HomeMy WebLinkAbout20101025PAC 3 (1) to Staff.pdf"J
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Mark C. Moench
Daniel E. Solander
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. (801) 220-4014
Facsimile No. (801) 220-3299
mark.moench((pacificorp .com
daniel.solander(fpacificorp.com
18ln Oei 25 AM to: 00
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(ihickeyevans. 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 THIR SET OF DISCOVERY
REQUESTS TO COMMISSION STAF
COMES NOW, Rocky Mountain Power and hereby serves its third set of data requests on Idaho
Public Utì1ty 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 defmitions 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, diary, 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 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 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 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, 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 (bearig 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 facì1ty, the intended.
purose 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 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, printed, oral, pictorial, electronic or otherwise,
including testimony or sworn statement, or any means or tye whatsoever.
3
. .
(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 brig 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
For Mr. English
RM 3.1 Mr. English makes an adjustment to remove all wage increases awarded
during 2009 and 2010 and sets the level of straight-time labor at the Januar 1, 2009 leveL.
Please provide all necessar documentation to show how the ($14,375,075) removal figue
shown on Exhibit No. 104 is calculated.
DATED this 22nd 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. (801) 220-4014
Facsimile No. (801) 220-3299
mark.moench~pacificorp.com
daniel.solander~pacificorp.com
4
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(ihickeyevans.com
Attorneys for Rocky Mountain Power
5
CERTIFICATE OF SERVICE
I hereby certfy that on this 22nd day of October, 2010, I caused to be served, via E-mail,
a true and correct copy of Rocky Mountain Power's Third Set of Discovery Requests to
IPUC StaffinPAC-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: e1o(iracinelaw.net
Tim Buller
Jason Harrs
Agrum, Inc.
3010 Conda Road
Soda Springs, ID 83276
E-Mail: tbuller(iagrium.com
J AHarris(iagrium.com
Brad Purdy
CAPAI
2019 N. 17th St.
Boise, ID. 83702
E-mail: bmpurdvtihotmail.com
Anthony Yankel.
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tony(iyankel.net
James R. Smith (E-mail only)
Monsanto Company
P.O. Box 816
Soda Sprigs, Idaho 83276
E-Mail: jim.r.smith(imonsanto.com
Ronald L. Wiliams
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
E-mail: ron(iwiliamsbradbury.com
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey,
Chartered
201 E. Center
P.O. Box 1391
Pocatello, ID 83204-1391
E-Mail: rcb(à)racinelaw.net
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Ave. , Suite 700
PO Box 467
Cheyenne, WY 82003
E-Mail: phickey(ihickeyevans.com
Benjamin 1. Otto
Idaho Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idaho 83702
E-mail: botto(iidahoconservation.org
Katie Iverson (E-mail only)
Brubaker & Associates
17244 W. Cordova Cour
Sunse, Arzona 85387
E-Mail: kiversonticonsultbai.com
Melinda J. Davison
Davison Van Cleve, P.e.
333 S.W. Taylor, Suite 400
Portland,OR97204
E-mail: mjd(idvc1aw.com
Scott Woodbury
Deputy Attorney General
Idaho Public Utì1ties Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
E-Mail: scdtt.woodbur(ipuc.idaho.gov
Dr. Don Reading (E-mail Only)
Idaho Conservation League
6070 Hil Road
Boise, ID 83703
E-mail: dreadingtimindsprig.com
lsI
Care Meyer
Coordinator, Administrative Services