200310103rd Request of Kimball-HP to Idaho Power.pdf

Peter J. Richardson
RICHARDSON & O'LEARY PLLC
99 East State Street
Eagle, Idaho 83616
Telephone: [phone]
Fax: [phone]
peter~ri chardsonando I eary. com
Attorneys for Kimball Properties Limited Partnership
RECEIVED mFILED
2003 OCT J 0 FH3:51
iD):dW PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Kimball Properties Limited Partnership, and
Hewlett Packard Company,
Complainants
Ys.
Idaho Power Company, an Idaho Corporation
CASE NO. IPC-00-
THIRD PRODUCTION
REQUEST OF HEWLETT-
PACKARD COMPANY TO
IDAHO PO~R 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 - THRill PRODUCTION REQUEST OF HEWLETT -PACKARD TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 15
Please provide copies of all "Incoming Miscellaneous Cash Transmittal" fonDS received
by the Corporate Cashier from Schedule 19 customers over the last 13 years. In the alternative
pleasae provide records kept by the Corporate Cashier of the data/infonnation in the same
documents.
REQUEST FOR PRODUCTION NO. 16
Please provide copies of all "substation area studies" as referenced in the 10 Year
Transmission Plan on page 8 for the last 13 years.
REQUEST FOR PRODUCTION NO. 17
Please provide copies of all BCRT's RODs.
REQUEST FOR PRODUCTION NO. 18
Please provide copies of all documents prepared to plan, design and build the Covlerdale
to Bethel Court to Wye Conversion to 138 KV as shown on page 16 of the 10 Year Transmission
Plan.
REQUEST FOR PRODUCTION NO. 19:
Please provide copies of Idaho Power billing infonnation for HP's Building #25 located
on Bethel Court from 1993 to 2000.
REQUEST FOR PRODUCTION NO. 20.
Please provide copies of all documentation in your possession regarding the connection
ofHP's Building No. 25 to Idaho Power s system.
2 - THRlD PRODUCTION REQUEST OF HEWLETT -PACKARD TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 21
Please provide copies of connected load infonnation utilized by or provided to Idaho
Power regarding load projections for HP's Buildings Nos. 26, 27, 28, and 29 located in the
Kimball Business Park.
REQUEST FOR PRODUCTION NO. 22
Please provide copies of all billing records for HP's Buildings Nos. 26, 27, 28, and 29 to
date.
. .
if/.
DATED this day of October 2003.
RICHARDSON & O'LEARY PLLC
B~
t! eter J. Richardson, ISB #3195
Attorneys for Kimball Properties
Limited Partnership and Hewlett
Packard
3 - THRID PRODUCTION REQUEST OF HEWLETT-PACKARD TO IDAHO POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of October, 2003 the within and foregoing
THIRD PRODUCTION REQUEST OF HEWLETT -PACKARD COMPANY TO IDAHO
POWER COMPANY was served on :
Bart Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707
by personal service to their corporate headquarters, and three copies were personally served on
Scott Woodbury
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Peter Richardson
CERTIFICATE OF SERVICE