20230406Staff 52-93 to AVU Redacted.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 6 PÑ fé 33POBOX83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.98 10
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )CASE NO.AVU-E-23-01
AVISTA CORPORATION FOR THE )AVU-G-23-01
AUTHORITY TO INCREASE ITS RATES AND )CHARGES FOR ELECTRIC AND NATURAL )REDACTED THIRD
GAS SERVICE TO ELECTRIC AND NATURAL )PRODUCTION REQUESTOF
GAS CUSTOMERS IN THE STATE OF IDAHO.)THE COMMISSION STAFF
)TO AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Avista Corporation dba Avista Utilities
("Avista"or the "Company")provide the followingdocuments and information as soon as
possible,but no later than THURSDAY,APRIL 27,2023.
This Production Request is to be considered as continuing,and Avista is requested to
provide,by way of supplementary responses,additional documents that it,or any person acting
on its behalf,may later obtain that will augment the documents or information produced.
Please provide answers to each question;supporting workpapers that provide detail or are
the source of information used in calculations;and the name,job title,and telephone number of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 1 APRIL 6,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.52:The impacts of the Washington Climate Commitment Act ("CCA")
started on January 1,2023.Please explain whether those impacts of CCA from January 1,2023,
through September 1,2023,are reflected in this case.
REQUESTNO.53:Please explain how the Department of Ecology in Washington
determines free allowances for Avista's electric utility service.Specifically,please respond to
the following:
a.Please explain whether the number of free allowances is initiallybased on
Avista's Integrated Resource Plan ("IRP")forecasts and how it is determined;and
b.Please explain whether there is a subsequent annual true-up to the number of free
allowances based on the actual hydro conditions,where expected thermal plants,
and/or imports,may be needed to make up for the lost emission-free hydro
energy.
REQUESTNO.54:Please explain whether there are any scenarios where Washington
ratepayers will need to pay for allowances.If so,please explain when these occur.Specifically,
in the followingtwo scenarios,will Washington's allowance costs be covered by the free
allowances?
a.When Boulder Park exports to EIM and its allowance costs are allocated between
Washington and Idaho;and
b.When surplus thermal generationis imported into Washington for sale at Mid-C
from Lancaster,Rathdrum,Coyote Springs 2,and Colstrip,and their allowance
costs are allocated between Washington and Idaho.
REQUESTNO.55:The CCA requires a minimum of 30%of allowances to be retired
in the year that emissions occur with any balance due at the end of 2023-2026 Compliance
Period.Does the Company plan to retire the minimum or a higher percentage?Please explain
how the decision may affect Idaho's allowance costs.
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 2 APRIL 6,2023
REQUESTNO.56:Please list and describe all the methods in which the CCA
allowances can be obtained (such as auctions,bilateral,electronic exchange trading,and reserve
accounts).Because allowances obtainedthrough different methods have different prices,please
explain how the Company plans to coordinatethese methods to minimize allowance costs.
REQUESTNO.57:Please confirm that when there are not enough allowances,Avista
will have to pay a penalty to cover emissions at the price cap.If so,please explain how the cap
is determined.Also,please explain whether these allowance costs will only be assigned to
Idaho,since Washington's allowances are free.
REQUESTNO.58:Please list all the potential options available for Idaho to avoid
paying the compliance costs from an operational perspective and describe each option in detail.
Please include specific examples that do and do not wheel-through Mid-C.
REQUESTNO.59:What are the Department of Ecology's requirements for how the
free allowances can be used?Does Avista have any flexibilityon how free allowances can be
used?If so,please explain.
REQUESTNO.60:Page 8 of Kalich's Direct Testimony lists four categories of
emissions covered by the CCA with respect to Avista:
Category 1:Washington situs-based thermal plants (i.e.Boulder Park),
Category 2:Washington's multi-jurisdictionalshare of thermal plants located
outside of Washington State,
Category 3:Carbon-emitting thermal generation imported into Washington,and
Category 4:All non-specified electricity imported into Washington.
Please answer the following:
a.For Category 2,please explain whether "Washington's multi-jurisdictionalshare
of thermal plants located outside of Washington State"refers to Avista's share of
Lancaster,Rathdrum,Coyote Springs 2,and Colstrip;
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 3 APRIL 6,2023
b.Please explain whether there will be allowance costs charged to Idaho,when the
energy from Avista's share of Lancaster,Rathdrum,Coyote Springs 2,and
Colstrip is used to serve Idaho's native load;
c.Please explain whether the energy from Avista's share of Lancaster,Rathdrum,
Coyote Springs 2,and Colstrip will be covered by Washington's free allowances
when it is used to serve Washington's native load;
d.Please explain whether there is any allowance cost charged to Avista,when the
energy from Avista's share of Lancaster,Rathdrum,Coyote Springs 2,and
Colstrip is purchased by a third party at each plant;
e.For Category 3,please explain whether carbon-emitting thermal generation
imported into Washington applies to both the thermal plants owned by Avista and
the thermal plants no_t owned by Avista;
f.Please explain whether energy imported into Washington by Avista from a
thermal plant not owned by Avista is modeled in developing the net power costs
in this case;
g.For Category 4,please explain whether EIM energy imported into Washington is
non-specified electricity;and
h.For Category 4,please explain whether thermal energy generated by specific
thermal plants (owned or not owned by Avista)and imported into Washington are
all non-specific electricity.
REQUESTNO.61:Please respond to the followingregarding the Boulder Park plant:
a.Page 9 of Kalich's Direct Testimony states "Idaho load served by Washington
State-sited plants emitting above the law's 25,000 metric ton annual threshold (i.e.
Boulder Park)will incur a share of the costs to comply with the CCA."Please
explain how the shares will be actually determined;
b.Please explain how Boulder Park is modeled in AURORA to reflect Idaho's
allowance costs;
c.Please explain if there is any difference between how Boulder Park is modeled
and how non-Boulder Park thermal plants are modeled;
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 4 APRIL 6,2023
d.When Boulder Park's energy is used to meet Washington's native load,are there
any allowance costs incurred to Idaho;
e.When Boulder Park's energy is used to meet Idaho's native load,are there any
allowance costs incurred to Idaho;
f.Please explain if Washington's allowance costs will be covered by Washington's
free allowances,when Boulder Park's energy is used to meet Washington's native
load;
g.Please confirm that when Boulder Park's surplus energy is sold at Mid-C,
Washington's allowance costs are covered by free allowances,while Idaho's
allowance costs are assigned to Idaho;and
h.Please explain what is meant by "surplus energy"stated on Page 9 of Kalich's
Direct Testimony.Does the Company mean the extra energy after the generation
of each thermal plant meets Avista's (includingboth Washington's and Idaho's)
native load?
REQUESTNO.62:Page 11 of Kalich's Direct Testimony states,"CCA carbon
allowance compliance is therefore modeled in Aurora such that each thermal plant must
overcome in its dispatch the Idaho share of the assumed carbon allowance price,or about $23.87
per metric ton."Please respond to the following:
a.Please confirm that the only change Avista has made in this case to reflect the
impacts of CCA is addition of the allowance price to each thermal plant's total
cost in the dispatch;
b.Please explain why the thermal plant must overcome only the Idaho share of the
carbon price,instead of using the full price of $69.26/ton and provide evidence
that the result of this treatment will reasonably reflect allowance costs of the
emission amounts that Idaho should pay for;and
c.Please list each thermal plant's CCA compliance price assumed in the dispatch
model and explain how the cost for each plant is determined.
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 5 APRIL 6,2023
REQUESTNO.63:Tab "Conf Idaho CCA Costs"of the Excel file "Confidential Exh
No 7 -Sch IC -5 01.09.2022.xlsx"shows that
However,each Rate Year starts on September 1,instead of
the middle of a year.Please explain why the rate for each Rate Year does not reflect September
1 as a starting point.
REQUESTNO.64:Will each Rate Year's price be trued-up based on the actual
allowance prices?If so,when and how does Avista plan to true-up the prices?How will the
actual allowance prices be determined,given the fact that allowances can be purchased from
different sources?
REQUESTNO.65:Page 13 of Kalich's Direct Testimony states that the total CCA
compliance costs are modeled at $145 million for the two-year period.However,Page 11 states
that the CCA compliance costs are $70.5 million for Rate Year 1 and $84.1 million for Rate Year
2,resulting in a total of $154.6 million.Please reconcile the amounts.
REQUESTNO.66:Please provide a complete list of actual Failed Plant and Operations
Technology Failed Assets for June of 2021 to the end of 2022.For each failed asset,please
provide an explanation of why the asset failed outside of its anticipated life according to a
lifecycle management program.
REQUESTNO.67:Please provide a worksheet that has a detailed list of pro forma
Failed Plant and Operations Technology Failed Assets expenses for 2023 and 2024.
REQUESTNO.68:Kensok Direct at 13 describes that the Technology Failed Assets
program is intendedto support replacement of physical technology devices that fail prior to
being refreshed as part of a lifecycle management program.Expenditures for the program are
expected to increase from $171,000 in 2022 to $544,000 in 2023 and 2024,and $363,000 in
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 6 APRIL 6,2023
2025.Please explain the reasoning and provide documentation for the increase in forecasted
expenditures.
REQUESTNO.69:If assets are predicted to fail at a rate to justify such a large line
item as noted in Technology Failed Assets,then why isn't the lifecycle management program of
these devices adjusted accordingly?
REQUESTNO.70:Please explain and provide the Company's policies and procedures
that have been put in place to mitigate accidents,or other situations,that would result in early
replacement of technology assets.
REQUESTNO.71:Please provide the workpapers for Table No.1 in Kensok Direct at
9 from 2022 through 2025.
REQUESTNO.72:Please provide the workpapers for the pro forma adjustments from
2023-2025 for the Enterprise &Control Network Infrastructure program and its three separate
business cases;Enterprise Network Infrastructure,Control and Safety Network Infrastructure,
and Network Backbone Infrastructure.
REQUESTNO.73:Please provide the workpapers for the actual expenses from 2021-
2022 for the Enterprise &Control Network Infrastructure program.If any expenses of that
program were separated into any of the three business cases Enterprise Network Infrastructure,
Control and Safety Network Infrastructure,or Network Backbone Infrastructure within that time,
please identify those expenses by business case.
REQUESTNO 74:Please describe the top menu self-help options that are available to
customers using the Company's Interactive Voice Response system.Please provide the
utilization rate for each available option for the past three years (2020,2021 and 2022).
REQUESTNO.75:Please describe the self-help options that are available to customers
using the Company's website.For each of the past three years (2020,2021,and 2022),please
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 7 APRIL 6,2023
provide the utilization rate for each available option and the percentage of Idaho customers that
have established an online account?
REQUESTNO.76:Please provide the Company's performance objectives for handling
incoming calls.
REQUESTNO.77:What steps does the Company take if it fails to meet its
performance objectives?
REQUESTNO.78:Please provide the number of incoming calls handled by the
customer service call center by month for each of the past three years (2020,2021 and 2022).
REQUESTNO.79:Please provide the number of abandoned calls to the customer
service call center by month for each of the past three years (2020,2021 and 2022)."Abandoned
calls"are calls that reach the Company's incoming telephone system,but the calling party
terminates the call before speaking with a customer service representative.
REQUESTNO.80:Please provide the average speed of answer for the customer
service call center by month for each of the past three years (2020,2021 and 2022)."Average
speed of answer"is the interval (typically measured in seconds)between when a call reaches the
Company's incoming telephonesystem and when the call is picked up by a customer service
representative.
REQUESTNO.81:Please provide the service level for the customer service call center
by month for each of the past three years (2020,2021 and 2022)."Service level"is the
percentage of calls answered within a certain number of seconds,e.g.,80%of calls answered
within 20 seconds.
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 8 APRIL 6,2023
REQUESTNO.82:Please provide the average handling time by month for each of the
past three years (2020,2021 and 2022)."Average handling time"is the average amount of time
(usuallyexpressed in minutes)it takes for a customer service representative to talk with a
customer plus any additional "off-line"time it takes to complete the transaction or fully resolve
the customer's issue(s).
REQUESTNO.83:Please provide the average response time for e-mail transactions by
month for each of the past three years (2020,2021 and 2022)."Average response time"is the
average number of hours from receipt of an e-mail by the Company to sending a substantive
response;auto-response acknowledgements do not count as a substantive response.
REQUESTNO.84:Please provide the first call resolution rate by month for each of the
past three years (2020,2021 and 2022)."First call resolution rate"is the percentage of calls
where the transaction,inquiry,or complaint is resolved upon initial contact with the Company.
REQUESTNO.85:In Company Witness Hydzik's direct testimony,she describes the
Company's initiative regarding new tech-savvy generation.Please explain how you plan to
assure that the non-tech-savvy senior market segment is not left behind in your Customer Facing
Technology Program ("CFTP")and other Company technology-basedcustomer service
programs.Please explain if there are any initiatives to enhance this market segments customer
expenence.
REQUESTNO.86:Please explain if the Company will maintain the same staffmg
levels for direct-contact customer services for the market segments that do not choose or are
unable to use the new CFTP initiatives.
REQUESTNO.87:In Company Witness Hydzik's Exhibit No.12,Schedule 1,page 13
of 33,it describes "40%of all consumers now prefer self-service to live contact."Please explain
how the Company intends to address the remaining 60%of consumers that do not prefer these
self-service options.
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 9 APRIL 6,2023
REQUESTNO.88:Regarding the Company's response to Production Request No.33,
Staff_PR_33-AttachmentA,for the followingflights,please provide the flightlog,the
passengers on the flight,the purpose of the event,and the customer benefit:
a.Flight AVA062222,We are Avista Oregon Employee participation,FERC #
880000,$4760.00
b.Flight AVA102621,Test Flight,FERC #930200,$6600.00 coded as CD.AA;and
c.Flight AVAl20822,Washington Roundtable Board Meeting,FERC #930200,
$6885.00 coded as CD.AA
REQUESTNO.89:Regarding the Company's response to Production Request No.12,
Staff PR 012C Confidential Attachment A,please provide further explanation of the following
injuries and damages,and any other pertinent information:
a.$15,176.25:invoice L-1179943R;
b.$1,440.30:invoice L-ll95290R;
c.$532.71:invoice L-1081702R;
d.$1,008.16:invoice L-1261996R;
e.$3,805.66:invoice L-1275971R;
f.$17,096.72:invoice L-ll23663R;
g.$1,778.77:invoice L-1208350R;
h.$7,989.15:invoice L-1299477R;
i.$10,000.00:invoice L-1170800D;and
j.$218.30:invoice L-ll23708D
REQUESTNO.90:Please provide actual annual costs of distribution wood pole
management from years 2018-2022,and the percentage of poles inspected each year by state
jurisdiction with associated costs.Please provide the percentage of poles replaced in each year
by jurisdiction with associated costs.
REQUESTNO.91:Please provide actual annual costs of electrical storm related to
distribution from years 2018-2022.Please include total system costs,and the costs allocated to
each of the Company's jurisdictions.
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 10 APRIL 6,2023
REQUESTNO.92:Regarding Witness Schultz workpapers,there is a file provided
labeled"3.08-3.11 Capital additions".Within that worksheet there is a tab labeled "TTP Detail
22-25".Under the column "Business Cases",please provide actual annual costs of each business
case between years 2018-2022.Please also provide the allocation factors used to allocate the
costs.
REQUESTNO.93:Please provide data on downed trees causing damage to plant in
service in years 2018-2022.This should include date,location,cause of issue,classification of
plant damaged (distribution,transmission,etc.),total costs,allocation factor used,and any other
useful information.
DATED at Boise,Idaho,this ÍDF4day of April 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/avue23.l_avug23.lcbde prod req 3
REDACTED THIRD PRODUCTION REQUEST
TO AVISTA CORPORATION 11 APRIL 6,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF APRIL 2023,SERVED
THE FOREGOING REDACTED THIRD PRODUCTION REQUESTOF THE
COMMISSION STAFF TO AVISTA CORPORATION,IN CASE NOS.AVU-E-23-01/
AVU-G-23-01,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PATRICK EHRBAR DAVID J MEYER
DIR OF REGULATORY AFFAIRS VP &CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX 3727 PO BOX 3727
SPOKANE WA 99220-3727 SPOKANE WA 99220-3727
E-mail:[e-mail] E-mail:[e-mail]
[e-mail]
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27TH STREET EAGLE,ID 83616
BOISE ID 83702 E-mail:[e-mail]
E-mail:[e-mail]
Electronic Service Only:
[e-mail]
[e-mail]
[e-mail]
ANDREW P MORATZKA LARRY A CROWLEY
STOEL RIVES LLP THE ENERGY STRATEGIES INSTITUTE
33 SOUTH SIXTH STREET,SUITE 4200 3738 S HARRIS RANCH AVE.
MINNEAPOLIS,MN 55402 BOISE ID 83716
E-MAIL:andrew.moratzka stoel.com E-mail:[e-mail]
JUSTINA A.CAVIGLIA STEVE W CHRISS
PARSONS BEHLE &LATIMER DIRECTOR,ENERGY SERVICES
50 W.LIBERTY STREET,SUITE 750 WALMART INC
RENO,NV 89502 2608 SOUTHEAST J ST
E-MAIL:[e-mail] BENTONVILLE AR 72716
E-MAIL:[e-mail]
CERTIFICATE OF SERVICE
MARIE CALLAWAY KELLNER BRAD HEUSINKVELDIDCONSERVATIONLEAGUEIDCONSERVATIONLEAGUE
710 N 6TH ST 710 N 6TH ST
BOISE ID 83702 BOISE ID 83702
E-MAIL:mkellner idahoconservation.org E-MAIL:
[e-mail]
F DIEGO RIVAS
NW ENERGYCOALITION
1101 8TH AVE
HELENA MT 59601
E-MAIL:diego nwenerev.org
SECRETARY
CERTIFICATE OF SERVICE