20171129NU Sixth Set of Data Requests to Avista.pdf

TEL [phone] ● FAX [phone] ● [e-mail] Suite 400 333 SW Taylor
Portland, OR 97204
November 17, 2017 Via Electronic Mail
David J. Meyer, Esq. Patrick D. Ehrbar Avista Corporation PO Box 3727 1411 E. Mission Ave, MSC 27
Spokane, WA 99220-3727 [e-mail] [e-mail]
Re: WUTC v. Avista Corporation Docket U-170970 Dear Mr. Meyer and Mr. Ehrbar:
Enclosed please find the Industrial Customers of Northwest Utilities’ (“ICNU”) Sixth Set of Data Requests to Avista Corporation (“Avista”) in the above-referenced matter. Avista has ten business days to respond to these Data Requests. Please provide your responses by no later than December 4, 2017.

Thank you for your attention to this matter. If you have any questions, please do not hesitate to call. Sincerely,

/s/ Haley M. Thomas Haley M. Thomas
cc: U-170970 Service List

PAGE 1 – ICNU’S SIXTH SET OF DATA REQUESTS TO AVISTA
DAVISON VAN CLEVE, P.C. 333 S.W. Taylor, Suite 400 Portland, OR 97204 Telephone: [phone]
BEFORE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION,
Complainant,

Respondent.

SIXTH SET OF
AVISTA
Dated: November 17, 2017
Please provide responses to these Data Requests by December 4, 2017. DATA REQUESTS
0083 Where an affiliate provides services to Avista, please explain Avista’s interpretation of
the price benchmark required to prevent subsidization, including whether prices charged by the affiliate to Avista must be:
a. Set no greater than the affiliate’s direct cost, with no loadings?
b. Set no greater than the affiliate’s direct cost, including loadings?
c. Set no greater than what comparable services would cost Avista, if it purchased
those services at market prices?
d. Set according to any other criteria?
0084 If an affiliate of Avista wants to purchase a non-tariff service from Avista, what price floor does Avista believe is required to ensure that the affiliate is not being subsidized?
0085 If an affiliate wants to buy labor services from Avista, does Avista take the position that
the affiliate is not being subsidized, even when the market price for the affiliate to obtain such labor services is greater, so long as the affiliate is charged Avista’s fully-loaded labor rate? Please explain.
PAGE 2 – ICNU’S SIXTH SET OF DATA REQUESTS TO AVISTA
DAVISON VAN CLEVE, P.C. 333 S.W. Taylor, Suite 400 Portland, OR 97204 Telephone: [phone]
0086 Refer to Avista’s response to ICNU Data Request 070(b). Is it Avista’s contention that it is not cross-subsidization, if the affiliate takes advantage of Avista’s size and scope to
obtain lower vendor prices than what the affiliate could otherwise obtain on its own?
Please explain.