20170829Wyoming_NLRA Set 1 (1-2).DOCX

BEFORE THE PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF THE APPLICATION)
OF ROCKY MOUNTAIN POWER FOR )
CERTIFICATES OF PUBLIC )Docket No. 20000-520-EA-17
CONVENIENCE AND NECESSITY AND ) (Record No. 14781)
NONTRADITIONAL RATEMAKING FOR)
WIND AND TRANSMISSION FACILITIES )
NORTHERN LARAMIE RANGE ALLIANCE’S
FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWERNorthern Laramie Range Alliance (“NLRA”), by and through their undersigned counsel, pursuant to applicable rules of procedure, submits the attached Data Requests to Rocky Mountain Power. The following response date, definitions and instruction apply to the attached Data Requests:
RESPONSE DATEPlease respond to these Data Requests within 10calendar days, i.e., by September 1, 2017.
DEFINITIONS
“Company” or “Applicant” or “you” shall mean Rocky Mountain Power; any merged or consolidated predecessor or predecessors in interest; parent(s), subsidiaries and affiliates, past and present; and the employees, officers, directors, agents, consultants, attorneys and all persons acting under contractual request only applies to one of the Applicants, please respond on behalf of that Applicant.
“Document” and “documentation” should be interpreted as broadly as possible to include, but not be limited to, the original or any copy, regardless of origin or location, of any book, pamphlet, periodical publication, letter, scrapbook, diary, calendar, canceled check, photograph, form, memorandum, schedule, tax return, telegram, telex, report, record, order or notice of governmental action of any kind, study, minutes, logs, graph, index, tape, disc, internal operating manual, data sheet or data processing card, or any other written, recorded, transcripted, punched, taped, filmed, graphic or retrievable matter or data of any kind, however produced or reproduced, to which you have or have had access. This definition is intended to include, but not be limited to, all documents which have been created and/or which reside in any type of electronic format.
Any document that is not exactly identical to another document for any reason, including, but not limited to, marginal notations or deletions, should be considered to be a separate document.
As to any document related to the matters addressed herein that is not currently in your possession but that you know or believe such a document exists, you are requested to identify and indicate to the best of your ability its present or last known location or custodian.
“Person or Entity” should be interpreted to denote, unless otherwise specified, any natural person, firm, corporation, association, group, individual or organization of any type whatsoever.
Any request to “identify” or “provide” should be interpreted to mean:
With respect to a natural person, that person’s full name, title, job description, and business and home address. Where the identification pertains to a past period, as to each person identified who is still in your employ, or the employment of the group with which such person is identified in response to any requests, provided, in addition, that person’s title and job description as of the time of such past period. Where the person is no longer in your employ or the employment of the group with which such person is identified in response to any request, provide that person’s affiliate, position, home and business address, if known, or if not known, such person’s last known affiliation, position, home and business address, or portions thereof as may be known.
With respect to an entity other than a natural person, that entity’s name, business, type of entity, present status and present or last known address.
With respect to a document, that document’s title, date, author (and, if different, the signer), addresses, recipients, or other persons who assisted in the preparation, subject matter or general nature, and any amendments thereto, present location and custodian, whether or not such document is in the respondent’s possession, custody or control and whether or not the document is claimed to be privileged. The final version and each draft of each document should be identified and produced separately. Each original and each non-identical copy (bearing marks or notations not found on the original) of each final version and draft of each document should be identified and produced separately.
With respect to a physical facility, the location of the facility, the intended purpose of the facility, the actual use of such facility, the operating dates of the facility, the installation date of the facility, the date utilization of the facility terminated if applicable, and whether the facility is subject to the jurisdiction of the Federal Energy Regulatory Commission, the Wyoming Public Service Commission, or any other regulatory body.
“Communication” should be interpreted to include, but not be limited to, all forms of communication, whether written, printed, oral, pictorial, electronic or otherwise, including testimony or sworn statement, or any means or type whatsoever.
“Relating To” or “Related To” means pertaining to, presenting, discussing, commenting on, analyzing, or mentioning in any way.
GENERAL INSTRUCTIONS
Where a request can be answered in whole or in part by reference to the responseto a preceding or subsequent request, it is sufficient to so indicate by specifying theresponse to the preceding or subsequent request by number and specifying whether it isclaimed that the response to the preceding or subsequent request is a full or partialresponse. If the latter, the response to the balance of the request shall be completed.
If various individuals are the authors of different responses to the Data Requests,please indicate the name of the author and his/her position within the Company, or ifhe/she is an expert or a consultant, please provide a current curriculum vitae for eachsuch expert of consultant.
As to any requests consisting of a number of separate subdivisions, or relatedparts or portions, a complete response is required to each part or portion with the sameeffect as if it were propounded as a separate request. Should objection to a request beinterposed it should clearly indicate to which part or portion of the request it isdirected.
For each document identified in a response which is computer generated, stateseparately (a) what types of data files or tapes are included in the input and the sourcethereof, (b) the form of the data which constitutes machine input (punch cards, tapes,etc.), (c) a description of the recordation system employed (including programdescriptions, flow charts, etc.), and (d) the identity of the person or persons, during thedesigned period, who was in charge of the collection of input materials, the processingof input materials, the data bases utilized, and/or the programming to obtain suchoutput.
Responses to requests referring to documents shall include all documents relatingto the time period specified in each request or in these instructions, whether preparedbefore, during or after that period.
Individual response of more than one page should be stapled or bound, and eachpage consecutively numbered.
If any document covered by this request is withheld for whatever reason, pleasefurnish a list identifying all withheld documents in the following manner:
the reasons for withholding;
date of the document;
name of each author or preparer;
name of each person who received the document; and
statement of facts constituting the basis for withholding the document.
If you assert that documents, records, or information responsive to any requestshave been destroyed and are thus not available, state when and explain why any suchdocument, record or information was destroyed, identify the person directing thedestruction and identify all documents relevant to such destruction or explanation. If aclaim is made that the destruction occurred pursuant to your document destructionprogram, identify and produce a copy of the guideline, policy, or company manualdescribing such document destruction program, and any correspondence orcommunication relating to the destruction of responsive documents, records orinformation.
If any of these requests are not answered on the ground that the material orinformation requested is confidential, privileged or otherwise immune to discovery, setforth in detail the factual and legal basis which support your decision to withholdproduction. Please also state whether a protective order or protective conditionsregarding disclosure would satisfy or resolve your concern.
Each document or written response shall designate the respective question (andsubpart of the question) under which it is being produced.
Each document produced shall be an authentic original document or a trueduplicate of an authentic original document.
Each of these requests shall be considered to be continuing and to requiresupplemental or amended answers as readily as information and knowledge is acquired.
If, in answering a request, you encounter any ambiguity in interpreting either therequest or a definition or instruction applicable thereto, please secure a clarification bycontacting undersigned counsel as soon as the ambiguity is known.
The term “and” and “or” should be construed either disjunctively orconjunctively whenever appropriate in order to bring within the scope of each requestany information or document which might otherwise be considered to be beyond itsscope.
The singular form of a word should be interpreted as plural, and the plural formof a word should be interpreted as singular, whenever appropriate in order to bringwithin the scope of each request any information or document which might otherwise beconsidered to be beyond its scope.
FIRST SET OF DATA REQUESTS
NLRA 1-1: Please provide complete copies of any and all past, present, and future data requests submitted to you by any party to this proceedingas well as the Wyoming Public Service Commission staff and your corresponding responses and supplemental responses to those data requests, unless previously provided. This is an ongoing request.
NLRA 1-2:Please provide all confidential versions of testimony, exhibits, and workpapers submitted in this proceeding. This is an ongoing request.Dated this 22nd day of August, 2017.Respectfully submitted,McDonough Law LLC__/s/ Crystal J. McDonough________Crystal J. McDonoughWY State Bar #7-4927McDonough Law LLC
1635 Foxtrail Dr. #327
Loveland, CO 80538Attorney for NLRA
CERTIFICATE OF SERVICE
I certify that on this 22nd day of August,2017 that a copy of the Northern Laramie
Range Alliance Set 1 to RMP was sent via electronic mailaddressed to the following:
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
Rocky Mountain Power
315 West 27th Street
Cheyenne, WY 82001
[e-mail]
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
[e-mail]
Paul J. Hickey
Hickey & Evans, LLP
P.O. Box 467
Cheyenne, WY 82003
[e-mail]
Katherine McDowell
McDowell Rackner & Gibson PC
419 SW 11th Avenue, Suite 400
Portland, Oregon 97205
[e-mail]
Ivan Williams
Christopher Leger
Office of Consumer Advocate
2515 Warren Avenue, Suite 304
Cheyenne, WY 82002
[e-mail]
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Or 97232
[e-mail]
(Email Only)
Robert M. Pomeroy, Jr.
Thorvald A. Nelson
Abby Briggerman
Nik S. Stoffel
Holland & Hart, LLP
6380 S. Fiddler's Green Circle, Suite 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
John Burbridge
Lori Brand
Wyoming Public Service Commission
2515 Warren Ave. Ste 300
Cheyenne, Wyoming 82002
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Lisa Tormoen Hickey
14 N. Sierra Madre
Colorado Springs, CO 80903
[phone]
[e-mail]
__/s/ Crystal J. McDonough_______
Crystal J. McDonough