20180223Staff 10-16 to Avista.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
RECEiVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
APPLICATION OF HYDRO ONE LIMITED
AND AVISTA CORPORATION FOR
APPROVAL OF MERGER AGREEMENT
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
AVISTA CORPORATION
The Staff of the Idaho Public Utilities Commission requests that Avista Corporation
(Company) provide the following documents and information as soon as possible, by FRIDAY,
MARCH 16,2018.
This Production Request is continuing, and the Company is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.01.0t.228.
THIRD PRODUCTION REQUEST
TO AVISTA
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CASE NO. AVU.E.17.O9
AVU-G-17-05
FEBRUARY 23,20181
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. l0: Please provide a listing and description of the planned post-merger
processes of determining the prudency of allocating services or costs from Hydro One to Avista.
Please provide a description the protections provided to Avista ratepayers for international costs,
including but not exclusive to:
A. Accounting differences between IFRS and US GAAP
B. Exchange rate fluctuations
REQUEST NO. 11: Please provide the amount and percentage of funds spent by the
Avista Foundation on projects that benefit ratepayers in each of the Company's jurisdictions for
2015-20t7.
REQUEST NO. 12: Please provide the amount of below the line
contributions/donations that Avista has contributed to organizations in each of the Company's
jurisdictions for 201 5-2017 .
REQUEST NO. 13: Does Avista plan to adopt Hydro One environmental and
sustainability policies? Please explain.
REQUEST NO. 14: As a company that previously divested from coal-fired generation,
what is Hydro One's plan regarding Avista's ownership of Colstrip? Please provide all
documents and describe all discussions between Avista and Hydro One related to the continued
operation, investment, or closure of Colstrip.
REQUEST NO. 15: Please explain how acquiring Avista, which owns a coal-fired
generation plant, might impact the Hydro One designation as a Canadian Sustainable Energy
Company. For example, does Hydro One need to pursue an exemption or any legal action in
order to maintain that designation? If so, will those costs be directly assigned to Hydro One?
THIRD PRODUCTION REQUEST
TO AVISTA 2 FEBRUARY 23,2018
REQUEST NO. 16: Please provide the Avista and Hydro One definition of "Pacific
Northwest" as it relates to the residency of Avista's Board of Directors. Morris Direct at3l.
Dated at Boise,Idaho, this fir)hay of February 2018.
General
Technical Staff: Joseph Terryll}-|2
Rachelle Farnsworth/l 3-1 6
i:umisc:prodreq/avuel7.9_avugl 7.5bkjtrf prod req3
THIRD PRODUCTION REQUEST
TO AVISTA J
Brandon
FEBRUARY 23,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF FEBRUARY 2018,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-I7-O9IAYU-G-I7-05, BY E-MAILING AND MAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COI.INSEL
AVISTA CORPORATION
PO BOX 3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
avistadockets @avistacorp. com
ELECTRONIC ONLY
ELIZABETH THOMAS
KARI VANDER STOEP
DIRK MIDDENTS
K&L GATES LLP
925 FOURTH AVE STE 29OO
SEATTLE WA 98104-1I58
E-MAIL : [e-mail]
kari.vanderstoep@kl gates. com
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
PO BOX 388
BOISE ID 8370I
E-MAIL: ron(@williams bradbury.com
ELECTRONIC ONLY
DEAN J MILLER
E-MAIL: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
ELECTRONIC ONLY
PATRICK EHRBAR DIR
AVISTA CORPORATION
E-MAIL: [e-mail]
ELECTRONIC ONLY
JAMES SCARLETT
HYDRO ONE
E-MAIL: i [e-mail]
LARRY A CROWLEY
THE ENERGY STRATEGIES INSTITUTE
5549 S CLIFFSEDGE AVENUE
BOISE ID 837I6
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
ELECTRONIC ONLY
CLEARWATER PAPER CORP.
carol. hau gen@clearwaterpaper. com
[e-mail]
j ohn j acobs@clearwaterpaoer. com
davi d. wren@ c learwaterpaper. com
nathan. [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
20I9 N ITTH STREET
BOISE ID 83702
E-MAIL: bmpurd),@hotmail.com
DANIELLE FRANCO-MALONE
SCHWERIN CAMPBELL BARNARD
IGLITZIN & LAVITT LLP
I8 W MERCER ST STE 4OO
SEATTLE WA 98119-3971
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE