20230504IFG 56-79 to AVU.pdf

119468930.1 0026695-00012
D. 612-373-

May 4, 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 56-79 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
Thursday, May 4, 2023 3:33:14 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]
119468895.1 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. 56-79 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 4th day of May, 2023.

/s/ Carmel Laney Carmel Laney

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 56 Reference workpaper folder “4. Schultz CONFIDENTIAL Workpapers\3.01-3.03 - 24.04,
24.08 PF - LABOR AND BENEFITS\.” Please provide Avista’s labor expense forecast for the test
period(s). The files appear to be missing from the referenced folder in the workpapers provided to IFG.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 57 Reference Shultz workpaper “Confidential Adj. 3.06 - ID GRC PF Insurance Adj:” Tab
“IA-2-Revised:” For each insurance policy identified in the request please identify or provide the
following:
a. The most recent date that the policy was renewed;
b. The most recent renewal premium, both with and without continuity credits;
c. The renewal statements and policy documents; and
d. The policy coverages, limits, deductibles, and other relevant terms associated with the policy.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 58 Reference Kalitch Exhibit 7, Schedule 2, Page 1: Please provide workpapers detailing each
of Avista’s transmission contracts with BPA and supporting the $1,427,000 increase to BPA Point
to Point Transmission expenses on line 46 of the referenced workpaper.

RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 59 Reference Kalitch Exhibit 7, Schedule 2, Page 2: Please provide the workpaper(s)
supporting the $75,051,000 revenue reduction on line 81 titled “Surplus AECO to Malin
Transportation.”

RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 60 Reference Kalitch Exhibit 7: Please identify the amount of gas optimization revenues
included in revenue requirement and explain how those benefits are calculated.

RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 61 Please identify all Washington Climate Commitment Act (“CCA”) allowances that Avista
has purchased to date. Please identify the purpose and/or facility, for which the purchases were
made. Please specify both the quantity and cost of the allowances.

RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 62 Please identify the quantity of free Washington CCA allowances that Avista has been
granted to date.

RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 63 Please identify the quantity of free Washington CCA allowances that Avista expects to be
granted in the respective test periods in this docket.

RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 64 Reference Kalitch Exhibit 7, Schedule 2: The referenced exhibit identifies $70,535,000
and $84,105,000 of Washington CCA allowances in the first and second test periods, respectively.
a. Please provide workpapers used to calculate the referenced amounts including
detail of the specific resources that are driving the need to purchase the referenced allowances.
b. Please explain how the allowances are being allocated between Idaho and Washington.
c. Do the referenced values include any emissions covered with free allowances?
Please explain.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 65 Please identify and describe all legal proceedings challenging the Washington CCA of
which Avista is aware.

RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 66 Reference Avista’s response to IFG Production Request 1: Did Avista modify system
dispatch in any way to accommodate the costs associated with the CCA, such as an adder to the
cost of thermal dispatch and/or increase cost associated with market purchases? If yes, please
describe these changes and quantify the impact of those changes on net power supply costs. If no,
please explain how system dispatch will be impacted by CCA compliance.

RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 67 Reference Shultz workpaper “3.00T - 24.00T PF - TRANSMISSION REVENUE &
EXPENSE\ID AVU-E-23_Transmission Pro Forma 2023-2025 Summary,” Tab “Actuals Jul2021-
Jun2022:” Please provide an updated version of the referenced workpaper with data for the year
ending December 31, 2022. Please reconcile the wheeling revenues in the responsive workpaper
to the $30,339,137 of wheeling revenues included on Avista’s 2023 FERC Form 1, Page 328-330.

RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 68 Reference Shultz workpaper “3.00T - 24.00T PF - TRANSMISSION REVENUE &
EXPENSE\ID AVU-E-23_Transmission Pro Forma 2023-2025 Summary,” Tab “Actual vs Pro
Forma,” Lines 30-31:
a. Please explain how transmission revenues associated with the Clearwater Paper line
item are being recovered and provide a copy of the contract governing the transmission services being acquired.
b. Please explain why Avista assumed that the transmission service revenues would terminate on 31-Dec-2023, while assuming the contract would remain in place for
purposes of rate design and revenue requirement. See, e.g., Avista’s response to
IFG Production Request 19.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 69 Reference Kalitch Exhibit 7, Schedule 2: Please identify the MWhs of production assumed
for the Clearwater Schedule 25P generator in the referenced exhibit for each month in the
respective test periods.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 70 Reference Schultz workpaper “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS,” Tab
“TTP Detail 22-25:”
a. Please provide actual annual transfers to plant for each year 2019 through 2022
(inclusive) using the same, or similar, capital addition names identified in the referenced workpaper.
b. Please provide actual transfers to plant by month for calendar year 2022 using the same, or similar, capital addition names identified in the referenced workpaper.
c. Please provide actual transfers to plant by month for calendar year 2023 through
the most recent month available using the same, or similar, capital addition names identified in the referenced workpaper.
d. Please provide an updated forecast of transfers to plant using the same format as the referenced workpaper based on the most recent information available.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 71 Reference Schultz workpaper “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS,” Tab
“TTP Detail 22-25,” Project Name “ER_2596 - Lolo-Oxbow 230kV Transmission Line Rebuild
Project:”
a. Please provide the business case and any economic analysis prepared supporting
the decision to execute the referenced project.
b. Please provide the monthly construction work in progress balances for the project since the project was initiated.
c. Please provide the current scheduled commercial operation date for the project.
d. Please provide the initial Gantt chart for the project at the time it was approved
detailing the major construction activities and milestones.
e. Please provide the latest Gantt chart for the project detailing the major construction activities and milestones, including detail of activities and milestones completed to date.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 72 Reference Schultz workpaper “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS,” Tab
“TTP Detail 22-25,” Project Name “ER_2629 - Hatwai-Moscow 230kV Asset Condition Rebuild.”
a. Please provide the business case and any economic analysis prepared supporting
the decision to execute the referenced project.
b. Please provide the monthly construction work in progress balances for the project since the project was initiated.
c. Please provide the current scheduled commercial operation date for the project.
d. Please provide the initial Gantt chart for the project at the time it was approved
detailing the major construction activities and milestones.
e. Please provide the latest Gantt chart for the project detailing the major construction activities and milestones, including detail of activities and milestones completed to date.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 73 Reference Schultz workpaper “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS,” Tab
“TTP Detail 22-25,” Project Name “ER_2531 - Westside 230 kV Substation – Rebuild.”
a. Please provide the business case and any economic analysis prepared supporting
the decision to execute the referenced project.
b. Please provide the monthly construction work in progress balances for the project since the project was initiated.
c. Please provide the current scheduled commercial operation date for the project.
d. Please provide the initial Gantt chart for the project at the time it was approved
detailing the major construction activities and milestones.
e. Please provide the latest Gantt chart for the project detailing the major construction activities and milestones, including detail of activities and milestones completed to date.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 74 Reference Schultz workpaper “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS,” Tab
“TTP Detail 22-25,” Project Names “BI_ST504 - Sunset 115kV Substation: Transmission
Integration,” “BI_SS890 - Sunset Sub – Rebuild,” “BI_SS890 - Sunset Sub – Rebuild,”
“BI_SS213 - Beacon Breakers and Cap Banks,” “BI_SD909 - Sunset 115/13V Sub Rebuild Dist
Integration,” “BI_SC001 - Sunset 115kV Substation Rebuild - Security Monitoring,” and
“BI_SC000 - Sunset 115kV Substation Rebuild - Backhaul Comm”:
a. Please provide the business case and any economic analysis prepared supporting the decision to execute the referenced projects.
b. Please provide the monthly construction work in progress balances for each project since the projects were initiated.
c. Please provide the current scheduled commercial operation date for each project.
d. Please provide the initial Gantt chart for the projects at the time they were approved detailing the major construction activities and milestones.
e. Please provide the latest Gantt chart for the projects detailing the major construction activities and milestones, including detail of activities and milestones completed to
date.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 75 Reference Schultz workpaper “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS,” Tab
“TTP Detail 22-25,” Project Name “ER_2274 - New Substations.”
a. Please identify the specific new substations that are being proposed with respect to
the referenced project and provide separate transfer to plant detail for each substation.
b. Please provide the business case and any economic analysis prepared supporting the decision to execute the referenced project.
c. Please provide the monthly construction work in progress balances for each
substation since the substation project was initiated.
d. Please provide the current scheduled commercial operation date for each substation.
e. Please provide the initial Gantt chart for each substation at the time they were approved detailing the major construction activities and milestones.
f. Please provide the latest Gantt chart for the projects detailing the major construction activities and milestones, including detail of activities and milestones completed to date.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 76 Reference Schultz workpaper “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS,” Tab
“TTP Detail 22-25,” Project Name “ER_2616 - Saddle Mountain Integration Phase 2.”
a. Please provide the business case and any economic analysis prepared supporting
the decision to execute the referenced project.
b. Please provide the monthly construction work in progress balances for the project since the project was initiated.
c. Please provide the current scheduled commercial operation date for the project.
d. Please provide the initial Gantt chart for the project at the time it was approved
detailing the major construction activities and milestones.
e. Please provide the latest Gantt chart for the project detailing the major construction activities and milestones, including detail of activities and milestones completed to date.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 77 Reference Howell Direct at 11:6-11:
a. Please identify the retirements by FERC and year account associated with the
wildfire programs identified in the referenced testimony. Please provide this data
for the period 2020 through 2022.
b. Please identify the number of pole replacements by year associated with the wildfire programs identified in the referenced testimony. Please provide this data for the period 2020 through 2022.
c. Please identify the number of wood pole replacements with steel poles by year
associated with the wildfire programs identified in the referenced testimony. Please provide this data for the period 2020 through 2022.
d. Please identify the number of pole replacements forecast for 2023, 2024, and 2025. Please separately detail wood pole replacements with steel poles.
e. Please detail the retirements forecast for 2023, 2024, and 2025 for the wildfire
resiliency plan.
RESPONSE:

IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 78 Reference Schultz workpaper “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS,” Tab
“TTP Detail 22-25,” Project Name “ER_2625 - Clearwater Wind Generation Interconnection.”
a. Please identify the project developer behind the proposed interconnection.
b. Please provide a description of the underlying project, including the nameplate capacity.
c. Please identify all customer contributed funds received, or expected to be received by the project developer, in connection with funding the interconnection.
RESPONSE:
IDAHO FOREST GROUP
Information Requests

Case Nos.: AVU-E-23-01 / AVU-G-23-01 Date of Request: May 4, 2023 Requested From: Avista Corporation Response Due: May 25, 2023
By: Idaho Forest Group (Andrew P. Moratzka)

Response by: List Sources of Information: Title:
Department:
Telephone:
Information Request No. 79 Please identify any grant applications made under the Inflation Reduction Act that Avista
has filed or expects to file, other than the grants identified in response to Staff Production Request
47.

RESPONSE:
119467665.1 0026695-00012