20101021PAC 1 (1-6) to Staff.pdf

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Mark C. Moench
Daniel E. Solander
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
mark.moench~pacificorp.com
danieLsolander~pacificorp.com
281l10CT 21 Afi 9= 33
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Avenue, Suite 700
P.O. Box 467
Cheyenne, VV 82003-0467
Ph. 307-634-1525
FX.307-638-7335
phickey(ßhickeyevans.com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF ROCKY)MOUNTAIN POWER FOR)
APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE)
SCHEDULES. AND A PRICE )
INCREASE OF $27.7 MILLION,
OR APPROXIMATELY 13.7
PERCENT
CASE NO. PAC-E-10;.07
DISCOVERY REQUESTS
ROCKY MOUNTAIN POWER'S FIRST SET OF DISCOVERY
REQUESTS TO IDAHO PUBLIC UTILITIES COMMISSION STAFF
COMES NOW, Rocky Mountain Power and hereby serves its first set of data requests on THE
Idaho Public Utilties Commission staff ("Staff') regarding the above docketed application of
Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utilities Commission's Rules
of Procedure, IDAPA 31.01.01, as follows:
1
DEFINITIONS AN 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, calendar, canceled check,
photograph, form, memorandum, schedule, tax retu, telegram, telex, report, record, order or
notice of governental 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, fimed, graphic or retrevable matter or data of ariy 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 tye of
electronic format and is to be constred 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 natual person, firm, corporation, association, group, individual or organization of any tye
whatsoever.
(3) Any request to "identify" or "provide" should be interpreted to mean:
a) With respect to a natual person, that person's full name, title, job
description, and business and home address. Where the identification pertins to a past period,
as to each person identified who is stil 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
2
title and job description as of the time of such past period. Where the person is no longer in your
employ or the employment of the group with which such person is identifed in response to any
request, provide that person's affiiate, position, home and business address, if known, or if not
known, such person's last known affiiation, 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, tye of entity, present status 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 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.
d) With respect to a physical facility, the location of the facility, the intended
purose of the facility, the actual use of such facility, the operating dates of the facilty, the
installation date of the facility, the date utilzation of the facility terminated if applicable, and
whether the facility is subject to the jursdiction 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 wrtten, prited, oral, pictorial, electronic or otherwise,
including testimony or sworn statement, or any means or tye whatsoever.
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(5) "Relating To" or "Related To" means pertaining to, presenting, discussing,
commenting on, analyzing, or mentioning in any way.
(6) The term "and" and "or" 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 brig within the scope
of each request any information or document which might otherwise be considered to be beyond
its scope.
DATA REQUESTS
RMP 1.1 Please provide all workpapers and exhibits supporting Mr. Lanspery's testimony
with all formulas and lins to other files intact, including but not limited to the GRID scenarios,
revised inputs to the scenarios, workpaper supporting the revisions to the Company's inputs and
assumptions, and the outputs demonstrating the impact of the adjustments. Please also identitY
the source of the data.
RMP 1.2 Please provide all workpapers and exhibits supporting Ms. Vaughn's testimony
with all formulas and links to other fies intact. Please also identitY the source of the data.
RMP 1.3 Please provide all workpapers and exhibits supporting Mr. English's testimony
with all formulas and links to other fies intact. Please also identitY the source of the data.
RM 1.4 Please provide all workpapers and exhibits supporting Mr. Lobb' s testimony with
all formulas and lins to other files intact. Please also identitY the source of the data.
RM 1.5 Please provide all workpapers and exhibits supporting Ms. Carlock's testimony
with all formulas and lins to other fies intact. Please also identitY the source of the data.
RM 1.6 Please provide all workpapers and exhibits supporting Mr. Leckie's testimony
with all formulas and lins to other fies intact. Please also identitY the source of the data.
4
"
DATED this 14th day of October 2010.
Respectfully submitted,
ROCKY MOUNTAIN POWER
lsi
Mark C. Moench
Daniel E. Solander
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
mark.moench~pacificorp.com
daniel.solander~pacificorp.com
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Avenue, Suite 700
P.O. Box 467
Cheyenne, WY 82003-0467
Ph. 307-634-1525
Fx. 307-638-7335
phickey(ßhickeyevans.com
Attorneys for Rocky Mountain Power
5
CERTIFICATE OF SERVICE
I hereby certifY that on this 14th day of October, 2010, I caused to be served, via E-mail, a
tre and correct copy of Rocky Mountain Power's First Set of Discovery Requests to
IPUC Staff in PAC-E-1O-07 to the following:
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey,
Chartered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: elo(ßracinelaw.net
Tim Buller
Jason Harrs
Agrum, Inc.
3010 Conda Road
Soda Springs, ID 83276
E-Mail: tbuller(ßagrium.com
JAHarris(ßagrium.com
Brad Purdy
CAPAI
2019 N. 17th St.
Boise, ID. 83702
E-mail: bmpurdv(ßhotmaiLcom
Anthony Yanke 1
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tony(ßyanke1.net
James R. Smith (E-mail only)
Monsanto Company
P.O. Box 816
Soda Sprigs, Idaho 83276
E-Mail: jim.r.smith(ßmonsanto.com
Ronald L. Wiliams
Wiliams Bradbury, P.e.
1015 W. Hays St.
Boise ID, 83702
E-mail: ron(ßwiliamsbradbury.com
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey,
Chartered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: rcb(ßracinelaw.net
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Ave. , Suite 700
PO Box 467
Cheyenne, WY 82003
E-Mail: phickey(ßhickeyevans.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idaho 83702
E-mail: botto(ßidahoconservation.org
Katie Iverson (E-mail only)
Brubaker & Associates
17244 W. Cordova Cour
Sunise, Arzona 85387
E-Mail: kiverson(ßconsultbai.com
Melinda J.Davison
Davison Van Cleve, P.e.
333 S.W. Taylor, Suite 400
Portland, OR 97204
E-mail: mjd(ßdvc1aw.com
Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
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...
Boise, ID 83720-0074
E-Mail: scott. woodbur(ßpuc.idaho.gov
Dr. Don Reading (E-mail Only)
Idaho Conservation League
6070 Hil Road
Boise, ID 83703
E-mail: dreading(ßmindspring.com
lsi
Carre Meyer
Coordinator, Administrative Services