20171129ICNU Sixth Set of Data Requests to Hydro One.pdf

TEL [phone] ● FAX [phone] ● [e-mail] Suite 400 333 SW Taylor
Portland, OR 97204
November 17, 2017 Via Electronic Mail
James Scarlett S. Kyle Mersky Hydro One Limited PO Box 3727 1411 E. Mission Ave, MSC-27
Spokane, WA 99220-3727 [e-mail] [e-mail]
Re: WUTC v. Avista Corporation Docket U-170970 Ladies and Gentlemen:
Enclosed please find the Industrial Customers of Northwest Utilities’ (“ICNU”) Sixth Set of Data Requests to Hydro One Limited (“Hydro One”) in the above-referenced matter. Hydro One has ten business days to respond to these Data Requests. Please provide your responses by no later than December 4, 2017.

Thank you for your attention to this matter. If you have any questions, please do not hesitate to call. Sincerely,

/s/ Haley M. Thomas Haley M. Thomas
cc: U-170970 Service List

Kari Vander Stoep, Partner Dirk Middents, Paralegal K&L Gates LLP 925 Fourth Ave, Suite 2900
Seattle WA 98104-1158 [e-mail] [e-mail]
PAGE 1 – ICNU’S SIXTH SET OF DATA REQUESTS TO HYDRO ONE
DAVISON VAN CLEVE, P.C. 333 S.W. Taylor, Suite 400 Portland, OR 97204 Telephone: [phone]
BEFORE WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION
WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION,
Complainant,

IES,
Respondent.

STRIAL
SIXTH SET OF
HYDRO

Dated: November 17, 2017
Please provide responses to these Data Requests by December 4, 2017. DATA REQUESTS
00100 What does Hydro One understand to be:
a. The relevant or applicable legal price floor, to prevent cross-subsidization from a US company to a Canadian company?
b. The relevant or applicable legal definition of a cross-subsidy from a US company to a Canadian company?
00101 Does Hydro One envision that any of Hydro One’s Canadian affiliates could purchase,
either directly from Avista, or indirectly through a US affiliate of Avista, services or intellectual property from Avista?