20230418AVU to Staff 1-27.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IFG RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: IFG-001 TELEPHONE: [phone] REQUEST: Please provide an updated version calculation of net power supply costs, which excludes any
impacts associated with the Washington Climate Commitment Act, including the cost of purchasing cap and trade allowances and the associated impacts on plant dispatch.
RESPONSE:
Please refer to confidential exhibit no. 7 – Schedule 2 (for both Rate Year 1 and 2). The net power supply costs, net of Washington CCA, is $108,495 (in $000) and $108,133 (in $000) for rate years 1 and 2. Washington CCA costs for each rate year can be found on line 24 of Schedule 2 for each respective rate years.

RECEIVED
2023 April 18, 3:57PM
IDAHO PUBLIC
UTILITIES COMMISSION
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: K. Schultz / E. Andrews REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-002 TELEPHONE: [phone] REQUEST:
Reference “4. Kaylene Schultz Workpapers\2.05 FIT&DFIT EXPENSE\1) E-FIT 06.22 Electric Adj” Rows “14:15”: Please explain why the tax deductions related to “997128 Meters Expensed” and “997129 Mixed Service Costs (IDD#5)” are treated as a temporary schedule M item and included as an increase to deferred tax expense, rather than being treated as a flow-through item.
RESPONSE: The Company is deferring the customer benefits received from flowing through Meters and Mixed Service Costs to ensure all benefits are returned to customers over time. Certain of these benefits
are being returned to customers through separate tariff 76 (electric) and 176 (natural gas) over a
2-year and 10-year period, respectively. The Company therefore does not treat Meters and Mixed Service Costs as flow through as to not double count this benefit. See also Avista’s response to IFG_PR_003.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: K. Schultz / E. Andrews REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-003 TELEPHONE: [phone] REQUEST:
Reference “4. Kaylene Schultz Workpapers\2.05 FIT&DFIT EXPENSE\1) E-FIT 06.22 Electric Adj” Row “86”: Please provide a schedule detailing the monthly balances of the Customer Tax Credit deferral accounts approved in Case Nos. AVU-E-20-12 and AVU-G-20-07. Please provide the detail over the period since the accounts were initiated through the most recent month
available. Please include detail of all amounts accrued to the balances; all amounts amortized from
the balance, and any other adjustments to the balances. RESPONSE:
See Staff_PR_003-Attachment A for the Idaho Electric Schedule.
See Staff_PR_003-Attachment B for the Idaho Gas Schedule. Note that amounts after February 2023 are estimates.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: K. Schultz / E. Andrews REQUESTER: IFG RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-004 TELEPHONE: [phone] REQUEST: Please provide the final revenue requirement models and revenue requirement workpapers as
approved in Avista’s 2021 General Rate Case. Please provide the Workpapers in a format similar to the workpapers of witness Schultz.
RESPONSE: Avista’s 2021 GRC - Case No. AVU-E-21-01 and AVU-G-21-01 final revenue requirements approved for its electric and natural gas Two-Year Rate Plan were the result of an all-party Settlement. See Stipulation and Settlement filed by the Parties in those dockets for details of
adjustments to expense and rate base agreed-to by the parties. A final revenue requirement model
and supporting workpapers were not prepared or agreed to between the Parties. The settlement revenue requirement for electric and natural gas over the Two-Year Rate Plan was agreed to as a result of various adjustments to specific expenses and rate base as a part of the give-and-take process by all parties and are available within the filed Stipulation and Settlement.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Jeanne Pluth TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-005 TELEPHONE: [phone] REQUEST: Reference “4. Kaylene Schultz Workpapers\1.00 Results of Operations - 06.2022”: Please provide
updated versions of the files in the referenced workpaper folder based upon results for the year ending December 31, 2022, and the year ending December 31, 2021.
RESPONSE:
Please see the reports requested, as follows: Attachment Date Report
Attachment A 12/31/2021 12A-Electric
Attachment B 12/31/2021 12E-Electric
Attachment C 12/31/2021 12A-Gas North
Attachment D 12/31/2021 12E-Gas North
Attachment E 12/31/2022 12A-Electric
Attachment F 12/31/2022 12E-Electric
Attachment G 12/31/2022 12A-Gas North
Attachment H 12/31/2022 12E-Gas North

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Jeanne Pluth TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-006 TELEPHONE: [phone] REQUEST: Reference “4. Kaylene Schultz Workpapers\1.00a Allocation Factors”: Please provide updated
versions of the files in the referenced workpaper folder based upon results for the year ending December 31, 2022. RESPONSE:
Please see information, as follows:

Attachment Ratio
Attachment A PT Ratio-2022 Data
Attachment B 5 Day Peak (2020-2022 Data)
Attachment C Allocation Factors 4 (E&G), 7,8,9 - 2022 Data
Attachment D Gas Note 10-2022 Data
Note: There is no change for Jackson Prairie Allocation Factor

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-007 TELEPHONE: [phone] REQUEST:
Please provide Avista’s historical kWh sales by rate class for each year 2019, 2020,2021, and 2022. RESPONSE:

Below is a summary table of the data requested. Please see IFG_PR_007_Attachment_A for detail by month/block.
Schedule 2019 2020 2021 2022
0001 1,196,917,197 1,210,052,464 1,265,847,800 1,332,902,579
0011 788,905,823 786,446,449 839,186,657 907,439,727
0012 28,334,362 29,033,739 31,542,425 35,550,019
0021 622,541,483 572,330,190 571,914,008 562,889,316
0022 7,180,480 6,839,880 7,370,960 7,564,760
0025 311,450,295 330,483,497 343,914,239 352,566,531
025P 392,167,740 385,882,960 372,138,274 378,936,584
025PG 318,111,000 425,937,000 422,712,000 434,874,000
0031 55,895,853 54,824,782 63,633,170 56,800,402
0032 4,455,913 4,008,854 5,510,175 4,245,784
0041 21,659 20,443 20,251 15,744
0042 5,657,546 5,555,658 5,464,534 5,395,902
0044 261,356 259,862 259,196 258,443
0045 353,441 354,587 353,113 336,897
0046 949,308 955,523 952,312 936,261
0047 450,224 422,238 388,720 355,060
0048 1,028,624 958,532 897,709 852,472
0049 2,330,316 2,264,892 2,209,409 2,172,811
Total 3,737,012,619 3,816,631,551 3,934,314,952 4,084,093,294
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Grant Forsyth REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-008 TELEPHONE: [phone] REQUEST:
Please provide Avista’s most recent electric load forecast on a total-Company basis and for the Idaho jurisdiction. Please provide detail over the period 2023 through 2027. RESPONSE:

Please see Avista's response 008C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
The most recent electric load forecast was prepared March 2023 with forecasted data beginning
March 2023. Actual data has been provided for the January and February 2023 period to reflect the entire 2023 calendar year. Please see IFG_PR_008C Confidential – Attachment A and the associated workpaper file as IFG_PR_008C Confidential – Attachment B.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Jeanne Pluth TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-009 TELEPHONE: [phone] REQUEST: Reference “4. Kaylene Schultz Workpapers\1.00a Allocation Factors\1) 2021&2022
PTRatio-2021 Data,” Tab “WA Adjustments”: Please explain the necessity for the adjustments to peak load identified in the referenced workpaper tab. Please also explain how the cost of the respective load requirements are included in net power supply costs.
RESPONSE:
The “MW Peak” information used in the P/T ratio calculation is derived from the Company’s Area Load by States data that includes the Washington peak load from certain non-retail entities (several nearby PUDs and a Direct Service customer). This non-retail Washington peak loads needs to be removed in order to reflect values associated with the costs to be allocated among the
states. The “WA Adjustments” tab Columns “A” through “J” totaled in Column “K” identifies the
non-retail peak loads included in the peak demand values shown in Column “C” of the “MW Peak” tab. For rate cases, load requirements are weather normalized in power supply costs and are not
impacted by peak conditions.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/18/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: Idaho Forest Group RESPONDER: Joel Anderson TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-010 TELEPHONE: [phone] REQUEST:
Please provide transaction level details supporting Avista’s operating expenses in the test period using a format substantially similar to Staff Data Request 57 in Oregon Docket No UG 461. Please reconcile these expenses to the amounts included in the results of operations at “4. Kaylene Schultz Workpapers\1.00 Results of Operations - 06.2022”.
RESPONSE: Please see IFG_PR_010 Attachment A. This attachment contains transaction detail for 12 months ended June 2022, as well as a “Summary” tab that reconciles the transaction detail to the results of
operations.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/18/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: Idaho Forest Group RESPONDER: Joel Anderson TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-011 TELEPHONE: [phone] REQUEST:
Please provide transaction level details supporting Avista’s operating expenses for the year ending December 31, 2022, using a format substantially similar to Staff Data Request 57 in Oregon Docket No UG 461. Please reconcile these expenses to the amounts included in Avista’s 2022 results of operations.
RESPONSE: Please see IFG_PR_011 Attachment A. This attachment contains transaction detail for 12 months ended December 2022, as well as a “Summary” tab that reconciles the transaction detail to the
results of operations.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-012 TELEPHONE: [phone] REQUEST: Reference “4. Kaylene Schultz Workpapers\1.01 ADFIT\2)CDA Legal Costs Amort.xlsx”: Is the
CDA Lake Settlement costs in the attachment continuing to be amortized for tax purposes over the original 15 year period? Please explain. RESPONSE:
Yes, the $2.3M of legal fees have a tax amortizable life of 15 years and were placed in service for
tax purposes in January 2009.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-013 TELEPHONE: [phone] REQUEST: Reference “4. Kaylene Schultz Workpapers\1.01 ADFIT\2)CDA Legal Costs Amort.xlsx”: Is the
CDA Lake Settlement subject to IRS normalization requirements? Please explain. RESPONSE: No, since this relates to tax straight-line amortization and not accelerated MACRS depreciation,
the IRS normalization requirements do not apply.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Jeanne Pluth TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-014 TELEPHONE: [phone] REQUEST: Reference “4. Kaylene Schultz Workpapers\1.01 ADFIT\2)CDA Legal Costs Amort.xlsx”, Tab
“182333.ED.AN-after tcja,” Cell “AE5”: Please explain the purpose for the negative value in the referenced cell, including a description of how this value impacts the calculation of deferred taxes and Lake CDA relicensing rate base.
RESPONSE:
The credit of $14 million in cell AE5 was to record the cash impact of the CDA settlement. The Company was required to pay $10 million in December 2009 and $4 million in December 2010. Those payments are reflected in cells AE16 and AE28.
This spreadsheet was originally set up to display the accounting for the various CDA settlement
payments. Columns K thru AC displays the portion related to legal fees and are used in the adjustment. Columns AE thru AL displays other CDA costs that were recorded. These costs do not impact the legal fees. The costs should be on 2 separate spreadsheets but were shown on one for ease of preparation. The costs recorded in FERC Accounts 182381 and 283382 are included in
rate base and are included in the test period and are shown in Results of Operation on the plant spreadsheet.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: Idaho Forest Group RESPONDER: Joel Anderson TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-015 TELEPHONE: [phone] REQUEST:
Reference “1.02 DEF DEBITS & CREDITS\6) ID MT Trust Fund Settlement.xlsx”: A note in the referenced file states the following: The existing 10-Year term of the lease payments agreed to expired at the end of 2016;
however, the Mt Trust Fund Settlement payments will continue as the lease payment
obligation is negotiated through future settlement discussions. Therefore, the expected 2022 lease payment expense has been included above. a. Please provide an update on the referenced settlement negotiations.
b. Please provide detail of all ongoing litigation with respect to the referenced lease payments, including detail of each ongoing legal proceeding.
c. Please provide detail of each Mt Trust Fund Settlement payment that Avista has made, including payments under protest in escrow, since the end of 2016?
d. Please provide detail of all legal expenses associated with the referenced settlement included in
the test period.
e. Please provide detail of all legal expenses associated with the referenced settlement incurred in
the year ending December 31, 2022.
RESPONSE: Please see Avista's response IFG_PR_015C, 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. A. We engaged in litigation with the State of Montana as to whether the most favored nations provision of our agreement with the State required a reduction of our prospective rental obligations, as well as a potential refund on past payments, due to ongoing litigation
between Northwestern Energy and the State. We received an adverse ruling at the trial
court level, and while the matter was on appeal, the Montana Supreme Court questioned whether the issue was ripe for decision, given that the litigation between NWE and the State had not been resolved. Both parties submitted briefing on that issue, and the Montana Supreme Court vacated the action on the grounds that it was not ripe. This vacated the trial
court decision, and we are now waiting for a final determination in the NEW/Montana
litigation before deciding how to proceed. B. In light of the uncertainty around our rental obligations, for several years we had been making our rental payments into escrow and have not commenced negotiations with the
State over new rental terms. One part of the trial court ruling that was not vacated, however, was that we could not continue to make payments into escrow. As such, we
began making rental payments directly to the State in 2022 and going forward.
C. Please see IFG_PR_015C Confidential Attachment A.
D. Please see IFG_PR_015C Confidential Attachment B for items d. and e.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/17/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: K. Schultz / E. Andrews REQUESTER: IFG RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-016 TELEPHONE: [phone] REQUEST: Reference 4. Kaylene Schultz Workpapers\3.14 Regulatory Amortizations (WF, COVID, EIM,
Other)\3.14 Reg Deferrals Amortization Adj:” Please provide transaction level details and any other workpapers necessary to support the $5,673,601 of deferred wildfire expenses Avista is seeking to amortize in this proceeding.
RESPONSE:

See attachment IFG_DR_016 – Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/17/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: K. Schultz / E. Andrews REQUESTER: IFG RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-017 TELEPHONE: [phone] REQUEST:
Please provide transaction level details of all amounts booked to the wildfire balancing account in the test period. RESPONSE:

See attachment IFG_DR_016 – Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/17/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: K. Schultz / E. Andrews REQUESTER: IFG RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-018 TELEPHONE: [phone] REQUEST:
Please provide transaction level details of all amounts booked to the wildfire balancing account in the year ending December 31, 2023.
RESPONSE:
See attachment IFG_DR_016 – Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IFG RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-019 TELEPHONE: [phone] REQUEST:
Reference “18. Joseph D. Miller Workpapers\Electric Workpapers 2023 (AVU-E-23-01) RY1”: Please explain why the revenue forecast does not include any Block 2 energy revenues for Schedule 25P.
RESPONSE: As described in my direct testimony, in Commission Order No. 34252, dated June 28, 2013, the Commission approved a five-year Electric Service Agreement (Agreement) between Avista and Clearwater, applicable to its Lewiston Plant.1 The Agreement became effective July 1, 2013 and
was replaced with a new Agreement effective March 1, 2019. The 2013 Agreement provided for
Clearwater to use its on-site generation to serve its own load, and for Clearwater to purchase from Avista all of the electric power requirements that exceed the electric power generated by Clearwater. This contract was not in effect with Avista during the twelve months ended 2022 test year.

On February 27, 2019 the Commission approved a new Power and Purchase and Sale Agreement (Order No. 34252) between Avista and Clearwater that allows Avista to sell to Clearwater an amount of energy equivalent to its generation at a second block rate of $24.56 per MWh. In turn, Clearwater sells the electricity it generates and the corresponding REC’s to Avista at a contract
rate of $24.50 per MWh (adjusted for Commission fees). Because Avista buys and sells an
equivalent amount of energy at near equivalent prices, the new Agreement provides the same benefit to Clearwater as allowing Clearwater to generate into its own load under the prior Agreement.
Avista serves Clearwater’s load requirements under Schedule 25P. As described in Schedule 25P,
for purposes of all proposals related to General Rate Case Filings, “Base Revenue” will be defined as Clearwater’s “net” generation requirements as measured through the Block 1 Retail Meter. Because the effects of the Block 2 Generation load are removed from the Company’s filing, the new Agreement has no impact on the level of base revenue proposed to be recovered in the
Company’s filing.

1 On July 30, 2015 the Commission approved (Order No. 33350) a Joint Petition between Avista and Clearwater
which, among other things, gave approval of a contract amendment which would extend the length of the original
contract from June 30, 2018 to June 30, 2021 (Case No. AVU-E-15-06).
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IFG RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-020 TELEPHONE: [phone] REQUEST:
Please detail each assumption Avista has made with respect to Schedule 25P generation in revenue requirement, and discuss the status of any current contract negotiations. RESPONSE:

Please refer to the Company’s response to the production request labeled IFG-019. There have been no substantive contract negotiations with Clearwater regarding the future of the purchase and sale agreement. Avista expects to engage Clearwater in the coming months to
discuss the future of the contract prior to its expiration.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IFG RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-021 TELEPHONE: [phone] REQUEST:
Please prepare a revenue requirement adjustment and a modified cost of service study that assumes 100% of the load requirements of Schedule 25P are served by the Company and the Schedule 25 Generation is sold to a third-party.
RESPONSE: Per Commission Order No. 34252 Avista and Clearwater have an approved Power and Purchase and Sale Agreement whereby Avista purchases Clearwater’s generation at a set rate as detailed in Schedule 25P. The Company has not conducted a hypothetical analysis to determine the revenue
requirement and cost of service study impacts of serving 100% of the load requirements of
Schedule 25P by the Company and therefore is unable to answer the production request.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IFG RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-022 TELEPHONE: [phone] REQUEST: Has a customer on Schedule 25P sold any generation to a third-party, other than Avista, in any period during the currently effective contract. If yes please state the amount of generation not sold
to Avista by month. RESPONSE:
No. Per the approved Power and Purchase and Sale Agreement (Order No. 34252) Avista sells to
Clearwater an amount of energy equivalent to its generation at a second block rate of $24.56 per MWh. In turn, Clearwater sells the electricity it generates and the corresponding REC’s to Avista at a contract rate of $24.50 per MWh (adjusted for Commission fees).
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IFG RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-023 TELEPHONE: [phone] REQUEST: Does Avista’s Tariff schedule “63 - Net Metering Option Schedule” apply to Schedule 25P? Does Avista have any other tariff schedules for providing standby and/or back-up generation services to
a Schedule 25P generator? RESPONSE:
No, it does not. The Company has a separate Purchase and Sale Agreement approved by the
Commission that governs how the Parties handle the generation portion of Clearwater’s load. There are no other tariff schedules for providing standby and/or back-up generation services to a Schedule 25P generator.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-024 TELEPHONE: [phone] REQUEST:
Please state the Schedule 25P block 1 and block 2 KWhs by month for the test period and in calendar year 2022. RESPONSE:

Below is a summary table of the data requested. Please see IFG_PR_007_Attachment_A for detail. Block 2 usage is labeled “025PG” on the “Usage by Month” tab within the workbook.
Usage Schedule 25P Schedule 25P
By Month (Block 1)(Block 2)
202107 29,206,523 41,207,000
202108 32,812,506 40,319,000
202109 32,908,128 34,826,000
202110 29,635,285 38,769,000
202111 30,931,322 38,314,000
202112 29,306,904 41,316,000
202201 25,995,909 37,967,000
202202 29,498,520 37,011,000
202203 32,027,074 39,740,000
202204 31,406,116 37,355,000
202205 32,464,445 37,325,000
202206 31,819,154 34,726,000
202207 35,881,209 36,072,000
202208 39,449,722 32,700,000
202209 34,381,779 35,549,000
202210 33,110,274 37,671,000
202211 23,595,478 27,442,000
202212 30,592,034 39,530,000
Test Year (12ME June 2022) Total 368,011,886 458,875,000
2022 Total 380,221,714 433,088,000
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-025 TELEPHONE: [phone] REQUEST: Reference “4. Kaylene Schultz Workpapers\2.12E - 24.09E Colstrip & CS2 Maintenance\09.2023
- ID Colstrip CS2 Maintenance Amort”: Please provide an explanation for the insurance proceeds identified on row 42 of “E-CCOM-1,” including a description of when the insurance proceeds were received and how Avista accounted for the insurance proceeds in its results of operations.
RESPONSE:
Please see Avista's response IFG_PR_025C, 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. As noted in Ms. Schultz direct testimony, page 25, footnote 13, in 2022, the Company received
$2.5 million in insurance proceeds related to the insurance claim filed in 2018 due to the failure of
equipment at the CS2 natural gas generating facility in 2018. Approximately $1.3 million of the insurance proceeds were recorded as an offset to net capital CS2 investment, with the remaining balance of approximately $1.2 million related to O&M expenses, deferred for return to Idaho and Washington customers. Idaho’s share of the O&M expense amount deferred was approximately
$413,000. Idaho’s share of the O&M expense amount deferred were netted together with the
estimated 2022 deferral, lowering the amount the Company would have otherwise collected from Idaho customers. See Confidential IFG_PR_025C – Confidential Attachment A for the detailed information
regarding the insurance proceeds.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-026 TELEPHONE: [phone] REQUEST:
Reference “4. Kaylene Schultz Workpapers\2.05 FIT&DFIT EXPENSE\4) ITC AMORT”: Please reconcile the 65 year remaining life for the Noxon and Nine Mile investment tax credits with the probable retirement dates assumed in Avista’s depreciation study.
RESPONSE: The depreciation study lists the probable retirement years as 2060 for Nine Mile and 2079 for Noxon Rapids.
The Noxon and Nine Mile ITC amortization schedules have not yet been updated to reflect the new
depreciation study since the depreciation study has not been approved by the Commission. These schedules will be updated once the depreciation study is approved.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/18/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-027 TELEPHONE: [phone] REQUEST:
Reference “4. Kaylene Schultz Workpapers\3.07 PF EDIT (RSGM)\2) RSGM Allocation”: Please provide the workpapers used to calculate the amounts on Rows “4:37” on Tab “ARAM Allocation.”
RESPONSE: See IFG_PR_027-Attachment A for the RSGM calculation. Please note that the calculation has been updated since the Company filed the General Rate Case and the attachment reflects the updated calculation.

The Company has updated the RSGM workpapers related to Pro Forma Adjustment 3.07 – Excess Deferred Income Taxes (EDIT) (RGSM). Please refer to IFG_PR_027-Attachment B and IFG_PR_027-Attachment C for updated workpapers.
For Idaho electric, the impact of updating the RSGM calculation related to Pro Forma Adjustment 3.07 – EDIT (RSGM) increases overall deferred income taxes by approximately $59,000 and increases the Company’s revenue requirement associated with these deferred income taxes by $75,000.

For Idaho natural gas, the impact of updating the RSGM calculation related to Pro Forma Adjustment 3.07 – EDIT (RSGM) increases overall deferred income taxes by approximately $277, and has no impact on the Company’s revenue requirement since revenue requirement is rounded to the nearest thousand.