20150716PIIC 1-7 to Pac.pdf

Wlliams Bradbrry
ATTORNEYSATLAW
July 16,2016
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Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
Re: PAC-E-15-09
Dear Ms. Jewell:
Please find enclosed four copies of First Production Request of Pacificorp Idaho
Industrial Customers to Rocky Mountain Power for filing in the above referenced docket.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerelv-
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Ronald L. Williams
RLV//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 LD,83702
Telephone : [phone]
Fax: [phone]
ron@williamsbradbury. com
Attorneys for Intervenor PIIC
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO
MODIFY THE ENERGY COST
ADJUSTMENT MECHANISM AND
INCREASE RATES BY $I0.2 MILLION,
OR APPROXIMATELY 3.9 PERCENT
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BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
Case No. PAC-E-15-09
FIRST PRODUCTION REQUEST OF
PACIFICORP IDAHO TNDUSTRIAL
CUSTOMERS TO ROCKY MOUNTAIN
POWER
I.
1.
PacifiCorp Idaho Industrial Customers ("PIIC"), by and through its attorney of record,
Ronald L. Williams, requests that PacifiCorp, dlbla Rocky Mountain Power (the "Compofly"),
provide the following documents and information on or before Thursday, August 6,2015.
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
communications, speeches, and all other records, written, electrical, mechanical, or
otherwise, and drafts of any of the above.
PIIC FIRST PRODUCTION REQUEST TO RMP, PAgE I
"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 (e.g., 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
of this discovery request any information or documents which might otherwise be
considered to be beyond their scope.
PIIC FIRST PRODUCTION REQUEST TO RMP, PAgE2
II.
t,
INSTRUCTIONS
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.
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.
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.
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.
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.
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)
the reason for withholding it and a statement of facts constituting the justification and
basis for withholding it.
2.
aJ.
5.
6.
7.
8.
9.
PIIC FIRST PRODUCTION REQUEST TO RMP, Page 3
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.
If no document is responsive to a Data Request that calls for a document, then so state.
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.
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, August 6,2015, to:
11.
12.
13.
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise lD,83702
Telephone : [phone]
Facsimile: 208-344-007 7
ron@wi lliamsbradbury.com
Bradley G. Mullins
333 S.W. Taylor, Suite 400
Portland, OR 97204
bmull [e-mail]
III. DATA REOUESTS
REQUEST NO. l: Please provide the Company's Idaho annual results of operations
and for calendar year 2014 in electronic format, including underlying workpapers with links
intact.
REQUEST NO. 2: Please provide the a copy of net power cost ("NPC") report used to
justify the $1.51 billion in base NPC proposed in this proceeding, with all links and
functionalities intact.
REQUEST NO. 3: Please provide PIIC Consultant, Brad Mullins, with access to the
GRID model projects used to calculate the level of NPC proposed in this proceeding.
PIIC FIRST PRODUCTION REQUEST TO RMP, PAgC 4
REQUEST NO.4: Please provide a copy of all of the standard GRID NPC input files
and workpapers, as they are typically provided in a general rate case, used to calculate the NPC
proposed in this proceeding.
REQUEST NO.5: Please provide the revenue requirement model, and underlying
revenue requirement workpapers, from [daho Case No. PAC-E-10-07.
REQUEST NO. 6: Reference Docket No. PAC-E-13-04, Stipulation at 4. Please
provide an update of the table on the referenced page to reflect actual amounts as of January l,
2015.
REQUEST NO. 7: Reference Docket No. PAC-E-13-04, Stipulation at 4. Please
provide an update of the table on the referenced page to reflect amounts expected as of
January 1,2016 and December 31, 2016, based on rate base data from the Company's ongoing
general rate case in Wyoming, Wy.PSC Docket No. 20000-469-ER-15.
Dated this 16th day of July,2015.
Respectfully submitted, ,
R,,atUlb
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for PIIC
PllC FIRST PRODUCTION REQUEST TO RMP, Page 5
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this l6th day of July, 2015,|caused to be served a true
and correct copy of the foregoing document upon the following individuals in the manner
indicated below:
Jean D. Jewell, Secretary (4 copies)
Idaho Public Utilities Commission
472W. Washington
Boise, lD 83702
X Hand Delivery
Ted Weston
Rocky Mountain Power
E-Mail: [e-mail]
ffi Electronic Transmission
Yvonne R. Hogle
Rocky Mountain Power
E-Mail: [e-mail]
X Electronic Transmission
Data Requests Only:
datarequest@pac ifi corp.com
[l Electronic Transmission
RandallC. Budge
Racine, Olson, Nye, Budge & Bailey, Chtd.
E-Mail: [e-mail]
Attorneys for Monsanto Company
I Electronic Transmission
Brubaker & Associates
E-Mail: [e-mail]
Monsanto Company
[l Electronic Transmission
James R. Smith
Monsanto Company
E-Mail: j [e-mail]
X Electronic Transmission
Val Steiner (e-mail only)
Agrium Us Inc.,A.lu-West Industries
E-mail : [e-mail]
PIIC
I Electronic Transmission
Jim Duke (e-mail only)
Idahoan Foods
E-mail: [e-mail]
PIIC
[] Electronic Transmission
Christina Zamora
Community Action Partnership Assoc. of Idaho
E-Mail: [e-mail]
ffi Electronic Transmission
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chtd.
E-Mail: [e-mail]
Attorneys for IIPA
I Electronic Transmission
Anthony Yankel
E-Mail: [e-mail]
IIPA
ffi Electronic Transmission
Williams
PIIC FIRST PRODUCTION REQUEST TO RMP, Page 6