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 
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8 has the meanings 
described below.  With respect to oral communications, &disclose and/or 
produce8 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8 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8 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8 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.

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, 
2001 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8 has the meanings 
described below.  With respect to oral communications, &disclose and/or 
produce8 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8 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8 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8 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.

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, 
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8 has the meanings 
described below.  With respect to oral communications, &disclose and/or 
produce8 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8 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8 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8 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:  Response DS-GE:001

Portland General Electric (PGE) objects to this Data Request on the grounds 
that it (i) seeks information that is not relevant; (ii) seeks information 
that is privileged; and (iii) seeks information that is unduly burdensome to 
produce.  Rules of Procedure Governing Rate Hearings, Section 1010.8(b).  PGE 
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.  Further, the Data Request PGE received in hard copy of March 9, 
2001 covered communications from October 16, 2001 to the present, of which 
there were none.  PGE hereby responds to the corrected Data Requests received 
March 14, 2001 covering communications from October 16, 2000 to the present. 
Without waiving the foregoing objections, PGE responds as follows:

 I reviewed my email archive (which is automatically emptied after two 
weeks), correspondence file and meeting notes and asked Lyn Williams to do 
the same.  I also questioned Ms. Williams about her recollections of any 
communications described in this Data Request.  Based on these inquiries and 
recollections, PGE reports the following communications:

1. On or about January 22, 2001, following a noticed settlement meeting, Pam 
Jacklin, Terry Mundorf and another party representative (I do not recall who) 
met with Alan Burns and Peter Burger in one of their offices to discuss 
whether BPA intended to file a supplemental proposal in this case.

2. During a Joint Customer Group testimony drafting session during the week 
of March 5, 2001 Lon Peters placed a telephone call to Bob Procter seeking 
clarification of BPA's intent with respect to treatment of transmission 
losses in the LB CRAC GRSPs.

3. Lyn Williams and/or Darcy Norville received the emails described below, 
copies of which are attached (emails that were sent or copied to the Service 
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: 
Settlement Signers.

4. 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.

5. 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.

Response DS-GE:002

Portland General Electric (PGE) objects to this Data Request on the grounds 
that it (i) seeks information that is not relevant; (ii) seeks information 
that is privileged; and (iii) seeks information that is unduly burdensome to 
produce.  Rules of Procedure Governing Rate Hearings, Section 1010.8(b).  PGE 
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.  Further, the Data Request PGE received in hard copy of March 9, 
2001 covered communications from October 16, 2001 to the present, of which 
there were none.  PGE hereby responds to the corrected Data Requests received 
March 14, 2001 covering communications from October 16, 2000 to the present. 
Without waiving the foregoing objections, PGE responds as follows:

I am aware of no communications responsive to this Data Request other than 
those disclosed in response to DS-GE:001.

Response DS-GE:003:

Portland General Electric (PGE) objects to this Data Request on the grounds 
that it (i) seeks information that is not relevant; (ii) seeks information 
that is privileged; and (iii) seeks information that is unduly burdensome to 
produce.  Rules of Procedure Governing Rate Hearings, Section 1010.8(b).  PGE 
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.  Further, the Data Request PGE received in hard copy of March 9, 
2001 covered communications from October 16, 2001 to the present, of which 
there were none.  PGE hereby responds to the corrected Data Requests received 
March 14, 2001 covering communications from October 16, 2000 to the present. 
Without waiving the foregoing objections, PGE responds as follows:

I am aware of no communications responsive to this Data Request other than 
those disclosed in response to DS-GE:001.







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