20230511AVU to CP 1-8.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: Clearwater Paper RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-001 TELEPHONE: [phone] REQUEST:
Please provide, in electronic format with all formulae intact where possible, all workpapers and other documents used in the development of Avista's Application in this matter. RESPONSE:

Avista will be providing all case filings and workpapers to Mr. Peterson and Dr. Don Reading using the OneDrive application. If you would like to also receive the documents in this form please provide me with an email address to receive the files.
RECEIVED
2023 May 11, 5:02PM
IDAHO PUBLIC
UTILITIES COMMISSION
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: Clearwater Paper RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-002 TELEPHONE: [phone] REQUEST:
Please provide copies of all communications between Avista and the Idaho Public Utilities Commission and/or its Staff regarding Avista's Application in this matter. RESPONSE:

The Company has provided all communications with the Commission to date and will continue to provide them.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: Clearwater Paper RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-003 TELEPHONE: [phone] REQUEST:
Please provide copies of all responses to production requests (both formal and informal) provided to any other party to this proceeding. RESPONSE:

Please see Avista's response 003C, 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 has provided all production requests from all parties to date and will continue to
provide them. See CP_PR_003 Attachments A-F and CP_PR_003C Confidential Attachments A & B for the informal responses provided to Staff.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: Clearwater Paper RESPONDER: Paul Kimball TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-003C TELEPHONE: [phone] REQUEST:
Please provide copies of all responses to production requests (both formal and informal) provided to any other party to this proceeding. RESPONSE:
Please note that the attached document contains TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and 233, and Section 9-340D, Idaho Code. The Company has provided all production requests from all parties to date and will continue to
provide them. See CP_PR_003 Attachments A-F and CP_PR_003C Confidential Attachments A
& B for the informal responses provided to Staff.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joseph Miller REQUESTER: Clearwater Paper RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-004 TELEPHONE: [phone] REQUEST:
Please confirm that the rates Avista proposes in this case will (if approved as filed) result in Clearwater's Rate of Return ratio of 1.49% RESPONSE:

Confirmed. At the Company’s proposed revenue requirement Clearwater’s Rate of Return Ratio would go from 1.59 to 1.49, and approximate 17% movement towards relative cost of service.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joseph Miller REQUESTER: Clearwater Paper RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-005 TELEPHONE: [phone] REQUEST:
Please confirm as accurate that in Avista's last Idaho jurisdiction general rate case, (AVU-E-21- 01) Avista's proposed rates, as originally filed, would have resulted in Clearwater's Rate of Return ratio of 1.53%. However, the parties settled that case and agreed to the following Stipulation that was approve by the Commission;

In recognition, however, that certain rate schedules are generally above their relative cost of service, the Parties agree that Schedule 25P should receive 25% of the overall percentage base rate changes for the September 1, 2021 and September 1, 2022 base rate increases. In addition, Schedules 11/12 should receive 25% of the overall percentage base
rate change for the September 1,2022 increase. [STIPULATION AND SETTLEMENT -
AVU.E-21-01, Page l9] Did the Company consider making or offering a similar adjustment to its proposed rates for Clearwater, or any other customer class, in this general rate case? Please explain why or why not.
RESPONSE: Clearwater’s present return ratio was 1.53 in the Company’s prior general rate case filing. As a
result of Settlement negotiations, the agreed to revenue requirement was ultimately lower than
originally proposed by the Company and the Parties agreed to apply 25% of the overall percentage base rate change to Clearwater based on differing cost of service assumptions unique to each Party. The Company has made a proposal to make greater movement towards relative cost of service for
schedules 11/12, 25 and 25P (Clearwater) should the Commission order a lower revenue requirement than what was proposed in the Company’s original filing.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joseph Miller REQUESTER: Clearwater Paper RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-006 TELEPHONE: [phone] REQUEST:
In the Direct testimony of Company witness Joseph Miller he states on page 7; If the Commission were to order a lower revenue requirement than filed for, the Company proposes to allocate the same increase as the Company's initial filing to Residential Service
Schedule 1, Large General Service Schedules 21/22, and Pumping Service Schedules
31/32. The remaining revenue should then be applied equally to Schedules 1l/12, Schedule 25, Schedule 25P and the Street and Area Lights Schedules as those schedules are providing significantly more than their relative cost of service as discussed by Mr. Garbarino. [Miller, Di, p. 7.]

Has the Company done any analysis (sensitivity or otherwise) estimating the impact and rate design assuming the Commission would decrease the proposed revenue requirement of any given percentage? If so please provide. RESPONSE: The Company has not conducted an analysis of the impact of a lower revenue requirement on rate design for all schedules. However, as stated above, if the Commission were to lower the ultimate
revenue requirement in this proceeding, under the Company’s proposal the Company would
allocate the same increase as initially proposed to rate Schedules 1, 21/22 and 31/32 resulting in no change in the overall impact and rate design from the Company’s initial proposal for these schedules.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joseph Miller REQUESTER: Clearwater Paper RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-007 TELEPHONE: [phone] REQUEST:
In the Direct testimony of Company witness Joseph Miller he states on page 6; However, given the relative size of the proposed base revenue increase, Avista is proposing to spread the revenue increase on a uniform percent of revenue basis at the proposed levels.
The spread of the proposed increase still results in the rates of return for the various electric
service schedules moving closer to the overall rate of return (unity). [Miller, Di, p. 6.] Please explain why the relative size of the proposed rate increase would support use of a uniform percent rate increase in class rates schedules rather than lower rate increases for those that "are
providing significantly more than their relative cost of service. . . ." Please also explain how a
"uniform percent of revenue" rate spread moves the "various electric service schedules closer to ... (unity)" RESPONSE:
The Company is sensitive to the level of proposed rate impact that would be realized by its customers at the proposed levels. In the Company’s view, each rate schedule is making meaningful movement towards relative cost of service without unduly burdening any one
customer class at the Company’s proposed revenue requirement. See the table below showing
each rate schedules Rate of Return Ratio at present and proposed rates illustrating each rate schedules movement towards cost of service:

Present Rates Proposed Rates
Present Present Proposed Proposed
Line Type of Sch.Rate of Relative Rate of Relative
No.Service Number Return ROR Return ROR
(a)(b)(c)(d)(f)(g)
1 Residential 1 4.10%0.87 6.93%0.91
2 General Service 11,12 5.89%1.24 8.80%1.16
3 Large General Service 21,22 4.18%0.88 6.84%0.90
4 Extra Large General Svc.25 5.80%1.22 9.04%1.19
5 Clearwater 25P 7.53%1.59 11.31%1.49
6 Pumping Service 31,32 3.58%0.75 6.04%0.80
7 Street & Area Lights 41-49 8.04%1.70 9.72%1.28
8 Total 4.74%1.00 7.59%1.00
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/10/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Joseph Miller REQUESTER: Clearwater Paper RESPONDER: Joe Miller TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: CP-008 TELEPHONE: [phone] REQUEST:
In the Direct testimony of Company witness Joseph Miller he states on page 6; The Company may propose additional movement toward unity in future proceedings. [Miller, Di, p. 6.]

Please explain why the Company is delaying a more significant rate spread in moving all customer classes to rate of return ratios closer to their cost of service. RESPONSE: The Company’s rate spread proposal attempts to strike a balance between moving all schedules closer to their relative cost of service without unduly burdening any one rate schedule. As an extreme example if the Company were to move all schedules to absolute cost of service in this
proceeding, this would result in some rate schedules receiving rate decreases, while other rate schedules would receive even larger base rate increases. In the Company’s view, this level of movement would be excessive and could be considered rate shock. In times of significant cost increases, as experienced by the Company in this case, a more measured rate spread approach is
appropriate whereby movement towards cost of service is achieved over a longer term.