20180126Avista to Staff_DR_013.docx

AVISTA CORP.
RESPONSE TO REQUEST FOR INFORMATIONJURISDICTION:WASHINGTONDATE PREPARED:11/20/2017CASE NO.:U-170970WITNESS:Patrick D. EhrbarREQUESTER:UTC StaffRESPONDER:Jennifer S. SmithTYPE:Data RequestDEPT:State & Federal RegulationREQUEST NO.:Staff – 013(AVA)TELEPHONE:[phone]EMAIL:[e-mail]:
Does Avista believe that the company’s rate of return should be calculated using revenue figures that take into consideration the revenues that would be earned absent a rate credit?RESPONSE:Avista believes the company’s earned rate of return should be calculated inclusive of the customer rate credits, just as the company’s incurredcosts will reflect merger benefits that are achieved. To the extent merger benefits offset a portion of the offsetablerate credits, there would be no impact on the earned rate of return. Any credits not offset by merger benefits, including the non-offsetable rate credits, would reduce the company’s earned rate of return, consistent with the testimony of Hydro One witness Chris Lopez.