20181212PAC to IIPA Attach 1d OCA Set 1.docx

BEFORE THE PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF ROCKYMOUNTAIN POWER’S APPLICATIONFOR AN ORDER AUTHORIZING ACHANGE IN DEPRECIATION RATESAPPLICABLE TO ELECTRICPROPERTY
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20000-539-EA-18
(Record No. 15095)
OFFICE OF CONSUMER ADVOCATE’S FIRST SET OF DATA REQUESTS
Submitted:November 20, 2018
COMES NOW the Office of Consumer Advocate, and hereby serves its First set of data requests regarding the above docketed 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 Christopher Leger, OCA Counsel, 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 responses to any and all past, present, and future data requests served upon the Company by any and all parties to this proceeding, as well as those served upon the Company by the staff of the Wyoming Public Service Commission.
Data Request 1.2:Please provide a copy of all discovery requests (including the responses) served on the Company from intervenors in Washington, Oregon, Utah and Idaho in their respective 2018 Depreciation Cases.
DATED:Tuesday, November 20, 2018
_______________________________
Christopher Leger,Counsel # 6-3963
Wyoming Office of Consumer Advocate
2515 Warren Avenue, Suite 304
Cheyenne, WY 82002
[e-mail] OF SERVICEI hereby certify that on November 20th 2018, I served the foregoing OCA First Set of Discovery Requestsby delivering copies thereof to the following individuals/entities below, by e-mail:
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
Rocky Mountain Power
315 W. 27th St.
Cheyenne, Wyoming 82001
[e-mail]
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 W. North Temple
Salt Lake City, Utah 84116
[e-mail]
D. Matthew Moscon
Lauren A. Shurman
Stoel Rives LLP
201 South Main Street, Suite 1100
Salt Lake City, Utah 84111
[e-mail]
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
[e-mail]
Thorvald A. Nelson
Michelle B. King
Abigail C. Briggerman
Holland & Hart LLP
6380 South Fiddler’s Green Circle, Suite 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Shannon Anderson
Staff Attorney
Powder River Basin Resource Council
934 N. Main St.
Sheridan, WY 82801
[e-mail]