Enron Mail

From:marss@perkinscoie.com
To:abuckley@wutc.wa.gov, alan@epud.org, ali.rodol@ci.seattle.wa.us,archive-power-ratecase@bpa.gov, aw_turner@pgn.com, bassl@sce.com, bessex@cowlitzpud.org, bferranti@mbllp.com, bpadiscovery@merkellaw.com, ccopatrny@e-z.net, crow@millernash.com, cub@tel
Subject:WP-02 Data Request
Cc:
Bcc:
Date:Tue, 3 Apr 2001 07:19:00 -0700 (PDT)

request_number: PS-BPA:117, 119, 120, 121 and 122-
firstname: Steve
lastname: Marshall
e-mail: marss@perkinscoie.com
directed_to: Peter J. Burger - LP-7
Office of General Counsel
Bonneville Power Administration
P.O. Box 3261
Portland, Oregon 97208-3621
exhibit_wp-02-e-: BPA-75
page_numbers: 4
request_text: PS-BPA:117, page 4, lines 6-7: Beginning at line 6 the=20
witnesses state =01&Tiered rates may be good for both BPA and the Northwest=
=20
region, and should properly be explored=018. How do you propose properly=
=20
exploring tiered rates?

PS-BPA:119, page 4, lines 3-4: Beginning at line 3 the witnesses state=20
=01&During these unprecedented market conditions, BPA will continue to expl=
ore=20
every potential avenue for finding solutions that are both fair and=20
practical.=018 Please give examples of such potential avenues. Would a ch=
ange=20
in base rates during the five-year rate period be one such avenue? Would a=
=20
change in the manner in which the CRACs are applied during the five-year ra=
te=20
period be one such avenue?

PS-BPA:120, page 4, lines 3-6: Beginning at line 3 the witnesses state=20
=01&During these unprecedented market conditions, BPA will continue to expl=
ore=20
every potential avenue for finding solutions that are both fair and=20
practical. This certainly would not exclude tiered rates, though the regio=
n=01,
s historically strong opposition to tiered rates is a factor that cannot be=
=20
ignored=018. Does the language =01&will continue=018 mean that BPA is curr=
ently=20
exploring the use of tiered rates as a potential avenue for finding=20
solutions? If so, please provide all data, analysis and communications tha=
t=20
make up this exploration.

PS-BPA:121, page 4, lines 5-6: Beginning at line 5 the witnesses state =01=
& . .=20
. though the region=01,s historically strong opposition to tiered rates . .=
.=018. =20
Please provide all bases for this statement.

PS-BPA:122, page 4, lines 5-6: Beginning at line 5 the witnesses state =01=
& . .=20
. though the region=01,s historically strong opposition to tiered rates . .=
.=018. =20
Please describe your use of the term =01&region=018. Do you mean to imply =
that the=20
opposition was a consensus of all parties in the region? If so, how did th=
is=20
consensus manifest itself? If not, what parties composed this opposition?
contact_name: Steve Marshall
contact_address: Perkins Coie
One Bellevue Center, Suite 1800
411 - 108th Avenue N.E.
Bellevue, WA 98004
contact_phone: 425-453-7314
contact_email: marss@perkinscoie.com
contact_fax: 425-453-7350
delivery_instructions: Please mail hard coies of data responses to Steve=
=20
Marshall at the address above

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