20180126Avista to Staff ICNU_DR_012.docx

AVISTA CORP.
RESPONSE TO REQUEST FOR INFORMATIONJURISDICTION:WashingtonDATE PREPARED:10/31/2017CASE NO.:U-170970WITNESS:Patrick D. EhrbarREQUESTER:ICNURESPONDER:Jennifer S. SmithTYPE:Data RequestDEPT:State & Federal RegulationREQUEST NO.:ICNU – 012(AVA)TELEPHONE:[phone]EMAIL:[e-mail]:
Refer to Joint Application, App. 7 at 1 & n.2, which states that, following the merger closing, Avista will be directly assigned the costs incurred “if Hydro One employees were to provide support for Avista’s utility operations.” Please explain and provide (or identify, within the Document Room) any supporting documents as to how:
“Hydro One employees” should be understood within the referenced text of the Direct Assignment Protocol—e.g., as including Hydro One Limited and any subsidiaries, or as limited to Hydro One Limited and only certain subsidiaries; and
“support for Avista’s utility operations” should be understood within the referenced text of the Direct Assignment Protocol—e.g., whether Hydro One Limited support for Olympus 1 LLC might be construed as indirectly supporting Avista, or whether only support directly to Avista Corporation and its subsidiaries would qualify. RESPONSE:
“Hydro One employees” should be understood within the referenced text of the Direct Assignment Protocol attached to the Joint Application as Appendix 7, to include all individuals employed by Hydro One Limited and all of its subsidiaries.
As discussed in the Direct Assignment Protocol, attached to the Joint Application as Appendix 7, in footnote 1, “support for Avista’s utility operations” should be understood as:
“Time and costs incurred include, but are not limited to activities for the following: a) services by the Board of Directors, and executive, management, professional, technical and clerical employees; b) financial and accounting services, corporate governance and compliance services, legal services, audit services, information and technology services, treasury services, investor relations services, governmental and regulatory services, human resources services, communications services, payroll processing services, employee benefits participation, procurement and fleet management, tax and related services, contract negotiation and administration services, insurance and risk management services, environmental services and engineering and technical services; c) the use of office facilities, including but not limited to office space, furniture, equipment, machinery, supplies, computers and computer software, communications equipment, insurance policies and other personal property; d) the use of automobiles, airplanes, other vehicles and equipment;”