20180316AVU to Staff 10-16.pdf

Avista Corp.
1411 East Mission P.O. Box3727
Spokane. Washington 99220-0500
Telephone [phone]
TollFree 800-727-9170
ldaho Public Utilities Commissionon't*t.ott!t,?e;t3n"
MAR I 6 20t8
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March 16,2018 Boise, idaho
Idaho Public Utilities Commission
472W. Washington St.
Boise, ID 83702-0074
Attn: Brandon Karpen
Deputy Attomey General
Re: Production Request of the Commission Staff in Case No. AVU-E-17-09/AVU-G-17-05
Dear Mr. Karpen,
Enclosed are Avista's responses to IPUC Staffs production requests in the above referenced
docket. Included in this mailing are the original and two poper copies of Avista's responses to
production requests: Staff 010(AVA) - 016(AVA). Also enclosed on three separate CD's are
copies of Avista's responses to the production requests. The electronic versions of the responses
were emailed on 3116118.
Enclosed please find the following HIGHLY CONFIDENTIAL ("HC") responses from Avista:
. Staff PR_014(HC)(AVA)
Please handle these materials in conformance with the Protective Agreement's "Highly
Confidential Provisions" and "Confidential Provisions" associated with the above-referenced
docket.
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'oexpect," "anticipate," "intend," "attempt,"
"may," "planr" t'will," "canr" "believe," "seek," "estimater" 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 informatior/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 enclosed information, please contact Paul Kimball at (509)
495-4584 or via e-mail at [e-mail]
t
Avista Corp.
1411 East Mission P.O.Box3727
Spokane. Washington 99220-0500
Telephone [phone]TollFree 800-727-9170
)4>-
Paul Kimball
Regulatory Analyst
Enclosures
CC (Email):
Ccs (w/encls.)
Daniella Franco-Malone, Esq.
Schwerin Campbell Barnard Iglitzin & Lavitt LLP
l8 West Mercer Street, Suite 400
Seaettle, WA 981 19-3971
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., #207
Sandpoint, ID 83864
Benjamin Otto
Energy Associate
Idaho Conservation League
710 N.6th Street
Boise, ID 83702
David Wren
Nathan Smith
C learwater Paper Corporation
803 MillRoad
Lewiston, ID 83501
#nnsrfr
cwp,
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)
Avista Corp.
1411 East Mission P.O.Box3727
Spokane. Washington 99220-0500
Telephone [phone]
TollFree 800-727-9170
Jay Backus
Clearwater Paper Corporation
601 W. Riverside Avenue, #l100
Spokane, WA9920l
Don Reading
Ben Johnson Associates
6070 W HillRoad
Boise, ID 83703
(representing Clearwater Paper Corporation)
Marvin A, Lewallen
M. A. Lewallen & Associates, LLC
7408 SW Mapleleaf Street
Portland, OP.97223
#nnsrt
cwp.
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: February 23,2018
AVU-E-I7-09 IAVU-G-17-05 WITNESS: Chris Lopez (Hl)IPUC RESPONDER: Adele Pantusa (Hl)
Production Request DEPARTMENT: LawStaff-010(AVA) TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Please provide a listing and description of the planned post-merger processes of determining the
prudency of allocating services or costs from Hydro One to Avista. Please provide a description the
protections provided to Avista ratepayers for international costs, including but not exclusive to:
A. Accounting differences between IFRS and US GAAP
B. Exchange rate fluctuations
RESPONSE:
As discussed in Mr. Ehrbar's testimony, as well as in the Joint Application, to the extent Avista
employees dedicate time and incur costs related to the operations of Hydro One, such costs would be
directly assigned and billed to Hydro One, and would not be borne by Avista's customers. Likewise,
should Hydro One employees dedicate time and incur costs associated with Avista's operations, such
costs would be directly assigned and billed to Avista and would be subject to review and approval by the
Commission prior to being recovered in retail rates. All transactions with Hydro One will follow the
"Protocol for Direct Assignment of Costs between Avista and Hydro One" as noted in Paragraphs 76
and 77 in the Joint Application, as well as pages 16-19 of Mr. Ehrbar's testimony. As described in
Paragraphs 76 and 77, the Company provided a memorandum in Appendix 7 to the Joint Application
that further describes the Direct Assignment Protocol.
Hydro One follows USGAAP and therefore, there will be no impact to Avista post-merger from any
accounting differences between IFRS and USGAAP. As the memorandum in Appendix 7 to the Joint
Application indicates, the assignment of costs between Avista and Hydro One is expected to be
relatively small and therefore there will not be a significant post-merger exposure to exchange rate
fluctuations.
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JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO,:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 0212812018
AVU-E-17-09 / AVU-G-17-05 WITNESS: Kevin ChristieIPUC RESPONDER: Pat Lynch
Production Request DEPARTMENT: Customer Solutions
Staff-0lI (AVA) TELEPHONE: [phone]
REQUEST:
Please provide the amount and percentage of funds spent by the Avista Foundation on projects
that benefit ratepayers in each of the Company's jurisdictions for 201 5-2017 .
RESPONSE:
Year WA ID OR MT AK
2015 s4r0,228 73.8%$ 105,750 19.0%$29,900 5.4%$6,390 1.1%$3,750 0.7%
2016 $468,867 72.704 $ I 15,551 17.9%$37,350 s.8%$10,200 1.6%$12,625 2.0%
2017 $664,072 81.3%$ 103,363 12.7%$36,150 4.4%$6,300 0.8%$6,900 0.8%
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION: IDAHO DATE PREPARED: 0212812018
CASE NO: AVU-E-I7-09 / AVU-G-17-05 WITNESS: Kevin Christie
REQUESTER: IPUC RESPONDER: Pat LynchTYPE: Production Request DEPARTMENT: Customer Solutions
REQUEST NO.: Staff-012(AVA) TELEPHONE: [phone]
REQUEST:
Please provide the amount of below the line contributions/donations that Avista has contributed
to organizations in each of the Company's jurisdictions for 2015-2017.
RESPONSE:
Year WA ID OR MT AK
2015 $2,168,046 $329,263 $ 1 40,1 50 $9,717 $ 15,750
2016 $ 1,783,898 $243,065 $88,523 $6,890 $37,098
2017 $ I ,610,609 $190,122 $ I 07,859 $6,659 $35,250
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-I7-09 / AVU-G.I7-05 WITNESS:IPUC RESPONDER:
Production Request DEPARTMENT:Staff-013(AVA) TELEPHONE:
312120t8
Mark Thies
Bruce Howard
Environmental
(s09) 49s-294t
REQUEST:
Does Avista plan to adopt Hydro One environmental and sustainability policies? Please explain.
RESPONSE:
Avista has established its own policies, procedures and practices relative to environmental matters
and sustainability. These are based on the generation and operations resources for which the
Company is responsible and the regulatory (local, state and federal) context in which we operate,
as well as evolving best management practices that are relevant to our business. Avista regularly
evaluates its environmental and sustainability policies and practices, and will continue to do so
post-merger. Avista has no plan to adopt Hydro One's existing policies.
JUzuSDICTION
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RE,SPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED:
AVU.E- 1 7-09/AVU-G-17 -05 WITNESS :IPUC RESPONDER:
Production Request DEPARTMENT:
Staff-014(AVA) TELEPHONE:
EMAIL:
February 26,2018
Ferio Pugliese
Adele Pantusa
Law
4t6.345.6310
apantusa@hydroone. com
REQUEST:
As a company that previously divested from coal-fired generation, what is Hydro One's plan regarding
Avista's ownership of Colstrip? Please provide all documents and describe all discussions between
Avista and Hydro One related to the continued operation, investment, or closure of Colstrip.
RESPONSE:
As explained in the Joint Application and Master List of Commitments, Avista will continue to operate
as a standalone utility and establish the plan for the operation of the business post-merger, including
with respect to plans regarding Avista's ownership of Colstrip. All discussions between Avista and
Hydro One related to the continued operation, investment, or closure of Colstrip are attorney-client
privileged and protected by the parties' common interest agreement or are subject to settlement
negotiation protections.
Attached are all documents between Avista and Hydro One related to continued operation, investment,
or closure of Colstrip that are not subject to attorney-client privilege or settlement negotiation
protections:
o Staft_PR_014(HC)(AVA) Highly Confidential Attachment A
o StafLPR_O14(HCXAVA) Highly Confidential Attachment B
. SIaLPR_O14(HC)(AVA) Highly Confidential Auachment C
o SIafLPR_014(HCXAVA) Highly Confidential Attachment D
o StafLPR_014(HCXAVA) Highly Confidential Attachment E
o StafLPR_O14(HCXAVA) Highly Confidential Attachment F
o StaLPR_014(HCXAVA) Highly Confidential Attachment G
. StaLPR_014(HCXAVA) Highly Confidential Attachment H
o StafLPR_014(HCXAVA) Highly Confidential Attachment I
o StafLPR_014(HCXAVA) Highly Confidential Attachment J
o StaLPR_014(HCXAVA) Highly Confidential Attachment K
. Staft_PR_014(HCXAVA) Highly Confidential Attachment L
o Staft_PR_O14(HC)(AVA) Highly Confidential Attachment M
o StafLPR_014(HC)(AVA) Highly Confidential Attachment N
o StafLPR_014(HCXAVA) Highly Confidential Attachment O
. StafLPR OI4(HCXAVA) Highly Confidential Attachment P
Page I of2
o SIafLPR_014(AVA) Attachment Q
. staff_PR_014(AVA) Attachment R
o Staff_PR_014(AVA) Attachment S
o Staff_PR_014(AVA) Attachment T
As a point of clarification, Hydro One did not divest from coal-fired generation. Ontario Power
Generation, which along with Hydro One was part of Ontario Hydro prior to 1999, did divest from
coal-fired generation, but this occurred after Hydro One and Ontario Power Generation split into
separate entities.
Page 2 of 2
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED
AVU-E-1 7-09IAVU-G- I 7-05 WITNESS:IPUC RESPONDER:
Production Request DEPARTMENT:Staff-0l5(AVA) TELEPHONE:
EMAIL:
February 26,2018
Mayo Schmidt
Adele Pantusa
Law
416.345.63r0
apantusa@hydroone. com
REQUEST:
Please explain how acquiring Avista, which owns a coal-fired generation plant, might impact the Hydro
One designation as a Canadian Sustainable Energy Company. For example, does Hydro One need to
pursue an exemption or any legal action in order to maintain that designation? If so, will those costs be
directly assigned to Hydro One?
RESPONSE:
Hydro One Networks Inc.'s (HOND designation as a Canadian Sustainable Energy Company will not be
impacted by the Avista purchase. HONI's operations will continue in such manner so as to sustain this
designation. HONI is an indirect, wholly-owned subsidiary of Hydro One Limited, and post-merger
HONI will continue to be an entity separate and apart from Avista. Upon closing of the merger, Avista
will continue its operations as it does today and it will be an indirect, wholly owned subsidiary of Hydro
One Limited.
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JUzuSDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED: 0310812018
AVU-E-I7-09 / AVU-G-I7-05 WITNESS: Mark ThiesIPUC RESPONDER: Paul Kimball
Production Request DEPARTMENT: State & Federal RegulationStaff-016(AVA) TELEPHONE: [phone]s84
REQUEST:
Please provide the Avista and Hydro One definition of "Pacific Northwest" as it relates to the residency of
Avista's Board of Directors. Morris Direct at 3 I .
RESPONSE:
See Commitment 3 in Appendix 8 to the Joint Application. The term "Pacific Northwest region" means
the Pacific Northwest states in which Avista serves retail electric or natural gas customers, currently
Alaska, Idaho, Montana, Oregon and Washington.
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