200310202nd Request of Staff to Idaho Power.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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UTILITIES COMMISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
KIMBALL PROPERTIES LIMITED
PARTNERSHIP, AND HEWLETT PACKARD CASE NO. IPC-00-
COMPANY,
COMPLAINANTS SECOND PRODUCTION
REQUEST OF THE
VS.COMMISSION STAFF
TO IDAHO POWER
IDAHO POWER COMPANY COMPANY
RESPONDENT.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information on or before FRIDAY,
OCTOBER 31 , 2003.
This Production Request is to be considered as continuing, and Idaho Power Company 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.
SECOND PRODUCTION REQUEST TO
IDAHO POWER OCTOBER 20, 2003
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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 who can sponsor the answer at hearing.
Request No. 12: Please provide historical demand readings for each of the three meter
accounts under which HPlKimball Properties buildings #26, #27, #28, and #29 are billed.
Include demand readings from their first billing through the most recent billing.
Request No. 13: Please provide copies of any written agreements or other written
documentation showing the date and size of the initial service request ofHPlKimball Properties.
Request No. 14: At what point in time (e., before construction, during construction or
after completion of construction of the Bethel Court substation) did Idaho Power realize that
none of the four HPlKimball Properties buildings would take service under Schedule 19 and
would instead take service as Schedule 9 primary customers? Please provide copies of all
Company documentation (correspondence, internal memos, etc.) regarding the service
requirements of Hewlett Packard and its change from a prospective Schedule 19 contract
customer to an actual Schedule 9 customer.
Request No. 15: Please quantify the portion of Schedule 9 primary s customers' demand
and/or energy charge that goes towards recovery of substation costs.
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DATED at Boise, Idaho, this dlJ day of October 2003.
~c;ru/~Scott oodbury
Deputy Attorney General
Technical Staff: Rick Sterling
sw: gd k/umisc/prdreql ipceOO 12 .swrps2
SECOND PRODUCTION REQUEST TO
IDAHO POWER OCTOBER 20, 2003
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF OCTOBER 2003
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-00-, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 1849
EAGLE ID 83616
LARRY D RIPLEY
SENIOR ATTORNEY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
BRIAN GRAHAM
HEWLETT P ARKARD COMPANY
11311 CHINDENBLVD
BOISE ID 83714
GREGORY W SAID, DIRECTOR
REVENUE REQUIREMENT
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
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SECRETARY
CERTIFICATE OF SERVICE