200307032nd Request of Hewlett Packard to ID Power.pdf

Peter J. Richardson
RICHARDSON & O'LEARY PLLC
99 East State Street
Eagle, Idaho 83616
Telephone: [phone]
Fax: [phone]
peter(qjri chardsonando eary. com
Attorneys for Kimball Properties Limited Partnership
"'-
. L'l.:::. ~ i::..C2J
: ,- i, iL E ~J
2003 JUL -3 p~,~ i:
, '
" , l
' ;
, L. , i.J
UTIL i T ir::S COHt'1!SS I
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Kimball Properties Limited Partnership, and
Hewlett Packard Company,
Complainants
vs.
Idaho Power Company, an Idaho Corporation
CASE NO. IPC-00-
SECOND PRODUCTION
REQUEST OF HEWLETT-
PACKARD COMPANY TO
IDAHO POWER COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission ), Kimball Properties Limited Partnership and the Hewlett-Packard Company,
by and through their attorney of record, Peter J. Richardson, hereby requests that Idaho Power
Company ("Idaho Power ) provide the following documents and respond to the following
interrogatories.
This production request is to be considered as continuing, and Idaho Power is requested
to provide by way of supplementary responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along with
the job title of such person( s) and the witness at hearing who can sponsor the answer.
1 - SECOND PRODUCTION REQUEST OF HEWLETT-PACKARD TO IDAHO POWER
REQUEST FOR PRODUCTION NO.
For purposes of responding to this Request for Production No., please refer to Case No.
IPC-03-, Idaho Power Company s Response to Staffs Request for Production No. 19 at
Attachment 2, page 29. Please provide a copy of the "growth management plan" that is
referenced in the first full paragraph on that page.
REQUEST FOR PRODUCTION NO.1 0
For purposes of responding to this Request for Production No. 10, please refer to Case
No. IPC-03-, Idaho Power Company s Response to Staffs Request for Production No. 19 at
Attachment 2, page 21. Please provide documentation for the statement that "The need for the
substation is determined by load growth in the Treasure Valley, primarily in the Kuna area.
Please include in said documentation the location and identity of all customers within a seven
mile radius of the Kuna substation with a demand in excess of 1 000 kw in any single month.
Said information may be provided pursuant to an earlier confidentially arrangement with Idaho
Power regarding the Idaho Power s disclosure of the identity of Schedule 19 customers in the
Boise Valley.
REQUEST FOR PRODUCTION NO.
For purposes of responding to this Request for Production No. 11 , please refer to Case
No. IPC-03-, Idaho Power Company s Response to Staffs Request for Production No. 19 at
Attachment 2, page 21. Please provide documentation for the statement that "This 40-
MW/year increase has held steady in the past few years." In said documentation please identify
the source and location of the 40-50 MW/year growth.
2 - SECOND PRODUCTION REQUEST OF HEWLETT-PACKARD TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 12
Please provide copies of all documents, including notes, memoranda, correspondence and
studies, relating to the recent expansion ofthe Company s transmission and substation facilities
in the City of Jerome, Idaho. Include in said documentation all work orders and the sources
funds for said work orders.
REQUEST FOR PRODUCTION NO. 13:
Please identify the location of all property currently owned by Idaho Power Company for
the purpose oflocating future substations in the Boise Valley. For each parcel please indicate the
date of acquisition and provide any studies that supported each individual site s selection.
tj,DATED this ~dayofJu1y2003.
RICHARDSON & O'LEARY PLLC
By:
Peter J. Richardson, ISB #3195
Attorneys for Kimball Properties
Limited Partnership and Hewlett
Packard
3 - SECOND PRODUCTION REQUEST OF HEWLETT-PACKARD TO IDAHO POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have, this 3rdy of July, 2003 , served the foregoing SECOND
PRODUCTION REQUEST OF HEWLETT-PACKARD TO IDAHO POWER COMPANY
as indicated below:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83720
( )U.S. Mail, Postage Prepaid
()(')Hand Delivered
( )Overnight Mail
( )Facsimile
Gregory Said
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
( ) U.S. Mail, Postage Prepaid
()l) Hand Delived
( )
Overnight Mail
( ) Facsimile
Barton L. Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
( ) U.S. Mail, Postage Prepaid
G() Hand Delivered
( ) Overnight Mail
( )
Facsimile
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, Idaho 83720
( ) U.S. Mail, Postage Prepaid
C)() Hand Delivered
( ) Overnight Mail
( )
Facsimile
Signed: n~t-l "\). Cu.A dt)
Nina M. Curtis
CERTIFICATE OF SERVICE