20250219ICIP 1-2 to IPC.pdf

RECEIVED
Wednesday, February 19, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
I Peter J. Richardson
515 N. 271" Street
2 Boise, Idaho 8702
3 (208) 9387901
[phone]
4 eter riclicirclsclonadams.com
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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8 IN THE MATTER OF IDAHO POWER CASE No.: IPC-E-24-45
9 COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
10 AND NECESSITY FOR TWO BATTERY FIRST PRODUCTION REQUEST OF THE
I I STORAGE FACILITIES INDUSTRIAL CUSTOMERS OF IDAHO
POWER TO IDAHO POWER COMPANY
12
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities
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14 Commission (the "Commission"), the Industrial Customers of Idaho Power by and through its
15 attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho
16 Power" or the "Company") provide responses to the following with supporting documents,
17
where applicable.
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19 This Production Request is to be considered as continuing, and Idaho Power is
20 requested to provide by way of supplementary responses additional documentation that it or any
21 person acting on its behalf may later obtain that will augment the responses or documents
22 previously produced.
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Please provide an additional electronic copy, or if unavailable, a physical copy, to
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Dr. Reading at; 280 S. Silverwood Way, Eagle, Idaho 83616 dreading minds ring.com .
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27 FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY
28 IPC-E-24-45
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I For each response, please indicate the name of the person(s)preparing the same
2 along with the job title of such person(s) and the name of the witness at hearing who can sponsor
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the answer.
4
5 REQUEST FOR PRODUCTION NO. 1:
6 Please provide copies of all communications between Idaho Power and the Idaho Public
7 Utilities Commission (including its Staff, consultants and/or Commissioners) regarding any
8 aspect of Idaho Power's Application, please include both the time period before the Application
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was filed and the time period after the Application was filed.
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11 REOEUST FOR PRODUCTION NO. 2:
12 Please provide copies of all responses to production requests in this matter(whether forma
13 or informal) provided to any Party or person (including the Idaho PUC Staff).
14 Dated this 19t" day of February 2025.
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16 2
Peter J. Richardson
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27 FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY
28 IPC-E-24-45
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1
I HEREBY CERTIFY that on the 191h day of February 2025, a true and correct copy of the
2 within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
3 CUSTOMERS OF IDAHO POWER TO IDAHO POWER in Docket No. IPC-E-24-45 was
served, pursuant to Commission Order No. 34602, by electronic copy only, to:
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Commission Secretary Tim Tatum
5 Idaho Public Utilities Commission Donovan E. Walker
6 PO Box 83720 Boise, ID 83720-0074
[e-mail] Idaho Power Company
7 Boise, Idaho 83702
Monica Barrios-Sanches ttatum(yidahopower.com
8 Commission Secretary dwalker e idahopower.com
9 Idaho Public Utilities Commission do_c_k_e_ts agi_da_h_opow_er.c_o_m__
monic_a.bariossanches a,puc.idaho.gov
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11 �
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By: Peter J. Richardson ISB # 3195
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27 FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY
28 IPC-E-24-45
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