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request_number: DS-GE:001-003
firstname: Darcy lastname: Norville e-mail: darcy@tonkon.com exhibit_wp-02-e-: JCG-01 and -02 page_numbers: not specified request_text: Request DS-GE:001 Please disclose and/or produce copies of any and all communications, from= =20 October 16, 2001 to the present, between any BPA representative and any=20 representative of any other party, concerning any of the following subjects= : a. The general structure of the Cost Recovery Adjustment Clauses (CRACs)=20 described in the testimony of the Joint Customers; b. Any differences between the form of the CRACs described in the testimony= =20 of the Joint Customers and the CRACs contained in BPA=01,s Amended Proposal= , or=20 those contained in BPA=01,s Supplemental Proposal; c. The detailed mechanics of implementing the CRACs described in the=20 testimony of the Joint Customers; d. Revenue effects of the CRACs described in the testimony of the Joint=20 Customers, any modifications; or e. Any aspect of the Partial Stipulation and Settlement Agreement and the= =20 Parties=01, Proposal attached thereto. For purposes of this Request, =01&disclose and/or produce=018 has the meani= ngs=20 described below. With respect to oral communications, =01&disclose and/or= =20 produce=018 means to describe the time, date, approximate duration, and=20 substantive content of the communication; the identity and organizational= =20 affiliation of the communicating individuals; whether the communication=20 occurred in person or by telephone; the location of the communication if in= =20 person; the identity of any witnesses to the communications, including all= =20 individuals in the room if the communication occurred by speakerphone; and= =20 whether the communication was made in the presence of or after coordination= =20 with BPA counsel (if so, identify such counsel). For purposes of this=20 Request, you need not =01&disclose and/or produce=018 oral communications t= hat=20 occurred during meetings noticed in compliance with Rate Case Rule 1010.7(d= ). With respect to written communications, the Request includes communications= =20 in any recorded form, whether on paper, electronic (including, without=20 limitation, e-mails), or whatever form. For such communications, =01&discl= ose=20 and/or produce=018 means to provide copies of all non-identical versions of= any=20 written communications and to describe with particularity the location wher= e=20 such communications were found and/or stored, including the identity of the= =20 individual with possession or control of the written communications; to=20 describe with particularity the circumstances under which they were generat= ed=20 or referred to; and to fully =01&disclose and/or produce=018 any oral=20 communications made in connection with the written communications consisten= t=20 with the preceding paragraph. For purposes of this Request, you need not= =20 produce papers served on all parties to the rate case and made part of the= =20 official file in the rate case. Request No.: DS-GE:002 Request: Exhibit: Direct Testimony of the Joint Customer Group Please disclose and/or produce any and all communications from October 16,= =20 2001 to the present, between the BPA representatives listed below and any= =20 representative of any other party concerning BPA=01,s rates to be in effect= for=20 Fiscal Years 2002-2006, the interactions of such rates and customer=20 contracts, or procedural aspects of these rate proceedings. Bob Proctor Tim McCoy Byrne Lovell Byron Keep Valerie Lefler Jon Wright Peter Berger For purposes of this Request, =01&disclose and/or produce=018 has the meani= ngs=20 described below. With respect to oral communications, =01&disclose and/or= =20 produce=018 means to describe the time, date, approximate duration, and=20 substantive content of the communication; the identity and organizational= =20 affiliation of the communicating individuals; whether the communication=20 occurred in person or by telephone; the location of the communication if in= =20 person; the identity of any witnesses to the communications, including all= =20 individuals in the room if the communication occurred by speakerphone; and= =20 whether the communication was made in the presence of or after coordination= =20 with BPA counsel (if so, identify such counsel). For purposes of this=20 Request, you need not =01&disclose and/or produce=018 oral communications t= hat=20 occurred during meetings noticed in compliance with Rate Case Rule 1010.7(d= ). With respect to written communications, the Request includes communications= =20 in any recorded form, whether on paper, electronic (including, without=20 limitation, e-mails), or whatever form. For such communications, =01&discl= ose=20 and/or produce=018 means to provide copies of all non-identical versions of= any=20 written communications and to describe with particularity the location wher= e=20 such communications were found and/or stored, including the identity of the= =20 individual with possession or control of the written communications; to=20 describe with particularity the circumstances under which they were generat= ed=20 or referred to; and to fully =01&disclose and/or produce=018 any oral=20 communications made in connection with the written communications consisten= t=20 with the preceding paragraph. For purposes of this Request, you need not= =20 produce papers served on all parties to the rate case and made part of the= =20 official file in the rate case. Request No.: DS-GE:003 Request: Exhibit: Direct Testimony of the Joint Customer Group Please disclose and/or produce any and all communications from October 16,= =20 2001 to the present, between any of the party representatives listed below= =20 and any representative of BPA concerning rates to be in effect for BPA=01,s= =20 Fiscal Years 2002-2006, the interactions of such rates and customer=20 contracts, or procedural aspects of rate these proceedings. Terry Mundorf (WPAG) Lon Peters (PGP) Linc Wolverton (ICNU) Scott Brattebo (PacifiCorp) Kevin Clark (Seattle City Light) David Hoff (PSE) Geoff Carr (Northwest Requirements Utilities) Dennis Parrish (Market Access Coalition Group) Pam Jacklin (PacifiCorp) Peter Richardson (PPC) Kyle Sciuchetti (PPC) Ray Kindley (PGP) Jay Waldron (PGP) Doug Brawley (PNGC) Eric Johnson (PNGC) Darcy Norville (PGE) Lynn Williams (PGE) Steve Weiss (Northwest Energy Coalition) Mark Hellman (OPUC) For purposes of this Request, =01&disclose and/or produce=018 has the meani= ngs=20 described below. With respect to oral communications, =01&disclose and/or= =20 produce=018 means to describe the time, date, approximate duration, and=20 substantive content of the communication; the identity and organizational= =20 affiliation of the communicating individuals; whether the communication=20 occurred in person or by telephone; the location of the communication if in= =20 person; the identity of any witnesses to the communications, including all= =20 individuals in the room if the communication occurred by speakerphone; and= =20 whether the communication was made in the presence of or after coordination= =20 with BPA counsel (if so, identify such counsel). For purposes of this=20 Request, you need not =01&disclose and/or produce=018 oral communications t= hat=20 occurred during meetings noticed in compliance with Rate Case Rule 1010.7(d= ). With respect to written communications, the Request includes communications= =20 in any recorded form, whether on paper, electronic (including, without=20 limitation, e-mails), or whatever form. For such communications, =01&discl= ose=20 and/or produce=018 means to provide copies of all non-identical versions of= any=20 written communications and to describe with particularity the location wher= e=20 such communications were found and/or stored, including the identity of the= =20 individual with possession or control of the written communications; to=20 describe with particularity the circumstances under which they were generat= ed=20 or referred to; and to fully =01&disclose and/or produce=018 any oral=20 communications made in connection with the written communications consisten= t=20 with the preceding paragraph. For purposes of this Request, you need not= =20 produce papers served on all parties to the rate case and made part of the= =20 official file in the rate case. response_text: Response DS-GE:001 Portland General Electric (PGE) objects to this Data Request on the grounds= =20 that it (i) seeks information that is not relevant; (ii) seeks information= =20 that is privileged; and (iii) seeks information that is unduly burdensome t= o=20 produce. Rules of Procedure Governing Rate Hearings, Section 1010.8(b). P= GE=20 further objects to this Data Request on the grounds that it is in improper= =20 form as it does not cite to specific testimony or indicate the specific use= =20 to which the information sought will be put. Special Rules of Practice,=20 WP-02-01. Further, the Data Request PGE received in hard copy of March 9,= =20 2001 covered communications from October 16, 2001 to the present, of which= =20 there were none. PGE hereby responds to the corrected Data Requests receiv= ed=20 March 14, 2001 covering communications from October 16, 2000 to the present= .=20 Without waiving the foregoing objections, PGE responds as follows: I reviewed my email archive (which is automatically emptied after two=20 weeks), correspondence file and meeting notes and asked Lyn Williams to do= =20 the same. I also questioned Ms. Williams about her recollections of any=20 communications described in this Data Request. Based on these inquiries an= d=20 recollections, PGE reports the following communications: 1. On or about January 22, 2001, following a noticed settlement meeting, Pa= m=20 Jacklin, Terry Mundorf and another party representative (I do not recall wh= o)=20 met with Alan Burns and Peter Burger in one of their offices to discuss=20 whether BPA intended to file a supplemental proposal in this case. 2. During a Joint Customer Group testimony drafting session during the week= =20 of March 5, 2001 Lon Peters placed a telephone call to Bob Procter seeking= =20 clarification of BPA's intent with respect to treatment of transmission=20 losses in the LB CRAC GRSPs. 3. Lyn Williams and/or Darcy Norville received the emails described below,= =20 copies of which are attached (emails that were sent or copied to the Servic= e=20 List are not included below or attached): a. From Dave Piper to Lyn Williams et al., dated 1/26/01, Subject: Re: Urgent: Potential Substantial Rate Increase; b. From Kyle Sciuchetti to A. W. Turner et al., dated 2/16/01, Subject:=20 Settlement Signers. 4. On October 16, 2000 representatives of six Northwest Investor-owned=20 Utilities sent a letter with comments on BPA's Proposed Amended FY 2002-200= 6=20 Power Rate Case to Syd Berwager, a copy of which is attached. 5. On October 16, 2000 representatives of five Northwest Investor-owned=20 Utilities sent a letter with supplemental comments on the appropriate scope= =20 of the reopened WP-02 proceeding to Syd Berwager, a copy of which is attach= ed. Response DS-GE:002 Portland General Electric (PGE) objects to this Data Request on the grounds= =20 that it (i) seeks information that is not relevant; (ii) seeks information= =20 that is privileged; and (iii) seeks information that is unduly burdensome t= o=20 produce. Rules of Procedure Governing Rate Hearings, Section 1010.8(b). P= GE=20 further objects to this Data Request on the grounds that it is in improper= =20 form as it does not cite to specific testimony or indicate the specific use= =20 to which the information sought will be put. Special Rules of Practice,=20 WP-02-01. Further, the Data Request PGE received in hard copy of March 9,= =20 2001 covered communications from October 16, 2001 to the present, of which= =20 there were none. PGE hereby responds to the corrected Data Requests receiv= ed=20 March 14, 2001 covering communications from October 16, 2000 to the present= .=20 Without waiving the foregoing objections, PGE responds as follows: I am aware of no communications responsive to this Data Request other than= =20 those disclosed in response to DS-GE:001. Response DS-GE:003: Portland General Electric (PGE) objects to this Data Request on the grounds= =20 that it (i) seeks information that is not relevant; (ii) seeks information= =20 that is privileged; and (iii) seeks information that is unduly burdensome t= o=20 produce. Rules of Procedure Governing Rate Hearings, Section 1010.8(b). P= GE=20 further objects to this Data Request on the grounds that it is in improper= =20 form as it does not cite to specific testimony or indicate the specific use= =20 to which the information sought will be put. Special Rules of Practice,=20 WP-02-01. Further, the Data Request PGE received in hard copy of March 9,= =20 2001 covered communications from October 16, 2001 to the present, of which= =20 there were none. PGE hereby responds to the corrected Data Requests receiv= ed=20 March 14, 2001 covering communications from October 16, 2000 to the present= .=20 Without waiving the foregoing objections, PGE responds as follows: I am aware of no communications responsive to this Data Request other than= =20 those disclosed in response to DS-GE:001. The following information is from the web server: 1. Logon: IUSR_GRANITE 2. Remote Host: 206.29.168.129 3. Remote IP Address: 206.29.168.129 4. Form URL: =20 http://www.bpa.gov/power/secure/psp/ratecase/discovery/wp_02_response.html 5. Browser Client: Mozilla/4.0 (compatible; MSIE 5.0; Windows NT; DigExt)
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