20170914Ehrbar Direct.pdf

ON BEIIAI.F OE AVISTA CORPORATION
DAV]D J. MEYER
VICE PRESTDENT AND CH]EE COUNSEL FOR
REGULATORY & GOVERNMENTAL AFFAIRS
P. O. BOX 37 2'l
74II EAST MISSION AVENUE
SPOKANE, WASHTNGTON 99220-3127
TELEPHoNE: [phone]
FACSIMILE: [phone]
DAVI D . MEYERGAVI STACORP . COM
ON BEHAIJF OE HYDRO ONE LIMITED
ELIZABETH THOMAS, PARTNER
KARI VANDER STOEP, PARTNER
K&L GATES LLP
925 EOURTH AVENUE, SUrTE 2900
SEATTLE, WA 981014-1158
TELEPHoNE: [phone]
EACSIMILE: [phone]
LI Z . THOMASGKLGATES . COM
KARI . VANDERSTOEPGKLGATES . COM
IN THE MATTER OF THE JOINT
APPLICATION OF HYDRO ONE LIMITED
(ACT]NG THROUGH ITS IND]RECT
SUBSIDIARY, OLYMPUS EQUITY LLC)
AND
AVISTA CORPORAT]ON
EOR AN ORDER AUTHOR]ZING PROPOSED
TRANSACTION
EOR AVISTA CORPORATION
(ELECTRIC AND NATURAL GAS)
BEFORE THE IDAHO PT'BLIC UTII.ITIES COMMISSION
CASE NO.
CASE NO.
i\)
AVU-E- 17-_QJ
AVU-G-17-qt
DIRECT TESTIMONY
UI
PATRICK D. EHRBAR
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I. INTRODUCTION
A. Please state your nane, business address and
present position with Avista Corporation?
A. My name is Patrick D.
is L41-L East Mission Avenue,
Ehrbar and my business address
Spokane, lVashi-ngton. I am
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presently assigned to the State and Federal Regulation
Department as Dj-rector of Rates.
A. Would you briefly describe
background and professional e><perience?
A. Yes. I am a 1995 graduate of
your educational
Gonzaga University
11 with a Bachelors degree in Business Administration. In 1991
1,2 I graduated from Gonzaga University with a Masters degree in
13 Business Administration. I started with Avista in April 1997
14 as a Resource Management Analyst j-n the Company's Demand Side
15 Management (DSM) department. Later, I became a Program
76 Manager, responsible for energy efficiency program offerings
1,1 for the Company's educational and governmental customers. In
18 2000, 7 was selected to be one of the Company's key Account
19 Executives. In this role f was responsible for, among other
20 things, being the primary point of contact for numerous
21 commercial and industrial customers, including delivery of
22 the Company's site specific energy efficiency programs.
23 I joined the State and Eederal Regulation Department as
24 a Senior Regulatory Analyst in 2007. Responsibifities in that
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role included being the discovery coordinator for the
Company's rate cases, Iine extension policy tariffs, as well
as miscellaneous regulatory
promoted to Manager of Rates
issues. In November 2009, I was
to be Senior Manager of Rates
and Tariffs, and later promoted
and Tariffs. In my current rol-e
revenue requirements, electricmy responsibilities include
and natural gas rate desi-gn, decoupling, power cost and
natural gas rate adjustments, customer usage and revenue
analysis, and Rates administration.
a. I[hat is the scope of your testimony in this
proceeding?
A. My testimony wilI expJ-ain certain commitments
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13 offered by Avista and Hydro One (hereafter jointly referred
74 to as "Joint Appli-cants") as part of our request for approvaf
15 of the Proposed Transaction. Among the commitments is a
16 proposed
closing
benefits
Rate Credit to customers beginning following the
71 of the transaction, which will- provide immediate net
to customers. I will explain how Joint Applicants
to Avista's electric
also explain other
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20 and natural gas customers I will
2l regulatory commitments offered by the companies.
fn addition, my testimony wilf explain the proposed
accounting protocol for any affiliate transactions between
Avista and Hydro One fol-Iowing the closing of the transaction.
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1 Einally, I wilI explain why Joint Applicants belj-eve this
2 fiLi-ng for approval of the Proposed Transaction should be
3 processed separately from the pending el-ectric and natural
4 gas general rate cases, and should not be consolidated.
5 Q. Are you sponsoring any exhibits that accompany your
6 testimony?
'7 A. Yes . I am sponsoring Exhibit No. '7 , Schedu.l-e 1
8 which provides the derivation of the Company's standard cost
9 affocators, which are used to spread the proposed Rate Credit
10 among the Company's electric and natural gas customers in
11 Idaho, Washi-ngton, and Oregon. Exhibit No. '7 , Schedule 2
12 shows the alfocation of the proposed Rate Credit to Avista's
13 Idaho el-ectric and natural gas customers. Next, I am
74 sponsoring Exhibit No. J, Schedul-e 3, which is a memorandum
15 summarizinq the proposed accounting protocol for any
16 affilj-ate transactions between Avista and Hydro One following
11 the closing of the transaction. Finally, Exhibit No. '7,
1B Schedule 4 includes proforma electric and natural gas tarj-ffs
!9 that provide the terms and conditions of the proposed Rate
20 Credit. These exhibits were prepared under my supervision.
27 A table of contents for my testimony is as fol-Iows:
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III.
Introduction
Rate Commitment No. 18
Regulatory Commitment Nos. 20, 23, 26-28,
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Accounting for Merger-Rel-ated Costs
Rel-ationship to Pending General- Rate Cases
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II. RATE COMMITI4ENT NO. 18
11 9. Please e:qrlain the annual Rate Credit (Corunitment
72 No. 18) proposed by iloint AppJ.icants.
13 A. As explained by Mr. Morris, the proposed annual- Rate
74 Credit is $2.65 mill-ion per year for the first five
15 following the closi-ng of the transacti-on, and the Rate
16 increases to $3. 65 milli-on per year for the last five
71 for a total of $31.5 million over the 1O-year period.
years
Credit
years
These
1B annual rate credit.s are system amounts, and woul-d be allocated
19 by service and state jurisdiction as described later in my
20 testimony.
27 Joint Applicants are proposing that the Rate Credit
22 applicable to Idaho customers be passed through to customers
23 through separate tariffs: Schedule 73 for electric customers
24 and Schedufe 713 for natural gas customers.
25 A. Is any portion of the proposed Rate Credit
26 offsetable?
27 A. Yes. A portion of the proposed Rate Credit for the
28 1O-year period is offsetabl-e. That is, when cost savi-ngs or
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1 net benefits directly refated to the transaction are already
customers, the separate
will- be reduced by an
of the Rate Credit. As
refl-ected in base retail rates for
amount up to the offsetable portion
Mr. Thies explains, $1.7 million of the $2.65 million annual
Rate Credit for the first five years is offsetable. For the
l-ast f ive years , $2.7 mill-ion of the $3. 65 mill-ion is
offsetabl-e. To the extent that Avista demonstrates there are
net cost savings t or net benefj-ts, directly associated with
the transaction that are already reflected in base retail-
rates, the Rate Credit for the first five years would be
reduced by up to $1. I million, and the Rate Credit for the
last five years would be reduced by up to $2.7 mill-ion.
The proposed $31.5 miflion benefit for the 10-year period
represents the "floor" of benefits customers will- receivei as
additj-onal merger savings occur, those woul-d be reflected as
part of the cost of service captured in subsequent general
rate cases. The $31.5 miIlion will be received by customers
either through the separate Rate Credit on tariff Schedules
73 and 173, or by the benefits being reflected j-n base retail-
Rate Credit on Schedules 73 and 713
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22 9. Please errplain how the Rate Credit is proposed to
23 be allocated among: Avista's electric and natural gas
24 customers.
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1 A. The cost savings refated to the transaction,
2 described by Mr. Thies, generally fal-l into the category of
3 costs referred to as "common costs." For ratemaking purposes,
4 these colnmon costs are afl-ocated between electric and natural
5 gas customers, and by state jurisdiction (Idaho, Washington,
6 and Oregon) using standard alfocation factors that have been
7 used for many years to allocate common costs, and have been
B reviewed periodically in general rate cases. r
9 Joint Applicants are proposing to al-l-ocate the Rate
10 Credit to Avista's electric and natural gas customers, and by
11 state jurisdiction, using these same aIl-ocation factors.2
72 A. Using' these existing'alLocation methods, how wouLd
i The all-ocation methodologies used for purposes of allocating "commoncosts" have been revlewed and approved by the utility commissj-ons in
Idaho, Washington, and Oregon. In addition, these methodologies are
employed j-n each general rate case filed by the Company in each
j urisdictlon.2 The AEL&P operations in the City and Borough of Juneau, Alaska, operatesubstantially independent of Avista Utilities, and the costs from which
the merger-refated cost savings are derived, are currently not being
charged to AEL&P. Therefore, there are no financial cost savings to flow
through to AEL&P customers. For Avista's retail operations in Montana,
Avista has approximately 30 retail- customers and total- retail- revenue of
approxj-mately $74,000. Due to the very limited retall operations byAvista i-n Montana, for administrative efficiency the past practice by the
Montana Public Service Commisslon has been to review the final rates
recently filed and approved j-n the State of ldaho, and approve those for
Avista's Montana customers, when a request is made by Avista. The date
of the last approved retaif rates in Montana for Avlsta was April 2f,
207I. Since that time electric retail rates have increased i-n the State
of Idaho, but Avista has not proposed simifar lncreases for its Montana
customers. Because Avista's current retaif rates for its Montana
customers are already befow its cost of service, and for the sake ofadministrative efficiency, Avlsta and Hydro One are not proposing to flow
through a financial benefit to Avista's Montana customers rel-ated to the
Proposed Transaction. (Tf a proportionate benefj-t to Montana customers
were to be cafcufated based on the level- of retail- revenue, the total-
annuaf Rate Credit for all customers combined woufd be approxi-mately
$190. )
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the Rate Credit be allocated first between Avista's services,
i.e., between electric and natural. gas operations?
A. To allocate the Rate Credit to electric and natural
gas operations, the Company uses what is referred to as a
"Factor J" aIfocator. This factor j-s developed using the
following four components:
( 1) Direct Operations & Maintenance (*O&M") and
Administrative and General- (A&G) costs, excluding
Iabor and resource costs, that are assigned to
electric service, natural gas North (Washington and
Idaho) service and Oregon natural gas service.
(2) Direct O&M and A&G Iabor costs that are assigned to
electrj-c service, natural gas North (Washington and
fdaho) service and Oregon natural- gas service.
(3) Number of customers for electric service, natural
gas North (Washington and fdaho) service and Oregon
natural gas service.
( 4 ) Net direct plant that is assigned to electric
service, natural gas North (Vfashington and ]daho)
service and Oregon natural- gas service.
The calcul-ations to develop the Eactor 7 allocator are
provided in Exhibit No. 7, Schedule 1.
A. Once the Rate Credit is allocated between electric
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30 A. Eor Avista's electric operations, the Company uses
31 what is referred to as a "Factor 4" aLlocator for purposes of
32 allocating common costs to Washington and Idaho. This factor
33 is developed using the following four factors:
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(1)
(2) Direct O&M and A&G labor costs that are
Washington and Idaho electric.
Direct O&M and A&G costs, excluding labor
resource costs that are assigned to Washington
Idaho electric servi-ce.
and
and
assigned to
(3)Number of customers
electri-c.
f or V,Iashington and Idaho
and
and
for Washington and Idaho
(4) Net direct plant that is assigned to Washington and
Idaho el-ectric service.
For Avista's natural gas operations, the Company uses a
similar natural gas "Eactor 4" all-ocator for purposes of
allocating natural- gas service costs common to Washington and
71 Idaho.3 This factor is developed using the following four
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(1) Direct O&M and A&G costs, excluding labor
resource costs that are assigned to Washington
Idaho natural gas service.
(2) Direct O&M and A&G Iabor costs that are assigned to
Vflashington and Idaho natural gas servi-ce.
(3)Number
natural
customers
service.
of
gas
(4) Net direct plant that is assigned to Washington and
Idaho natural gas service.
32 The calculations to develop the Factor 4 all-ocators are
33 provided in Exhibit No. 7, Schedule 1
34 A. And finalJ.y, how are iloint Applicants proposing to
3 The a1l-ocation of the Rate Credit to Oregon naturaf gas customers will
have already been determlned uslng the Eactor 7 alfocator explained
earlier.
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1 spread the Rate Credit among the electric and natural gas
2 service schedules within each state?
A. Eor Avista's electric service schedules, the Joint
Applicants are proposing to spread the Idaho el-ectric Rate
Credit on a uniform percent of base revenue basis. The Joint
Appl j-cants chose this method of rate spread because j-t
generally matches how the conrmon costs discussed earlier are
presently being recovered from customers. For the spread of
the Rate Credit within each service schedu1e (i.e., rate
design), the Joint Applicants applied the Rate Credit to the
volumetric energy blocks on a uniform cents per kvfh basis.
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72 Page 2 of Exhibit No. J, Schedule 2 provides the proposed rate
13 spread and rate design of the el-ectric Rate Credit.
14 For Avista's natuEql g4p peryice schedules, the Joint
15 Applicants are proposing to spread the Idaho natural gas Rate
76 Credit on a unj-form percent of margin basis. As with the
1-1 electric rate spread, the Joint Applicants chose this method
18 of raLe spread because it generally matches how the common
19 costs discussed earlier are presently being recovered from
20 customers. For the spread of the Rate Credit within each
27 service schedul-e (i.e., rate design), the Joint Applicants
22 applied the Rate Credit to the volumetric energy blocks on a
23 uniform cents per therm basj-s. Page 2 of Exhibit No. J,
24 Schedule 2 provides the proposed rate spread and rate design
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1 of the natural gas Rate Credit.
2 Q. I{hen would those credits be reflected in customers'
3 bil1ing rates?
4 A. Joint Applicants propose to have the Rate Credit go
5 into effect on the first day of the month following the month
6 in which the transaction c1oses. For example, Lf the
7 transaction closes on October I, 20!8, the Rate Credit woufd
8 go into effect on November L, 2018. This timing wj-Il allow
9 time for Avista to file conforming tariffs with the
10 Commission, and give the Commission adequate tj-me for review.
11 A. Have the iloint Applicants filed tariffs that would
72 iryIement the proposed Rate Credit?
13 A. Yes. The Joint Applicants have developed electric
74 and natural gas proforma tariffs outlining the terms and
15 conditions of proposed Rate Credit, and they are included in
L6 Exhibit No. '7 , Schedule 4 . Joint Applicants would f j-le
11 conforming tariffs prior to the Rate Credit effective date to
18 implement the credit, j-f the Commission approves the Proposed
79 Transaction.
20 A. Wi1L the per klfltr or per therm Rate Credit be static
2l over the 1O-year period?
22 A. No. Joint Applicants are proposing that the
23 allocation factors used to spread the Rate Credit by service
24 and by state be updated over time, such that the most current
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allocation factors used in the most recent general rate case
are used for purposes of allocating the Rate Credit. By
updating these factors at the conclusion of a general rate
case, they wiII be consistent with the allocation factors used
in establishing base retail rates for customers at the time.
In addition, as explained earlier, as the annual benefits
to customers are rolled into base retail rates over time, the
separate Rate Credit on Schedules 73 and 173 witl change.
III. REGUI,ATORY COMMITMENT NOS. 20 23 26-28 3L-32
A. What are the regrulatory cormnitments offered by
Avista and Hydro One as part of iloint Applicants' reguest for
approval of the Proposed Transaction that you are addressing'
in your testimony?
A. Joint Applicants are offering the following
regulatory commitments that I am supporting:
o Compliance with Existing Commission Orders
Commitment No. 20
o Cost Allocations Related to Corporate Structure
and Affiliate Interests - Commitment No. 23
o FERC Reporting Requirements - Commitment No. 26
o Participation in National and Regi-ona1 Forums
Commitment No. 27
o Treatment of Confidential Information
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comPliance
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Commitment No. 2B
o Annual Report on Commitments - Commitment No. 31
o Commitments Binding - Commitment No. 32
Iflhat is iloint Applicants' cormnitment reJ.ated to
with existing Cormnission Orders (Conmritment No.
Under thj-s commitment, Olympus Holding Corp. and
its subsidiaries, including Avista, acknowledge that all- of
the existing orders issued by the Commission with respect to
Avista (or its predecessor, Washington Water Power Co.) remain
in effect, and are not modified or otherwise affected by the
Proposed Transaction.
9. P1ease er<trrIain the conmritment associated with Cost
AlJ.ocations ReJ.ated to Corporate Structure and Affiliated
Interests (Comnitment No. 231 .
A. In Commitment No. 23, Avista makes specif i-c
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71 commitments rel-ated to Cost allocations rel-ated to corporate
1B structure and affifj-ated interests. Avista agrees to provide
19 cost al-Iocation methodologies used to allocate to Avista any
costs refated to Olympus Holding Corp. or its other
subsidiaries, and commits that there will be no cross-
subsidization by Avista customers of unregulated activities.
The cost-allocation methodology provided pursuant to
this commitment will be a generic methodology that does not
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requrre
specific
proceeding
proof in
affi I iate
Commission approval prior to it being proposed for
application in a general rate case or other
affecting rates. Avista wiII bear the burden of
any general rate case that any corporate and
cost al-Iocation methodology is reasonable for
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ratemaking purposes. Neither Avj-sta nor Olympus Holding Corp.
or its subsidiaries will contest the Commission's authority
to disa11ow, for retail- ratemaking purposes in a general rate
case, unreasonabl-e, or misall-ocated costs from or to Avista
or Olympus Holdi-ng Corp. or its other subsidiaries.
Vfith respect to the ratemaking treatment of affiliate
transactions affecting Avista, the Joint Applicants wil-I
comply with the Commj-ssion's then-existing practice;
provided, however, that nothing in this commitment limits
Avista from also proposing a different ratemaking treatment
for the Commission's consideration, or limit the positions
any other party may take with respect to ratemaking treatment.
Avista wil-1 notify the Commission of any change in
corporate structure that affects Avista's corporate and
affiliate cost al-l-ocation methodologies.
revisions to such cost a.l-Iocation
Avista wiII propose
methodologi-es to
accommodate such changes.
that compliance with this
Avista will not take the position
provision constitutes approval- by
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the Commission of a particular methodology for corporate and
affiliate cost aflocation.
9. Eor Conmitment No. 26 , TIEERC Reporting:
Requirerrents", what have iloint Applicants conunitted to as a
part of the Proposed Transaction?
A. Avista will continue to meet aII the applicable EERC
reporting requirements with respect to annual and quarterly
reports (e.9., EERC Eorm 7, 2, 3q) after closing of the
Proposed Transactj-on.
A. As it relates to Avista's "Participation in
National and Regional Eorums", what have Joint Applicants
comritted to as a part of this transaction (Comnitment No.
27t ?
A. Under this commitment Avista agrees that it will
continue to participate, where appropriate, in national and
regional forums regarding transmj-ssion issues, pricing
polj-cies, siting requirements, and interconnection and
integration policies, when necessary to protect the interests
of its customers.
A. PJ.ease explain the cornrnitment addressing the
\\Treatment of Confidential InformatLotr," (Comritnent No. 281 .
A. Commitment No. 28 states that, "Nothing in these
commj-tments wilf be interpreted as a waiver of Hydro One's,
its subsidiaries', or Avista's rights to request confj-dential
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1 treatment of information that j-s the subject of any of these
2 commitments. "
3 Q. Please describe Comitrnent No. 31, \\Annual Report
4 on Cormitsents".
5 A. By May 7, 2079 and each May 1 thereafter through
6 May 1, 2023, Avj-sta will f il-e a report with the Commission
1 reqardi-ng the implementation of the commitments as of December
B 31 of the preceding year. The report wiII, dt a minimum,
9 provj-de a description of the performance of each of the
10 commitments. If any commitment is not being met, relative to
11 the specj-fic terms of the commitment, the report wil-I provide
12 proposed corrective measures and target dates for completion
13 of such measures.
14 A. Please describe Coruaitment No. 32 , \\Comitrnents
15 Binding".
76 A. While there is more specific language contained
I7 within Commitment No. 32, in short, Hydro One and Avista
18 acknowledge that the commitments being made by Hydro One and
19 Avista are binding only upon them, their affil-iates where
20 noted, and their successors in interest. Eurther, the Joint
2I Applicants are not requesting in thj-s proceeding a
22 determination of the prudence, just and reasonable character,
23 rate or ratemaking treatment, or public interest of the
24 investments, expenditures or actions referenced in the
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conrmitments, and that Parties j-n appropriate proceedings may
take such positi-ons related to those items as they deem
appropriate.
IV. ACCOUNTING EOR MERGER-REI,ATED COSTS
A. Please describe how Avista is accounting for the
costs associated with the Proposed Transaction.
A. AII costs associated with evaluating and executing
on the Proposed Transaction are being separately tracked and
recorded below-the-line to a nonoperating account. This
includes internal labor, outside services, travel, and alI
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Attached as Exhibi-t No. 7, Schedul-e 3 is Avista's "Direct
Assignment Protocol, " developed by Avista for the assignment
of costs associated with the Proposed Transaction. The
Protocol addresses the accounting for costs both prior to the
closing of the transaction, as wefl as the accounting for
costs followi-ng the closing.
A. Eollowing the closing of the transaction, how will
Avista account for the costs associated with time and e:q>enses
incurred by Avista employees and Hydro One employees for any
services or work between the two companies?
A. To the extent Avista employees dedicate time and
incur costs related to the operations of Hydro One, those
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COSTS
would
Hydro
with
will be directly assigned and bill-ed to Hydro One, and
not be borne by Avista's customers. Likewise, should
10 One and from Hydro One, to be refatively small, especially in
11 the near-term, since Avista will continue to operate as a
72 standalone utility.
13 At this point in time, there are no plans to combine any
14 speci-fj-c utility operations. In the future, however, if
15 opportunities arise for the consolidation of certain Avista
16 and Hydro One utility functions, where the utilities have an
1aLI opportunity to benefit
achieve efficiencies,
from specialized expertise or to
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costs woul-d be directly
assigned and bil-led to Avista. If a Hydro One employee's time
and costs are related to Avista's requlated utility
operations, the costs would be subject to review and approval
by the Commission prior to bei-ng recovered in retail rates.
The Company expects such assignment of costs, both to Hydro
ir
One employees dedicate time
Avista's operations, such
and i-ncur costs associated
may be appropriate to develop
direct assignment or allocatlon79 additionaf or different
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protocols.
A. Is Avista currently using the proposed Direct
Assigmment Protocol with other existing affiliate companies
of Avista?
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A. Yes. fn 2014 Avj-sta acquired Alaska Energy and
Resources Company (AERC), includi-ng AEL&P,
electric service to customers in the City
which provides
and Borough of
Juneau, Alaska. We are using the same Protocol for these
companj-es as we will use for the Avista/Hydro One Proposed
Transaction.
To the extent Avista's general office employees spend
time providing services and support to our existing
subsidiaries, these costs are charged to suspense accounts
foaded for benefits,10 (Deferred Debit Account No. lB6), are
11 and are then established as a receivable (EERC Account No.
146) when bill-ed to the subsidiary. If other resources are
expended during the course of this work, such as travel or
consulting services, these costs are also charged to suspense
accounts and billed to the subsidiary. AII corporate services
provided, and costs j-ncurred, are direct bil-led to
subsidiaries at cost. No additional margin or profit is
included and no assets are allocated. This assignment of
Avista costs, which are then biIled back to the subsidiary at
cost, serve to reduce the utj-lity's expenses.
As indicated earlier, if Hydro One's employees were to
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support for Avista's utility operations, such costs
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assigned to Avista.
for direct assignment
Avista wi-1I use the
of costs rel-ated to
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its refati-onship with Hydro One, as it is with AERC and AEL&P,
as per the attached "Protocol for Direct Assignment" in
Exhibit No. J, Schedule 3.
V. REI.ATIONSHIP TO PENDING GENERAL RATE CASES
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A. Should the Proposed Transaction be consolidated
with Avista's pending eleetric and natural gas general rate
caseg (Case Nos. AVt-E-17-01 and AVt-e-17-01)?
A. No. As explained by Mr. Morris, following the cl-ose
of this transaction, there will- be littl-e to no change in the
operations of Avista, as compared to Avista's operations prj-or
to the transaction.
There will be some cost savings immediately following
the closing of the transaction, such as reduced expenses
associated with Avista no longer having publicly traded common
stock, fewer non-employee members of the Avista Board of
Directors, and other cost savings explained by Mr. Thies.
These savings, however, wj-II be covered by the proposed Rate
Credit. Avista and Hydro One are proposing to flow through
to Avista's electric and natural gas retail customers a Rate
Credit beginning at the time the Proposed Transaction closes
(through the separate tariff Schedules 73 and 173).
Therefore, the costs which are currently embedded in either
existing retaif rates or the current rate case, which wil-l be
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Ehrbar, Di 79
Avista Corporation
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reduced as a dj-rect result of the Proposed Transaction, will
be immediately credited back to customers beginning at the
time the Proposed Transaction closes, through the Rate Credit.
Furthermore, the pending general rate cases are
scheduled to be completed on or before January l, 2078. A
decision on this Proposed Transaction filing likety wiII not
occur prior to this date. Thus, dt the time a decision j-s
due in the general rate cases, it will not be known whether
the Proposed Transaction wilI be approved, and therefore
whether there wi11, in fact, be any merger-rel-ated cost
savings.
A. Does this conclude your pre-filed, direct
testimony?
A. Yes it does.
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Avista Corporation
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