20101109PIIC to PAC 4 (1).pdf

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Melinda J. Davison, OSB No. 930572
Davison Van Cleve, P.C.
333 SW Taylor, Suite 300
Portland, OR 97204
Telephone: [phone]
Fax: [phone]
mjd(fdvclaw.com
20HìNOV-9 AM 8:19
Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
ron(fwiliamsbradbur .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 )
APPROV AL OF CHANGES TO ITS )
ELECTRIC SERVICE SCHEDULES AND A)
PRICE INCREASE OF $27.7 MILLION, OR )
APPROXIMATELY 13.7 PERCENT )
)
Case No. PAC-E-I0-07
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS' RESPONSE TO ROCKY
MOUNTAIN POWER'S FOURTH SET
OF DISCOVERY REQUESTS
Pursuant to Rule 228 of the Idaho Public Utilties Commission's Rules of
Practice and Procedure, PacifiCorp Idaho Industrial Customers' ("PIlC") response to Rocky
Mountain Power ("RMP") Fourth Set of Discovery Requests are as follows:
PAGE 1 - PILC'S RESPONSE TO ROCKY MOUNTAIN POWER'S FOURTH SET OF
DISCOVERY REQUESTS
GENERAL OBJECTIONS
1. PILC objects to the instructions set forth in Rocky Mountain Power's Fourth Set
of Data Requests to the extent that these instructions impose obligations on PILC that exceed, are
unauthorized by or are inconsistent with the discovery rules.
2. PILC objects to the request to the extent that the data requested is not relevant to
the issues identified in this proceeding.
3. PILC 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. PILC 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 - PIlC'S RESPONSE TO ROCKY MOUNTAIN POWER'S FOURTH SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 4.1
On page 13 of Mr. Meyer's testimony, Normalization of Revenues, please
indicate if a corresponding adjustment was made to system energy or peak loads to account for
the impact to Idaho-allocated revenue requirement?
PUC RESPONSE TO RMP 4.1
No adjustment was made to system energy or peak loads.
Dated: November 8, 2010
Prepared by Melinda J. Davison, PILC representative and attorney.
PAGE 3 - PILC'S RESPONSE TO ROCKY MOUNTAIN POWER'S FOURTH SET OF
DISCOVERY REQUESTS