WP-02 Data Response

request_number: DS-PS:001-003
firstname: Steve
lastname: Marshall
e-mail: marss@perkins.com
exhibit_wp-02-e-: JCG01 and 02
page_numbers:
request_text: DS-PS:001 Please disclose and/or produce copies of any and all
communications, from October 16, 2000 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 location where
such communications were found and/or stored, including the identity of the
individual with possession or control of the written communications; 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.

DS-PS:002: Please disclose and/or produce any and all communications from
October 16, 2000 to the present, between the BPA representatives listed below
and any representative of any other party concerning BPA's rates to be in
effect for Fiscal Years 2002-2006, the interactions of such rates and
customer 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, "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 location where
such communications were found and/or stored, including the identity of the
individual with possession or control of the written communications; 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.

DS-PS:003: Please disclose and/or produce any and all communications from
October 16, 2001 to the present, between any of the party representatives
listed below and any representative of BPA concerning rates to be in effect
for BPA's Fiscal Years 2002-2006, the interactions of such rates and customer
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, "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 location where
such communications were found and/or stored, including the identity of the
individual with possession or control of the written communications; 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: DS-PS:001: PSE refers to and incorporates the response from
PacifiCorp, including the following objection to the data request, as follows:

"PacifiCorp objects to this Data Request on the grounds that it (1) seeks
information that is not relevant and (2) seeks information that is unduly
burdensome to produce. (Rules of Procedure Governing Rate Hearings, Section
1010.8(b).) PacifiCorp 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 to information sought will be put.
(Special Rules of Practice, WP-02-O-01.) Without waiving the foregoing
objections, we respond as follows in the below attached exhibits:

For oral communications, see Exhibit 1.

For written communications, see Exhibit 2."

DS-PS:002: PSE refers to and incorporates
the response from PacifiCorp, including the following objection to the data
request, as follows:

"PacifiCorp objects to this Data Request on the grounds that it (1) seeks
information that is not relevant and (2) seeks information that is unduly
burdensome to produce. (Rules of Procedure Governing Rate Hearings, Section
1010.8(b).) PacifiCorp 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 to information sought will be put.
(Special Rules of Practice, WP-02-O-01.) Without waiving the foregoing
objections, we respond as follows in the below attached exhibits:

For oral communications, see Exhibit 1.

For written communications, see Exhibit 2."

DS-PS:003:
PSE refers to and incorporates the response from PacifiCorp, including the
following objection to the data request, as follows:

"PacifiCorp objects to this Data Request on the grounds that it (1) seeks
information that is not relevant and (2) seeks information that is unduly
burdensome to produce. (Rules of Procedure Governing Rate Hearings, Section
1010.8(b).) PacifiCorp 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 to information sought will be put.
(Special Rules of Practice, WP-02-O-01.) Without waiving the foregoing
objections, we respond as follows in the below attached exhibits:

For oral communications, see Exhibit 1.

For written communications, see Exhibit 2."

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