20171129UM 1897 Hydro-One DR 208-211 MG.docx

November 1, 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 208– DR 211
November 15, 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: Cost Allocations, Merger Costs
Please explain how Hydro One allocates shared costs to all jurisdictions in which the company operates and provides electric services; please also explain how Hydro One allocates shared costs to its affiliates. In your response, please also include the following information for Hydro One’s most recent completed rate case:
Written policies and procedures regarding allocation methodologies;
The allocation factors worksheets used to prepare the rate case;
Any modifications to the allocation methodology proposed by intervenors; and,
The allocation factors used as applied in the ordered rates.
Please explain Hydro One’s current transfer pricing between its regulated energy jurisdictions and its affiliates. In the response, please provide all written policies and procedures regarding transfer pricing. In the response, please also address the purchase or transfer of services between affiliates and the purchase or delivery of power between affiliates.
If Hydro One’s merger application is approved by Avista’s regulators, please explain how the anticipated allocation of shared costs, transfer pricing of services, and the purchase or delivery of power between Hydro One and Avista and between Hydro One’s affiliates and Avista will differ or be consistent with the methodologies, policies or procedures described by Hydro One in its responses to Staff’s above DR Nos. 208 and 209.
Please provide the following information regarding Hydro One’s accounting for the preclosing costs associated with the acquisition of Avista:
Please describe Hydro One’s method for determining if a cost is directly assigned or allocated;
Please provide all policies, guidelines, and training material used by Hydro One employees to determine direct assignment or allocation of these costs; and,
Please identify any estimates used to apply or assign costs and provide the supporting calculations in Excel; and,
Please provide the total amount of cost incurred currently and explain how Hydro One expects to recoup the costs.
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:Marianne Gardner [e-mail] 503-378-6117