20101025PIIC to PAC 2 (1-3).pdf

Melinda J. Davison, OSB No. 930572
Davison Van Cleve, P.C.
333 SW Taylor, Suite 300
Portland, OR 97204
Telephone: [phone]
Fax: [phone]
mjd~dvclaw.com
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Ronald 1. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays S1.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
ron~willamsbradbur.com
Attorneys for PacifiCorp Idaho Industrial Customers
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICA nON )
OF ROCKY MOUNTAIN POWER FOR )
APPROVAL OF CHANGES TO ITS )
ELECTRIC SERVICE SCHEDULES AND A)
PRICE INCREASE OF $27.7 MILLION, OR )
APPROXIMATEL Y 13.7 PERCENT )
)
Case No. PAC-E-I0-07
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS' RESPONSE TO ROCKY
MOUNTAIN POWER'S SECOND SET
OF DISCOVERY REQUESTS
Pursuant to Rule 228 of the Idaho Public Utilties Commission's Rules of
Practice and Procedure, PacifiCorp Idaho Industrial Customers' ("PIIC") response to Rocky
Mountain Power ("RMP") Second Set of Discovery Requests are as follows:
PAGE 1 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S SECOND. SET OF
DISCOVERY REQUESTS
GENERAL OBJECTIONS
1. PIIC objects to the instructions set fort in Rocky Mountain Power's Second Set
of Data Requests to the extent that these instructions impose obligations on PIIC that exceed, are
unauthorized by or are inconsistent with the discovery rules.
2. PIIC objects to the request to the extent that the data requested is not relevant to
the issues identified in this proceeding.
3. PIIC objects to the request to the extent that production of the data requested
would be unduly burdensome and that the request is overly broad.
4. PIIC objects to the request to the extent that production of the requested data
would reveal information protected by the attorney-client privilege, and/or the work product doctrine,
and/or any other privilege.
5. Each of the preceding general objections is incorporated by reference in the
specific response below.
PAGE 2 - PILe'S RESPONSE TO ROCKY MOUNTAIN POWER'S SECOND SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 2.1
Please provide all workpapers supporting Mr. Falkenberg's testimony with all
formulas and links to other fies intact, including but not limited to the GRID scenarios, revised
inputs to the scenaros, workpaper supporting the revisions to the Company's inputs and
assumptions, and the outputs demonstrating the impact of the adjustments. Please also identify
the source of the data.
PUC RESPONSE TO RMP 2.1
Please see the enclosed cds.
PAGE 3 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S SECOND SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 2.2
Please provide all workpapers and exhbits supporting Mr. Meyer's testimony
with all formulas and links to other fies intact. Please also identify the source of the data.
PUC RESPONSE TO RMP 2.2
Please see the enclosed cds.
PAGE 4 - PILe'S RESPONSE TO ROCKY MOUNTAIN POWER'S SECOND SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 2.3
Please provide all workpapers and exhibits supporting Mr. Schoenbeck's
testimony with all formulas and links to other fies intact. Please also identify the source of the
data.
PUC RESPONSE TO RMP 2.3
Please see the enclosed cds.
Dated: October 21,2010
Prepared by Melinda J. Davison, PIIC representative and attorney.
PAGE 5 - PILe'S RESPONSE TO ROCKY MOUNTAIN POWER'S SECOND SET OF
DISCOVERY REQUESTS