20230427AVU to Staff 52-93.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-052 TELEPHONE: [phone] REQUEST:
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.
RESPONSE:
This case affects rates beginning September 1, 2023. While the CCA took effect January 1, 2023, the case only includes the impacts of the CCA for the pro forma period of September 1, 2023 through August 31, 2025.

RECEIVED
2023 April 27, 5:37PM
IDAHO PUBLIC
UTILITIES COMMISSION
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-053 TELEPHONE: [phone] REQUEST: 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 initially based 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. RESPONSE:
Please see Avista's response 053C, 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.
a) The number of free Washington allowances was based on the emissions of resource operations in our WA CEIP filing for years 2023-2025 and Avista’s 2021 IRP for 2026 (the first compliance period is 2023-2026 which exceeded the CEIP compliance period which ended in 2025). The allowances used Ecology emission factors defined in rule for the forecast. A copy of our Washington forecast filing (Docket - 220770) is attached as Staff_PR_053C
Confidential Attachment A. b) Avista understands there will be a subsequent annual true up for the difference between the
approved forecast of allowances and the actual amount of allowances for a given year based on the following in WAC 173-446-230 (2)(g) The initial allocation of allowances will be adjusted to account for any differential between the applicable reported greenhouse gas emissions for the prior years for which the reporting data are available and verified in accordance with WAC 173-441 and the number of allowances that were allocated for the prior year through this
process.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-054 TELEPHONE: [phone] REQUEST:
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 following two 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 generation is 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.
RESPONSE:
Our understanding of CCA rules is that Washington ratepayers will not incur CCA allowance costs, as the transition to clean energy for the electric industry is directed by the 2019 Clean Energy Transformation Act. In both scenarios described above, Washington electric ratepayers
will not pay for allowances.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-055 TELEPHONE: [phone] REQUEST: 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.
RESPONSE:
Avista is at the very early stages of developing a strategy for managing CCA allowance costs and does not have a draft plan at this point. Idaho will be affected by the strategy as it will affect the cost of allowances and the PCA accounting requested in Case No. AVU-E-23-04.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-056 TELEPHONE: [phone] REQUEST:
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 obtained through different methods have different prices, please explain how the Company plans to coordinate these methods to minimize allowance costs.
RESPONSE: The methods above describe the likely methods Avista will employ to minimize CCA allowance costs. Avista is presently at the early stages of developing its CCA allowance strategy and does not
yet have one to share with the Commission.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-057 TELEPHONE: [phone] REQUEST:
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.
RESPONSE: When there are not enough allowances, Avista will have to cover emissions with a penalty rate equal to a price cap. The cap starts in 2023 at approximately $82 per tonne and increases annually
at the consumer price index plus 5%. Since Washington’s portion is covered by free allowances,
no purchases at the cap or otherwise will be necessary for Washington customers. In the unlikely event Avista did not have adequate allowances to cover its emissions, purchases at the cap for Idaho would be necessary.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-058 TELEPHONE: [phone] REQUEST:
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. RESPONSE:
Currently utilities have a “lesser of” proposal before the Department of Ecology with the intent to change the accounting of sales at Mid-C. Under this proposal any Mid-C hydro resource is specified as non-emitting instead of being unspecified as they currently are. If successful in our proposal, we believe this would greatly reduce the amount of allowances purchased for Idaho.
Another option we will employ, where more beneficial to Idaho than selling unspecified energy at the Mid-C, is selling power from outside-Washington carbon emitting resource at the busbar or another non-Washington delivery point. While this strategy would eliminate Idaho CCA
compliance costs for power sold in this fashion, as stated in testimony the approach likely would
result in lower net revenues to Idaho than if power is sold at the Mid-C. Further, there is no liquid market for such sales and so the viability of this strategy executed on a large scale is not high.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-059 TELEPHONE: [phone] REQUEST:
What are the Department of Ecology's requirements for how free allowances can be used? Does Avista have any flexibility on how free allowances can be used? If so, please explain.
RESPONSE: Our present understanding is that free allowances must be used only to offset portfolio emissions
benefitting Washington customers.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-060 TELEPHONE: [phone] REQUEST:
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-jurisdictional share 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-jurisdictional share of thermal plants located outside of Washington State" refers to Avista' s share of Lancaster, Rathdrum, Coyote Springs 2, and Colstrip;
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 not 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.
RESPONSE: a) Washington’s multijurisdictional share of thermal plants located outside of Washington includes Lancaster, Rathdrum, Coyote Springs 2 and Colstrip (Avista transfers ownership of Colstrip after 12/31/2025).
b) There will be allowance costs charged to Idaho for its portion of Lancaster, Rathdrum, Coyote Springs 2 and Colstrip used to serve retail load. c) Washington’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) The purchase of CCA allowances could be avoided if a third party purchased power at the
busbar of the Lancaster, Rathdrum, Coyote Springs 2, and Colstrip. e) Carbon-emitting thermal generation imported into Washington, whether owned by Avista or not, would incur an allowance cost. f) Since Aurora (no other model for that matter) cannot comprehend and represent with
precision the CCA, we approximate its impact by applying allowance costs in the Aurora
dispatch. In the Aurora dispatch, only regulated carbon-emitting resources incur allowance costs in their dispatch decision. This approach is intended to approximate the amount of emissions created. Once Aurora has dispatched all resources and determined the amount of surplus sales in each hour, the amount of emissions that get charged for
ratemaking purposes is calculated (outside of Aurora). This is the 0.437 tonnes/MWh *
MWh of market sales. This is the best approximation we know to do with the limitations of modeling tools such as Aurora. g) EIM imports are considered non-specified electricity. h) Under current regulation, all electricity, unless it is somehow delivered into the state as
specified-source energy, is non-specified electricity.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-061 TELEPHONE: [phone] REQUEST: Please respond to the following regarding 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; 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 (including both Washington ' s and Idaho 's) native load?
RESPONSE: Please see Avista's response 061C, 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. a) Avista has historically used the production-transmission (PT) ratio to determine Idaho’s share of resources. We propose this same allocation in this case. The rate as filed is 34.4% for Idaho’s portion.
b) CONFIDENTIAL PORTION OF RESPONSE c) There is no difference. d) No, Idaho pays for Boulder Park emissions only to the extent the energy serves Idaho retail loads. e) See d above.
f) CCA costs of Washington’s portion of Boulder will be offset by free allowances, irrespective of whether it serves retail load or is sold as surplus energy. g) This is our interpretation of the rule, yes. h) Surplus energy is generation exceeding the retail loads of Idaho and Washington.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-062 TELEPHONE: [phone] REQUEST:
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.
RESPONSE:
Please see Avista's response 062C, 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.

a) The main change from the last case to this case is the inclusion of the CCA impact. For modeling and dispatch purposes, the $23.87 per metric ton was included in Aurora, however, the estimation of CCA costs for Idaho is based on Idaho PT share of emissions generated from the dispatch.
b) Using the Idaho PT share of allowance costs in dispatch modeling ensures Aurora only dispatches when market prices are greater than the plant’s marginal cost (i.e., allowance costs for Idaho) including the carbon cost. Including the full $67.81 in dispatch would overstate actual compliance costs and result in less dispatch and value to Idaho.
c) Only Boulder Park had CCA allowance costs included in dispatch in Aurora. Please see Staff_PR_062C Confidential Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-063 TELEPHONE: [phone] REQUEST:
Tab "Conf Idaho CCA Costs" of the Excel file "Confidential Exh No 7 - Sch IC- 5 01.09.2022. xlsx" shows that the CO2 Equivalents Price per Metric Ton ($67.81 for Rate Year 1 and $70.71 for Rate Year 2) are calculated by averaging the forecast price in 2023 and the forecast price in 2024 and averaging the forecast price in 2024 and the forecast price
in 2025, respectively. 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. RESPONSE:

The cost per ton rate was calculated as mentioned above was used in the rate case. If we’d used an allocation more closely aligned with the timing of the rate case, a slightly higher cost per ton would have resulted. This was an oversight on our part.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-064 TELEPHONE: [phone] REQUEST:
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?
RESPONSE:
Any differences (plus or minus) from what goes into rates would flow through the Power Cost Adjustment. The specifics of methodology are being addressed in Case No. AVU-E-23-04.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/24/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Lori Hermanson TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-065 TELEPHONE: [phone] REQUEST:
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.
RESPONSE: The estimated two-year CCA compliance costs are $154 million. It appears the numbers were
transposed on Page 13 of Kalich’s Direct Testimony.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/27/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elisabeth Sibulsky TYPE: Production Request DEPARTMENT: Enterprise Tech. PMO
REQUEST NO.: Staff-066 TELEPHONE: [phone] REQUEST: 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.
RESPONSE:
Below is a list of actual Failed Plant and Operations Technology Failed Assets from June of 2021 to December 31, 2022. These are represented as individual projects in this business case, that describe failures outside of typical device failure cadence and are listed below.
• Coeur d’Alene to Pine Creek – Optical Ground Wire (OPGW) – Tree fell and broke the
OPGW wire and required replacement.
• Mt. Spokane Siding project – There is no planned refresh for siding on buildings. The original paneling material was 20+ years old and started to become brittle. As a result,
the wind storms over the last few years have broken multiple panels and Avista has no
spare panels for repairs. The panels are secured to a wooden frame that started to deteriorate as well.
• Fixed Network repeaters – these fail on a cadence of about once per month. This business case stocks an inventory of these devices so they can replace them when
needed. The Fixed Network system is 17 years old.
• Projector screens - Multiple projector screens and the ceiling lift for the auditorium projector have failed in the last year. These devices do not have a planned refresh cycle due to typically low failure rates.
• Shawnee – North Lewiston Fiber Break. Avista experienced a break in the fiber lines near Shawnee and North Lewiston substations, due to small animal activity. This Fiber is crucial for communications at both locations. If completely broken, this would cause
potentially 11 substations in the area to go offline, with a maximum impact of losing the
Gridnet for the whole of Avista’s southern region. This Business Case also supports a number of “blanket” projects that run on an annual cadence and replace assets that fail on a regular basis. The list of these projects is in Staff_PR_067 Attachment
A. Avista’s strategy regarding planned refresh has shifted in some cases for non-critical devices,
such as mobile phones and printers. The change is to remove funding for planned refresh for these devices and instead run devices to failure. This necessitates an increase in the failed assets business case, while saving the Company money on devices that are still functional past a typical planned refresh lifecycle. A majority of the failures that occurred in this Business Case, did not happen
outside of a planned lifecycle refresh.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/27/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elisabeth Sibulsky TYPE: Production Request DEPARTMENT: Enterprise Tech. PMO
REQUEST NO.: Staff-067 TELEPHONE: [phone] REQUEST: Please provide a worksheet that has a detailed list of pro forma Failed Plant and Operations Technology Failed Assets expenses for 2023 and 2024.
RESPONSE: Please see Staff_PR_067 Attachment A for the projects that make up the pro forma transfers-to-plant in Technology Failed Assets for 2023 and 2024.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elisabeth Sibulsky TYPE: Production Request DEPARTMENT: Enterprise Tech. PMO
REQUEST NO.: Staff-068 TELEPHONE: [phone] REQUEST: Kensok Direct at 13 describes that the Technology Failed Assets program is intended to 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 2025. Please explain the reasoning and provide documentation for the increase in forecasted expenditures.
RESPONSE: The Pro Forma capital amounts included in this case for 2022 represent the period July 1, 2022 to December 31, 2022 (1/2 year), 2023 (full year), 2024 (full year) and 2025 (January 1, 2025-August 31, 2025). When reviewing the year over year projected increase in transfers-to-plant, it is more
appropriate to review the full year or annual amount expected. The following represents the
2022-2025 expected transfers-to-plant on a system basis (as provided in Staff_PR_016 Supplemental 2) for this business case:

Changes between years are primarily due to the post pandemic return to the office for most of the workforce, as well as supply chain delays starting to resolve in 2023. The amount provided above for 2023 is expected to be somewhat higher than shown as many purchases from prior years is expected to arrive in 2023. In addition, increases in 2022 and 2023 are also related to a change in
process regarding spare devices purchased for projects that bring in new technology. These spare assets are now paid for out of this business case to improve asset tracking. The decrease from 2023 to 2024 is due to the supply chain issue for these technologies is improving, as we don’t expect as much of a delay in product arrivals from 2023 to 2024. We have
made a similar assumption for 2024 to 2025. In addition to supporting technology devices that fail prior to refresh, this business case also supports ad hoc failures to assets that are not part of any planned lifecycle management program
due to the length of the asset lifecycle being longer.
Please see further details regarding the Company’s strategy in response to Staff_PR_066.
1 Represents the full year of 2022 actual system transfers-to plant. The amount included in the Company’s case
represents a partial year. 2 Represents the entire year of 2025 expected system transfers-to-plant. The amount included in the Company’s case
was a partial year.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elisabeth Sibulsky TYPE: Production Request DEPARTMENT: Enterprise Tech. PMO
REQUEST NO.: Staff-069 TELEPHONE: [phone] REQUEST: 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? RESPONSE: As noted in the Company’s response to Staff_PR_066, the Company has revised its strategy on
certain assets from a lifecycle management approach to a run to fail approach for printer and
phones and therefore, will not update or adjust a lifecycle management program. In addition, there is a disparity of cost between types of devices in this business case. For example, some printer needs are simple and can cost only a few thousand dollars while other printers are complex and can cost into the tens of thousands of dollars. It is difficult to predict the failure rate for some devices
due to changes in usage, which was compounded by Covid due to working from home. Device
failures for returning to the office have increased as workers return to the office and are beginning to use devices that have sat unused for a few years. Supply chain issues also compounded this issue with long lead times. The Company is evaluating the impacts on the usage for these devices given these challenges over the last few years and will adjust the business case over time if
determined necessary.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elisabeth Sibulsky TYPE: Production Request DEPARTMENT: Enterprise Tech. PMO
REQUEST NO.: Staff-70 TELEPHONE: [phone] REQUEST: 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. RESPONSE: The Company has the following policies and procedures in place to mitigate early replacement of
technology assets:

• Incentives for bring your own device mobile phones encourage employees to use their personal phones instead of a company phone.
• Ram upgrades were implemented for Lenovo T470 and T480 laptops to improve the performance of older deployed laptops. These devices would normally have been replaced as a “failure” due to the device running too slowly.
• All mobile tablets and phones that are deployed for use in the field or within the business
are deployed with a ruggedized case to decrease the number of failures due to drops or breakage.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: James Kensok REQUESTER: IPUC RESPONDER: Tia Benjamin TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-071 TELEPHONE: [phone] REQUEST:
Please provide the workpapers for Table No. 1 in Kensok Direct at 9 from 2022 through 2025. RESPONSE:
The source for Table No. 1 in Company witness Mr. Kensok’s Direct Testimony can be found in
TTP Detail 22-25 tab of Ms. Schultz’s workpapers “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS”. For ease, the Company is attaching the source data in Staff_PR_071 Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elizabeth Arnold TYPE: Production Request DEPARTMENT: Enterprise Tech. PMO
REQUEST NO.: Staff-072 TELEPHONE: [phone] REQUEST: 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. RESPONSE:
Please see Ms. Benjamin’s workpapers “3.08-3.11 - 24.01-24.02 PF - CAPITAL ADDITIONS”,
TTP Detail 22-25 tab. For ease, the Company is providing the breakout for this specific request in Staff_PR_072 Attachment A. The source data can be found in Staff_PR_071 Attachment A. The Enterprise & Control Network Infrastructure business case was broken into three separate
business cases to provide more visibility into the projects and to help prioritize the projects under
each functional area. Projects included in Control and Safety Network Infrastructure, Enterprise Network Infrastructure, and Network Backbone Infrastructure were previously included as the Enterprise & Control Network Infrastructure business case in 2021. With the breakout of the business case into three separate ones, the dollars were reallocated as shown in Staff_PR_072
Attachment A. Staff was also provided a detailed description of the work in each business case and the reason for the change in management during their onsite visit at the Company.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/27/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elizabeth Arnold TYPE: Production Request DEPARTMENT: Enterprise Tech. PMO
REQUEST NO.: Staff-073 TELEPHONE: [phone] REQUEST: 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.

RESPONSE: Please see the actual expenses from 2021-2022 for the Enterprise & Control Network Infrastructure program in Staff_PR_073 Attachment A.

The Enterprise & Control Network Business Case was scheduled to Close at the end of 2022, however, there were projects which were delayed and expected to extend into 2023 and 2024. These projects were descoped and closed within the Enterprise & Control Network Business Case. That project work was transferred into the Network Backbone Infrastructure business case in 2022
resulting in transfer to plant now in 2023.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-074 TELEPHONE: [phone]
REQUEST: 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).
RESPONSE: Please see Staff_PR_074 Attachment A.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/19/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Matt Halloran TYPE: Production Request DEPARTMENT: Customer Solutions
REQUEST NO.: Staff-075 TELEPHONE: [phone] REQUEST NO. 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 provide the utilization rate for each available option and the percentage of Idaho customers that have established an online account.
RESPONSE: As outlined in Exhibit 12 Hydzik Testimony page 24, the self-service functionality available to Avista customers is as follows:
• Knowledge Resource for all customers (desktop web, mobile web). Myavista.com
contains a wealth of information that our customers find valuable and assists in call avoidance.
• View bill and associated info (desktop web, mobile web, mobile app, automated
phone)
• Pay bill (desktop web, mobile web, mobile app, automated phone, payment kiosk)
• View meter data and usage info (desktop web, mobile web)
• Outage Reporting (desktop web, mobile web, mobile app, automated phone,
text/SMS)
• View outage information (desktop web, mobile web, mobile app, automated phone, text/SMS)
• Start Service (desktop web, mobile web, automated phone)
• Stop Service (desktop web, mobile web, automated phone)
• Transfer Service (desktop web, mobile web, automated phone)
• Apply for Energy Efficiency Rebates (desktop web, mobile web)
• Report an Issue or Concern, ‘Contact Us’ web form (desktop web, mobile web, mobile app)
• Alerts and Notifications Management: Ability to enroll and update contact
information for alerts and notifications (desktop web, mobile web, mobile app, automated phone, text/SMS)
• Enroll in Payment Arrangements (desktop web, mobile web) Update Personal Contact and Account Information (desktop web, mobile web)
• Energy Use Calculator for “Always-on” energy loads (desktop web, mobile web) Registration of an online account is one way to measure self-service utilization but it’s important to note that not all self-service functionality requires registering an account. Utilizing services
provided by the company’s website analytics and tracking software, the company is able to make
generalized and imperfect estimates for website traffic originating from internet service providers (ISP) within the state of Idaho. Please note that the numbers below are inherently imperfect due to technologies that exist that can mask a computer or device’s ISP location. One such common
example of that technology is utilization of a “Virtual Private Network” (VPN). Additionally, it cannot be assumed that all website traffic originating from an Idaho based ISP is an Idaho Avista
customer. Therefore, the below numbers should only be used as generalized and imperfect
assessments of Idaho customer myavista.com functionality utilization. Table 1: Total Annual Estimated myavista.com ‘Top 50’ Page Utilization by Idaho Based ISP Web Traffic.

2020 2021 2022
Estimated Page Views Estimated Utilization (minutes) 5,144,232 4,996,367 5,162,940
Table 2: 2022 Top 50 myavista.com page utilization by Idaho based ISP web traffic.
2022
Page Title Idaho Based ISP Page Views
Avg. Idaho ISP Time on Page (Seconds)
Estimated Idaho Customers' Utilization (Minutes)
Avista bill pay & customer sign in | Avista 573,534 112.45 1,074,925
Account Summary 354,807 112.31 664,143
Make A Payment 313,680 182.07 951,870
247,183 36.54 150,549
Billing History 40,852 256.43 174,593
Billing and Payment options 36,998 124.97 77,058
Agency Worker 35,652 844.71 501,928
Our Commitment 31,052 130.43 67,502
Ways to pay your Avista bill | Avista 25,419 45.36 19,216
View Your Usage 24,938 124.85 51,891
Your Profile 22,362 83.92 31,276
Register Account 19,217 201.03 64,386
Multiple Accounts Pay 19,168 208.32 66,551
13,938 83.79 19,465
Forgot Password 13,742 101.53 23,253
Reset password 12,877 81.04 17,393
12,808 29.15 6,223
12,031 456.24 91,484
11,619 547.70 106,062
Go Solar 11,324 266.25 50,250
Your Enrollments 11,098 74.49 13,778
Find By Account Page 10,409 90.80 15,752
Apply for a rebate 10,026 1885.56 315,078
9,947 437.05 72,455
Paying Your Avista Bill: Comfort Level Billing | Avista 9,947 124.17 20,585
Working at Avista 9,525 591.88 93,962
Contact Us 8,689 263.39 38,144
8,473 34.18 4,827
Payment Arrangements 8,276 94.95 13,096
Property Management 8,139 46.49 6,306
7,932 371.50 49,112
error-display-page 6,507 83.03 9,004
Start Service 6,468 435.70 46,969
Search Results 6,340 37.40 3,952
6,202 393.30 40,654
Conditions for the PNW Area | 5,121 504.16 43,030
4,797 582.45 46,567
Compare Your Bills 4,522 166.95 12,582
4,522 58.62 4,418
The Power of Compassion 4,168 41.90 2,911
Alert Preferences 4,069 105.71 7,169
3,706 144.57 8,930
Stop Service 3,706 268.81 16,603
Mobile app, text, and alerts 3,666 184.04 11,245
Need other payment options 3,548 100.76 5,958
2,860 403.69 19,243
2,457 100.60 4,120
Notification Center 2,349 75.26 2,947
Idaho assistance 2,339 244.19 9,519
For your home 2,212 379.89 14,005
Estimated Total 2,015,221 NA 5,162,940
Table 3: 2021 Top 50 myavista.com page utilization by Idaho based ISP web traffic.
2021
Page Title Idaho Based ISP Page Views
Avg. Idaho ISP Time on Page (Seconds)
Estimated Idaho Customers' Utilization (Minutes)
Avista bill pay & customer sign in | Avista 376,296 82 513,311
Account Summary 364,855 108 654,385
Make A Payment 361,422 206 1,241,377
295,919 40 195,767
Sign In 294,603 75 368,260
52,157 190 164,926
Billing History 40,580 233 157,610
Billing and Payment options 37,437 125 77,717
Find By Account Page 31,103 105 54,539
30,803 388 199,378
Your Profile 29,110 82 39,575
Multiple Accounts Pay 25,010 204 85,082
Register Account 23,897 225 89,537
Our Commitment 20,068 102 33,955
Forgot Password 18,153 105 31,636
Ways to pay your Avista bill | Avista 17,979 53 15,761
error-display-page 17,940 85 25,422
View Your Usage 17,863 178 53,026
Reset Password 15,155 74 18,575
14,816 24 6,022
14,033 413 96,613
Your Enrollments 13,878 64 14,816
11,315 554 104,423
Working at Avista 10,870 476 86,263
Property Management 10,484 41 7,227
9,652 35 5,552
8,839 118 17,397
Start Service 8,385 641 89,530
7,930 195 25,758
Ways to Pay 6,161 40 4,085
Rebates 5,764 1,241 119,220
5,745 452 43,301
5,725 154 14,683
New Customers 5,696 66 6,271
Payment Arrangements 5,406 85 7,635
Text and mobile app 5,348 346 30,836
Contact Us 5,213 354 30,747
Stop Service 5,203 261 22,646
Conditions for the PNW Area | 5,010 612 51,137
Need other payment options 4,981 82 6,767
Agency Worker 4,420 861 63,419
Outage Map How-To 4,362 249 18,097
Alert Preferences 4,352 155 11,219
Compare Your Bills 4,323 135 9,701
4,052 139 9,398
3,946 553 36,338
Conserve 3,743 259 16,183
The Power of Compassion 3,462 30 1,737
3,201 174 9,268
3,104 198 10,240
Total 2,279,769 NA 4,996,367

Table 4: 2020 Top 50 myavista.com page utilization by Idaho based ISP web traffic.
2020
myavista.com Page Title Idaho Based ISP Page Views
Avg. Idaho ISP Time on Page (Seconds)
Estimated Idaho Customers' Utilization (Minutes)
Sign In 858,483 71 1,021,517
Account Summary 414,569 103 710,585
Make A Payment 264,082 198 871,968
260,156 32 140,006
Checkout 144,825 92 221,125
Home 107,429 37 66,269
Receipt 102,079 182 308,918
Billing History 46,576 230 178,526
Billing and Payment options 41,495 110 75,964
Find By Account Page 33,062 98 54,195
29,667 200 98,809
Your Profile 29,146 80 39,054
Ways to Pay 29,102 51 24,568
Register Account 28,798 217 103,926
Multiple Accounts Pay 28,416 200 94,571
Contact Us 28,321 447 210,921
Reset Password 25,342 71 30,158
Forgot Password 21,112 99 34,920
Your Enrollments 15,085 51 12,757
Guest Checkout 14,825 90 22,193
Moving 13,765 36 8,194
13,722 334 76,403
Comfort Level Billing 13,357 113 25,092
Property Management 12,593 29 6,146
Agency Worker 11,785 872 171,287
View Your Usage 11,116 184 34,041
Compare Your Bills 10,778 155 27,769
Working at Avista 10,187 161 27,338
Rebates: Idaho 9,892 337 55,550
Start Service 9,275 507 78,312
6,548 418 45,615
New Customers 6,314 54 5,714
Stop Service 5,810 187 18,127
Avista's COVID-19 Response 5,324 213 18,910
Rebates 5,272 539 47,320
error-display-page 4,342 131 9,447
Outage FAQs 4,212 195 13,714
Notification Center 4,177 63 4,352
4,056 130 8,759
Emergency Payment Arrangements 4,021 174 11,637
Virtual Office 3,448 535 30,748
Search Results 3,231 27 1,455
Water Flow Information 3,222 413 22,165
Need other payment options 3,187 71 3,756
Transfer Service 3,126 237 12,342
3,031 183 9,268
Agency Search 2,970 240 11,899
811 - Call Before You Dig | Avista 2,831 472 22,294
High Low Average 2,831 313 14,777
Find Energy Rebates | Avista 2,770 18 849
Total 2,719,763 NA 5,144,232
Table 5: Registered myavista.com userID counts for Idaho based customer accounts.
Year
143,454 18,324
145,964 18,342 147,376 17,036
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-076 TELEPHONE: [phone]
REQUEST: Please provide the Company's performance objectives for handling incoming calls. RESPONSE:
Avista’s performance objectives are that 80% of incoming calls are answered within 60 seconds.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/17/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: William Ozminkowski TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-077 TELEPHONE: [phone]
REQUEST: What steps does the Company take if it fails to meet its performance objectives?
RESPONSE: Twice a year, Avista conducts a long-range analysis that looks out 2 years to determine expected staffing needs. If there are periods of time that appear short on staffing, the Company then plans
to hire and have new staff fully trained before the shortfall occurs. If Avista misses its performance
objectives in any given month, an additional long-range analysis is completed to determine what has changed, and if it is determined that there is a new need for additional staff, the Company can plan accordingly for additional hiring.

Od toAVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-078 TELEPHONE: [phone]
REQUEST: 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). RESPONSE:

Jan 57,211 46,145 40,771 Feb 50,072 36,085 39,049
Mar 44,915 44,154 44,734
Apr 34,662 37,452 40,535
May 34,986 32,615 37,438
Jun 40,170 39,116 38,414
Jul 37,436 34,975 37,454
Aug 35,573 37,073 39,643 Sep 40,557 35,715 38,736
Oct 44,317 38,950 36,654
Nov 34,829 39,257 38,167 Dec 37,046 37,530 36,786
Total

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-079 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE:
Jan 3,065 2,931 1,135
Feb 2,803 675 1,003
Mar 2,769 1,381 1,181
Apr 1,853 1,811 1,121
May 3,628 870 1,186 Jun 5,454 1,617 1,296
Jul 1,693 899 1,359
Aug 1,740 1,278 1,440
Sep 2,166 1,199 1,713
Oct 3,805 1,197 1,106
Nov 1,199 1,340 2,072
Dec 1,644 889 2,382

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-080 TELEPHONE: [phone]
REQUEST: 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 telephone system and when the call is picked up by a customer service representative.
RESPONSE:
Jan 0:34 1:03 0:36
Feb 0:30 0:17 0:32
Mar 0:27 0:31 0:33
Apr 0:17 0:28 0:30
May 0:28 0:25 0:37
Jun 0:23 0:35 0:39 Jul 0:21 0:30 0:38
Aug 0:35 0:31 0:38
Sep 0:44 0:31 0:41
Oct 1:04 0:30 0:28
Nov 0:26 0:26 0:53
Dec 0:32 0:26 1:14

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-081 TELEPHONE: [phone]
REQUEST:
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. RESPONSE:

Jan 80.70% 80.70% 81.40% Feb 83.50% 92.10% 82.80%
Mar 84.40% 85.30% 83.20%
Apr 89.60% 86.10% 85.10% May 82.20% 88.00% 82.80%
Jun 80.30% 84.30% 80.50%
Jul 88.30% 86.20% 80.50%
Aug 81.10% 85.20% 80.80%
Sep 81.70% 85.40% 77.90%
Oct 78.30% 84.10% 84.80%
Nov 86.90% 88.00% 74.70% Dec 84.50% 87.30% 68.90%

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-082 TELEPHONE: [phone]
REQUEST: 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 (usually expressed 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).
RESPONSE:
Jan 6:46 7:40 7:40
Feb 6:59 7:30 8:00
Mar 6:58 7:24 7:50
Apr 7:09 7:24 7:25
May 7:33 7:16 7:30
Jun 7:08 7:05 7:29 Jul 7:32 7:04 7:14
Aug 8:04 7:05 7:47
Sep 7:57 7:30 7:42
Oct 8:10 7:33 7:49
Nov 8:01 7:15 7:44
Dec 8:02 7:21 8:43

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/19/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-083 TELEPHONE: [phone]
REQUEST:
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.
RESPONSE: The table below reflects the average response time for Avista’s Net Reps to respond to customers’ email inquiries for each month for the previous three years (2020, 2021, and 2022). The Company changed its software used to receive and respond to customer emails during this period of time.
Previously, Avista used Egain which was discontinued with the implementation of Salesforce on
December 15, 2020. However, Salesforce’s reporting capabilities were not available until February 4, 2021. Therefore, data is not available for January 2021. Additionally, the increase in email response time between 2020-2022 is due to the difference in reporting capabilities between Egain and Salesforce. Egain’s response time was measured for ALL email queues (so a quick delete of a
spam email factored into the “response time”, essentially lowering it). Salesforce’s improved
reporting capabilities allows Avista to calculate response time more precisely. Average Response Time for Emails (HH:MM:SS) Month 2020 2021 2022
Total 7:17:39 13:45:00 19:19:50

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Dalila Sheehan TYPE: Production Request DEPARTMENT: Corporate Communications
REQUEST NO.: Staff-084 TELEPHONE: [phone] REQUEST:
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.
RESPONSE:
Please see Staff_PR_084 Attachment A which reflects the first call resolution rate collected through Avista’s Voice of the Customer results for Overall Satisfaction displayed as a percent for the following question:

“How would you rate your satisfaction with the representative giving you all the information you needed in one call?”
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/19/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Matt Halloran TYPE: Production Request DEPARTMENT: Customer Solutions
REQUEST NO.: Staff-085 TELEPHONE: [phone] REQUEST:
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 non-tech-savvy senior market segment is not left behind in your Customer Facing Technology Program (“CFTP”) and other Company technology-based customer service programs. Please explain if there are any
initiatives to enhance this market segments customer experience.
RESPONSE: Please see the Company’s response to Staff_PR_087.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/14/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Brandon Kafflen TYPE: Production Request DEPARTMENT: Customer Service
REQUEST NO.: Staff-086 TELEPHONE: [phone]
REQUEST: Please explain if the Company will maintain the same staffing levels for direct-contact customer services for the market segments that do not choose or are unable to use the new CFTP initiatives. RESPONSE:
Avista will continue to maintain employee staffing in order to meet its Grade of Service, answering 80% of calls within 60 seconds, in all situations.

1 NICE 2022 Digital-First Customer Experience Report Finds 81% of Consumers Say They Want More Self-Service Options | NICE
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/19/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Nicole Hydzik REQUESTER: IPUC RESPONDER: Matt Halloran TYPE: Production Request DEPARTMENT: Customer Solutions
REQUEST NO.: Staff-087 TELEPHONE: [phone] REQUEST:
In Company Witness Hydzik’s Exhibit No. 12, Schedule1, page 13 of 33, it describes “40% of all customers now prefer self-service to live contact.” Please explain how the Company intends to address the remaining 60% of the consumers that do not prefer these self-service options.
RESPONSE:
Customer expectations of digital self-service functionality continue to rise but given our obligation to serve a wide customer base, the Company acknowledges that it must strive to meet customer needs outside of the digital self-service realm as well. The Company has a long history of
developing and delivering solutions prior to the digital age and will continue in the future, as it
makes sense to do so. In support of meeting customers where they are, the Company actively supports mechanisms for our customers to engage with us that don’t require internet, smart phone or landline phone.
Specifically, the Company is committed to maintaining in-person lobbies that allow customers to have questions answered real time as well as make payments. Our field service personnel also have a multitude of processes that require ‘door knocks’ for scheduled field work, which is in addition to phone and/or email prior notifications. For those customers who prefer phone interactions, the
Company is committed to serving and meeting our customer’s needs on that channel as well
through a well-developed team of Customer Service Representatives. For our customers who choose to receive a paper bill via the USPS, the paper bill packet includes monthly Bill Inserts that contain valuable safety, energy efficiency and company news updates.
Lastly, the quoted metric of “40% of all customers now prefer self-service to live contact” that was included in the Customer Facing Technology Program Business Case Justification, Hydzik’s Exhibit No. 12, Schedule1, page 13 of 33, requires an update to align with more recent data that has been obtained. Specifically, the Company quoted within the testimony (Exhibit 12, page 4 of 35,
line 20) a more recent study by NICE that found “81% of consumers say they want more self-service options.”1 Even with the increasing expectations for digital self-service, and the overwhelming majority of customers preferring digital self-service, the Company is committed to serving all customers, regardless of their channel of choice.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IPUC RESPONDER: Marcus Garbarino TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-088 TELEPHONE: [phone] REQUEST:
Regarding the Company's response to Production Request No. 33, Staff_PR _33-AttachmentA, for the following flights, please provide the flight log, 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 AVA120822, Washington Roundtable Board Meeting, FERC # 930200, $6885.00 coded as CD.AA
RESPONSE: Please see Staff_PR_088 Attachment A for copies of the flight logs, including passenger listings, for the flights requested. The purpose and customer benefit for each flight is listed below. AVA062222 Flight Purpose: To pick up employees in the Oregon service territory to participate in the Company’s “We Are Avista” event.
The “We Are Avista” employee engagement activity was hosted on June 23, 2022 in Spokane and
attended by ~100 Avista employees, who are employed across our service territory in Oregon, Washington, and Idaho. During the event, employees heard presentations by executive leadership, including Dennis Vermillion, Heather Rosentrater and Jeff Schlect. They also networked in small groups, before taking tours of Avista’s Downtown Spokane Electric Network facility and
hydroelectric projects in Spokane’s Riverfront Park.
All employees, including those from our Oregon service territory, volunteered to attend. The Oregon employees in attendance were flown on the Company plane and it was a goal to maximize the plane’s capacity and fill the most seats possible.

Customer Benefit: This event was created so Avista employees, who had been working in relative isolation from each other since March 2020 could gather, network and learn from co-workers after most pandemic-related distancing restrictions had been lifted. Employees were able to reconnect with their colleagues through safety and customer experience moments, thus boosting employee
morale and engagement. AVA102621 Flight Purpose: This flight was to keep the Company’s pilots current with licensing requirements
that allow them to carry passengers. The pilots are required to have three takeoffs and landings
every ninety days in order to carry passengers. In addition, they are required to have made six
instrument approaches in the preceding six months. This flight was to meet those requirements during and immediately after the slowdown in flights due to COVID.
Customer Benefit: The plane is used for business purposes that support all jurisdictions, which
vary by flight, and because this flight was to keep the pilots current on their requirements to carry passengers, it in turn benefits all customers. AVA120822
Flight Purpose: Dennis Vermillion is on the Board for Washington Roundtable – this was to take him over to a Board meeting in Seattle. Per the organization’s website, “The Washington Roundtable is a nonprofit organization comprised of senior executives of major private sector employers in Washington state. Our members work together to effect positive change on public policy issues that they believe are most important to supporting state economic vitality and
fostering opportunity for all Washingtonians.” Customer Benefit: Although the organization is based in Washington, the information and knowledge gained by Mr. Vermillion serving on the Board is of benefit to the Company as a whole and therefore benefits all customers.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IPUC RESPONDER: Darrel Moss TYPE: Production Request DEPARTMENT: Claims
REQUEST NO.: Staff-089 TELEPHONE: [phone] REQUEST:
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-1123663R
g. $ 1,778.77: invoice L-1208350R h. $ 7,989.15: invoice L-1299477R i. $10,000.00: invoice L-ll70800D j. $ 218.30: invoice L-ll23708D
RESPONSE: Please see Avista's response 089C, 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.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: T. Benjamin / J. DiLuciano REQUESTER: IPUC RESPONDER: Mark Gabert/Tia Benjamin TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-090 TELEPHONE: [phone] REQUEST:
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.
RESPONSE: Please see Staff_PR_090 Attachment A for the actual annual costs for the Wood Pole Management program from 2018-2022. The Wood Pole Management Program includes, in addition to inspecting and replacing poles, visual inspection of distribution transformers, cutouts, insulators,
wildlife guards, lightning arrestors, cross arms, guying, idle facilities, old bare poles, and pole
grounds. Assets identified as defective are replaced or removed under this program as well and are reflected in the actual annual program costs. Please see Staff_PR_090 Attachment B for the cost and percentage of poles inspected each year by
state. Note that inspection is an O&M activity, therefore although cost of inspections has been provided as requested, this is not relational to the costs provided in Staff_PR_090 Attachment A. It should also be noted that the inspections have many variables and are billed on a unit pricing schedule such that each inspection is not the exact same price and therefore the allocation of
Idaho’s share of cost and number of inspections is not the same. Variables that affect the price
include age of the pole and necessary inspection activities based on its condition. As an example, a pole that needs only visual inspection vs a sound and bore inspection vs digging will all be different pricing.
Please see Staff_PR_090 Attachment C for a table of poles issued to replace existing by year for 2018-2022, with associating percentages. When work is carried out, poles are issued to the job and delivered to site at onset. Work is then carried out over a period of time and costs are placed into service as they are installed. The Company does not track pole counts as they are changed out and placed into plant but rather at the time they are issued to the job. Work can cross years and be
placed into plant in a different year than the count represented in this table, and therefore will not match the data provided in Staff_PR_090 Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/26/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Tia Benjamin REQUESTER: IPUC RESPONDER: Tia Benjamin TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-091 TELEPHONE: [phone] REQUEST:
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. RESPONSE:

Please see Staff_PR_091 Attachment A, where the Company has provided electric storm related distribution transfers to plant for 2018-2022.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/26/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Tia Benjamin REQUESTER: IPUC RESPONDER: Tia Benjamin TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-092 TELEPHONE: [phone] REQUEST:
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.
RESPONSE: Please see Staff_PR_092 Attachment A for 2018-2022 actual transfers to plant and June, 2022 allocations. Please note that the Company has applied the June 2022 allocation factors to all years
for ease of preparation of this repsonse. Additionally, please see the actual transfers to plant
included in the case, as found in Ms. Schultz’s workpapers “3.08-3.11 Capital additions", and updated in Staff_PR_016 Supplemental 2 Attachment A.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 04/25/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: David Howell REQUESTER: IPUC RESPONDER: David James TYPE: Production Request DEPARTMENT: Wildfire Resiliency
REQUEST NO.: Staff-93 TELEPHONE: [phone] REQUEST: 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. RESPONSE:
Please see Staff_PR_093 Attachment A for outage management logs related to tree fall-in outages
that required a response. This information, for Idaho only, includes date and time, location, size of outage, type (distribution or transmission), and other details provided in the dispatcher comments. Note that if the crew responding to the outage is able to make the repair with the truck and equipment they have on hand (broken wire, insulator, crossarm, etc.) there are no Maximo order or
related material costs captured. Responding to routine outages is part of our regular business, thus
we don't connect routine costs to a single incident. If the repair is more extensive and a crew will be sent back to make final repairs (new pole, new transformer, etc.), then a follow-up work order is created in Maximo and the time/materials are tracked against that order, but this information is not captured in the outage logs.