request_number:  BPA-JCG:012
firstname:  Pamela
lastname:  Jacklin
e-mail:  pljacklin@stoel.com
exhibit_wp-02-e-:  JCG-02
page_numbers:  page 11, line 13 - page 18, line 10
request_text:  The JCG proposes to eliminate WP-02-E-BPA-65 and 
WP-02-E-BPA-74, except for page 1, lines 1-22 and page 8, line 4 to page 9, 
line 17.  The JCG, however, has filed testimony on the same central issue for 
which it finds BPA,s testimony objectionable.  Why is it necessary to 
eliminate either BPA,s or the JCG,s testimony when Section C.1. of the 
Partial Stipulation and Settlement Agreement provides that &no Party shall be 
deemed to have approved, admitted or consented to the facts, principles, 
methods or theories employed in arriving at the terms of this Partial 
Settlement Agreement or the Parties, Proposal, nor shall any party be deemed 
to have agreed that any provision of this Partial Settlement or Parties, 
Proposal is appropriate for resolving issues in any other proceeding 
regardless of whether the Parties, Proposal or Partial Settlement is adopted 
by the Administrator, except as expressly provided in this Partial 
Settlement8?  Please provide a complete explan!
at!
ion why it is absolutely necessary to eliminate any currently filed testimony 
and please provide any alternatives to eliminating such testimony considered 
by the JCG.
response_text:  OBJECTION

Data Request BPA-JCG:012 was not properly served and is otherwise 
objectionable.  The Joint Customer Group objects to the above Data Request, 
as it seeks information about why the Joint Customers contend that the 
testimony is inconsistent with the Partial Settlement.  Whether BPA's 
testimony is consistent or not with the Partial Settlement is not the proper 
subject of a data request.

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