PIIC set 1 (1-7).docx

Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for IntervenorPIIC
BEFORE THE IDAHO PUBLIC UTILITES COMMISSIONIN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER TO MODIFY THE ENERGY COST ADJUSTMENT MECHANISM AND INCREASE RATES BY $10.2 MILLION, OR APPROXIMATELY 3.9 PERCENT
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Case No. PAC-E-15-09
FIRST PRODUCTION REQUEST OF PACIFICORP IDAHO INDUSTRIAL CUSTOMERSTO ROCKY MOUNTAIN POWERPacifiCorp Idaho Industrial Customers (“PIIC”), by and through its attorney of record, Ronald L. Williams, requests that PacifiCorp, d/b/a Rocky Mountain Power (the “Company”), provide the following documents and information on or before Thursday, August 6, 2015.DEFINITIONS1.“Documents” refers to all writings and records of every type in your possession, control, or custody, whether or not claimed to be privileged or otherwise excludable from discovery, including but not limited to: testimony and exhibits, memoranda, papers, correspondence, letters, reports (including drafts, preliminary, intermediate, and final reports), surveys, analyses, studies (including economic and market studies), summaries, comparisons, tabulations, bills, invoices, statements of services rendered, charts, books, pamphlets, photographs, maps, bulletins, corporate or other minutes, notes, diaries, log sheets, ledgers, transcripts, microfilm, microfiche, computer data (including Email), computer files, computer tapes, computer inputs, computer outputs and printouts, vouchers, accounting statements, budgets, workpapers, engineering diagrams (including “one-line” diagrams), mechanical and electrical recordings, telephone and telegraphic communications, speeches, and all other records, written, electrical, mechanical, or otherwise, and drafts of any of the above.
“Documents” includes copies of documents, where the originals are not in your possession, custody or control.
“Documents” includes every copy of a document which contains handwritten or other notations or which otherwise does not duplicate the original or any other copy.
“Documents” also includes any attachments or appendices to any document.2.“Identification” and “identify” mean:
When used with respect to a document, stating the nature of the document (e.g., letter, memorandum, corporate minutes); the date, if any, appearing thereon; the date, if known, on which the document was prepared; the title of the document; the general subject matter of the document; the number of pages comprising the document; the identity of each person who wrote, dictated, or otherwise participated in the preparation of the document; the identity of each person who signed or initiated the document; the identity of each person to whom the document was addressed; the identity of each person who received the document or reviewed it; the location of the document; and the identity of each person having possession, custody, or control of the document.
When used with respect to a person, stating his or her full name; his or her most recently known home and business addresses and telephone numbers; his or her present title and position; and his or her present and prior connections or associations with any participant or party to this proceeding.3.“RMP” refers to Rocky Mountain Power, any affiliated company, or any officer, director or employee of Rocky Mountain Power, or any affiliated company.4.“Person” refers to, without limiting the generality of its meaning, every natural person, corporation, partnership, association (whether formally organized or ad hoc), joint venture, unit operation, cooperative, municipality, commission, governmental body or agency, or any other group or organization.5.“Studies” or “study” includes, without limitation, reports, reviews, analyses and audits.6.The terms “and” and “or” shall be construed either disjunctively or conjunctively whenever appropriate in order to bring within the scope of this discovery any information or documents which might otherwise be considered to be beyond their scope.7.The singular form of a word shall be interpreted as plural, and the plural form of a word shall be interpreted as singular, whenever appropriate in order to bring within the scope of this discovery request any information or documents which might otherwise be considered to be beyond their scope.II.INSTRUCTIONS1.These requests call for all information, including information contained in documents, which relate to the subject matter of the Data Request and which is known or available to you.2.Where a Data Request has a number of separate subdivisions or related parts or portions, a complete response is required to each such subdivision, part or portion. Any objection to a Data Request should clearly indicate the subdivision, part, or portion of the Data Request to which it is directed.3.The time period encompassed by these Data Requests is from 2001 to the present unless otherwise specified.4.Each response should be furnished on a separate page. In addition to hard copy, electronic versions of the document, including studies and analyses, must also be furnished if available. 5.If you cannot answer a Data Request in full, after exercising due diligence to secure the information necessary to do so, state the answer to the extent possible, state why you cannot answer the Data Request in full, and state what information or knowledge you have concerning the unanswered portions.6.If, in answering any of these Data Requests, you feel that any Data Request or definition or instruction applicable thereto is ambiguous, set forth the language you feel is ambiguous and the interpretation you are using in responding to the Data Request.7.If a document requested is unavailable, identify the document, describe in detail the reasons the document is unavailable, state where the document can be obtained, and specify the number of pages it contains.8.If you assert that any document has been destroyed, state when and why it was destroyed and identify the person who directed the destruction. If the document was destroyed pursuant to your document destruction program, identify and produce a copy of the guideline, policy, or company manual describing such document destruction program.9.If you refuse to respond to any Data Request by reason of a claim of privilege, confidentiality, or for any other reason, state in writing the type of privilege claimed and the facts and circumstances you rely upon to support the claim of privilege or the reason for refusing to respond. With respect to requests for documents to which you refuse to respond, identify each such document, and specify the number of pages it contains. Please provide: (a) a brief description of the document; (b) date of document; (c) name of each author or preparer; (d) name of each person who received the document; and (e) the reason for withholding it and a statement of facts constituting the justification and basis for withholding it.10.Identify the person from whom the information and documents supplied in response to each Data Request were obtained, the person who prepared each response, the person who reviewed each response, and the person who will bear ultimate responsibility for the truth of each response.11.If no document is responsive to a Data Request that calls for a document, then so state.12.These requests for documents and responses are continuing in character so as to require you to file supplemental answers as soon as possible if you obtain further or different information. Any supplemental answer should refer to the date and use the number of the original request or subpart thereof.13.Whenever these Data Requests specifically request an answer rather than the identification of documents, the answer is required and the production of documents in lieu thereof will not substitute for an answer.14.Please provide the responses to these Data Requests by Thursday, August 6, 2015, to:
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
BoiseID, 83702
Telephone: [phone]
Facsimile: 208-344-0077
[e-mail] G. Mullins333 S.W. Taylor, Suite 400Portland, OR [e-mail]
III.DATA REQUESTSREQUEST NO. 1:Please provide the Company’s Idaho annual results of operations and for calendar year 2014 in electronic format, including underlying workpapers with links intact.REQUEST NO. 2:Please provide the a copy of net power cost (“NPC”) report used to justify the $1.51 billion in base NPC proposed in this proceeding, with all links and functionalities intact.REQUEST NO. 3:Please provide PIIC Consultant, Brad Mullins, with access to the GRID model projects used to calculate the level of NPC proposed in this proceeding.REQUEST NO. 4:Please provide a copy of all of the standard GRID NPC input files and workpapers, as they are typically provided in a general rate case, used to calculate the NPC proposed in this proceeding.REQUEST NO. 5:Please provide the revenue requirement model, and underlying revenue requirement workpapers, from Idaho Case No. PAC-E-10-07.REQUEST NO. 6:Reference Docket No. PAC-E-13-04, Stipulation at 4. Please provide an update of the table on the referenced page to reflect actual amounts as of January 1, 2015.REQUEST NO. 7:Reference Docket No. PAC-E-13-04, Stipulation at 4. Please provide an update of the table on the referenced page to reflect amounts expected as of January 1, 2016 and December 31, 2016, based on rate base data from the Company’s ongoing general rate case in Wyoming, Wy.PSC Docket No. 20000-469-ER-15.
Dated this 16th day of July, 2015.
Respectfully submitted,
________________________________________________
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for PIIC
CERTIFICATE OF DELIVERYI HEREBY CERTIFY that on this 16th day of July, 2015, I caused to be served a true and correct copy of the foregoing document upon the following individuals in the manner indicated below:
Jean D. Jewell, Secretary (4 copies)
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Hand Delivery
James R. Smith
Monsanto Company
E-Mail: [e-mail]
Electronic Transmission
Ted Weston
Rocky Mountain Power
E-Mail: [e-mail]
Electronic Transmission
Val Steiner (e-mail only)
Agrium Us Inc.,/Nu-West Industries
E-mail: [e-mail]
PIIC
Electronic Transmission
Yvonne R. Hogle
Rocky Mountain Power
E-Mail: [e-mail]
Electronic Transmission
Jim Duke (e-mail only)
Idahoan Foods
E-mail: [e-mail]
PIIC
Electronic Transmission
Data Requests Only: [e-mail]
Electronic Transmission
Christina Zamora
Community Action Partnership Assoc. of Idaho
E-Mail: [e-mail]
Electronic Transmission
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey, Chtd.
E-Mail: [e-mail]
Attorneys for Monsanto Company
Electronic Transmission
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chtd.
E-Mail: [e-mail]
Attorneys for IIPA
Electronic Transmission
Brubaker & Associates
EMail: [e-mail]
Monsanto Company
Electronic Transmission
Anthony Yankel
E-Mail: [e-mail]
IIPA
Electronic Transmission
_____________________________________
Ronald L. Williams