BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of (U 901 E) for an Expedited Order Authorizing Special Charges and Tariffs for Smart Meter Opt-Out and Privacy/Data Release Programs Related to Advanced Metering Infrastructure Deployment. Application No (Filed August 10, 2017) MOTION OF (U 901 E) TO ADMIT INTO THE RECORD PREVIOUSLY SERVED DIRECT AND REBUTTAL TESTIMONY AND ACCOMPANYING EXHIBITS Cynthia Hansen Mifsud 825 N.E. Multnomah St., Suite 1800 Portland, OR Telephone: (503) Facsimile: (503) Dated: May 23, 2018 Attorney for PacifiCorp

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of (U 901 E) for an Expedited Order Authorizing Special Charges and Tariffs for Smart Meter Opt-Out and Privacy/Data Release Programs Related to Advanced Metering Infrastructure Deployment. Application No (Filed August 10, 2017) MOTION OF (U 901 E) TO ADMIT INTO THE RECORD PREVIOUSLY SERVED DIRECT AND REBUTTAL TESTIMONY AND ACCOMPANYING EXHIBITS In accordance with Rule 13.8(c) of the Commission s Rules of Practice and Procedure, PacifiCorp, d/b/a Pacific Power (PacifiCorp), submits this motion to admit into the record of this proceeding (Motion) PacifiCorp s previously served direct and rebuttal testimony and accompanying exhibits. I. TESTIMONY AND EXHIBITS SUBJECT TO THIS MOTION PacifiCorp respectfully requests that the Commission admit the following previously served direct and rebuttal testimony and exhibits in support of Application (A.) into the record of this proceeding: Exhibit No. Title Party Date Served Witness PAC/100 PAC/101 Direct Testimony of Michael S. Cochran PacifiCorp Smart Meter Security Overview PacifiCorp August 10, 2017 M. Cochran PacifiCorp August 10, 2017 M. Cochran - 1 -

3 PAC/102 Test Specification and PacifiCorp August 10, 2017 M. Cochran Statement of Work for AMI Deployment Equipment Validation PAC/200 Direct Testimony of PacifiCorp August 10, 2017 B. Coughlin Barbara A. Coughlin PAC/201 Rule 27, Privacy and PacifiCorp August 10, 2017 B. Coughlin Security of Customer Data and Release of Customer Data PAC/202 Rule 28, Data Request PacifiCorp August 10, 2017 B. Coughlin and Release Process PAC/300 Direct Testimony of PacifiCorp August 10, 2017 M. Nottingham Melissa S. Nottingham PAC/301 Rule 17, Metering PacifiCorp August 10, 2017 M. Nottingham PAC/302 Schedule 300, Charges PacifiCorp August 10, 2017 M. Nottingham and Credits as Defined by the Rules and Regulations PAC/303 Estimated Opt-Out PacifiCorp August 10, 2017 M. Nottingham Cost and Estimated Monthly Meter Reading Cost PAC/400 Rebuttal Testimony of PacifiCorp April 20, 2018 M. Nottingham Melissa S. Nottingham PAC/401 PacifiCorp s Service Territory and Potential Opt-Out Customer Locations PacifiCorp April 20, 2018 M. Nottingham II. SUPPORT FOR MOVING THE TESTIMONY INTO THE RECORD OF THIS PROCEEDING Rule 13.8(c) provides in pertinent part that prepared testimony may be offered into evidence by written motion in the absence of an evidentiary hearing. Pursuant to the Scoping Memorandum and Ruling of the Assigned Commissioner dated March 29, 2018 (Ruling), evidentiary hearings were not held in this proceeding. 1 Accordingly, PacifiCorp s previously 1 The Ruling provides that no hearings will be held unless the parties jointly request them no later than April 27, Ruling, p. 4. The parties to A did not jointly request hearings

4 served prepared testimony, including both its direct and rebuttal testimony, should be admitted into evidence. Further, PacifiCorp and the Office of Ratepayer Advocates (ORA) are the only active parties in this proceeding, and neither party objects to the offering and receipt of the other party s prepared direct or rebuttal testimony. 2 The declaration of Cynthia Hansen Mifsud, attesting that the prepared testimony offered into evidence by this motion is true and correct, is included as Attachment A to this motion. The requirements of Rule 13.8(c) are satisfied. III. CONCLUSION PacifiCorp moves to admit its prepared direct and rebuttal testimony and supporting exhibits listed above into the record in lieu of submitting testimony under direct examination at a hearing. Respectfully submitted May 23, 2018, at San Francisco, California. Cynthia Hansen Mifsud 825 N.E. Multnomah St., Suite 1800 Portland, OR Telephone: (503) Facsimile: (503) cynthia.hansen@pacificorp.com By Cynthia Hansen Mifsud Attorney for PacifiCorp 2 As stated in Ms. Cynthia Mifsud s May 14, to Administrative Law Judge Karl Bemesderfer, PacifiCorp and ORA, whose legal counsel is copied on this message, have conferred, and neither party objects to the offering and receipt into evidence of the prepared testimony (including rebuttal testimony) of the other party. PacifiCorp notes that by motion dated May 18, 2018, ORA also has moved to admit its previously served prepared testimony, as well as its contemporaneously served corrected testimony, into the record of this proceeding

5 ATTACHMENT A DECLARATION OF CYNTHIA HANSEN MIFSUD IN SUPPORT OF MOTION OF (U 901 E) TO ADMIT INTO THE RECORD PREVIOUSLY SERVED DIRECT AND REBUTTAL TESTIMONY AND ACCOMPANYING EXHIBITS

6 DECLARATION OF CYNTHIA HANSEN MIFSUD IN SUPPORT OF MOTION OF (U 901 E) TO ADMIT INTO THE RECORD PREVIOUSLY SERVED DIRECT AND REBUTTAL TESTIMONY AND ACCOMPANYING EXHIBITS I, Cynthia Hansen Mifsud, state: 1. I am Assistant General Counsel for PacifiCorp. 2. On August 10, 2017, PacifiCorp submitted its Application for an Expedited Order Authorizing Special Charges and Tariffs for Smart Meter Opt- Out and Privacy/Data Release Programs Related to Advanced Metering Infrastructure Deployment (A ). 3. In support of its Application, PacifiCorp submitted prepared direct testimony of Michael Cochran, Melissa Nottingham, and Barb Coughlin, along with supporting exhibits, and rebuttal testimony of Melissa Nottingham, along with supporting exhibits. 4. PacifiCorp and the Office of Ratepayer Advocates are the only parties to this proceeding. 5. The California Public Utilities Commission did not hold an evidentiary hearing in this proceeding. 6. The prepared direct and rebuttal testimony and supporting exhibits listed in PacifiCorp s Motion to Admit Into the Record Previously Served Direct and Rebuttal Testimony and Accompanying Exhibits are true and correct. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 23 rd day of May, 2018, at Portland, Oregon. Cynthia Hansen Mifsud, Attorney for PacifiCorp

7 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA In the Matter of the Application of (U 901 E) for an Expedited Order Authorizing Special Charges and Tariffs for Smart Meter Opt- Out and Privacy/Data Release Programs Related to Advanced Metering Infrastructure Deployment. Application No (Filed August 10, 2017) CERTIFICATE OF SERVICE I hereby certify that I have this day served a copy of PacifiCorp s MOTION OF (U 901 E) TO ADMIT INTO THE RECORD PREVIOUSLY SERVED DIRECT AND REBUTTAL TESTIMONY AND ACCOMPANYING EXHIBITS on all known parties to A , by transmitting an message with the documents attached to each person on the official service list. (See the attached Service List A ) Executed on May 23, 2018, at Portland, Oregon. Katie Savarin Coordinator, Regulatory Operations 1

8 CPUC - Service Lists - A Page 1 of 2 5/23/2018 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: A FOR AN FILER: LIST NAME: LIST LAST CHANGED: APRIL 2, 2018 Download the Comma-delimited File About Comma-delimited Files Back to Service Lists Index Parties ROSANNE O'HARA CYNTHIA HANSEN MIFSUD SR. ATTORNEY LEGAL DIVISION ROOM NE MULTNOMAH ST., STE VAN NESS AVENUE PORTLAND, OR SAN FRANCISCO, CA FOR: FOR: ORA Information Only ONLY ONLY, CA ANDREW B. BROWN ATTORNEY ELLISON SCHNEIDER HARRIS & DONLAN LLP 2600 CAPITOL AVE., STE. 400 SACRAMENTO, CA JEDEDIAH J. GIBSON ANNE MARSH ATTORNEY 4628 PINE CONE DRIVE ELLISON SCHNEIDER HARRIS & DONLAN LLP ETNA, CA CAPITOL AVENUE, SUITE 400 SACRAMENTO, CA BETTY J. KREEGER VICKI GOLD 1020 KINGSTON RD, APT. 3-D 2102 TANAGER LANE MT. SHASTA, CA MT SHASTA, CA 96067

9 CPUC - Service Lists - A Page 2 of 2 5/23/2018 CATHIE ALLEN REGULATORY AFFAIRS MGR. 825 NE MULTNOMAH ST., STE 300 PORTLAND, OR State Service JASON HOUCK ENERGY ADVISOR CPUC - ENERGY ONLY ONLY, CA BRIAN GOLDMAN ENERGY SAFETY & INFRASTRUCTURE BRANCH AREA 505 VAN NESS AVENUE SAN FRANCISCO, CA FOR: ORA JOSE ALIAGA-CARO KARL BEMESDERFER INFRASTRUCTURE PLANNING AND PERMITTING B DIVISION OF ADMINISTRATIVE LAW JUDGES AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MINA BOTROS MITCHELL SHAPSON ELECTRIC SAFETY AND RELIABILITY BRANCH LEGAL DIVISION AREA ROOM VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: ORA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS