20230411AVU to Staff 35-51.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/28/2023 CASE NO: AVU-E-23-01/AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IPUC RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff – 035 TELEPHONE: [phone] REQUEST:
Please provide any studies the Company has in its possession, or any studies the Company has reviewed on the electric and/or gas consumption of low-income customers.
RESPONSE: The Company does not have in its possession, nor has it reviewed, any such studies regarding the electric and/or gas consumption of its low-income customers in Idaho.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/28/2023 CASE NO: AVU-E-23-01/AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IPUC RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff – 036 TELEPHONE: [phone] REQUEST:
Please provide a schedule of rate cases in other states or by other subsidiaries of Avista Corp since January 1, 2020. If those rate cases were settled with a stated return on equity, please provide the stipulated return on equity.
RESPONSE: Please see Staff_PR_036 Attachment A for the requested information.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/03/2023 CASE NO: AVU-E-23-01/AVU-G-23-01 WITNESS: E. Andrews/D. Howell REQUESTER: IPUC RESPONDER: J. Webster / L. Andrews TYPE: Production Request DEPARTMENT: Finance
REQUEST NO.: Staff – 037 TELEPHONE: [phone] REQUEST:
Please provide a worksheet that details a list of all Operation and Maintenance ("O&M") expenses incurred for the Wildfire Resiliency Plan ("WRP") for July 1, 2020, to date. In your response, please provide vendor name, amount, date, FERC account number, a brief description of the expense, and breakdown expenses by rate year.

RESPONSE: Please see Staff_PR_037 Attachment A for the requested information.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/30/2023 CASE NO: AVU-E-23-01/AVU-G-23-01 WITNESS: Tia Benjamin/David Howell REQUESTER: IPUC RESPONDER: Kaylene Schultz TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff – 038 TELEPHONE: [phone] REQUEST:
Please provide a worksheet that details a list of all Capital expenses incurred for the WRP for July 1, 2020, to date. In your response, please provide vendor name, amount, date, FERC account number, a brief description of the expense, and breakdown expenses by rate year.
RESPONSE: Please refer to Staff_PR_038 Attachment A for the Wildfire Resiliency Plan (WRP) Business Case actual transfers-to-plant (TTP) detail by month for the period of January 1, 2020 through February 28, 2023.
This TTP detail includes items such as Business Case name, expenditure request (ER), ER description,
budgeted item (BI), BI description, amount transferred to plant by month on a system, Idaho electric and Idaho natural gas basis, service, jurisdiction, accounting period, and utility (FERC) account. As soon as available, the Company intends to update its capital additions workpapers related to Pro
Forma Capital Additions Adjustments 3.08 through 3.11 in RY1, and Pro Forma Capital Additions Adjustments 24.01 and 24.02 in RY2 for July 1, 2022 through February 28, 2023 actual TTP and a re-forecast of March 1, 2023 through December 31, 2023 pro forma TTP. TTP from January 1, 2024 through August 31, 2025 will remain unchanged from the Company’s direct filed case.

For additional information on March 2023 – August 2025 pro forma WRP capital additions, please see Staff_PR_040.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/04/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: E. Andrews/D. Howell REQUESTER: IPUC RESPONDER: Liz Andrews TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-039 TELEPHONE: [phone]
REQUEST:
Please provide a worksheet that has a detailed listing of the pro forma WRP O&M Expenses
for 2023, 2024, and 2025. RESPONSE: As noted in Ms. Andrews direct testimony, page 5, note 4:
After completion of the preparation of the Company’s revenue requirement in this proceeding, and completion of calendar year 2022 Wildfire Plan efforts, the Wildfire Plan capital additions and O&M expenses for 2023 – 2029 were revised to reflect lessons learned in 2022. Specifically, Wildfire capital additions and O&M
expenses were revised upward, impacting the Two-Year Rate Plan. The Company will update its requested level in RY1 for wildfire capital additions, expenses and its proposed baseline during the pendency of this general rate case to reflect the January 2023 Wildfire Plan, capital additions and revised Wildfire expense levels
as discussed by Mr. Howell.
And at Andrews note 13, page 16: Specifically, Wildfire O&M expenses were revised to $17.7 million, $16.5 million
and $15.3 million respectively, for the periods 2023, 2024 and 2025.
Please see PR_Staff_039 Attachment A for updated Pro Forma Wildfire expenses expected over the Two-Year Rate Plan (electric system and Idaho), which have been slightly refined to $17.1
million, $16.1 million and $14.9 million, respectively. The updated O&M expense pro-rated in Rate Year 1 results in total O&M wildfire expense of $15.95 million system (excluding labor/benefits), and $6.7 million Idaho share. The updated Idaho Wildfire Balancing Account proposed baseline, therefore is $6,732,000. The impact of updating wildfire expenses increases
overall wildfire expenses by approximately $2.096 million and increases the Company’s revenue
requirement associated with these expenses by $2.1 million. For updated Wildfire capital additions, see Avista’s responses to Staff_DR_038 for actual 2022 transfers-to-plant, and Staff_DR_040 for revised monthly 2023 expected transfers-to-plant (TTP).
A complete update for all actual 2022 capital additions (2022 monthly actual transfers to plant) and monthly expected 2023 capital additions (2023 monthly transfers to plant) data, along with updated electric and natural gas capital adjustments PF 3.08 through PF 3.11 in RY1, and adjustments PF 24.01 and PF 24.02 in RY2, will be provided as soon as available. These updates
will include actual transfer-to-plant July 1, 2022 through February 28, 2023, and a re-forecast of March 1, 2023 through December 31, 2023 pro forma TTP. TTP from January 1, 2024 through August 31, 2025 will remain unchanged from the Company’s direct filed case.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/03/2023 CASE NO: AVU-E-23-01/AVU-G-23-01 WITNESS: Tia Benjamin/David Howell REQUESTER: IPUC RESPONDER: Kaylene Schultz TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff – 040 TELEPHONE: [phone] REQUEST:
Please provide a worksheet that has a detailed listing of the proforma WRP Capital Expenses for 2023, 2024, and 2025. RESPONSE:

The Company provided a detailed listing of all pro forma capital additions, including the Wildfire Resiliency Plan (WRP) Business Case additions, for the period of July 1, 2022 through August 31, 2025 in its direct filed workpapers related to Pro Forma Capital Additions Adjustments 3.08 through 3.11 in RY1, and Pro Forma Capital Additions Adjustments 24.01 and 24.02 in RY2. Company witness Ms.
Benjamin sponsors these adjustments and related workpapers, while Mr. Howell discusses the need for
WRP capital additions in his direct filed testimony. As discussed in Staff_PR_038, as soon as available, the Company intends to update its capital additions workpapers related to Pro Forma Capital Additions Adjustments 3.08 through 3.11 in RY1, and Pro
Forma Capital Additions Adjustments 24.01 and 24.02 in RY2 for July 1, 2022 through February 28, 2023 actual transfers-to-plant (TTP) and a re-forecast of March 1, 2023 through December 31, 2023 pro forma TTP. TTP from January 1, 2024 through August 31, 2025 will remain unchanged from the Company’s direct filed case.

Please refer to Staff_PR_038, particularly Staff_PR_038 Attachment A, for actual WRP capital additions for January 1, 2020 through February 28, 2023. The Company has updated WRP 2023 capital additions with actuals for January 1, 2023 through February 28, 2023, and a re-forecast of March 1, 2023 through December 31, 2023. Capital additions for the pro forma period of January 1, 2024 through August 31,
2025 remain unchanged from the Company’s direct filed case. Please see Staff_PR_040 Attachment A
for WRP Business Case proforma capital additions for calendar years 2023-2025. Actuals are provided for January-February 2023 only.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: Shane Pacini TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-41 TELEPHONE: [phone] REQUEST: Please explain why the forecasted budget for the Dry Land Substation SCADA is expected to
nearly double in 2023 from 2022 actuals. Company witness Howell Exhibit 10, Schedule 1 at 29. RESPONSE: This was how internal funding and the project planning for Dry Land Substation SCADA was set
up over the 10-year Wildfire Resiliency plan, to gradually ramp up the project from conception to
completion for this portion of the overall expected funding. This was not due to scope increase or identification of more sites.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-42 TELEPHONE: [phone] REQUEST: In the WRP, the Company states there are 15 remote substations in high fire risk areas. WRP at 55.
a. Please provide the number of remote substations located in high fire risk areas that are in Idaho; and b. Please provide a worksheet detailing the actual Dry Land Substation SCADA costs for the 2022 calendar year including the name of each substation, allocation of costs for each
substation completed, and the state where each substation is located.
RESPONSE: a) Assuming by “remote” this refers to rural substations, there are 15 substations in Idaho that are located in high fire risk areas. These include Huetter, Rathdrum, Spirit Lake,
Grangeville, Orofino, Weippe, Big Creek, Bunker Hill, Osburn, Pine Creek, Wallace,
Lolo, Blanchard, and Oldtown. This does not include the St. Maries substation, which has already been completed. b) Please see Staff_DR_042 Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-43 TELEPHONE: [phone] REQUEST: Please explain why the forecasted budget for the Safe Tree program is expected to nearly double in
2023 from 2022 actuals. a. Please provide a worksheet detailing the actual cost of the Safe Tree program in the 2022 calendar year including the allocation of costs to each state.
RESPONSE:
The Forecasted budget for the Safe Tree program for 2022 was $350,000, as the program was just ramping up starting with a pilot. The actual spend for this program in 2022 was $331,267.16. The 2023 Budget has been increased to scale the program, including into Washington state (the pilot was in Kellogg, Idaho). Addition costs are also factored into the 2023 budget including increased
labor costs and increased material costs such as replacement trees.
a) Please see Staff_DR_043 Attachment A for the associated worksheet requested.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-44 TELEPHONE: [phone] REQUEST: As part of the Fuel Reduction program, please describe if there was any cost sharing between
partners. If any, please provide a worksheet detailing how costs were allocated between partners. RESPONSE: There were no sharing costs between partners in the 2022 fuels reduction projects. Bonner County
pays for their own staffing and equipment to accomplish the fuels reduction work. As the work is
completed, an invoice is generated for direct costs. Bonner County generates an invoice and then sends it to Avista. Once the approval for reimbursable work is issued by Avista personnel, a check is sent directly to the County to cover all approved costs.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: Annie Gannon TYPE: Production Request DEPARTMENT: Corporate Communications
REQUEST NO.: Staff-45 TELEPHONE: [phone] REQUEST: In Company witness Howell's direct testimony, he describes the first phase of the Wildfire
Resiliency Communication Plan. Howell stated: "No communications began until the organization was ready from an operational and regulatory standpoint." Howell Direct at 49. a. Please explain when communication first occurred; and b. Please provide the incremental costs to make the communication systems ready
for additional use. Please provide supporting workpapers. RESPONSE: a. The Company’s first Wildfire Resiliency Plan and supporting communications plan was
completed in May 2020. The first communication customers received was in June 2020. A
press release was also sent in June 2020. b. There were no new systems set up as we used existing communication channels such as email, customer newsletters, press releases, website and community presentations. In 2020,
the Company spent approximately $12,650 with an agency to create materials supporting the wildfire program, such as visual assets, fact sheet, customer handouts, web/press release copy and presentation templates.
1 | P a g e
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: Robb Raymond TYPE: Production Request DEPARTMENT: Asset Maintenance
REQUEST NO.: Staff-46 TELEPHONE: [phone] REQUEST: In Company witness Howell's testimony, he stated: "As part of the 2023 Wildfire strategy, we will
commit to underground facilities in connecting new customers in high fire threat districts whenever financially feasible." Howell Direct at 61. a. Please provide the Company's undergrounding project guidelines; b. Please explain the specific criteria used to evaluate "financially feasible";
c. Please explain the selection process for undergrounding; and
d. Provide a cost-benefit analysis for completed and future undergrounding projects. RESPONSE:
a. Since the 1980’s the bulk of new distribution infrastructure is constructed with underground
cables and pad mounted equipment. This is especially true in urban areas associated with greenfield developments. However, converting existing overhead facilities to underground has not been widely adopted by U.S. utilities.
Avista is a member of the Western Electric Institute’s Underground/Overhead (UG/OH) forum and this topic of conversion has been discussed many times. Fortis (Alberta) and BC Hydro have conducted extensive research in this area and recommend conversion when the costs do not exceed 3-5X times the overhead equivalent. For example, if the cost to
reconstruct a segment of a lateral circuit is $100,000, the acceptable range of UG conversion
is $300-500k. b. In general, conversion is only feasible in rural areas where direct bury plowing can be used and where excavation isn’t encumbered by other buried utilities and surface improvements.
In urban areas, the costs to convert from overhead to underground are in the 10-20X range of direct replacement. Additionally, the cost of underground materials and equipment such as conduit, wire type, ground enclosures and pad mount transformers are much higher. Unless excavation and material costs are shared between utility entities, it is generally not financially feasible to convert these circuits.
c. Avista’s Grid Hardening initiative, sponsored by Avista’s Wildfire Resiliency Program, is a 10-year program that applies Grid Hardening scope to each mile of the electric distribution system in areas of elevated wildfire risk, thereby reducing the risk of generating or being impacted by wildfires.
When designing Grid Hardening treatments in any given area within the Grid Hardening scope, the following criteria are used to assess underground conversion:
• Overall assessment of pole and wire condition
• Customer density
• Ground and terrain conditions
• Other factors which might include relocating a section of overhead circuit where access is limited or is routed through a heavily forested area Avista has developed a calculator when assessing converting overhead to underground: 1. Compares maintenance and installation costs of overhead lines vs. underground lines
within a given feeder. 2. Calculates an underground conversion score using the characteristics of the specified area. 3. Determines whether converting to underground would be justified for that area.
Guidelines have been established to not underground when costs exceed 3 to 5 times the
cost to overhead. For the area being assessed, a score is calculated and weighted against the fire risk level of the area. Calculation metrics include the following major categories:
• Annual maintenance costs which include routine pole inspection, vegetation management, and life cycle costs of overhead and underground equipment.
• Customer impact costs are estimated based on historical outage data and average costs to fix
an outage.
• Cost estimates to underground. Variables include costs of construction methods (trenching, boring, vs. plowing) based on ground conditions.
• Accessibility
• Removal of overhead equipment d. Under the scope of the Grid Hardening program, less than 1% of the 400 miles hardened to date in Washington and Idaho have been converted to underground. In cases where
underground conversion has been done, it has been in very short sections where
accessibility has been problematic. Below is an example of an area where we applied the calculator and decided not to convert to underground.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: Robb Raymond TYPE: Production Request DEPARTMENT: Asset Maintenance
REQUEST NO.: Staff-47 TELEPHONE: [phone] REQUEST: Please provide all funding alternatives and sources that the Company has pursued and/or received
for its WRP. Please provide supporting workpapers.
RESPONSE: Avista is currently in the application process for a 5 year, $100M grant from the Department of Energy. 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. Grid Resilience Utility and Industry Grants support activities that will modernize the electric grid to reduce impacts from extreme weather and natural disasters. This grant program will fund
comprehensive transformational transmission and distribution technology solutions that will mitigate weather hazards across a region or within a community including wildfires, floods, hurricanes, extreme heat, extreme cold, and extreme weather events that can cause a disruption to the power system. This funding opportunity is available to electric grid operators, electricity storage operators, electricity generators, transmission owners or operators, distribution providers,
and fuel suppliers.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-48 TELEPHONE: [phone] REQUEST: Please provide the Company's process guidelines and all least-cost, least-risk, analysis used to
evaluate pilot projects and for converting pilot projects to full programs.
RESPONSE: As part of the 2020 Wildfire Resiliency Plan, Avista committed to adding vegetation remote
sensing to the list of wildfire defense mechanisms. This project involved expanding use of LiDAR surveys on the 2,270 mile transmission system and adding satellite imaging and machine-learning computer algorithms on the 7,650 mile distribution grid. Avista had previous experience with LiDAR and were able to leverage that experience to assess vegetation risk along transmission
corridors including the evaluation of forest health. However, Avista did not have experience using
satellite images to determine distribution vegetation risk and conducted a limited scope pilot project near Kellogg, Idaho in 2020. The vegetation team worked closely with the vendor to determine the viability and cost effectiveness of satellite inspections. Current costs per mile for satellite images is around $70 dollars per linear mile which compares favorably to ground
inspections where costs vary from $400 to $500 dollars per linear mile. Avista conducted a system wide satellite inspection in 2021 and 2022 and are planning to update that data in 2023. The accuracy of machine-learning systems is directly correlated to the continuity
of data and change detection. These are foundational elements of remote sensing systems. In order
for the data to generate useful information the user must commit to succession satellite image scans in order to realize maximum benefit from the model. Avista’s vegetation managers have taken measured steps to ensure that the satellite data is accurate, timely, and actionable. In fact, in 2023 we are transitioning fully to the vendor’s computer system planning tool. The ultimate goal is
to transition away from pure cycle-based tree trimming and towards a more risk informed approach where multiple variables including outage risk, fire risk, and costs can be managed simultaneously. For the Wildfire Resiliency program, this was the only pilot project that was implemented. The success of the pilot led to wider adoption and inclusion into the vegetation management system. From an industry perspective, several investor-owned utilities are
implementing remote sensing technologies to help them fully access the vegetation risks across their systems.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: Ken Sweigart TYPE: Production Request DEPARTMENT: Transmission Design
REQUEST NO.: Staff-49 TELEPHONE: [phone] REQUEST: The WRP references how the Company has been replacing wooden poles with steel poles since
2006 as standard construction. WRP at 20. a. Please provide the number of steel poles that were installed outside the scope of the WRP since implementation in 2020; and b. Please provide the annual costs of steel pole replacements outside the scope of the WRP
since implementation in 2020. RESPONSE: The Company previously tracked steel pole installation in one group, specifically breaking out wildfire-only steel pole installations beginning in 2022.

In 2020 the Company installed a total of 368 steel poles. 2020 costs are indicated below:

In 2021 the Company installed 1016 steel poles. Costs are indicated below:

In 2022 the Company began tracking the number of steel poles installed for Wildfire separately. 118 poles were installed directly related to wildfire resiliency, with another 632 poles installed in
all other categories. Costs for steel installations in 2022 are indicated below:

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01/AVU-G-23-01 WITNESS: Elizabeth Andrews REQUESTER: IPUC RESPONDER: Jeremiah Webster TYPE: Production Request DEPARTMENT: Finance
REQUEST NO.: Staff – 050 TELEPHONE: [phone] REQUEST:
Please provide a worksheet that details a list of all the O&M expenses incurred for the Company's existing vegetation management program, but not for the WRP, for July 1, 2020, to date. In your response, please provide vendor name, amount, date, FERC account number, a brief description of the expense, and breakdown expenses by rate year.

RESPONSE: Please see Staff_PR_050 Attachment A for the requested information.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 03/31/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-51 TELEPHONE: [phone] REQUEST: Please explain if the Company is required to comply with any orders or laws in relation to its WRP
for the state of Washington. Please provide a brief description of the order or law and include a list of all costs required for compliance. Please include any workpapers with formula intact. RESPONSE:
The Washington Utilities and Transportation Commission (WUTC) has not mandated utility
Wildfire Resiliency Plans.