WP-02 Data Response

request_number: DS-AC:003
firstname: Thomas
lastname: DeBoer
e-mail: tdeboer@painehamblen.com
exhibit_wp-02-e-: JCG-01 and JCG-02
page_numbers:
request_text: Please disclose and/or produce any and all communcations
from October 16, 2001 to the present, between any of the
party 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 these rate 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 duraction, and substantive
content of the communicatoin; 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 cousnel). 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: There have been no communications from October 16, 2001
forward. We have received your amendment to this data
request via e-mail but have not yet received a hard copy.
Once we receive the hard copy, we will respond within
seven (7) days, as set forth in WP-02-O-05.

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