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Home My WebLink About20071009PAC to Shurtz 1-7.pdf'_' " John R. Hammond, Jr., ISB No. 5470 FISHER PUSCH & ALDERMAN LLP U S Bank Plaza, 5th Floor 101 South Capitol Boulevard O. Box 1308 Boise, Idaho 83701 (208) 331-1000 (208) 331-2400 facsimile irh~~fpa-law .com.com d" ,"1 "'0 ')c ""' T--. to j ' ,.)0 LlhJ J . I ,'OJ tn \ ~ \ l;HiikO dd~~~A \ ~ s Justin Lee Brown Pro Hac Vice Admission Pending Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Telephone: (801) 220-4050 Fax: (801) 220-3299 Email: justin.brown~pacificorp.com Attorneys for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF PACIFICORP DBA ROCKY MOUNTAIN POWER FOR APPROVAL OF CHANGES TO ITS ELECTRIC SERVICE SCHEDULES CASE NO. PAC-O7- DATA REQUESTS ROCKY MOUNTAIN POWER' FIRST SET OF DATA REQUESTS TO TIMOTHY SHURTZ Pursuant to Rules 222 and 225 of the Idaho Public Utilities Commission Rules of Procedure, Rocky Mountain Power, a division of PacifiCorp (herein , " Rocky Mountain Power" or "Company ), by and through its counsel, herein submits its first set of data requests to Timothy Shurtz ("Mr. Shurtz ) and requests that Mr. Shurtz respond, in writing, within fourteen (14) days after service hereof, to the following data requests: ROCKY MOUNTAIN POWER'S FIRST Page SET OF DATA REQUESTS TO SHURTZ DEFINITIONS AND INSTRUCTIONS The following definitions and instructions apply to each of the requests for production set forth herein and are deemed to be incorporated therein. (1)Document" and "documentation should be interpreted as broadly as possible to include, but not be limited to, the original or any copy, regardless of origin or location, of any book, pamphlet, periodical publication, letter, scrapbook, diary, calendar canceled check, photograph, form, memorandum, schedule, tax return, telegram, telex report, record, order or notice of governmental action of any kind, study, minutes, logs graph, index, tape, disc, internal operating manual, data sheet or data processing card, or any other written, recorded, transcribed, punched, taped, filmed, graphic or retrievable matter or data of any kind, however produced or reproduced, to which you have or have had access. This definition is intended to include, but not be limited to, all documents which have been created and/or which reside in any type of electronic format and is to be construed in its most comprehensive sense as contemplated by the Idaho Rules of Civil Procedure. (2)Person or Entity" should be interpreted to denote, unless otherwise specified, any natural person, firm, corporation, association, group, individual or organization of any type whatsoever. (3)Any request to identify" or "provide should be interpreted to mean: With respect to a natural person, that person s full name, title, job description, and business and home address. Where the identification pertains to a past period, as to each person identified who is still in your employ, or the employment of the group with which such person is identified in response to any requests, provided, in addition that person s title and job description as of the time of such past period. Where the person is ROCKY MOUNTAIN POWER'S FIRST Page 2 SET OF DATA REQUESTS TO SHURTZ no longer in your employ or the employment of the group with which such person is identified in response to any request, provide that person s affiliate, position, home and business address, if known, or if not known, such person s last known affiliation, position home and business address, or portions thereof as may be known. With respect to an entity other than a natural person, that entity s name business, type of entity, present status and present or last known address. With respect to a document, that document's title, date, author (and, if different, the signer), addresses, recipients, or other persons who assisted in the preparation subj ect matter or general nature, and any amendments thereto, present location and custodian, whether or not such document is in the respondent's possession, custody or control and whether or not the document is claimed to be privileged. The final version and each draft of each document should be identified and produced separately. Each original and each non-identical copy (bearing marks or notations not found on the original) of each final version and draft of each document should be identified and produced separately. With respect to a physical facility, the location of the facility, the intended purpose of the facility, the actual use of such facility, the operating dates of the facility, the installation date of the facility, the date utilization of the facility terminated if applicable, and whether the facility is subject to the jurisdiction of the Federal Energy Regulatory Commission, the Idaho Public Utilities Commission, or any other regulatory body. (4)Communication" should be interpreted to include, but not be limited to, all forms of communication, whether written, printed, oral, pictorial, electronic or otherwise including testimony or sworn statement, or any means or type whatsoever. ROCKY MOUNTAIN POWER'S FIRST Page 3 SET OF DATA REQUESTS TO SHURTZ (5)Relating To" or "Related To" means pertaining to, presenting, discussing, commenting on, analyzing, or mentioning in any way. (6)The term "and" and "" should be construed either disjunctively or conjunctively whenever appropriate in order to bring within the scope of each request any information or document which might otherwise be considered to be beyond its scope. (7)The singular form of a word should be interpreted as plural, and the plural form of a word should be interpreted as singular, whenever appropriate in order to bring within the scope of each request any information or document which might otherwise be considered to be beyond its scope. DATA REQUESTS What is the factual basis for the assertion that natural gas prices have decreased? Please provide any and all documents that you rely upon in support of your assertion. Regarding the property tax cut referenced in your prefiled direct testimony, what was the amount of the tax cut? Were there any other corresponding changes in taxes charged to the utility? Regarding your prefiled direct testimony on street lighting, provide calculations, analyses, studies, or work papers relied upon by you for your assertion that bills will be higher in the winter. Please indicate whether you considered what the cost implications would be to the Company s Idaho customers if the Company were to implement your suggestions on electronic bills and additional noticing requirements set forth in your prefiled ROCKY MOUNTAIN POWER'S FIRST Page 4 SET OF DATA REQUESTS TO SHURTZ direct testimony. If not, please explain. If yes, please provide copies of any and all studies analyses, calculations, or work papers relied upon by you. Please confirm whether you agree with the Idaho Public Utilities Commission Staff s position to disallow only those severance costs that exceed the amount of the lower of the actual amount paid or the savings realized. If you do not, please explain your response. Please provide copies of all work papers, analyses, documents, and other material relied upon or that you anticipate relying upon in support (including electronic files with active formulas) of your return on equity recommendations. Please produce any and all documents that you expect or reasonably anticipate introducing into evidence at hearing in the above-captioned docket. DATED this 9th day of October 2007. Respectfull y'submi tted ROCKY MOUNTAIN POWER -.. R. Hammond, Jr., ISB No. 5470 FIS ER PUSCH & ALDERMAN LLP Bank Plaza, 5th Floor 01 South Capitol Boulevard O. Box 1308 Boise, Idaho 83701 (208) 331-1000 (208) 331-2400 facsimile rhCCi)Jp law. com -and- Justin Lee Brown Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Telephone: (80l) 220-4050 Fax: (801) 220-3299 Email: iustin.brown(Ci),pacificorp.com ROCKY MOUNTAIN POWER'S FIRST Page 5 SET OF DATA REQUESTS TO SHURTZ CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of October, 2007, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, and addressed to; by fax transmission to; by overnight delivery to; or by personally delivering to or leaving with a person in charge of the office as indicated below: Jean Jewell, Commission Secretary Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, Idaho 83720-0074 Email: iean.iewell((l),puc.idaho.gov J u.S. Mail J Facsimile J Overnight Delivery Hand Delivery (j Email Neil Price Deputy Attorney General Idaho Public Utilities Commission P. O. Box 83720 Boise, ill 83720-0074 nei1.priceC?i~puc .idaho. gov J U.S. Mail J Facsimile J Overnight Delivery Lx1 Hand Delivery ( ) Email Data Request Response Center PacifiCorp 825 N. E. Multnomah, Suite 2000 Portland, OR 97232 e-mail: datarcqucst(Q:)pacificorp.com J U.S. Mail J Facsimile J Overnight Delivery J Hand Delivery ()\I Email J u.S. Mail J Facsimile J Overnight Delivery (XI Hand DeliveryJ Email Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) O. Box 83720 Boise, ID 83720-0074 scott. woodburv~puc. idaho. gov Attorney for Commission Staff James R. Smith Monsanto Company O. Box 816 Soda Springs, ill 83276 E-mail: iim.r.smith~monsanto.com J U.S. Mail J Facsimile J Overnight Delivery J Hand Delivery ( "tf Email Only ROCKY MOUNTAIN POWER'S FIRST Page 6 SET OF DATA REQUESTS TO SHURTZ Randall C. Budge Racine, Olson, Nye, Budge & Bailey, Chtd. O. Box 1391 Pocatello, Idaho 83204- 1391 Email: rcb~vracinelaw.net Attorneys for Monsanto Company J u.S. Mail J Facsimile J Overnight Delivery J Hand Delivery (~ Email Maurice Brubaker Katie Iverson Brubaker & Associates 17244 W. Cordova Court Surprise, AZ 85387 Email: mbrubaker~consu1tbai.com ki verson(cU,consultbai.com Consultant for Monsanto Company J u.S. Mail ( J Facsimile ( J Overnight Delivery ( J Hand Delivery (~ Email Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Chtd. 201 E. Center O. Box 1391 Pocatello, Idaho 83204-1391 Email: elo(~,racinelaw .net Attorneys for Idaho Irrigation Pumpers Association, Inc. J u.S. Mail J Facsimile J Overnight Delivery J Hand Delivery Email Anthony Yankel 29814 Lake Road Bay Village, OH 44140 E-mail: tO1W(q.!vanke l.net Consultant for Idaho Irrigation Pumpers Association, Inc. ( J u.S. Mail ( J Facsimile ( J Overnight Delivery J Hand Delivery f)(J Email Idaho Irrigation Pumpers Association, Inc. c/o Lynn Tominaga O. Box 2624 Boise, ill 83701-2624 E-mail: Ivnn tominaga(a:ihotmai l.com ( J u.S. Mail J Facsimile ( J Overnight Delivery ( J Hand Delivery Email Tim Buller Agrium, Inc. 3010 Conda Road Soda Springs, Idaho 83276 E-mail: tbul1er~agrium.com J u.S. Mail ( J Facsimile ( J Overnight Delivery ~ J Hand DeliveryEmail ROCKY MOUNTAIN POWER'S FIRST Page 7 SET OF DATA REQUESTS TO SHURTZ Conley E. Ward Michael C. Creamer Givens Pursley LLP 608 W. Bannock Street P. O. Box 2720 Boise, ill 83701-2720 E-mail: cew0J,givenspursley.com Attorneys for Agrium, Inc. J u.S. Mail J Facsimile ( J Overnight Delivery J Hand Delivery '1J Email Dennis Peseau, Ph. Utility Resources, Inc. 1500 Liberty Street S, Ste. 250 Salem, OR 97302 E-mail: dpeseaLL~excite.com Consultant for Agrium, Inc. ( J U.S. Mail J Facsimile J Overnight Delivery ( J Hand Delivery Email Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise, ill 83702 Email: bmpurdv0J,hotmai1.com Attorneys for Community Action Partnership Association of Idaho ( J u.S. Mail J Facsimile ( J Overnight Delivery J Hand Delivery (X( Email Kevin B. Homer, Esq. 1565 South Boulevard Idaho Falls, ill 83404 Email: kbh~khomerlaw.com Attorney for Timothy Shurtz Tim Shurtz 411 S. Main Firth, Idaho 83236 Email: tim((i~idahosupreme.com ( J U.S. Mail ( J Facsimile J Overnight Delivery ( J Hand Delivery ("4 Email J u.S. Mail ( J Facsimile ( J Overnight Delivery J Hand Delivery f\I Email ROCKY MOUNTAIN POWER'S FIRST Page 8 SET OF DATA REQUESTS TO SHURTZ