20230502AVU 125-37_139-166 to Staff.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: William Ozminkowski TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-PR-125 TELEPHONE: [phone]
REQUEST:
Please identify how many Customer Service Representatives ("CSRs") in total are employed by
the Contact Center. RESPONSE:
Currently, Avista employees a total of 112 Customer Service Representatives (CSRs) in its Contact
Centers.
RECEIVED
2023 May 2, 4:35PM
IDAHO PUBLIC
UTILITIES COMMISSION
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: William Ozminkowski TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-PR-126 TELEPHONE: [phone]
REQUEST:
Please list how many CSRs work in each of the Contact Centers located in Spokane WA, Coeur
d'Alene ID, and Lewiston, ID respectively. RESPONSE: The table below reflects the number of Customer Service Representatives (CSRs) in each of
Avista’s Contact Centers.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Amanda Ghering TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-127 TELEPHONE: [phone]
REQUEST:
Please list the operating hours of the Contact Center in each location.
RESPONSE: Avista operates three separate contact center locations that all have the same operating hours, as
follows:

Spokane, Washington
Coeur d’Alene, Idaho
Lewiston, Idaho
The Company also employs “Home Agents” and “24-Hour Agents” who are available to assist customers 24 hours a day, seven days a week.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Kim Vollan TYPE: Production Request DEPARTMENT: Corp. Comm.
REQUEST NO.: Staff-128 TELEPHONE: [phone]
REQUEST:
Please explain the efforts put forth by the Company to promote Project Share.
RESPONSE:
In Idaho and Washington, Project Share is a community fuel fund, administered by SNAP under their 501c3. Avista employees, customers, and non-customers can donate to the fund, which is not distributed solely to Avista customers.

Due to the variety of programs available through community action agencies and per customer and agency experience feedback, Avista does not promote specific bill assistance programs (such as Project Share). Instead, Avista spreads awareness about the general availability of assistance (ex: myavista.com/assistanceprograms).
Avista’s focus for Project Share is on education about the program, including ways to contribute. Since the beginning of the COVID pandemic, the Company has included a statement in its monthly customer newsletter about assistance availability.
In addition, Avista partners with the Spokane Chiefs hockey team each season to raise funds and
awareness for Project Share. For every Power Play Goal the Chiefs score, $25 is donated to the fund. During the 2021-2022 season, the Chiefs scored 59 power play goals resulting in $1,475 in Project Share donations.
To donate to Project Share, customers can set up one time or reoccurring pledges, when paying
online. Once enrolled, an acknowledgement message displays and advises that confirmation email
will be sent. Donors can cancel or update their “enrollment”, as desired. Please see Staff_PR_128 Attachment A for promotional materials.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Kim Vollan TYPE: Production Request DEPARTMENT: Corp. Comm.
REQUEST NO.: Staff-129 TELEPHONE: [phone]
REQUEST:
Please describe the types of advertising (radio, tv, bill insert, welcome kit, etc.) that is conducted
in Idaho to inform and educate customers about the following: a. Energy assistance and bill payment options; b. Energy conservation; and
c. Winter Moratorium and the Winter Payment Plan.
In addition, please provide copies of any written brochures or documents sent or otherwise provided to customers for each defined category listed in this question.
RESPONSE:
a. Avista informs customers about comfort level billing, preferred due dates, flexible payment arrangements, and energy assistance programs through print advertising and emails. Messaging aims to educate customers about the options available to them for managing their energy bill. The
Avista website has additional information and lists ways for customers to sign up for various bill
payment options. (myavista.com/waystopay) Advertisements are placed in publications and newspapers in Avista’s service territory that best target customers, such as seniors and vulnerable adults, who may need energy assistance and bill
payment options. Messaging is also placed within Avista’s new customer welcome kits. Customers
are directed to the Company’s website for more information (myavista.com/assistanceprograms). From the onset of the COVID pandemic, through the first half of 2021, Avista approached energy assistance and bill payment outreach in innovative ways, out of an abundance of caution for
customers and employees. Deliveries of energy totes including educational materials were
delivered to all food banks within Avista’s Idaho service territory. These totes included a billing and payment options flyer, which mentioned assistance options through community action agencies. Later in 2021 and into 2022, as COVID restrictions began to relax, Avista began hosting mobile outreach and energy workshop events in Idaho, where energy assistance and bill payment
options were shared.
In addition, an email was sent to customers about potential rental and utility assistance. A bill insert was shared in residential bills, promoting billing and payment options. A bill assistance brochure was made available and energy assistance and billing options information is sent to every
new customer in a Welcome Brochure (pages 8-9 and 11-12). Assistance options were presented
in Avista’s monthly newsletters and ads were placed in community resource publications.
Please see Staff_PR_129 Attachment A for copies of communications pertaining to Energy Assistance and bill payment options.

b. Energy conservation education was shared with customers via television, print and digital advertising, as well as through Avista’s website and program partners (e.g., trade allies and community action agency partners) through which low and no-cost energy saving tips and rebate program information were promoted.

Energy conservation information can be found on Avista’s website at Myavista.com/energytips, Myavista.com/getrebates, Energy Saving Advice for Your Business (myavista.com), and Myavista.com/bizrebates. Avista also collaborated with one of its residential customers on an energy-saving storytelling journey called ‘At Home with Lisa’.

Lisa bought her home which was built in 1910, because she loved its old-world character, but didn’t love how much energy it used. The concerns she had are common for Avista customers, as older inefficient homes are prevalent throughout the Company’s service territory. So many customers don’t understand how they’re using so much energy and when they realize their house
is the root of the problem, identifying ways to manage it seems overwhelming or out of reach. In
Lisa, we found a customer who others could easily see their own experiences in. She began writing a weekly feature for Avista, from her perspective and experience on performing simple DIY projects around her house that would help her save energy and increase comfort. These stories were posted weekly on Avista’s Connections blog and can be found here: Avista Connect: Energy
Blog & Community Stories (myavista.com).
Similar to energy assistance and bill payments noted above, from the onset of the COVID pandemic, through the first half of 2021, Avista also approached energy conservation outreach in innovative ways, out of an abundance of caution for customers and employees. Deliveries of
energy totes including educational materials were delivered to all food banks within Avista’s Idaho
service territory. These totes included a summer/warm weather energy-saving tips sheet, along with a handful of low-cost/no-cost DIY energy-saving products (such as v-seal, battery back-up LED lights, and window plastic). An Energy Use & Saving Guide was also available (in print and online). Mobile conservation outreach events resumed, as COVID restrictions eased. Avista’s
mobile energy resource van partnered with area resource agencies to be present on-site and provide
energy-saving education, in addition to the energy-saving products mentioned above. Avista’s energy efficiency equipment rebate programs were promoted through broadcast ads that ran during the summer 2021 Olympics and can be viewed at Avista Emissions 2021 Broadcast -
YouTube, Avista Rebates 2021 Broadcast - YouTube and Avista Tips 2021 Broadcast - YouTube.
These ads were streamed, placed on YouTube, and shown in online search banners. Digital and print ads promoting energy savings and rebates were also used to spread awareness and encourage engagement and participation. Customers were sent rebate bill inserts and
introduced to rebate options in the new customer Welcome Series. Energy-saving conservation
tips were promoted in Avista’s monthly customer newsletter and in paperless bills. Business customers were targeted with energy-saving conservation education through case studies marketed via print and broadcast. Case studies featured Avista business customers who have
utilized and benefited from Avista’s energy-saving rebate programs. Broadcast ads ran during
spring 2022 Olympics and March Madness and can be found at Mead School District Energy Management - YouTube and Harvester Restaurant Energy Efficiency Upgrades - YouTube.
Trade allies (contractors and equipment installers) were invited to an in-person ‘Trade Ally Open House’, where conservation programs were shared and discussed.

Please see Staff_PR_129 Attachment B for copies of communications pertaining to Energy Conservation. c. Winter Moratorium and the Winter Payment Plan are not promoted via paid advertising
campaigns or collateral. However, awareness about the programs is made available to customers
in several ways. A brochure entitled "Helpful Information About Your Avista Utilities Account," with information on both the Idaho Moratorium Program and Winter Payment Plan, is sent to all residential
customers annually. All customers that receive a Final Disconnection Notice during the months of
November through February are made aware of the Idaho Moratorium Program and the Winter Payment Plan through a bill insert entitled "Winter Payment Plan, Moratorium Information." For those customers who have declared eligibility for the moratorium, a brochure on the Winter Payment Plan is provided with the December, January, and February payment reminder notices
that are sent out.
In addition, Avista’s Customer Service Representatives receive annual training in October on both programs. This training includes Winter Moratorium and Winter Payment Plan qualification requirements and key education to provide to customers upon enrollment. Once enrolled,
customers receive an enrollment confirmation letter that provides program details and their Winter
Payment Plan amount, if applicable. This letter also provides the name and phone number of the local Community Action Agency in their area. Collection Notices sent between November 1st and February 28th include an insert advising of the Winter Payment Plan and Moratorium options.
Please see Staff_PR_129 Attachment C for copies of communications pertaining the Winter
Moratorium and Winter Payment Plan options.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Amanda Ghering TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-PR-130 TELEPHONE: [phone]
REQUEST:
Please describe in detail the type of standard payment plans/arrangements the Company offers its
customers. RESPONSE:
Avista offers its customers two types of payment arrangements. The first is a short term pay plan
that allows customers to pay their balance by their next bill due date. An account does not need to be in arrears to enroll in a short term pay plan. Customers can also choose the payment amounts and dates that work best for their financial situation as long as the final payment is received prior to the next bill due date.

The second type of payment arrangement is a long-term arrangement, typically up to 3 months. Payment arrangements spread the arrears over several months and the customer pays that amount in addition to their current bill each month (current bill plus the agreed upon arrangement amount). The additional amount is due with the customer’s current bill each month until the arrears is caught
up.
In addition to the arrangement options listed above, during the months of December through February, Idaho customers who are not able to pay their bill in full and have someone in the household who is infirm, elderly, or children qualifies for Idaho Moratorium. Payments are not
required while enrolled in the Idaho Moratorium program and the full balance or payment
arrangements are required by the first of March. Customers can also choose to enroll in the Winter Payment Plan which protects a customer’s account during the months of November through March. Unlike the Moratorium program, the Winter Payment Plan requires a payment each month. If a customer misses a payment, the Winter Payment Plan is cancelled, and the account reverts to
the Idaho Moratorium program to prevent a service disconnection during the winter months.
Avista also offers a Comfort Level Billing (CLB) option to even out the seasonal highs and lows that occur throughout the year. When enrolled in CLB, customers pay the average billed amount calculated from the previous 12 months of usage.

See Avista’s response to Staff_PR_132.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Amanda Ghering TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-PR-131 TELEPHONE: [phone]
REQUEST:
Please describe in detail the temporary alternative/modified payment/plan arrangements the
Company offered its customers in 2020 and 2021 due to COVID-19. RESPONSE:
During the COVID-19 pandemic, the Company extended its maximum long term payment
arrangement installments (discussed in Staff_PR_130) from 3 months to 18 months. See also Avista’s response to Staff_PR_132.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Amanda Ghering TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-PR-132 TELEPHONE: [phone]
REQUEST:
Did the Company make any of the temporary alternative/modified payment plan/arrangement a
permanent offering? If no, please explain why not. RESPONSE:
Avista has not reduced its long-term payment arrangements to the pre-pandemic length of three
months. However, in February 2023, the Company reduced the long-term payment arrangement length from 18 months to 12 months. Avista recognizes the importance of providing its customers with options to address arrears, which is why it has not reduced the payment arrangement length to the original 3 months nor are there plans to in the near future.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Charissa Bisiar TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-133 TELEPHONE: [phone]
REQUEST:
For each of the past three winters (2020-2021, 2021-2022 and 2022-2023), how many participants
were under Winter Moratorium each year? Of that amount, how many participants agreed to be placed on the winter payment plan and how many were unable to meet their monthly payment? RESPONSE:

The following chart represents the number of customers during each winter/heating season that participated in the Winter Moratorium (Moratorium), Winter Payment Plan (WPP), and customers who were unable to meet their monthly payments while on WPP, respectively.
Winter Period Moratorium WPP Unable to Pay WPP
2020-2021 688 365 220
2021-2022 679 254 153
2022-2023 800 289 117

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Denise Vermillion REQUESTER: IPUC RESPONDER: Dalila Sheehan TYPE: Production Request DEPARTMENT: Corporate Communications
REQUEST NO.: Staff-134 TELEPHONE: [phone] REQUEST:
Does the Company follow up after each customer interaction to gauge customer satisfaction? If yes, please provide the method the Company uses, such as surveys or satisfaction scores and provide the results for the past three years (2020, 2021 and 2022).
RESPONSE: Avista’s Voice of the Customer Survey is an instrument for following up to gauge customer satisfaction, however, participants are randomly selected (i.e. every single customer is not contacted). The table below provides the annual overall customer satisfaction score represented as
a percent for 2020, 2021, and 2022.

Year 2020 2021 2022
Overall Satisfaction
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Dennis Vermillion REQUESTER: IPUC RESPONDER: Dalila Sheehan TYPE: Production Request DEPARTMENT: Corporate Communications
REQUEST NO.: Staff-135 TELEPHONE: [phone] REQUEST:
Please explain the steps the Company made to address or follow up on any concerns identified through the above methods, such as surveys or satisfaction scores, to ensure customer satisfaction with their Contact Center and/or CSR.
RESPONSE: No, the Company does not follow up after each customer interaction to gauge customer satisfaction. Throughout the course of the survey, customers who are “unsatisfied” have the ability to request a follow up conversation. Team Leaders in Avista’s Contact Center reach out to each of
these customers in an attempt to resolve any complaints.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/01/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-136 TELEPHONE: [phone] REQUEST: Please provide test year monthly expenses for account E-908 referenced in Schultz Exhibit 1.00
Result of Operations. a) Please provide a breakdown of monthly expenses by category (i.e., incentives, admin, labor, etc.).
RESPONSE: Please see “Staff_PR_136_Attachment_A” the detail requested of E-908 referenced in Schultz Exhibit 1.00 Result of Operations. Please note that the amounts in accounts 908600 and 908690, totaling $10.8 million of the $10.9 million total amount in E-908, is eliminated in the Revenue
Normalization adjustment (2.07 E-RN).
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/01/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-137 TELEPHONE: [phone] REQUEST: Please provide test year monthly expenses for account G-908 referenced in Schultz Exhibit 1.00
Result of Operations. a) Please provide a breakdown of monthly expenses by category (i.e., incentives, admin, labor, etc.).
RESPONSE: Please see “Staff_PR_137_Attachment_A” the detail requested of G-908 referenced in Schultz Exhibit 1.00 Result of Operations. Please note that the amounts in accounts 908600 and 908690, totaling $1.5 million of the $1.6 million total amount in G-908, is eliminated in the Revenue
Normalization adjustment (2.07 G-RN).
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IPUC RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-139 TELEPHONE: [phone]
REQUEST:
Regarding the Company's response to Production Request No. 4(d), Staff Attachment 4A, please
provide copies of the Moody reports received for years 2021 and 2022. RESPONSE:

Please see Staff_PR_139 Attachments A-B.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IPUC RESPONDER: Debbie Deubel TYPE: Production Request DEPARTMENT: Corporate Secretary
REQUEST NO.: Staff-140 TELEPHONE: [phone] REQUEST:
Regarding the Company's response to Production Request No. 4(f), Staff Attachment 4C, please provide documents/contracts/agreements to support the 2022 amounts paid to K Blake and S Morris.
RESPONSE: Please see Staff_PR_140 Attachment A (K Blake) and B (S Morris).
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IPUC RESPONDER: Debbie Deubel TYPE: Production Request DEPARTMENT: Corporate Secretary
REQUEST NO.: Staff-141 TELEPHONE: [phone] REQUEST:
Regarding the Company's response to Production Request No. 4(f), Staff Attachment 4C, tab MR_BOD-2, please provide copies of invoices and/or supporting documentation, and a brief explanation of expenses and the need for the following Board of Directors expenses: a. 020 Professional Services: Dean Davis Photography $2,753.96; and b. 020 Professional Services: Davis Polk & Wardwell $16,684.00.
RESPONSE: Please see Avista's response 141C, 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_141C Confidential Attachment A (Dean Davis Photography) and B (Davis Polk & Wardwell).

Dean Davis Photography, Inc. invoice – every few years the Company updates/renews the photos of our board of directors and officers for the proxy and for our website. Davis Polk & Wardell – this was for a guest speaker, Ning Chiu, who spoke at the May 2022 Board
meeting on Diversity and Governance.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/01/2023 CASE NO: AVU-E-23-01/AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IPUC RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff – 142 TELEPHONE: [phone] REQUEST: Please describe changes made to the Company's allocation methodology since the last general rate
case. a. If changes were made due to legislation, regulatory mandates, or commission orders please explain how allocation factors were modified for each change and each jurisdiction; and b. Quantify the impact, if any, to Idaho in dollars, as a result of the change.
RESPONSE: As noted in Ms. Schultz’s direct testimony at page 55, lines 13-20, Q. Have there been any changes to the Company’s system and
jurisdictional procedures since the Company’s last general electric and natural gas cases, Case Nos. AVU-E-21-01 and AVU-G-21-01, respectively? A. No. For ratemaking purposes, the Company allocates revenues, expenses and rate base between electric and natural gas services and between Idaho, Washington and Oregon jurisdictions where electric and/or natural gas
service is provided. The annually updated allocation factors used in this case have been provided with my workpapers. As further discussed recently with staff, the Company directly assigns revenues and costs, when appropriate. Costs not specifically identifiable to a specific Service and Jurisdiction must be
allocated using a reasonable method. The Company’s methodology of using various allocation factors to allocate non-direct costs is consistently used in all 3 states which was approved in 1993 by all jurisdictions. Annually, the
Company updates the allocation factors using actual direct costs. Annually updating factors with
current costs and customers is appropriate so growth in each jurisdiction is factored into the allocation. In addition, by updating the factors, if any Service or Jurisdiction has disproportionate growth of customers or costs, the allocation factor will reflect the shift in costs.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/02/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IPUC RESPONDER: Tia Benjamin/Jeff Webb TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-143 TELEPHONE: [phone] REQUEST:
Please describe and include specifics of how the Coeur d'Alene, ID gate station upgrade described in the Company's latest natural gas IRP was considered in this case. RESPONSE:

The referenced project is funded through the “Gas Regulator Station Replacement Program” business case provided in Mr. DiLuciano’s direct testimony, Exhibit 9, Schedule 3, page 311. The Coeur d’ Alene, ID gate station was selected for replacement due to several factors: 1. The station components (valves and regulators) are antiquated and in need of replacement.
2. There is also currently no official demarcation point between the interstate pipeline and us.
Right now there is just a change in paint color on the pipe. For the new station, an above grade isolation flange will be installed to properly distinguish pipeline ownership. 3. The existing station does not have complete MAOP (Maximum Allowable Operating Pressure) records. A proper pressure test cannot be substantiated due to lack of
documentation at the time of original construction. Construction of the new station will eliminate any gaps in the documentation to ensure Avista is compliant with state and federal rules. 4. The new station will be designed to meet future flow requirements in the Coeur d’ Alene
area.
As a result of the size of this project, it was listed in the IRP. This project will soon be under construction and is expected to be placed in to service (transferred to plant) in third quarter of 2023.
Please also refer to Avista’s Natural Gas IRP provided in Company witness Mr. Kinney’s direct testimony, Exhibit 6, Schedule 3, Section 8. Distribution Planning which discusses how Avista determined the projects needed to meet resource capacity, including the Coeur d’ Alene, ID gate station.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/02/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Tia Benjamin REQUESTER: IPUC RESPONDER: Tia Benjamin TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-144 TELEPHONE: [phone] REQUEST:
Please provide an Excel version of Table No. 4 on page 24 of Company witness DiLuciano's Direct Testimony that details the natural gas capital projects costs by system and jurisdiction (Idaho, Oregon, and Washington) by project, and by year, for the years 2022 through 2025.
RESPONSE:
The source data for Table No. 4 of Company witness Mr. DiLuciano’s Direct Testimony was provided in Ms. Schultz’s workpapers “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS”. Staff_PR_144 Attachment A reconciles the source data to Table No. 4 on the “Pivot” tab.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/26/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Tia Benjamin REQUESTER: IPUC RESPONDER: Tia Benjamin TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-145 TELEPHONE: [phone] REQUEST:
Please provide the costs that will be allocated to Idaho natural gas for the System Operations Office ("SOO") and Backup Control Center ("BuCC") project by year for 2022 through 2025. RESPONSE:

Please see Staff_PR_145 Attachment A. This data comes from the “TTP Detail 22-25” tab of Ms. Schultz’s workpapers, 3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IPUC RESPONDER: Patrick Ehrbar TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-146 TELEPHONE: [phone] REQUEST:
Company witness DiLuciano's Direct Testimony maintains that federal and state regulatory requirements are a driver of 39% of the Company's investment for 2022 through 2025. Please provide a workpaper that details the costs by regulatory requirement and year for Idaho for the years 2022 through 2025.

RESPONSE: The purpose of the six drivers of capital investment, as shown in Mr. DiLuciano’s testimony, and
described in more detail in the testimony of Mr. Thies, is to generally divide our capital
expenditures into meaningful and explanatory categories, so that the Company can generally describe the drivers behind our capital investments. Those projects broken down into the six drivers is provided in Table No. 4 of Mr. DiLuciano’s testimony. The 39% referenced value is related to “Mandatory and Compliance” projects, and not necessarily “Federal and State
Regulatory Requirements” as noted in this request. This is an important clarification and distinction, because the biggest project in the Mandatory and Compliance subcategory is the systematic replacement of Aldyl A natural gas pipe, a 20-year program that is further described on p. 25-26 of Mr. DiLuciano’s testimony (along with further information provided in his exhibits).
This project is deemed mandatory due to the nature of the pipe and potential hazards if not
addressed. Again, we view this project as mandatory for safety reasons; no federal or state edict was issued mandating this work. As for other projects in this category, the project drivers are described in the summaries in Mr. DiLuciano’s testimony and exhibits (i.e., road moves are related to franchise agreements with the jurisdictions we serve in, Cathodic Protection and Overbuild Pipe
are required by Federal Department of Transportation regulations, etc.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01/AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IPUC RESPONDER: David Smith TYPE: Production Request DEPARTMENT: Gas Engineering
REQUEST NO.: Staff – 147 TELEPHONE: [phone] REQUEST:
Please describe how Idaho Commission Order No. 35585 in Case No. AVU-G-22-03 was incorporated into the cost calculations for the Planned Meter Changeout program as referenced in Company witness DiLuciano's Direct Testimony on page 27.
RESPONSE:
Annual assumptions were made based off current meter inventory information to help determine the level of expected transfers-to-plant (TTP) for the Gas Planned Meter Changeout (PMC) Program Business Case that will occur during the 2-Year Rate Plan. These assumptions are already reflected in the TTP
included within the capital adjustments of this case. The assumptions may be subject to change
depending on expected meter deliveries, which could impact the timing of when the PMC and failed meter family program can resume.
Resume failed family replacements for 250 cfh sized meters in 2024 (≈1,786 meters).today, there will not be sufficient inventory of 425, 630 and 1000 meters to resume failed family meters replacements
Resume PMC program (≈1,026 meters)
Resume failed family replacements of 425, 630 and 1000 scfh sized meters (≈676 meters)

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/29/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IPUC RESPONDER: Tim Harding TYPE: Production Request DEPARTMENT: Gas Engineering
REQUEST NO.: Staff-148 TELEPHONE: [phone] REQUEST: In Company witness DiLuciano's Direct Testimony on page 28, the witness describes the Gas
Transient Voltage Mitigation Program. Please explain if, and what, the Company's electric business is doing to mitigate issues on the electric transmission system.
RESPONSE:
The Gas Transient Voltage Mitigation Program is being run by the Gas Engineering department. In the state of Idaho there is one active project in the Rathdrum area. This gas system is adjacent to, or crossed by 13 electric transmission lines that are owned by three different utilities. Because of the complexity of the gas and electric transmission systems, a consulting firm was hired to
perform a design study on the interaction between that electric and gas systems. Their study didn’t
propose making any changes to near-by electric systems. Instead, mitigation is being done on the gas system. Avista’s Electric Transmission and Gas Engineering groups have engaged multiple times in the
last year to review changes to transmission systems adjacent to high pressure steel gas mains in Washington. The Electric Transmission group understands that the co-location of electric and gas facilities can cause steady-state and fault voltage hazards on the gas piping. The Gas Engineering group is continuing to gain more knowledge on this subject and is actively working on projects in
Idaho, Washington, and Oregon.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Amanda Ghering TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-PR-149 TELEPHONE: [phone]
REQUEST:
Please describe in detail the services the Customer Assistance Referral and Evaluation Services
("CARES") team provides. RESPONSE:
Avista's contact center has a specialized team referred to as CARES (Customer Assistance Referral
and Evaluation Services), which provides support to Avista’s most vulnerable customers. This team is specially trained to handle accounts for customers who are elderly, low or fixed income, use medical equipment in the home, or have other extenuating circumstances. They also act as a liaison between customers and Avista’s community partner networks to provide resources for
energy assistance, food, housing, and medical care.
The CARES team is an excellent resource for Customer Service Representatives (CSRs) who may have questions about assistance options available for customers. Customers who may need additional support are referred to the CARES team. One of the primary responsibilities of CARES
is to manage all of the Emergency Medical Certificates (EMC) and Life Support accounts. The
CARES team works with customers to complete the necessary paperwork during enrollment and recertification. The CARES team monitors these accounts on a regular basis to ensure they are receiving the appropriate support pertaining to energy assistance and payment arrangement options.

Customers in the CARES caseload receive additional attention when their accounts become past due and enter the collections cycle. CARES attempts to contact customers who have received a past due notice to help them with payment arrangements and provide energy assistance referrals, prior to them being eligible for disconnection. While CARES tries to prevent disconnection of
service for these customers, there are no guarantees that services will not be at risk. They are
familiar with customer's extenuating circumstances and strive to offer multiple options that are in the customer's best interest and offer resolution. CARES seeks to engage and educate known low-income and senior customers about effective
home energy management methods and available community resources. They educate customers
about low-cost/no-cost ways to manage energy use and provide power outage preparedness tips. Avista has an Energy Resource mobile van that is available for onsite education to heighten awareness about energy assistance, online tools, billing/payment options, and energy-saving kits and informational brochures. The CARES team provides ongoing support during these outreach
events.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joe Miller REQUESTER: IPUC RESPONDER: Amanda Ghering TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-PR-150 TELEPHONE: [phone]
REQUEST:
Please provide the number of customers the CARES team has assisted in each of the past three
years (2020, 2021 and 2022) in total and by jurisdiction. RESPONSE:
The tables below reflect the total customers listed as CARES or Life Support customers by
jurisdiction for 2020, 2021, and 2022. Table 1: Number of Customers Listed as CARES/Life Support - Idaho
5,375 442
8,143 891
8,375 949
Table 2: Number of Customers Listed as CARES/Life Support - Washington
13,184 1,287 19,738 2,111
19,427 2,109

Table 3: Number of Customers Listed as CARES/Life Support - Oregon
663 0
965 0
1,054 0

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/01/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies / E. Andrews REQUESTER: IPUC RESPONDER: Bob Brandkamp TYPE: Production Request DEPARTMENT: Risk Management
REQUEST NO.: Staff-151 TELEPHONE: [phone] REQUEST: Regarding the Company’s response to Production Request No. 04(i), Staff Attachment 4A, please
provide copies of invoices, contracts, workpapers, supporting documentation and a brief explanation on the cost differences between 2021 and 2022 insurance coverage. RESPONSE:
Please see Avista's response Staff_PR_151C, 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. Please see folder labeled “Staff_PR_151C Confidential Attachments A” for invoices and other
materials labeled as noted below, per insurance coverage.
See also Staff_PR_151C Confidential Attachment B for the updated confidential Pro Forma Insurance workpaper (previously “Confidential Adj. 3.06 -ID GRC PF Insurance Adj” in Schultz workpapers, updated now with current information). As noted within this file, the overall decrease
in insurance premiums decreases overall insurance expense pro formed by the Company by approximately $361,000, on a system basis, decreasing the Company’s insurance expenses by $39,000 for Idaho electric and $17,000 for Idaho natural gas. (This update reduces the Company’s revenue requirement by $39,000 Idaho electric and $15,000 Idaho natural gas.) See also Avista’s response to Staff_PR_156C and Staff_PR_157C.
This update also revises the proposed Insurance Balancing Account Baseline to the following:
Effective 9.2023 Total Insurance
ID E 4,314,600$ Proposed Baseline
ID G 697,543$ Proposed Baseline Down from that as-filed to reflect the lower expense notes above.
General Liability
Attachments: GL 1 - 12 31 20, GL 2 - 12 31 20, GL 3 - 12 31 20; GL 15a 12 31 20, GL 15b 12 31 20; GL 4 - 12 31 21, GL 5 - 12 31 21, GL 6 - 12 31 21, GL 7 - 12 31 21, GL8 - 12 31 21, GL 9 - 12 31 21, GL 10 - 12 31 21, GL 11 - 12 31 21, GL 12 - 12 31 21, GL 13 - 12 31 21, GL 14a - 12 31 21, GL 14b - 12 31 21

The increase in excess GL premiums from 2021 to 2022 results from multiple causes. One, continued increases in loss costs industry wide due to increased dollar awards granted by juries in civil litigation resulted in increased non-wildfire premiums. Secondly, insurers across all layers of our excess tower continued to seek premium increases for wildfire risk. Lastly, HDI, an excess
insurer from London on our liability tower that provided $25 million excess of $135 million
discontinued offering coverage in 2022. This resulted in Avista having to obtain additional
coverage through the Bermuda marketplace for both non-wildfire and wildfire coverage through multiple insurance carriers. Not only is the Bermuda marketplace typically more expensive than
London, but we also had to secure new coverage from multiple insurers in this more expensive
marketplace. Directors and Officers Attachments: DO1 - Side A DIC - 3 31 20, DO2 - McGriff Invoices 3 31 20, DO3 - EIM Invoices
3 31 20; DO4 - DO $110M 3 31 21, DO5 - EIM 3 31 21, DO6 - Side A and DIC 3 31 21; DO7 - AEGIS et al - ex EIM 3 31 22, DO8 - EIM 3 31 22 Also refer to previously submitted document, Confidential Adj. 3.06 -ID GRC PF Insurance Adj.
The increase in D&O premiums from 2021 to 2022 was due to industry premium increases of approximately 4.4% (64K) and a reduction of AEGIS continuity credit received of 25.2% ($64K). 2022 saw a decline in the magnitude of premium increases Avista had experienced in both 2020 and 2021 due to D&O insurers in some layers seeking 10-20% increases industry wide to bring this
line of business back to profitability. Property Attachments: Prop 1 - 12 1 20; Prop 2 - 12 1 21
Annual increases in property premiums began an upward trajectory in 2019 following property
insurance industry losses resulting from two of the biggest catastrophic loss years (due to hurricanes) in the industry’s history in 2017 and 2018. Avista received property premium increases of 9.5% in 2019, 18.8% in 2020, and 26.8% in 2021. Since 2021, the rate of premium increases has begun to decrease as evidenced by a 17.6% increase in 2022 and a 16.8% increase in
2023. Cyber Attachments: CYB1 10 22 20, CYB2 - 11 3 21, CYB3 - 10 31 22

Avista, in 2019, began to see significant cyber increases due to increases in frequency and amount of loss industry wide. Premium increases were 18.9% in 2019, 13.7% in 2020, 64.1% in 2021, and 33.3% in 2022. The premium increase peaked in 2021. Our 2021 renewal occurs later in the year and followed the large industry breach experienced by Colonial Pipeline that year. Although the
rate of premium increase began to decline in 2022 (33% in 2022 vs. 64% in 2021), the size of the
increase was still significant. Given the magnitude of the peak increase in 2021, it will most likely be several years before rate increases stabilize. Colstrip
Attachments: Colstrip Financial Assurance Bonds: COL1 #107027209 1 15 20, COL2
#107027209 2 2 22; COL3 - 107027210 11 18 21, COL4 - 107027210 12 7 21; COL5a - 107012874 10 8 20, COL5b - 107012874 return prem 2 5 21, COL6 - 107012874 12 7 21. Colstrip Insurance Expenses: Insurance charges related to Colstrip are not invoiced to Risk
Management. Risk management receives charge back amounts to Avista from Colstrip. Talen manages the insurance program for Colstrip and allocates amount to each of the ownership entities based on their percentage ownership.
Increases in Colstrip related expenses from 2021 to 2022 were driven by allocated insurance
expenses back to us from Talen. In 2021, insurance ($480K) represented approximately 71% of
total Risk Management expenditures related to Colstrip. In 2022, insurance ($623K) grew to approximately 80% of total Risk Management expenditures related to Colstrip. Insurance
expenses allocated by Talen increased by approximately 30% from 2021 to 2022. Workers’ Comp Attachments: WC1 - 4 15 21, WC2 - 1 4 22
Workers’ Comp premiums increased approximately 2% from 2021 to 2022 because of general industry loss cost increases.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IPUC RESPONDER: Debbie Deubel TYPE: Production Request DEPARTMENT: Corporate Secretary
REQUEST NO.: Staff-152 TELEPHONE: [phone] REQUEST:
Regarding the Company's response to Production Request No. 3, Staff_PR-003C- Confidential Attachment 153A, please provide copies of invoices from Staffs confidential attachment. RESPONSE:

Staff was provided access to this material during their on-site audit. The requested information is confidential and would be unduly burdensome to provide.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IPUC RESPONDER: Debbie Deubel TYPE: Production Request DEPARTMENT: Corporate Secretary
REQUEST NO.: Staff-153 TELEPHONE: [phone] REQUEST:
Regarding the Company's response to Production Request No. 3, Staff_PR-003C- Confidential Attachment 154A, please explain what happened and provide additional details about each item listed in Staff's confidential attachment. RESPONSE: Staff was provided access to this materials during their on-site audit. The requested information is confidential and would be unduly burdensome to provide.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 04/28/2023
CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell
REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency REQUEST NO.: Staff-154 TELEPHONE: [phone]
REQUEST: Regarding the Company's response to Production Request No. 37, please provide all documents and supporting information for Wildfire Operation and Maintenance expense samples selected in Attachment 155A, tab labeled O&M.
RESPONSE: Please see Avista's response 154C, 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 folder “Staff_PR_154C Confidential Attachment A” for specific invoices. Please also see Staff_PR_154 Attachment A for a listing of requested expense items listed per
Staff O&M listing Attachments 155A and 156A noted in the request (Staff_PRs 154 and 155).
These items are non-invoice related and represent overheads, materials, AFUDC, or labor transactions. A high-level explanation of these types of transaction is as follows: Materials
Orders of material and equipment are initiated through iProcurement. Requisitions are routed
through the Purchasing/Contracts department. The requisition includes the appropriate account (capital or O&M) and project to be charged for the item. These requisitions may be fulfilled by the Company's Materials Inventory.
Overheads Overhead rates are the means by which overhead costs are allocated throughout the Company. Separate overhead rates are established for labor (payroll benefits, paid time off, payroll taxes, and payroll incentives). Overhead structures and schedules are established to allocate overhead costs to projects based on the type of project and expenditure types charged to the project. Projects with
labor costs charged to them will receive an allocation of the payroll overhead costs (benefits, paid time off, and taxes), and so forth. The labor incentive overhead rates are monitored by Corporate Accounting.
AFUDC
AFUDC represents the cost of both the debt and equity funds used to finance utility plant additions during the construction period. As prescribed by regulatory authorities, AFUDC is capitalized during construction as part of the cost of plant.
Labor
Labor costs for many capital and O&M distribution projects are tracked through Maximo. Maximo is the principal timekeeping system for project-related work performed by bargaining unit
employees; all other time is entered into UltiPro and tracked by project. Time worked is entered by the employee or a designated timekeeper; all time is approved by management through UltiPro.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-155 TELEPHONE: [phone] REQUEST: Regarding the Company's supplemental response to Production Request No. 16, please provide all
documents and supporting information for ER 2075 -Wildfire Resiliency samples selected in Attachment 156A, tab labeled Capital. RESPONSE:
Please see Avista's response 155C, 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 folder “Staff_PR_155C Confidential Attachment A” for specific invoices.

Please also see Staff_PR_154 Attachment A for a listing of requested expense items listed per Staff O&M listing Attachments 155A and 156A noted in the request (Staff_PRs 154 and 155). These items are non-invoice related and represent overheads, materials, AFUDC, or labor transactions. A high-level explanation of these types of transaction is as follows:
Materials Orders of material and equipment are initiated through iProcurement. Requisitions are routed through the Purchasing/Contracts department. The requisition includes the appropriate account
(capital or O&M) and project to be charged for the item. These requisitions may be fulfilled by the
Company's Materials Inventory. Overheads Overhead rates are the means by which overhead costs are allocated throughout the Company.
Separate overhead rates are established for labor (payroll benefits, paid time off, payroll taxes, and payroll incentives). Overhead structures and schedules are established to allocate overhead costs to projects based on the type of project and expenditure types charged to the project. Projects with labor costs charged to them will receive an allocation of the payroll overhead costs (benefits, paid time off, and taxes), and so forth. The labor incentive overhead rates are monitored by Corporate
Accounting. AFUDC AFUDC represents the cost of both the debt and equity funds used to finance utility plant additions during the construction period. As prescribed by regulatory authorities, AFUDC is capitalized
during construction as part of the cost of plant. Labor Labor costs for many capital and O&M distribution projects are tracked through Maximo. Maximo
is the principal timekeeping system for project-related work performed by bargaining unit
employees; all other time is entered into UltiPro and tracked by project. Time worked is entered by the employee or a designated timekeeper; all time is approved by management through UltiPro.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies / E. Andrews REQUESTER: IPUC RESPONDER: Bob Brandkamp TYPE: Production Request DEPARTMENT: Risk Management
REQUEST NO.: Staff-157 TELEPHONE: [phone] REQUEST: Please provide any supporting documentation for the increase in insurance related to the Wildfire
Resiliency Plan (“WRP”) for 2022. Please provide any supporting documentation for the estimated increase in insurance costs for 2023 and 2024 (i.e. emails, letters, invoices). RESPONSE:
Please see Avista's response Staff_PR_157C, 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. Please See Avista’s response to Staff_PR_151C for revised Pro Forma Insurance adjustment.
See documents provided in folder “Staff_PR_157C Confidential Attachments A” including the
following: Attachments: 157Email1 - AEGIS WF Allocation 12 21 22, 157Email2 - EIMWF allocation 12 19 22, 157Email3 - Bermuda allocations 12 15 22; 157GL1 - AEGIS MAP and EIM taxes 1 26 23,
157GL2 - EIM premium invoice 1 20 23, 1573 - Helix Invoice 1 26 23, 157GL4 - Sompo invoice 1 10 23, 157GL5 - OCIL1 invoice 1 10 23, 157GL6 - OCIL 2 invoice 1 10 23, 157GL7 - Ark and Ascot invoice 1 10 23, 157GL8 - Bermuda placement regular taxes 1 26 23, 157GL9 - FET Tax Liability Calculation for Q1 23 Tax Payment to IRS
Wildfire insurance is not a component of the WRP, nor is its cost directly tied to WRP mitigation activities. There is an indirect linkage, in that the implementation of the entirety of the 10-year WRP should reduce the likelihood that utility caused fires occur. The reduction of wildfire loss events specific to Avista will help to mitigate premium increases related to wildfire risk.
However, reduction of wildfire occurrence specific to Avista is only one factor involved in determining the wildfire premiums that Avista pays. Two other major factors are previous wildfire events experienced by Avista as well as industry wildfire loss experience.
In terms of wildfire premium, these charges are not displayed as separate charges on invoices, but
rather through communications from the brokers (see attached 157Email 1-3). 2023 are actual invoiced charges and broken out by wildfire portions as indicated by broker (see Staff_PR_151C Confidential Attachment B for the updated Confidential Pro Forma Adj. 3.06 - ID
GRC PF Insurance Adj workpaper, tab 2023 GL Actual). 2024 premium charges are estimated by
the amount of increase or decrease experienced in 2023 rates (see Staff_PR_151C Confidential Attachment B for the updated Confidential Pro Forma Adj. 3.06 - ID GRC PF Insurance Adj workpaper, tab 2024 GL Est).

See also Avista’s response to Staff_PR_151C and Staff_PR_156C.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-158 TELEPHONE: [phone] REQUEST: Please describe any occurrences where the Company undergrounded any distribution lines both
inside and outside of the scope of the WRP. a. If any, please provide a supporting work. RESPONSE:
Of the 419 feeder miles hardened under the Wildfire Resiliency Program in Idaho and
Washington, 3.2 miles or .7% was converted from overhead service to underground. 5.4 miles are currently in design with a plan to be converted in 2023. All miles constructed and currently in planning have fallen within the project guidelines.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/01/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-159 TELEPHONE: [phone] REQUEST: Please explain why the wildfire category cost of "Wildfire Planning" in 2022 was nearly $217,000
more than the projected cost for 2023. Please provide any supporting workpapers. RESPONSE: Actual Wildfire Planning is made up of labor and benefits for existing employees that existed in
2019 forward. Increases to labor and benefits annually generally relate to annual Company salary
adjustments and benefits. These expenses are not considered incremental expenses to the Wildfire Resiliency Plan and are excluded from consideration in the Wildfire deferral account. In 2019 the Company began to separately track the Wildfire Planning team employee payroll labor
(benefit overheads followed the labor costs) to the Wildfire program, to separately track all
wildfire O&M expenses – both labor and non-labor. The Wildfire Planning team consists of four individuals: a manager, business analyst, wildfire specialist/forester, and project engineer. O&M budget amounts for labor for the Wildfire Program are prepared at a high level with an
emphasis on ensuring that they align with the appropriate jurisdiction. Budget for Wildfire Planning is not prepared at the specific project and task level, but in total as anticipated labor – i.e. budget amounts include expected labor of the 4 employees noted above. However, as actual labor costs are incurred, labor is charged to the specific projects, as well as payroll benefits which are
loaded following the same project and task as the labor.
Year-end actuals for 2020-2022 are shown below for transmission and distribution related expenses.
As noted, there is a significant increase in labor expense between 2020 and 2022 and budgeted
amounts for 2023 ($144,000 transmission, $335,000 distribution, $499,000 total). W50 is the organization code for the Wildfire Planning team labor for these 4 individuals. During 2021 and 2022 certain individuals assisting the Wildfire Planning team charged their time to the Wildfire Planning codes. This additional labor, although charged to the Wildfire planning projects, are not
incremental labor charges overall to the Company, and as noted, for purposes of reviewing annual
incremental wildfire expenses (and amounts impacting the Wildfire deferral), labor and benefits
are excluded from those results. (See Avista’s response to Staff_PR_037 providing annual non-labor/benefits Wildfire Expenses for the period 2020-2023 (as of February 2023).)

In 2023, the combined O&M expense for the Wildfire Planning team is $499,000 (includes labor and non-labor expense). During 2023 individuals outside of the 4 employees noted above is expected to charge account codes outside of the Wildfire planning project codes.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-160 TELEPHONE: [phone] REQUEST: In the table "2023 Wildfire Resiliency Program Elements" on pages 11 and 12 in the WRP, there
are 4 projects that have costs labeled as "Embedded cost". a. Please define "embedded costs". RESPONSE:
Embedded costs are costs that will occur regardless of whether there is a special program in place
or not. For example, in the Wildfire Plan the cost of the Company automating circuit reclosers, responding to a wildfire situation with an EOP, or working with external agencies is a natural part of employee workload so does not add additional expense. In order to implement the Wildfire Plan, some of this work has been shifted to focus on high fire threat areas, but it is still the same
kind of work and occurring at the same level of cost so there is no additional expense associated
with it.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-161 TELEPHONE: [phone] REQUEST: Please explain why the Company changed its "Risk Tree" program to inspect 100% of distribution
lines every year from 20%. a. Please explain the benefits of doing the annual inspection of 100% of the electric distribution system each year compared to the 20%; and b. Please provide supporting documents of the increased need for the full-scale program
and supporting workpapers that show the increased year-over-year costs through 2025.
RESPONSE: a. The 5-year inspection and pruning cycle (20%) represents a practical maintenance cycle for most trees in Avista’s service territory. Using site and tree specific pruning specifications,
most trees can be pruned to industry standards to provide adequate clearance for five years.
Tree risk changes in ways that do not follow the 5-year maintenance cycle, necessitating more frequent evaluation. For example, changes to tree health due to insects, disease, or weather may change a tree’s risk rating from one year to the next. Likewise, changes to the structure of the tree due to mechanical or environmental damage may elevate the risk the tree poses to
Avista’s facilities. The company set the risk tree inspection and mitigation cycle on an annual schedule to best provide for safety and reliability. The Company still completes Routine Maintenance inspection and pruning on a 5-year cycle
while concurrently completing Risk Tree inspection and mitigation on an annual cycle. These
projects represent two different scopes of work. Routine Maintenance is full scope and includes any and all risk trees, while the risk tree scope is limited to imminent vegetation risks. Tree contact with powerlines is the third leading cause of outages on Avista's system (after
planned outages and animal-related outages) but is one of the most preventable incidents we experience. In addition, vegetation related wildfires have caused some of the largest wildfires in history, including the Dixie, Guejito, Witch, and Rice fires in California and the Malden and Pine City fires in Washington state. Trees and other vegetation coming into contact with powerlines can cause fires in many ways, including tearing down live conductor so that it lands
on the ground and into dry vegetation. A branch falling across two spans of conductor can ignite the branch or arc up to multiple feet and may break the line or burn it down. Trees falling into conductor can flash over and create a shower of sparks or a fire. This is one reason our Commissions have encouraged and historically supported a robust vegetation management program, along with the benefits to customer reliability these programs afford in reducing the
number of outages. b. Distribution vegetation management plays an important role in the safe and reliable operation of Avista’s approximately 7,600 miles of overhead electrical distribution. In the past, the
approach to distribution vegetation management was cadence-based with a goal of addressing
the entire system over a five-year to seven-year period. The routine maintenance program
budget included the cyclical program maintenance, customer requested service requests, area requested work, the tree replacement program (Right Tree Right Place), and risk tree
mitigation. As part of the development of Avista’s Wildfire Resiliency Plan and developing
strategy, distribution vegetation management was identified as an area of risk that could be addressed through an enhancement of the distribution vegetation management program. The identified areas of enhancement included: an annual risk tree program, increased emphasis of “Right Tree Right Place” in high fire risk areas, and the addition of best project management
practices to the routine maintenance program.
Figure 1: Impact of unplanned work and risk trees on routine cycle time Figure 1 shows the impact of unplanned work and identified risk trees on the five-year routine maintenance cycle. Before the development of the Enhanced Vegetation Management Program, the Vegetation Management Program encompassed planned routine maintenance trimming,
unplanned work (capital requests, service requests, safety trims, area office requests), and identified risk tree mitigation. Over time, the number of identified risk trees has increased due to higher temperatures, drought conditions, and forest health decline. Increases in risk tree volume and service requests lead to the program falling behind on the five-year cycle. To address this
issue, the Enhanced Vegetation Management Program was developed.
As described above, the increased need for a more full-scale program is the increasing risk of wildfire and the number of large scale wildfires (examples of which were listed above) that have resulted from vegetation contact with powerlines. It is in everyone's best interests to remove this
proven risk, and Avista firmly believes that focusing efforts on removing this risk could be
instrumental in saving lives and property. The increased costs include $900,000 per year for digital data inspection (LiDAR) for the transmission system and another $750,000 for digital inspection (satellite) of the distribution system. The cost for these two elements has increased (as shown in
the budget) as they moved from a pilot stage to full production stage. This information is also
discussed in Company witness direct testimony and exhibits.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-162 TELEPHONE: [phone] REQUEST: Please provide a worksheet that describes any participation in wildfire-related groups. Please
include the name of the group, description of the group, cost of participation, and the benefits gained from each group. RESPONSE:
Engaging with wildfire-related groups is the best way to gain knowledge of best practices, learned
about strategies and techniques that are effective (or are not effective), increase insights and knowledge based on the experiences of other experts in this area, and use brainstorming to develop superior programs for all involved. Participation with these groups is an embedded cost, as the employee time in these discussions and engagements is already part of their regular job
responsibilities, but the benefits can be immense. Some are informal, such as meetings Avista has
held with Idaho Power, NorthWestern, San Diego Gas and Electric, and Southern California Edison to ask for guidance, to share plans and programs, and strategize on how to maximize the value of utility programs.
Over the years the utilities Avista have engaged with on wildfire issues have discussed their programs, customer engagement strategies, safety measures, insurance issues, and much more. These utilities have also freely shared their wildfire plans and the products they use. For example, Avista learned about fire resistant wood pole wrap through discussions with Southern California
Edison (SCE). Prior to gaining this insight, Avista had been following the prior industry practice
of painting fire resistant materials on wood poles, which was effective but had a limited lifespan of about 5-8 years. For about the same price as painting the poles, fire mesh wrap can be installed, provides superior protection, and is expected to last 20-25 years. SCE was eager to share this new product with others in the industry. Since utilities do not compete with one another, sharing
information like this comes at no cost to those sharing it and greatly benefits all utilities, which ultimately benefits customers. Informal meetings and engagements have also provided platforms for developing invaluable relationships with state agencies and fire professionals. As an example, cross-training Avista
frontline employees with fire professionals across our service territory helps ensure that both are safer around powerlines associated with active fires. This is also an embedded cost, as training is a routine part of employee workload. Avista has partnered with external agencies such as the Washington Dept. of Natural Resources
(DNR) and the Idaho Dept. of Lands (IDL), including them in the weekly wildfire meetings we hold during fire season. Again, this is an informal arrangement, but which has developed strong partnerships and mutual support and aid. For example, the Company has an agreement with DNR that they will respond to any reports of wildfire within our Washington service territory and is
working on a similar agreement with IDL. This is at no cost to Avista but could potentially prevent
fires from growing in size and impact.
Some engagements are more formalized such as those shown in Staff_PR_162 Attachment A.
None of these organizations require additional expenditures specifically from Wildfire for
participation. Either the Company has a corporate membership (such as EEI and WEI), thus the engagements are covered under that membership and do not require additional expenditures to participate, or participation is free unless the Company sponsors the meeting, which may mean $300 to $500 in costs for lunches, snacks, and beverages. All participants, including Avista,
leverage information shared to help determine the most efficient use of dollar spend on wildfire mitigations. Learning what doesn’t work helps utilities avoid spends on wildfire mitigations that in the end, do not provide the best risk reduction benefits per dollars spent, or may point utilities to technologies or other strategies that actually create greater efficiencies in their mitigation processes (e.g. LiDAR, satellite imagery, cost sharing with agencies on fuels reduction, etc.) As an
example, the Western Utilities Wildfire Working Group, which Avista started in 2019, meets semi-annually to exchange information on wildfire mitigation and insurance strategies in an effort to learn from each other’s experiences, successes, and challenges. This forum has grown from six Northwestern IOUs to utilities across the West as well as Edison International and even Tucson,
Xcel Energy and Oklahoma Gas and Electric.
It is completely in Avista’s best interests to engage with other entities who share our interest in wildfire prevention and in protecting customers and infrastructure. We realize we don’t have all the answers, even with nearly 140 years of utility experience. The California utilities have been
focused on wildfire issues for over a decade longer than the utilities in the Northwest. Leaning on
their experience and expertise, which has been freely given, has kickstarted the work we are doing and helped us focus on the right things from the start of our wildfire work, saving customers money and saving us a great deal of time and effort. External experts have participated in developing Avista’s Wildfire Plan since it was implemented in 2019, and we believe their
guidance, experience, knowledge, and insights have helped us develop a robust, comprehensive, and effective Plan.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-163 TELEPHONE: [phone] REQUEST: Please explain how jurisdictional allocations are considered and displayed within the WRP. If
jurisdictional allocations are not considered and displayed within the WRP, please explain why not. RESPONSE:
The Company does not breakout our Wildfire programs by jurisdiction and allocation within the
Wildfire Plan itself. The Plan is prepared on a system level based on wildfire risk, focused on areas of our service territory that are identified as having that risk as identified by Avista’s Wildland Urban Interface (WUI) map. Costs are allocated appropriately to each state in both the budget and actual expenditures reported, budgeted for the five-year period based on transmission (allocated
based on Production/Transmission (“P/T”) ratio to Washington and Idaho) and distribution
(directly assigned to each state).
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-164 TELEPHONE: [phone] REQUEST: Please explain how jurisdictional allocations are reconciled between the WRP and actual costs.
RESPONSE: The Company does not breakout costs by jurisdiction in the WRP because it is intended to
represent the system-level approach to wildfire risk mitigation rather than a detailed budget plan.
System level costs are based on wildfire risk, focused on areas of our service territory that are identified as having that risk as identified by Avista’s Wildland Urban Interface (WUI) map. However, costs are allocated appropriately to each state in both the budget and actual expenditures reported, budgeted for the five-year period based on transmission (allocated based on
Production/Transmission (“P/T”) ratio to Washington and Idaho) and distribution (directly
assigned to each state). Specifically, budget allocations are assigned by jurisdiction and costs tracked via the Company’s POET system (project ID, operating location, expenditure type, and task/activity).
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-165 TELEPHONE: [phone] REQUEST: As a supplement to response to Production Request No. 48, please explain what the criteria to
determine a pilot a "success" is. Please explain how least-cost, least risk is used to evaluate projects. RESPONSE:
For the Wildfire program, the LiDAR and satellite pilot projects described in Production Request
No. 48 allowed Avista to "test drive" the new technologies of LiDAR and satellite imaging to see if they are as accurate and useful as the companies providing these services claimed. The providers agreed to a one-time limited scope to allow us to see what they could do with limited financial obligation from the Company. As described in PR-48 and in the Wildfire Plan, these pilots showed
promise and warranted further evaluation, development and integration into Avista’s vegetation
management practices and wildfire plan. The images and analyses provided have proven to be valuable in identifying areas of vegetation encroachment, vegetation growth patterns, forest health, insect damage, proximity to powerlines, structures infringing in rights-of-way, and more. They allow us to see beyond what is capable with human inspections, more quickly, and more
comprehensively. The LiDAR project in particular also provides detailed high-resolution photographs that can be used to evaluate structural or other issues with our equipment. Though remote sensing likely will not eliminate human-based inspections completely, it allows us to thoroughly supplement inspection of the entire distribution and transmission systems each year
while focusing boots-on-the-ground inspection to identified areas of greater risk and higher
vegetation. These pilots are difficult to tie directly to the concept of "least-cost, least-risk" as that was not their purpose. The purpose of the pilot projects in this case was to ensure that the technology worked as expected prior to our investing in it, knowing that appropriate and comprehensive vegetation management practices are critical to both customer reliability and
wildfire prevention and that this technology could be instrumental in focusing our efforts in this area.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/28/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-166 TELEPHONE: [phone] REQUEST: As stated in Company response to Production Request No. 49, the Company did not begin tracking
steel poles installations directly related to wildfire resiliency until 2022. Please explain how the Company attributed steel pole installations expenses to the WRP in 2021. RESPONSE:
In 2021 Wildfire budgeted $5.5 million to transmission steel pole replacements in high fire threat
areas. In 2021 this effort was focused on the Addy-Gifford and Addy-Devil's Gap 115 kV lines which have experienced historical fire activity. The Addy-Gifford line has approximately 300 poles, of which about 60% are listed as wood, 40% are steel as of the end of 2022. The Addy-Devils Gap line has about 460 poles of which approximately 85% are listed as wood, 15%
are steel. All of these poles are located in elevated or extreme fire risk areas. In 2021
approximately 100 steel poles were installed on the Addy-Gifford line. On the Addy-Devils Gap line about 40 new steel poles were installed in 2021. As these are such large projects, these installations will be ongoing. Note that the Wildfire metrics did not, until this year, differentiate between poles installed specifically for wildfire and those that were installed based on asset
condition, pole failure, or other causes. We tracked steel pole installations but did not differentiate between those installed in WUI zones and other business cases. This situation has been changed to keep these metrics separately going forward.