20230512AVU to Staff 189-201.pdf

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Annette Brandon TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-189 TELEPHONE: [phone] REQUEST: Mr. Kalich’s Direct Testimony states that the EIM revenues above expenses will pass through the
PCA. Please respond to the following: a) Does Account 447 Sales for Resale capture the EIM revenues above expenses; b) If not, how do the EIM revenues above expenses pass through the PCA; and c) Please define the EIM expenses and explain how the EIM expenses are determined.

RESPONSE: The Company apologizes for the confusion in the statement “EIM revenue above expenses will pass through the PCA” has caused. The statement should have read: “EIM expense are allowed to
run through the PCA up to the benefits received”. Please see below for additional context:
Per the Settlement Stipulation for the EIM from AVU-E-21-01 it reads, the treatment of EIM is as follows: “Energy Imbalance Market (EIM). Currently Idaho’s share of its incremental EIM O&M expenses are being deferred per Order No. 34606 in Case No. AVU-E-20-01 until the expected
“go live” date March 1, 2022. The Parties agree that effective with the expected “go live” March
1, 2022 date, the Company will begin to reflect Idaho’s share of incremental EIM O&M expenses through the PCA up to Idaho’s share of EIM benefits that also will flow through the PCA. Any incremental EIM O&M expenses exceeding EIM benefits would continue to be deferred for review
and determination of recovery in a future proceeding.”
a. No. see above. b. NA
c. Please see the Company’s response to Staff_PR_190.
RECEIVED
2023 May 12, 4:35PM
IDAHO PUBLIC
UTILITIES COMMISSION
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Clint Kalich REQUESTER: IPUC RESPONDER: Annette Brandon TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-190 TELEPHONE: [phone] REQUEST: Schedule 2 of Confidential Exhibit No. 7 includes a line item “407 Regulatory Debits: Incremental
EIM O&M.” Please respond to the following: a) What does “Incremental EIM O&M” means: b) How was the $286,000 determined; and c) Why was the $286,000 item eliminated from the pro forma.
RESPONSE: Please also see the Company’s response to Staff_PR_189 for an explanation of the treatment of O&M specific to EIM.
a. Incremental O & M means any operation and maintenance expenses that are above what is
currently embedded within other O&M expenses in the Company’s current base rates. These expenses exist solely due to Avista’s participation in the EIM market. Absent our participation, we would not have incurred these expenses and EIM costs are not currently included in base rates (again, meaning they are incremental).
b. All O & M expenses are tracked on an individual project journal, with a specific project and task. c. This amount was eliminated from the pro forma because it was only tracked in this method
until such time as it was allowed to go through the PCA. Please note this was reviewed in
depth in the 2021-2022 PCA review conducted on-site by Idaho Staff during the August 2022 Annual PCA review.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Scott Kinney TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-191 TELEPHONE: [phone]
REQUEST: Please answer the following regarding WRAP funding included in Kinney Direct testimony at
56:
a. Please provide actual WRAP funding amounts for 2022 and 2023 (through March 31, 2023
b. Please define Phase 1, Phase 2, Phase 2b, Phase 3A, and Phase 3B
c. Please explain the basis and types of costs that make up the actual and estimated funding included in Table Nos. 9 and 10, respectively. Please provide a cost breakdown of each cost included in the tables and include whether the costs are
one-time or ongoing; and
d. Please explain how the Company determined an annual recovery amount of $350,000 given that WRAP has proposed one-time fees and ongoing fees. Please include electronic workpapers with all formula enabled.

RESPONSE: Please see Avista's response 191C, which contain TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code. a. Avista funded $346,300 in 2022 and has funded $37,800 in 2023 through March. b. Phase 1 (Initial Investigation) was completed in the fall of 2019 and included several different
components conducted by different strike teams. The first team reviewed other resource
adequacy programs that were operating in North America to understand how they operated and see what functions could be utilized in a northwest program. The second team reviewed the current assumptions and methodologies used in individual utility resource planning specifically around planning reserve margin and resource adequacy reliability metrics,
calculation of capacity contribution for renewable resources, and the reliance on market
purchase for long term planning. The final team developed an initial high level program structure and potential requirements for a northwest resource adequacy program. Phase 2 (Preliminary Design) included the development of the preliminary WRAP design and
was completed in June 2020. The preliminary design included the structure of the forward
showing and operational programs as well as the draft program governance structure. The Southwest Power Pool (SPP) was hired as a design consultant to help with this phase since they were operating a similar program in their region.
Phase 2B (Detailed Design) was completed in August of 2021 and included the development
of the WRAP detailed program design. The detailed design included all the structure and
elements for the forward showing and operations program. This phase also included finalizing the governance structure which included the need to transition the Western Power Pool (WPP) board to a fully independent Board. The detailed design was used as the basis for developing the participant data requirements, program models, and FERC tariff.

Phase 3A (Implementation and Non-Binding Trial) began in September of 2022 and included significant data gathering and modeling by SPP and Board transition work by the WPP to allow for a non-binding trial of the forward showing program in the winter of 2022-2023 and the summer of 2023. Participants submitted data as if they were operating in the forward showing
program. SPP conducted modeling and assessed whether participants met the minimum
program requirements. No penalties were applied for non-compliance. This phase also included the development and filing of the WRAP tariff in September of 2023. Participants were asked to sign up for the full binding program by December 31, 2022, contingent on FERC approval of the tariff.

Phase 3B (Binding Program Development and Operations) began in parallel with Phase 3A and supported efforts associated with the full binding program. Participants recognized there were efforts that needed to be started to ensure the program was ready for operations after the FERC approval of the tariff. If these items were not worked on in parallel with the tariff
development, then there would be a delay in finalizing the WRAP and getting it operational.
Phase 3B included hiring a consultant to vet new potential independent Board members as required in the tariff to oversee the program. This phase also included finishing the detailed design of the operations program component. With the approval of the FERC tariff and commitment of twenty-two participants to the biding program, the program is officially in
Phase 3B and has now transitioned to WRAP operations. Participants were asked to commit to
a binding program start date between summer of 2025 and the winter of 2027/2028. Participants are currently working with the WPP to determine when the first binding season will start. Until that time the program will continue to operate under a non-binding governance.
c. The cost shown in Table 9 of my testimony are all actual costs billed by the Western Power
Pool/Northwest Power Pool (WPP) for each of the years listed. The WPP created a budget forecast for each phase of the WRAP development, but billed participants monthly based on actual spend per the agreed cost allocation methodology for each phase. Phase 1 costs were minimal and associated with minor WPP labor to support the evaluation effort and to pay for
a consultant. Phase 2 and Phase 2B costs were associated with WPP labor to coordinate and
support the WRAP design development, hiring SPP as a design consultant, and hiring Wright and Talisman for FERC legal support. Phase 3A and 3B costs were also associated with WPP labor, SPP support as the Program Operator, stakeholder outreach and legal support for the FERC tariff development and filing. Phase 3A/B costs are hirer than Phase 1 and Phase 2/2B
because both the WPP and SPP have hired additional staff to support the actual operation of
the WRAP. All off the costs shown in Table 9 are onetime costs. The cost shown in Table 10 for 2023, 2024, and 2025+ are based on estimates provided by the WPP. These costs are required to cover WPP and SPP labor for newly hired staff to support
the operations of the program, technology and application costs, a pro-rata share of the new
WPP independent Board, legal costs to help with FERC reviews and future filings, an independent evaluator to review how the program is functioning and a small amount of reserves to cover unexpected costs. Program participants agreed on a cost methodology where
a portion of the WRAP costs are divided equally (base costs), and a portion is allocated based on participant load ratio share of the total program load (load cost). WPP recently calculated
Avista’s share at 3.2 percent for its load cost and there are twenty-two participants so Avista
will pay 5.5 percent of base costs based on the number of current participants. WPP will bill monthly on actual program costs incurred. Avista’s share may change in the future based on load ratio share changes or the potential for committed participants to leave the program or new participants to join. The current twenty-two committed participants can’t leave the
program for at least 2 years based on the approved tariff. These annual costs will be reoccurring
and are required to keep the WRAP running long term. d. The WRAP efforts and funding from 2019 through 2022 were onetime costs to design and get the program running and create the FERC tariff. These costs supported Phases 1 though Phase
3A and some preliminary efforts to support Phase 3B. Costs in 2023 and going forward are
reoccurring costs to keep the program operating. The $350,000 request in the rate filing was based on an estimate provided by the WPP. See Staff_PR_191C Confidential Attachment A - WPP WRAP Budget Forecast Email, a confidential email from the WPP dated November 16, 2021, that provided an estimate of Avista’s WRAP costs in 2023, 2024, and 2025. Although
the email indicated an estimated spend of $250,000 in 2023, in early 2022 WPP indicated that
all participants will be required to help fund working capital to support SPP as the WRAP Program Operator and allow them to hire employees and acquire required applications and not impact its existing RTO customers. Avista’s estimated working capital amount was $100,000 which resulted in a total estimated cost of $350,000 for 2023. Avista actually paid the working
capital cost in December of 2022. The confidential invoice (Staff_PR_191C Confidential
Attachment B - WRAP December 2022 WPP Invoice – Working Capital) is attached to this PR and included in the total 2022 costs shown in section a above. Avista just received a new WRAP budget forecast that will be presented to the WPP Board in
May for approval. The updated forecast incorporates future program costs based on the most
recent information including new staff at both WPP and SPP, pro-rata portion of the WPP Board, technology, legal services, independent evaluator, and reserves. The confidential forecast (Staff_PR_191C Confidential Attachment C - WRAP Budget Forecast 2023 to 2027) is attached. Since the WPP uses a July to June fiscal budget, the estimates provided by the
WPP transition across calendar years. The attached confidential workpaper(Staff_PR_191C
Confidential Attachment D - Avista WRAP 2023-2027) estimates the annual Avista costs for 2023 through 2027 based on the April 2023 WPP forecast. WPP will bill monthly on actual costs incurred so there will be a difference from these estimated forecasts.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Scott Kinney REQUESTER: IPUC RESPONDER: Scott Kinney TYPE: Production Request DEPARTMENT: Energy Resources
REQUEST NO.: Staff-191C TELEPHONE: [phone]
REQUEST: Please answer the following regarding WRAP funding included in Kinney Direct testimony at
56:
a. Please provide actual WRAP funding amounts for 2022 and 2023 (through March 31, 2023
b. Please define Phase 1, Phase 2, Phase 2b, Phase 3A, and Phase 3B
c. Please explain the basis and types of costs that make up the actual and estimated funding included in Table Nos. 9 and 10, respectively. Please provide a cost breakdown of each cost included in the tables and include whether the costs are
one-time or ongoing; and
d. Please explain how the Company determined an annual recovery amount of $350,000 given that WRAP has proposed one-time fees and ongoing fees. Please include electronic workpapers with all formula enabled.

RESPONSE: Please see the Attachments provided, which contain TRADE SECRET, PROPRIETARY or CONFIDENTIAL information and are separately filed under IDAPA 31.01.01, Rule 067 and
233, and Section 9-340D, Idaho Code. a. Avista funded $346,300 in 2022 and has funded $37,800 in 2023 through March. b. Phase 1 (Initial Investigation) was completed in the fall of 2019 and included several different
components conducted by different strike teams. The first team reviewed other resource
adequacy programs that were operating in North America to understand how they operated and see what functions could be utilized in a northwest program. The second team reviewed the current assumptions and methodologies used in individual utility resource planning specifically around planning reserve margin and resource adequacy reliability metrics,
calculation of capacity contribution for renewable resources, and the reliance on market
purchase for long term planning. The final team developed an initial high level program structure and potential requirements for a northwest resource adequacy program. Phase 2 (Preliminary Design) included the development of the preliminary WRAP design and
was completed in June 2020. The preliminary design included the structure of the forward
showing and operational programs as well as the draft program governance structure. The Southwest Power Pool (SPP) was hired as a design consultant to help with this phase since they were operating a similar program in their region.
Phase 2B (Detailed Design) was completed in August of 2021 and included the development
of the WRAP detailed program design. The detailed design included all the structure and
elements for the forward showing and operations program. This phase also included finalizing the governance structure which included the need to transition the Western Power Pool (WPP) board to a fully independent Board. The detailed design was used as the basis for developing the participant data requirements, program models, and FERC tariff.

Phase 3A (Implementation and Non-Binding Trial) began in September of 2022 and included significant data gathering and modeling by SPP and Board transition work by the WPP to allow for a non-binding trial of the forward showing program in the winter of 2022-2023 and the summer of 2023. Participants submitted data as if they were operating in the forward showing
program. SPP conducted modeling and assessed whether participants met the minimum
program requirements. No penalties were applied for non-compliance. This phase also included the development and filing of the WRAP tariff in September of 2023. Participants were asked to sign up for the full binding program by December 31, 2022, contingent on FERC approval of the tariff.

Phase 3B (Binding Program Development and Operations) began in parallel with Phase 3A and supported efforts associated with the full binding program. Participants recognized there were efforts that needed to be started to ensure the program was ready for operations after the FERC approval of the tariff. If these items were not worked on in parallel with the tariff
development, then there would be a delay in finalizing the WRAP and getting it operational.
Phase 3B included hiring a consultant to vet new potential independent Board members as required in the tariff to oversee the program. This phase also included finishing the detailed design of the operations program component. With the approval of the FERC tariff and commitment of twenty-two participants to the biding program, the program is officially in
Phase 3B and has now transitioned to WRAP operations. Participants were asked to commit to
a binding program start date between summer of 2025 and the winter of 2027/2028. Participants are currently working with the WPP to determine when the first binding season will start. Until that time the program will continue to operate under a non-binding governance.
c. The cost shown in Table 9 of my testimony are all actual costs billed by the Western Power
Pool/Northwest Power Pool (WPP) for each of the years listed. The WPP created a budget forecast for each phase of the WRAP development, but billed participants monthly based on actual spend per the agreed cost allocation methodology for each phase. Phase 1 costs were minimal and associated with minor WPP labor to support the evaluation effort and to pay for
a consultant. Phase 2 and Phase 2B costs were associated with WPP labor to coordinate and
support the WRAP design development, hiring SPP as a design consultant, and hiring Wright and Talisman for FERC legal support. Phase 3A and 3B costs were also associated with WPP labor, SPP support as the Program Operator, stakeholder outreach and legal support for the FERC tariff development and filing. Phase 3A/B costs are hirer than Phase 1 and Phase 2/2B
because both the WPP and SPP have hired additional staff to support the actual operation of
the WRAP. All off the costs shown in Table 9 are onetime costs. The cost shown in Table 10 for 2023, 2024, and 2025+ are based on estimates provided by the WPP. These costs are required to cover WPP and SPP labor for newly hired staff to support
the operations of the program, technology and application costs, a pro-rata share of the new
WPP independent Board, legal costs to help with FERC reviews and future filings, an independent evaluator to review how the program is functioning and a small amount of reserves to cover unexpected costs. Program participants agreed on a cost methodology where
a portion of the WRAP costs are divided equally (base costs), and a portion is allocated based on participant load ratio share of the total program load (load cost). WPP recently calculated
Avista’s share at 3.2 percent for its load cost and there are twenty-two participants so Avista
will pay 5.5 percent of base costs based on the number of current participants. WPP will bill monthly on actual program costs incurred. Avista’s share may change in the future based on load ratio share changes or the potential for committed participants to leave the program or new participants to join. The current twenty-two committed participants can’t leave the
program for at least 2 years based on the approved tariff. These annual costs will be reoccurring
and are required to keep the WRAP running long term. d. The WRAP efforts and funding from 2019 through 2022 were onetime costs to design and get the program running and create the FERC tariff. These costs supported Phases 1 though Phase
3A and some preliminary efforts to support Phase 3B. Costs in 2023 and going forward are
reoccurring costs to keep the program operating. The $350,000 request in the rate filing was based on an estimate provided by the WPP. See Staff_PR_191C Confidential Attachment A - WPP WRAP Budget Forecast Email, a confidential email from the WPP dated November 16, 2021, that provided an estimate of Avista’s WRAP costs in 2023, 2024, and 2025. Although
the email indicated an estimated spend of $250,000 in 2023, in early 2022 WPP indicated that
all participants will be required to help fund working capital to support SPP as the WRAP Program Operator and allow them to hire employees and acquire required applications and not impact its existing RTO customers. Avista’s estimated working capital amount was $100,000 which resulted in a total estimated cost of $350,000 for 2023. Avista actually paid the working
capital cost in December of 2022. The confidential invoice (Staff_PR_191C Confidential
Attachment B - WRAP December 2022 WPP Invoice – Working Capital) is attached to this PR and included in the total 2022 costs shown in section a above. Avista just received a new WRAP budget forecast that will be presented to the WPP Board in
May for approval. The updated forecast incorporates future program costs based on the most
recent information including new staff at both WPP and SPP, pro-rata portion of the WPP Board, technology, legal services, independent evaluator, and reserves. The confidential forecast (Staff_PR_191C Confidential Attachment C - WRAP Budget Forecast 2023 to 2027) is attached. Since the WPP uses a July to June fiscal budget, the estimates provided by the
WPP transition across calendar years. The attached confidential workpaper(Staff_PR_191C
Confidential Attachment D - Avista WRAP 2023-2027) estimates the annual Avista costs for 2023 through 2027 based on the April 2023 WPP forecast. WPP will bill monthly on actual costs incurred so there will be a difference from these estimated forecasts.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Karen Schuh TYPE: Production Request DEPARTMENT: ET Project Mgmt. Off.
REQUEST NO.: Staff-192 TELEPHONE: [phone] REQUEST: Please reconcile the differences in the requested spend amounts for CIP v5 Transition described in
Table No. 1 of Company Witness Kensok's Direct Testimony at 9 of $416,000 and the $250,000 described in the Business Case Justification Narrative in Kensok's Exhibit No. 11 at 254. Please provide a narrative explanation of the difference and any changes made to the business case.
RESPONSE:
The amounts listed in Kensok’s Direct Testimony at 9 of $416,000 for 2023 represent an annual transfer-to-plant amount and the $250,000 listed in the Business Case Justification Narrative in Kensok’s Exhibit No. 11 represent a spending amount that does not include LTD total project costs like a transfer-to-plant amount does.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Karen Schuh TYPE: Production Request DEPARTMENT: ET Project Mgmt. Off.
REQUEST NO.: Staff-193 TELEPHONE: [phone] REQUEST: Please explain what the Company's existing lifecycle management program covers. Please provide
a supporting workpaper that includes the year over year budgets, actual spend, and a brief description of differences by item for the years 2020 through 2023. RESPONSE:
Please see the Company’s response to Staff_PR_066 for details surrounding how the Technology
Failed Assets business case is in lieu of a lifecycle management program. Please see the Company’s response to Staff_PR_196 Attachment A - ITFA 2020-2023 Spend for budgets to spend variances.

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AVISTA CORP.
RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: WASHINGTON DATE PREPARED: 05/11/2023 CASE NO.: UE-220053 & UG-220054 WITNESS: Jim Kensok/K. Schultz REQUESTER: Public Counsel RESPONDER: Nate Kahovec
TYPE: Data Request DEPT: Enterprise Technology
REQUEST NO.: PC – 194 TELEPHONE: [phone] EMAIL: [e-mail] REQUEST:
In reference to Footnote 6 of Kensok's Direct Testimony at 39, please provide an update on the IS/IT
contracts including renewal status, changes to Terms and Conditions, and consolidation. If contract savings are achieved, please explain the amount of savings and how the Company will reflect Idaho's share of the savings in this case.
RESPONSE: Footnote 6 of Kensok’s Direct Testimony at 39 references the renewal of Avista’s Microsoft desktop business application suite. The renewal was completed as planned, there were no changes to the terms and conditions, and the consolidation yielded approximately the expected savings. Consolidating the Microsoft
business application products from three products into one was expected to yield an annual savings of
$173,000 for the next three years. Combining Microsoft Office 365, Microsoft Enterprise Mobility and Security, Windows 10 resulted in cost savings of $168,000 annually or $504,000 over the life of the three-year agreement. The difference can be attributed to estimations based upon publicly available pricing at the time of the Company’s filing. As expected, increasing our licensed user count qualified us for volume-based
discounts of $78,000 over three years. The total annual savings resulting from both the product
consolidation and volume-based discounts is $194,000 per year for the remainder of the three-year agreement, split approximately $112,000 benefiting annual ISIT expense and $82,000 benefiting capital. The impact of the consolidation on expense was already reflected in the Company’s as-filed Pro Forma ISIT Expense Adjustment 3.04, with Idaho’s share reducing ISIT expense by $27,000 for electric and
$6,000 for natural gas. The reduction in capital would be realized over time in reduced return on investment
and reduced depreciation expenses.

AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Karen Schuh TYPE: Production Request DEPARTMENT: ET Project Mgmt. Off.
REQUEST NO.: Staff-195 TELEPHONE: [phone] REQUEST: Please explain if the Distribution Integrity Management Plan ("DIMP") expected $200k annual
reduction in risk profile beginning in 2023 is reflected in the Company's revenue requirement. If not, please explain. RESPONSE:
It is not reflected in the Company’s revenue requirement for 2023. At this point, we are still in the process of implementing the software and won’t have any deliverables (risk results) from the software until later this summer. This will also mean that we likely won’t be able to act on any of those results until 2024, at which point we would begin realizing a reduction in the risk profile over
time. We are still performing integrity related gas replacement work (GFRP) which is continually
lowering our risk profile, but we are not yet able to measure that risk reduction (system) with the software.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elisabeth Sibulsky TYPE: Production Request DEPARTMENT: Enterprise Technology
REQUEST NO.: Staff-196 TELEPHONE: [phone] REQUEST: As supplement to Production Request No. 66, please provide a supporting spreadsheet that breaks
down each actual cost, description, and year booked within the Technology Failed Assets from July 2021 to end of the Test Period. Please include details for the items listed in the Company's response, as well as any additional items incurred between July 2022 through March 2023.
RESPONSE: Please see Staff_PR_196 Attachment A for further breakdown of the Technology Failed Assets for 2020 through March of 2023. This list includes monthly transfers to plant for items in Staff_PR_066 and Staff_PR_067.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elisabeth Sibulsky TYPE: Production Request DEPARTMENT: Enterprise Technology
REQUEST NO.: Staff-197 TELEPHONE: [phone] REQUEST: As supplement to Production Request No. 66, for the Mt. Spokane Siding project, please explain
what the building is used for, why costs are allocated to Idaho, and reasoning for the project to be included under the Technology Failed Asset business case. Additionally, please explain why the project is not considered under a building asset account.
RESPONSE:
The building is used solely as a shelter for communications equipment on top of Mt. Spokane. This building, and the equipment inside it, are part of the communications network that Avista has built covering its service territory in Washington and Idaho, which is why the costs were partly allocated to Idaho. Since the siding was in a failed state, and it existed solely to shelter an IT asset,
it was determined the cost to replace it should be funded from the ITFA business case. Similarly,
the Company’s Project Accounting Department reviewed the accounting at the start of the project to determine if this should be considered a communication or a buildings and structures asset, determining this was a Communications Asset. Commentary from project accounting included below:
Email October 7, 2021 - “As discussed, the Panels/Siding for the Antenna Loft would fit in FERC 397000, specifically RUC 397.33 Communication Support System Structures. After our meeting, we further determined that we do not
need to add a retirement unit to the catalog for this, but we will add a note for
future reference on where these fit in.”
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 5/12/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Jim Kensok REQUESTER: IPUC RESPONDER: Elisabeth Sibulsky TYPE: Production Request DEPARTMENT: Enterprise Technology
REQUEST NO.: Staff-198 TELEPHONE: [phone] REQUEST: As supplement to Production Request No. 70, please provide a supporting worksheet for employee
incentives to use their own mobile devices instead of a Company phone. Please include the amount budgeted and the actual spend by month for the period July 1, 2021 through March 31, 2023. RESPONSE:

The Company pays a flat fee to employees who bring their own devices. Historically, the majority of these fees have been approximately $71.26/month, and recently the Company reduced this reimbursement amount to approximately $45/month, effective April 28, 2023 as a Corporate cost saving measure. Please see Staff_PR_198 Attachment A for the details of the monthly totals
compared to budget. There is a small variance monthly from the budget due to unanticipated
additions in employees needing reimbursement.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/12/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Dennis Vermillion REQUESTER: IPUC RESPONDER: Laura Vickers TYPE: Production Request DEPARTMENT: HR
REQUEST NO.: Staff-199 TELEPHONE: [phone] REQUEST: Please provide a copy of all Avista employee surveys conducted since January 1, 2021, and a
summary of the results. RESPONSE: Please see Staff_PR_199-Attachment A (Safety Culture) & B (Employee engagement /
Experience).
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/11/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Dennis Vermillion REQUESTER: IPUC RESPONDER: Dana Anderson TYPE: Production Request DEPARTMENT: Communications
REQUEST NO.: Staff-200 TELEPHONE: [phone] REQUEST: Please provide a copy of all Customer Surveys conducted by/for Avista since January 1, 2021, and
a summary of the results. RESPONSE: Please see Staff_PR_200 Attachments A & B.
AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 05/08/2023 CASE NO: AVU-E-23-01 / AVU-G-23-01 WITNESS: Kaylene Schultz REQUESTER: IPUC RESPONDER: Jeanne Pluth TYPE: Production Request DEPARTMENT: Regulatory Affairs
REQUEST NO.: Staff-201 TELEPHONE: [phone] REQUEST: Please provide a list of payments made to Ethisphere from 2021 through March 31, 2023, and
include the amounts, dates, and accounts charged. RESPONSE:
Please see Staff_PR_201-Attachment A.