20190304PAC to IIPA WA UE-180778 PC-BWP.pdf

February 28, 2019
Lance Kaufman
4801 E. Yale Avenue Denver, CO 80219 [e-mail] (C)
Nina Suetake
Public Counsel Unit Office of Attorney General 800 Fifth Avenue, Suite 2000 Seattle, WA 98104
[e-mail] (C)
Tyler Pepple Davison Van Cleve, P.C. 1750 SW Harbor Way, Suite 450 Portland, OR 97201
[e-mail] (C)
RE: WA UE-180778
PC-BWP 1st Set Data Request (1-22) Please find enclosed Pacific Power & Light Company’s 6th Supplemental Response to PC-BWP Data Request 1. Also provided is Attachment to PC-BWP 1a-1 6th Supplemental. Provided on
the enclosed Confidential CD is Confidential Attachment PC-BWP 1a-2 6th Supplemental.
Information in Confidential Attachment PC-BWP 1a-2 is confidential per the protective order in WUTC Docket UE-180778. The company’s responses include confidential documents produced in a state other than Washington. Those documents are provided without alteration, including the markings required in the state in which they were produced or filed. Certain information
included in those documents is confidential and subject to the protective order issued in UE-
180778. If a party files any of those documents, the party must comply with the requirements of the protective order or seek waiver of any applicable regulations regarding the specific marking of materials required under the protective order. If you have any questions, please call me at 503-813-5410. Sincerely,

__/s/___ Ariel Son Regulatory Affairs Manager
Enclosures
C.c. Matthew Gerhart/Sierra Club [e-mail] (C) Ana Boyd/Sierra Club [e-mail] (C) David Panco/WUTC [e-mail] (C) Nash Callaghan/WUTC [e-mail] (C)
UE-180778 / Pacific Power & Light Company
February 28, 2019 PC-BWP Data Request 1 – 6th Supplemental PC-BWP Data Request 1
Please provide copies of any and all data requests submitted to you by any party to the following proceedings and your corresponding responses to those data requests. This is an ongoing request:
(a) Public Utility Commission of Oregon Docket No. UM 1968;
(b) Washington Utilities and Transportation Commission Filing Docket UE-180778;
(c) Idaho Public Utilities Commission Case No. PAC-E-18-08;
(d) Wyoming Public Service Commission Docket No. 20000-539-EA-18; and (e) Utah Public Service Commission Docket No. 18-035-36.
6th Supplemental Response to PC-BWP Data Request 1 PacifiCorp continues to object to this request as overly broad, unduly burdensome, and outside the scope of this proceeding. Without waiving any objections, the company responds as follows:
(a) Please refer to Attachment PC-BWP 1a-1 6th Supplemental and Confidential Attachment PC-BWP 1a-2 6th Supplemental.
(b) PC-BWP will be provided copies of discovery on an ongoing basis.
(c) There has been no additional discovery in Idaho. (d) There has been no additional discovery in Wyoming.

(e) There has been no additional discovery in Utah. The company does not waive any objections raised in the data request responses included in the attachments.
Going forward, PC-BWP will be provided supplemental responses to this data request as requests and responses are received. Information in Confidential Attachment PC-BWP 1a-2 is confidential per the protective order in WUTC Docket UE-180778. The company’s responses include
confidential documents produced in a state other than Washington. Those
Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently disclosed information.
UE-180778 / Pacific Power & Light Company
February 28, 2019 PC-BWP Data Request 1 – 6th Supplemental documents are provided without alteration, including the markings required in the
state in which they were produced or filed. Certain information included in those
documents is confidential and subject to the protective order issued in UE-180778. If a party files any of those documents, the party must comply with the requirements of the protective order or seek waiver of any applicable regulations regarding the specific marking of materials required under the protective order.

PREPARER: Kaley McNay SPONSOR: Not Applicable
Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently disclosed information.