20181031Avista to Staff 1-4.pdf

Avista Corp.
1411 East Mission P.O. Box3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
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Corp,
October 31, 2018
Idaho Public Utilities Commission
472W. Washington St.
Boise, ID 83720-0074
Attn: Ed Jewell
Deputy Auorney General
Re: Production Request of Commission Staff in Case No. AVU-E-18-09
Dear Mr. Jewell,
Enclosed is Avista's response to IPUC Staffs production request in the above referenced
dockets. Included in this mailing are the original and two paper copies of Avista's response to
production request: Staff I - 4. Also enclosed on CD are copies of Avista's response to the
production request. The electronic version of the response was emailed on 10/31/18.
If there are any questions regarding the enclosed information, please contact Paul Kimball at
[phone] or via e-mail at [e-mail]
S
Paul Kimball
Mgr. Compliance & Discovery
Enclosures
AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-18-09
Staff
Production Request
Staff-01
DATE PREPARED: 1012512018WITNESS: N/A
RESPONDER: Jeff Schlect
DEPARTMENT: Transmission ServicesTELEPHONE: [phone]
REQUEST:
Please provide a scaled drawing of the area containing the assets to be transferred per the
Company's Application. Include in the drawing: all property lines, roadways, structures, and
significant electrical equipment being sold/purchased. Please title by name those assets which are
being sold/purchased.
RESPONSE:
Please see the following map file with four maps showing the I 15kV transmission facilities being
acquired from BPA:
StaflPR_0l Attachment A: BPA Asset Transfer - Maps
Sheet I - Overview
Sheet 2 - Four Lakes Substation ( I 15kV bus to be owned by Avista)
Sheet 3 - Four Lakes Tap point of interconnection with Shawnee-Sunset I 15kV Line
Sheet 4 - Four Lakes Tap point of interconnection with Sunset-Westside I l5kV Line
Additionally, please see the following one-line diagram drawings acquired from BPA which
provide additional detail regarding the specific types of facilities being acquired from BPA:
StafLPR_0I Attachment B - One Line - Cheney Tap
StafLPR_0l Attachment C - One Line - Four Lakes Tap
Please see the following file showing the Hatwai 230kV power circuit breaker line position
facilities transferred to BPA:
Staff PR 0l Attachment D - BPA One Line Hatwai
Page I of 1
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PATROL DIAGRAM WIRE & STRUCTURE
INFORMATION
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ACSR 267 KCM PARTRIDGEGWTNoSALUMOWELD
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E- 18-09
Staff
Production Request
Staff-02
DATE PREPARED: l0ll5l20l8WITNESS: N/A
RESPONDER: Jason Boni
DEPARTMENT: Utility Accounting
TELEPHONE: [phone]
REQUEST:
Please provide the original cost and remaining book value of all assets being transferred between
the Company and BPA.
RESPONSE:
The Company is providing an Excel spreadsheet that outlines the proposed accounting entries for
recording the transaction and provides the remaining book value of all assets being transferred
between the Company and BPA.
See Sta[PR_02 Attachment A - Accounting Entries for Avista-BPA Transaction.
Page I of 1
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-18-09
Staff
Production Request
Staff-03
DATE PREPARED: l0ll5l20l8WITNESS: N/A
RESPONDER: Jeff Schlect
DEPARTMENT: Transmission Services
TELEPHONE: (509) 49s-4851
REQUEST:
Please provide the Company's analysis showing how the asset transfer fulfills the requirements
stated within Idaho Code 6l-328:
a. That the transaction is consistent with the public interest;
b. That the cost of and rates for supplying service will not be increased by reason of such
transaction; and
c. That the applicant for such acquisition or transfer has the bona fide intent and financial
ability to operate and maintain said property in the public service.
RESPONSE:
The Company did not prepare a detailed, written analysis of the proposed transaction with respect
to the specific elements of Idaho Code 6l-328, but considered all pertinent aspects of the public
interest while negotiating the transaction with BPA.
(a) The transaction is consistent with the public interest because it:(i) Does not increase any costs associated with transmission rate base and decreases
transmission expenses, as outlined in the response to (b);(ii) Provides future options for the Company to support and enhance transmission system
reliability in the local area, as outlined in the response to (c); and(iii) Enhances the ability for both Avista and BPA to effectively comply with mandatory
federal reliability standards. The transaction eliminates a situation where a
transmission asset owned by one pafi (230kV power circuit breaker owned by
Avista) is located within the fenced substation boundary of another party (in BPA's
Hatwai 500/23OkV Substation). While Avista has all compliance responsibilities for
mandatory reliability standards for its asset, Avista was unable to perforrn or
document any such activities for this asset because it resided within BPA's secure
physical boundary. Avista had to rely upon BPA to both perform required
maintenance and document such required maintenance in such a way that Avista
could demonstrate its own compliance with mandatory standards. This situation had
become administratively burdensome for both Avista and BPA.
(b) The cost of, and rates for, providing either retail electric service under state jurisdiction or
transmission service under federal jurisdiction will not increase by reason of this
transaction. In fact, the Company expects the overall cost and rates for supplying retail
service will decrease as a result of this transaction.
With respect to assets, as outlined in the Company's response to StaflPR_04, there will be
no effective change to the Company's net transmission investment due to this transaction.
Page I of2
The net depreciated value of the transmission assets being acquired from BPA is $460,900
system. The net value of the transmission assets being transferred to BPA plus acquisition
adjustments is also $460,900. The composite depreciation rate to be applied to the
acquired assets is the same as what was applicable to the assets being transferred to BPA.
Accordingly, from the standpoint of asset rate base recovery, there will be no increase in
costs or retail rates due to this transaction.
With respect to annual transmission expenses, this transaction will result in a decrease in
costs. The Company was paying BPA $608 per month ($7,296 per year system) for
operations and maintenance charges associated with the Company's Hatwai 230kV power
circuit breaker located in BPA's Hatwai Substation. Following the transfer of this asset to
BPA, the Company is no longer paying this monthly charge to BPA.
(c) The Company owns, operates and maintains approximately 2250 miles of ll5kV and
230kV electric transmission facilities. The assets acquired from BPA consist of
approximately 15 miles of ll5kV transmission facilities that are electrically located
entirely within Avista's balancing area and are bounded entirely within Avista's 1l5kv
transmission system network west of Spokane - these BPA assets had been an isolated
pocket within the Avista system. The acquisition represents an increase of only 0.67% of
transmission mileage for which the Company will need to operate and maintain.
Additionally, the acquisition of BPA's lines and right of way could possibly provide future
transmission line routing options to support and enhance reliable transmission service to
both Avista and BPA loads in the area west of Spokane. Accordingly, the Company has
both the financial and operational capability to reliably operate and maintain the acquired
facilities in the public interest.
Page 2 of 2
AVISTA CORPORATION
RESPONSE TO REQIIEST FOR INFORMATION
JURISDICTION:
CASE NO:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-18-09
Staff
Production Request
Stafl04
DATE PREPARED: l0lt5l20l8WITNESS: N/A
RESPONDER: Jeff Schlect
DEPARTMENT: Transmission Services
TELEPHONE: [phone]
REQUEST:
Please describe how the disposition of the assets will be recorded for accounting purposes. Please
include applicable procedures and spreadsheets with formulas enabled.
RESPONSE:
The Company is providing an Excel spreadsheet outlining the proposed accounting entries for
recording the transaction in its response to Sta[PR_02. The Company is also providing a copy of
its Section 203 filing with the Federal Energy Regulatory Commission ("FERC") which also
outlines the transaction's disposition of assets for accounting purposes. See Section Y - Proposed
Accounting Entries in the Company's FERC filing.
See Staff PR_02 Attachment A - Accounting Entries for Avista-BPA Transaction and
Sta[PR_04 Attachment A - FERC Filing 20180831 - Section 203 Acquisition.
Page I of I
UNITED STATES OF AMERICA
BEF.'ORf, THE
FEDORAL ENERGY REGULATORY COMMISSION
Avista Corporation Docket Nos. EClS-
APPLTCATION TOR AUTHORJZATION PUR.SI.IANT TO
$ECTION 203 OT THE FEDERAL POWER ACT
Ilursuanl to section 203 of the Federal Power Act ("FPA"), l6 U,S.C. $ 824b. and
Part 33 of the regulations of the Federal fnergy Regulatory Commission ("'I{ERC'" or
"Commission"), l8 CFR Part 33, Avista Corpo:ation ("Avista") ("Applicant") hereby
submits this Application fot approval of the acquisition of eertain transmission facilities
Avista is acquiring from the Bonneville Power Administration ("BPA") as part of a
transaction under which Avista transferred certain facilities to BPA in exchange lbr thc
tbciliries that are the subject of this Applicatinn ("'liansaction").1
Pursuant to an agreement with BPA (attached hereto as Exhibit I), Avista
acquired certain tap lincs and easernents associated with those tap lines, which are
described in that agreement as the Four Lakes Tap Line and the Cheney Tap Line
("F'acilities"). Thc purchase price for the F'acilities was $0. As consideration for the
F'acilities, Avista transferred certain equipment to BPA pursunnt to a sepfiate'Iransftr of
Ownership Agreement, Contract No. l STX-I 6631.2 The Transaction is necessary to
' Avista has notificd FERC Staff that this liling is being made late duc to an inadwrtent oversight. Avista's
transt'er of certain facilities to BPA does not require prior autlrorization undcr section 203(aX I )(A) of the
FPAbecausethevalueofthosefacilitierislessthanSl0million. Seel6U.S.C.gE2ab(aXtXA):18
C.F.K 33.1(aXi).
? Concurrent with this tmnsaction, BPA is acquiring Avista's 230kV power circuit breaker and nppur?enant
equipment that is located within BPA's Hatwai 500/230kV Substation. As notcd above, Avista's transfcr
of rhis equipment to BPA does not require prior authorization under section 203(aXl XA) of the FPA
Page - I APPLICATION FOR AUTHORIZATION PURSUANT T0 SECTION 203
OF TI"I[ FEPERAI, POW-ER ACT
Staff_PR_o4 Attachment A Page 1 of 16
)
)
enable both parties to better cornply with mandatory reliability standards governing
maintenance of bulk electric system equipment. I'he "l'ransaction eliminates Avista's
ownership of an asset inside one of BPA's stations. thereby simpliling operation and
maintenance responsibilities.
As demonstrated herein, the Transaction satisfies the requirements of Section 203
of the FPA and Part 33 of the Commission's regulatioas because it is consistent with the
public interest, will not adversely aftbct competition, rates or regulation, and will not
re.sult in any cross-subsidization. pledge or encumbrBnee on behalf of an associate
company. As described herein and consistent with Commission precedent. the Applicant
rcquests that the Commission grant waivers of its Part 33 liling requirements to the extent
that informaticrn otherwise required to be filed is not necessary to determine that the
Transaction satis{ies the requirements of FPA Sestion 203.1
I. DESCRIPTION OF APPLICANT
Avista is a corporation created and organized under the laws of the State of
Washington with its pr:incipal oflce in Spokane, Washington. Avista is an investor-
owned utility engaged in the business of generatingo transmitting. and distributing electric
ptlwer to wholcsale and retail customers and transmitting electric pow€r on behalf of
third parties. Avista is authorized by the Commission to engage in sales of capacity and
because the value of such equipment is less than 810 million. .$ee l6 U.S.C. $ 8?4b(aXlXA): IE C.F.R.
33.l(aXi). Accordingly, Avista is not seeking approval of its transfer of equipment to BPA pursuant to the
Transfer of Owncrship Agreement Confact No. I 8'IX- l 6163 I .
3 See c.g,, lior'l Energ: & Gas ?'ransilitsion, lnc., 108 FERC { 62,148 (200,1); Northhroo* rV, }:, tIC. 130
FERC ,0 62.128 (2010); EBG Holtlings LLC',ll9 FERC T 62.172(2007): I{ACH Gen, LLC,I l3 FERC I
6l,l3E(2005): BostonGenerating LII',113 FERCtl6l,l09(2005): LoPolomaHoldingCo", LLC,ll?
FERC{61,052(2005); I.a*eRoadlltlding,Co., LL*l12 FERC{61,051 (?005}; seeal.soRevisedFiling
Requirements llnder Part ji qf'the Llommhsion's Regulations, FERC Slats. & Regs. n 3 l.l I I at 31.914-15
(2000) ("Order No. 642").
Page - 2 APPLICATION I'OR AUTHORIZA'IION PURSUAN'I TO SECTION 203
O} THE FEDERAI, POWER ACT
Staff_PR_o4 Attachment A Page 2 of 16
energy at cost-ba.eed and market -based rates.i Avisk also offers open-access
transmission services pursuant to its Commission-approved Open Access 'fransmission
Tariff. Avista is also engaged in the distribution of natural gas in certain portions of
$/ashington, Idaho, and 0regon.
II. DESCRIPTION OT TI{E TRANSACTION
The Facilities that Avista is acquiring are tap lines comprised of approximately 15
miles of BPA's I lskv transmission assets in the Airway lleights, Washington area. The
acquired assets currently reside within Avista's Balancing Authority Area, are physically
and electrically separate from BPA's main transmission network. and are entirely
surrounded by Avista's transmission system. "l'he acquired assets provide transmission
intcrconnection and load service to two of BPA's wholesale utility customers. Avista
provides Network lntegration Transmission Service to BPA for service to these two
wholesale utility customers. Ownership and mairtenance of equipment inside another
entityrs station has presented administrative burdens to both parties in their efforts to
comply with certain NERC standarrds. The Transaction will simpliff both parties' ability
to comply with mandatory NERC reliability standards goveming the operation and
maintenance of Bulk Electric System equipment.
ilI. STANDARI} T'OR APPROVAL
The Commission will approve a transaction under section 203 of the FPA, if the
proposed transaction is consistent with the puhlic interest. In evaluating consistency with
{ ,{vista (formerly known as The Washington Warer Power Company) wac first granted market-bascd rate
aurhority in an order issued trn Novernber 29, 1996 in Dochet No. ER97-?, The ll'ushington Wilt* Fower(ompany.77 FERC: I6l":33 (1996). On January 2J, 1999" Avisla filed a notice of succrssion, includirrg
succession with rcgard to The Washington Warer Power Company's rate schedules. in Docket No. ER99-
1435-000. In a leuer order issucd on February 24. 1099, the Commission accepted Avista's January 25,
1999 filing.
Page - 3 APPLICATION FOR AUTHORIZATION PURSUANT TO SECTION 203
OF THI] FHDERAI. POWER ACl'
Staff_PR_04 Attachment A Page 3 of 16
the public interest, the Commission hcuses on: (l ) the eflect on competition; (2) the
effect on rates; and (3) the effect on regulation.s In addition, Section 203(aXa) of the
F'PA requires the Commission to consider whether a proposed transaction will "result in
cross-subsidization of a non-utility associate company or the pledge or encumbrance of
utility asscts tbr the benefit of an associate company.*6 In its Supplemenlal Merger
Poliqt Statement. the Commission clarified the information required to demonstrate that a
transaction dcles not raise cros.s-subsidization coneerns and identified'safe harbors" or
classes of transactions that do not raise cross*subsidization concems.T
A. Thc Transuction is in the Public Interest
Section 203(aX4) ol'the FPA provides that the Cornmission "shall approve [a]
proposed disposition. consolidation, acquisition, or change in control. if it finds that the
proposed transacti<rn will bc consistent with the public interest, and will not result in
cross-subsidization of a non-utility associate company or the pledge or encumbrance of
utility assets lbr the benelit of an associate company.-s [n determining whether a
proposed transaction is in the public interest. the Commission considers whether it will
have an adversc eff'ect on competition, rates. or regulation.e As described below. the
Transaction satisfies the requirtments of FPA Section 203 and the Commission's
implementing regulations and is consistent with the Public Intercst.
t See Merger Policy Stutement.
n l6 U.s,C. s't 824b(axa).
1 FPA Ssctian 30 j Supplemental Poliq, Stutement, t20 FrRC 1[ 61,020. PP I I -26 (200?), reh'g ond
durilication clenied,lS2 trERC T 61,157 (2008) {"Supptemental Merger Follq' Stotemcnf').
* t6 u.s.c. $ s24b(oX,t).
'$ lnqutry Concerning the Commissittn's lvlerger Pollry l/nder the Feelerut Pawer Act: ttoliey. Srorcmenr,
Order No. 592, FERC Stats. & Regs. t[ 3 1 ,M4., at 30,l l l- 12 { 1 996} (" Merger Poliq' 31u1r**r,"r,
rccttnslderutittn denled, Order No. 592-A" 79 FERC ![ 6l J2l ( 199?).
Page - 4 APPLICATION FOR AUT'HORIZATION PURSUANT TO SECTION 203
OF TIIE FENERAI," POWER ACT
Staff_PR_o4 Attachment A page 4 of 16
B. The Proposed Trrnsactions Will Not Have Any Adverse Impact on
Competition in Wholesale Markets
Part 33 of the Commission's regulations provides that a Section 203 applicant
must file a horizontal competitive analysis screen "if, as a result of the proposed
tramaction. a single corporate entity obtains ownership or control over the generating
facilities of previously unat'filiated merging entities . . . ool0 and/or a vertical competitive
analysis "if. as a result of the proposed transaction, a single corporate entity has
ownership or control over one or more merging entities that provides inputs to electricity
products and one or more merging entities that provides electric gerreration products . . ,
."tl The Transactions do not involve a change of ownership or control of any generating
facilities or entities that provide electric generation products and, as such. do not require
horiz.ontal market power or vertical competitive analyses.12
The Commission has concluded that "anticompetitive ellbcts are unlikely to arise
with regard to . . . transactions that only involve the disposition of transmission
faoilities."l'! llhe only assets transferred in the Transaction are the transmission facitities
described in Exhibit L The'l'ransaction will not have any adverse impacts on
competition.
C" The Proposed Transaetions Will Not Have Any Adverse Impaet On
Avista's Rates
When considering the impact of a transaction on rates. the Commission looks
primarily at impacts on transmission rates and on rates for captive wholesale
ro tE c.F,R. 33.3(aXi).rrrBc.F.R.33.4(aXi)
rr See, eg., Unlon Elce- L'o, I 14 FERC n 61.254, at P 36 (2006); PSEG Waterford Energl', LLC.ll2
FERC'!i 6 1.308, at P l2 (2005): Exelon Corp.. I l2 FERC ti 6 1,0 I l. at P 198 (2005).
t3 Trans$cttom suhject to FPA Section -?0J, Order No. 669, $'ERC Sta&. & Regs. n I1.200, at P 190
(:005), ("Order No. 669"), on reh'g,, Order No. 669-A. FERC Stats. & Regs. .| 31,214, on reh'gg, Order No.
669-8, FERC Stats. & Regs. tl 31.235 (?006).
Page - 5 APPI.ICATION FOR AUTHORIZATION PURSLJANT TO SECTION 203
OF''t'}IE FEDERAL POWER ACT
Stafi_PR_04 Attachment A Page 5 of 16
rcquirements customers.l{ Tte Transaction will also have no adverse impact on Avista's
rates.
Avista does not propose to change rates for service as a result of the Transaction.
The Transaction does not raise the possibility of any rate increasss for existing cost,ba-ced
rvholesale power sales customers or transmission customen. The only potential impact
on rates is the recovery of costs and expenses nf any incremeltal operation and
maintenance ("O&M") performed by Avista on the subject facilities. Such incremental
cost and expense of O&M will be offset by reduced O&M as a result of the transfer of
certain facilities to BPA. Aecordingly, ey O,&M performed on the subject facilities will
have a de minimis effect on rates.
The Transactions also have no adverse effect on the rates for wholesale power
sales. Avista makes wholesale power sales pursuant to its Commission-accepted ma*et-
based rate taritl'. Jhe Commission has concluded that such market-based rate sales do
not raise any concerns about a transaction's possible adverse effects on rates.li
D. The Proposed Transactlons Will Have Not Hove Any Adverse Impact
On Regulation
The Transaction will also havc no adverse e{Iect on reguiation. The
Commission's regulatory jurisdiction over Avista and will contiuue atler the Transaction.
Avista will also continue to be subject to the jurisdiction of the state utility commissions
with regard to any retail ratepayers. Accordingly, there is no eftbct on either tbderal or
state regulatory authority.
tn Merg,er Poliq' Srarcmcnr at 10, l2l.tl()inergp'Carp",140 FERC r[ 61.180, arP 4l (201211"Ths Commission has prrviously stated *rat, when
therc are market-based ratca. the sffect on rstes is not of concern.'t) (citing Duquesne l.ight Haldings, lnr.,
I l7 FERC $ 61.326, at P 25 (2006)).
Page - 6 APPLICATION FOR AUTHORIZATION PURSUANT TO SECTION 203
OF THE FEDERAL POWER ACT
Staff_PR_o4 Attachment A Page 6 of 16
f,. The Proposed Trrnsaction Will Not Result in Cross{ubsidization or
the Pledge or Encumbrrnce of Utility Ascets
Pursuant to scction 203(aXa) of the FPA, the Commission considers whether a
proposed transactiort will result in a cross-subsidization of a non-utility associated
company by a utility company" or in a pledge or encumbrance of utility essets for the
bene{it of an associated company. In the F'PA Seclion 203 Supplemental Policy
Statement. the Cornmission explained that Section 203 applicants can "demonstrate that a
proposed transaction will not result in inappropriate cross-subsidization . . . either
thmugh meeting one of the safe harbor demonstrations [recognized in the Supplemental
Policy Statementl . . . or demonstrating that there are no poteutial cross-subsidy issues
associated with the proposed transaclions."I6
T'he Transaction involves only non-affiliates, and therefcrre falls within the
Commission's safe harbor "where a franchised public utility transacts only with
nonalliliated entities."lT lturther, the'liansaction does not involve the issuance ol'
securities or a pledge or encumbrance of utility assets for the benetit of an associate
company,
ry. INT'oRMATTON REQUTRED BY SACTION 33"2 Or THE
COMMISISON'S RECULATIONS AND REQUESTS FOR WAIVER
ln support of this Application, Applicant hereby submits the tbllowing
information required by Part 33 of the Commission's regulations.tfl To the extent that
ce(ain requcsted information is inapplicable to the Commission's consideration of
tb F'PA Sectictn 203 Supplemental Policy Stotemen , 120 FERC f 6 I ,060, at P 23 (2007).
t1 l:PA S€ctktn 103 Supplenental PolicT'Stutemenl,l2A FERC li at P 19 ("Where a franchised public utility
transasts onty with nonaffiliated entities, the potentiol for inappropriate cross-subsidiaation of a non-utility
associate company or the plcdgc or encumb(ancc of utility assets for the benefit of an associate company is
generally not prescnt. "llherefore, cornpliance rvilh Exhibit M could bc satisfied with n showing that a public
utility transacts only with nonafliliated cntities.").ri t8 c.F.R. S 33.2.
Page - 7 APPLICATION FOR AUTHORIZATION PURSUANT T0 SECTION 203
OF T}I[ FI]DIRAI- I'OWER ACT
Staff_PR_O4 Attachment A Page 7 of 16
'*,hether the Transaction is consistent with thc public interest, Applicant respectfully
requests that the Commission waive such information requirements as discussed below,
Thc Eract Namc and Address of the Applieant ond lts Principrl
Business Offiee * $ecfiou 33,2(a)
ll'he name and principal office of Avista are as follow's:
Avista Corporation
l4l I E. Mission Ave.
Spokane, WA 99202
Nrme and Address of the Person Authorized to Reccive Notices and
Communications with Reepect to the Application - $ectiou 33.2(b)
The following are authorized to receive notice and communications on behalf of
Avista:
A.
B"
Jeff Schlect
Senior Manager FLT.RC Policy and
Transmission Services
Avista Corporation
l.ll l U. Mission Ave."*MSC-I6
Spokane, WA 99202
i e fT. sch I ect(4av i stacom. c om
509495485r
Michael C. Andrea
Senior Counsel
Avista Corporation
l4l I E. Mission Ave.-MSCI-I7
Spokane. WA 99202
michael. andrea@avi stacorp.com
sag-495-2564
Applicant requests that thesc per$ons be placed upon the official service list compiled by
the Secretary of the Commission for this proceeding pursuant to l8 C.F.R. $ 385.2010.
C. All Business Activities of the Applicant, including authorizations by
charter or regulatorT approyal - Section 33.2(c[1)
The business activities of Applicant are described in Section III above.
Accordingly, Applicant requests a waiver of thc requiremcnt to file f;xhibit A.
D.A list of all enerry subsidiaries end energr affiliates, percentage
ownership interest in sueh subsidiaries and affiliates, and a
Page - 8 APPLICA'IION I]OR AUTHORIZATION PLJRSUANT TO SECTION 203
OF THE FEDERAL POWER AC]T
Staff-PR-o4 Attachment A Page 8 of 16
description of the primary business in which each energgr subsidiaty
rnd afriliate is engaged.
'fhe Transaction does not allbct any of Avista's affiliates. Because the
Transaction does not afl-ect any of its atliliates. Applicant respectfully requests waiver of
the requirement to file Exhibit I].
Organizational Charts Depicting the Applicant's Current and
Proposed Post-Transaction Corporate Structurrcs Indieating All
Prrent Companies, Energt Snbstdiffries and Energr Affiliates - f 8
C.F.R $ 33.2(cX3)
Applicant respectfully requcst$ waiver of the rtquirement that it submit
organizational charts depicting its corporate sffucture belore and after the Transactions
because the'fransactions do not affect its corporate structure.
Dcscriptions of All Joint Yentures, Stretegk Alliances, Tolling
Armngements or Other Business Arrangements, Includiug Transfers
of Operational Control of Trrnsmission l'rcilities to Commisrion
Approved Regional Trsnsmission Orgrnlzrtionen Both Currento rud
Plsnned to Occur lVithin a Year from the Date of S'iling, to Which the
Applicrnt or its Parent Companies, Energy Subsidiaries, end Enerry
Afriliates is a Parfy, Unless the Applicant Demonstrates that the
Proposed Trrnsaction Does not Affect Any of its Business Interests -r8 C.F.R $ 33J(c)(a)
The Transaction has no effect on any joint yentures, strategic alliances. or other
business arrangements of Applicant. Therefore, to the extent necessary, Applicant
requests waiver of the requirement to provide information in Exhibit D to this
Applieation.
Page - 9 APPLICATION FOR AUTHORIZATION PURSUANT TO SECTION 203
OF THE FHDERAI, POWER ACT
Staff_PR_o4 Attachment A Page 9 of 16
f,.
r
G. Thc ldentity of Common Olficers or l)irectors of Parties to the
Proposed Transaction - I8 C.f.R $ 33.2(cX5)
Applicant has no officers or directors in common with BPA, and none resulted
from rhe consummation of the Transaction. Therefbre, Applicant respectfully requests
waiver of the requirement to file Exhibit U.
H.Dccription and Location of Wholesale Power Sales Customers nnd
Unbundled Trensmission Serviees Customers Served by the Applicart
or its Parent Companies, Subsidieriee, Afriliates, and Associnte
Comprnies - l8 C.F.R. $ 33.2(cX6)
The Transaction will not alter any other existing wholesale power sales or
transmission services. Applicant requests waiver of the requirement to tile information in
Exhibit F.
A Description of Jurirdictional Fscilities Ownedo Operated, or
Controlled by the Applicant or its Parent Companies, Subsidiericsn
Afliliatcs, rnd A*rocieted Comprnies - l8 C.F.R. $ 33.2(d)
The jurisdictional thcilities acquired by Applicant in the I'ransaction are the
lhcilities identified in Exhibit I. Applicant requests rvaiver of the requirement to tile
additional information in Exhibit G.
A Narstiyc Description of thc Transaction for which Commi*gior
Authorization is Requested,Including: (t) the ldentity of All Parties
Involved in the Trrnsaefion; (2) AII Jurisdictional Fmilities and
Securities Associated With or Affected By the Trarsactior; (3) the
Comideration for the Transactlon; and (4) the Effect of the
Traneaction on Such Jurisdictionrl Facilities rnd Securities - I8
C.r.R $ 33.2(e)
T'he inlbrmation rcquested by Section 33.2(e) of'the Commission's regulations is
provided in Sections IY above and in Exhibit I. Therefore. Applicant requests waivet of
the requirement to file Exhibit H.
Page - l0 APPLTCATION fOR AL,TITORIZATION P{"JRS[JAN'[ T0 SECI'ION 203
OF TTIH FEDERAI, POWER AC'T
Stafi-PR-04 Attachment A Page 10 of 16
I.
,l
All Contmcts Relatsd to the Trrnsaction Together rtrith Copies of AII
Otber \ilritten Instrumeats Entered Into or Proposed to be Entered
Into by the Parties to the Trnnsaction - It C.F.R. $ 33.2(0
Applicant submits the contract regarding the Transaction in Exhibit I.
A Ststement Explaining the Flcts Relied Upon to Demonstrate thnt
fhc Transsction is Consistent with the Public Intcrest - lE C,F.R $
33.2(g)
lhe facts relied upon to demoustrate that the'I'ransaction ae consistent with the
public interest are described in Sections IV and V above. Therctbre, Applicant requests
wBivcr of the requirement to file Exhibit J.
M, A General or Key Map Showing the Properties of Each Party to the
Transaction - 18 C.F,R. $ 33.2(h)
'[he Transaction would not result in any new combination of market participants
and, therefore, a map would not convey any useful information regarding the proximity
of properties not previously under common control. 'fherefbre, Applicanl requests
waiver of the requirement to file Exhibit K.
N.Identify tbe Licenses, Ordors, or Other Approvrls Required Froxr
Other Regulatory Bodies in Connection with the Proposed
Tmnsaction, and the Status of Other Regulntory Actlons - l8 C.f.R. $
33.2(i)
Avista will make a filiag with the Washington Utilities and Transportation
Commission and the Idaho Public Utility Commission. No other approvals are required.
'l'heretbre, Applicant requests waiver of the requirement to file Exhibit L.
Page - I I APPLICATION FOR AUTHORIZATION PURSI"JANT TO SECTION 203
OF: THE FEDERAI, POWER ACT
staff-PR-O4 Attachment n Page 11 of '16
K,
L.
o.An Explanation, With Appropriate Evidentiary Support for Such
Explanationn of How the Proposed Trunsaction \{i$ Not Result in
Cross-$uhsidization of Non-Utility Assoeiate Company or the Pledge
or Encumbrrnce of Utilify Assets for the 3onefit of en Associate
Company - l8 C.F.R. $ 33.20)
As described above. the Transaction involves a conveyance and acceptance of
certain facilities between non-affiliated entities. The Transaction is among the class
of transactions which the Commission has recogniz.ed as turlikely to raise cross-
subsidization concerns and thus are within one of the Commission's "sat'e harbors."
Further, thc 'lransaction does not involve the issu,ance of any security or the pledge or
encumbrance of utility assets for the benetit of an associate company. Based on the
fbregoing. Applicant respectfully requests waiver of the requirement to lile Exhibit M.
Page - 12 APPLICATION FOR AUTHORIZATION PURSUANT T0 SECTION 203
OF'THE FEDERAI, POWIiR ACT
Staff_PR_04 Attachment A Page 12 of 16
Y. PROPOSED ACCOUNTING ENTRIES
In accordance with l8 C.f .R. $ 33.5. the proposed accounting entries for the
Transaction with sufficient detail to indicate the effects on all account balances are as
follows:
Jos.n6l Nunrb?r A(counl Numbs frthsof Arcentrtdlouffil lnlry Dct(ription
I xol Eh(t h n ,n kt Snicr
loi €hctrk Pl€rt Purdrnredor Sokl
tq{tgfint obts,'sd lfim a?A orfulnal &il.
z r0l EL(*PLntinsrfncc
lO2 Ehcttk Planl PuEh6sdor Sold
tareilrnls &l,.itLal fto.^ nPA
3 ro2 Ele($kPlamFurctl.rldot5aH
m Arcuwl.tld Pmvirion fo, D.prect}tion
ktarulored Acorcaldtwt dt BPA rqut,,ne fia
g"bi! _ sr!!!!
77W42.@
7n,782-00
18s,o(n.00
r85,000.00
501,882.00
501,887^00
859,361.47
859.361.47
114,t41,54
l12.!4l.tt
l8sJ19.S3
285jr9.93
i?cord frrnr{sr o{ AYln ,5!6tt to IPA
itrdd Cb.rht tnldE
4 102 fhrtrkFlrrtpunh.sedorsold
101 EhcEkPLrnhService
Equirtrcn Vp/tEfarltd @ aPA o,i9tul cast
5 108 Arcun etedProvkionlorDaplaclaton
loil thclrk PLnt PurEhared or Sold
Aeufrulow OegQdotanlat Equlpttz,t{ot rloftert @ ,.pA
5 ll4 EhctrkPLntAcqslltionAdprrnlnnr
l(n thctrlc Plr0t PurqbldorSold
aeadng lha ,02 ocr,,wt olter lhe t,?,Il[lrt ol ,ropany
YtrRIFICATION
Attached hereto as Attachment I is the signed verification required by l8 C.p.R. $
33.7,
Page - l3 APPLICATION FOR AUTHORIZATION PURSUANT TO SECTION 203
OIT TTIE THDERAT, POWNR AC'T
Staff_PR_O4 Attachment A Page 13 of 16
vI.
vII. CONCLUSION
WHEREFORE, tbr the foregoing reasons. the Applicant respectfully requests that
the Commission consider this Application and issue an order granting the requested
waivers and authorizing the Transaction under section 203 of &e FPA.
Respcctfully submitted,
AVISTA CORPORA"I"ION
ls/ Michael G..*ndrea
Michael G. Andrea
Senior Counsel
Dated: August 31.2018
Page - 14 APPLICATION IOR AUTHORIZATION PLTRSIJANT TO SECTION 203
OF THE FEDERAI" POWfiR ACT
Staff-PR-04 Attachment A Page 14 of 16
ATTACHME1YT 1
Staff_PR_o4 Attachment A Page 15 of 16
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Avista Corporation Docket Nos. EClS-
Verification Pursuant to l8 C.f.R. $ 33.7
STATE OF WASHINGTON )
) ss.
County ot'Spokane )
The undersigned, being duly sworn. states that he is the authorized
representative of Avista (lorporation, that he has read the lbregoing application and
knows the contents thereol and that all ot'the statements contained therein with respect
to Avista Corporation and its aifrliates are true and correct to the best of his knowledge,
infbrmation, and belief
)
)
l_UJ--
Deanis Vermillion
President Avista Corporation
SIGNED AND SWORN to beftrre me or tt i*.{}to,v of August. 2018
lrrL,Ut-Lw
a'
i;e i t
g0TAR),
Pugt-tc
NOTARY PLJBLIC in and for the Srate of
Washington. residing at Spokane.
Commission Expires: df-tt? -gCP {
Staff_PR_o4 Attachment A Page 16 of 16