20230511AVU to IFG 28-57_59-60_64_69_79.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IFG RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: IFG-28 TELEPHONE: [phone] REQUEST: Reference AVU-E-21-01, Howell Direct at 20: In the referenced testimony filed in Avista’s 2021
GRC, Avista proposed $6,917,000 in wildfire O&M expenses in 2022. Please reconcile that figure with the $16,509,318 of 2022 wildfire expenses identified in response to IFG Production Request 16, Attachment A and the $16,477,600 of 2022 wildfire expenses identified in response to Staff Production Request 37, Attachment A. Please provide itemized details of the variances between
these figures and an explanation for why the actual spending exceeded the planned spending by
more than 100%. RESPONSE: In 2022, Avista conducted a risk tree inspection of 6,466 miles of distribution lines. Historically,
Avista has conducted risk/hazard tree inspections in conjunction with routine maintenance and did
so on 20% of the system annually (a 5-year cycle). However, as part of the Wildfire Resiliency Program, routine vegetation maintenance on distribution lines was separated from risk tree inspection so that 100% of the system could be inspected. We had estimated the number of dead, dying, and diseased trees, at approximately 50% of what was discovered. The intense drought of
2021 combined with insect infestations and other mortality trends have severely impacted forest health throughout Eastern Washington and Northern Idaho. We recognized this trend in early 2022 and after an executive management review, decided to stay the course with plans to inspect 100% of the system. Data indicates that trees are 4 to 5 more times likely to fall into distribution
lines than to encroach upon them. Over the last 5-year, an average of 373 trees have fallen into
distribution lines and dead, dying, and diseased trees are much more likely to fall than green, healthy trees. Identifying and mitigating risk/hazard trees in a prominent feature in Avista’s Wildfire plan.
Please see IFG_PR_028 Attachment A - WFRES MAC 201 2021_2022 Comparison.xlsx
RECEIVED
2023 May 11, 5:02PM
IDAHO PUBLIC
UTILITIES COMMISSION
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IFG RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: IFG-29 TELEPHONE: [phone] REQUEST: Reference Avista’s response to IFG Production Request 16, Attachment A, Tab “Transaction
Details”: Please provide all documentation regarding the eight entries on invoices 1199 and 607 for GEODIGITAL INTERNATIONAL CORP included in the referenced workpaper. Please include a copy of the reports or deliverables received in connection with the services from GEODIGITAL INTERNATIONAL CORP under invoices 1199 and 607.
RESPONSE: Invoice 607 is for partial payment for the 2021 LiDAR project based on the project delivery and payment schedule and is attached. The 2021 project consisted of 1143.2 line miles of LiDAR acquisition and analysis, along with high resolution imagery capture. Please see IFG_PR_029
Attachment A - “2021 & 2022 LiDAR project line lists” for a detailed list of the transmission lines
included in the project. Below are examples of the LiDAR and high-resolution imagery provided under the 2021 contract that invoice 607 refers to.
2021 LiDAR example (Invoice 607) (IFG_PR_029 Attachment B):

2021 High-Resolution Imagery Example (Invoice 607):

Invoice 1199 is for partial payment for the 2022 LiDAR project based on the project delivery and payment schedule and is attached. The 2022 project consisted of 2269.1 line miles of LiDAR
acquisition and analysis, along with high resolution imagery capture. Please see IFG_PR_029 Attachment A - “2021 & 2022 LiDAR project line lists” for a detailed list of the transmission lines included in the project. 2022 LiDAR example (Invoice 1199)(IFG_PR_029 Attachment C):

2022 High-Resolution Imagery Example (Invoice 1199):

The 3D LiDAR examples shown above are provided for every span included in the projects. The
user can pan around within these 3D images and view the span from any angle. The data is currently hosted by GeoDigital in an online web server where Avista’s forester and other personnel can access, view, and query the projects. The LiDAR data can be queried to find vegetation encroachment, strike potential, and forest health problems among other uses. The high-resolution imagery shown above is also hosted by GeoDigital and available online.
There are approximately 5 to 10 images taken for every span from multiple angles. These images are useful for visually identifying problem vegetation and can also be used to inspect transmission towers and equipment.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IFG RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: IFG-30 TELEPHONE: [phone] REQUEST: Reference Avista’s response to IFG Production Request 16, Attachment A, Tab “Transaction
Details,” Vendor “GENICS INC”: Please identify each location where fire wrapping was installed and identify the number of poles wrapped for each site. RESPONSE:

No poles were wrapped in Idaho during the time period indicated in the attachment for IFG Production Request 16. The following work was done in Washington during that time: 2022:
Devils Gap-Stratford 373 poles
Saddle Mountain-Walla Walla 230kv 147 poles Saddle Mountain-Wanapum 230kv 376 poles Neilson-Washtucna 249 poles Devils Gap-Lind 115kv 351 poles
Total 1496 2023 to date: Shawnee-Sunset 115kv 86 poles
Lind-Shawnee 115kv 201 poles
The rest of the work in 2023 is scheduled in Washington. Distribution expenses are directly assigned by State, and therefore charged to Washington.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IFG RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: IFG-31 TELEPHONE: [phone] REQUEST: Reference Avista’s response to IFG Production Request 16, Attachment A, Tab “Wildfire
Incremental Expense”: Please identify the amount of risk tree vegetation management included in the referenced attachment by month. RESPONSE:
Please reference IFG_PR_016 Attachment A, Tab “Transaction Details”. Columns are arranged
by month, for example column “202110” is for October 2021. Rows display risk tree vegetation management amounts for both transmission “L11” and distribution “L12” (see column P – expenditure Organization).

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IFG RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: IFG-32 TELEPHONE: [phone] REQUEST: Reference Avista’s response to IFG Production Request 16, Attachment A: Please provide a copy
of the invoice numbers 79V16421, 76Q57621, 78R62521, and 74X33021 for ASPLUNDH TREE EXPERT LLC. For each invoice, please identify the specific location(s) where the work was performed, identify the number and types of trees removed, identify the distribution or transmission lines affected, and provide a general description of the work performed.
RESPONSE: Invoices are attached as IFG_PR_032 Attachments A-D. IFG_PR_032 Attachment E provides the additional information requested for each invoice, organized by tabs labeled to the corresponding invoice.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IFG RESPONDER: Robb Raymond TYPE: Production Request DEPARTMENT: Asset Maintenance
REQUEST NO.: IFG-33 TELEPHONE: [phone] REQUEST: Reference Avista’s response to Staff Production Request 47:
a. Please provide a copy of the grant application identified in the referenced response.
b. Please state when Avista expects to receive a decision on the grant application.
c. Please detail the terms of the grant funding, including any requirements to reimburse the grant funding.
d. How does Avista plan to account for the grant funding, if received?
RESPONSE: a. At the time when Avista responded to Staff Production Request 47, Avista was in the application process for a 5 year, $100M grant from the Department of Energy. Since the
response, Avista revised the Grant Application to $50M. As part of the Bipartisan
Infrastructure Law, the Grid Deployment Office (GDO) is administering a $10.5 billion Grid Resilience and Innovation Partnership Program (GRIP) to enhance grid flexibility and improve the resilience of the nation’s power grid against growing threats of extreme weather and climate change. The full application package (attached) was submitted to the Department of
Energy on 4/6/2023.
b. The Department of Energy reported that applicants will be notified the summer of 2023.
c. IFG_PR_033 Attachment A - FundOpp_DE-FOA-0002740.pdf outlines the complete terms of
the Grant. Notables include:
 Section II-v on page 33 stipulates that the execution of the work shall take 60 months. If awarded, the duration shall be 2024 through 2028.
 Section B, Topic Area 1 on page 37 states that an eligible entity that receives a grant under this section shall be required to match 100% of the amount of the grant (at least
50% of the total project costs). Thus, Avista will be responsible for funding $50M of the $100M of work defined in the Grant application.

d. Avista will financially isolate the grant sponsored work by creating independent projects by feeder. Additionally, the budget and financials will be rolled up to one of four regions for
reporting and audit purposes.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-034 TELEPHONE: [phone] REQUEST:
Reference Avista’s response to IFG Production Request 03: In what accounting month did Avista record the basis reduction associated with the Form 3115 tax accounting change for expensing meters and mixed service costs (IDD#5)?

RESPONSE:
The Form 3115 tax accounting method change impacts were recorded with October 2020 close upon the filing of the 2019 Federal Tax Return.
The customer deferral accounting to FERC Account 254393 – Reg Liab – Tax Customer Credit
related to flowing through meters and IDD #5 was initially recorded with April 2021 close when Avista received approval from the Commissions.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies/ E. Andrews REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-035 TELEPHONE: [phone] REQUEST:
Reference Avista’s response to IFG Production Request 03, Attachment A: Please identify from the referenced attachment the total deferred balance Avista believes will be refundable to customers as of the rate effective date in this proceeding.

RESPONSE:
Per the referenced attachment, the estimated remaining balance to be refunded to electric customers is $2.1M (tab “Monthly ADJ” cell F40) as of August 31, 2023.
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/S. Kinney REQUESTER: IFG RESPONDER: Eric Tipton TYPE: Production Request DEPARTMENT: Transmission
REQUEST NO.: IFG-036 TELEPHONE: [phone] REQUEST: Reference Avista’s response to IFG Production Request 09: Does Avista provide electric services
to the referenced PUDs and Direct Service customers? If yes, please provide the power supply agreements for those customers. If no, please explain why the referenced entities load requirements are included in Avista’s system requirements.
RESPONSE: Avista does not provide electric services to the referenced PUDs and Direct Service customers. These referenced PUDs and Direct Service customers are within our BAA (Balancing Authority Area). Avista provides them with balancing services and Avista needs to include the load and
generation amounts for these referenced PUDs and Direct Service customers that are in our BAA
for the purposes of operational reserves for balancing load and generation.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IFG RESPONDER: John Gibson TYPE: Production Request DEPARTMENT: Innovation
REQUEST NO.: IFG-037 TELEPHONE: [phone] REQUEST: Reference Avista’s response to Staff Production Request 22, Attachment A: Please identify the
purpose of the lease at the Scott Morris Center and provide detail of each employee who works the leased location.
RESPONSE:
Avista’s Innovation Lab leases space from the third floor of the Scott Morris Center for Innovation. Avista Innovation lab was founded upon the utilities mission to “…improve our customers’ lives through innovated energy solutions”. Avista’s Innovation Lab goal is to operationalize power electronic devices and technology platforms to operate reliable, safely and
affordably on our system. Within the last year, Avista’s power system had over a thousand power
electronic devices installed on our system by third party owners. To ensure safe, reliable and affordable service, Avista’s Innovation Lab is developing the standards, work practices and design artifacts required to enable our professional and craft workers to operate the system to host these power electronic devices.
Avista Innovation Lab has deployed a real-time digital environment to support control and power hardware in the loop simulations to validate the operational characteristic of these power electronic devices on the power delivery system. Avista Innovation Lab employees four engineers
and one data scientist to ensure the power electronic devices adhere to the State and utility
requirements for power quality, voltage stability and safe work practices. Avista Innovation Lab enables the design and training requirements for operational staff to efficiently deploy and operate power electronic devices and technology platforms prior to field deployment. With the acceleration of these power electronic devices, Avista has the obligation to ensure these devices
due not disrupt or impede the deployment of energy commodities to our customers. The Avista Innovation Lab employs an engineering manager, three electrical engineers, and one data analyst.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kevin Christie REQUESTER: IFG RESPONDER: Mark Gustafson TYPE: Production Request DEPARTMENT: Avista Edge
REQUEST NO.: IFG-038 TELEPHONE: [phone] REQUEST: Reference Avista’s response to Staff Production Request 22, Attachment A: Please identify the
amount Avista has invested in the Scott Morris Center and neighboring properties. Please also provide a general description of Avista’s involvement in the development. RESPONSE:
As a part of the Washington Department of Commerce Clean Energy Fund III (CEFIII)
project, Avista Utilities is deploying thermal and electric storage assets in the Morris Center central plant to improve utilization of the electric delivery system. The CEFIII project installed phase state thermal storage, DC bus, electric storage and AC switchboard for approximately $5.4 million. The phase state thermal storage allows the energy plant to pre-cool the building to offset
the peak load. The DC buss operates as a combiner to aggregate the DC solar and storage behind
the meter. Electric storage supports the storing of solar generated energy behind the meter. The AC switchboard supports the utility metering for the energy district.” The total gross investment by Avista Development, Inc. in the 4 entities that make up the Catalyst
project is: $16,414,449.47. The cost of these assets are not included as Avista Utility rate base impacting customers. South Landing Building A LLC
Grand Total $ 7,428,535.58

611 E Sprague, LLC

Grand Total $ 2,300,000.17

Spokane ECO District I, LLC

Grand Total $ 2,400,000.00

521 E Sprague, LLC

Grand Total $ 2,225,000.00

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-039 TELEPHONE: [phone] REQUEST: Reference Avista’s response to Staff Production Request 33: Please identify the rate base of the
hangar and jet included in revenue requirement, including separate detail for Gross Plant, Accumulated Depreciation, and Accumulated Deferred Taxes. RESPONSE:
Please see table below showing the detail of plane and hangar’s gross plant, accumulated
depreciation, and accumulated deferred federal income taxes (ADFIT) on a system basis and the amounts allocated to Idaho Electric and Idaho Natural Gas included in the revenue requirement for Rate Year 1 (9/1/2023 – 8/31/2024) and Rate Year 2 (9/1/2024 – 8/31/2025).
Pro Forma
Rate Year 1
AMA Balance
ID Electric
Allocation
ID Natural Gas
Allocation
Plane 23.68%5.59%
Cost (Gross Plant)5,507,887$ 1,304,384$ 307,869$
Accumulated Depreciation*(4,233,792) (1,002,652)$ (236,652)$
ADFIT Liability (included in 282900)**(333,682) (79,023)$ (18,651)$
Plane Net Book Value 940,413$ 222,710$ 52,565$
Hangar
Cost (Gross Plant)2,138,350$ 506,407$ 119,525$
Accumulated Depreciation*(162,139) (38,398)$ (9,063)$
ADFIT Liability (included in 282900)**(28,247) (6,689)$ (1,579)$
Plane Net Book Value 1,947,964$ 461,319$ 108,883$
Total Rate Base 2,888,378$ 684,029$ 161,449$
Total Rate Base Included in Revenue Requirement (Rate Year 1)684,029$ 161,449$
Pro Forma
Rate Year 2
AMA Balance
ID Electric
Allocation
ID Natural Gas
Allocation
Plane 23.68%5.59%
Cost (Gross Plant)5,507,887$ 1,304,384$ 307,869$
Accumulated Depreciation*(4,422,712) (1,047,392)$ (247,212)$
ADFIT Liability (included in 282900)**(333,682) (79,023)$ (18,651)$
Plane Net Book Value 751,493$ 177,969$ 42,005$
Hangar
Cost (Gross Plant)2,138,350$ 506,407$ 119,525$
Accumulated Depreciation*(135,071) (31,988)$ (7,550)$
ADFIT Liability (included in 282900)**(28,247) (6,689)$ (1,579)$
Plane Net Book Value 1,975,032$ 467,729$ 110,396$
2,726,525$ 645,699$ 152,402$
Total Rate Base Included in Revenue Requirement (Rate Year 2)645,699$ 152,402$
*The depreciation expense that impacts accumulated depreciation is calculated using the authorized depreciation rates
because the proposed rates included in the case have not been approved by the Parties. The difference is not material.
**ADFIT is not forecasted at this level of detail, therefore we used the actual ADFIT balances for the Plane and Hangar as of
6/30/2022 for this response as we do not expect it to change materially throughout the rate years.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Marcus Garbarino REQUESTER: IFG RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-040 TELEPHONE: [phone] REQUEST: Reference Avista’s response to IFG Production Request 19: Please provide the hourly generation
from the Schedule 25P generation resource over the period July 1, 2021, through December 31, 2022.
RESPONSE: Please see Avista's response IFG_PR_040C, 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 “IFG_PR_040C Confidential Attachment A” which includes the hourly generation from Schedule 25P generation resource over the period July 1, 2021, through December 31, 2022.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Marcus Garbarino REQUESTER: IFG RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-040C TELEPHONE: [phone] REQUEST: Reference Avista’s response to IFG Production Request 19: Please provide the hourly generation
from the Schedule 25P generation resource over the period July 1, 2021, through December 31, 2022.
RESPONSE: Please see the Attachment provided, 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 “IFG_PR_040C Confidential Attachment A” which includes the hourly generation from Schedule 25P generation resource over the period July 1, 2021, through December 31, 2022.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/08/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-041 TELEPHONE: [phone] REQUEST: Reference Shultz workpaper “3.14 Reg Deferrals Amortization Adj:” Please identify the
Commission order where the regulatory asset of $699,119 for the EIM was approved. RESPONSE: As noted in Company witness Schultz testimony:

Avista Case No. AVU-E-20-01 (Order No. 34606 dated March 23, 2020) allowed the Company to defer, with no carrying charge, its Idaho jurisdictional incremental O&M costs associated with joining the California Independent System Operator’s (CAISO) Western Energy Imbalance Market (EIM) until the go-live date. This
adjustment proposes the approximately $699,000 of Idaho electric deferred costs,
as of June 30, 2022, recorded in FERC Account 182334 – Regulatory Asset EIM be included in base rates and amortized for recovery over two years beginning September 1, 2023.
Within Case No. AVU-E-20-01, Order No. 34606, the Commission noted “A prudency review of the deferred expenses will occur before the Company is allowed to recover any Idaho jurisdictional incremental O&M costs associated with joining the EIM.” Further, in Case No. AVU-E-22-11, Annual Power Cost Adjustment (PCA) Application for the
period July 1, 2021 through June 30, 2022 Review Period, the Commission noted at page 3 of Order 35543, the following: “…the Commission finds the Company’s various power cost transactions were reasonable, prudently incurred, and complied with previous Commission orders
and the Company’s risk management principles. The Commission also finds it just and reasonable to authorize the Company to continue to recover EIM incremental expenses in the PCA, up to the benefits
realized from the EIM. Staff verified the Company’s calculations of these
expenses, but the Commission will require the Company to further explain its methodology for measuring EIM benefits, and how that method differs from CAISO’s method. The Commission acknowledges that it gave the Company authority in Order No. 35156 to reflect Idaho’s share of incremental EIM and O&M
expenses through the PCA, up to Idaho’s share of EIM benefits that flow through the PCA, effective as of the March 1, 2022 “go live” date. In consideration of the Company’s comments and Commission precedent, we will continue the current method of addressing this matter in the PCA process.”

Based on prior Commission Orders as noted above, the Company deferred its Idaho share of incremental EIM expenses which occurred beginning in 2021 through the “go-live” date of March
1, 2022. Beginning March 1, 2022, at the “go-live” date, the Company began passing its EIM
expenses through the PCA, up to the EIM benefits also passing through the PCA. Beyond March 1, 2022, no further deferral of EIM expenses has occurred, as EIM benefits have been greater than EIM expenses.
The Company is therefore requesting in this proceeding, the recovery of the deferred incremental EIM expenses deferred by the Company through March 1, 2022 of $699,119, over a two year amortization period included in the Company’s Two-Year Rate Plan. See IFG_DR-041 Attachment A for monthly data.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Jeanne Pluth TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-042 TELEPHONE: [phone] REQUEST: Reference Shultz workpaper “1)12A-2022.06_Working Capital_PULL:” Please provide a fully
functional working capital model necessary to support all of the hard coded numbers in the referenced workpaper. Please provide the model in excel format with all formulas and links intact.
RESPONSE:
The workpaper “1)12A-2022.06_Working Capital_PULL:” is the model that supports the working capital in this case. The Company utilizes software called UIPlanner to prepare the working capital amounts. This software imports all GL accounts and computes averages, groups them according to authorized method and calculates allocations. The program then exports the report
that the Company uses as working capital back up. This process has been used for the past 10
years. It would be too time consuming to prepare a report from the GL that would produce the same result.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Jeanne Pluth TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-043 TELEPHONE: [phone] REQUEST: Reference Shultz workpaper “1)12A-2022.06_Working Capital_PULL:” Please provide Avista’s
most recent lead lag study. RESPONSE: Avista does not prepare a lead/lag study for the Company for Idaho. The Idaho Commission has
approved the ISWC (Investor Supplied Working Capital) Method in Idaho, and those work papers
have been provided in the filed case. The Oregon Commission has approved the lead/lag study method for Oregon. The lead/lag study most recently prepared for Oregon is attached as IFG_PR_043 Attachment A. All of the data in the Oregon lead/lag study is Oregon data, therefore it cannot be updated for Idaho. It is a voluminous undertaking to prepare the Oregon Lead Lag
Study alone, so preparation of an Idaho specific lead/lag study is not feasible.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-044 TELEPHONE: [phone] REQUEST:
Reference “4. Kaylene Schultz Workpapers\2.05 FIT&DFIT EXPENSE\4) ITC AMORT”: Please provide a description of the specific investments that Avista made in order to recognize the investment tax credits in the referenced workpaper. If available, please provide details of the ITC eligible investments by FERC account and year placed in service.
RESPONSE: The Noxon ITC was recognized on the replacement of the turbines. Unit 1 was placed in service in 2009, Unit 2 was placed in service in 2011, Unit 3 was placed in service in 2010, and Unit 4 was
placed in service in 2012.
The Nine Mile ITC was recognized on the replacement of the turbine and generator of Units 1 and 2 and was placed in service in 2016.
This information is not available by FERC account.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Megan Kennedy TYPE: Production Request DEPARTMENT: Tax
REQUEST NO.: IFG-045 TELEPHONE: [phone] REQUEST: Referenced Avista’s response to IFG Production Request 27, Attachment C: Please provide an
updated version of the referenced workpaper incorporating the results of the new depreciation study. RESPONSE:
See IFG_PR_045 Attachment A for an estimate of the 2024 and 2025 excess deferred turnaround
after incorporating the proposed new depreciation study. Please note, this calculation is an estimate as the depreciation study has not been approved by the Utility Commission and new depreciation rates are still subject to change. See IFG_PR_045 Attachment B for revised PF EDIT (RSGM) Adjustment 3.07 reflecting the results of the proposed depreciation study.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Marcus Garbarino REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-046 TELEPHONE: [phone] REQUEST:
Reference “4. Kaylene Schultz Workpapers\3.12 - 24.06 PF REVENUE & O&M OFFSETS\2) Electric New Customer Revenue ID PF.xlsx”. Please provide updated customer counts by rate schedule and month over the period July 2022 through March 2023.
RESPONSE: Please see “IFG_PR_046 Attachment A” for the requested customer counts by rate schedule and month over the period July 2022 through March 2023.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Marcus Garbarino REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-047 TELEPHONE: [phone] REQUEST:
Reference “4. Kaylene Schultz Workpapers\2.07 REVENUE ADJ \Normalized Usage by Month 12ME 202206 11.7.22,” Tab “Meters,” Excel Row “140:” Please provide an explanation of the purpose of the line item “ID Sch 21/25 Shifting” and describe how that line item affects the revenue forecast in this proceeding.
RESPONSE: The purpose of that line is to account for customer moving between schedules. The values of one meter shifting from Schedule 21 to Schedule 25 in 8 of the 12 months during the test period was an
inadvertent error; there was no shifting that occurred during the test period. The only calculation
depended on these cells are in excel Line 122 on the “Summary” tab in the same workbook which is the total number of Non-Residential Group Customers that is used to calculate the Non-Residential Group Normalized Use per Customer during the test year. Because it was only one customer during those months out of an average of ~25 thousand customers per month, there is
no impact from the inadvertent error in this workbook or the revenue forecast in this proceeding.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Marcus Garbarino REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-048 TELEPHONE: [phone] REQUEST:
Reference “4. Kaylene Schultz Workpapers\2.07 REVENUE ADJ \Normalized Usage by Month 12ME 202206 11.7.22,” Tab “summary:” Please provide actual, unadjusted monthly usage by rate class over the period July 1, 2022, through March 31, 2023.
RESPONSE: Please see “IFG_PR_048 Attachment A” which includes the unadjusted billed monthly usage over the period July 1, 2022, through March 31, 2023.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Grant Forsyth REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-049 TELEPHONE: [phone] REQUEST:
Please provide Avista’s most recent electric sales (kWh) forecast by rate schedule, including monthly detail of customer counts and usage through December 31, 2025. RESPONSE:

Please see Avista’s response to IFG_PR_008. In that response, the most recent electric sales forecast by rate schedule, including customer counts through December 2027 was provided on the tab labeled “Bill Determ” in “IFG_PR_008C_Confidential – Attachment B”.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Grant Forsyth REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-050 TELEPHONE: [phone] REQUEST: Reference “4. Kaylene Schultz Workpapers\2.07 REVENUE ADJ \Normalized Usage by Month
12ME 202206 11.7.22,” Tab “Weather Adjustment,” Excel Row “5”: Please provide fully functional workpaper used to calculate the Idaho weather adjustment detailed on the referenced row.
RESPONSE: The data in the referenced row is a sum of the data input in rows 12 through 15 in the Tab “Weather Adjustment”. Those rows are an input from the Garbarino workpaper labeled “Weather Adj Calculation 12ME 202206” on Tab “Summary for Normalized Usage WB,” Excel Rows 18
through 21. That fully functional workpaper was provided with the original filing and is being
provided as “IFG_PR_050 Attachment A” with this production request.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Grant Forsyth REQUESTER: IPUC RESPONDER: Grant Forsyth TYPE: Production Request DEPARTMENT: Fin. Planning & Analysis
REQUEST NO.: IFG-051 TELEPHONE: [phone] REQUEST: Please provide monthly historical electric sales (kWh) and customer counts by rate schedule and
weather zone (as used in Avista’s weather normalization model) over the period 2013 through 2022 (inclusive). RESPONSE:

Please see Avista's response IFG_PR_051C, 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.
The full forecast for Spring 2023 is attached as “IFG_PR_051C Confidential Attachment A”. This
file contains the detailed customer and usage data for Washington and Idaho. Actual and forecast data since 2012 can be found in the tab, “Spring 2023 Forecasts.” Similar data would have also been provided as part of the Idaho weather normalization procedure proposed in this rate case by Dr. Grant Forsyth. This data in the weather normalization submission would include customer
counts, load, and degree days between 2012 and 2022.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Grant Forsyth REQUESTER: IPUC RESPONDER: Grant Forsyth TYPE: Production Request DEPARTMENT: Fin. Planning & Analysis
REQUEST NO.: IFG-051C TELEPHONE: [phone] REQUEST: Please provide monthly historical electric sales (kWh) and customer counts by rate schedule and
weather zone (as used in Avista’s weather normalization model) over the period 2013 through 2022 (inclusive). RESPONSE:

Please see the Attachment provided, 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.
The full forecast for Spring 2023 is attached as “IFG_PR_051C Confidential Attachment A”. This
file contains the detailed customer and usage data for Washington and Idaho. Actual and forecast data since 2012 can be found in the tab, “Spring 2023 Forecasts.” Similar data would have also been provided as part of the Idaho weather normalization procedure proposed in this rate case by Dr. Grant Forsyth. This data in the weather normalization submission would include customer
counts, load, and degree days between 2012 and 2022.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Grant Forsyth REQUESTER: IFG RESPONDER: Grant Forsyth TYPE: Production Request DEPARTMENT: Fin. Planning & Analysis
REQUEST NO.: IFG-052 TELEPHONE: [phone] REQUEST: Please provide actual monthly average temperatures and degree days by weather zone over the
period 2013 through 2022 (inclusive). RESPONSE:
The base temperature data (daily) for Spokane International Airport are attached in the Excel file,
“IFG_PR_052 Attachment A”. This data is used to calculate the monthly total of heating and cooling degree days for a 65 degree Fahrenheit base. The resulting heating degree day (HDD) and cooling degree day (CDD) calculations for each month are contained in the attached Excel file, “IFG_PR_052 Attachment B”. Note that there are two degree day calculations. The tab, “WA and
ID HDD and CDD Data” shows the true calendar month degree days, which are used for weather
normalization of the calendarized load data (see Dr. Grant Forsyth’s testimony regarding this proposed weather normalization procedure). The tab, “WA and ID Billing Cycle Adj. DD” shows an adjustment to calendar degree days to adjust for the billing cycle. These adjusted degree days are used for the regression models using non-calendarized, billed customer data.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Grant Forsyth REQUESTER: IPUC RESPONDER: Grant Forsyth TYPE: Production Request DEPARTMENT: Fin. Planning & Analysis
REQUEST NO.: IFG-053 TELEPHONE: [phone] REQUEST: Please provide average temperatures and degree days by weather zone used in Avista’s revenue
normalization calculation. Please also identify the period over which the averages were calculated and provide the historical data necessary to recalculate the averages. RESPONSE:

See also response to IFG_PR_52. The definition of normal weather is the average heating and cooling degree days for the last 20 years. This average is moved up each time a new calendar year of temperature data is added. The average calendar years for starts in cell A99 (heating degree days, HDD) and R99 (cooling degree days, CDD) in the tab, “WA and ID HDD and CDD Data” in
the Excel file, “IFG_PR_052 Attachment B” attached with the response to IFG_PR_52. The
assumption of normal weather submitted by Dr. Grant Forsyth for the proposed weather normalized was done using the 2002-2021 average for normal weather. Since the end of 2022, the definition of average weather shifted to the 2003-2022 average. Note that this a average is also calculated using the billing period adjusted degree days. This calculation starts in in cell A97
(HDD) and AE97 (HDD) in the tab, “WA and ID Billing Cycle Adj. DD” in the Excel file,
“IFG_PR_052 Attachment B”.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kenny Dillon REQUESTER: IFG RESPONDER: Kenny Dillon TYPE: Production Request DEPARTMENT: Transmission Services
REQUEST NO.: IFG-054 TELEPHONE: [phone] REQUEST:
Reference Avista’s 2021 Transmission Rate Filing in ER21-02198: Please provide an updated version of Exhibit AVA-500, Statement BB - Allocation Demand and Capability Data based on transmission system demands for 2022.
RESPONSE: Please see IFG_PR_054-Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/15/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kenny Dillon REQUESTER: IFG RESPONDER: Kenny Dillon TYPE: Production Request DEPARTMENT: Transmission Services
REQUEST NO.: IFG-055 TELEPHONE: [phone] REQUEST:
Please describe Avista’s method for segregating transmission and distribution services for purposes of establishing Open Access Transmission Tariff rates.
RESPONSE:
For the purposes of developing Avista’s FERC approved rates for customers taking service under Avista’s Open Access Transmission Tariff, all assets operated at 100 kV or above are included, with the following exceptions:

- All non-transmission FERC accounts are excluded - All Colstrip transmission facilities, regardless of voltage, are accounted for separately - All step-up transformers, which are assigned to the generator they interconnect
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IFG RESPONDER: Tia Benjamin TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-056 TELEPHONE: [phone] REQUEST: 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: Please see Avista's response IFG_PR_056C, 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.

The as-filed information was provided with the original provided workpapers of witness Ms. Schultz. For ease of reference, this file is being provided again as IFG_PR_056C Confidential Attachment A. As discussed by Ms. Schultz’s direct testimony, the Company adjusts test period labor expense (12ME 06.30.2023) by incremental labor %’s for union and non-union, approved by
contract or the Board of Directors, annualizing actual 2022 %’s increases, including actual
2023%’s increases, approved 2024 increases, and expected 2025 increases. The effect of these increases are included, with results shown for the Rate Year 1 and Rate Year periods (pro-rated by rate year) in IFG_PR_056C Confidential Attachment A, tabs “Electric” and “Natural Gas”.
See also Avista’s response to Staff_PR_185C and Staff_PR_185C Confidential Attachment F -
3.01 Non-Executive Labor Adjustment for the updated labor adjustment utilizing actual data as of 12.31.2022. This update provides the incremental increase in labor as a result of comparing actual 12ME 06.30.2022 labor expense plus increases for 2023-2025, versus 12ME 12.31.2022 actual labor expense plus incremental increases for 2023-2025 – the difference in expense totaling
$382,000 in RY1 for Idaho electric, and $220,000 in RY1 for Idaho natural gas. The incremental
amount in RY2 of $13,000 (electric) and $8,000 (natural gas) is immaterial, and therefore was ignored at this time.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IPUC RESPONDER: Tia Benjamin TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: IFG-056C TELEPHONE: [phone] REQUEST: 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: Please see the Attachment provided, 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.

The as-filed information was provided with the original provided workpapers of witness Ms. Schultz. For ease of reference, this file is being provided again as IFG_PR_056C Confidential Attachment A. As discussed by Ms. Schultz’s direct testimony, the Company adjusts test period labor expense (12ME 06.30.2023) by incremental labor %’s for union and non-union, approved by
contract or the Board of Directors, annualizing actual 2022 %’s increases, including actual
2023%’s increases, approved 2024 increases, and expected 2025 increases. The effect of these increases are included, with results shown for the Rate Year 1 and Rate Year periods (pro-rated by rate year) in IFG_PR_056C Confidential Attachment A, tabs “Electric” and “Natural Gas”.
See also Avista’s response to Staff_PR_185C and Staff_PR_185C Confidential Attachment F -
3.01 Non-Executive Labor Adjustment for the updated labor adjustment utilizing actual data as of 12.31.2022. This update provides the incremental increase in labor as a result of comparing actual 12ME 06.30.2022 labor expense plus increases for 2023-2025, versus 12ME 12.31.2022 actual labor expense plus incremental increases for 2023-2025 – the difference in expense totaling
$382,000 in RY1 for Idaho electric, and $220,000 in RY1 for Idaho natural gas. The incremental amount in RY2 of $13,000 (electric) and $8,000 (natural gas) is immaterial, and therefore was ignored at this time.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 5/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Elizabeth Andrews REQUESTER: IFG RESPONDER: Bob Brandkamp TYPE: Production Request DEPARTMENT: Risk Management
REQUEST NO.: IFG - 057 TELEPHONE: [phone] REQUEST: 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:
Please see Avista's response IFG_PR_057C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
a. The most recent date that the policy was renewed.
• General Liability - 12/31/22
• Directors and Officers - 3/31/23
• Property - 12/1/22
• Cyber - 10/17/22
• Colstrip - Talen, the operator of Colstrip manages the insurance program. Avista
does not have the current date(s) of policies associated with Colstrip insurance
program. Other Avista expenses related to Colstrip are related to surety bonds in place for clean up remediation.
• Workers’ Comp - 1/1/23
b. The most recent renewal premium, both with and without continuity credits
• See Confidential Adj. 3.06 - ID GRC PF Insurance Adj - Revised 4 24 23 as referenced in 151C for details on most recent premiums and continuity credits associated with each line of insurance.
c. The renewal statements and policy documents (See Confidential Folder IFG_PR_5C Confidential Attachment A)
• Invoices included are as follows: o IFG - 57 INV1 - Property o IFG - 57 INV1 - 9 - Liability
o IFG - 57 INV1-2 - D and O
o IFG - 57 INV1-2 - Workers Comp o IFG - 57 INV1 - Cyber
o IFG - 57 INV1-3 Colstrip Surety Bonds (Risk Management does not receive invoices for the monthly allocation by Talen for insurance expenses related to
Colstrip.)

• Policy documents included are as follows: o IFG - 57 POL1 - 9 - Property (IFG - 57 POL4 - Property is AIG policy from
12/1/22 renewal. AIG policy from 12/1/22 has not yet been received from the insurance company.)
o IFG - 57 POL1 - 7 - Liability o IFG - 57 POL1-8 - D and O (2022 policies as 2023 policies have not been issued. Same insurance companies and limits as of 2023.)
o IFG - 57 POL1-2 - Workers Comp
o IFG - 57 POL1 - Cyber
o Colstrip - Insurance managed by Colstrip operator, Talen. Avista does not have copies of these property policies.
d. The policy coverages, limits, deductibles, and other relevant terms associated with the policy. See policies provided in response to question c. above.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 5/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Elizabeth Andrews REQUESTER: IFG RESPONDER: Bob Brandkamp TYPE: Production Request DEPARTMENT: Risk Management
REQUEST NO.: IFG – 057C TELEPHONE: [phone] REQUEST: 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:
Attachments to Avista's response to IFG 057C, contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and are filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
a. The most recent date that the policy was renewed.
• General Liability - 12/31/22
• Directors and Officers - 3/31/23
• Property - 12/1/22
• Cyber - 10/17/22
• Colstrip - Talen, the operator of Colstrip manages the insurance program. Avista
does not have the current date(s) of policies associated with Colstrip insurance
program. Other Avista expenses related to Colstrip are related to surety bonds in place for clean up remediation.
• Workers’ Comp - 1/1/23
b. The most recent renewal premium, both with and without continuity credits
• See Confidential Adj. 3.06 - ID GRC PF Insurance Adj - Revised 4 24 23 as referenced in 151C for details on most recent premiums and continuity credits associated with each line of insurance.
c. The renewal statements and policy documents (See Confidential Folder IFG_PR_5C Confidential Attachment A)
• Invoices included are as follows: o IFG - 57 INV1 - Property
o IFG - 57 INV1 - 9 - Liability
o IFG - 57 INV1-2 - D and O
o IFG - 57 INV1-2 - Workers Comp o IFG - 57 INV1 - Cyber
o IFG - 57 INV1-3 Colstrip Surety Bonds (Risk Management does not receive invoices for the monthly allocation by Talen for insurance expenses related to
Colstrip.)

• Policy documents included are as follows: o IFG - 57 POL1 - 9 - Property (IFG - 57 POL4 - Property is AIG policy from
12/1/22 renewal. AIG policy from 12/1/22 has not yet been received from the insurance company.)
o IFG - 57 POL1 - 7 - Liability o IFG - 57 POL1-8 - D and O (2022 policies as 2023 policies have not been issued. Same insurance companies and limits as of 2023.)
o IFG - 57 POL1-2 - Workers Comp
o IFG - 57 POL1 - Cyber
o Colstrip - Insurance managed by Colstrip operator, Talen. Avista does not have copies of these property policies.
d. The policy coverages, limits, deductibles, and other relevant terms associated with the policy. See policies provided in response to question c. above.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IFG RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: IFG-059 TELEPHONE: [phone] REQUEST: 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:
The revenue line item 81 should be netted with the natural gas fuel purchases in line item 25. The net of these represents the extent to which we didn’t use transport capacity and sold the excess. Therefore, the test year amount of $7.551 million is more in line with the pro forma amount of $7.796 million when compared in total. See table below.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IFG RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: IFG-060 TELEPHONE: [phone] REQUEST: Reference Kalich Exhibit 7: Please identify the amount of gas optimization revenues included in
revenue requirement and explain how those benefits are calculated.
RESPONSE:
In the confidential workpaper “Confidential Exh No 7 – Sch 1C – 5 01.09.2022.xlsx” on the tab, Schedule 2 RY1. The revenue line item 81 should be netted with the natural gas fuel purchases in line item 25. The net of these represents the extent to which we didn’t use transport capacity and sold the excess. Therefore, the test year amount of $7.551 million is more in line with the pro
forma amount of $7.796 million when compared in total. The modeled pro forma has less
optimization revenue in the form of AECO to Malin gas sales due to much higher utilization of the transportation to fuel our gas plants that operate at much higher levels in the pro forma period.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IFG RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: IFG-064 TELEPHONE: [phone] REQUEST: Reference Kalich 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: a) Please refer to workpaper ‘Confidential Exh No 7 Schedule 1C – 5 01.09.2022.xlxs’, specifically tab ‘Confidential Idaho CCA Costs’ that was provided with the case filing.
b) Allowances are allocated between Idaho and Washington using the Production Transmission
Allocation factor, where 34.47 percent of system costs would be allocated to Idaho.
c) The Washington portion of allowances would be covered by free allowances.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IFG RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: IFG-069 TELEPHONE: [phone] REQUEST: Reference Kalich 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:
Please see Avista's response IFG_PR_069C, 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.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IFG RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: IFG-069C TELEPHONE: [phone] REQUEST: Reference Kalich 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:
Avista's response to IFG-069C, contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and are filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
The Clearwater line item shown on Schedule 2 is based on the test year annual actuals and
represents 458,875 MWh. Clearwater is directly assigned to Idaho.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IFG RESPONDER: Elizabeth Arnold TYPE: Production Request DEPARTMENT: IT
REQUEST NO.: IFG-079 TELEPHONE: [phone] REQUEST: 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: To date, Avista has not submitted a grant application under the Inflation Reduction Act (IRA)
since Avista is not eligible for most opportunities, primarily because the IRA focuses on tax
benefits. Avista has submitted grants under the Infrastructure Investment and Jobs Act (IIJA) as stated in the response to Staff_PR_047. We expect the IRA will benefit our customers and communities through additional tax credits for energy efficiency measures and transportation electrification, as well as through grant opportunities for Tribes and non-profits through the
recently announced Greenhouse Gas Reduction fund. In addition, we will evaluate both direct and
indirect opportunities available through the IRA in our business operations and during our bi-annual Integrated Resource Planning. Most recently, we were able to secure a lower price for the 100MW wind project from our recent all-source RFP due to the IRA.