COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION

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Lynette Cobb
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1 ~~~~~~~~ COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION RUULlC SERViiCE In the Matter of: APPLICATION OF LOUISVILLE GAS ) AND ELECTRIC COMPANY FOR AN ) dase NO ADJUSTMENT OF ITS ELECTRIC ) AND GAS BASE RATES ) DATA REQUESTS OF LOUISVILLE GAS AND ELECTRIC COMPANY TO THE DEPARTMENT OF DEFENSE AND OTHER FEDERAL EXECUTIVE AGENCIES Louisville Gas and Electric Company ( L,G&E ) respectfully submits the following data requests to the Departinelit of Defense and Other Federal Executive Agencies ( DOD/FEA ) to be answered by the date specified in the Kentucky Public Service Coiiiinission s ( Coiiiiiiissioii ) procedural schedule order herein. Instructions As used herein, Documents iiiclude all correspondence, ~nemoranda, notes, , maps, drawings, surveys or other written or recorded materials, whether external or internal, of every kind or description iii tlie possession of or accessible to the DODIFEA, its witiiesses or counsel. A. Please identify by name, title, position and responsibility the person or persoiis aiisweriiig each of these data requests for information. R. These requests shall be deemed continuing so as to require further and supplemental responses if the DOD/FEA receives or generates additional information within tlie scope of these requests betweeii the time of tlie response and tlie time of aiiy hearing conducted lierein.

2 C. To tlie extent that tlie specific documelit, work paper or information as requested does not exist, but a similar document, work paper or inforniatioii does exist, provide tlie similar document, work paper or infomation. D. To the extent that any request may be answered by way of a computer priiitout, spreadsheet or otlier form of electronic media, please identify each variable contained in tlie document or file which would not be self evident to a person not familiar with the docuiiient or lile. E. If tlie DOD/FEA has ob-jectioiis to aiiy request on the grounds that the requested information is proprietary in nature, or for any otlier reason, please notify the undersigned counsel for LG&E as soon as possible. F. For any document withheld on the ground of privilege, state tlie following: date; author; addressee; indicated or blind copies; all persons to whom distributed, shown or explained; ant the nature and legal basis for the privilege asserted. G. In tlie event any document requested has been destroyed or transferred beyond the control of tlie DOD/FEA or aiiy of its witnesses, state: the identity of the person by whom it was destroyed or transferred and the person authorizing the destruction or transfer; the time, place and iiietliod of destruction or transfer; and the reason(s) for its destruction or transfer. If destroyed or transferred by reason of a document retention policy, describe in detail the doctmient retention policy. H. If a docuiiieiit responsive to a request is a matter of public record, please produce a copy of tlie document rather than refer L,G&E to the record where the document is located. 2

3 Data Requests 1. To the extent not previously provided, please provide electronic copies (on CD) of all tables, charts, diagrams, schedules, and exhibits (collectively, Exhibits ) contained in tlie testimony of all witnesses for the DOD/FEA. Please iiiclude all workpapers, scliedules, uriderlyiiig coniputations aiid supporting docuineiitatioii used and relied upon by each witness in the preparation of liis or her testimony, including tlie preparation of all Exhibits. Please provide all electronic spreadsheets with cell formulas, cell references, macros and VRA code intact. 2. To the extent not previously provided, please provide copies of all schedules aiid underlying computations and workpapers developed in tlie analysis by tlie DOD/FEA and/or its witness(es) of LG&E s requested rate iiicrease in electronic spreadsheet format with all formulas intact. This request includes, but is not limited to, tlie analyses of the reveriue requirement components and computations, includi~ig all ratemaking adjustments to tlie historic data, and the cost of service model. Mr. Prisco 3. LG&E cannot uiiderstand Mr. Prisco s colicern with respect to its pro,forinn adjustinelit to operating expenses for injuries arid damages (page 15 of Mr. Prisco s testimony). Please restate Mr. Prisco s concern in greater detail.

4 Dated: May 6,201 0 Respectfully submitted, Kendrick R. Riggs W. Duncan Crosby 111 Monica Braun Stoll Keenon Ogden PLLC 2000 PNC Plaza 500 West Jefferson Street Louisville, Keiituclcy Telephone: (502) Robert M. Watt 111 Stoll Keenon Ogdeii PLLC 300 West Vine Street, Suite Lexington, Kentucky Allyson K. Sturgeon Senior Corporate Attorney E.ON 1J.S. LLC 220 West Main Street Louisville, Kentucky Telephone: (502) Counsel for Louisville Gas and Electric Company I I344 I I / I 4

5 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true aiid correct copy of the foregoing was served on the following persons 011 the 6th day of May, 2010, by United States mail, postage prepaid: Dennis G. Howard I1 Lawrence W. Cook Paul D. Adam Assistant Attorneys General Ofiice of the I<entucl<y Attorney General Office of Rate Interveiitioii 1024 Capital Center Drive, Suite 200 Fra~iltfort. KY Michael L. Kurtz David F. Boehni Boehm, Kurtz & Lowry 36 East Seventh Street, Suite Cincinnati, OH Frank F. Cliuppe Wyatt, Tarraiit & Combs, LLP 500 West Jefferson Street Suite 2800 Louisville, KY Robert A. Gantoii Regulatory Law Office U.S. Army Legal Services Agency 901 N. Stuart Street, Suite 525 Arlington, VA Matthew R. Malone William H. May, I1 Hurt, Crosbie & May PLLC The Equus Building 127 West Main Street Lexington, KY David C. Brown Stites & Harbison PLLC 400 West Market Street, Suite 1800 Louisville, KY Lisa I<illtelly Eileen Ordover L,egal Aid Society 416 W. Muha~iimad Ali Blvd., Suite 300 Louisville, KY Gardner F. Gillespie Dominic F. Perella Hogan & Hartsoii LLP 555 Thirteenth Street, N.W. Washington, DC Steven A. Edwards, Esq. Administrative Law Division Office of Staff Judge Advocate Third Avenue Room Fort Knox, KY Tom FitzGerald Liz D. Edrnoiidson Kentucky Resources Council, Inc. P.O. Box 1070 Frankfort, KY Counsel for Louisville Gas aiid Electric Compaii y

COMMONWEAL TH OF KENTUCKY ORDER. The matter is before the Commission upon a motion filed by Community Action

COMMONWEAL TH OF KENTUCKY ORDER. The matter is before the Commission upon a motion filed by Community Action COMMONWEAL TH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION In the Matter of: ELECTRONIC APPLICATION OF KENTUCKY UTILITIES COMPANY FOR AN ADJUSTMENT OF ITS ELECTRIC RATES CASE NO. 2018-00294 ORDER The