20130730Affidavit Brad Purdy.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17ft St.
Boise,ID. 83702
[phone]
FAX: [phone]
[e-mail]
Attorney for Intervenor
Community Action Partnership
Association of Idaho
nt' o. rJ-.'rl. fl-..1 J
BEFORE TIIE IDAHO PUBLIC UTILITIES COMIVtrSSION
IN TIIE MATTER OT THE APPLICATION )
oF PACIFTCORP DBA ROCKY MOUNTATN )
POWER TO TMTTATE DTSCUSSIONS WITH )
INTERESTED PARTIES ON ALTERNATWE )
RATE PLAIY PROPOSALS
Affiant being first duly swom upon oatfu hereby deposes and states as follows:
l. That he is legal counsel of record for the Community Action Partrership Association of
Idaho (CAPAI) and, as suctl possesses sufficient information and knowledge to attest to
the statements set forth herein.
That attached to this Affidavit as Exhibit "A" is a tnre and correct copy of an email
received by Affrant from Mr. Ted Weston on April 29,2013.
That attached to this AfEdavit as Exhibit uB" is a true and correct copy of the Word
document attached to Exhibit A.
That attached to this Affidavit as Exhibit C is a true and correct copy of an email received
by Affrant from Mr. Ted Weston on May 2,2013.
CASE NO. PAC.E.B-o4
AFFIDAVIT OF BRAD M.PURDY
IN SUPPORT OF MOTION TO
COMPEL
)
)
)
)
3.
4.
AFFIDAVIT OF BRAD M. PURDY
5.
6.
That attached to this Affidavit as Exhibit nD" is an email received by Affiant from Ms.
Kaley McNay on May 29,2013.
That attached to this Affidavit as Exhibit "E" is the Word document attached to Exhibit
D.
FURTHER your affiant saith not.
DATED this 30H day of July, 2013.
SLJBSCRIBED Al.lD SWORN TO before me this 306 day of July, 2013.
Residing at Boise, AdaCounty
My Commission expires:
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AFFIDAVIT OF BRAD M. PURDY
CERTIFICATE OF SERVICE
I, the undersigned, hereby certiff ttrat on the 30th day of July,20l3,I served a copy of
the foregoing document on the following by electronic mail and U.S. Postage, first class.
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
ted.weston@pacifi corp.com
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
daniel. solander@pacifi corp.com
Electronic Service Only:
Data Request Response Center
PacifiCorp
datarequest@pacifi corp.com
Neil Price
Deputy Attorney General
Idatro Public Utilities Commission
472 W, Washington (837 02)
P0 Box 83720
Boise, lD 83720-0074
neil.price@puc. idaho. eov
Randall C. Budge
Racine, Olson, Nyc, Budge & Bailey
201 E. Center
P0 Box l39l
Pocatello, ID 83204-1 391
E-Mail: [e-mail]
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
bcol I ins@consu ltbai.com
James R. Smith
Monsanto Company
P.O. Box 816
SodaSprings, ID 83276
Jim.r. [e-mail]
AFFIDAVIT OF BRAD M. PURDY
Eric L. Olsen
ASSOCIATION,INC: Racine, Olson,Nye, Budge & Bailey
@xhibitNos.30 l-400) 201F,. Center
P0 Box 1391
Pocatello, ID 83204- 139 I
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village,OH44140
tony@.yankel.net
Benjamin J. Otto
Idaho Conservation League
710 N. 6tr St.
Boise,ID 83702
botto @ idahoconservation. org
Ronald Williams
Williams Bradbury, P.C.
l0l5 W. Hays St.
Boise, D 83702
ron@wi I I iamsbradbury.com
Don Schoenbeck
RCS,Inc.
900 Washington St., Suite 780
Vancouveq WA 98660
[e-mail]
Tim Buller
Agrium,Inc.
3010 CondaRd.
Soda Springs, ID 83276
[e-mail]
Ken Miller
Snake RiverAlliance
Box 1731
Boise,ID 83701
E-Mail : kmiller@,snalteriveralliance.org
4AFFIDAVIT OF BRAD M. PURDY
Brad M. Purdy
Outlook Print Message Page 1 of I
EXHIBIT A
Case PAC-E-13-04: CAPAI Discovery
From : brad purdy ([e-mail])
Sent: Mon4l29ll3 4:13 PM
To: TedWeston([e-mail])
I attachment
CAPAI Discovery.docx (13.8 KB)
Hi Ted: Per our phone call earlier today, I am attaching via a Word doc, CAPAI's discovery requests in
the above-referenced case. You agreed that it makes sense for all parties to submit their discovery
requests directly to you and informally via email to expedite the Company's ability to respond to same,
ideally prior to this Thursday's second settlement conference. Given the nature of CAPAI's discovery, it
is possibly not possible for you to provide a response that quickly, but it will give you an idea of what
issues and information my client is potentially interested in raising and delving into. Please do not
hesitate to contact me should you have any questions or suggestions on how to provide the requested
information as easily and expeditiously as possible. Thanks Ted. bp
Brad M. Purdy Attorney at Law
2019 N. 17th St.
Boise, lD 83702
208-384-1299 Land
208-484-9980 Cell
208-384-8511 Fax
[e-mail]
https://sntl38.mail.live.com/mail/PrintMessages.aspx?cpids:fdb49553-bl l9-lle2-adf9-18... 712812013
EXHlBlr B
TO:
FROM:
DATE:
Re:
TED WESTON
BRAD PT]RDY
April29,2013
Case PAC-E-13-04: CAPAI Discovery Requests
l. How many of Rocky Mountain Power's (RMP's) Idaho Residential class customers
received LIHEAP benefits during the test year for which the general rate case application, if filed
in this proceeding, will be based upon? Please note that in all subsequent discovery where the
term "test year" is found is to be defined identically to that stated in this request.
2. How many of RMP's Idaho Residential class customers received benefits under the
Company's Low-Income Weatherization (LIWA) program?
3. Please calculate the total number of RMP customers who receive either LIHEAP or
LIWA benefits during the test year. In making this calculation, please count customers who
receive both LIHEAP and LIWA only once (hereinafter referred to as RMP's "low-income
customer proxy group").
4. Please provide the actual monthly consumption during the test year of all customers
included in the low-income proxy group.
5. Please provide the actual monthly consumption during the test year of the Company's
Residential class customers excluding those customers included in the low-income proxy group.
6. Using the Company's low-income proxy group, and based on actual monthly test year
data as referred to in Request No.4, please make the following rate design model runs:
a. Calculate the effects on the low-income customer proxy group's monthly bills if
the Company's monthly basic charge were increased from its current level to $10, $15 and to
$20, (assuming no changes to the existing commodity rates for the Residential class's two-tiered
rate). In responding to this request, please make the requested calculations at existing rates
during the test year.
b. Assuming no change to the Company's existing monthly basic charge, calculate
the effects on the low-income proxy groups' monthly bills in comparison to non-low income
residential customers (using test year actual monthly consumption) if the existing two-tiered rate
design is changed such that the consumption amount of the first tier is increased from the
existing 700 kwh sunmer block to 800 kWh/month, 1000 kWh and 1200 kwh. Please provide
the same data for the winter block of 1000 kWh if the block were changed to 800 kwh, 1200
kWh and 1400 kWh.
Ouflook Print Message Page I ofl
EXI.IIBff C
Fhd: Responses for Brad Purdy
From: Weston, Ted ([e-mail]) You moved this message to its current
location.
Sent: T}iu5l02ll3 8:37 AM
To: Brad M. Purdy ([e-mail])
5 attachments
CAPAI 5.doc (43.5 KB) . CAPAI l.doc (35.0 KB) , CAPAI 2.doc (35.0 KB).
CAPAI 3.doc (35.0 KB) , CAPAI4.doc (45.5 KB)
Brad
Attached are responses 1-5 question 6 will take sometime. See you later this moming.
Ted Weston
Sent from my Verizon \Mreless 4G LTE Smartphone
--- Fonrarded message ---
From : "Bell, Barry" < Barry. Bell@pacifi corp. com>
To:'Weston, Ted" <Ted.Weston@pacifi corp.com>, "Solander, Daniel"
<Daniel. Solander@pacifi corp. com>
Subject Responses for Brad Purdy
Date: Wed, May 1,2013 5:41 PM
Ted and Daniel: Attached are responses to CAPAI 1-5 for Brad Purdy. Please review and if you're okay
with them, please provide directly to Brad at settlement tomorrow. The documents are locked. lf you
see something that needs to be changed, please e-mail me; l'll change and send back to you. Otherwise
you can provide responses to Brad as is, including fonrarding to him electronically.
https://snt138.mail.live.com/mail/PrintMessages.aspx?cpids:c3 e2af57-b335-lle2-9920-00... 712912013
Outlook Print Message Page I of2
ID PAC-E-13-04 Rocky Mountain Powerrs Response to EXHBIT p
CAPAI 6
From: McNay, Kaley ([e-mail]) You moved this message to its
current location.
Sent: Wed5l29ll3 ll:45 AM
To:'Randy Budge' ([e-mail]);
'[e-mail]' ([e-mail]) ;
'[e-mail]' ([e-mail]);
'j [e-mail]' ( [e-mail]);
'robert. l. [e-mail]' (robert. l. geddes@monsanto. com) ; Price, Neil (ID
PUC) ([e-mail]); tony @yankel.net ([e-mail]);'dws@-c-s-
inc.com' ([e-mail]); [e-mail]
([e-mail]); [e-mail] ([e-mail]);
[e-mail] ([e-mail]); [e-mail]
([e-mail]); [e-mail]
([e-mail]); [e-mail] ([e-mail])
Cc: Watkins, Betsy @[e-mail]); Bell, Barry
@[e-mail]); C&T Discovery ([e-mail]); Weston,
Ted (Ted. Weston@pacifi corp.com); Solander, Daniel
([e-mail]) ; Data Request Response Center
(datareq@pacifi corp. com)
2 attachments
CAPAI DR 6.docx (23.7 KB) . Attach CAPAI DR 6a.xlsx (34.6 KB)
Attached above is Rocky Mountain Powe/s Response to CAPAI 5 in lD PAC-E-13-04. Please let me know
if you have any trouble opening the attached file(s).
Thank you,
Kaley McNay
Coordinator, Regulatory Operations
503-813-6257
https://sntl38.mail.live.com/maiVPrintMessages.aspx?cpids:85b9c18b-c887 -lle2-975b-0... 7129/2013
PAC-E-I 3-04lRocky Mountain Power
May,2013
CAPAI DataRequest 6
CAPAI Data Request 6
ExlilBt'ir E
Using the Company's low-income proxy gfoup, and based on actual monthly test
year data,as referred to in Request No.4, please make the following rate design
model runs:
a. Calculate the effects on the low-income customer proxy group's
monthly bills ifthe Company's monthly basic charge were increased from its
current level to $10, $15 and to $20, (assuming no changes to the existing
commodity rates for the Residential class's two-tiered rate). In responding to this
request, please make the requested calculations at existing rates during the test
year.
b. Assuming no change to the Company's existing monthly basic
charge, calculate the effects on the low-income proxy groups' monthly bills in
comparison to non-low income residential customers (using test year actual
monthly consumption) if the existing two-tiered rate design is changed such that
the consumption amount of the first tier is increased from the existing 700 kwh
summer block to 800 kWh/month, 1000 kwh and 1200 kWh. Please provide the
same data for the winter block of 1000 kWh if the block were changed to 800
kWb" 1200 kWh and 1400 kWh.
Response to CAPAIData Request 6
Please refer to Attachment CAPAI DR 6a for the requested monthly bill
impact analysis for the low-income customer proxy group who were under
Schedule I un2012.
The Company has not perfomred the two-tieredrate designanalysis requested
by CAPAI.As specified in paragraph 18 ofthe Stipulation if CAPAI is party
to the Stipulation the Company agrees to participate in a collaborative rate
design process to evaluate altematives.
Record holder: James 7-hary
Sponsor: Joelle Steward