SN-03 DATA RESPONSE

Request No.: CR&YA/JC: 002

Witnesses:

Exhibit(s): SN-03-E- JC-01

Page(s): p.3, ln. 15 to p. 5, ln. 9

Request: Please provide any data, analysis, testimony, briefs, or
related documents regarding utility evaluations of whether the costs
that BPA assumed in May 2000 and June 2001 were over-optimistic.

Response: No data, analysis, testimony, briefs or related documents are
provided since this is not our testimony.

DATA RESPONSE -- CR-JC-002

SN-03 DATA RESPONSE

Request No.: CR&YA/JC: 003

Witnesses:

Exhibit(s): SN-03-E- JC-01

Page(s): p.3, ln. 15 to p. 5, ln. 9

Request: Please provide any data, analysis, testimony, briefs, or
related documents regarding utility evaluations of whether the
assumptions of the Comprehensive Review or Cost Review Panel were
over-optimistic.

Response: No data, analysis, testimony, briefs or related documents are
provided since this is not our testimony.

DATA RESPONSE -- CR-JC-003

SN-03 DATA RESPONSE

Request No.: CR&YA/JC: 004

Witnesses:

Exhibit(s): SN-03-E- JC-01

Page(s): p.3, ln. 15 to p. 5, ln. 9

Request: Please provide any data, analysis, testimony, briefs, or
related documents regarding the Comprehensive Review or Cost Review
Panel evaluation of the costs associated with complying with the FCRPS
Biological Opinion, the Council's Fish and Wildlife Program, or BPA's
tribal trust responsibilities.

Response: No data, analysis, testimony, briefs or related documents are
provided since this is not our testimony.

DATA RESPONSE -- CR-JC-004

SN-03 DATA RESPONSE

Request No.: CR&YA/JC: 005

Witnesses:

Exhibit(s): SN-03-E- JC-01

Page(s): p.3, ln. 15 to p. 5, ln. 9

Request: Please provide any data, analysis, testimony, briefs, or
related documents regarding utility evaluations of the reliability of
BPA cost assumptions.

Response: The Joint Customers relied on the results of BPA's Financial
Choices process for its recommendations in order to reduce the size of
the SN CRAC. Assuming that BPA had done the appropriate analyses for
these cost categories, we performed no independent analysis, or studies.

DATA RESPONSE -- CR-JC-005

SN-03 DATA RESPONSE

Request No.: CR&YA/JC: 006

Witnesses:

Exhibit(s): SN-03-E- JC-01

Page(s): p. 8, ln. 14

Request: Please provide any data, analysis, or related documents
regarding whether the 2001 actual spending was adequate to implement the
FCRPS biological opinions and the Council's Fish and Wildlife Program.

Response: No data, analysis, testimony, briefs or related documents are
provided since this is not our testimony.

DATA RESPONSE -- CR-JC-006

SN-03 DATA RESPONSE

Request No.: CR&YA/JC: 007

Witnesses:

Exhibit(s): SN-03-E- JC-01

Page(s): p. 13, ln. 14-16

Request: Please provide any data, analysis, or related documents
regarding the specific fish and wildlife functions that are reduced in
the \$80 million cited. We would also appreciate any information
regarding whether reduction of these functions are consistent with the
FCRPS biological opinions, the Council's fish and wildlife program, or
other BPA obligations.

Response: The Joint Customers relied on the results of BPA's Financial
Choices process for its recommendations in order to reduce the size of
the SN CRAC. Assuming that BPA had done the appropriate analyses for
these cost categories, we performed no independent analysis, or studies.

DATA RESPONSE -- CR-JC-007

SN-03 DATA RESPONSE

Request No.: CR&YA/JC: 008

Witnesses:

Exhibit(s): SN-03-E- JC-01

Page(s): p. 13, ln. 19-22

Request: Please provide any data, analysis, or related documents
regarding the uncertainties associated with the cost reductions that you
recommend.

Response: The Joint Customers relied on the results of BPA's Financial
Choices process for its recommendations in order to reduce the size of
the SN CRAC. Assuming that BPA had done the appropriate analyses for
these cost categories, we performed no independent analysis, or studies.

DATA RESPONSE -- CR-JC-008

SN-03 DATA RESPONSE

Request No.: CR&YA/JC: 009

Witnesses:

Exhibit(s): SN-03-E- JC-01

Page(s): p.17, ln. 18

Request: In the summary of findings, we did not see a discussion of the
uncertainties that the Joint Customers considered in its analysis.
Please provide any data, analysis, or related documents regarding the
uncertainties you considered, including the potential for added costs
associated with recovery plans, subbasin plans, Clean Water Act
compliance, litigation, FCRPS Biological Opinion check-ins, and
uncertainties associated with load, natural gas volatility, secondary
revenue, the west coast power market, and the costs of ENW, the Corps of
Engineers, and the Bureau of Reclamation.

Response: The Joint Customers relied on the results of BPA's Financial
Choices process for its recommendations in order to reduce the size of
the SN CRAC. Assuming that BPA had done the appropriate analyses for
these cost categories, we performed no independent analysis, or studies.

DATA RESPONSE -- CR-JC-009