20230426IFG 1-27 to AVU.pdf

119032435.1 0026695-00012
Andrew P. Moratzk
33 S. Sixth Street, Suite 4200
Minneapolis, MN 55402
D. 612-373-8822
[e-mail]
March 28, 2023
VIA E-MAIL:
[e-mail]
[e-mail]
[e-mail]
David Meyer
Vice President and Chief Counsel of
Regulatory & Governmental Affairs
Avista Corporation
PO Box 3727
Spokane, WA 99220-3727
Patrick D. Ehrbar
Director of Regulatory Affairs
Avista Corporation
PO Box 3727
Spokane, WA 99220-3727
Re: Idaho Public Service Commission Case No. AVU-E-23-01
Avista Corporation’s 2023 General Rate Case
Dear Messrs. Meyer and Ehrbar:
Attached herewith and served upon you, please find Idaho Forest Group LLC’s Information
Requests 1-27 in both Word and PDF format. Also enclosed is a Certificate of Service.
Very truly yours,
Andrew P. Moratzka
APM:cal
Enclosures
cc (via email): Larry Crowley – [e-mail]
Bradley Mullins – [e-mail]
RECEIVED
Wednesday, April 26, 2023 11:05:37 AM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 1 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 2 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:
IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 3 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:
IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 4 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 5 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 6 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 7 Please provide Avista’s historical kWh sales by rate class for each year 2019, 2020,2021,
and 2022.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 8 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 9 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 10 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 11 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 12 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 13 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 14 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 15 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:
IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 16 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 17 Please provide transaction level details of all amounts booked to the wildfire balancing
account in the test period.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 18 Please provide transaction level details of all amounts booked to the wildfire balancing
account in the year ending December 31, 2023.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 19
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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 20 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 21 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 22 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 23 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:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 24 Please state the Schedule 25P block 1 and block 2 KWhs by month for the test period and
in calendar year 2022.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 25 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:
IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 26 Reference “4. Kaylene Schultz Workpapers\2.05 FIT&DFIT EXPENSE\4) ITC AMORT”:
Please reconcile the 65 year remaining life for the Nixon and Seven Mile investment tax credits
with the probable retirement dates assumed in Avista’s depreciation study. RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case No.: AVU-E-23-01 / AVU-G-23-01 Date of Request: March 28, 2023 Requested From: Avista Corporation Response Due: April 18, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 27 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:

119024737.1 0026695-00012