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Home My WebLink About20100723PAC (1-7) to PIIC.pdfMark C. Moench Danel E. So lander 201 South Main Street, Suite 2300 Salt Lake City, Uta 84111 Telephone No. (801) 220-4014 Facsimile No. (801) 220-3299 mark.moench(âpacificorp.com daniel.solander(ipacificorp.com Paul J. Hickey Hickey & Evans, LLP 1800 Carey Avenue, Suite 700 P.O. Box 467 Cheyenne, vr 82003-0467 Ph. 307-634-1525 Fx.307-638-7335 phickey(ihickeyevans.com Attorneys for Rocky Mountain Power Rr"l"t:lì CI,J k.. ¡ zorn JUL 23 AM ß: l 5 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR APPROVAL OF CHAGES TO ITS ELECTRIC SERVICE SCHEDULES AND A PRICE INCREASE OF $27.7 MILLION, OR APPROXIMATELY 13.7 PERCENT ) ) ) ) ) ) ) ) ) CASE NO. PAC-E-IO-07 DISCOVERY REQUESTS ROCKY MOUNTAI POWER'S FIRST SET OF DISCOVERY REQUESTS TO TH PACIFICORP IDAHO INUSTRI CUSTOMERS COMES NOW, Rocky Mounta Power and hereby serves its fist set of data requests on the PacifiCorp Idao Industral Customers regardig the above docketed application of Rocky Mounta Power, pursuat to Rule 225 of the Idao Public Utilties Commssion's Ru1es of Procur, IDAPA 31.01.01, as follows: 1 DEFINTIONS AND INSTRUCTIONS The following definitions and instrctions 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, diar, calenda, canceled check, photograph, form, memorandum, schedule, ta retu, telegram, telex, report record, order or notice of governenta action of any kind, study, minutes, logs, graph, index, tape, disc, internal operating manua, data sheet or data processing card, or any other wrtten, recorded, trcribed, punched, taped, filmed, graphic or retrevable matter or data of any kind, however produced or reproduced, to which you have or have had access. Ths d~finition is intended to include, but not be limited to, all documents which have been created and/or which reside in any tye of electronic format and is to be constred in its most comprehensive sense as contemplated by the Wyomig Rules of Civil Procedure. (2) "Person or Entity" should be interpreted to denote, uness otherwse specified, any natual person, firm, corporation, association, group, individua or organzation of any tye whatsoever. (3) Any request to "identify" or "provide" should be interpreted to mean: a) With respect to a natual peron, that person's ful name, title, job description, and business and home address. Where the identification pers to a past period, as to each person identifed who is stil in your employ, or the employment of the group with which such pern is identified in response to any requests, provided, in addition, tht person's title and job description as of the time of such pas period. Where the person is no longer in your 2 employ or the employment of the group with which such person is identified in response to any request, provide that person's affliate, position, home and business address, if known, or if not known, such person's last known affliation, position, home and business address, or portions thereof as may be known. b) With respect to an entity other than a natual person, that entity's name, business, type of entity, present statu and present or last known address. c) 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, subject matter or general natue, 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 draf of each document should be identified and produced sepårately. Each original and each non-identical copy (bearng marks or notations not found on the original) of each final version and draf of each document should be identified and produced separately. d) With respect to a physical facilty, the location of the facilty, the intended purse of the facility, the actual use of such facilty, the operatig dates of the facilty, the instalation date of the facilty, the date utilization of the facilty terminated if applicable, and whether the facility is subject to the jursdiction of the Federal Energy Reguatory Commssion, the Public Servce Commssion of Wyoming, or any other reguatory body. (4) "Communication" should be interpreted to include, but not be limted to, all forms of communcation, whether wrtten, prited, ora, pictorial, electronic or otherwse, includig testiony or sworn statement, or any mean or tye whatsoever. 3 (5) "Relating To" or "Related To" means perting to, presenting, discussing, commenting on, analyzing, or mentioning in any way. (6) The term "and" and "or" should be constred either disjunctively or conjunctively whenever appropriate in order to bring withn the scope of each request any inormation or document which might otherwse 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 with the scope of each request any information or document which might otherwse be considered to be beyond its scope. 4 DATA REQUESTS RM 1.1 Please describe when the PacifiCorp Idaho Industrial Customers ("PIIC") intervention group was formed. RM 1.2 Is the PII C a registered business entity in the State of Idaho? If so, please provide the type of business entity and date of registration with the State ofIdaho. RMP 1.3 Does the PIIC have a Board of Directors? If yes, please identify each of the members of the Board of Directors. RM 1.4 Does the PIIC have officers? If yes, please identify each officer. RM 1.5 Please identify each ofthe members of the PIIC. RM 1.6. For each of the members identified in RM 1.5, please state whether each is a customer of Rocky Mounta Power. RM 1.7 the PIIC. For each of the members identified in RM 1.5, please state the date each joined DATED this 20th day of July 2010. Respectfuly submitted, ROCKY MOUNTAIN POWER ark C. Moench Danel E. Solander 201 South Main Street, Suite 2300 Salt Lake City, Uta 84111 Telephone No. (801) 220-4014 FacsiIile No. (801) 220-3299 mark.moench(iacificorp.com dael.solander(ipacificorp.com Paul J. Hickey Hickey & Evan, LLP 1800 Carey Avenue, Suite 700 P.O. Box 467 Cheyenne, vr 82003-0467 Ph. 307-634-1525 Fx.307-638-7335 phickeytßickeyevans.com 5 CERTIFICATE OF SERVICE I hereby certify that on ths 20th day of July, 2010, I caused to be served, via email and/or US mail, Rocky Mountain Power's First Set Discovery Requests to PacifiCorp Idao Industral Customers in PAC-E-10-07 to the following: Scott Woodbur Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington P.O. Box 83720 Boise, ID 83720-0074 Scott. woodbur(ipuc.idaho.gov Randall C. Budge Racine, Olson, Nye, Budge & Bailey, Charered 201 E. Center P.O. Box 1391 Pocatello,ID 83204-1391 rcb(iracinelaw.net Katie Iverson Brubaker & Associates 17244 W. Cordova Cour Surrise, AZ 85387 kiverson(iconsultbai.com James R. Smith (Email Only) Monsanto Company P.O. Box 16 Soda Sprigs, ID 83276 Jim.r.smith(imonsanto.com Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Charered 201 E. Center P.O. Box 1391 Pocatello,ID 83204-1391 E-Mai: elo(iracinelaw.net Michael C. Creamer Kelsey J. Nunez Givens Pursley LLP 601 W. Banock Street P.O. Box 2720 Boise, ID 83701-2720 Mcc(igivenspursley.com kelseynunez(igivenspurley.com Anthony Yanel 29814 Lae Road Bay Vilage, OH 44140 tonyrgyaneLnet Tim Buller Agrum, Inc. 3010 CondaRoad Soda Sprigs, ID 83276 tbullerrgagrum.com Benjam J. Otto Idao Conseration League 71 0 N. 6th Street P.O. Box 844 Boise, il 83702 botto(gidaoconservation.org Melinda J. Davison Davison Van Cleve, P.C. 333 SW Taylor, Suite 400 Portand, OR 97204 mjd(gdvclaw.com Ronald L. Wiliams Willams Bradbur, P.C. 1015 W. Hays Street Boise, ID 83702 ron(iwillamsbradbur.com Brad M. Purdy Attorney at Law 2019N. 17th Street Boise,ID 83702 bmpurdy(ihotmail.com \1Y..~!M Arel S~n Coordinator, Regulatory Operations