Response to 27_28.DOC

Case No IPC-E-01-43
February 18, 2002

Staff Request No. 27: Please provide copies of any written reports or other documents from the past five years that discuss the partial shutdown or full closure of the Pocatello plant created by or for Astaris LLC, Astaris Idaho, Idaho LLC [sic] or FMC.
Response to Request No. 27: Astaris objects to this request because it is oppressive and unduly burdensome in calling for an extensive records search for and the production of voluminous documents. Without waiving its objection, Astaris has reached an agreement with counsel for Staff whereby Astaris will provide certain readily retrievable documents relative to full or partial shutdown or closure of the Pocatello facilities during the period immediately preceding, during or after the Letter Agreement. Public documents are attached hereto, and confidential documents are being furnished to Staff, depending on the nature of the confidential document, either under separate cover or for inspection without copying pursuant to protective agreement entered into by Astaris and Staff. See also Astaris Response Idaho Irrigation Pumpers Requests 1, 3, 5 and 7-9.

Case No IPC-E-01-43
February 18, 2002

Staff Request No. 28: Please provide copies of any written reports or documents created by or for Astaris LLC, Astaris Idaho LLC or FMC since 1997 discussing the Electric Service Agreement or the Letter Agreement Amendment to the Electric Service Agreement.
Response to Request No. 28: Astaris objects to this request because it is oppressive and unduly burdensome in calling for an extensive records search for and the production of voluminous documents. Without waiving its objection, Astaris has reached an agreement with counsel for Staff whereby Astaris will provide certain readily retrievable documents relative to the Letter Agreement negotiations with Idaho Power in early 2001. Public documents are attached hereto, and confidential documents are being furnished to Staff under separate cover pursuant to protective agreement entered into by Astaris and Staff.

CERTIFICATE OF SERVICE
I hereby certify that I have this 20th day of February 2002, served the foregoing RESPONSES TO DISCOVERY REQUESTS 27 & 28 OF THE STAFF TO ASTARIS, LLC. in Case No. IPC-E-01-43, by electronically filing a copy thereof, and by first-class mail postage prepaid, to the following:

LARRY D. RIPLEY
IDAHO POWER COMPANY
1221 W. IDAHO
BOISE, ID 83702-5627

e-mail: [e-mail]
BARTON L KLINE
IDAHO POWER COMPANY
1221 W. IDAHO
BOISE, ID 83702-5627

e-mail: [e-mail]
RICHARD PASQUIER
FMC CORPORATION
1735 MARKET ST
PHILADELPIA PA 19103

e-mail: [e-mail]
MIQUEL F UGARTE
ASTARIS LLC
622 EMERSON RD
PO BOX 411160
ST LOUIS MO 63141

e-mail: [e-mail]
PETER J. RICHARDSON
RICHARDSON & O’LEARY
PO BOX 1849
999 EAST STATE STREET
EAGLE ID 83616

e-mail: [e-mail]
RANDALL C. BUDGE
RACINE OLSON NYE ET AL
201 EAST CENTER ST A#2
POCATELLO, ID 83201-6339

e-mail: [e-mail]
JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 W. WASHINGTON
BOISE, ID 83702-5983

e-mail: [e-mail]
ANTHONY YANKEL
29814 LAKE RD.
BAY VILLAGE, OH 44140

e-mail: [e-mail]
JEAN JEWELL
IDAHO PUBLIC UTILITIES COMMISSION
472 W. WASHINGTON
BOISE, ID 83702-5983

e-mail: [e-mail]