20180124Avista to WNIDCL 3, 13, 18, 20.pdf

K&L GATES
REC E IVED
?0lB Jfrll 2L AH 9: 55
li"l."ri":r'i i:UELIC
I l: !t li ii:tl-C0MtllSSl0N
January 23,2018 Elizabeth Thomas
[e-mail]
Via FedEx
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 Highly Confidential and Confidential Responses to Data
Requests of Washington and Northern ldaho District Gounci! of Laborers
("wNlDcL")
!daho Public Utilities Commission, Docket AVU-E-I7-09 and AVU-G.17-05
SUBJECT TO PROTECTIVE AGREEMENT
Dear Ms. Franco-Malone
Enclosed please find the following HIGHLY CONFIDENTIAL ("HC') and CONFIDENTIAL ('C')
responses from Hydro One Limited:
wNr DcL_PR_003(HCXH 1 );
WNIDCL_PR_O1 3(HC)(H1) and Highly Confidential Attachment A;
WNIDCL_PR_O18(CXH1) and ConfidentialAttachments B, D, F, G, H and J; and
wN r DoL_PR_020(HC)(H 1 ).
We have also enclosed executed ldaho Attorney Confidentiality Certificates for each of the
above-referenced responses.
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
T [phone]
F [phone]
a
a
a
a
K&L GAIES LLP
925 FOURTH AVENUE SUITE 29OO SEATTLE WA 98104.1158
T [phone] F +'l 2066237022 klgates.com
With respect to all of Hydro One's data responses served in this proceeding, to the extent any
response or attachments contain forward-looking information or statements, within the meaning
of applicable securities laws, that are based on current expectations, estimates, forecasts and
projections about Hydro One's business and the industry in which Hydro One operates and
include beliefs and assumptions made by the management of Hydro One, such information and
statements are not guarantees of future performance or actions and involve assumptions and
risks and uncertainties that are difficult to predict. Words such as "expect," "anticipate,"
"intend," "attempt," "ma!," "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.
Very truly yours,
I c{trrwax,/ 'i
Elizabeth Thomas
Kari Vander Stoep
Attorneys for Hydro One Limited
Enclosures
Ccs (w/encls.)
Brandon Karpen
Camille Christen
Deputy Attorneys G eneral
ldaho Public Utilities Commission
472 West Washington Street
Boise, lD 83702
2
January 23,2018
Peter J. Richardson
Gregory Adams
KandiWalters
Richardson Adams PLLC
Richardson & O'Leary PLLC
515 N. 27th Street
Boise, lD 83702
(representing Cleanvater Paper Corporation)
Matthew Nykiel
Conservation Associate
ldaho Conservation League
102 Euclid Ave.,#207
Sandpoint, lD 83864
Benjamin Otto
Energy Associate
ldaho Conservation League
710 N. 6th Street
Boise, lD 83702
David Wren
Nathan Smith
Cleanvater Paper Corporation
803 Mill Road
Lewiston, lD 83501
Jay Backus
Clearwater Paper Corporation
601 W. Riverside Avenue, #1100
Spokane, WA 99201
Don Reading
Ben Johnson Associates
6070 W Hill Road
Boise, lD 83703
(representing Clearwater Paper Corporation)
Marvin A. Lewallen
M. A. Lewallen & Associates, LLC
7408 SW Mapleleaf Street
Portland, OR97223
3
January 23,2018