate envelope, marked CONFIDENTIAL. Ifthere are any questions regarding the enclosed information, please contact Paul Kimball at (509) 495-4584 or via e-mail at paul.kimball@avistacorp.com. Sincerely, -/a -zl- Paul Kimball Manager of Compliance & Discovery Enclosures CC (Email)IPUC (Hanian) Idaho Forest Group (Miller, Williams, Crowley) AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JUzuSDICTION CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-004 DATE PREPARED: 0612512019WITNESS: Elizabeth Andrews RESPONDER: Violet Makhanov DEPARTMENT: Corporate Accounting TELEPHONE: (509) 49s-2883 REQUEST: Please provide the total amount that the Company spent on the following activities for 2018, and show how the Company allocated the amounts between its Avista Utilities operating division and the rest of the Company and its subsidiaries: a. Internal auditing expenses; b. The Company's annual report; c. Deloitte; d. Rating agencies; e. All software or information system-related issues; f. Board of Directors compensation, travel expenses, and meeting expens{ 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; and k. All other allocated expenses. RESPONSE: See Staff PR 004 Attachment A. Gk;ot lrFl T\) C)cn lTl -re-rn5(f (Jto 4F_lfrr I r l-a. ()* Lr::gF (,?() gs REQUEST NO. 4: Please provide the total amounts spent on the following activifies during 20t 6 and show how the amounts were allocated between Avista Utilities and Avista Corp and its subsidiaries: a. Intemal auditing expenses (by employees and consultants); O&M Utilitv O&M Non-Utiliry / Subsidiary Labor 637,999 7,750 Employee Expenses 21,725 Training 1,773Other 3,833 Deloitte Consulting 1,896,581 Total$2,561,911$7,750 b. Avista Corporation's annual report; c. Deloitte & Touche and Deloitte Consulting; Refer to (a.) d. Rating agencies; O&M Utility O&M Non-Utilitv / Subsidiarv Moody 110,000 S&P Total s 200,000 s e. All software or information system-related items; o&MUtilitv Contractor $ 4,286,844 Hardware/Software $ 8,996,945 Labor I 7,145,254 TelecomAletwork $ 3,140,185 Hosting Services $ 3,954,602 PrinterToner S 222,839 Other $ 776,535 Rents $ 319,227 i. Insurance coverage; Property Insurance O&M Non-Utility / Subsidiarv $ $ $ s 12,4s3 82,400 106,813 7,027 42,915 Training $ 45,909 Total $28,888,339 $ 251,608 f Board ofDirectors compensation, travel expenses, meeting expenses; (See Andrews workpepers section "2.12" Miscellaneous RestatiDg adj) g. Corporate or chartered aircraft; (Refer to Request No. 34) h. Travel and training for Avista Utilities executives that are also Avista Corporation executives; O&M Utilitv O&M Non-Utiliw / Subsidiarv Total $ 3,802 s O&M Utilitv O&M Non-Utility i Subsidiarv 1,462,798 361,060 Insurance j. Overhead items including utilities, property taxes, security services, and other corporate headquarters expenses*; O&M Utilitv O&M Non-Utilitv / Subsidiar.v Janitorial Services 269,766 Labor 538,790 Lease Expense 75 Materials & Equipment 181,353 Other 34,712 37,413 Professional Services 333,340 Rental Expense 4,383 Security Services 253,217 Utilities 810,375 Total $2,426,011 $ 37,413 rcharges associated with the Mission campus only k. All other allocated expenses; Time & expenses are directly assigned, there will be no other allocated expenses. StaflPR_0O4 Attachment A.XLSX Page I of I AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-005 DATE PREPARED: 0612512019WITNESS: Elizabeth Andrews RESPONDER: Jaime Majure DEPARTMENT: Regulatory Affairs TELEPHONE: (s09) 495-7839 REQUEST: Please provide a copy of all regulatory orders relating to Avista Utilities or the Company and its subsidiaries issued by state agencies in Oregon, Washington, Alaska, or the Federal Energy Regulatory Commission (FERC) in20l7 through 2019 to date. RESPONSE: See Staff AR_005 Attachment A for the State orders. See Staff AR_005 Attachment B for the FERC orders. Due to the voluminous nature of the attachments, they are being provided in electronic format only AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO.: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-008 DATE PREPARED: 0612512019WITNESS: Mark Thies RESPONDER: Laura Vickers DEPARTMENT: Finance TELEPHONE: (509) 49s-2904 REQUEST: Please provide a matrix identifuing the major capital expenditure approval levels that includes the dollar level of authorization by employee title, division, and company. Please include within your response the dollar level at which the individual capital expenditures require approval by the Board of Directors. RESPONSE: Please refer to the Infrastructure Plan in Thies testimony for additional information regarding Avista's capital planning process. The Capital Planning Group (CPG), comprised of nine director- level employees from across the organization, is responsible for prioritizing capital expenditures, allocating funds and ultimately developing a recommended five-year capital plan. This five-year capital plan is discussed in detail with the Officer group and once agreement regarding funding is reached it is finalized for submittal to the Finance Committee of the Board of Directors (FC). Through this process the Officers are approving all funding through approval of the overall plan. The FC reviews the plan and also approves funding of the individual projects and programs by approval of the overall plan for the first year of the five year plan. The Officers have delegated the CPG authority to make reallocations throughout the year to accommodate revisions and new projects to the extent that the total approved capital budget is not exceeded. Any new projects over $10 million that were not part of the original approved plan need to be approved by the FC. Page I of I AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO.: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-0 1 I DATE PREPARED WITNESS: RESPONDER: DEPARTMENT: TELEPHONE: EMAIL: 0612012019 Elizabeth Andrews Joel Anderson State & Federal Regulation (s09) 49s-281 l j oel. anderson@avistacorp.com REQUEST: Please provide a list of "out-of-period adjustments" and "extraordinary items" for the years 2017-2019 to date. RESPONSE: The Company believes there are no extraordinary items for years 2017 through2019 year to date, which includes the test period of twelve months ended December 31,2018. Each month, as the Results of Operations reports are prepared, the Company reviews unusual fluctuations in revenues and expenses. Certain prior period costs are removed at that time (primarily tax return true-ups for prior years). The Company is in the process of reviewing all non-standard journal entries for the period 2017-2019 to date, and will supplement this response at the conclusion of that review. Page I of I AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JUzuSDICTION: CASE NO.: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-012 DATE PREPARED: 0612412019WITNESS: Elizabeth Andrews RESPONDER: Joel Anderson DEPARTMENT: State & Federal Regulation TELEPHONE: (509) 495-2811EMAIL: joel.anderson@avistacorp.com REQUEST: Please provide a schedule showing injuries and damages claims over $2,000 for the years 2016-2018. Please include within your response the description of each item, the amount for each item, and the account charged. 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_0I2C Confidential Attachment A for the requested information. Page I of I AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JUzuSDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-0 1 9 DATE PREPARED: 06125120t9WITNESS: Mark Thies RESPONDER: Laura Vickers DEPARTMENT: Finance TELEPHONE: (s09) 495-2904 REQUEST: Please provide copies of the monthly, quarterly, and annual comparison of operating and capital budget to actuals expenditures for 2016-2019 to date. Please include within your response a narrative explanation for budget variations. This should include, but not be limited to, written operating and capital budget variance reports and explanations used by Company officers and managers to monitor and control budgets under their responsibility. Please supplement your response as additional information becomes available throughout 2019. RESPONSE: TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public viewandisseparatelyfiledunderIDAPA3l.0l.0l,Rule06T and233,andSection9-340D,Idaho Code, and pursuant to the Protective Agreement Please see Staff AR_019C Confidential Attachment A, a folder that contains the requested information by year and by month, for capital expenditures actual to budget comparisons by expenditure request (ER) and operating expenses actual to budget comparisons with variance explanations by organization code (department). Due to the voluminous nature of the attachment, it is being provided in electronic format only. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff - 023 DATE PREPARED: 0612412019WITNESS: Mark Thies RESPONDER: Ian Mclelland DEPARTMENT: Corporate Accounting TELEPHONE: (509) 495-4868 REQUEST: Please provide a list of all leased items in 2017,2018, and2019 to date. Please separate capital leases from operating leases and show the dates, terms, amounts, and accounts used for each lease. RESPONSE: Please see Staff PR_023 Attachment A for a list of all leased items in 2017,2018 and2019 year-to-date. i i iia iE :EEE ii$$$i r *iEEiiE i E 6g EgiE" + i"-F'tE rfi * I B- R4F;ia gEe'# A;g 6-a 6 o TP{€ 5 -6id!,:fBdrA!'-q99 Boo3PAdaF a a. 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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: TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and233, and Section 9-340D, Idaho Code, and pursuant to the Protective Agreement Please see Staff PR_025C Confidential Attachment A for total compensation for executive officers for 2015-2018. 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 Sta[PR_026 for additional information on incentive compensation. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-027 DATE PREPARED: WITNESS: RESPONDER: DEPARTMENT: TELEPHONE: 06125120t9 Elizabeth Andrews Annette Brandon State & Federal Regulation (s09) 49s-4324 REQUEST: Please provide the quantifiable savings from any cosVworkforce reduction programs during the past five years. Please provide any additional workforce reduction programs planned for 20t8-2019. RESPONSE: The last quantifiable workforce reduction was completed in 2012 wrth the Company's Voluntary Severance Incentive Plan (VSIP). Since VSIP, no workforce reduction programs have been made and none are currently anticipated. However, in an effort to mitigate the annual growth in operating expenses, Avista has ongoing hiring restrictions, which requires approval by the Chairman/President/CEO, the President of the Utility, the Chief Financial Officer, and the Sr. VP for Human Resources for all replacement or new hire positions. In addition to base wages, the Company also provides variable pay (in the form of pay-at-risk incentive compensation) and a comprehensive benefit package. Each component is carefully considered within the overall package in order to provide total compensation, which will be cost-effective for the Company, remain attractive to employees, and is an effective recruitment tool. In order to manage costs for total compensation, adjustments have been made to the benefits portion of compensation. Please see the Company's response to StafLPR_028 for additional information regarding benefits and retirement plans. See also Staff_PR_033 for an explanation of the basis for setting employee compensation by employee group. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-028 DATE PREPARED WITNESS: RESPONDER: DEPARTMENT: TELEPHONE: 0612512019 Elizabeth Andrews/Mark Thies Annette Brandon State & Federal Regulation (s09) 49s-4324 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 (hires after 01.01.14 - 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.l 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-based24l7 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 $250,000 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. I 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, effective January l, 2074 the Company made the following changes to the medical plan offered to employees: For non-union employees hired or rehired on or after January I,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. a a Beginning January 1,2020, the method for calculating health insurance premiums for the following employee groups will change: non-union retirees, Local Union 659, hired or rehired after April 1,2014 under age 65, and active non-union 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 l, 2020. Finally, as of 2017, Avista offers a self-insured High Deductible Health Plan ("HDHP") in addition to the current self-insured plan. 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. Over time we expect this plan to result in lower overall medical costs to the Company. The level of cost savings is dependent upon, among other things, the number of employees that choose this plan, and the level of utilization of medical care for those employees (i.e., the overall medical expense to the Company under the High Deductible plan versus the old plan for those particular employees and their families). The level of cost savings from the HDHP is expected to be minimal initially, and will be unknown for the longer-term until we have actual experience under the plan. 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, 20l42,the Company's defined benefit is closed to all non-union. All actively employed non-union employees that were hired prior to January 1,2014, and were covered under the defined benefit pension plan at that time, will continue accruing benefits as originally specified in the plan. A defined contribution a0lft) plan replaced the defined benefit pension plan for all non-union employees hired or rehired on or after January 1, 2014. 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-union retirees under the defined benefit pension plan to provide non-union 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, a 2 Changes were applicable to Local Union 659 (Southeast Oregon) effective Aprill,2014 Miscellaneous Other Benefits The Company also offers these miscellaneous other Miscellaneous Benefits. Overall, costs represented by these benefits represent less than 2o/o of overall benefit costs: o Short and Long Term Disability o 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 l5Yo 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. Avista regularly participates in a comprehensive benefit study, BENEVAL, conducted by 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_033 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_025 and StaflPR_026 for additional information on incentive and base pay. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-029 DATE PREPARED: WITNESS: RESPONDER: DEPARTMENT: TELEPHONE: 06t2s/2019 Elizabeth Andrews Annette Brandon State & Federal Regulation (s09) 49s-4324 REQUEST: Please provide the amount of Supplemental Executive Retirement Plan expense, if any, which is included in the test year. RESPONSE: No Supplemental Executive Retirement Plan expenses have been included in the test year AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-030 DATE PREPARED: WITNESS: RESPONDER: DEPARTMENT: TELEPHONE: 0612s120t9 Mark Thies Kaylene Schultz State & Federal Regulation (s}e) 4es-2482 REQUEST: Please provide copies of the Company's pension and actuarial reports for the years 2016-2018. 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: TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 3l .01.01, Rule 067 and233, and Section 9-340D, Idaho Code, and pursuant to the Protective Agreement See Staff PR_030C Confidential Attachments A - C for the2016-2018 actuarial reports. The reports contain the calculations, company contributions, balances, and assumptions. Due to the voluminous nature of the attachments, they are being provided in electronic format only. AVISTA CORP. RESPONSE TO REQUEST FOR TNFORMATTON JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: IDAHO AVU-E-19-04 IPUC Production Request Staff-033 DATE PREPARED: MTNESS: RESPONDER: DEPARTMENT: TELEPHONE: 0612s12019 M. Thies / E. Andrews K. Schultz / D. Ellenson Regulatory Affairs (s09) 49s-2482 REQUEST: To the extent not previously included in Request No. 32, 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 2012-2017 to date. RESPONSE: Please see Avista's response 033C, 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_033C Confidential Attachment" which is a "zip file" that includes over 75 salary studies the Company has participated in for 2017-2019 to date. These studies include companies such as Willis Towers Watson (formerly Towers Watson), Mercer, Milliman, Work at Work, to name a few. Due to the voluminous nature of the documents they are being provided in electronic format onlv. 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 packagel. 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-union, and union, as described further below. Benchmarking may be conducted annually or as needed depending on the group ofemployees. The types ofresources 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 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. 1Salary 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. Page I of6 While benchmarking is an important component ofthe 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 progrzrm for the offrcers. 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 $2.3 billion and $3.1 billion, respectively. The data is not adjusted to reflect the differences in size because the Committee generally targets overall compensation within +l- 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 $l 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-Union 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-union 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-union group. The studies typically include base salaries, short-term cash incentives and long-term incentives. The Company Page 2 of 6 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-union group is different from the officer group in that we do not have a specific Peer Group for the entire non-union group. Ow 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. General General General General $1 - $3 billion All sizes All sizes All sizes All sizes And relative to our competitor group, we monitor market rate data as follows: Median (Median Median Median percentile) 75th percentile 75ft percentile 75ft percentile 75th 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 Gas, Electric & Alternative Nation- wide Exec Base salary, incentives, pay practices Inclustry Geography Orgarrization Size Managentr,"nt Statistical Data Adrninistrative/ J cchnical Professiorral Cornpensation Data .$11.r]:9r ,,-., . -,-wTw- American (ias Association WTW - Energy Services Executive hrduslrl' Location 'l 1.'pes o1'Positions 'l )'pe o1'Data Page 3 of6 I,abor h4 arket Conr pet itols Support WTW - Energl, Sen,iccs h'IAP Nliltiman - NIV Utilities Millinran - NW lllgmt & Prof l\'Iilliman - Spokane Area N{illiman - NW Technologr illercer - Technology (oeldcd 2015) EAPDIS AONtIeuitt - Markcting & Tratling TIY - General Inclustry ACR - Invcstor Ilelations i\lilliman - Enginecring, Scicntific & Project Managernent (odded 2aI7) Utility Electric Non and regulated Utilities Pacific Northwest Nation- wide Mgmt, Prof, Tech & Craft Base salary, pay All Industries Technology Nation- wide Spokane& Tech&Support Kootenai Counties Base salary, incentives, pay practices Base salary, incentives, pay practices Mgmt, Prof, Tech & Support Exec, Mgmt, Prof & Tech Base salary, incentives, pay practices 2015 - discontinued participation 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 retumed 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 50th percentile or median data to better estimate the "typical" pay for the job. Avista's compensation philosophy for the non-union group is to target compensation levels within +/- l5o of market median. Avista has a pay structure with established pay ranges that are divided into thirds. The middle third represents the "market" (+l- 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 extemal 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. Page 4 of6 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 l. 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 intemal average pay. This benchmarking process is time consuming and complex. In order to simpliff 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-union 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 Regional Energy/lJtility Local National Regional Energytutility Local National Regional EnergyAJtility National Regional EnergyAJtility 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 Actual & Projected Salary Increase Budgets Actual & Projected Structure $djustments..,.., Execulive OverallNqll,.EfetT,p!_.., . ,. :r E{-elIlp.t Page 5 of6 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. Union Group The benchmarking process for the union group is again different from the other groups. The studies are conducted during or before the contract negotiations. They are not done on an arurual 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. Page 6 of6