20181010Staff 43-45 to Avista.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
TDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
RECEIVED
?ill8 OcT l0 P?'1 2: 2\
Street Address for Express Mail:
472 W. 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
FIFTH 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
WEDNESDAY, OCTOBER 24, 20 18. I
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
! Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffls
attorney at [phone].
FIFTH PRODUCTION REQUEST
TO AVISTA
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CASE NO. AVU.E-I7-09
AVU-G-17-05
I ocToBER 10,2018
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0t.0t.228.
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. 43: Please individually specify the compensation, bonuses, and any
type of additional financial benefit that each Avista and Hydro One employee who filed
testimony or supplemental testimony in this case stands to make if the merger is completed.
REQUEST NO. 44: Please specify the financial benefits that will accrue to shareholders
of Avista and Hydro One if the merger is completed.
REQUEST NO. 45: Before July 11,2018, Staff was not aware that the Providence of
Ontario had the ability to fire the Board of Directors and pressure the CEO to resign. This raises
concerns about other authority that the Province of Ontario may already have or may have the
ability to create through legislation over Hydro One. The Oregon Citizens Utility Board
expressed a similar concern and now believes there are'ono limits" on the Providence of
Ontario's legislative authority over Hydro One. Please explain what other authority the Province
of Ontario has over Hydro One and/or the exact limits of that authority. In particular, please
explain how the Province of Ontario is prohibited from passing legislation to impact the
operation or finances of Hydro One.
Dated at Boise, Idaho, this Ory day of October 2018.
i :umisc:prodreq/avue I 7.9_avug I 7.5bksd prod req4
FIFTH PRODUCTION REQUEST
TO AVISTA 2
General
ocroBER 10,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1OTH DAY OF OCTOBER 2018,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO AVISTA CORPORATION, IN CASE NOS.
AVU-E-17-09/AVU-G-T7-05, BY E-MAILING AND MAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
DAVID J MEYER
VP & CHIEF COLTNSEL
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-3727
E-MAIL: [e-mail]
avistadockets@avistacorp. com
ELIZABETH THOMAS
KARI VANDER STOEP
DIRK MIDDENTS
K&L GATES LLP
925 FOURTH AVE STE 29OO
SEATTLE WA 98104-1158
E-MAIL : liz.thomas@,klgates.com
kari.vanderstoep@kl gates. com
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
ELECTRONIC ONLY
DEAN J MILLER
E-MAIL: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE TD 83702
E-MAIL : [e-mail]
ELECTRONIC ONLY
PATRICK EHRBAR DIR
AVISTA CORPORATION
E-MAIL: patrick.ehrbar@,avistacorp.com
ELECTRONIC ONLY
JAMES SCARLETT
HYDRO ONE
E-MAIL : j scarlett@l"r),droone.com
LARRY A CROWLEY
THE ENERGY STRATEGIES INSTITUTE
5549 S CLIFFSEDGE AVENUE
BOISE ID 83716
E-MAIL: crowleyla(a)aol.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
ELECTRONIC ONLY
CLEARWATER PAPER CORP.
carol.haugen@clearwaterpaper. com
[e-mail]
j ohn.-i acobs@,clearwaterpaper. com
david. wren@clearwatemaper. com
nathan. smith@,cl earwaterpaper. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
NORMAN M SEMANKO
PARSON BEHLE & LATIMER
8OO W MATN ST STE 13OO
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N ITTH STREET
BOISE ID 83702
E-MAIL: [e-mail]
DANIELLE FRANCO-MALONE
SCHWERIN CAMPBELL BARNARD
IGLITZIN & LAVITT LLP
I8 W MERCER ST STE 4OO
SEATTLE WA 98119-3971
E-MAIL: [e-mail]
GARRICK L BAXTER, DEPUTY
ID ATTORNEY GENERAL
ID DEPT OF WATER RESOURCES
PO BOX 83720
BOISE ID 83720-0098
E-MAIL: [e-mail]
SECRE
CERTIFICATE OF SERVICE