20230503AVU to Staff 94-115_138.pdf

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AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 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-094 TELEPHONE: [phone] REQUEST:
Please provide an Excel file showing all capital projects completed within the test year (July 1, 2021 through June 30, 2022). For each project, please provide the following: a. Name or Title; b. Project identifier(s) (BCJN, ER, and BI);
c. Plant-In-Service date;
d. Business Case classification (i.e. Generation, Transmission, Distribution, Environmental, Enterprise, Other, etc.); e. Rationale supporting the need for each capital investment; f. Whether a cost benefit analysis was completed (Yes/No);
g. Project dates: (i.e. target start date, actual start date, target completion date, and actual
completion date); h. Project costs: (i.e. estimated cost, budgeted cost, and actual cost). Note: Where adjustments were made to forecasted costs indicate the date and amount of the adjustment; i. Cost analysis considering whether the work should be completed by a contractor or primarily
using company employees (Yes/No);and j. If a contractor was used, was a request-for-proposal issued for the project (Yes/No). RESPONSE:

a. – d. Please see Staff_PR_094 Attachment A for a table that summarizes plant activity (actual and budget) for calendar 2021 and 2022, including Business Case, Expenditure Request (ER) and Budget Item (BI), the business case classification (function code), and the witness who’s testimony it was included in AVU-E-23-01 and AVU-G-23-01. After discussions with Staff
during their on-site audit during the week of April 24-28, 2023, the Company determined
providing calendar 2021 and 2022 business case actual and budget information, rather than split test period data (actual July 1, 2021 through June 30, 2022) and actual available pro forma data requested in Staff_PR_095 (actuals available: July 1, 2022 through February 28, 2023) would be more useful for comparison purposes of what Staff was looking for.

For detail transaction information, also providing information related to a. Name or Title; b. Project identifier(s) (BCJN, ER, and BI); c. Plant-In-Service date; and d. Business Case classification (i.e. Generation, Transmission, Distribution, Environmental, Enterprise, Other, etc.) see Avista’s response to Staff_PR_016 Supplemental 2 and Staff_PR_016 Supplemental 2
Attachment A. This file provides the updated capital additions workpapers (referred to in the Company’s original filing as Ms. Benjamin’s workpapers titled ‘3.08-3.11 – 24.01-24.02 PF – CAPITAL ADDITIONS’). Within this attachment, the Company has updated transfers-to-plant (TTP) with actuals for July 1, 2022 through February 28, 2023 and a revised TTP forecast for all
pro forma capital additions for March 1, 2023 through December 31, 2023. Pro forma capital
RECEIVED
2023 May 3, 5:14PM
IDAHO PUBLIC
UTILITIES COMMISSION
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additions (TTP) from January 1, 2024 through August 31, 2025 remain unchanged from the Company’s direct filed case. This attachment also provides the Revised 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 reflecting the impact of the updated TTP. Please note, while the TTP for 2024 and 2025 do not change, there is a flow through impact to RY2 from the impact of updating TTP in RY1 (2022 and 2023), as noted in adjustments 24.01 and 24.02.
e. – j. Due to the voluminous nature of this request, the Company is unable to provide the items e. – j requested, or summarize the requested information, in this response (and Staff_PR_095), for each Business Case/project filed within the Company’s direct filed case, representing system capital additions for the period July 1, 2021 – August 31, 2025.
However, included with the Company’s filed case are descriptions in testimony and the Business Cases for each capital addition representative of the transfers-to-plant included by the Company over its Two-Year Rate Plan, as shown Table No. 1 below. 1
Table No. 1 – Capital Projects TTP (System), Functional Area and Witness Exhibit Location

Most Business Cases included in the Company’s filed case provide the following information by Section: Executive summary, 1. Business problem, driver, need for project and risks if not completed (for example, section 1.5.1 in particular references any studies that support the
problem); 2. Metrics, data or analysis, cost, reductions to O&M if applicable, alternatives considered, timeline of project or program, why considered prudent, etc., which have been considered for determining the need for the work; and 3. Steering Committee or Advisory Groups overseeing/governance of the Business Case. This is discussed further below.

Although the Company is unable to provide the specific requested items e. – j. for all Business Cases/projects, the Company has provided much of the requested information specific to Staff’s production request numbers 98-124, representing 26 Business Cases (see table below), in which the Company is providing detailed documentation, including project charters, cost analyses,
budget to actual analyses, contracting considerations, change documents, and much more, as requested, to demonstrate the need for the project and diligence used by the Company when
1 As noted previously in this response, the Company has updated transfers-to-plant (TTP) with actuals for July 1, 2022
through February 28, 2023 and a revised TTP forecast for all pro forma capital additions for March 1, 2023 through December 31, 2023 in Staff_PR_016 Supplemental 2. Pro forma capital additions (TTP) from January 1, 2024 through
August 31, 2025 remain unchanged from the Company’s direct filed case.
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carrying out work. The Company has also spent multiple days with Staff presenting, discussing, and answering questions on twenty-two specific business cases (or projects) while Staff was on
site, as well as a field trip to one of Avista’s recently completed Substation Rebuild projects,
“Sunset Substation” and a tour of the Company’s Warehouse and Asset Recovery Departments. If Staff is interested in additional documentation beyond what has been provided through these avenues, the Company will gladly respond to additional specific requests beyond what is already being provided. (See the Table No. 2 below.)
Table No. 2 – Business Case Requested PR and Onsite Audit Review
Business Case
Supporting
Documentation
in PR #
Staff On-site
Meeting Director Witness
Base Load Thermal Program 101 Alexander Kinney
Cabinet Gorge Station Service 102 Alexander Kinney
Colstrip Generation Capital Projects 98-99 Alexander
CS2 Single Phase Transformer 103 x Alexander
HMI Control Software 104 Alexander Kinney
KF Fuel Yard 105 x Alexander Kinney
Long Lake Plant Upgrade 106 Alexander Kinney
Long Lake Stability Enhancements 107 Alexander
Noxon Spillgate Refurb 108 Alexander Kinney
Regulating Hydro 109 Alexander Kinney
Gas Facility Replacement Program (GFRP) Aldyl A Pipe Replacement x Gibbs DiLuciano
Gas Non-Revenue Program x Gibbs DiLuciano
Gas Replacement Street and Highway Program x Gibbs DiLuciano
Cabinet Gorge Dam Fishway 100 x Howard DiLuciano
Distribution Grid Modernization 120 Howell DiLuciano
Distribution Minor Rebuilds 121 x Howell DiLuciano
Elec Relocation and Replacement Program x Howell DiLuciano
Electric Storm 119 Howell DiLuciano
Wildfire Resiliency Plan x Howell Howell
Wood Pole Management 122 x Howell DiLuciano
Energy Imbalance Market 110 x Kinney Kinney
Fleet Services Capital Plan x Magalsky DiLuciano
Distribution System Enhancements 123 Malensky DiLuciano
Protection System Upgrade for PRC-002 111 Malensky DiLuciano
Saddle Mountain 230/115kV Station Integration Phase 2 112 x Malensky DiLuciano
Spokane Valley Transmission Reinf 113 Malensky DiLuciano
Substation New Distribution Station Capacity 124 x Malensky DiLuciano
Substation Rebuilds 116 x Malensky DiLuciano
Transmission Construction - Compliance 114 Malensky DiLuciano
Transmission Major Rebuilds - Asset Condition 118 x Malensky DiLuciano
Transmission Minor Rebuilds 117 Malensky DiLuciano
Transmission NERC Low-Risk Priority Lines Mitigation 115 Malensky DiLuciano
For additional supporting information on the following business cases, please refer to the identified Production Request as
well as Staff's on site meeting where the Company addressed several of the asked questions, such as labor considerations
and contracting and procurement practices.

In addition, Avista’s response to Staff_PR_016 identified 20 Business Cases for which the transfers-to-plant (additions to rate base) allocated or directly assigned to Idaho electric or Idaho natural gas exceeded $2 million annually in 2021 through January 2023 to date. Those 20 Business
Cases are listed below. Avista’s response to Staff_DR_017 provided requested copies of the cost/benefit analysis, internal rates of return, or similar analysis for each of the 20 capital Business Cases identified in Staff_DR_016 (some which overlap with Staff DRs 98-124 and discussions during Staff’s on-site audit noted above):

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Table No. 3 – Staff PR 016/017 Capital Investment Review

Please also see Staff_PR_096 for Avista’s Procurement Best Practices for Contracting Goods and Services and Avista’s Supply Chain Procedures for procuring goods and services, including issuing RFP’s. Furthermore, as discussed by Mr. Thies, when Avista makes any capital investment there is an
obligation to demonstrate that the overall need, evaluations of alternatives, and the planned timing of implementation is prudent and in the customer’s best interests. Whether the investment touches the customer directly, such as customer service or metering systems, or indirectly, such as improving the capability and efficiency of employees and internal work processes, each dollar
invested ultimately supports one purpose: to provide customers with safe, reliable, and
cost-effective energy services that meet their expectations for quality of service and value. In Mr. Thies’ testimony, he discusses the six drivers of investment: 1. To respond to customer requests for new service or service enhancements;
2. To meet regulatory and other mandatory obligations; 3. To replace equipment that is damaged or fails, and support field operations; 4. To replace infrastructure at the end of its useful life based on asset condition; 5. To meet our customers’ expectations for quality and reliability of service; and
6. To address system performance and capacity issues.
When evaluating investments, Avista applies a four-part prudency standard: 1. Demonstrated proof of need for a project. 2. Evidence that reasonable alternatives were considered that allowed objectively
selecting the best, most cost-effective alternative.
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3. Company awareness of the need for and approval of the project, meaning that affected employees have been made aware of and are in favor of the project and are
kept informed of any material changes.
4. Documentation is maintained during the course of the project that would allow a person (sometimes years later) to reach the same conclusions about key decisions based on what was known at the time, or should have been known by the project manager.
Projects are developed through various means including planning studies, engineering and asset management analyses, as scheduled upgrades or need for replacements are identified, or with observations made by expert personnel. These projects undergo internal review by multiple stakeholders within the business units themselves and through a formal review process at the
appropriate business area level, keeping the prudency standard referenced above in mind. The capital projects are identified in the lower-left portion of Illustration No. 1 below labeled “Business Unit Needs,” and are then prioritized within each department. This prioritization occurs with the knowledge of the continuing constraint on the capital spend level for the Company, while
at the same time the leadership of each department informs Senior Management of both the near-term and longer-term needs that are being delayed. For the prioritized projects, Business Cases2 are developed for each of the Capital Requests that go to the Capital Planning Group (CPG) (as illustrated in the diagram).

The Business Case for each prioritized project serves as the documentation of the justification of the investment and specifically addresses the proposed solution to the business problem and why it is the best and/or least cost alternative and why the investment is considered a prudent investment (see Business Case justification, specifically Section 2). As noted above in
Table No. 1, the Business Cases associated with the capital additions included in this case have been provided in the following witnesses exhibits:
Mr. Kinney: Exhibit No. 6, Schedule 4 – Generation and Environmental
Mr. DiLuciano: Exhibit No. 9, Schedule 3 – Electric Distribution, Transmission, Natural Gas Distribution, General Plant, Fleet and Facilities Resources Mr. Howell: Exhibit No. 10, Schedule 1 – Wildfire Resiliency Plan Mr. Kensok: Exhibit No. 11, Schedule 1 – Enterprise Technology
Ms. Hydzik: Exhibit No. 12, Schedule 1 – Customer Experience & Technology
2 A Business Case is a summary document that defines the business problem addressed by a project or program, along
with a proposal and recommended solution. The Business Case explains why the work is necessary, and the risks associated with not making the investment, as well as the alternatives considered, the selected alternative and the
timeline associated with the project.
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Business Unit
Needs FundedNot Funded(Deferred)
Capital Planning Group
Overall Infrastructure Priority and Capital Allocation
Capital Requests/Business Cases
Prioritization
Senior Management
Board Finance Committee
Illustration No. 1 - Identification and Prioritization Process

Further, to summarize the capital planning process, additional information can be found in greater detail in Mr. Thies’ Direct Testimony, describing that as part of the capital investment planning process, Business Cases are developed for each of the capital requests that go to the Capital
Planning Group (CPG). As he notes, the CPG uses the Business Cases to make budgeting
decisions and help prioritize work across departmental lines. As part of the budgeting process, Business Cases are further broken down by Expenditure Requests, which are further broken out by Budgeted Items. Each of the ERs are assigned BIs to
identify and track the costs of capital additions. Each Business Case contains one or more ER and each ER contains one or more BI. Many of the Business Cases have a single ER. Illustration No. 2 below is a simplified flowchart that illustrates this process. These levels are simply a tracking mechanism for folks managing the work and associated budget, the number of ERs and BIs per
Business Case can vary.
Illustration No. 2 - Sample Business Case, ER and BI Relationships

Finally, as discussed further in Avista’s response to Staff_PR_096, with regards to procurement of
capital materials, the Company procures its materials and services in a disciplined manner, that is
designed to obtain the maximum value for each dollar of expenditure. See the Company’s Procurement Best Practices for Contracting Goods and Services attached as Staff_PR_096 Attachment B. Specifically please see Section 7, “Competitive Bidding,” and Section 9, “Awards and Supplier Selection,” which has lowest overall cost as a key factor for supplier selection. It
is important to remember, though, that least cost might ultimately mean lowest life-cycle cost, not
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necessarily lowest upfront cost. Lowest cost items, upfront, may ultimately lead to a higher life cycle cost due to future O&M costs to keep an item or project operational. Key items from Section
7 and Section 9 include:
Section 7.3.1 - Bids are opened privately by Avista only after the deadline for receiving proposals has passed. Supply Chain Management reviews the bids for responsiveness and exceptions, and compares the bids, with an emphasis on pricing, terms, exceptions and/or
delivery, with the appropriate BU. Additional financial and risk analyses are performed as required. Legal and/or Risk Management review exceptions and form, as necessary. Section 9.1 - Suppliers should be selected on the basis of:
• Ability to provide materials, equipment and/or services in accordance with the
specifications;
• Ability to meet standards for quality, service level, and long term benefit to Avista;
• Optimum value / lowest overall cost;
• Financial and business stability, past performance and relevant experience; and
• Other pertinent factors as deemed necessary.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/02/2023 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-095 TELEPHONE: [phone] REQUEST: Please provide an Excel file showing all capital projects completed within the pro forma period
(July 1, 2022 through August 31, 2025). For each project separated by year, please provide the following: a. Name or Title; b. Project identifier(s) (BCJN, ER, and BI);
c. Plant-In-Service date;
d. Business Case classification (i.e. Generation, Transmission, Distribution, Environmental, Enterprise, Other, etc.); e. Rationale supporting the need for each capital investment; f. Whether a cost benefit analysis was completed (Yes/No);
g. Project dates: (i.e. target start date, actual start date, target completion date, and actual
completion date); h. Project costs: (i.e. estimated cost, budgeted cost, and actual cost). Note: Where adjustments were made to forecasted costs indicate the date and amount of the adjustment; i. Cost analysis considering whether the work should be completed by a contractor or primarily
using company employees (Yes/No);and j. If a contractor was used, was a request-for-proposal issued for the project (Yes/No). RESPONSE:

Please see Avista’s response to Staff_PR_094.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IPUC RESPONDER: Rubal Gill TYPE: Production Request DEPARTMENT: Operations Analytics
REQUEST NO.: Staff-096 TELEPHONE: [phone] REQUEST:
Please explain the Company's procedures for determining the need to initiate a request-for-proposal in constructing a capital project. Please also provide any Company policies and/or guidelines relevant to the process.
RESPONSE:
The capital determination for a project is made at the onset of the project, in the scoping and Business Case Justification stage. Once a project has been selected and approved to proceed, project teams may need the support of consultants, vendors, and contractors to help deliver scope
items that Avista does not have the expertise of, or the internal bandwidth to deliver with internal
resource capacity. Once these needs have been identified with department leadership and project teams, they engage with Avista’s Supply Chain Team for contract and procurement support. The respective departments and teams work with Supply Chain following their prescribed policies and processes for when an RFP is required and how agreements are established. Please see
Staff_PR_096 Attachment A for Avista’s Supply Chain Procedures. Supply Chain is responsible for administering Avista’s Request for Proposal (“RFP”) processes and serves as the single point of contact to manage all communications, including clarifications or
modifications, to ensure all RFP-related information is issued simultaneously to all potential
bidders. Competitive bids are solicited through a formal, confidential RFP when the potential value of the contract is $100,000 or more. RFP’s of lesser value are evaluated for opportunity and subject to competitive bidding or written quotations as advised by Supply Chain.
The Company procures its materials and services in a disciplined manner that is designed to obtain the maximum value for each dollar of expenditure. See the Company’s Procurement Best Practices for Contracting Goods and Services provided in Staff_PR_096 Attachment B. Specifically please see Section 7, “Competitive Bidding,” and Section 9, “Awards and Supplier Selection,” which has lowest overall cost as a key factor for supplier selection. It is important
to remember, though, that least cost might ultimately mean lowest life-cycle cost, not necessarily
lowest upfront cost. Lowest cost items, upfront, may ultimately lead to a higher life cycle cost due to future O&M costs to keep an item or project operational. Key items from Section 7 and Section 9 include:
Section 7.3.1 - Bids are opened privately by Avista only after the deadline for receiving proposals has passed. Supply Chain Management reviews the bids for responsiveness and exceptions, and compares the bids, with an emphasis on pricing, terms, exceptions and/or delivery, with the appropriate BU. Additional financial and risk analyses are performed as
required. Legal and/or Risk Management review exceptions and form, as necessary.

Section 9.1 - Suppliers should be selected on the basis of:
• Ability to provide materials, equipment and/or services in accordance with the
specifications;
• Ability to meet standards for quality, service level, and long term benefit to Avista;
• Optimum value / lowest overall cost;
• Financial and business stability, past performance and relevant experience; and
• Other pertinent factors as deemed necessary.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: DiLuciano REQUESTER: IPUC RESPONDER: John Gross TYPE: Production Request DEPARTMENT: System Planning
REQUEST NO.: Staff_PR_97 TELEPHONE: [phone] REQUEST:
Please provide data and any analyses showing how the following categorized transmission capital
investments are directly beneficial to Avista's Bulk Electric System (see Bulk Electric System (BES) Definition Reference Document (nerc.com) (https://www.nerc.com/pa/RAPA/BES%20DL/bes_phase2_reference_document 20140325 final clean.pdf). For each of the transmission projects listed below, please provide an explanation with
specific reasoning and examples indicating how these capital investments directly benefit the
Company's Idaho ratepayers: a. Saddle Mountain 230/ll5kV Station (New) Integration Project Phase 1; b. Saddle Mountain 230/115kV Station (New) Integration Project Phase 2;
c. Spokane Valley Transmission Reinforcement Project; and
d. Westside 230/115kV Station Brownfield Rebuild Project. RESPONSE:

The projects listed (a-d) were scoped to mitigate inadequate transmission system performance. The Transmission Elements associated with each of the projects are operated at 100kV or higher and do not meet any exclusion criteria of the NERC Bulk Electric System definition. Therefore, all the Transmission Elements associated with each of the projects are categorized as part of the Bulk
Electric System.
Please refer to Staff_PR_97 Attachments A through D as project reports containing data and analysis results from transmission system technical planning studies. Each report identifies how the transmission system would not meet applicable performance criteria and how the selected
project scopes mitigate the performance issues. The following list associates the referenced
attachments to the requested capital investments. a. Saddle Mountain 230/ll5kV Station (New) Integration Project Phase 1 i. Staff_PR_97 Attachment A - Avista Saddle Mountain Project V1
b. Saddle Mountain 230/115kV Station (New) Integration Project Phase 2 i. Staff_PR_97 Attachment A - Avista Saddle Mountain Project V1 ii. Staff_PR_97 Attachment B - Othello City Rebuild Study-V0 c. Spokane Valley Transmission Reinforcement Project
i. Staff_PR_97 Attachment C - Irvin Project Final
d. Westside 230/115kV Station Brownfield Rebuild Project i. Staff_PR_97 Attachment D - Westside Transformer Replacement - V1 The listed transmission capital investments are geographically located in the state of Washington.
Each project is scoped to mitigate transmission system performance issues as stated in the
associated attached documents. Avista is obligated to maintain acceptable transmission system performance through NERC Reliability Standards and requirements of the Reliability Coordinator
in the operating time horizon. Adherence to applicable NERC Reliability Standards is enforceable
through monetary fines which Avista would be obligated to pay if found to be in non-compliance. Additionally, investment and improvements to Avista’s transmission system, as part of the Bulk Electric System, provides for incremental transmission system capacity which could be used to provide Transmission Service to wholesale customers. Revenue obtained through Transmission
Service benefits Avista customers in all jurisdictions.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Steve Wenke TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-098 TELEPHONE: [phone] REQUEST:
Please provide the following documentation for the Colstrip Generation Capital Projects referenced in Kinney Direct Testimony, page 38. The response should include all individual projects within this filing where Avista is seeking recovery of the Company's capital investment. If any of the information requested below cannot be provided or is not available, please explain why,
and explain how the Company ensured the construction of the project was completed at least cost.
a. Analysis of Need -- a justification of need for the project and a cost/benefit analysis comparing alternatives. b. Project Plan i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule. c. Requests for proposals ("RFP") i. Project requirements. ii. Specifications.
iii. Short list bidder scorecard. iv. RFP from winning bid. d. Project construction documentation including: i. Construction contract.
ii. Organizational chart.
iii. Scope document. iv. Work breakdown structure. v. Baseline Schedule. vi. Monthly project status report(s).
vii. Action items list(s). viii. Contractors change order request(s). e. Company project completion analysis a. Lessons learned. b. Budget-to-actual comparisons for overall project and by year.
c. Baseline schedule-to-actual schedule comparison. d. For any actual costs differing from the budget amount by plus or minus five percent during a particular year, please list and explain the reason(s) for the budget amount difference. RESPONSE: Please see Avista's response Staff_PR_098C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.
In Mr. Kinney’s testimony, one capital project was identified for consideration related to this
Production Request. This was the Design/Build Dry Waste Disposal System which was
completed in October 2022. This project provides for installation of a “non-liquid” disposal system for Coal Combustion Residue (CCR) material created by the operation of Units 3 and 4. This capital project is required
as part of the AOC related litigation settlement. The specific response for this project are included below: a. Analysis of Need -- a justification of need for the project and a cost/benefit analysis comparing alternatives.
The Dry Waste Disposal (DWD) Project originated from the settlement of a 2016 lawsuit with
Sierra Club, Montana Environmental Information Center, and the National Wildlife Federation
and the Colstrip Owners. Litigation on the AOC resulted in a Settlement that required the owners
to convert to a “non-liquid” disposal of the coal combustion residual (CCR) by July 1, 2022. The
legal requirements for this project are defined in two documents, the Dry Disposal Certificate
Amendment Notice and the Montana Dept of Environmental Quality (MDEQ or DEQ) Major
Facility Siting Act amendment allowing implementation of this DWD project. These documents
are attached.
For each capital project, a “hurdle sheet” is created to provide the reason to do the project, description, identify alternatives, initial budget requirements, and other project information. This is attached as: 1) Staff_PR_098 Confidential Attachment a01 -Dry Disposal Certificate Amendment Notice
Final - 20May 2016
2) Staff_PR_098 Confidential Attachment a02 -DEQ Approval - MFSA Amendment
Non-Liquid Disposal 6-20-16 3) Staff_PR_098 Confidential Attachment a03 - Dry Waste Disposal System HRWS
b. Project Plan
i. Initial project scope. To meet the requirement of dry disposal of coal combustion residuals (CCR) at the Colstrip Units 3&4 Effluent Holding Pond (EHP), a Dry Disposal System was installed. This System takes the CCR material that is removed by the wet scrubbers at Units 3&4 and dewaters that material so that
it can be deposited in the EHP as a non-liquid material. The overall process includes an initial
dewatering step that removes most of the free available water from the CCR material. This initial dewatering step utilizes a Paste Production Storage Mechanism (PPSM), commonly termed a thickener, which removes water from the CCR material through a mechanical process that causes the CCR solids to settle out quickly and allows the water to be decanted off the top of the deep tank
thickener and returned to the scrubbers for re-use. The CCR that remain are then pumped to the Dry Disposal System which further dewaters the CCR material to a dry state (passes the paint filter test) and the dry material is deposited in the final disposal area, the EHP. The Dry Disposal System is a filter press technology with associated pumps, tanks, piping, conveyors,
instrumentation, and controls to produce a dry CCR material. The Dry Disposal System is
designed and built with backup equipment to meet the high reliability requirements for ongoing dry disposal of CCR material from Colstrip Units 3&4. The illustration below shows the slurry coming out of the scrubbers and schematically being
delivered to the Paste Plant where the new Dry Waste Disposal plant is to be added.

As it was not clear if a dry waste disposal system could work on coal ash as no project like this had
been performed on a coal ash slurry as was being proposed for Colstrip. A pilot program was
initiated to determine the viability of a system like this. This was completed in 2020 and did result
in some changes the original concept to assure the system would meet the terms of the agreement.

In January of 2021, and more develop plan, schedule, and cost estimate was developed.
b. Project Plan ii. Proposed budget.
The proposed budget for the system evolved as the project evolved. This evolution included demonstration projects to determine if the process proposed was viable for this application. The initial budget proposed a simplex system for this process – meaning there was no redundancy in the system should a single element fail. After discussions, it was concluded that the system should be built with complete redundancy for the overall system to meet the 85% availability target
required by the settlement agreement. This discussion is summarized in the e mail: 4) Staff_PR_098 Confidential Attachment b01 - 210104 Criswell - Dry Disposal Project Update

During the period of material procurement, COVID caused delays in equipment fabrication and delivery. These delays caused some cost increases in some areas as initiatives were taken on in order to meeting the July 1, 2022, project deadline. To achieve the required schedule, decisions were made by Project Management to move some of the equipment fabrication from the factory to
the job site. The exhibit Staff_PR_098 Confidential Attachment b05 - 210113 Criswell - Request
to Appv Struc Steel illustrates the decisions that were made. Expediting efforts were increased and alternative suppliers and contractors were pursued who could provide equipment and services to meet the schedule. Some of these activities did increase the final cost.

5) Staff_PR_098 Confidential Attachment b02 - 210113 Criswell - Request to Appv Struc
Steel
Scrubber
Paste Plant
6) Staff_PR_098 Confidential Attachment b03 - Colstrip 34 Dry Disposal Project Budget Approval Request 3-5-21
7) Staff_PR_098 Confidential Attachment b04 - 210507 Criswell - May Capital Request
8) Staff_PR_098 Confidential Attachment b05 - Colstrip Aug 2022 DWD Report 9) Staff_PR_098 Confidential Attachment b06 -20230419.0 Criswell - DWD Final Cost b. Project Plan
iii. Proposed schedule As described above, the project was initiated with a July 19, 2016, settlement agreement which required that a “non-liquid” disposal for CCR (i.e. Coal Combustion Residue) material be in place by July 1, 2022. Also, as described above, there was an amount of uncertainty associated with this requirement as to the knowledge of the project team on how to successfully implement this
requirement. The solutions being proposed were part of a demonstration project in 2020 that resulted in a final plan and schedule in January of 2021. Attached below is the initial schedule plan that shows the project being completed in time for the July 1, 2022, deadline. This schedule is attached below.

As the project experienced delays due to the impacts of COVID on material, equipment, and labor supply, it became evident that the project was not going to meet the original July 1, 2022, deadline. A request was made to MDEQ and the other settlement Parties to extend the July 1, 2022, deadline to October 1, 2022. This request was granted and a letter authorizing this extension was sent on
April 1, 2022. This is attached below.
Subsequently, during final commissioning, the Dry Waste Plant experienced some problems with getting the conveyors to fully function. A request was made to the settlement Parties and granted to move the final date to October 31, 2022. This request was granted September 15th and
acknowledged by the plant on September 16th. An E mail thread of this request and approval is attached below. 10) Staff_PR_098 Confidential Attachment b07 - Dry Disposal Preliminary Schedule 1-14-21
11) Staff_PR_098 Confidential Attachment b08 – Force Majeure Letter 3-21-22
12) Staff_PR_098 Confidential Attachment b09 – 22-04-01 Response to Force Majeure letter 13) Staff_PR_098 Confidential Attachment b10 – 20220916.0 Criswell DWD Extension 14) Staff_PR_098 Confidential Attachment b11 - 20221031.0 Criswell - DWD In Service
c. Requests for proposals ("RFP")
i. Project requirements. Project requirements evolved from preliminary engineering work done to demonstrate which of several options may be viable. This work established the basic project approach that was to govern the balance of the project. The record that shows this is an exchange documented in files:

15) Staff_PR_098 Confidential Attachment c01 - 210510.0 Criswell - Additional Dry Waste
Studies 16) Staff_PR_098 Confidential Attachment c02 - 31-1079-00-TW-TEC-001 Rev A Interim Test Work Results
17) Staff_PR_098 Confidential Attachment c03 - 31-1079-00-TW-REP-001 Rev B Ash
Dewatering TW Report 18) Staff_PR_098 Confidential Attachment c04 - LAB320068 TALEN ENERGY Report rev 1.0_en

Once the concept was finalized, final engineering, material procurement, and construction procurement was executed to meet the schedule already provided here as Staff_PR_098
Confidential Attachment b10 - Dry Disposal Preliminary Schedule 1-14-21.
c. Requests for proposals ("RFP") ii. Specifications. iii. Short list bidder scorecard.
iv. RFP from winning bid. This specific project was executed over a period of several years and involved many different vendors used for design, equipment, and construction contracts. These vendors were selected through several methods. In cases where the specialty of the supply was unique, they were sole sourced. In other instances, vendors were selected directly based on previous performance on
other projects at the plant or they were already under contract and work was executed with a change agreement. Some vendors were selected through a traditional bidding process where a low evaluated bid was awarded.
The specific documents requested for this project are numerous as three were at least 22 contracts
let out for this single project. All of this documentation is not included in this response. However, a table is attached below to provide a list of the contracts, their estimate, and the status of the agreement at the time this report was issued. This
19) Staff_PR_098 Confidential Attachment c05 - Paste Plant Dewatering Project-Vendor
Contract Summary d. Project construction documentation including: i. Construction contract.
ii. Organizational chart. As presented previously, there were 22 or more contracts associated with the construction of this project that was organized under a single Project Manager at the plant. The Project Manager reported to Talen management and was supported as needed by various staff
at the Colstrip plant for cost reporting and accounting, procurement of materials, logistics support, warehousing and equipment lay-up and storage. Support was also provided from Talen’s Corporate Office for some items (i.e. legal, engineering equipment procurement, expediting, etc.). d. Project construction documentation including:
iii. Scope document. In January of 2021, a final plan, schedule, and cost estimate was developed.

The scheme below is what was accepted for final development in January 2021

System Process Design Steps
1. Thickener underflow pumps located in the 3&4 Paste Plant will pump thickened tailings from the PPSM’s [i.e. Paste Plant Slurry Mix] to either of two agitated filter feed tanks. One filter feed tank and agitator will be operating, while the other tank and agitator will be standby for maintenance operations.
2. One operating filter feed pump will draw thickened tailings from the operating filter feed tank and pump the slurry to the recessed chamber pressure filters. Two of the filters will be operating and two will be standby. The filter feed pump will only feed one of the two operating filters at a time. When not feeding a filter, the pump will recirculate slurry to the feed tank. To reach the target cake moisture, the filtration cycle will have a form step followed by an air blow
drying step. 3. An air compressor will provide compressed air to the filter air receiver. The filter cycles will be staggered to allow the air receiver to be recharged for the air blow drying step for the second operating filter.
4. After the air blow drying step, a core wash and core blow cycle push the slurry from the
pressure filter core. The core wash slurry is recycled back to the operating filter feed tank through an air separator. When the core wash and\ core blow are complete, the pressure filters will open to discharge the dry filter cake onto their respective under‐filter conveyor. 5. The under‐filter conveyors are reversible to transfer the filter cake to one of two takeaway
conveyors depending on which take away conveyor is operating. The takeaway conveyor will
then transfer the filter cake to their respective truck load out bin which will be used to load haul trucks for material disposal. 6. During the filtration cycle, the filtrate will gravity flow to the agitated filtrate tank. The filtrate
return pumps deliver the filtrate to the Clearwell Pond (A Cell). The filtrate pumps will also
utilize the filtrate during the core wash cycle and for plant washdown and flushing lines and pumps. 7. The filter clothes are cleaned using a high‐pressure cloth wash. The wash water tank will be filled with clean water to be used in the cloth wash cycle. The water then gravity flows to a
small settling tank to allow solids to settle before the water is reused in the cloth wash system.

20) Staff_PR_098 Confidential Attachment d01 - Dry Disposal Project Technology Evaluation
21) Staff_PR_098 Confidential Attachment d02 - Past Plant Dewatering System
Scheme 22) Staff_PR_098 Confidential Attachment d03 -Paste Plant Dewatering Project Renderings
d. Project construction documentation including:
iv. Work breakdown structure. v. Baseline Schedule. A work breakdown structure was not created for this project. Above, the baseline schedule was provided as Staff_PR_098 Confidential Attachment b10 - Dry Disposal Preliminary Schedule
1-14-21
d. Project construction documentation including: vi. Monthly project status report(s).
vii. Action items list(s).
viii. Contractors change order request(s). Owners were apprised of the progress of this project periodically in the monthly Owners Meetings. The March 18, 2020 and the November 18, 2020 meeting minutes document these discussions.
23) Staff_PR_098 Confidential Attachment d04 - March 18 2020 U34rev2 Owners'
Meeting-Final 041420 24) Staff_PR_098 Confidential Attachment d05 - March 18 2020 U34rev2 Owners' Meeting-Final 041420
Project updates were provided to the Owners during Monthly project updates were provided at each Owners Meeting starting in December 2019. The attached file includes the monthly reports provided to the Owners during the duration of the planned project. 25) Staff_PR_098 Confidential Attachment d06 - DWD Project Update Reports

e. Company project completion analysis i. Lessons learned. ii. Budget-to-actual comparisons for overall project and by year.-
There have been several significant shifts in the budget on this project since it was initially
conceived after the 2016 Settlement Agreement was reached. Discussion with Golder on the Dry Disposal System started in June 2018 and Golder was asked for a proposal. There was not an RFP that led to Golder’s proposal. It was requested of them to
provide a proposal based on discussions which began in June 2018. This work was done with a
sole source justification based on the work being provided as a trial, pilot, proprietary, unique, or state of the art service. They provided their Proposal for a Fly Ash Dry Disposal Feasibility Study on 1/3/19 and we executed a contract with them on 1/21/19. The end date of this contract was 5/15/19 with the expectation of moving into the next phase which would be design
engineering/pilot testing. In June of 2019 they quit corresponding on the project and we went to Worley and Paterson & Cook to complete the design engineering process. The demonstration project proceeded with Worley and Paterson & Cook. The work here involved
some additional expenses as alternatives and materials were evaluated. As discussed previously,
this had not been done on an ash slurry from a coal unit before, so the investigation needed to
conclude with some certainty around the viability of the solution proposed. This process is documented with attachments already included in this material. Specifically: Staff_PR_098
Confidential Attachment c01 - 210510.0 Criswell - Additional Dry Waste Studies; Staff_PR_098
Confidential Attachment c02 - 31-1079-00-TW-TEC-001 Rev A Interim Test Work Results;
Staff_PR_098 Confidential Attachment c03 - 31-1079-00-TW-REP-001 Rev B Ash Dewatering TW Report; Staff_PR_098 Confidential Attachment c04 - LAB320068 TALEN ENERGY Report rev 1.0_en
During the development of the project there were a number of key changes to the project that caused the estimates to escalate. These included the decision to build the system with full redundancy so that it could meet the mandated 85% availability target. Additionally, once bids were issued, costs were higher than originally estimated. These escalations were due to several
factors including higher commodity costs as well as impacts to the supply chain due to the world wide COVID pandemic. The costs basis and some explanations are included in the attached budget history document.
26) Staff_PR_098 Confidential Attachment e01 - Dry Waste Disposal Budget History
e. Company project completion analysis iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the budget amount difference. As this project was reported monthly, a baseline to actual schedule was not created. It was also not created as part of the wrap up of the project as this project is not likely to occur again where the
time spent would provide a benefit. As described earlier in this response, there were several budget changes that occurred as this project progressed. These are documented in the e.iii. Budget-to-actual comparison section, and
d.vi Monthly Project Status Reports section, and b.ii Proposed Budget section of this response. Those discussions are not repeated here. See also Avista’s response to Staff_PR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Steve Wenke TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-099 TELEPHONE: [phone] REQUEST: Specific to the Colstrip plant, please describe the methods used to ensure capital investment projects were completed in a least cost manner. Please include any guidelines and procedures documenting these methods.
RESPONSE: Please see Avista's response Staff_PR_099C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is
separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. Per the Owners and Operations Agreement (O&O) Talen is designated as agent on behalf of the six Owners at Colstrip. Talen is bound by the conditions in the O&O agreement Paragraph 3.(b) [page 7 of the attached O&O Agreement] “The Operator, as agent for and on behalf of the Owners and
the Project Users, shall construct, operate and maintain the Project, hire all Project personnel,
and pay all Costs of Construction and Costs of Operation, all in accordance with Prudent utility Practice, the project Agreements, guidelines established from time to time by the Committee, and any applicable laws, regulations, orders, permits and licenses, now or hereafter in effect, of any
governmental authority having authority.”
Continuing, the O&O agreement stipulates in Paragraph 3.(d) “In every instance where Operator is required by any of the Project Agreements to act as agent for and on behalf of the Owners and/or Project Users, or any of the Owners and/or Project Users, Operator is hereby granted and
shall have the power to exercise authority to do everything necessary, proper and usual, in the
ordinary course of business, for effecting the purpose of its agency, including, but not limited to,
the power to enter into contracts with third parties for and on behalf of the Owners and/or Project Users, the power to make and receive payments, the power to initiate, compromise or settle claims with third parties, the power to act as agent in its own name, and the power to appoint subagents.”

1) Staff_PR_099 Confidential Attachment 1 - Ownership Agreements As these sections of the O&O agreement show, as an Owner, Avista has delegated the specific
methods of project management and controls as implied by this question to Talen Montana, the
Plant Operator. The plant does not follow a singular process as implied with this question. Projects are managed and executed through a variety of means and methods. The Plant Operator is held to a “Prudent Utility Practices” as identified in Paragraph 3.(b). The O&O agreement is attached to this response. Avista is aware that Talen has internal processes for bidding work, sole
sourcing work, and executing Change Orders with existing contractors, and utilizing the plant
work force to complete the work. While aware of these, Avista, nor the other owners, do not
review or provide oversite on these as these are clearly Prudent Utility Practices required by the delegated processes of the O&O agreement.

While the owners do not strictly approve many of the project decisions, there are several places of interaction where Owners are given the opportunity to input and monitor the work. The first is the review and approval of annual budgets where necessary work is scrutinized and ultimately a budget plan for project work is approved by the Owners. (This approval process is again governed
by the O&O agreement, Paragraph 7.) The first formalized part of this is the creation of a Hurdle Rate Work Sheet by the Operator that provides a basic statement of the why each project is needed, a high-level scope of work, alternatives if available, and cost estimates. These “Hurdle Sheets” are submitted to the Owners
for their review to support the adoption of a final annual budget. Ultimately, these are used to build budgets, work scopes, and schedules. These are used to establish the Owner approved budget for the year. Attached are the Hurdle Sheets for the 2022 Capital Budget items to illustrate this element of project selection and oversite.

2) Staff_PR_099 Confidential Attachment 2 - Hurdle Rate Work Sheets Another tool for the Owners to monitor the progress and management of a project are the monthly Budget to Actual Reports. An example of a report from December 2022 which shows the final
costs of the project work for 2022. There are several tabs that provide details on different elements
of the Capital, Asset Retirement Obligation (ARO), and O&M portions of the budget. These reports provide information 3) Staff_PR_099 Confidential Attachment 3 - 12-22 Bud vs Act Un 3-4
Finally, interactions with plant staff at in person Owners Meetings, phone calls, and other special sessions when they are held allow opportunity for the Owners to monitor the work. If requested, the Plant can provide details of project documents for the Owners to review.
See also Avista’s response to Staff_PR_094.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Michael Truex TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-100 TELEPHONE: [phone] REQUEST:
Please provide the following documentation for the Cabinet Gorge Dam Fishway project referenced by BCJN_01 of Kinney's Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of the project was completed at least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit
analysis comparing alternatives. b. Project Plan i. Initial project scope. ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals ("RFP") i. Project requirements. ii. Specifications. iii. Short list bidder scorecard.
iv. RFP from winning bid. d. Project construction documentation including: i. Construction contract. ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure. v. Baseline Schedule. vi. Monthly project status report(s). vii. Action items list(s).
viii. Contractors change order request(s). e. Company project completion analysis i. Lessons learned. ii. Budget-to-actual comparisons for overall project and by year. iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus five v. percent during a particular year, please list and explain the reason(s) for the vi. budget amount difference. RESPONSE:
Please see information requested provided in folders attached with this response, a summary of which has been provided below. a. Analysis of need – a justification of need for the project and cost/benefit analysis comparing
alternatives. The Business Case Justification Narrative is provided along with the Final Design
Report in Section A artifacts attached.
b. Project Plan. The project plans are detailed in the Project Charter and Project Management Plan
provided in Section B artifacts attached.
c. Requests for proposals (“RFP”) Provided in Section C artifacts attached.
i. Project requirements. Provided in Section C artifacts and project and contract specific
documents are with each contract respectively.
ii. Specifications. Provided in Section C artifacts.
iii. Short list bidder scorecard. Provided where applicable in Section C artifacts and project
and contract specific documents are with each contract respectively.
iv. RFP from winning bid. Provided in Section C artifacts. Additionally, Avista refers to these
as Agreements and Work Authorizations. Note the construction contract RFP was initially
issued in September 2015. Competitive bids were received from two firms (MJ Kuney
$41.7M and Slayden $22.8M) in December 2015. In January both bids were rejected and
Avista retained Slayden to engage in a collaborative CM/GC delivery model including
value engineering, pre-construction, cofferdam Design-Build, and CM/GC GMP
Construction contract which took place from March 2016 through June 2018.
d. Project construction documentation including:
i. Construction contract. Provided in Section C artifacts reference Contract R-42242.
ii. Organizational chart. Provided in Section D artifacts attached.
iii. Scope document. Please refer Section A artifacts for executive summary explanation of
project scope and the Design Drawings & Specifications provided in Section D artifacts.
iv. Work breakdown structure. The CGDF WBS was developed in P6 with the project
schedule development and integrated into Oracle Primavera Cloud when Avista GPSS
migrated to the new system and can be referenced in Section E artifacts.
v. Baseline Schedule. The CGDF schedule was developed in P6 and integrated into Oracle
Primavera Cloud when Avista GPSS migrated to the new system. The initial baseline
schedule is provided in Section D artifacts, is also embedded in the project planning
documents in Section B and is included with the project schedule comparison in Section E
artifacts.
vi. Monthly project status report(s). Provided in Section D artifacts.
vii. Action items list(s). These are provided and captured in Avista Project Team Meetings,
Avista Steering Committee Meetings, CGDF Project Team Meetings (Consultant, CM,
Engineering, Contractor) all of which are provided in Section D artifacts.
viii. Contractors change order request(s). The Project Change Log is provided the summarizes
the project changes and approvals for the project provided in Section D artifacts. Contract
change orders are provided with Section C artifacts.
e. Company project completion analysis
i. Lessons learned. Provided in Section E artifacts.
ii. Budget-to-actual comparisons for overall project and by year. Provided in Section E
artifacts attached. These artifacts include explanations and references to Business Case
Funds Changes Request to the Capital Planning Group.
iii. Baseline schedule-to-actual schedule comparisons. Provided in Section E artifacts.
iv. For any actual costs differing from the budget amount by plus or minus five percent during
a particular year, please list and explain the reason(s) for the budget amount difference.
This is provided in Section E artifacts and summarized with the Budget-to-actual
comparison. Additional Business Case Funds Change Requests as mentioned in the
summary have been provided in the Section E artifacts.

See also Avista’s response to Staff_PR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kinney REQUESTER: IPUC RESPONDER: Greg Wiggins TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-PR-101 TELEPHONE: [phone] REQUEST:
Please provide the following documentation for the Base Load Thermal Program projects referenced by BCJN_34 of Kinney's Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.

a. Analysis of need – a justification of need for the project and cost/benefit analysis comparing
alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent during a
particular year, please list and explain the reason(s) for the budget amount difference.
RESPONSE: Please see BCJN_34 of Kinney's Exhibit No. 6, Schedule 4 sections 1.1 to 2.1 for the justification
and analysis of need for the projects under the Base Load Thermal Program business case. Reference Staff_PR_101 Attachment A for a detailed list of fifty-nine projects funded in the Base Load Thermal Program. The Base Load Thermal Program is designed to fund projects at Kettle
Falls Generating Station and Coyote Springs 2. As stated in Staff_PR_101 Attachment B, the projects vary in scope, schedule, and budget. Four random projects were selected for further
review which include two projects from Kettle Falls Generating Station and two projects from
Coyote Springs 2. The two Kettle Falls Generating Station projects are examples of one break / fix project KF #2 Air Compressor Replacement and one planned project, KF D10R Dozer Certified Power Train Replacement Project. The two Coyote Springs 2 projects are examples of one break / fix project CS2 HRSG Expansion Joint Replacement Project and one planned project CS2 BFW
Pump A Backpressure Regulator Upgrade. Please see the attached files which contain documents to support the sample projects listed above. Each folder attached to this response contains a cover sheet addressing each item a. – e. requested along with additional supporting documents within the file structure: analysis of need,
project plan, request for proposal, and company project completion with supporting documents contained in each. (See summary files: “Staff_PR_101_Dozer Certified Powertrain Replacement”, “Staff_PR_101_KF #2 Air Compressor Replacement”, “ID PUC - CS2 BFW Backpressure Reg Replace” and “ID PUC - HRSG Expansion Joint Replacement”.) An overall summary description
of each item is provided below:
a. Analysis of need – The base load thermal program has a blend of planned and emergent
break / fix projects. Planned enhancement work is analyzed more thoroughly while break /
fix work is captured within the department asset management system.
b. Project Plan
i. Initial project scope. Each project listed on Staff_PR_101 Attachment A is either
scoped using the Thermal project intake document for planned work or Maximo1
work orders for direct break / fix projects.
ii. Proposed budget. See Staff_PR_101 Attachment A
iii. Proposed schedule. Varies depending on project type. Many projects are planned
during the Spring annual outage time frame but could happen anytime during the
year.
c. Requests for proposals (“RFP”)
iv. Project requirements. Some projects follow the Corporate Supply Chain RFP
process while other projects are direct equipment replacement projects utilizing the
Corporate Supply Chain purchase requisition process.
v. Specifications. Varies depending on project type.
vi. Short list bidder scorecard. Varies depending on project type.
vii. RFP from winning bid. Follow Corporate Supply Chain RFP process.
d. Project construction documentation including:
viii. Construction contract. Some projects follow the Corporate Contracting process other
projects are covered under the Corporate Supply Chain purchase purchase requisition
process.
ix. Organizational chart. Many projects are covered at the plant level, but some projects
utilize outside contractor support.
x. Scope document. Small projects are captured in the Maximo work order while larger
projects follow a more detailed scope.
xi. Work breakdown structure. Varies depending on project type.
xii. Baseline Schedule. Varies depending on project type.

1 Maximo is Avista’s work management system.
xiii. Monthly project status report(s). Project status is managed at the plant manager level
for smaller projects while larger projects utilize contractor reports.
xiv. Action items list(s). Captured with a Maximo Service Request.
xv. Contractors change order request(s). Utilize Corporate Supply Chain change order
process.
e. Company project completion analysis
xvi. Lessons learned. Varies depending on project.
xvii. Budget-to-actual comparisons for overall project and by year. Captured monthly and
reported up.
xviii. Baseline schedule-to-actual schedule comparisons. Captured monthly and reported
up.
xix. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference. Captured at the end of the project and filed with the project file.

See also Avista’s response to Staff_PR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Steve Gadau TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-102 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the Cabinet Gorge Station Service project
referenced by BCJN_11 of Kinney’s Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference.
RESPONSE:
a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives. The Business Case Justification Narrative is provided with the
original BCN dated 201704 in Section A artifacts attached.
b. Project Plan. The project plans are provided in the Charter, the original Business Case
Justification Narrative dated 201704, CG Station Service Basis of Design (BOD) Rev 4,
and Controls BOD Rev 2, all of which are provided in Section B artifacts attached.
c. Requests for proposals (“RFP”). The following Section C items have been provided in
Section C artifacts attached.
i. Project requirements. Provided in contract specific documents (Work
Authorizations) in each contract.
ii. Specifications. Provided in each contract.
iii. Short list bidder scorecard. Provided when items were bid out in “Purchased
Materials.” For items that were not bid out, a Sole Source Approval has been
provided for major equipment purchases.
iv. RFP from winning bid. Provided.
d. Project construction documentation including: The following documents are provided
in Section D artifacts attached.
i. Construction contract. Provided for R-40122 and R43215 contracts. Most of the
construction for this project has been executed from Avista crew, not under
contract. Additional contracts are pending. Provided in Section D artifacts.
ii. Organizational chart. Project Organizational structure is broken down in the
Charter table provided in Section B artifacts.
iii. Scope document. Provided CG Station Service BOD Rev 4, Budget Estimates CG
SS, Controls BOD Rev 2, Environmental Permit Packet, FERC Submittals, and
construction transmittals that have been issued in phased approach. To date,
transmittals through phase 3 of 10 have been issued to Avista crew for construction.
iv. Work breakdown structure. Provided in P6 schedule.
v. Baseline Schedule. Provided in P6 schedule.
vi. Monthly project status report(s). Provided.
vii. Action items list(s) Provided critical meeting notes.
viii. Contractors change order request(s). See associated Change Requests, also
listed in Project Change Log.
e. Company project completion analysis.
i. Lessons learned. Not completed until the end of the project.
ii. Budget-to-actual comparisons for overall project and by year. Provide year by
year reporting of budget vs actual in GPSS Budget Reporting Status Sheet. Also
reference Project Change Log, and associated In Year Financial Change Requests.
These are provided in Section E artifacts.
iii. Baseline schedule-to-actual schedule comparison. Provided P6 schedule in
Section E artifacts.
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference. Provided in GPSS Budget Reporting Status Sheet in
Section E artifacts attached’

See also Avista’s response to Staff_PR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Mike Mecham TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-PR-103 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the CS2 Single Phase Transformer project
referenced in the Company’s response to Staff Production Request 17. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference.
RESPONSE: a. Analysis of need – Please see the following documents for Analysis of Need information.
i. Attachment A – 20190731 Decision Tree Narrative
ii. Attachment B – 20190919 CS2 GSU Single Phase Transformer Business Case iii. Attachment C - 20190919 Power Supply Asset Management Consolidated Financial
Analysis iv. Attachment D - Appendix II CS2 GSU engineering recommendation v. Attachment E - CS2_Transformer_Analysis_080719 (Financial analysis) vi. Attachment F - Xfrmr Rev Req5. (CIRR Analysis)
b. Project Plan
i. Initial project scope. See Black & Veatch concept report Attachment G - B&V
Design-Avista-CoyoteSpgs-GSU-Replcmt-Concept-Report_Final_Rpt-w-ATT rev
ii. Proposed budget. Attachment H - Coyote 4820 (overall budget estimate update)
iii. Proposed schedule. Two year Black & Veatch schedule Attachment I - 403868_Coyote
Spgs GSU Xfmr_Project-Schedule_Update_24MAR2020
iv. Attachment J - 2020.05.07 Funds Change Request CS2. Funds Change Request discussing
reasoning for a two-year project.
c. Requests for proposals (“RFP”). The following Section C items have been provided in Section C
artifacts.
i. Project requirements. Provided in contract specific documents (Work Authorizations) in
each contract.
ii. Specifications. Provided in each contract.
iii. Short list bidder scorecard. Provided when items were bid out in “Purchased Materials.”
For items that were not bid out, a Sole Source Approval has been provided for major
equipment purchases.
iv. RFP from winning bid. Provided.
d. Project construction documentation including:
i. Construction contract. These are provided in the reference Section C artifacts.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
i. Attachment K - Avista Coyote Springs Phase II 09JUN21 By Scope w Resources
ii. Attachment L - Avista Coyote Springs Phase II 09JUN21 Overall w resources
vi. Monthly project status report(s). Attachment M - 4. Monthly Report_Coyote_April 2021
(Example)
vii. Action items list(s).
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned. Attachment N - 5.2 Lessons Learned - CS2 91321
ii. Budget-to-actual comparisons for overall project and by year.
i. Attachment O - White Paper Coyote Budget 11.24.21_Revised Final.
ii. Attachment P - 2021.07.20 Funds Change Request CS2 TCD
iii. Attachment Q - 2021.11.09 Funds Change Request CS2 TCD
iii. Baseline schedule-to-actual schedule comparisons. Captured monthly and reported up.
iv. For any actual costs differing from the budget amount by plus or minus five percent during
a particular year, please list and explain the reason(s) for the budget amount difference.
Captured at the end of the project and filed with the project file.

See also Avista’s response to Staff_PR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: CJ Mcmahon TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-104 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the HMI Controls Software project referenced by
BCJN_16 of Kinney’s Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference.
RESPONSE: The information requested has been summarized below. A. Analysis of Need: The current Business Case Justification Narrative (BCJN) dated
7.9.2021 is provided in Section A artifacts attached.
B. Project Plan
i. Initial Project Scope: Project scope is outline in the HMI Joint Charter
provided in Section B artifacts attached. ii. Proposed Budget: Cash flow and budget analysis are provided in Section B artifacts.
iii. Proposed Schedule: A representative sample of the documentation generated and distributed to the project team on a regular cadence (some weekly, some monthly), depending on the life cycle phase of project sub-components (design, execution, closeout etc.) Provided in Section B
artifacts. C. Requests for Proposals (RFP) – Contracted work under this project includes the following scopes and or sub-components of scopes:
i. Project Requirements: Provided in contract specific documents (Work
Authorizations) in each contract. ii. Specifications: Provided in each contract.
iii. Bidder Scorecard: Provided when items were bid out in “Purchased
Materials.” For items that were not bid out, a Sole Source Approval has been provided for major equipment purchases. D. Project Construction Documentation:
i. Construction Contract: There is no contracted construction on this project. The only consultant involved in this scope of work is CASNE Engineering, on contract for Screen Design and Ignition Software expertise and support. Their contract documentation is provided above in the attachments referenced in
Section C.
ii. Org Chart: Provided in Section D artifacts, attached. iii. Scope Document: N/A, since no specific construction component – scope provided in project records previously requested under Section A. iv. WBS: N/A, since no specific construction component – scope provided in
project records previously requested under Section B artifacts v. Baseline Schedule: N/A, since no specific construction component – scope provided in project records previously requested under Section B artifacts vi. Monthly Project Status Reports: Provided in Section D artifacts vii. Action Items Lists: A representative sample of meeting minutes and action
items are provided in Section D artifacts viii. Contract Change Order Requests: Casne Engineering Change Orders 1-6 are provided in Section D artifacts. E. Company Project Completion Analysis
i. Lesson Learned – N/A ii. Budget to Actuals – additional budget forecast detail can be found in the Steering Committee slide deck referenced in section B artifacts

iii. Baseline Schedule to Actuals and iv. Variance explanation – Specific project schedule changes can be seen by comparing the two schedules previously provided in Section B artifacts
See also Avista’s response to Staff_PR_094.
Year Budget Actual/Forecast
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Greg Crossman TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-105 TELEPHONE: [phone] REQUEST:
Please provide the following documentation for the Kettle Falls Fuel Yard Upgrade project referenced by BCJN_20 of Kinney’s Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference.
RESPONSE: a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives. The Business Case Justification Narrative is provided in Section
A artifacts.
b. Project Plan. The project plans are detailed in the Project Charter provided in Section B
artifacts.
c. Requests for proposals (“RFP”) Provided in Section C artifacts.
i. Project requirements. Provided in Section C artifacts and project and contract
specific documents are with each contract respectively.
ii. Specifications. Provided in Section C artifacts.
iii. Short list bidder scorecard. Provided where applicable in Section C artifacts and
project and contract specific documents are with each contract respectively.
iv. RFP from winning bid. Provided in Section C artifacts. Construction was broken
into two “phases”: underground phase and a “balance of plant” (BOP) phase.
Underground was awarded to and executed by Greenberry Industrial. Following
that package, an RFP was issued for BOP construction. Only one RFP response was
received and Avista opted not to award; instead, Avista procured BOP construction
by awarding individual scopes to various firms in a multi-prime arrangement.
Those contract documents are also provided in Section C artifacts.
d. Project construction documentation including:
i. Construction contract. Phase 1 construction contract is provided in Section C
artifacts; reference Contract R-43294. Phase 2 was executed in a multi-prime
arrangement with multiple construction contracts awarded, which are also provided
in Section C artifacts.
ii. Organizational chart. A RACI-type Roles & Responsibilities Matrix is provided
in Section D artifacts.
iii. Scope document. Please refer Section A artifacts for executive summary
explanation of project scope and the Design Drawings & Specifications provided in
Section C artifacts.
iv. Work breakdown structure. The design engineer consultant created the baseline
WBS. This was utilized to inform the baseline schedule and project estimates. This
document is included in its original MS Excel format in Section D artifacts.
v. Baseline Schedule. The KFFY schedule was developed in MS Project. The initial
baseline schedule is provided in Section D artifacts and is included for the project
schedule comparison in Section E artifacts.
vi. Monthly project status report(s). Provided in Section D artifacts.
vii. Action items list(s). These are provided and captured in Project Status Meetings
and Avista Steering Committee Meetings, all of which are provided in Section D
artifacts.
viii. Contractors change order request(s). The Project Change Log and associated
Project Change Requests summarize the project changes and approvals for the
project provided in Section D artifacts. Contract change orders are provided with
Section C artifacts.
e. Company project completion analysis
i. Lessons learned. The project is transferred to plant and operational, however some
construction activities remain. A Lessons Learned workshop is being scheduled for
the summer of 2023 as the remaining items approach completion.
ii. Budget-to-actual comparisons for overall project and by year. Provided in
Section E artifacts. These artifacts include explanations and references to Business
Case Funds Changes Request to the Capital Planning Group.
iii. Baseline schedule-to-actual schedule comparisons. When Avista GPSS
migrated to Oracle Primavera Cloud, the schedule had changed significantly from
the MS Project baseline (provided in Section D artifacts) so the original schedule
was not migrated into the new system. The most recent project schedule from the
new system is provided in Section E artifacts for comparison with the baseline
provided in Section D artifacts.
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference. This is provided in Section E artifacts and
summarized with the Budget-to-actual comparison. Additional Business Case
Funds Change Requests as mentioned in the summary have been provided in the
Section E artifacts.
See also Avista’s response to Staff_PR_094.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: James Edwards TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-106 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the HMI Controls Software project referenced by
BCJN_16 of Kinney’s Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference.
RESPONSE: a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives. The Business Case Justification Narrative is provided along with
the Voltage Change Study that drove the decision to change generator voltage in Section A
artifacts.
b. Project Plan. The project plans are detailed in the Project Charter and Project
Management Plan (PMP) provided in Section B artifacts.
c. Requests for proposals (“RFP”) Provided in Section C artifacts.
i. Project requirements. Provided in Section C artifacts and project and contract
specific documents are with each contract respectively.
ii. Specifications. Provided in Section C artifacts.
iii. Short list bidder scorecard. Provided where applicable in Section C artifacts and
project and contract specific documents are with each contract respectively.
iv. RFP from winning bid. Provided in Section C artifacts. Additionally, Avista
refers to these as Agreements and Work Authorizations. Bridge crane work was
awarded through a competitive bid and work was completed in 2017-18. In 2021 an
RFP was issued for generators. Bids were received from six suppliers and
ultimately the contract was awarded to General Electric. Program FEED (front end
engineering and design) was awarded through a competitive bid process. Three
firms bid and the award was given to Stantec. A competitive bid process is being
prepared for detailed design of the program. Generating Step-Up Transformers
(GSUs) were issued on a competitive bid. The award was given to GE Prolec.
d. Project construction documentation including:
i. Construction contract. Provided in Section C artifacts.
ii. Organizational chart. Provided in Section D artifacts.
iii. Scope document. Please refer Section A artifacts for executive summary
explanation of project scope, Section B artifacts, Charters and PMPs, for further
developed and detailed scope associated with individual projects, and lastly, Scope
Documents, in Section D.iii.
iv. Work breakdown structure. The LLPU WBS was developed in P6 with the
project schedule development and integrated into Oracle Primavera Cloud when
Avista GPSS migrated to the new system and can be referenced in Section E
artifacts. They are shared at the Program level, as well as for the individual projects
within the program.
v. Baseline Schedule. The LLPU schedule was developed in P6 and integrated into
Oracle Primavera Cloud when Avista GPSS migrated to the new system. The initial
baseline schedule is provided in Section D artifacts, is also embedded in the project
planning documents in Section B and is included with the project schedule
comparison in Section E artifacts.
vi. Monthly project status report(s). Provided in Section D artifacts.
vii. Action items list(s). These are provided and captured in Avista Project Team
Meetings, Avista Steering Committee Meetings LLPU Project Team Meetings
(Consultant, CM, Engineering, Contractor) all of which are provided in Section D
artifacts. Action Items lists are also shared within the Section D artifacts.
viii. Contractors change order request(s). The Project Change Log is provided the
summarizes the project changes and approvals for the project provided in Section D
artifacts. Contract change orders are provided with Section C artifacts.
e. Company project completion analysis
i. Lessons learned. Provided in Section E artifacts.
ii. Budget-to-actual comparisons for overall project and by year. Provided in
Section E artifacts. These artifacts include explanations and references to Business
Case Funds Changes Request to the Capital Planning Group.
iii. Baseline schedule-to-actual schedule comparisons. Provided in Section E
artifacts.
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference. This is provided in Section E artifacts and
summarized with the Budget-to-actual comparison. Additional Business Case
Funds Change Requests as mentioned in the summary have been provided in the
Section E artifacts.

See also Avista’s response to Staff_PR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Michael Truex TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-107 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the Long Lake Stability Enhancement projects
referenced by BCJN 24 of Kinney's Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost. a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference.
RESPONSE: a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives. The Business Case Justification Narrative is provided in Section A
artifacts.
b. Project Plan. The project plans are detailed in the Project Charter in Section B artifacts.
c. Requests for proposals (“RFP”) This project is in the engineering and design stage of the
project and has not gone to construction at this time. There was intent to break out a smaller
project within the business case to drill and install water-stop on the spillway construction
joints and corner block in May 2021. The global project design and 3D Finite Element
Model (FEM) development in conjunction with the water-stop Potential Failure Mode
Analysis for Construction resulted in concerns with pressure grouting adjacent and on the
piers without doing some additional field engineering and stability mitigation. A decision
was made with the technical project team and steering committee to proceed with doing
more detailed field engineering on the spillway piers, proceed with 3D FEM Phase 5,
proceed with geotechnical engineering, and post pone water stop drilling and installation
until additional field engineering has been performed. Engineering & design contract
documentation has been provided in Section C artifacts.
i. Project requirements. The technical team is still developing the technical
requirements as part of the design process.
ii. Specifications. The technical team is still developing the technical specifications
as part of the design process.
iii. Short list bidder scorecard. This is not applicable at this time.
iv. RFP from winning bid. This is not applicable at this time.
d. Project construction documentation including:
i. Construction contract. This is not applicable at this time.
ii. Organizational chart. The project technical team organizational chart is provided
in Section D artifacts.
iii. Scope document. Please refer Section A artifacts for executive summary
explanation of project scope.
iv. Work breakdown structure. The detailed project WBS will be developed as the
final elements of the design are completed, but at not completed at this time.
v. Baseline Schedule. The current project schedule with the primary design elements
is included in Section D artifacts.
vi. Monthly project status report(s). Provided in Section D artifacts.
vii. Action items list(s). Pertinent steering committee meeting minutes are provided in
Section D artifacts.
viii. Contractors change order request(s). This is not applicable at this time.
e. Company project completion analysis. The project is currently in the engineering and
design functions of the Planning process group within the Avista Project Delivery
Framework. The requested artifacts are not applicable at this time.
i. Lessons learned. This is not applicable at this time because of the stage this project
is currently in.
ii. Budget-to-actual comparisons for overall project and by year. This is not
applicable at this time because of the stage this project is currently in.
iii. Baseline schedule-to-actual schedule comparisons. The project team is still in
the process of developing the construction baseline with the design progression.
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference. This is not applicable at this time because of the stage
this project is currently in.
See also Avista’s response to Staff_PR_094.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Wendy Iris TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-108 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the Noxon Rapids Spillgate Refurbishment
project referenced by BCJN_32 of Kinney’s Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference.
RESPONSE: a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives. The Business Case Justification Narrative is provided in Section
A artifacts.
b. Project Plan. The project plans are detailed in the Project Charter in Section B artifacts.
c. Requests for proposals (“RFP”) Knight Construction was selected utilizing Sole Source.
Knight designed and constructed the Stop Log system that would need to be used to
perform the Spillgate Work and their intimate knowledge of the Noxon Rapids Facility and
the Stop Log system is cost savings. The pertinent sourcing approval and contract
documentation is provided in Section C artifacts.
d. Project construction documentation including:
i. Construction contract. The construction contract documentation is provided in
Section C artifacts.
ii. Organizational chart. The project is utilizing the organizational role table
provided in the charter in Section B artifacts.
iii. Scope document. Please refer Section A artifacts for executive summary
explanation of project scope.
iv. Work breakdown structure. The NR Spillgate WBS was developed in P6 with
the project schedule development and integrated into Oracle Primavera Cloud
when Avista GPSS migrated to the new system. The overall project schedule is
provided in Section E artifacts.
v. Baseline Schedule. The NR Spillgate WBS was developed in P6 with the project
schedule development and integrated into Oracle Primavera Cloud when Avista
GPSS migrated to the new system. The overall project schedule is provided in
Section E artifacts. High level schedule baseline milestones are provided in the
Charter in Section B artifacts.
vi. Monthly project status report(s). Provided in Section D artifacts.
vii. Action items list(s). Pertinent meeting minutes are provided in Section D artifacts.
viii. Contractors change order request(s). The construction contract documentation is
provided in Section C artifacts.
e. Company project completion analysis. As of this filing, the project is not complete.
Construction will resume in the Summer of 2023 and complete by December 2023.
a. Lessons learned. This is not applicable at this time.
b. Budget-to-actual comparisons for overall project and by year. Pertinent
funds change request have been provided in Section E artifacts.
c. Baseline schedule-to-actual schedule comparisons. This is provided in
Section E artifacts.
d. For any actual costs differing from the budget amount by plus or
minus five percent during a particular year, please list and explain the
reason(s) for the budget amount difference. Pertinent funds change
request have been provided in Section E artifacts.
See also Avista’s response to Staff_PR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Greg Wiggins TYPE: Production Request DEPARTMENT: GPSS
REQUEST NO.: Staff-PR-109 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the Regulating Hydro projects referenced by
BCJN_34 of Kinney's Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost. a. Analysis of need – a justification of need for the project and cost/benefit analysis
comparing alternatives
b. Project Plan
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”)
i. Project requirements.
ii. Specifications.
iii. Short list bidder scorecard.
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract.
ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule.
vi. Monthly project status report(s).
vii. Action items list(s)
viii. Contractors change order request(s).
e. Company project completion analysis
i. Lessons learned.
ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparisons.
iv. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference.

RESPONSE: Please see BCJN_34 of Kinney's Exhibit No. 6, Schedule 4 sections 1.1 to 2.1 for the justification and analysis of need for the projects under the Regulating Hydro business case.

Please see Staff_PR_109 Attachment A for a detailed list of the projects included in the Regulating Hydro business case. The Regulating Hydro business case is designed to fund projects at the four
largest hydro plants on Avista’s system: Noxon Rapids and Cabinet Gorge on the Clark Fork River
in Montana and Idaho and Long Lake and Little Falls on the Spokane River. As stated in the narrative, the projects vary in size and support needed based on the nature of the project. Medium to small projects can be implemented by a project engineer or project coordinator and many can be handled by contractors managed by local site personnel. The smaller projects consist of break-fix,
direct replace and small upgrades and will not have the level of documentation a large project with a larger stakeholder group and an assigned project manager will have. Most projects will be documented at a level that will satisfy b.i, b.ii, and b.iii of the request in the form of a Capital Project Request (CPR) as some are unplanned/reactionary and spin up quickly
when equipment breaks down and needs a timely turnaround to make it operational. Five projects were selected for further review which include two Noxon Rapids projects (NR Emergency Generator and NR Air Shaft #4), one Cabinet Gorge project (Cabinet Gorge Access Road), one Little Falls project (LF Spillway Conduit Relocation) and one Long Lake project (LL Parking
Lot). Please see each project folder and its attached files which contain documents to support the
sample projects listed above. Each folder for each project attached to this response contains a cover sheet addressing each item a. – e. requested, along with additional supporting documents within the file structure:
analysis of need, project plan, request for proposal, and company project completion with
supporting documents contained in each. (See summary files: “Staff_PR109 - LF Conduit Replacement Coversheet”, “Staff_PR109 - 20305168 LL Parking Lot Coversheet”, “Staff_PR109_30405165 CG Access Road_Coversheet”, “Staff_PR109 - 40105197 NR EG Coversheet” and “Staff_PR109 - 40105254 Air Shaft #4 Coversheet”.) An overall summary
description of each item is provided below:
a. Analysis of need – The regulating hydro program has a blend of planned and emergent
break / fix projects. Planned enhancement work is analyzed more thoroughly while break /
fix work is captured within the department asset management system.
b. Project Plan
i. Initial project scope. Each project listed on Staff_PR_109 Attachment A is either
scoped using the Hydro project intake document for planned work or Maximo work
orders for direct break / fix projects.
ii. Proposed budget. See Staff_PR_109 Attachment A
iii. Proposed schedule. Varies depending on project type. Many projects are planned
during the Spring annual outage time frame but could happen anytime during the
year.
c. Requests for proposals (“RFP”)
iv. Project requirements. Some projects follow Corporate Supply Chain RFP process
while other projects are direct equipment replacement projects utilizing Corporate
Supply Chain purchase requisition process.
v. Specifications. Varies depending on project type.
vi. Short list bidder scorecard. Varies depending on project type.
vii. RFP from winning bid. Follow Corporate Supply Chain RFP process.
d. Project construction documentation including:
viii. Construction contract. Some projects follow the Corporate Contracting process other
projects are covered under the Corporate Supply Chain purchase requisition process.
ix. Organizational chart. Many projects are covered at the plant level, but some projects
utilize outside contractor support.
x. Scope document. Small projects are captured in the Maximo work order while larger
projects follow a more detailed scope.
xi. Work breakdown structure. Varies depending on project type.
xii. Baseline Schedule. Varies depending on project type.
xiii. Monthly project status report(s). Project status is managed at the plant manager level
for smaller projects while larger projects utilize contractor reports.
xiv. Action items list(s). Captured with a Maximo Service Request.
xv. Contractors change order request(s). Utilize Corporate Supply Chain change order
process.
e. Company project completion analysis
xvi. Lessons learned. Varies depending on project.
xvii. Budget-to-actual comparisons for overall project and by year. Captured monthly and
reported up.
xviii. Baseline schedule-to-actual schedule comparisons. Captured monthly and reported
up.
xix. For any actual costs differing from the budget amount by plus or minus five percent
during a particular year, please list and explain the reason(s) for the budget amount
difference. Captured at the end of the project and filed with the project file.
See also Avista’s response to Staff_PR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/02/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Annette Brandon TYPE: Production Request DEPARTMENT: Resource Marketing
REQUEST NO.: Staff-110 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the Energy Imbalance Market projects
referenced by BCJN_36 of Kinney's Exhibit No. 6, Schedule 4. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives. b. Project Plan i. Initial project scope. ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals ("RFP") i. Project requirements. ii. Specifications. iii. Short list bidder scorecard.
iv. RFP from winning bid. d. Project construction documentation including: i. Construction contract. ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure. v. Baseline Schedule. vi. Monthly project status report(s). vii. Action items list(s).
viii. Contractors change order request(s). e. Company project completion analysis i. Lessons learned. ii. Budget-to-actual comparisons for overall project and by year. iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus five percent during a particular year, please list and explain the reason(s) for the budget amount difference. RESPONSE: Please see Avista's response Staff_PR_110C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.

The Company is including Company witness Mr. Kinney’s direct testimony (Staff_PR_110 Attachment K - Kinney Testimony ID 2021) and Exhibit No. 8, Schedules 1-12 (Staff_PR_110
Attachment K - Kinney Exhibit 8, Schedule 1-12 and Staff_PR_110C Confidential Attachment L -
Kinney Exhibit 8, Schedule 8(C), 10(C)), from the 2021 Idaho General Rate Case, and all Schedules for reference purposes for this production request. The majority of the information requested can be found within these documents. Please see below for which Exhibit No. 8, Schedule 1-12 from Attachments K or Confidential Attachment L is applicable:
a. Please See Schedule 11 (Att K) which includes the Energy and Environmental Economics (E3) EIM Benefit analysis report. Please see also Schedule 12 (Att K) which includes the EIM Business Case.
b. (i) – (iii) Please see Schedule 6 (Att K) for the initial EIM Program Charter dated May 2019, which includes initial project scope, budget and proposed schedule. Schedule 7 (Att K), the Program Scope document provides the updated scope, budget, and proposed schedule as of October 2020.

c. In this context, the Company understands this request to be twofold: the first is whether there was an RFP for the system integrator and the second for software. In terms of system integrator, Utilicast was utilized as a sole source provider, please see Staff_PR_110C Confidential Attachment A for this document. The RFP for the
software resulted in three bidders, and PCI was selected for the majority of the
software, and Power Settlement was chosen for EIM settlement calculations. The software requirements Staff_PR_110C Confidential Attachment B and the vendor scorecard Staff_PR_110C Confidential Attachment C and winning bidders (listed above) is provided also in Staff_PR_110C Confidential Attachment B.
d. (i) Project construction documentation including: The majority of the construction work was conducted by internal Avista employees with the exception of installing Automated Generation Control (AGC) at the Lancaster Combustion Turbine plant (see Staff_PR_110C Confidential Attachment D), which also included a communications
fiber agreement with Bonneville Power Administration to support the AGC (see Staff_PR_110 Attachment E). (ii). The Company maintained a program-level organization chart. Please see Staff_PR_110 Attachment F.
(iii). The Lancaster AGC project scope, schedule and budget are provided as Staff_PR_110C Confidential Attachment G (Lancaster AGC).
(iv) Please see part (iii)
(v) Please see part (iii) (vi) Monthly project status report(s). The monthly project status reports were tracked
as part of monthly Steering Committee presentations at the director and executive level. These have been consolidated into one filing as Staff_PR_110C Confidential Attachment H.
(vii) Specific action items are listed in the monthly project status report updates and
meeting notes. Please see part (vi)
(viii) Please see Staff_PR_110C Confidential Attachment I (Lancaster AGC).

e. Company project completion analysis (i) – (iv)The Company has a Program Close document date November 2022, which includes an overview of the program and associated projects, and includes all of the information listed below, with the exception of part (i) and (ii). Budget to actual is
available at the total project level. Lessons learned was part of the overall discussion held monthly throughout the process in conversations held regularly. See Staff_PR_110C Confidential Attachment J. See also Avista’s response to Staff_PR_094.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: DiLuciano REQUESTER: IPUC RESPONDER: Glenn Madden TYPE: Production Request DEPARTMENT: Electrical Engineering
REQUEST NO.: Staff-111 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the Protection System Upgrade for PRC-002
projects referenced by BCJN_ 15 of Diluciano's Exhibit No. 9, Schedule 3. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit analysis comparing
alternatives. b. Project Plan i. Initial project scope. ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals ("RFP") i. Project requirements. ii. Specifications. iii. Short list bidder scorecard.
iv. RFP from winning bid. d. Project construction documentation including: i. Construction contract. ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure. v. Baseline Schedule. vi. Monthly project status report(s). vii. Action items list(s).
viii. Contractors change order request(s).
e. Company project completion analysis i. Lessons learned. ii. Budget-to-actual comparisons for overall project and by year. iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the budget amount difference. RESPONSE:
See also Avista’s response to Staff_DR_094. The Protection System Upgrade for PRC-002 contains several smaller projects within it. The largest and most significant project in the Protection System Upgrade for PRC-002 Business Case
was the Rathdrum PRC Substation Project.

a. – e. The attachments provided in this response are documents to support this project as an example of the decision making and oversight of the projects under this business case.

• This project was driven by compliance to NERC PRC-002-2 and replaced 8 relay panels with modern relaying, as outlined in the technical scope document attached as Staff_PR_111 Attachment A – Rathdrum Sub Scoping Memo.
• The project charter which outlines the project scope, schedule and high-level budget is attached in Staff_PR_111 Attachment B – Rathdrum Sub Project Charter.
• The detailed Rathdrum Substation Budget by month is provided in Staff_PR_111 Attachment C – Rathdrum Sub Budget.
• An example of the monthly reports used for tracking and discussed at the weekly Substation Department Roundtable and monthly department scheduling meetings is attached in Staff_PR_111 Attachment D – Rathdrum Sub Monthly Reports.
• The change log for this project is attached in Staff_PR_111 Attachment E – Rathdrum Sub
Change Log.
• The full project schedule is provided in Staff_PR_111 Attachment F – Rathdrum Sub Project Schedule.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IPUC RESPONDER: Glenn Madden TYPE: Production Request DEPARTMENT: Electrical Engineering
REQUEST NO.: Staff-112 TELEPHONE: [phone] REQUEST:
Please provide the following documentation for the Saddle Mountain 230/115kV Station (New) Integration Project referenced by BCJN_16 of Diluciano's Exhibit No. 9, Schedule 3. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.

a. Analysis of Need - a justification of need for the project and a cost/benefit analysis comparing alternatives. b. Project Plan i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule. c. Requests for proposals ("RFP") i. Project requirements. ii. Specifications.
iii. Short list bidder scorecard. iv. RFP from winning bid. d. Project construction documentation including: i. Construction contract.
ii. Organizational chart.
iii. Scope document. iv. Work breakdown structure. v. Baseline Schedule. vi. Monthly project status report(s).
vii. Action items list(s). viii. Contractors change order request(s). e. Company project completion analysis i. Lessons learned. ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison. iv. For any actual costs differing from the budget amount by plus or minus five percent during a particular year, please list and explain the reason(s) for the budget amount difference. RESPONSE: a. – e. The attachments provided in this response are documents included to provide a sample of the project documentation developed by the project team to support this project’s decision making and oversight of the projects under this business case.

• Please refer to Staff_PR_112 Attachment A – 2014 Othello Area Initial Study for an
explanation of the system performance issues and evaluation of alternatives considered for
this project.
• The Othello City Substation construction is the final project in the Saddle Mountain business case. This project is to replace the existing Othello City substation with a larger capacity substation, as outlined in the technical scope document (Staff_PR_112
Attachment B – Othello Sub Scoping Memo).
• The project charter (Staff_PR_112 Attachment C – Othello Sub Project Charter) outlines the project scope, schedule, and budget.
• See also:
o The Othello Substation Budget (Staff_PR_112 Attachment D – Othello Sub Budget) o Monthly reports (Staff_PR_112 Attachment E – Othello Sub Monthly Reports) o Change log (Staff_PR_112 Attachment F – Othello Sub Change Log)
o Full project schedule (Staff_PR_112 Attachment G – Othello Sub Project Schedule) and o Full project management plan (Staff_PR_112 Attachment H – Othello Sub PMP)
See also Avista’s response to Staff_DR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IPUC RESPONDER: Ken Sweigart TYPE: Production Request DEPARTMENT: Transmission Design
REQUEST NO.: Staff-113 TELEPHONE: [phone] REQUEST: Please provide the following documentation for the Spokane Valley Transmission Reinforcement
Project referenced by BCJN 17 of DiLuciano's Exhibit No. 9, Schedule 3. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost. a. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
b. Project Plan i. Initial project scope. ii. Proposed budget. iii. Proposed schedule.
c. Requests for proposals ("RFP")
i. Project requirements. ii. Specifications. iii. Short list bidder scorecard. iv. RFP from winning bid.
d. Project construction documentation including: i. Construction contract. ii. Organizational chart. iii. Scope document.
iv. Work breakdown structure.
v. Baseline Schedule. vi. Monthly project status report(s). vii. Action items list(s). viii. Contractors change order request(s).
e. Company project completion analysis: i. Lessons learned. ii. Budget-to-actual comparisons for overall project and by year. iii. Baseline schedule-to-actual schedule comparison. iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the budget amount difference. RESPONSE: Please see Avista's response Staff_PR_113C, which contains TRADE SECRET,
PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. This phase of the Spokane Valley Transmission Reinforcement project pertains to the Beacon-Boulder #2 (BEA_BLD #2 line (renamed BEA-IRV #2).

a. In addition to the Spokane Valley Transmission Reinforcement Business Case Justification Narrative, which gives a full overview of the overall project, please see Staff-PR-113
Attachment 2474A for the Design Scoping Document for this more specific body of work
on the BEA-IRV #2 line, which includes a project description, schedule, cost estimate and more.
b. Project Plan:
i. The work done under the Spokane Valley Transmission Reinforcement Business
Case covers the Transmission rebuild and reconductor work necessary to mitigate a NERC TPL-001-4 system deficiency. The transmission system in the Spokane Valley currently fails TPL-001-4(P2.4) which is an internal Breaker Fault (Bus-tie Breaker) on A717 at the Boulder Station. In addition, the system fails the NERC TPL-001-4 P2 contingency for the 2017 heavy summer scenario. Completion of
this project is required to ensure Avista maintains compliance with NERC regulations and Avista's planning documents.
ii. The proposed budget for the BEA-IRV #2 Line was $1,879,022 based on the project originating Design Scoping Document (DSD) and $3,015,000 based on budget adjustment requests (see Staff-PR-113 Attachments 2474A, 2474E1 and
2474E2).
iii. For project schedule see Staff-PR-113 Attachments B3A and B3B.
c. Requests for Proposals (“RFP”):
The RFP Bid documents requested in parts i through iv can be found under Staff-PR-113 Attachments 2474C1-2474C2.
d. Project construction documentation including:
The construction documentation requested in parts i through viii can be found under Staff-PR-113 Attachments 2474D1-2474D24.
e. Company project completion analysis:
See attached Staff-PR-113 Attachments 2474E1 and 2474E2, Transmission Expected
Spend spreadsheets.
The Actual Spend for Boulder-Irvin #1 (Transmission and Distribution) was $3,039,850.
The Lessons Learned from this project include:
i. The Feasibility level associated with the Budget estimate did not take into
consideration the rate of inflation and how it would affect the project costs.
ii. Budget estimate did not take into consideration the complexity of urban construction with Distribution Underbuild. Feasibility estimate was for an average cost of installing 115kV Transmission.
iii. Do a better job of estimating and budgeting urban projects.
iv. Large number of Change Orders (~$550k worth) need to be avoided:
a. Pole Fabrication Issues: (5) CO’s for $271,033.88
b. Distribution Design Issues: (6) CO’s for $69,769.10
c. Local Regulatory Issues: (3) CO’s for $123,129.39
d. Scope Change: (2) CO’s for $35,360.95
e. Other (Construction Unknowns): (4) CO’s for $49,831.73
See also Avista’s response to Staff_PR_094.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Josh DiLuciano REQUESTER: IPUC RESPONDER: Ken Sweigart TYPE: Production Request DEPARTMENT: Transmission Design
REQUEST NO.: Staff-114 TELEPHONE: [phone] REQUEST 114:
Please provide the following documentation for the Transmission Construction - Compliance projects referenced by BCJN 18 of DiLuciano's Exhibit No. 9, Schedule 3. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company ensured the construction of these projects was completed at least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives. b. Project Plan i. Initial project scope. ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals ("RFP") i. Project requirements. ii. Specifications. iii. Short list bidder scorecard.
iv. RFP from winning bid. d. Project construction documentation including: i. Construction contract. ii. Organizational chart.
iii. Scope document.
iv. Work breakdown structure. v. Baseline Schedule. vi. Monthly project status report(s). vii. Action items list(s).
viii. Contractors change order request(s). e. Company project completion analysis: i. Lessons learned. ii. Budget-to-actual comparisons for overall project and by year. iii. Baseline schedule-to-actual schedule comparison.
iv. For any actual costs differing from the budget amount by plus or minus five percent during a particular year, please list and explain the reason(s) for the budget amount difference. RESPONSE:
Please see Avista's response Staff_PR_098C, which contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and exempt from public view and is separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code.

a. In addition to the Transmission Construction - Compliance Business Case provided in Company witness Mr. DiLuciano’s Testimony, Exhibit No. 9, Schedule 3, which gives an
overview of the work within this program, please see Staff-PR-114 Attachment 2622A, the
Design Scoping Document for the Boulder-Irvin #1 115kV Rebuild Project specifically within this business case. This scoping document includes a project description, schedule and cost estimate among other things.
b. Project Plan:
i. The work done under Transmission Construction – Compliance covers the Transmission rebuild and reconductor work necessary to maintain compliance with the NERC Reliability Standard TPL-001-4 – Transmission System Planning Performance Requirements (“Standard”). This standard mandates that an annual planning assessment be conducted and corrective actions be identified and
implemented to remedy any system performance deficiencies. Corrective Action Plans must be completed within the required timeframe to meet the system performance requirements dictated by the Standard.
The Transmission Construction – Compliance Business Case also covers the Transmission line rebuild for lines not meeting National Electric Safety Code
(NESC) physical capacities for appropriate loading cases. These code minimums have also been adopted into the State of Washington's Administrative Code (WAC). These lines may have met the NESC criteria at the time of their original construction but have been found to not be up to standards through analysis either
as a result of requests for facility additions, or identified past additions not analyzed
at the time of installation.
ii. The proposed budget for the BLD-IRV #1 Line was $2,000,000 (see Staff-PR-114 Attachment A).
iii. For project schedule see Staff-PR-114 Attachment B.
c. Requests for Proposals (“RFP”):
The RFP Bid documents requested in parts i through iv can be found under Staff-PR-114 Attachments C1-C2.
d. Project construction documentation including:
The construction documentation requested in parts i through viii can be found under
Staff-PR-114 Attachments 2622D1-2596D3.
e. Company project completion analysis:
See attached Staff-PR-114 Attachment 2622E Transmission Expected Spend spreadsheet.
The Actual Spend for Boulder-Irvin #1 (Transmission and Distribution) was $3,893,103.
The Lessons Learned from this project include:
i. Budget estimate failed to accommodate Distribution costs.
ii. The Feasibility level associated with the Budget estimate did not take into consideration the rate of inflation and how it would affect the project costs.
iii. Budget estimate did not take into consideration the complexity of urban
construction with Distribution Underbuild. Feasibility estimate was for an average
cost of installing 115kV Transmission.
iv. Do a better job of estimating and budgeting urban projects.
See also Avista’s response to Staff_PR_094.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: DiLuciano REQUESTER: IPUC RESPONDER: Ken Sweigart TYPE: Production Request DEPARTMENT: Transmission Design
REQUEST NO.: Staff-115 TELEPHONE: [phone] REQUEST 115:
Please provide the following documentation for the Transmission NERC Low-Risk Priority Lines Mitigation projects referenced by BCJN-19 of DiLuciano’s Exhibit No. 9, Schedule 3. If any of the information requested below cannot be provided or is not available, please explain why, and explain how the Company can ensure the construction of these projects was completed at least
cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit analysis comparing alternatives. b. Project Plan i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule. c. Requests for proposals ("RFP") i. Project requirements. ii. Specifications.
iii. Short list bidder scorecard. iv. RFP from winning bid. d. Project construction documentation including: i. Construction contract.
ii. Organizational chart.
iii. Scope document. iv. Work breakdown structure. v. Baseline Schedule. vi. Monthly project status report(s).
vii. Action items list(s). viii. Contractors change order request(s). e. Company project completion analysis i. Lessons learned. ii. Budget-to-actual comparisons for overall project and by year.
iii. Baseline schedule-to-actual schedule comparison. iv. For any actual costs differing from the budget amount by plus or minus five percent during a particular year, please list and explain the reason(s) for the budget amount difference. RESPONSE: a. Please see the BCJN 19 for Transmission Low Priority Ratings Mitigation in Company witness Mr. DiLuciano’s Testimony, Exhibit No. 9, Schedule 3 for a full description of the need for
this work. Additionally, please see Staff-PR-115 Attachment A.
b. Project Plan:
i. The Transmission NERC Low Priority Lines Mitigation Business Case covers the
work to reconfigure insulator attachments, and/or rebuild existing transmission line
structures, or remove earth beneath transmission lines in order to mitigate ratings/sag discrepancies found between "design" and "field" conditions as determined by LiDAR survey data. This program was undertaken in response to the October 7, 2012 North American Electric Reliability Corporations (NERC)
"NERC Alert" - Recommendation to Industry, "Consideration of Actual Field Conditions in Determination of Facility Ratings". This Capital Program covers mitigation work on Avista's "Low Priority" 230kV and 115kV transmission lines. Mitigation brings lines in compliance with the National Electric Safety Code (NESC) minimum clearances values. These code minimums have also been
adopted into the State of Washington's Administrative Code (WAC). This program is expected to be completed in 2024.
ii. The proposed budget for the 9CE-3HT (Latah Tap) Line (Phase 2) project is $2,400,000, please see Staff-PR-115 Attachment B.
iii. For project schedule see Staff-PR-115 Attachment C.
Note: If Electric System conditions prevent portions of the 9CE-3HT (Latah Tap) Line (Phase 2) project from being constructed in 2023, these assets replacements will be rescheduled for 2024. One of the remaining projects scheduled for 2024 will be shifted into 2023 to fully subscribe budget and schedule.
c. Requests for Proposals (“RFP”):
The RFP Bid documents requested in parts i through iv are under development for an anticipated issue during the summer time frame.
d. Project construction documentation including:
The construction documentation requested in parts i through viii have yet to be
developed/submitted because RFP is scheduled to be issues in the summer time frame.
e. Company project completion analysis:
See attached Staff-PR-115 Attachment B, Transmission Expected Spend spreadsheet.
The Actual Spend for the 9CE-3HT (Latah Tap) Line (Phase 2) project $28,083 (through March).

See also Avista’s response to Staff_DR_094.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/03/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Mark Thies REQUESTER: IPUC RESPONDER: Janessa Stromberger TYPE: Production Request DEPARTMENT: PFA Accounting
REQUEST NO.: Staff-138 TELEPHONE: [phone] REQUEST: Regarding the Company's response to Production Request No. 4, Staff Attachment 4A, please
provide copies of invoices, contracts, workpapers, supporting documentation and a brief explanation on the cost differences between 2021 and 2022 for the following:
a. 4a-Internal auditing expenses: 2021 employee expenses $2,981 and 2022 employee expenses $17,982;
b. 4e-software/information system items: 2021 other $2,877,313 and 2022 other $3,357,750;
c. 4e-software/information system items: 2021 training $52,262 and 2022 training $98,307;
d. 4h-travel & training for executives: 2021 $14,695 and 2022 $35,031;
e. 4j-overhead items: 2021 other $77,883 and 2022 other $5,678; and
f. 4j-overhead items: 2021 professional services $290,741 and 2022 professional services
$790,546.
RESPONSE: See Staff_PR_138 Attachment A for a detailed list of the above referenced 2021 and 2022 expenses, indicating the invoice number, vendor name, and charge description. As there are
thousands of invoices referenced in the attachment, Avista can provide additional support, such as invoices and contracts, if applicable, for selected line items.
The cost differences between 2021 and 2022 for the above are due to the following:
a. The increase in internal audit employee expenses is due to restrictions on attending
in-person conferences and trainings in 2021; internal audit attended no conferences in 2021
and attended a few conferences in 2022.
b. The increase in other software/information systems is mainly due to an increase in software subscriptions as well as equipment rental expenses and security services.
c. The increase in software/information system training is related to additional fiber optics
training as well as increased travel for training in 2022 over restricted in-person training in 2021.
d. The increase in travel and training for executives is due to an additional executive receiving coaching in 2022 as well as increased travel for training in 2022 over restricted in-person training in 2021.
e. The decrease in other overhead items is largely due to Ross Park repair work executed in 2021 and no significant work occurring in 2022.
f. The increase in professional services overhead is mainly due to increased costs towards snow removal and deicer at Mission Campus.