20161007PIIC 1-8 to PAC.pdf

WILLIAMS · BRADBURY
ATTORNEYS AT LAW
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83 702
Re: PAC-E-16-12
Dear Ms. Jewell:
October 7, 2016
RECE IVED
201b ..CT -1 AM· 10: 35
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Please find enclosed one original and two conformed 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.
RLW/jr
Enclosures
Sincerely,
Ronald L. Williams
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]
[e-mail]
Attorneys for Intervenor PIIC
f~ECE IVED
2016 DL-T -7 AH IQ: 36
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BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER TO )
UPDATE BASE NET POWER COSTS AND)
IMPLEMENT A RA TE STABILITY PLAN )
)
)
)
Case No. PAC-E-16-12
FIRST PRODUCTION REQUEST OF
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS TO ROCKY MOUNTAIN
POWER
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 27, 2016.
I. DEFINITIONS
1. "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 (~, 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, Page 2
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.
5. 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.
8. 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)
the reason for withholding it and a statement of facts constituting the justification and
basis for withholding it.
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.
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 27, 2016, to:
III.
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Facsimile: 208-344-0077
[e-mail]
DATA REQUESTS
Bradley G. Mullins
333 S.W. Taylor, Suite 400
Portland, OR 97204
[e-mail]
REQUEST NO. 1: Please provide electronic copies of the Company's annual results
of operations for the Idaho jurisdiction for the period ending December 31, 2015.
REQUEST NO. 2: Please provide the Company's semi-annual results of operations
for the Idaho Jurisdiction for the period ending June 30, 2016, if available.
REQUEST NO. 3: Please state the Company's actual, annual return on equity for the
Idaho jurisdiction for the calendar periods 2013, 2014, and 2015. Please provide this value based
on normalized and as booked results. Please also provide a brief description of how the Energy
Cost Adjustment Mechanism revenues are reflected in establishing the respective return on
equity values.
PIIC FIRST PRODUCTION REQUEST TO RMP, Page 4
REQUEST NO. 4: Please provide accounting workpapers used to calculate the current
depreciation deferral balance included in the Company's most recently filed results of operations
for the Idaho jurisdiction.
REQUEST NO. 5: Please provide accounting workpapers used to estimate the $6.9
million balance for the depreciation deferral balance through December 31 , 201 7, as identified in
footnote 4 of the Company's Application.
REQUEST NO. 6: Please provide workpapers used to calculate the figures in the
Direct Testimony of Mr. Wilding, Page 4, Table 2.
REQUEST NO. 7: Please provide the Company's actual net power costs for the
periods 2015 and 2016 (through the most recent month available). Please provide this
information including the underlying accounting database entries and fuel supply cost
calculations.
REQUEST NO. 8: Please provide all workpapers used to calculate the proposed level
of Base NPC, including access to the GRID model and GRID model workpapers, in the manner
typically provided in a general rate case.
Dated this 7th day of October, 2016.
Respectfully submitted,
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for PUC
PlIC FIRST PRODUCTION REQUEST TO RMP, Page 5
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 7th day of October, 2016, I 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 (3 copies)
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: [e-mail]
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: [e-mail]
Randall C. Budge
Thomas J. Budge
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-Mail: [e-mail]
Attorney for Monsanto Company
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
E-Mail: [e-mail]
Monsanto Company
5rl Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission D Federal Express D Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
~ Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
6(1 Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
@ Electronic Transmission
PIIC FIRST PRODUCTION REQUEST TO RMP, Page 6
Eric L. Olson
ECHO HA WK & OLSEN, PLLC
505 Pershing Ave., STE. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: (208) 4 78-1670
Attorney for Idaho Irrigation Pumpers
Association
Anthony Y ankel
12700 Blake Avenue, Unit 2505
Lakewood, OH 44107
E-mail: [e-mail]
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission 0 Federal Express &J Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission 0 Federal Express
'gJ Electronic Transmission
Ronald L. Williams
Williams Bradbury, P.C
Attorney for PUC
PIIC FIRST PRODUCTION REQUEST TO RMP, Page 7