20230426IFG 28-55 to AVU.pdf

119375241.1 0026695-00012
D. 612-373-

April 26, 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
Director of Regulatory Affairs
Avista Corporation PO Box 3727 Spokane, WA 99220-3727
Re: Idaho Public Service Commission Case Nos. AVU-E-23-01 and AVU-G-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 28-55 in both Word and PDF format. Also enclosed is a Certificate of Service.

APM:cal
Enclosures cc (via email): Service List Jan Noriyuki, Commission Secretary - [e-mail]
Larry Crowley - [e-mail]
Bradley Mullins – [e-mail]
RECEIVED
Wednesday, April 26, 2023 3:05:01 PM
IDAHO PUBLIC
UTILITIES COMMISSION
1
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC AND
NATURAL GAS SERVICE TO ELECTRIC
AND NATURAL GAS CUSTOMERS IN THE
STATE OF IDAHO
)
)
)
)
)
)
)
CASE NOS. AVU-E-23-01
AVU-G-23-01
AVISTA CORPORATION: Patrick D. Ehrbar

COMMISSION STAFF:

SERVICE LIST
2
CLEARWATER PAPER CORPORATION: Peter J. Richardson

th
ELECTRONIC ONLY:
IDAHO FOREST GROUP, LLC:

ELECTRONIC ONLY:
Bradley R. Mullins
Principal Consultant
MW Analytics
E-mail: [e-mail]
3
WALMART, INC: Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
E-mail: [e-mail]
Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast “J” Street
Bentonville, AR 72716
E-mail: [e-mail]
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
E-mail: [e-mail]
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
E-mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8th Ave.
Helena, MT 59601
E-mail: [e-mail]
119374954.1 0026695-00012
CERTIFICATE OF SERVICE
I, Carmel Laney, hereby certify that I have this day served a true and correct copy of the following
document(s) to all persons at the addresses indicated below or on the attached list by electronic filing, electronic mail, courier, interoffice mail or by depositing the same enveloped with postage paid in the United States Mail at Minneapolis, Minnesota.
INFORMATION REQUEST NOS. 28-55 TO AVISTA CORPORATION ON BEHALF OF IDAHO FOREST GROUP LLC via email upon:
Vice President and Chief Counsel of Regulatory & Governmental Affairs Avista Corporation PO Box 3727
Spokane, WA 99220-3727
[e-mail]
Director of Regulatory Affairs Avista Corporation PO Box 3727 Spokane, WA 99220-3727
[e-mail]
[e-mail]
Idaho Public Service Commission
Case Nos. AVU-E-23-01 and AVU-G-23-01
Avista Corporation’s 2023 General Rate Case Dated this 26th day of April, 2023.

/s/ Carmel Laney Carmel Laney

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 28 Reference AVU-E-21-01, Howell Direct at 20: In the referenced testimony filed in Avista’s
2021 GRC, Avista proposed $6,917,000 in wildfire O&M expenses in 2022. Please reconcile that
figure with the $16,509,318 of 2022 wildfire expenses identified in response to IFG Production Request 16, Attachment A and the $16,477,600 of 2022 wildfire expenses identified in response to Staff Production Request 37, Attachment A. Please provide itemized details of the variances between these figures and an explanation for why the actual spending exceeded the planned
spending by more than 100%.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 29 Reference Avista’s response to IFG Production Request 16, Attachment A, Tab
“Transaction Details”: Please provide all documentation regarding the eight entries on invoices
1199 and 607 for GEODIGITAL INTERNATIONAL CORP included in the referenced workpaper.
Please include a copy of the reports or deliverables received in connection with the services from
GEODIGITAL INTERNATIONAL CORP under invoices 1199 and 607.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 30 Reference Avista’s response to IFG Production Request 16, Attachment A, Tab
“Transaction Details,” Vendor “GENICS INC”: Please identify each location where fire wrapping
was installed and identify the number of poles wrapped for each site.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 31 Reference Avista’s response to IFG Production Request 16, Attachment A, Tab “Wildfire
Incremental Expense”: Please identify the amount of risk tree vegetation management included in
the referenced attachment by month.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 32 Reference Avista’s response to IFG Production Request 16, Attachment A: Please provide
a copy of the invoice numbers 79V16421, 76Q57621, 78R62521, and 74X33021 for ASPLUNDH
TREE EXPERT LLC. For each invoice, please identify the specific location(s) where the work
was performed, identify the number and types of trees removed, identify the distribution or
transmission lines affected, and provide a general description of the work performed.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 33 Reference Avista’s response to Staff Production Request 47:
a. Please provide a copy of the grant application identified in the referenced
response.
b. Please state when Avista expects to receive a decision on the grant application.
c. Please detail the terms of the grant funding, including any requirements to
reimburse the grant funding.
d. How does Avista plan to account for the grant funding, if received?
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 34 Reference Avista’s response to IFG Production Request 03: In what accounting month did
Avista record the basis reduction associated with the Form 3115 tax accounting change for
expensing meters and mixed service costs (IDD#5)?
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 35 Reference Avista’s response to IFG Production Request 03, Attachment A: Please identify
from the referenced attachment the total deferred balance Avista believes will be refundable to
customers as of the rate effective date in this proceeding.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 36 Reference Avista’s response to IFG Production Request 09: Does Avista provide electric
services to the referenced PUDs and Direct Service customers? If yes, please provide the power
supply agreements for those customers. If no, please explain why the referenced entities load
requirements are included in Avista’s system requirements.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 37 Reference Avista’s response to Staff Production Request 22, Attachment A: Please identify
the purpose of the lease at the Scott Morris Center and provide detail of each employee who works
the leased location.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 38 Reference Avista’s response to Staff Production Request 22, Attachment A: Please identify
the amount Avista has invested in the Scott Morris Center and neighboring properties. Please also
provide a general description of Avista’s involvement in the development.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 39 Reference Avista’s response to Staff Production Request 33: Please identify the rate base
of the hangar and jet included in revenue requirement, including separate detail for Gross Plant,
Accumulated Depreciation, and Accumulated Deferred Taxes.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 40 Reference Avista’s response to IFG Production Request 19: Please provide the hourly
generation from the Schedule 25P generation resource over the period July 1, 2021, through
December 31, 2022.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 41 Reference Shultz workpaper “3.14 Reg Deferrals Amortization Adj:” Please identify the
Commission order where the regulatory asset of $699,119 for the EIM was approved.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 42 Reference Shultz workpaper “1)12A-2022.06_Working Capital_PULL:” Please provide a
fully functional working capital model necessary to support all of the hard coded numbers in the
referenced workpaper. Please provide the model in excel format with all formulas and links intact.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 43 Reference Shultz workpaper “1)12A-2022.06_Working Capital_PULL:” Please provide
Avista’s most recent lead lag study.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 44 Reference “4. Kaylene Schultz Workpapers\2.05 FIT&DFIT EXPENSE\4) ITC AMORT”:
Please provide a description of the specific investments that Avista made in order to recognize the
investment tax credits in the referenced workpaper. If available, please provide details of the ITC
eligible investments by FERC account and year placed in service.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 45 Referenced Avista’s response to IFG Production Request 27, Attachment C: Please provide
an updated version of the referenced workpaper incorporating the results of the new depreciation
study.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 46 Reference “4. Kaylene Schultz Workpapers\3.12 - 24.06 PF REVENUE & O&M
OFFSETS\2) Electric New Customer Revenue ID PF.xlsx”. Please provide updated customer
counts by rate schedule and month over the period July 2022 through March 2023.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 47 Reference “4. Kaylene Schultz Workpapers\2.07 REVENUE ADJ \Normalized Usage by
Month 12ME 202206 11.7.22,” Tab “Meters,” Excel Row “140:” Please provide an explanation
of the purpose of the line item “ID Sch 21/25 Shifting” and describe how that line item affects the
revenue forecast in this proceeding.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 48 Reference “4. Kaylene Schultz Workpapers\2.07 REVENUE ADJ \Normalized Usage by
Month 12ME 202206 11.7.22,” Tab “summary:” Please provide actual, unadjusted monthly usage
by rate class over the period July 1, 2022, through March 31, 2023.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 49 Please provide Avista’s most recent electric sales (kWh) forecast by rate schedule,
including monthly detail of customer counts and usage through December 31, 2025.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 50 Reference “4. Kaylene Schultz Workpapers\2.07 REVENUE ADJ \Normalized Usage by
Month 12ME 202206 11.7.22,” Tab “Weather Adjustment,” Excel Row “5”: Please provide fully
functional workpaper used to calculate the Idaho weather adjustment detailed on the referenced
row.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 51 Please provide monthly historical electric sales (kWh) and customer counts by rate
schedule and weather zone (as used in Avista’s weather normalization model) over the period 2013
through 2022 (inclusive).
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 52 Please provide actual monthly average temperatures and degree days by weather zone over
the period 2013 through 2022 (inclusive).
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 53 Please provide average temperatures and degree days by weather zone used in Avista’s
revenue normalization calculation. Please also identify the period over which the averages were
calculated and provide the historical data necessary to recalculate the averages.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 54 Reference Avista’s 2021 Transmission Rate Filing in ER21-02198: Please provide an
updated version of Exhibit AVA-500, Statement BB - Allocation Demand and Capability Data
based on transmission system demands for 2022.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: April 26, 2023 Requested From: Avista Corporation Response Due: May 17, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 55 Please describe Avista’s method for segregating transmission and distribution services for
purposes of establishing Open Access Transmission Tariff rates.
RESPONSE:
119374399.1 0026695-00012