20120927PIIC 1-13 to PAC.pdf

Williams • Bradbury
ATTORNEYS AT LAW RECE\'
iUVl SE? 21 i O 0
September 27, 2012
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Re: PAC-E-12-12
Dear Ms. Jewell:
Please find enclosed an original and seven copies of First Set of Data Requests to
Rocky Mountain Power of PacifiCorp Idaho Industrial Customers for filing in the above
referenced case.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,
Rei,
Ronald L. Williams
RLW/jr
Enclosures
1015 W. Hays Street - Boise, ID 83702
Phone: [phone] - Fax: [phone] - www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
ISB#3034
ronwilliamsbradbury.com
RECEIVED
Attorneys for PIIC
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION ) Case No. PAC-E-12-12
OF ROCKY MOUNTAIN POWER FOR )
AUTHORITY TO CANCEL SCHEDULE ) FIRST SET OF DATA REQUESTS TO
NO. 17 AND IMPLEMENT A NEW ) ROCKY MOUNTAIN POWER OF
PARTIAL REQUIREMENTS TARIFF ) PACIFICORP IDAHO INDUSTRIAL
) CUSTOMERS
PacifiCorp Idaho Industrial Customers ("PIIC"), by and through its attorney of record,
Ronald L. Williams, requests that PacifiCorp, d/b/a Rocky Mountain Power (the "Company"),
provide the following documents and information on or before Thursday, October 18, 2012.
I. DEFINITIONS
"Documents" refers to all writings and records of every type in your possession, control,
or custody, whether or not claimed to be privileged or otherwise excludable from
discovery, including but not limited to: testimony and exhibits, memoranda, papers,
correspondence, letters, reports (including drafts, preliminary, intermediate, and final
reports), surveys, analyses, studies (including economic and market studies), summaries,
comparisons, tabulations, bills, invoices, statements of services rendered, charts, books,
pamphlets, photographs, maps, bulletins, corporate or other minutes, notes, diaries, log
sheets, ledgers, transcripts, microfilm, microfiche, computer data (including E-mail),
computer files, computer tapes, computer inputs, computer outputs and printouts,
vouchers, accounting statements, budgets, workpapers, engineering diagrams (including
"one-line" diagrams), mechanical and electrical recordings, telephone and telegraphic
First Set of Data Requests to RMP of PIIC - 1
communications, speeches, and all other records, written, electrical, mechanical, or
otherwise, and drafts of any of the above.
"Documents" includes copies of documents, where the originals are not in your
possession, custody or control.
"Documents" includes every copy of a document which contains handwritten or other
notations or which otherwise does not duplicate the original or any other copy.
"Documents" also includes any attachments or appendices to any document.
2."Identification" and "identify" mean:
When used with respect to a document, stating the nature of the document letter,
memorandum, corporate minutes); the date, if any, appearing thereon; the date, if known,
on which the document was prepared; the title of the document; the general subject
matter of the document; the number of pages comprising the document; the identity of
each person who wrote, dictated, or otherwise participated in the preparation of the
document; the identity of each person who signed or initiated the document; the identity
of each person to whom the document was addressed; the identity of each person who
received the document or reviewed it; the location of the document; and the identity of
each person having possession, custody, or control of the document.
When used with respect to a person, stating his or her full name; his or her most recently
known home and business addresses and telephone numbers; his or her present title and
position; and his or her present and prior connections or associations with any participant
or party to this proceeding.
3."RMP" refers to Rocky Mountain Power, any affiliated company, or any officer, director
or employee of Rocky Mountain Power, or any affiliated company.
4."Person" refers to, without limiting the generality of its meaning, every natural person,
corporation, partnership, association (whether formally organized or ad hoc), joint
venture, unit operation, cooperative, municipality, commission, governmental body or
agency, or any other group or organization.
5."Studies" or "study" includes, without limitation, reports, reviews, analyses and audits.
6.The terms "and" and "or" shall be construed either disjunctively or conjunctively
whenever appropriate in order to bring within the scope of this discovery any information
or documents which might otherwise be considered to be beyond their scope.
7.The singular form of a word shall be interpreted as plural, and the plural form of a word
shall be interpreted as singular, whenever appropriate in order to bring within the scope
First Set of Data Requests to RMP of PIIC -2
of this discovery request any information or documents which might otherwise be
considered to be beyond their scope.
II. INSTRUCTIONS
1.These requests call for all information, including information contained in documents,
which relate to the subject matter of the Data Request and which is known or available to
you.
2.Where a Data Request has a number of separate subdivisions or related parts or portions,
a complete response is required to each such subdivision, part or portion. Any objection
to a Data Request should clearly indicate the subdivision, part, or portion of the Data
Request to which it is directed.
3.The time period encompassed by these Data Requests is from 2001 to the present unless
otherwise specified.
4.Each response should be furnished on a separate page. In addition to hard copy,
electronic versions of the document, including studies and analyses, must also be
furnished if available.
If you cannot answer a Data Request in full, after exercising due diligence to secure the
information necessary to do so, state the answer to the extent possible, state why you
cannot answer the Data Request in full, and state what information or knowledge you
have concerning the unanswered portions.
6.If, in answering any of these Data Requests, you feel that any Data Request or definition
or instruction applicable thereto is ambiguous, set forth the language you feel is
ambiguous and the interpretation you are using in responding to the Data Request.
7.If a document requested is unavailable, identify the document, describe in detail the
reasons the document is unavailable, state where the document can be obtained, and
specify the number of pages it contains.
If you assert that any document has been destroyed, state when and why it was destroyed
and identify the person who directed the destruction. If the document was destroyed
pursuant to your document destruction program, identify and produce a copy of the
guideline, policy, or company manual describing such document destruction program.
9. If you refuse to respond to any Data Request by reason of a claim of privilege,
confidentiality, or for any other reason, state in writing the type of privilege claimed and
the facts and circumstances you rely upon to support the claim of privilege or the reason
for refusing to respond. With respect to requests for documents to which you refuse to
respond, identify each such document, and specify the number of pages it contains.
Please provide: (a) a brief description of the document; (b) date of document; (c) name
of each author or preparer; (d) name of each person who received the document; and (e)
First Set of Data Requests to RMP of PIIC - 3
the reason for withholding it and a statement of facts constituting the justification and
basis for withholding it.
10.Identify the person from whom the information and documents supplied in response to
each Data Request were obtained, the person who prepared each response, the person
who reviewed each response, and the person who will bear ultimate responsibility for the
truth of each response.
11.If no document is responsive to a Data Request that calls for a document, then so state.
12.These requests for documents and responses are continuing in character so as to require
you to file supplemental answers as soon as possible if you obtain further or different
information. Any supplemental answer should refer to the date and use the number of the
original request or subpart thereof.
13.Whenever these Data Requests specifically request an answer rather than the
identification of documents, the answer is required and the production of documents in
lieu thereof will not substitute for an answer.
14.Please provide the responses to these Data Requests by Thursday, October 18, 2012, to:
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Facsimile: 208-344-0077
E-mail: ronwi11iamsbradbury.com
Don Schoenbeck
RCS, Inc.
900 Washington St, Suite 780
Vancouver WA, 98660
E-Mail: [e-mail]
III. DATA REQUESTS
1.With regard to the prefiled testimony of Ms. Joelle Steward page 3, lines 11-14, please
provide an electronic copy of all the workpapers in the original software with all
formulae intact used to determine all the Year 2 rate charges for Schedule 9 and the
Company's proposed Schedule 31 charges.
2.With regard to the prefiled testimony of Ms. Joelle Steward page 2, line 6, please provide
an electronic EXCEL file containing the back-up power supplied by the Company for
each customer served under Schedule 31 in Utah for the last four years (2008 —2011)
showing the year, month, day and time the backup power was provided in fifteen minute
intervals.
3.With regard to the prefiled testimony of Ms. Joelle Steward page 2, line 6, please provide
an electronic EXCEL file containing the maintenance power supplied by the Company
for each customer served under Schedule 31 in Utah for the last four years (2008 —2011)
First Set of Data Requests to RMP of PIIC -4
showing the year, month, day and time the maintenance power was provided in fifteen
minute intervals.
4.With regard to the prefiled testimony of Ms. Joelle Steward page 2, line 7, please provide
an electronic EXCEL file containing the back-up power supplied by the Company for
each customer served under Schedule 33 in Wyoming for the last four years (2008 -
2011) showing the year, month, day and time the backup power was provided in fifteen
minute intervals.
5.With regard to the prefiled testimony of Ms. Joelle Steward page 2, line 7, please provide
an electronic EXCEL file containing the maintenance power supplied by the Company
for each customer served under Schedule 33 in Wyoming for the last four years (2008 -
2011) showing the year, month, day and time the maintenance power was provided in
fifteen minute intervals.
6.Please provide copies of select workpapers or pages from any reports prepared by the
Company indicating the actual system peak load (and the time at which it occurred) and
all available resources (load/resource balance indicating surplus capacity) by month from
January 2008 to date.
7.With regard to the prefiled testimony of Ms. Joelle Steward page 5, lines 6-9, please
provide any analysis done by the Company to support the application of the Company's
generation planning reserve margin for customer owned generation facilities. In other
words, please provide any documentation that shows the additional resources acquired by
the Company in order to provide back-up or maintenance services for customer owned
generation.
8.With regard to the prefiled testimony of Ms. Joelle Steward page 5, lines 17-19, please
provide an explanation and documentation on why the Company is proposing to restrict
scheduled maintenance to just one 30 day period or two fifteen day periods.
9.With regard to the prefiled testimony of Ms. Joelle Steward page 5, lines 19-20, please
provide an explanation and documentation on why the Company is proposing that
scheduled maintenance power is at one-half of the Back-up Power rate.
10.It appears that the Company's proposed Schedule 31 back-up and scheduled maintenance
demand charges in Idaho are not limited to just on-peak hours as is the case with regard
to the Company's Utah and Wyoming tariffs. Please explain why the Company is
proposing to assess demand costs for back-up and schedule maintenance service during
off-peak hours in Idaho.
11.With regard to the prefiled testimony of Ms. Joelle Steward page 5, line 21 to page 6, line
2, please provide an explanation and documentation on why the Company is proposing
that the Excess Power Rates be twice the Supplemental Power Rate.
First Set of Data Requests to RMIP of PIIC - 5
12.With regard to the prefiled testimony of Ms. Joelle Steward page 5, line 21 to page 6, line
2, please provide an explanation on why the Company is proposing to include an Excess
Power Rate in Schedule 31 when no such charge exists under Schedule 9 service.
13.With regard to Exhibit 1, Page 8 of 13, Definitions: Back-Up Contract Power, the
sentence reading: "The Back-up Contract Power shall be established by agreement
between the Customer and the Company." Please explain the circumstances under which
the customer would not have the unilateral right to specify or elect the exact amount of
Back-up Power it requires. In other words, under what circumstances would the
Company not agree to the amount requested by the customer?
r -) DATED: This ( / day of September, 2012.
Ronald L. Williams
First Set of Data Requests to RMP of PIIC - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of September, 2012, I caused to be served a true
and correct copy of the foregoing document upon the following individuals in the manner indicated
below:
Ted Weston Hand Delivery
Rocky Mountain Power fl US Mail (postage prepaid)
201 South Main, Suite 2300 Facsimile Transmission
Salt Lake City, UT 84111 [=1 Federal Express
E-Mail: ted.westonpacificorp.com EI Electronic Transmission
Daniel E. Solander Hand Delivery
Rocky Mountain Power J US Mail (postage prepaid)
201 South Main Street, Suite 2300 Facsimile Transmission
Salt Lake City, UT 84111 R Federal Express
E-Mail: daniel.solanderpacificorp.com L1 Electronic Transmission
Data Request Response Center II Electronic Transmission
PacifiCorp
E-Mail: datarequestpacificorp.com
Randall C. Budge Hand Delivery
Racine, Olson, Nye, Budge & Bailey, Chtd. US Mail (postage prepaid)
P.O. Box 1391; 201 E. Center Facsimile Transmission
Pocatello, ID 83204-1391 E Federal Express
E-Mail: [e-mail] Electronic Transmission
Attorneys for Monsanto
Brubaker & Associates fl Hand Delivery
16690 Swingley Ridge Rd., #140 US Mail (postage prepaid)
Chesterfield, MO 63017 Facsimile Transmission
E-mail: [e-mail] Federal Express
Monsanto Consultant FA Electronic Transmission
James R. Smith R Hand Delivery
Monsanto Company fl US Mail (postage prepaid)
P.O. Box 816 EJ Facsimile Transmission
Soda Springs, ID 83276 fl Federal Express
E-Mail: jim.r.smithmonsanto.com Electronic Transmission
First Set of Data Requests to RMP of PIIC - 7
Tim Butler
PacifiCorp Idaho Industrial Customers
Agrium Us Inc./Nu-West Industries
3010 Conda Road
Soda Springs, ID 83276-5301
E-Mail: TBulleragrium.com
F1 Hand Delivery
fl US Mail (postage prepaid)
Facsimile Transmission
Federal Express
LI Electronic Transmission
Don Schoenbeck
RCS, Inc.
900 Washington Street, Ste. 780
Vancouver, WA 98660
E-Mail: [e-mail]
PIIC Consultant
El Hand Delivery El US Mail (postage prepaid)
El Facsimile Transmission
El Federal Express
Electronic Transmission
Ronald L. Williams
First Set of Data Requests to RMP of PIIC - 8