Control Number : Item Number : 262. Addendum StartPage : 0

Transcription

1 Control Number : Item Number : 262 Addendum StartPage : 0

2 SOAH DOCKET NO DOCKET NO APPLICATION OF SOUTHWESTERN PUBLIC SERVICE COMPANY FOR AUTHORITY TO CHANGE RATES AND TO RECONCILE FUEL AND PURCHASED POWER COSTS FOR THE PERIOD JANUARY 1, 2010 THROUGH JUNE 30, 2012 ^ PH 4: ^ r BEFORE THE STATE OFFICE OF ADMINISTRATIVE HEARINGS SOUTHWESTERN PUBLIC SERVICE COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO TEXAS INDUSTRIAL ENERGY CONSUMERS' _FIR REQUEST-FOR-IM (1RM A TTf1N_ QUESTION NO (Filename: SPSRespTIEC 1 st(supp2).doc; Total Pages: 11) 1. WRITTEN RESPONSES...2 II. INSPECTIONS...3 SUPPLEMENTAL RESPONSE...5 QUESTION NO. TIEC 1-27:...:... 5 CERTIFICATE OF SERVICE EXHIBITS ATTACHED: Exhibit SPS-TIEC 1-27(a)(SUPP2) (non-nativeformat)...7 Exhibit SPS-TIEC 1-27(b)V(SUPP2) (non-nativeformat) TIEC 1 (SUPP2)(CD)...10 Exhibit SPS-TIEC 1-27(b)V(SUPP2)(CONF) (non-nativeformat)...11 TIEC 1(SUPP2)(CD)(CONF)...11 PUC Docket No SOAH Docket No Southwestern Public Service Company's Second Supplemental Response to Texas Industrial Energy Consumers First Request for Information -1- ^^Y

3 SOAH DOCKET NO DOCKET NO APPLICATION OF SOUTHWESTERN PUBLIC SERVICE COMPANY FOR AUTHORITY TO CHANGE RATES AND TO RECONCILE FUEL AND PURCHASED POWER COSTS FOR THE PERIOD JANUARY 1, 2010 THROUGH JUNE 30, 2012 BEFORE THE STATE OFFICE OF ADMINISTRATIVE HEARINGS SOUTHWESTERN PUBLIC SERVICE COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO TEXAS INDUSTRIAL ENERGY CONSUMERS' SECOND nuest FOR TTn z vn QUESTION NO Southwestern Public Service Company ("SPS") files this second supplemental response to Texas Industrial Energy Consumers ("TIEC") First Request for Information, Question No WRITTEN RESPONSES SPS's written supplemental responses to TIEC's First Request for Information are attached and incorporated by reference. Each response is stated on or attached to a separate page on which the request has been restated. SPS's responses are made in the spirit of cooperation without waiving SPS's right to contest the admissibility of any of these matters at hearing. Pursuant to P.U.C. PROC. R (c)(2)(A), each response lists the preparer or person under whose direct supervision the response was prepared and any sponsoring witness. When SPS provides certain information sought by the request while objecting to the provision of other information, it does so without prejudice to its objection in the interests of narrowing discovery disputes pursuant to P.U.C. PROC. R (d)(5). Pursuant to P.U.C. PUC Docket No SOAHDocket No Southwestern Public Service Company's Second Supplemental Response to Texas Industrial Energy Consumers First Request for Information - 2-

4 PROC. R (c)(2)(F), SPS stipulates that its responses may be treated by all parties as if they were made under oath. II. INSPECTIONS If responsive documents are more than 100 pages but less than eight linear feet in length, the response will indicate that the attachment is VOLUMINOUS and, pursuant to P.U.C. PROC. R (h)(2), the attachment will be provided on CD and made available for inspection at SPS's voluminous room at 401 Congress Avenue, Suite 2100, Austin, Texas 78701; telephone number (512) In addition, SPS will provide voluminous exhibits to all parties on CD. If a response or the responsive documents are provided pursuant to the protective order in this docket, the response will indicate that it or the attachment is either CONFIDENTIAL or HIGHLY SENSITIVE as appropriate under the protective order. Highly sensitive responses will be made available for inspection at SPS's voluminous room, unless they form a part of a response that exceeds eight linear feet in length; then they will be available at their usual repository in accordance with the following paragraph. Please call in advance for an appointment to ensure that there is sufficient space to accommodate your inspection. If responsive documents exceed eight linear feet in length, the response will indicate that the attachment is subject to the FREIGHT CAR DOCTRINE, and, pursuant to P.U.C. PROC. R (h)(3), the attachment will be available for inspection at its usual repository, SPS's offices in Amarillo, Texas, unless otherwise indicated. SPS requests that parties wishing to inspect this material provide at least 48-hours notice of their intent by contacting Ron Moss of Winstead, P.C., 401 Congress Avenue, Suite 2100, Austin, Texas 78701; PUC Docket No SOAH Docket No Southwestern Public Service Company's Second Supplemental Response to Texas Industrial Energy Consumers First Request for Information - 3-

5 telephone number (512) ; facsimile transmission number (512) ; address Inspections will be scheduled to accommodate all requests with as little inconvenience to the requesting party and to SPS's operations as possible. Respectfully submitted, XCEL ENERGY SERVICES INC. Stephen Fogel State Bar No Matthew P. Loftus State Bar No Congress Avenue, Suite 1650 Austin, Texas Office: (512) Facsimile: (512) WINSTEAD P.C. Ron H. Moss State Bar No Congress Avenue, Suite 2100 Austin, Texas Office: (512) GRAVES, DOUGHERTY, HEARON & MOODY P.C. Thomas B. Hudson, Jr. State Bar No Congress Avenue, Suite 2200 Austin, Texas Office: (512) Facsimile: (512) COURTNEY, COUNTISS, BRIAN & BAILEY, LLP Amy M. Shelhamer State Bar No S. Tyler, Suite 1700 Amarillo, Texas Office: (806) Facsimile: (806) BY: ATTORNEYS FOR SOUTHWESTERN PUBLIC SERVICE COMPANY PUC Docket No SOAH Docket No Southwestern Public Service Company's Second Supplemental Response to Texas Industrial Energy Consumers First Request for Information - 4-

6 SUPPLEMENTAL RESPONSES QUESTION NO. TIEC 1-27: Please provide the information described in Rule 194.2(f), (g) of the Texas Rules of Civil Procedure. SUPPLEMENTAL RESPONSE 2: The following supplements SPS's prior responses: Please refer to Exhibit SPS-TIEC 1-27(a)(SUPP2), which is a Witness Document Index that indicates additional documents received by specific witnesses. Please refer to Exhibit SPS-TIEC 1-27(b)V(SUPP2), provided on the enclosed CD ("TIEC 1(SUPP2)(CD)"), and SPS-TIEC , - provided on -- tlie enc ose CD ("TIEC 1(SUPP2)(CD)(CONF)"), for documents described in TRCP 194.2(f)(4)(A) that have not previously been produced. SPS is still compiling the documents responsive to this request and will provide a further supplemental response. Preparer: Sponsor: Wesley Berger Alice K. Jackson PUC Docket N4 SOAHDocket No Southwestern Public Service Company's Second Supplemental Response to Texas Industrial Energy Consumers First Request for Information -5-

7 CERTIFICATE OF SERVICE I certify that on the 18th day of January 2013, a true and correct copy of the foregoing instrument was served on all parties of record by electronic service and by either hand delivery, Federal Express, regular first class mail, certified mail, or facsimile transmission. ea M. Stover '^ - PUC Docket No SOAH Docket No Southwestern Public Service Company's Second Supplemental Response to Texas Industrial Energy Consumers First Request for Information - 6-

8 Exhibit TIEC 1-27(a)(SUPP2) Witness Document Index The following document was made available to all witnesses who testified to affiliate charges: SPS-TIEC SPS-TIEC James L. Altman 2. Alan L. Bellinghausen SPS-TIEC SPS-TIEC SPS-TIEC SPS-TIEC SPS-TIEC Teresa I. Donnelly 4. Stan P. Dufault SPS-TIEC SPS-TIEC SPS-TIEC Jack S. Dybalski SPS-TIEC SPS-TIEC SPS-TIEC SPS-TIEC S. Michelle Edwards 7. Kurtis J. Haeger SPS-TIEC SPS-TIEC SPS-TIEC SPS-TIEC David C. Harkness I

9 9. Cathy J. Hart 10. Thomas A. Imbler 11. Gary N. Lakey SPS-TIEC Kim S. Locker 13. David A Low 14. Mark R. McCloskey SPS-TIEC SPS-TIEC Confidential SPS-TIEC SPS-TIEC Mark P. Moeller 16. Gary J. O'Hara SPS-TIEC SPS-TIEC Janet Schmidt-Petree 18. Amy L. Stitt SPS-TIEC a - SPS-TIEC f 19. Matt W. Watson t

10 20. Bennie F. Weeks SPS-TIEC SPS-TIEC 1-27 Confidential SPS-TIEC SPS-TIEC

11 Exhibit SPS-TIEC 1-27(b)V(SUPP2) ;,. ^. Iry_k 1 N:.. i;. f t t = -,i ti 10

12 Exhibit SPS-TIEC 1-27(b)V(SUPP2)(CONF) SOAH DOCKET NO PUCT DOCKET NO APPLICATION OF SOUTHWESTERN PUBLIC SERVICE COMPANY FOR AUTHORITY TO CHANGE RATES AND TO RECONCILE FUEL AND PURCHASED POWER COSTS FOR THE PERIOD JANUARY 1, 2010.,.rrn_u nn.tr F - 4 TIEC 1(SUPP2)(CONF)(CD) C-1 11