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Enron Mail |
request_number: DS-AC:001
firstname: Thomas lastname: DeBoer e-mail: tdeboer@painehamblen.com exhibit_wp-02-e-: JCG-01 and JCG-02 page_numbers: request_text: Amended Request No.: DS-AC:001 Request: Witnesses: Pamela Lesh, Robert E. Orton, Marilyn G. Showalter and W. Scott Brattebo, David W. Hoff, Kevin P. O'Meara, Lon L. Peters, Geoffrey H. Carr, and Marc H. Hellman, respectively Exhibit: WP-02-E-JCG-01 and WP-02-JCG-02 Please disclose and/or produce copies of any and all communications, from October 16, 2001 to the present, between any BPA representative and any representative of any other party, concerning any of the following subjects: a. The general structure of the Cost Recovery Adjustment Clauses (CRACs) described in the testimony of the Joint Customers; b. Any differences between the form of the CRACs described in the testimony of the Joint Customers and the CRACs contained in BPA's Amended Proposal; or those contained in BPA's Supplemental Proposal; c. The detailed mechanics of implementing the CRACs described in the testimony of the Joint Customers; d. Revenue effects of the CRACs described in the testimony of the Joint Customers, any modifications; or e. Any aspect of the Partial Stipulation and Settlement Agreement and the Parties' Proposal attached thereto. For purposes of this Request, "disclose and/or produce" has the meanings described below. With respect to oral communications, "disclose and/or produce" means to describe the time, date, approximate duration, and substantive content of the communication; the identity and organizational affiliation of the communicating individuals; whether the communication occurred in person or by telephone; the location of the communication if in person; the identity of any witnesses to the communications, including all individuals in the room if the communication occurred by speakerphone; and whether the communication was made in the presence of or after coordination with BPA counsel(if so, identify such counsel). For purposes of this Request, you need not "disclose and/or produce" oral communications that occurred during meetings noticed in compliance with Rate Case Rule 1010.7(d). With respect to written communications, the Request includes communications in any recorded form, whether on paper, electronic (including, without limitation, e-mails), or whatever form. For such communications, "disclose and/or produce" means to provide copies of all non-identical versions of any written communications and to describe with particularity the circumstances under which they were generated or referred to; and to fully "disclose and/or produce" any oral communications made in connection with the written communications consistent with the preceding paragraph. For purposes of this Request, you need not produce papers served on all parties to the rate case and made part of the official file in the rate case. response_text: Avista Corporation (Avista) objects to this Data Request on the grounds that it: (i) seeks information that is not relevant; and (ii) seeks information that is unduly burdensome to produce. (Rules of Procedure Governing Rate Hearings, Section 1010.8(b)). Avista further objects to this Data Request on the grounds that it is in improper form as it does not cite to specific testimony or indicate the specific use to which the information sought will be put. (Special Rules of Practice, WP-02-01). Without waiving the foregoing objections, Avista responds as follows: 1. Tom DeBoer either sent or received the following e-mails, copies of which are attached to this response (e-mails that were sent or copied to the Service List are not included below or attached): a. From Tom DeBoer to A.W. Turner et al., with a copy to Peter Burger, dated 2/7/01 Subject: Re: Joint Customer Meeting b. From Tom DeBoer to Peter Burger, dated 2/13/01 Subject: stipulation changes c. From Kevin Clark to Jeff Schlect et al. with a copy to Peter Burger, dated 2/7/01 Subject: Re: Joint Customer Meeting 2. On October 16, 2000 representatives of six Northwest Investor-owned Utilities sent a letter with comments on BPA's Proposed Amended FY 2002-2006 Power Rate Case to Syd Berwager, a copy of which is attached. 3. On October 16, 2000 representatives of five Northwest Investor-owned Utilities sent a letter with supplemental comments on the appropriate scope of the reopened WP-02 proceeding to Syd Berwager, a copy of which is attached. The following information is from the web server: 1. Logon: IUSR_GRANITE 2. Remote Host: border.paine-hamblen.com 3. Remote IP Address: 207.53.155.98 4. Form URL: https://secure.bpa.gov/power/secure/psp/ratecase/discovery/wp_02_response.html 5. Browser Client: Mozilla/4.7 [en] (Win95; I)
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