20171129UM 1897 Hydro-One DR 154-172 KZ.docx

October17, 2017
ELIZABETH THOMAS, PARTNER
JAMES SCARLETT
KARI VANDER STOEP, PARTNER
EXECUTIVE VICE PRESIDENT &
K&L GATES LLP
CHIEF LEGAL OFFICER
925 FOURTH AVENUE, SUITE 2900
HYDRO ONE
SEATTLE, WA 98104-1158
483 BAY ST, 8TH FL, SOUTH TOWER
[e-mail]
TORONTO, ONTARIO, M5G 2P5
[e-mail]
[e-mail]
DIRK MIDDENTS, PARALEGAL
S. KYLE MERSKY, SENIOR ADVISOR
K&L GATES LLP
OFFICE OF THE PRESIDENT & CEO
925 FOURTH AVENUE, SUITE 2900
HYDRO ONE INC.
SEATTLE, WA 98104-1158
483 BAY ST, 8TH FL, SOUTH TOWER
[e-mail]
TORONTO, ONTARIO, M5G 2P5
[e-mail]
RE:
Docket No.
Staff Request Nos.
Response Due By
UM 1897
DR 154– DR 172
October 31, 2017
Please provide responses to the following request for data by the due date. Please note that all responses must be posted to the PUC Huddle account. Contact the undersigned before the response due date noted above if the request is unclear or if you need more time. In the event any of the responses to the requests below include spreadsheets, the spreadsheets should be in electronic form with cell formulae intact.
Topic or Keyword: Customer ServiceRegarding Avista 500, Christie/3 – Community outreach and energy assistance:
Please provide a narrative response explaining the actions the Company has taken in the past, and presently takes, to demonstrate that this statement is true.Regarding Avista 500, Christie/12 – low income energy funding:
Please provide a current list of companies and/or foundations working with Avista and Hydro One respectively, and briefly describe the focus of each company and/or foundation.
Please describe each of the funding mechanisms by which Hydro One and Avista support these companies and/orfoundations.
Please compare the Hydro One funding for low income assistance in Ontario as a percentage of Hydro One’s gross revenues, with Avista’s like ratio for its operations individually in ID, OR, WA, and MT.
For 2015, 2016, and 2017, please provide the number of Hydro One customers in arrears at any time in each of the listed years.
For 2015, 2016, and 2017, what percentage of residential Hydro One customers were in arrears at any time during each of the listed years?
For 2015, 2016, and 2017, what percentage of total Hydro One customers were in arrears at any time during each of the listed years?
For 2015, 2016, and 2017, please describe the Ontario Electricity Support Program and explain what portion, if any, of Hydro-One’s bad debt is covered by this program.
Please provide a narrative explanation of how the above issuesare likely to affect rates for Oregon customers post-closing of the merger?Regarding Avista 600, Pugliese/2 and 4 – Operations in Data Center:Customer service, summary of testimony:
Does Avista currently provide 24/7 support for its data center?
Will Avista coordinate call and data center operations with Hydro One post-merger?
If the answer to either of the two prior sub-questions is “yes,” how is Avista planning on meeting the need for call and data center staff and equipmentpost-merger?
Please explain in detail what off-setting cost savings Hydro One anticipates from procurement of Avista, i.e., less overtime, less contract labor.
How are the cost savings identified above in subpart (D) to be reflected in the next Avista general rate case test year revenue requirement?
Does Hydro One share phone support and/or data center management, staff and resources across subordinate companies? If so, please explain what drivers Hydro One uses to allocate costs.Regarding Billing Accuracy:
For 2015, 2016, and 2017, please provide the Ontario ombudsman count of how many faulty Hydro One bills there were for each listed year.Regarding First Nations and Metis Communities:
Please specify Hydro One’s work plan for building and maintaining positive and mutually beneficial relationships with Native American Tribes in Oregon.Regarding Avista/600 page 9 – Customer satisfaction:
As Hydro One and Avista collaborate to serve the customers from both companies, how will this collaboration be reflected in Oregon customer rates? In this discussion, please address specifically whether residential rates in Oregon are expected to increase, decrease, or remain static over the next 2 years, and provide the supporting rationale for your conclusion.
With regard to the testimony discussion of “benefits to customers from the proposed transaction,” the total estimated annual cost saving to customers, on a system basis for Avista, is approximately $1.7 million. Please clarify the geographic and regulatory scope of “system” as the term is used here and whether that meaning is different than as used by Avista in its last general rate case.
Topic or Keyword: Customer ServiceWhat kind of legal actions regarding environmental and/or employment law has Hydro One experienced in the past ten years? Please provide the number of disputes, type, and alleged violation. Also, in this response, please indicate what legal actions or remedies are currently ongoing and have not reached resolution. Regarding Hydro One’s brochure about the Heber Down conservation area, please specify the name of “the invasive species” that Hydro one eliminated, describing how and at what cost this was accomplished, and whether this action was integral to Hydro One utility operations.Regarding Hydro One /403, Lopez/134 – Hazardous Substances:
What specific actions has the company taken to dateto demonstrate that the following statement is true?
“Hydro One manages a number of hazardous substances, such as PCBs, herbicides, and wood preservatives. In addition, some facilities have substances present which are designated for special treatment under occupational; health and safety legislation, such as asbestos, lead and mercury. The Company has environmental management programs in place to deal with PCBs, herbicides, asbestos and other hazardous substances.”Please provide a narrative explanation discussing the outstanding environmental remediation obligations Hydro One has, and indicate whether they are participating in any superfund or like cleanup efforts. As an example, consider the Portland Oregon Harbor superfund cleanup.Does Hydro One have obligations to restore land after the end of the useful life of generating or substation facilities? If so, how does Hydro One financially guarantee each of these future restoration obligation? For example in Oregon, an electric utility might provide an unsecured letter of credit that is somewhat less expensive than a letter of credit backed by the utility’s revolving credit facility, or a bond.Has Hydro One acquired land or substations that itdid not surveyfor environmental risks prior to acquisition? If so, please provide the detail of those properties.Please describe what safeguards, protections, or policies related to birds that Hydro One deploys on its transmission lines.Please provide Hydro One’s studies of its impact on raptors over the last ten years and explain whether raptor deaths are increasing or decreasing, and why?Please describe what methods Hydro One’s new transmission and upgrades use to cross rivers, streams, and wetlands, and how Hydro One is confident that these methods are reflective of current best environmental and engineering practices.Does Hydro One findthat First Nations and conservation groups concur with Hydro One’s positive assessment of its environmental stewardship?What grants does Hydro One have funded through the (a) national Canadian government and (b) the Province of Ontario. Please specify the purposes of the grant, the amount, and total duration.Please explain whether Hydro One has a grant manager or like skill set on staff with experience in grant writing and whether that expertise would be applied to seek U.S. Federal grants for environmental and infrastructure purposes for Avista in any US federal infrastructure stimulus program.
Topic or Keyword: Workplace and Employee SafetyPlease list each Hydro One major accident and workplace death in the last 10 years, such as the incident at Hinchinbrooke Distribution Station and at Toronto transformer station. With this list please summarize the causes for the major accident or death and if there has been an accident for the same reasons since. Please tie this response in to the Company’s response to DR 25 regarding scorecards.
Note: if this response is Highly Confidential, please mail any hard copy provided on green paper.
Please name your responsive file to include the Data Request number. Once you have posted your response to the Data Request to the PUC Huddle account, use the “Sharing” feature of Huddle to generate an email to authorized parties notifying them that the response has been posted. In the body of the generated email, list the Data Request number associated with your response.
You must mark confidential responses as such and post them to Huddle in the appropriate “Confidential” folder. Access to Confidential folders is limited to individuals who have signed the protective order. You should not send confidential documents (hard copy or electronic) separately to the Commission or its Staff; you should post confidential responses only to the Huddle account.
Should you need to request an extension to the due date for the data responses you will need to contact the staff attorney assigned to the case for approval?
Questions regarding the use of Huddle should be directed to [e-mail].
/s/ John Crider
Staff AdministratorStaff Initiator:Kathy [e-mail]503-378-4629