FirstProdRequest2102.doc

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, ID 83720-0074
Idaho Bar No. 5470
Tele: [phone]
FAX: [phone]

Street Address for Express Mail:

472 W Washington
Boise, ID 83702-5983

Attorney for the Idaho Public Utilities Commission

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE PETITION OF THE COMMISSION STAFF REQUESTING THAT THE COMMISSION INVESTIGATE THE BUY-BACK RATES IN THE LETTER AGREEMENT ENTERED INTO BY IDAHO POWER COMPANY AND ASTARIS LLC )
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) CASE NO. IPC-E-01-43

FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY

The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, John Hammond, Deputy Attorney General, requests that Idaho Power Company provide the following documents and information on or before Friday, February 8, 2002.
The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder. Reference IDAPA 31.01.01.228.
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.
Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
Each matter of which an admission is requested shall be separately set forth. The matter is admitted unless, within seven (7) days after service of the request the party to whom the request is directed serves upon the party requesting the admission a written answer or objection addressed to the matter. If objection is made the reasons therefore shall be specifically stated.
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. For all responses to the following requests, please provide all workpapers.

Request for Admission No. 1: Please admit that the Letter Agreement identified as Staff Exhibit No. 111 by its terms amends the Electric Service Agreement dated December 30, 1997, and identified as Staff Exhibit 109.

Interrogatory No. 1: In the event that the Company is unable to make an admission and response to Request for Admission No. 1, please state each and every reason why the Company is unable to make that admission.

Interrogatory No. 2: What is the justification for take-or-pay rates in the Astaris Electric Service Agreement?

Request for Admission No. 2: Please admit that the monthly flat product forward prices identified in column (D) in Staff Exhibit No. 103 are the prices provided by Idaho Power to Mr. Hessing in December 2001.

Request for Admission No. 3: Please admit that the methodology used to create the monthly buy back prices attached to the Astaris buy back contract (Staff Exhibit No. 111) is the same methodology and monthly forward market prices referenced in the testimony of Mr. Hessing and contained in his Exhibit 103, column (D).

Dated at Boise, Idaho, this lst day of February 2002.

John Hammond
Deputy Attorney General

O:Astaris_Discovery_02012002

CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF FEBRUARY 2002, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.  IPC-E-01-43, BY ELECTRONICALLY FILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:

LARRY D. RIPLEY
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
e-mail: [e-mail]
BARTON L KLINE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
e-mail: [e-mail]
ROBERT M POMEROY JR
THORVALD A NELSON
HOLLAND & HART LLP
8390 E CRESCENT PKWY, STE 400
GREENWOOD VILLAGE CO 80111
e-mail: [e-mail]
MIQUEL F UGARTE
ASTARIS LLC
622 EMERSON RD
PO BOX 411160
ST LOUIS MO 63141
e-mail: [e-mail]
RICHARD PASQUIER
FMC CORPORATION
1735 MARKET ST
PHILADELPIA PA 19103
e-mail: [e-mail]
RANDALL C. BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO, ID 83204-1391
e-mail: [e-mail]
PETER J. RICHARDSON
RICHARDSON & O’LEARY
PO BOX 1849
EAGLE ID 83616
e-mail: [e-mail]
ANTHONY YANKEL
29814 LAKE RD.
BAY VILLAGE, OH 44140
e-mail: [e-mail]

/S/
SECRETARY

FIRST PRODUCTION REQUEST OF
STAFF TO IDAHO POWER 1 FEBRUARY 1, 2002

CERTIFICATE OF SERVICE