To: NAESB WEQ/WGQ FERC Forms Subcommittee

August 27, 2015

To: NAESB WEQ/WGQ FERC Forms Subcommittee Re: Informal comments of Avista Corporation regarding the Subcommittee preliminary topics

Thank you for the opportunity to submit these informal comments. Avista’s comments are from an end user perspective and do not adequately address some of the technical questions posed by the Subcommittee.

1. Should the final work product mirror the NAESB eTariff Standard?

Not sure what this means. The eTariff standard is in use and familiar. Is this a third party software developer’s concern?

2. Should the FERC forms be grouped by industry, form, or a hybrid of the two?

A hybrid as outlined in the work paper seems best approach because wherever commonalities exist they will be consistent, while details will be unique for electric and gas industries. Think about resolving inconsistencies between industries for similar forms. For example, Form 1 and Form 2 are largely similar but with curious differences in the information requested. Form 2 includes information on security holders and voting powers which is absent from Form 1. Should this information be collected from both the electric and gas industries? Likewise for the Form 2 information for unamortized debt expense, premium and discount on long term debt, and gain on reacquired debt.

3. Should the subcommittee address the standards development through form or industry specific task forces or as a whole?

The hybrid approach might be a good choice. Address commonalities as a whole, then task forces address industry specific details noting the differences and why there are differences.

4. Should there be a single schema or a form specific schema?

What are the pros and cons of the options? Would a single schema be more flexible? Would a form specific schema be easier to work with? Which will be easier to maintain and roll forward each reporting period? Page 1 of 3 5. Should the subcommittee work to develop “common” data structures or maintain slightly varying structures?

Common data structures may be helpful to respondents with several forms to submit.

6. What XML design pattern will best suit the effort?

Not sure which pattern is the best fit. Eliminate Garden of Eden since it is difficult to read and understand.

7. Should validations be built into the XML schemas?

Yes, because validations should ensure better data quality, but will some respondents find it difficult to respond appropriately? Will the validations fit every respondent?

8. Is there a need for XML level validations?

Yes, because validations should ensure better data quality, but will some respondents find it difficult to respond appropriately? Will the validations fit every respondent?

9. Should application validations be included?

Yes, utilities currently rely on the application-level checks to the extent they are accurate. Some are not accurate in the FoxPro application for Forms 1 and 2. Validations would be beneficial to ensure reporting accuracy; for instance, total utility plant must tie between the balance sheet and other places it is reported. Will the validations fit every respondent?

10. What should the validation/error messages look like?

Based on experiences with the FERC EQR csv file submission process where a test filing is submitted to trigger validations and allow for corrections before the final submission: A timely email is preferable in the interest of time. Direct the respondent to

of 3 the specific error so it can be corrected efficiently. Make error messages easy to understand. List all errors in one email so the respondent may make multiple corrections to the file and then resubmit. The FoxPro application currently allows for error checks on Forms 1 and 2 before submission and respondents will not want to lose that functionality.

11. What method does FERC expect to utilize for entities to submit the XML files?

A guess would be something similar to the portal for EQR submissions. This portal makes on-line review of the data very difficult. Manual input is extremely awkward. The Report Viewer output is in a somewhat different order and format than the input data, but it is fairly easy to export (in csv) and review. The Download option provides a complete filing by the respondent and is easy to request and use.

Respondents should have robust user interfaces because utilities prepare various Form 1 pages throughout the organization during the first quarter of the year. The respondent will compile an organization’s data as it is received and will cross check some pages to other pages.

Has FERC explored a filing mechanism similar to EDGAR used by the SEC? EDGAR provides the ability to submit XML-tagged files and the file creation is largely up to the user.

Thank you for considering Avista’s informal comments on the Subcommittee’s preliminary topics to be addressed work paper.

Respectfully,

/s/ Lori Hamilton Lori Hamilton FERC Compliance Manager Avista Corporation

509-495-4846 [email protected]