20180130Avista to WNIDCL 1-40.pdf

Avista Corp.
l4l 1 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
idaho Public Utilities Commission
Otfice of the SecretaryRECEIVED
JAN 3 0 20t8
Aknsrt
Corp.
Boise. ldaho
January 30,2018
Danielle Franco-Malone
Law Offices of Schwerin Campbell Barnard Iglitzin & Lavitt Llp
l8 West Mercer Street Suite 400
Seattle, Washington 981 l9-3971
RE: Docket AVU-E-17-09/AVU-G-17-05 - WNIDCL Data Request Responses
Enclosed are Avista's responses to WNIDCL's data requests in the above referenced docket.
Included in this mailing are the original copies of Avista's responses to WNIDCL l-40. The
electronic versions of the responses were emailed on 113012018.
In addition, Avista's responses to WNIDCL 001(HC)(AVA),016(C)(AVA),018(C)(AVA),
019(CXAVA),020(C)(AVA),027(CXAVA),029(C)(AVA), and 030(C)(AVA) are provided
under a sealed separate envelope, marked CONFIDENTIAL or HIGHLY CONFIDETNIAL.
The information in these documents is CONFIDENTIAL PER PROTECTIVE
AGRE,EMENT WITH WNIDCL FILED IN CASE NO. AVU.17-O9IAYA-G.17.05.
Note as to forward-looking statements and information:
With respect to all of Hydro One's data responses served in this proceeding, to the extent any
response or attachments contain forward-looking information or statements, within the meaning
of applicable securities laws, that are based on current expectations, estimates, forecasts and
projections about Hydro One's business and the industry in which Hydro One operates and include
beliefs and assumptions made by the management of Hydro One, such information and statements
are not guarantees of future performance or actions and involve assumptions and risks and
uncertainties that are difficult to predict. Words such as "expect," "anticipate," "intend,"toattemptr" t'may," ttplanr" ttwillr" "canr" tobelieve," ttseekr" ttestimater" and variations of such
words and similar expressions are intended to identify such forward-looking
information/statements. Therefore, actual outcomes and results may differ materially from what
is expressed, implied or forecasted in such forward-looking information/statements. Hydro One
does not intend, and Hydro One disclaims any obligation to update any forward-looking
information/statements, except as required by law.
If there are any questions regarding the attached information, please contact me at [phone]
or via e-mail at [e-mail], or Dirk Middents at [phone] or via email at
dirk. middents@klgates. com.
Sincerely,
/s/ Paul Kimball
Regulatory Analyst
CC (Email);IPUC (Hanian)
Clearwater (Richardson, Reading, Lewallen, Haugen, Jacobs, Wren, Smith)
Idaho Conservation League (Otto, Nykiel)
Idaho Forest Group (Miller, Williams, Crowley)
CAPAI (Purdy)
WNIDCL (Franco)
Ccs (w/encls.)
Brandon Karpen
Camille Christen
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702
Peter J. Richardson
Gregory Adams
Kandi Walters
Richardson Adams PLLC Richardson & O'Leary PLLC
515 N. 27th Street
Boise, ID 83702
(representing Clearwater Paper Corporation)
Matthew Nykiel
Conservation Associate Idaho Conservation League
102 Euclid Ave.,#20'7
Sandpoint, ID 83864
Benjamin Otto
Energy Associate
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
David Wren
Nathan Smith
Clearwater Paper Corporation
803 MillRoad
Lewiston, ID 83501
Jay Backus
Clearwater Paper Corporation
601 W. Riverside Avenue, #l100
Spokane, WA 99201
Don Reading
Ben Johnson Associates
6070 W Hill Road
Boise, ID 83703
(representing Clearwater Paper Corporation)
Marvin A. Lewallen
M. A. Lewallen & Associates, LLC
7408 SW Mapleleaf Street
Portland, OP.97223
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-I7 -09 I AVU.G.I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-OOI(AVA) TELEPHONE:
t/2812018
Mark Thies
Annette Brandon
State & Federal Regulation
(s09) 49s-4324
REQUEST:
Provide copies of all production responses provided to other parties or Commission Staff.
RESPONSE:
Please see WNIDCL_PR_001(AVA) Attachment A for the non-confidential responses and
WNIDCL_PR_00I(HCXAVA) Highly Confidential Attachment A for the Highly Confidential
responses. The information for all three attachments is being provided on separate CDs only.
500996047 v2
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REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED:
AVU-E-17-09 / AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-002(AVA) TELEPHONE:
U28120r8
Mark Thies
Annette Brandon
State & Federal Regulation
(s}e) 4es-4324
REQUEST:
Provide all guidelines, policies, and other Documents prepared by or for Avista that specify, or
concern or relate to, the circumstances in which Avista uses Contractor Personnel in the
performance of Avista's utility operations in Washington.
RESPONSE:
The Company's decision to utilize a contractor is made by each Manager dependent upon labor
resource availability. Typically, Management would fully utilize internal labor resources prior to
engaging contract employees. Should there not be sufficient labor resources to perform required
tasks, the Manager has the authority to utilize third-party contractors. Please see
WNIDCL_PR_002(AVA) Attachments A-O, which are examples of the contract templates that
are utilized by the Company for contracted services, and which contain standard provisions
goveming the Contractor and its workforce. Please see response to WNIDCL_PR_0I5(AVA) for
the Company's current Best Practices for contracting.
For union employees in the International Brotherhood of Electrical Workers (IBEW) Local77
agreement, there is a contract provision that requires the Company to utilize Union workers prior
to hiring external contract crews.
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 112812018
AVU-E-I7-09 / AVU-G-17-05 WITNESS: Mark Thies
WNIDCL RESPONDER: Annette Brandon
Production Request DEPARTMENT: State & Federal RegulationWNIDCL-003(AVA) TELEPHONE: [phone]
REQUEST:
To the extent not provided in response to Production Request No. l, provide all guidelines,
policies, and other Documents prepared by or for Avista that are applicable to the performance of
utility operations by Contractor Personnel in Washington.
RESPONSE:
Please see Avista's response to WNIDCL_PR_002(AVA)
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 112812018
AVU-E-I7-09 / AVU-G-17-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Annette Brandon
Production Request DEPARTMENT: State & Federal Regulation
WNIDCL-O04 (AVA) TELEPHONE: [phone]
REQUEST:
To the extent not provided in response to Production Request Nos. 7 and2, provide all guidelines,
policies, and other Documents prepared by or for Avista that state, concern or relate to the
certifications required by Avista to work on a Washington maintenance, capital, reliability, or
other Washington construction project, including those that list of all required certifications, from
2014 to present.
RESPONSE:
Please see Avista's responses to WNIDCL_PR_007(AVA), WNIDCL_PR_020(C)(AVA), and
WNTDCL_PR_O23(AVA).
500869550 v'l
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CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-17-09 / AVU-G-17-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:WNIDCL-005(AVA) TELEPHONE:
U2812018
Mark Thies
Greg Hesler
Supply Chain
(s}e) 4es-2208
REQUEST:
Provide copies of all Documents prepared by or for Avista that include information concerning the
number of contractor employees, full time equivalent positions ("FTE"), total labor hours, or any
other data that details, by occupation, the number of Contractor Personnel employed on
maintenance, capital, reliability, or other Washington construction projects from 2014 to present
(by year).
RESPONSE:
The Company does not track the total labor hours nor the number of contractor employees working
on maintenance, capital, reliability, or other projects. The Company also does not track the
compensation and benefits for contractor employees by occupation, as that goes beyond the
purview of the independent contractor relationship.
On contracts that provide for services to be provided on a time and materials basis, the contractor is
required to provide a labor rate sheet, an example of which is included in the materials provided in
response to WNIDCL_PR_002(AVA). This is primarily used to ensure that costs associated with
change orders are appropriate and to reconcile potential invoicing issues.
For contracts that are invoiced on a time and materials basis, the contractor is required to provide
supporting documentation for the time and materials charged to the Company. With more than
2,500 active contractor agreements across its service territory, attempting to produce all such
records would be unduly burdensome.
The Company also maintains, as a part of its standard contract provisions, the ability to audit a
specific contractor to verify compliance with, among other things, any wage and benefits
requirements that might be applicable under the contract.
500869550 v"l
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REQUESTER:
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REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-I7 -09 I AVU-G.I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-006(AVA) TELEPHONE:
v2812018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Refer to commitment number 8 in the Master List of Commitments. Please clarify whether Avista
is making the same commitment to maintain compensation and benefits for contractor personnel,
and provide copies of all Documents prepared by or for Avista that include information concerning
the compensation and benefits for these Contractor Personnel by occupation from 2014 to present.
RESPONSE:
The Company does not dictate the compensation or benefits of contractor personnel beyond
applicable prevailing wage requirements where applicable, as that goes beyond the purview of the
independent contractor relationship. As stated in WNIDCL_PR_01l(AVA), no changes in current
processes related to contracted out construction services are currently being considered, evaluated,
explored or otherwise contemplated. We anticipate procedures to remain consistent pre and
post-merger.
500869550 v1
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED
CASE NO: AVU-E-17-09 / AVU-G-17-05 WITNESS:
REQUESTER: WNIDCL RESPONDER:TYPE: Production Request DEPARTMENT:
REQUEST NO.: WNIDCL-007(AVA) TELEPHoNE:
112812018
Mark Thies
Greg Hesler
Supply Chain
(s}e) 4es-2208
REQUEST:
Provide copies of all Documents prepared by or for Avista that include information conceming the
number of contractor employees who have obtained the requisite certifications to work on a
maintenance, capital, reliability, or other Washington construction project, and a list of all required
certifications from 2014 to present.
RESPONSE:
The Company maintains over 2,500 active contracts across its service territory, with each contract
involving multiple contractor employees and, potentially, multiple certification requirements,
depending on the nature of the work, differences in job site locations, scope of work and type of
contractor employee. Avista actively engages with Contractors to ensure compliance with all
certification requirements that are applicable and/or required by law; however, responsibility for
recordkeeping regarding certifications is the ultimate responsibility of the Contractor.
500995964 v2
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED:
AVU-E-17-09 / AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-008(AVA) TELEPHONE:
y2812018
Mark Thies
Annette Brandon
State & Federal Regulation
(s09) 49s-4324
REQUEST:
For each year during the period from2014 to the present, provide the: (a) total amount expended
by Avista on construction labor; and (b) proportion of that total amount spent on Construction
Contractors or Contractor Personnel. Provide all supporting data (including worksheets).
RESPONSE:
Costs for Construction Services are tracked on a total basis and not by labor and non-labor
expense. Please see WNIDCL_PR_008(AVA) Attachment A for the expense related to
construction services for January 2014 through December 31, 2017 .
500869550 v1
JURISDICTION:
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REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: l/2812018
AVU-E-I7-09 IAVU-G-17-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Annette Brandon
Production Request DEPARTMENT: State & Federal Regulation
WNIDCL-009(AVA) TELEPHONE: [phone]
REQUEST:
Provide copies of all Documents prepared by or for Avista that include information conceming the
number of contractor employees who have obtained the requisite certifications to work on a
maintenance, capital, reliability, or other Washington construction project, and a list of all required
certifications from 2014 to present.
RESPONSE:
Please see Avista's response to WNIDCL_PR_OO8 (AVA)
500869550 v1
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED
AVU-E- I 7 -09 I AVU.G- 17-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-010(AVA) TELEPHONE:
U28120t8
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
For each capital investment projected to be undertaken during the period 2018-2021, provide: (a)
forecasted expenditures for projects to be performed by Construction Contractors; and (b) the
scope of the work to be performed by outside construction contractors.
RESPONSE:
Projected capital investments are primarily categorized based on labor and non-labor expense.
Details specific to outside construction contractors for all projected capital investments are not
available. Please see Avista's response to WNIDCL_PR_002(AVA) for additional information.
500869550 v'1
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARE,D
AVU-E-17-09 / AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-0II(AVA) TELEPHONE:
U2812018
Mark Thies
Annette Brandon
State & Federal Regulation
(s09) 49s-4324
REQUEST:
Provide all Documents, whether prepared by or for Avista, that state, detail, concern or relate to
potential changes to the post-merger processes or systems used to procure the services of
Construction Contractors. Your response should include changes being considered, evaluated,
explored, or otherwise contemplated.
RESPONSE:
No changes in current process or systems related to contracted out construction services are
currently being considered, evaluated, explored, or otherwise contemplated. We anticipate
procedures to remain consistent pre and post-merger.
500869550 v1
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REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RE,SPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 112812018
AVU-E-I7-09 / AVU-G-17-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Annette Brandon
Production Request DEPARTMENT: State & Federal RegulationWNIDCL-012(AVA) TELEPHONE: (509) 49s-4324
REQUEST:
Provide all documents, whether prepared by or for Avista, including those received from Hydro
One, that detail any post-merger employment goals, commitments, or understanding that concern
or relate to Contractor Personnel.
RESPONSE:
Currently there are no formal employment goals or commitments as it relates to contractor
employees. As noted in Avista's response to WNIDCL_PR_002(AVA), the hiring of contractor
employees is done only after internal resources have been fully utilized, on a case-by-case basis.
500869550 v1
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REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 112812018
AVU-E-I7-09 IAVU-G-17-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply ChainWNIDCL-013(AVA) TELEPHONE: (s09) 49s-2208
REQUEST:
Provide any analysis, document, or report that details plans to recruit additional direct employees
or contractor personnel necessary to sufficiently staff future capital investments.
RESPONSE:
In general, the Company's employees perform primarily repair and maintenance work, which,
depending on the circumstances, may represent capital work. Conversely, planned capital
construction work is generally performed by Avista and/or Contractors, depending on available
resources, capacity and need.
500869550 v1
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO DATE PREPARED
CASE NO: AVU-E-17-09 / AVU-G-17-05 WITNESS:
REQUESTER: WNIDCL RESPONDER:TYPE: Production Request DEPARTMENT:
REQUEST NO.: WNIDCL-O14(AVA) TELEPHONE:
U28t2018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Provide all Documents that state or detail contractor or procurement goals as they relate to Woman
Business Enterprises and Minority Business Enterprises.
RESPONSE:
The Company has not adopted specific procurement goals or quotas relating to Woman or
Minority Business Enterprises, but does look for opportunities to partner with such businesses
where appropriate.
The Company is an equal opportunity employer and does not discriminate against any entity or
person, including in its procurement of contractors, on the basis of disability,race, color, religion,
sex, sexual orientation, gender identity, or national origin. The Company likewise requires all
contractors to comply with the same requirements. See the sample contracts provided in response
to WNIDCL_PR_002(AVA).
500869550 v1
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CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED:
AVU-E-I 7.09 / AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:WNTDCL-01s(AVA) TELEPHONE:
112812018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Provide any Document, including analyses, data, reports, or surveys used to determine projected
contract labor expenditures.
RESPONSE:
The Company utilizes several methods to ensure that it obtains appropriate and competitive
pricing from its contractors. The use of any specific method is dependent on the nature of the
contract, the type of work involved, the value of the contract, and the discretion of the Company's
Supply Chain and Legal Departments. For example, for contracts in excess of $100,000, the
Company (a) issues a formal Request for Proposal ("RFP") from qualified bidders, utilizing the
market forces inherent in that process to ensure competitive pricing, or (b) in cases where an RFP
is not appropriate, goes through a Sole Source approval process to justify why the RFP process is
not appropriate in that instance. In contracts of a lesser value, the Company will secure written
quotations from qualified suppliers, or alternatively, work with the Company's Category
Managers to ensure competitive and appropriate pricing. Please see WNIDCL_PR_0I5(AVA)
Attachment A for the Company's current Best Practices for contracting.
In each of the instances noted above, the Company's Category Managers may seek outside market
data, most notably from the Bureau of Labor Statistics. Bureau of Labor Statistics occupational
wage data is public information and freely accessible.
In addition to the above, the Company's contracts include, among others, lump-sum pricing,
not-to-exceed contract caps for (time and materials work), or unit based pricing methodologies.
These help provide predictability, on a contract by contract basis, for contract labor expenditures.
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
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REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: 112812018
AVU-E-17-09 / AVU-G-17-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply ChainWNIDCL-016(AVA) TELEPHONE: (509) 49s-2208
REQUEST:
Provide copies of the last five most recent contract awards for the provision of traffic control
services. Please include the Request for Proposal, technical evaluations used to qualify
contractors, bid amounts and actual costs of the awarded contract, and any evaluations of the
performance of the winning bidder.
RESPONSE:
In the majority of instances, traffic control services are provided via a subcontract between the
traffic control contractor and the general contractor. In those instances, the Company is not
provided with a copy of the subcontract agreement.
The Company currently has flagging companies under contract in Idaho. Copies of the contacts
with these entities are attached (WNIDCL_PR_016(C)(AVA) Confidential Attachments A-E),
save for pricing information, which is proprietary to the contractor(s).
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
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REQUEST NO.:
IDAHO DATE PREPARED: ll28l20l8
AVU-E-I7-09 IAVU-G-17-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply ChainWNIDCL-017(AVA) TELEPHONE: (s09) 495-2208
REQUEST:
Provide copies of any and all current Master Service Agreements (MSAs) between Avista and any
Contractor. For each such MSA, provide a schedule of when it will expire, and the timeline in each
instance (if any) for securing new MSA contracts.
The Company maintains over 2,500 active contracts, the majority of which are Master Service
Agreements. In any instance where it is likely that the Company will engage a contractor on
multiple occasions, it is preferable to negotiate a Master Service Agreement so that subsequent
projects can be accomplished without having to negotiate underlying terms and conditions.
The Company does not maintain a master schedule of expiring active contracts. The Company
instead produces a monthly report of contracts that are set to expire during that month so that
action may be taken to renew, extend or renegotiate those contracts as appropriate. Please see
WNIDCL_PR_017(AVA) Attachment A for an example of the monthly report.
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JURISDICTION:
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REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-17-09 / AVU-G-17-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-018(AVA) TELEPHONE:
U28t2018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Provide all third party damage reports generated from 2014 to current, and any reports or root
cause analyses performed on third party damages.
RESPONSE:
Please see WNIDCL_PR_018(CXAVA) Confidential Attachments A for details related to
excavation damages that have been recorded with respect to the Company's Idaho service territory
from 2014 to current. Due to the voluminous nature, data is provided in electronic form only. As
part of this process, the Company's Claims Department will seek recovery from the responsible
party where it appears to have been caused by the negligence of that party. This process, however,
does not result in a formal root cause analysis or report.
The Company's Claims Department also handles third party damage claims against the Company,
which may be the result of the Company's operations or the actions of Contractors. These are
investigated and either accepted or denied based on the results of that investigation. This process
also does not result in a formal root cause analysis or report.
Avista is developing an incident assessment process as part of its Human Performance
Improvement (HPI) initiatives. This process does not look at root cause, but rather includes an
analysis of occupational factors that create the possibility for error, using traditional HPI
techniques. This process is still under development.
500869550 v'l
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REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED:
AVU-E-I 7.09 I AVU-G-17-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-019(AVA) TELEPHONE:
1128t2018
Mark Thies
Greg Hesler
Supply Chain
[phone]
REQUEST:
Provide copies of all pipeline reportable incidents from 2014 to current, and any internal analyses
or reports completed by Avista aimed at identify ways to reduce pipeline safety risks.
RESPONSE:
Please see WNIDCL_DR_019(C)(AVA) Confidential Attachment A for copies of Idaho
reportable incidents from2014 to present. Please see WNIDCL_DR_019(CXAVA) Confidential
Attachment B for the Company's Distribution Integrity Management Plan.
500869550 v1
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CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: ll28l20t8
AVU-E-I7-09 / AVU-G-I7-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply ChainWNIDCL-020(AVA) TELEPHoNE: (s09) 49s-2208
REQUEST:
Provide all Documents that detail the prequalification process by which outside Construction
Contractors are selected to bid on capital or maintenance projects.
RESPONSE:
Entities that desire to bid on projects for the Company go through a prequalification process,
which is administered by the Company's Category Managers. The Prequalification Process
includes submission and review of both a Safety and a Financial Questionnaire, copies of which
are attached.
The Company currently uses Avetta for safety auditing of contractors. Moreover, the Company is
in the process of revising its prequalification process to incorporate Avetta as a precondition to
bidding on most Company projects.
The Company also utilizes an annual scorecard process to review the performance of its larger
contractors, including contractors working on its natural gas system. The scorecard process
includes metrics spanning several different performance criteria. Please see
WNIDCL_PR_020(C)(AVA) Attachment A for a copy of the Company's Scorecard Template.
Please see WNIDCL_PR_020(CXAVA) Attachment B for the Supplier Qualification Business
Info Questionnaire and WNIDCL_PR_020(C)(AVA) Attachment C for the Supplier Qualification
Safety Questionnaire.
See, also, Procurement Best Practices, found in WNIDCL PR_015(AVA) Attachment A.
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: Il28l20l8
AVU-E-I7-09 / AVU-G-I7-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply Chain
WNIDCL-021(AVA) TELEPHONE: (509) 49s-2208
REQUEST:
Provide all Documents used to assess the qualifications of Construction Contractors bidding on
capital or maintenance projects, including qualifications that relate to the contractor's capacity to
meet any and all safety, regulatory, engineering, environmental, legal, manpower, and financial
requirements.
RESPONSE:
Please see Avista's response to production requests WNIDCL_PR_002(AVA),
WNIDC L_PR_020(AVA), and WNIDC L_PR_023 (AVA).
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED
AVU-E-I7-09 I AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNIDCL-}22(AV A) TELEPHONE:
v2812018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Provide a list of Contractors that have met the prequalification standards for construction and
maintenance projects described in the response to Production Request No. 20.
RESPONSE:
All of the Company's active contractors have met applicable prequalification standards. The
Company maintains over 2,500 active contracts across its service territory.
500869550 v1
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-I7-09 I AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNIDCL-O23(AVA) TELEPHONE:
112812018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Detail the process by which Contractor Personnel obtain Operator Qualification certihcation.
Provide copies of all Documents, including training curriculum, training materials, and instructor
qualification criteria, used or approved for use by Avista.
RESPONSE:
The process by which contractor employees obtain Operator Qualification certification is managed
by each independent contractor Company. Avista does not provide training, training curriculum,
or instructor qualification criteria. Contractors are, however, responsible for meeting the Standards
set forth in the Avista Utilities Gas Standards Manual. Please see WNIDCL_PR_023(AVA)
Attachment A for a copy of this manual.
Avista does provide some continuing leaming opportunities for contractors through the Avista
Learning Network. Please see WNIDCL_PR_023(AVA) Attachment B for materials available for
contractors to utilize as needed. This coursework is not intended to replace contractor in-house
training, but rather can be utilized as a means to refresh contractor knowledge. This attachment is
provided in electronic format only.
500869550 v1
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-I 7.09 I AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-024(AVA) TELEPHONE:
1128120r8
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Provide all Documents prepared by or for Avista which state or describe policies, procedures or
guidelines that concern or relate to sub-contracted out services.
RESPONSE:
Although the Company requires general contractors to notify it of any sub-contracted services, it
does not maintain policies or guidelines relating to subcontracting. Any requirements applicable
to subcontractors are incorporated into the agreement between the Company and the general
contractor. See, e.g., response to WNIDCL_PR_002(AVA).
500869550 v1
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 112812018
AVU-E-I7-09 / AVU-G-I7-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply ChainWNIDCL-025(AVA) TELEPHoNE: (s09) 49s-2208
REQUEST:
Identify and describe in detail all workforce safety, health, or environmental metrics employed by
Avista to measure Contractor performance. For the period 2014 until the present, provide all
Documents, including reports, analyses or studies, prepared by or for Avista that contain or
evaluate Contractor performance (whether using these metrics or other performance measures).
Please see Avista's response to WNIDCL_PR_020(AVA).
500869550 v1
RESPONSE:
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: l/2812018
AVU-E-I7-09 / AVU-G-I7-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply ChainWNIDCL-026(AVA) TELEPHoNE: (s09) 49s-2208
Provide all analyses or other Documents prepared by or for Avista that compare or contrast the
performance (whether measured using safety, health, environmental, timeliness, or any other
productivity metrics) of each of the Contractors who have worked on Avista's competitively bid
capital or maintenance projects.
Please see Avista's response to WNIDCL_PR_020(AVA).
500869550 vl
REQUEST:
RESPONSE:
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU.E-I 7 -09 I AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNIDCL-027(AVA) TELEPHONE:
112812018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Provide copies of the last five most recent contract awards for capital projects valued at over $1
million. Please include the Request for Proposal, technical evaluations used to qualify contractors,
bid amounts and actual costs of the awarded contract, and any and all performance evaluations
done by or for Avista after commencement of the project.
RESPONSE:
Please see WNIDCL_PR_020(C)(AVA) Confidential Attachments A-C for responsive
agreements, less pricing information, which is proprietary to the contractor.
Please see WNIDCL_PR_027(CXAVA) Conf,rdential Attachment A for the 5 most recent
contracts awarded for capital projects valued at over $1.0 million, less pricing information, which
is proprietary to the contractor. The files are being provided in electronic format only.
500869550 vl
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: tl28l20l8
AVU-E-I7-09 / AVU-G-I7-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply ChainWNIDCL-028(AVA) TELEPHONE: [phone]
REQUEST:
Provide all Documents regarding the applicability, or planned applicability, of any health, safety,
or environmental management system to Contractor Personnel and/or Construction Contractors
working on Avista maintenance, capital, reliability, or other construction projects.
RESPONSE:
Please see Avista's response to WNIDCL_PR_020(AVA)
500869550 v'1
AVISTA CORPORATION
R-ESPONSE TO R_EQUEST FOR TNFORMATTON
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: l/2812018
AVU-E-I7-09 IAVU-G-I7-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply ChainWNIDCL-029(AVA) TELEPHONE: (s09) 49s-2208
REQUEST:
Provide all Documents, including communications, reports, violations, internal audits, and
corrective action plans, which concern or relate to any investigation or review Contractor
compliance with Avista's Operator Qualification program.
RESPONSE:
Avista utilizes a team of Quality Assurance (QA) Auditors to review its Company and Contract
employees' construction work. These auditors observe construction work as it is being performed
and reviews whether it meets Avista's internal Standard Operating Procedures, is in compliance
with its Operator Qualification Program (as applicable) and Safety practices.
Independent of the QA process, Incident Assessments may be initiated for cause or when it is
believed that work was not being performed properly. An "independent" team performs an
Incident Assessment which often includes interviews with individuals involved and may involve
material evaluations also. A report is produced with the Assessment findings.
WNIDCL _PR_029(CXAVA) Confidential Attachment A includes QA Audits and Incident
Assessments for the past 12 months performed on Avista's ID contractors who performed
construction work. The attachment is being provided in electronic format only.
500869550 vl
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-I7-09 I AVU-G.I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-030(AVA) TELEPHONE:
1t28t2018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
For the period 2017-2021, provide a list, timeline, and schedule for any future or active capital
projects valued at more than $1 million, and any long-term planning or supportive documents.
RESPONSE:
Please see WNIDCL_PR_030(C)(AVA) Confidential Attachment A for the Five Year Capital
Plan for Idaho-related projects. Compiling support documents for each Business Case is overly
burdensome and time-consuming. Please also see WNIDCL_DR_002(AVA) as to the use of
contractors in Avista Projects.
500869550 v1
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST F'OR INFORMATION
IDAHO DATE PREPARED
AVU-E-17-09 / AVU-G-1 7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-O31 (AVA) TELEPHONE:
U2812018
Mark Thies
Greg Hesler
Supply Chain
(s09) 49s-2208
REQUEST:
Describe in detail Avista's plans to recruit, train, and retain sufficient Contractor Personnel to
perform forecasted construction activities on capital, maintenance, and reliability projects.
RESPONSE:
The Company's Supply Chain Department actively works with applicable business units to ensure
that there are sufficient contractor resources available to meet the needs of planned projects, to
secure those resources when needed, and to confirm that those resources are provided at a
competitive price, without compromising safety or quality. Procurement is accomplished through
a variety of mechanisms, depending on the size, complexity and nature of the projected work.
Please see WNIDCL_PR_015(AVA) for the Procurement Best Practices document.
500869550 v"l
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: ll28l20l8
AVU-E-I7-09 IAVU-G-I7-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply Chain
WNIDCL-032 (AVA) TELEPHONE: (509) 49s-2208
REQUEST:
Describe Avista's plans to recruit, train, and retain sufficient Operator Qualif,red contractor
employees to perform forecasted construction activities on capital, maintenance, and reliability
projects.
RESPONSE:
Please see Avista's response to WNIDCL_PR_031(AVA) and WNIDCL_PR_023(AVA)
500869550 v1
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 1l28l20t\
AVU-E-17-09 IAVU-G-17-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply Chain
WNIDCL-033 (AVA) TELEPHONE: [phone]
REQUEST:
Provide copies of any and all training programs administered by or approved by Avista for
contractor employees.
RESPONSE:
The Company does not administer or approve training programs for contractor employees.
500869550 v'l
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 112812018
AVU-E-17-09 / AVU-G-I7-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Greg Hesler
Production Request DEPARTMENT: Supply Chain
WNIDCL-034 (AVA) TELEPHONE: (s09) 495-2208
REQUEST:
Detail annual amounts spent on training for contractor employees from 2010 to present.
RESPONSE:
Please see Avista's response to WNIDCL*PR_033(AVA).
500869550 v1
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED
AVU-E-17-09 / AVU-G-17-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNIDCL-035 (AVA) TELEPHONE:
U2812018
Mark Thies
Annette Brandon
State & Federal Regulation
(s09) 49s-4324
REQUEST:
Provide copies of all collective bargaining agreements, memoranda of understanding, or other
labor contracts that pertain to minimum standards that will be met for contract personnel to which
Avista or its Subsidiaries are signatories.
RESPONSE
Please see WNIDCL_PR_035(AVA) Attachment A for the contract between the Company and
Local Union 77.
Please see WNIDCL_PR_035(AVA) Attachment B for the contract between the Company and
Local Union 659.
Please see WNIDCL_PR_035(AVA) Attachment C for the contract between the Company and
Local Union 77 (Distribution Dispatchers and Gas Controllers).
500869550 v"l
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED
AVU-E-I7.09 I AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-036 (AVA) TELEPHONE:
U28t20r8
Mark Thies
Annette Brandon
State & Federal Regulation
(s09) 49s-4324
REQUEST:
Provide all Documents that any beneficiaries of Avista's $4,000,000 in annual charitable
contributions (funded by both Avista and the Avista Foundation) as stated in Appendix 8 to the
Application, that are engaged in workforce training.
RESPONSE:
The $4,000,0000 in annual charitable contributions (funded by Avista and the Avista Foundation)
as stated in Appendix 8 to the Application is a prospective number, with Avista sustaining that
level of community giving once the acquisition has been completed. WNIDCL_PR_036(AVA)
Attachment A outlines Avista's charitable contributions for 2015,2016 and through September of
2017.
500869550 v1
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED: I/28I2OI' BOiSE, IdAhO
AVU-E-I7-09 IAVU-G-17-05 WITNESS: Mark Thies
WNIDCL RESPONDER: Linda Gervais
Production Request DEPARTMENT: State & Federal Regulation
WNIDCL-O37 (AVA) TELEPHONE: [phone]s
REQUEST:
Provide any and all documents regarding Avista's existing levels of community involvement as
stated in Appendix 8 to the Application.
RESPONSE:
Avista is engaged in our communities in a number of different ways, and our vision for giving back
focuses on community investments that can be transformational and make a lasting impact.
Where there's a major event, it's almost a given that Avista will be there. Investments are also
made through the time, talent and treasure that Avista employees put into the organizations in the
towns they call home throughout our service area. We encourage our employees to engage in their
communities. Hundreds of our employees are in volunteer leadership roles across our service
territory, and we track community involvement as a corporate strategy. Below is a five-year
history of Avista employee volunteer hours.
2016 47,800
2015 48,500
2014 48,000
2014 46,500
2013 50,700
We strive to create economically vibrant communities for the benefit of our customers. We work
to achieve that objective through community support in the following areas:
I Corporate Philanthropy through both corporate support and through the Avista
Foundation;
r Economic Vitality through active involvement in organizations and causes that are
growing jobs and improving the quality of life in our region;
. Employee Volunteerism through corporate support of community events, as well as the
investment of time and talent by Avista employees;
. Sponsorships through the support of special events, community gatherings,
fundraisers, sporting events, and activities that strengthen and broaden the reach of
local organizations; and
r Energy Assistance through corporate and customer contributions primarily in support
of low income and senior customers, with the goal of reducing the burden of energy
costs for our most vulnerable customers.
For additional information regarding Avista's community partnerships, please see the Community
Partnership section starting on page 62 of WNIDCL_PR_037(AVA) Attachment A.
500869550 v1
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO DATE PREPARED:
AVU-E-I7-09 / AVU-G-I7-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNTDCL-O38 (AVA) TELEPHONE:
U2812018
Mark Thies
Linda Gervais
State & Federal Regulation
(soe) 49s-497s
REQUEST:
Provide any and all documents describing Avista's past practices concerning Economic
Development as stated in Appendix 8 to the Application.
RESPONSE:
Avista contributes to the growth of our communities and customers as a professional, stable and
supportive corporate partner. Economic development strategies are regionally specific and
targeted to provide the greatest sustainable economic lift in order to recruit, retain, and grow
businesses, jobs, wages, and populations.
We primarily do this in three ways:
. Initiate and drive;
' Participate and support; and. Facilitate and convene.
We fund and support economic development organizations that work to transform our
communities through job creation, community development, grant writing, and other strategic
initiatives. Additionally, through research, analysis, and community networking, we are leading
and/or partnering in "rising tide" initiatives and other strategic efforts that leverage opportunities
to build the community's capacity for sustainable and responsible growth.
500869550 v1
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 112812018
AVU-E-I7-09 IAVU-G-17-05 WITNESS: Mark ThiesWNIDCL RESPONDER: Joel Anderson
Production Request DEPARTMENT: State & Federal Regulation
WNIDCL-039 (AVA) TELEPHONE: [phone]
REQUEST:
Provide a list of all industry trade groups and membership organizations to which Avista has paid
dues within the last three years.
RESPONSE:
Please see WNIDCL_PR_039(AVA) Attachment A, for a listing of all "dues" payments made by
Avista between September 2014 and September 2017.
500869550 v'1
JURISDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-17-09 / AVU-G-17-05 WITNESS:WNIDCL RESPONDER:
Production Request DEPARTMENT:
WNIDCL-04O (AVA) TELEPHONE:
1128120r8
Mark Thies
Linda Gervais
State & Federal Regulation
(s09) 49s-497s
REQUEST:
With regard to Commitment (10), provide all Documents regarding the metrics used by Avista to
determine or assess whether its "staffing and presence in communities in which Avista operates" is
sufficient to maintain the provision of safe and reliable services and cost-effective operations.
RESPONSE:
The Company does not standardize its staffing and presence in communities in which we serve,
instead providing levels of support and staffing required by the individual circumstances of each
community. Avista has continued to align its natural gas operations with industry best practices.
In an effort to benchmark our practices with fellow gas distribution companies, we are active
participants in multiple industry organizations. Our most notable industry participation is through
involvement with the American Gas Association (AGA); the Western Energy Institute (WEI); and
the Gas Technology Institute, Operations Technology Development section (GTI-OTD).
Furthermore, we meet bi-annually with our fellow western natural gas distribution companies
(Southwest Gas Co., NW Natural Gas Co., Cascade Natural Gas Co., Questar, and Intermountain
Gas Co.). Each of these meetings lasts for two days at the host utilities' headquarters, and we
discuss relevant agenda items that we each have submitted. The matters routinely discussed
involve how to implement new code requirements, how to enhance construction practices, and
how to improve customer satisfaction/experience.
500869550 v1