20180124Avista to WNIDCL 1-25.pdf

K&L GATES
RECE IVED
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January 24,2018 Elizabeth Thomas
[e-mail]
T [phone]
F [phone]
Kari Vander Stoep
[e-mail].
T +'l 206 370 7804
F +'l 206 6237022
Via Electronic Mail
Ms. Daniella Franco-Malone, Esq.
Schwerin Campbell Barnard lglitzin & Lavitt LLP
18 West Mercer Street, Suite 400
Seattle, WA 98119-3971
Re:Hydro One Limited's Non-Confidentia! Responses to Data Requests of
Washington and Northern ldaho Qistrict Council of Laborers ("WN|DGL")
ldaho Public Utilities Commission, Docket AVU-E-I7-09 and AVU-G-17-05
Dear Ms. Franco-Malone:
Enclosed please find Hydro One Limited's non-confidential responses to WNIDCL data requests
1-25.
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 fonrvard-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," "attempt," "may," "plan," "will," "can," "believe," "seek," "estimate," 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.
Please let us know if you have any questions
K&L GATES LLP
925 FOURTH AVENUE SUITE 29OO SEATTLE WA 981 04.1 1 58
T [phone] F [phone] klgates.com
Very truly yours,
47rrr,'s/2
Elizabeth Thomas
KariVander Stoep
Attorneys for Hydro One Limited
Enclosures
Ccs (via email)
franco@workerlaw. com ;
Brandon. Karpen@puc. idaho.gov;
Camille.Ch risten@puc. idaho.gov;
[e-mail] ;
g reg @richardsonadams. com ;
[e-mail];
[e-mail] ;
botto @ id a h oco n servatio n . org ;
david.wren@clearwaterpaper,com ;
nathan.sm [e-mail] ;
jay. [e-mail] ;
dreading@mindspring. com ;
[e-mail];
[e-mail];
[e-mail];
ron@will iamsbrad bury.com ;
deanj miller@cableone. net;
[e-mail];
carol. haugen@dearwaterpaper. com ; and
joh n.jacobs@clearwaterpa per. com'
2
January 24,2018
HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION
CASE NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 002 (H1)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
REQUESTER:
TYPE:
REQUEST NO.:
REQUEST:
For each year during the period from2014 to the present, provide the amounts paid to each Construction
Contractor, and the scope of utility work performed by each.
RESPONSE:
WNIDCL PR 002 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 002 (Hl) seeks information regarding the amounts paid by
Hydro One to each Construction Contractor, and the scope of utility work performed by each. If the
merger is approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval), making its own decisions on contractor hiring. Avista operates an electric and gas utility in
Idaho, while Hydro One's electric transmission and distribution utility operations are located solely in
the Province of Ontario, and there is no relationship between Hydro One's use of third-party contractors
in Ontario and Avista's in Idaho.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO.: AVU-E-17-09/
AVU-G-17-05
REQUESTER: WNIDCLTYPE: Production Request
REQUEST NO.: WNIDCL - 001 (H1)
DATE PREPARED: January 18,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
For each year during the period from2014 to the present, provide the: (a) total amount expended by
Hydro One on construction labor; and (b) proportion of that total amount spent on Construction
Contractors or Contractor Personnel. Provide all supporting data (including worksheets).
RESPONSE:
WNIDCL PR 001 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 001 (Hl) seeks information regarding the amount of money
that Hydro One spends on construction labor and contractor labor and personnel. If the merger is
approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval), making its own decisions on contractor hiring. Avista operates an electric and gas utility in
Idaho, while Hydro One's electric transmission and distribution utility operations are located solely in
the Province of Ontario, and there is no relationship between Hydro One's use of third-party contractors
in Ontario and Avista's in Idaho.
Without waiving these objections, the following table illustrates the approximate annual gross
expenditures since 2014 on large (over $lM) transmission capital projects whereby Hydro One has
contracted a major portion of the Engineering, Procurement, and Construction (EPC) work.
EPC Contract Costs ($CDN)
2014 20ts 2016
$101M $100M $84M
Distribution projects have not yet been contracted out for EPC work, and as such, the above information
is not available for said projects.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 003(Hl)
DATE PREPARED: January 19, 2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
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:
WNIDCL PR 003 (H1) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 003 (Hl) seeks information regarding each capital
investment Hydro One projects to be undertaken during the period 2018-2021. If the merger is
approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval), making its own decisions on contractor hiring. Avista operates an electric and gas utility in
Idaho, while Hydro One's electric transmission and distribution utility operations are located solely in
the Province of Ontario, and there is no relationship between Hydro One's use of third-party contractors
in Ontario and Avista's in Idaho.
Please see response to WNIDCL_PR_003(HCXHI).
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION: IDAHO
CASE NO.: AVU-E-I7-09/
AVU-G-17-05
REQUESTER: WNIDCLTYPE: Production Request
REQUEST NO.: WNIDCL - 004 (Hl)
DATE PREPARED: January 19,2018
WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
REQUEST:
Provide all Documents, whether prepared by or for Hydro One, 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:
Hydro One does not currently have plans for system or process changes related to contracting out
construction work post-merger.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 00s (Hl)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Provide all documents, whether prepared by or for Hydro One, including those received from Avista,
that detail any post-merger employment goals, commitments, or understanding that concern or relate to
Contractor Personnel.
RESPONSE:
Generally, Hydro One engages contractors based on need, and our contracting processes do not focus on
creating contractor positions. Furthermore, Hydro One and Avista do not have any documents that
detail any post-merger employment goals, commitments, or understanding that concern or relate to
Contractor Personnel.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO.: AVU-E-I7-09/
AVU-G-17-05
REQUESTER: WNIDCLTYPE: Production Request
REQUEST NO.: WNIDCL - 006 (H1)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
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:
WNIDCL PR 006 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 006 (H1) seeks information regarding Hydro One's plans to
recruit additional direct employees or contractor personnel necessary to sufficiently staff future capital
investments. If the merger is approved, Avista will continue as a stand-alone utility (as set forth in the
application for IPUC approval), making its own decisions on contractor hiring. Avista operates an
electric and gas utility in Idaho, while Hydro One's electric transmission and distribution utility
operations are located solely in the Province of Ontario, and there is no relationship between Hydro
One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, Hydro One notes that it engages contractors based on need, and our
contracting processes do not focus on creating contractor positions.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 007 (H1)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Provide all Documents that state or detail contractor or procurement goals as they relate to Woman
Business Enterprises and Minority Business Enterprises.
RESPONSE:
WNIDCL PR 007 (H1) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 007 (H1) seeks information regarding Hydro One's
contractor or procurement goals as they relate to Woman Business Enterprises and Minority Business
Enterprises. If the merger is approved, Avista will continue as a stand-alone utility (as set forth in the
application for IPUC approval), making its own decisions on contractor hiring. Avista operates an
electric and gas utility in Idaho, while Hydro One's electric transmission and distribution utility
operations are located solely in the Province of Ontario, and there is no relationship between Hydro
One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, Hydro One does not have procurement goals as it relates to Woman
Business Enterprises. With regards to the Minority Business Enterprises, Hydro One is committed to
ensure business opportunities exist for Indigenous Businesses.
Hydro One's primary goal for Indigenous procurement, for 2017 through2}l9,is2|Yo spend increases
year-over-year and 2.1%o of annual procurement spend. Hydro One was awarded the Canadian Council
for Aboriginal Business (CCAB) Bronze certificationfor 2017.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION:
CASE NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 008 (Hl)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
REQUESTER:
TYPE:
REQUEST NO
REQUEST:
Provide any Document, including analyses, data, reports, or surveys used to determine projected
contract labor expenditures.
RESPONSE:
WNIDCL PR 008 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 008 (Hl) seeks information regarding Hydro One's
analyses, data, reports, or surveys used to determine projected contract labor expenditures. If the merger
is approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval), making its own decisions on contractor hiring. Avista operates an electric and gas utility in
Idaho, while Hydro One's electric transmission and distribution utility operations are located solely in
the Province of Ontario, and there is no relationship between Hydro One's use of third-party contractors
in Ontario and Avista's in Idaho.
Without waiving these objections, Hydro One engages contractors based on need, and our contracting
processes do not focus on creating contractor positions.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 009 (Hl)
DATE PREPARED: January 19,2018
WITNESS: Mayo Schmidt
RESPONDER: Adele Pantusa
DEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
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:
WNIDCL PR 009 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 009 (Hl) seeks information regarding Hydro One's last five
most recent contract awards for the provision of traff,rc control services including the Requests 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. If the merger is approved,
Avista will continue as a stand-alone utility (as set forth in the application for IPUC approval), making
its own decisions on contractor hiring. Avista operates an electric and gas utility in Idaho, while Hydro
One's electric transmission and distribution utility operations are located solely in the Province of
Ontario, and there is no relationship between Hydro One's use of third-party contractors in Ontario and
Avista's in Idaho.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 010 (Hl)
DATE PREPARED: January 19,2018
WITNESS: Mayo Schmidt
RESPONDER: Adele Pantusa
DEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
REQUEST:
Provide copies of any and all current Master Service Agreements (MSAs) between Hydro One 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.
RESPONSE:
WNIDCL PR 010 (Hl) is overly broad, unduly burdensome, and will'not lead to the production of
admissible evidence because WNIDCL PR 010 (Hl) seeks information regarding Hydro One's Master
Service Agreements (MSAs) between Hydro One and any Contractor, and a schedule of when these
MSAs will expire, and the timeline in each instance (if any) for securing new MSA contracts. If the
merger is approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval), making its own decisions on contractor hiring. Avista operates an electric and gas utility in
Idaho, while Hydro One's electric transmission and distribution utility operations are located solely in
the Province of Ontario, and there is no relationship between Hydro One's use of third-party contractors
in Ontario and Avista's in Idaho.
Without waiving these objections, please refer to WNIDCL_PR_010(H1) Attachment A for a copy of
Hydro One's contract standard for construction services.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G- 17-05
WNIDCL
Production Request
WNTDCL - 011 (Hl)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
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:
WNIDCL PR 011 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 011 (H1) seeks information regarding Hydro One's third
party damage reports generated from2014 to current, and any reports or root cause analyses performed
on third party damages. If the merger is approved, Avista will continue as a stand-alone utility (as set
forth in the application for IPUC approval), making its own decisions on contractor hiring. Avista
operates an electric and gas utility in Idaho, while Hydro One's electric transmission and distribution
utility operations are located solely in the Province of Ontario, and there is no relationship between
Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Withoutwaivingtheseobjections,fortheperiod2014toJanuary l9,20lS,therearenoclaimsof$lMor
greater for damages to the property of Hydro One Networks Inc. arising from the actions of a third party,
including from Hydro One's contractors.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 0r2 (H1)
DATE PREPARED: January 19, 2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Provide all Documents that detail the prequalification process by which outside Construction
Contractors are selected to bid on capital or maintenance projects.
RESPONSE:
WNIDCL PR 012 (H1) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 012 (H1) seeks information regarding Hydro One's
Documents that detail the prequalification process by which outside Construction Contractors are
selected to bid on capital or maintenance projects. If the merger is approved, Avista will continue as a
stand-alone utility (as set forth in the application for IPUC approval), making its own decisions on
contractor hiring. Avista operates an electric and gas utility in Idaho, while Hydro One's electric
transmission and distribution utility operations are located solely in the Province of Ontario, and there is
no relationship between Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, Hydro One does not have a prequalification process to identify or
select vendors to bid, Qualifications are reviewed and validated through the competitive bidding
process.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 013(Hl)
DATE PREPARED: January 19, 2018
WITNESS: Mayo Schmidt
RESPONDER: Adele Pantusa
DEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
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:
WNIDCL PR 013 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 013 (Hl) seeks information regarding Hydro One's
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. If the
merger is approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval), making its own decisions on contractor hiring. Avista operates an electric and gas utility in
Idaho, while Hydro One's electric transmission and distribution utility operations are located solely in
the Province of Ontario, and there is no relationship between Hydro One's use of third-party contractors
in Ontario and Avista's in Idaho.
Please response to WNIDCL_PR_O13(HCXHI) and Highly Confidential Attachment A.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JUzuSDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 014 (Hl)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
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. 12.
RESPONSE:
WNIDCL PR 014 (H1) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 014 (Hl) seeks Hydro One's list of Contractors that have
met the prequalification standards for construction and maintenance projects described in the response
to Production Request No. 12. If the merger is approved, Avista will continue as a stand-alone utility (as
set forth in the application for IPUC approval), making its own decisions on contractor hiring. Avista
operates an electric and gas utility in Idaho, while Hydro One's electric transmission and distribution
utility operations are located solely in the Province of Ontario, and there is no relationship between
Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, please see Hydro One's response to WNIDCL PR 12(H1).
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 0ls (Hl)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Provide all Documents prepared by or for Hydro One which state or describe policies, procedures or
guidelines that concern or relate to sub-contracted out services.
RESPONSE:
WNIDCL PR 015 (H1) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 015 (Hl) seeks Hydro One's Documents prepared by or for
Hydro One which state or describe policies, procedures or guidelines that concern or relate to
sub-contracted out services. If the merger is approved, Avista will continue as a stand-alone utility (as
set forth in the application for IPUC approval), making its own decisions on contractor hiring. Avista
operates an electric and gas utility in Idaho, while Hydro One's electric transmission and distribution
utility operations are located solely in the Province of Ontario, and there is no relationship between
Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, Hydro One does not have any guidelines or policies in relation to the
use of contracted out workforce. Any requirements for the use of subcontractors by a contractor would
be specified in the relevant agreement with the contractor.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G- l7-05
WNIDCL
Production Request
WNTDCL - 016 (H1)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele Pantusa
DEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
REQUEST:
Identify and describe in detail all workforce safety, health, or environmental metrics employed by Hydro
One to measure Contractor performance. For the period 2014 until the present, provide all Documents,
including reports, analyses or studies, prepared by or for Hydro One that contain or evaluate Contractor
performance (whether using these metrics or other performance measures).
RESPONSE:
WNIDCL PR 016 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 016 (H1) seeks the workforce safety, health, or
environmental metrics employed by Hydro One to measure Contractor performance and all Documents
since 2014, including reports, analyses or studies, prepared by or for Hydro One that contain or evaluate
Contractor performance (whether using these metrics or other performance measures). If the merger is
approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval), making its own decisions on contractor hiring. Avista operates an electric and gas utility in
Idaho, while Hydro One's electric transmission and distribution utility operations are located solely in
the Province of Ontario, and there is no relationship between Hydro One's use of third-party contractors
in Ontario and Avista's in Idaho.
Without waiving these objections, the following workforce safety, health and/or environmentalmetrics are
used by Hydro One to measure contractor performance for major contracts (with a contract value of $25K
and above):o Does the contractor utilize an environmental screening criteria when hiring subcontractors and
monitor performanceo Has the contractor been convicted of any regulatory offenses in the last three (3) years and if so,
disclosure of corrective actions. Does the contractor maintain a written Environmental Policy and has the contractor established best
practices for the protection of the environmento Does the contractor provide specialized training to adequately prepare workers to handle the
environmental risks associated with their worko Contractor maintains all environmental compliance approvals required to complete work
During a contractor's performance of work, Hydro One monitors its environmental performa& in the
following areas:o Emergency and spill response management. Chemical storageo Waste Managemento Pesticide useo Environmentalprotection
Page I of2
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For our major facilities management contract:
. We have Critical Service Levels that are tracked/reviewed on a monthly basis during our Line of
Business meetings with the contractor. These are the health, safety, and environment related
categories:o Lost Time injuries. Medical attentionso MinistryNotices/orders. Environmental Spills
For incentive payments (or reductions), we use the following metrics for performance assessment:o Completion of 100% Orientation of Staff and Vendors and corporate required core training. Timeliness of incident reporting
. Number of reported health and safety incidentso HONI Policies and Procedures not adhered to
a
For major construction projects:o As per the contractual terms and conditions, our contractors are required to report to us on the
following incidents: Fatality; Critical Injury; Medical Attention Injury; Lost Time Injury; Illness;
Fire or Explosion; Ministry of Labour Orders or Charges; Work Stoppage or Refusal; Significant
Environment Spill. These incidents are tracked and utilized to monitor performance.o We also utilize 3'd party Site Inspectors who monitor contractor performance.
HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 017 (Hl)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
REQUEST:
Provide all analyses or other Documents prepared by or for Hydro One 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 Hydro One's competitively bid
capital or maintenance projects.
RESPONSE:
WNIDCL PR 017 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 017 (Hl) seeks Hydro One's analyses or other Documents
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 Hydro
One's competitively bid capital or maintenance projects. If the merger is approved, Avista will continue
as a stand-alone utility (as set forth in the application for IPUC approval), making its own decisions on
contractor hiring. Avista operates an electric and gas utility in Idaho, while Hydro One's electric
transmission and distribution utility operations are located solely in the Province of Ontario, and there is
no relationship between Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, please refer to Hydro One's response to WNIDCL_PR_016(H1) for
information on our metrics. These metrics assist us in assessing each contractor who works on capital or
maintenance projects but no comparison is undertaken between contractors.
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 018(Hr)
RESPONDER:
DEPT:
TELEPHONE:
EMAIL:
Adele Pantusa
Law .,:
416.345.63r0
arl._t -llill lA.'iili=,, l-uDLlu
li:S ';O[{MlSSlON
RE C E IVED
DATE PREPARED: January 19,2018WITNESS: Mayo Schd{}ffi Jeil 2lr A},1 ll: 32
!i
apantusa@hydroone. com
REQUEST:
Provide copies of the last five most recent contract awards for capital projects valued at over $l 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 Hydro
One after commencement of the project.
RESPONSE:
WNIDCL PR 018 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 018 (Hl) seeks copies of Hydro One's last hve most recent
contract awards for capital projects valued at over $1 million and the associated Requests 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 Hydro One after commencement of the project.
If the merger is approved, Avista will continue as a stand-alone utility (as set forth in the application for
IPUC approval), making its own decisions on contractor hiring. Avista operates an electric and gas
utility in Idaho, while Hydro One's electric transmission and distribution utility operations are located
solely in the Province of Ontario, and there is no relationship between Hydro One's use of third-party
contractors in Ontario and Avista's in Idaho.
Without waiving these objections, Hydro One provides the following confidential information and
attachments:
Project Request
for
Proposal
Technical evaluations Bid amount
(winning bid)
Actual costs of the
awarded contract
Centralia TS Attachment
A
Please see Confidential
Attachment B
Please see
WNIDCL_PR_O
18(CXHI)
Please see
WNTDCL_PR_018(CX
Hl)
Leamington TS Attachment
C
Please see Confidential
Attachment D
Please see
WNIDCL_PR-O
l8(cxHl)
Please see
WNTDCL_PR_0r8(CX
H1)
London Nelson
GIS Building
Attachment
E
Please Confidential
Attachment F
Please see
WNIDCL_PR_O
l8(cxH l )
Please see
wNTDCL_PR_o18(C)(
H1)
Please see
WNIDCL_PR-O
l8(cxHl)
Please see
Confidential
Attachment
G
Please see Confidential
Attachment H
Please see
WNIDCL_PR_O
l8(cxHr )
Please see
WNTDCL_PR_0r8(C)(
Hl)
Page I of2
Leaside X Main
(H7L) Cable
Replacement
Attachment I Please see Confidential
Attachment J
Please see
WNIDCL_PR_O
18(cXHl)
Please see
WNTDCL_PR_O18(CX
Hl)
Hydro One has not conducted any formal performance evaluations after the commencement of the
projects.
HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 019 (Hl)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele PantusaDEPT: Law
TELEPHONE: [phone]EMAIL: [e-mail]
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 Hydro One maintenance, capital, reliability, or other construction projects.
RESPONSE:
WNIDCL PR 019 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 019 (Hl) seeks Hydro One's Documents regarding the
applicability, or planned applicability, of any health, safety, or environmental management system to
Contractor Personnel and/or Construction Contractors working on Hydro One maintenance, capital,
reliability, or other construction projects. If the merger is approved, Avista will continue as a
stand-alone utility (as set forth in the application for IPUC approval), making its own decisions on
contractor hiring. Avista operates an electric and gas utility in Idaho, while Hydro One's electric
transmission and distribution utility operations are located solely in the Province of Ontario, and there is
no relationship between Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, the following health, safety, and environmental management system
related policies and procedures apply to all contractors working on maintenance, capital, reliability, or
other construction projects:
Attachment A: Hydro One Health & Safety Policy;
Attachment B: Hydro One Environmental Policy;
Attachment C: SP 0312 R6 HSE Requirements for Purchase of Contractor Services; and
Attachment D: Requirements for Contractor Project Specific Health and Safety Plans.
In addition, the following health, safety, and environmental management system related documents and
sublevel documents may also apply to said contractors, depending on the nature of work performed.
Attachment E: Applicable Hydro One Safety Rules must be identified by contract administrators and
followed by contractors.t\?ci)
(fi)
Attachment F: SP 0328 R 15 Health, Safety and Environment Management Systerry$Vefbw d
sublevel documents (links within SP0328) may apply depending on the contract. ',li; 5 Hr-)--' F fn* i.t);- /s*= t,E| frtE,.^f,U'\ /9(-roN)&
Page I of I
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
HYDRO ONE LIMITED
RE,SPONSE TO REQUEST FOR INFORMATION
IDAHO DATE PREPARED:January 19, 2018AVU-E-I7-09/ WITNESS: Mayo SchmidtAVU-G-17-05 RESPONDER: Adele PantusaWNIDCL DEPT: Law
Production Request TELEPHONE: [phone]
WNIDCL - 020(H1) EMAIL: [e-mail]
REQUEST:
For the period 2017 -2021, provide a list, timeline, and schedule for any future or active capital projects
valued at more than $l million, and any long-term planning or supportive documents.
RESPONSE:
WNIDCL PR 020 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 020 (Hl) seeks for the period 2017-2021, Hydro One's 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. If the merger is approved, Avista will continue as a
stand-alone utility (as set forth in the application for IPUC approval), making its own decisions on
contractor hiring. Avista operates an electric and gas utility in Idaho, while Hydro One's electric
transmission and distribution utility operations are located solely in the Province of Ontario, and there is
no relationship between Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Please see response to WNIDCL_PR_020(HCXH1).
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 021 (Hl)
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt
RESPONDER: Adele Pantusa
DEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
REQUEST:
Describe in detail Hydro One's plans to recruit, train, and retain sufficient Contractor Personnel to
perform forecasted construction activities on capital, maintenance, and reliability projects.
RESPONSE:
WNIDCL PR 021 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 021 (Hl) seeks Hlzdro One's plans to recruit, train, and
retain sufficient Contractor Personnel to perform forecasted construction activities on capital,
maintenance, and reliability projects. If the merger is approved, Avista will continue as a stand-alone
utility (as set forth in the application for IPUC approval), making its own decisions on contractor hiring.
Avista operates an electric and gas utility in Idaho, while Hydro One's electric transmission and
distribution utility operations are located solely in the Province of Ontario, and there is no relationship
between Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, a large portion of Hydro One transmission construction work is
performed by construction unions directly hired by Hydro One. This is supplemented by contracted
work that follows a competitive bid process, with a small number of pre-qualified commercial
contractors.
Hydro One has prequalified 11 contractors across 4 major work streams: transmission stations,
transmission lines, high voltage underground cable, and transmission station buildings. Hydro One
works closely with its prequalified contractors and the union trade labor groups to provide a forecast of
future work demands, including skilled trade labor hours.
Page I of I
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 022 (Ht)
REC E IVE D
DATE PREPARED: January 19,2018WITNESS: Mayo Schmidt ?01fi Jjlt{ 2t} AH ll:RESPONDER: Adele PantusaDEpT: Law ji";,,,I .'1 P:U*,110
TELEpHONE: ite,.ZqS.OZ.,O .iir lr'ii:il col*[4ls
EMAIL: [e-mail]
REQUEST:
Provide copies of any and all training programs administered by or approved by Hydro One for
contractor employees.
RESPONSE:
WNIDCL PR 022 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 022 (Hl) seeks Hydro One's training programs administered
by or approved by Hydro One for contractor employees. If the merger is approved, Avista will continue
as a stand-alone utility (as set forth in the application for IPUC approval), making its own decisions on
contractor hiring. Avista operates an electric and gas utility in Idaho, while Hydro One's electric
transmission and distribution utility operations are located solely in the Province of Ontario, and there is
no relationship between Hydro One's use of third-party contractors in Ontario and Avista's in ldaho.
Without waiving these objections, generally, contractors are required to provide workers who are
trained and competent to perform the work. Hydro One, on occasion, may provide particular training
related to Hydro One specific procedures or rules, site or task hazards.
It is incumbent upon the Hydro One supervisor who manages the contractor to ensure the contractor
receives the Hydro One specific training to ensure compliance with Hydro One's regulations and safety
rules.
There are several Hydro One polices or procedures that specify to the types of health, safety and
environment training that could be required of contractors. While the requested training documents are
both proprietary and stored online, the reference documents include the following key points / guidance:
o Contractors shall work to the same regulations and safety standards as Hydro One employees.
o Electrical Safety Awareness training is required if a third party is unaccompanied at a station in a
hazardous area.
o Contractor escorted Access - the Consultant shall not enter Purchaser's premises unless
accompanied by an employee of the Purchaser or Purchaser may waive this requirement in
writing.o Safety - If the work includes field work, the Consultant shall comply with all relevant safety
rules and regulations, including those established by the Purchaser.
o Qualifications - the Consultant must demonstrate that they have qualified and competent
workers with suitable experience to carry out the specified work safely.
The list of potential safety and environment related courses for contractors include
Page I of2
. Station Safety Awareness for External Contractors
o Electrical Safety Awareness
o Occupational Health & Safety
. Hydro One Safety Rules
o WHMIS
o First Aid
. Flame Retardant Clothing
o Overview of the Utility Work Protection Code
o Confined Space Awareness
. Defensive Driving
o Fleet Safety Program for Small Vehicles
o Fire Training
o Subject Waste Management
o Transportation of Dangerous Goods
. Cyber Security training
HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO.: AVU-E-I7-09/
AVU-G-17-05
REQUESTER: WNIDCLTYPE: Production Request
REQUEST NO.: WNIDCL - 023 (Hl)
DATE PREPARED: January 19,2018
WITNESS: Mayo Schmidt
RESPONDER: Adele Pantusa
DEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
RE,QUEST:
Detail annual amounts spent on training for contractor employees from 2010 to present.
RESPONSE:
WNIDCL PR 023 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 023 (Hl) seeks H)rdro One's annual amounts spent on
training for contractor employees from 2010 to present. If the merger is approved, Avista will continue
as a stand-alone utility (as set forth in the application for IPUC approval), making its own decisions on
contractor hiring. Avista operates an electric and gas utility in Idaho, while Hydro One's electric
transmission and distribution utility operations are located solely in the Province of Ontario, and there is
no relationship between Hydro One's use of third-party contractors in Ontario and Avista's in Idaho.
Without waiving these objections, there are no training costs specifically associated with training as
contractors take the same online courses that would be required from employees performing similar
work.
Page I of I
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION:
CASE NO.:
REQUESTER:
TYPE:
REQUEST NO.:
IDAHO
AVU-E-17-09/
AVU-G-17-05
WNIDCL
Production Request
WNTDCL - 024 (Hl)
DATE PREPARED: January 19,2018
WITNESS: Mayo Schmidt
RESPONDER: Adele Pantusa
DEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
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 Hydro One
or its Subsidiaries are signatories.
RESPONSE:
WNIDCL PR 024 (Hl) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 024 (H1) seeks Hydro One's collective bargaining
agreements, memoranda of understanding, or other labor contracts that pertain to minimum standards
that will be met for contract personnel to which Hydro One or its Subsidiaries are signatories. If the
merger is approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval), making its own decisions on contractor hiring. Avista operates an electric and gas utility in
Idaho, while Hydro One's electric transmission and distribution utility operations are located solely in
the Province of Ontario, and there is no relationship between Hydro One's use of third-party contractors
in Ontario and Avista's in Idaho.
Page I of I
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HYDRO ONE LIMITED
RESPONSE TO REQUEST FOR INFORMATION
JURISDICTION: IDAHO
CASE NO.: AVU-E-I7-09/
AVU-G-17-05
REQUESTER: WNIDCLTYPE: Production Request
REQUEST NO.: WNIDCL - 025 (Hl)
DATE PREPARED: January 19,2018
WITNESS: Mayo Schmidt
RESPONDER: Adele Pantusa
DEPT: Law
TELEPHONE: [phone]
EMAIL: [e-mail]
REQUEST:
RESPONSE:
WNIDCL PR 025 (H1) is overly broad, unduly burdensome, and will not lead to the production of
admissible evidence because WNIDCL PR 025 (Hl) seeks Hydro One's list of all industry trade groups
and membership organizations to which Hydro One has paid dues within the last three years. If the
merger is approved, Avista will continue as a stand-alone utility (as set forth in the application for IPUC
approval). Please see Avista's answer to WNIDCL PR 39(AVA) for the list of Avista's industry trade
groups and membership organizations.
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Page I of I
Provide a list of all industry trade groups and membership organizations to which Hydro One has paid
dues within the last three years.