20170912Wyoming_OCA Set 1 (1).docx

BEFORE THE PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AN ORDER APPROVING NONTRADITIONAL RATEMAKING RELATED TO WIND REPOWERING
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DOCKET NO. 20000-519-EA-17
RECORD NO. 14780
OFFICE OF CONSUMER ADVOCATE’S FIRST SET OF DATA REQUESTS
Submitted:September 5, 2017
COMES NOW the Office of Consumer Advocate and hereby serves its first set of data requests regarding the above docketed general rate applicationof Rocky Mountain Power, to be answered pursuant to Rules 33, 34, and 36 of the Wyoming Rules of Civil Procedure. The responses are to be served upon and produced in care of Ivan Williams, Senior Counsel;Wyoming Office of Consumer Advocate; 2515 Warren Avenue, Suite 304; Cheyenne, WY 82002.Instructions and Definitions
1.Each discovery request calls for all information known by you and your attorneys, officers and agents, all information from sources under your control, and all information given to you by others. If any files are known to you but not within your control please identify the location of such files, the name by which such files may be requested and the custodian of the files.
2.“You” and “Your” means Rocky Mountain Poweras well as its past and present agents, officers, directors, employees, servants, accountants, consultants, and other representatives, and every other person that acted for or on behalf of Rocky Mountain Power.
3.Whenever in the following discovery requests, any writing must be described or identified or produced, all writings in the possession or control of yourself and your representatives are included, and all such writings not produced shall be identified by date, author, addresses, title, subject, title of document (contract, invoice, work order, letter or other identifying designation), number and physical description. As to each such writing not produced, the address of the present location of such writing, and the name and address of the custodian thereof, are also requested.
4.The term "writing" is used herein in its broadest sense, and includes any original reproduction or copy of any kind of writing or any documentary material, including, without limitations, papers, drafts, correspondence, e-mails, internal and external newsgroup postings, letters, memoranda, inter-office communications, notes, diaries, contract documents, drawings, photographs, film, videotapes, computer disks, computer tapes, computer printouts, plans, charts, models, permits, written ordinances, calendars, travel and expense records, surveys, ledgers, journals, instructions, agreements, canceled checks, vouchers, check stubs, plans, specifications, estimates, vouchers, permits, written ordinances, minutes of meetings, invoices, billings, checks, reports, studies, telegrams, telexes, cables, notes of telephone conversations, and notes of any oral communications, work papers, and any printout that can be made from information accessible by computer. “Writing” means any handwritten, typewritten, printed, recorded, transcribed, punched, taped, photocopied, photo-static, telexed, faxed, filmed, microfilmed, scanned, converted or otherwise prepared matter, including any of the above that are accessible by computer and that can be delivered, transmitted, reduced, reproduced, or otherwise rendered in or into tangible form.
5.If you contend that the production of any information accessible by computer is too burdensome, please describe the information that meets the substance of the request with sufficient specificity so that the request may be defined in some more limited manner, or so that the adjudication of the Commission with respect to the request can be sought.
6.With respect to each discovery request herein relating to oral communication, it is intended that each answer set forth the names, addresses, business positions and occupations of the persons involved in the said communications, and the names and addresses of any other persons present during said communications.
7.Whenever in the course of answering these discovery requests, information is called for which is other than within the personal knowledge of the person executing the answers hereto, you are requested, in addition to providing such information, to provide the name, address, telephone number, official capacity and job title of each person providing such information to you, or if the information is obtained from writing, to identify each such writing as described below.
8.Please take further notice that these written discovery requests are all continuing in nature, and you are requested to furnish amended or supplemental responses as additional information and/or documents become available.
9.Supplementation of responses is also requested for any new information which you receive that shows an original response to these discovery requests was incorrect when made, or although correct when made, is no longer true in light of such new information. The duty to supplement shall be continuing as to the above-described types of information, and supplementary responses are hereby requested to be served whenever such information is discovered or determined.
10."Identify" when used with respect to a person, means to give the person's name, present or last known street and mailing address and business address and telephone and facsimile numbers, and the position together with the position, occupation, title, and business affiliation of the person at the time of his actions in connection with the matters alleged in this action.
11."Identify" when used with respect to person that is not an individual or a corporation or other form of business organization, means to state the legal and trade name of such person, corporation or business organization, the address of its principal place of business, its telephone and fax numbers, and the identity of all individuals who acted on its behalf in connection with the matters alleged in this action. Please also provide if the organization has additional or prior trade names, street and mailing addresses, telephone and fax numbers.
12."Identify" when used with regard to a document or writing, means to give the type of document or writing (e.g., letter, memorandum, telegraph, chart, report, etc.), date, file and/or identifying symbol, to identify the author, its subject, title, length in pages, a physical description, address where located, each custodian of such document, and to state the substance of such document or produce same.
13."Describe" when used with respect to a communication, act or conduct, means to give, state or identify the following:
a. The date of the communication, act or conduct, and the person or persons present;
b. If a communication, the words or substances of the communication, the person making each of the particular statements so listed, and the mode of the communication (e.g., in writing, telephone, in person);
c. If an act or conduct, the details of the act or conduct being described and what each participant in such act or conduct did; and
d. Any document evidencing or reflecting any communication, act or conduct described in response to, or called for by, the discovery request requesting you to describe the communication, act or conduct; and
e. The location or locations at which the communication, act or conduct took place.
14.“Person” is used in its broadest sense and includes, without limitation, any individual, corporation, partnership, joint venture, association, cooperative, limited liability company, trust, estate, governmental body, subdivision or agency, and any other business or governmental organization.
17.If any matter responsive to any of the following discovery requests is being withheld based on any claim of privilege, describe generally the matter withheld, state the privilege being relied upon, and identify all persons or entities that have or have had access to such matters.
18.If the answer to any discovery request is that you lack knowledge of the requested information, describe all efforts made by you to obtain the information necessary to answer the discovery request.
19.If an objection is made with regard to any information sought, state the nature of the objection and legal authority therefore. If objection is made with regard to production of documents on grounds of attorney/client or work product privilege, identify as directed each document claimed to be so privileged.
20.If any discovery request calls for the production or provision of any document(s), please produce such document in response to the discovery request.Where possible, the OCA would prefer responses in electronic format. DATA REQUESTS
Data Request 1.1:Please provide copies of all responses to past, present, and future data requests submitted to Rocky Mountain Power by any and all other parties to this proceeding including the staff of the Wyoming Public Service Commission.
DATED:Tuesday, September 05, 2017
________________________________Ivan Williams, Senior Counsel (5-2976)
Wyoming Office of Consumer Advocate
2515 Warren Ave., Suite 304
Cheyenne, WY82002
[phone]
CERTIFICATE OF SERVICEI hereby certify that on September 5, 2017, I served the foregoing First Set of Data Requests by delivering copies thereof to the individuals/entities below, by the method(s) indicated: Data Request Response CenterPacifiCorp825 NE Multnomah, Suite 2000Portland, OR [e-mail](E-mail only)Stacy SplittstoesserWyoming Regulatory Affairs ManagerRocky Mountain Power315 West 27th StreetCheyenne, WY [e-mail] R. HogleAssistant General CounselRocky Mountain Power1407 West North Temple, Suite 320Salt Lake City, UT [e-mail] HickeyHickey & Evans, LLPP.O. Box 467Cheyenne, WY [e-mail] McDowellMcDowell Rackner & Gibson, PC419 SW 11th Avenue, Suite 400Portland, OR [e-mail] M. Pomeroy, Jr.Thorvald A. NelsonAbigail C. Briggerman #7-5476Nikolas S. Stoffel #7-5484Holland & Hart LLP6380 South Fiddler’s Green Circle, Suite 500Greenwood Village, CO [e-mail]@[e-mail]@[e-mail]@[e-mail]
Crystal J. McDonough
McDonough Law, LLC
1635 Foxtrail Dr. #327
Loveland, CO 80538
[e-mail]
Lisa Tormoen Hickey
14 N. Sierra Madre
Colorado Springs, CO 80903
[phone]
[e-mail] Williams,Senior Counsel (5-2976)Wyoming Office of Consumer Advocate2515 Warren Ave., Suite 304Cheyenne, WY 82002(307) 777-5717