200306302nd Request of ICIP to IPC.pdf

Peter J. Richardson
RICHARDSON & O'LEARY PLLC
99 East State Street
Eagle, Idaho 83616
Telephone: [phone]
Fax: [phone]
peter(fYri chardsonando 1 eary. com
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UTiL iES COr'1hISSION
Attorneys for Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO REVISE
ITS DEPRECIATION RATES FOR PLANT
IN SERVICE
SECOND PRODUCTION
REQUEST OF THE
INDUSTRIAL CUSTOMERS
OF IDAHO POWER TO IDAHO
POWER COMPANY
CASE NO. IPC-O3-
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission ), the Industrial Customers ofIdaho Power (ICIP) , by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho
Power ) provide the following documents.
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.
Please provide one copy of your answer to Mr. Richardson at the address noted above and
one copy to Dr. Reading at 6070 Hill Road, Boise, Idaho 83703. Please provide Dr. Reading
copy in electronic format, if available.
1 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER
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.
REQUEST FOR PRODUCTION NO.
For the purpose of this request No., please refer to the Response to Request No. 10
First Commission Staff Request and the Second Commission Staff Request, Response to Request
No. 18, and page 43 of378 (11-33) of J Spanos Exhibit No.1. Please provide the specific index or
indices published by the Department of Labor that leads to the conclusion "trended to the
probable retirement year based on 3 percent rate of inflation." Please include in your answer the
years used to find the 3 percent value for each index used in the estimation.
REQUEST FOR PRODUCTION NO.
For the purpose ofthis Request No., please refer to the Response to Request No., First
Commission Staff Request. Response No.9 states
, "
There have been a few other studies
conducted that produce similar results to support the 1993 study used in this - case." Please
provide a copy of each of those studies.
REQUEST FOR PRODUCTION NO.
For the purpose ofthis Request No., please refer to Attachment A of Response to
Request No., accounts 391.20 and 391.21. The referenced Attachment Column. 2 shows the
existing net salvage percent at 5 , Column 3 shows a proposed change at O. Should the value in
Column 4 be 5 rather than
REQUEST FOR PRODUCTION NO.
What is the current method of calculating depreciation for each of the accounts
recommended for amortization included in Response to Request No. 11 , First Commission Staff
2 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER
Request? If the recommended amortization method is different from the current method please
explain fully the reason for the change.
REQUEST FOR PRODUCTION NO.
For the purpose ofthis Request No., please refer to page 361 of378 (111-314) of J.
Spanos Exhibit No.1. Is the current remaining life for account 9 years for account 391.2 as
indicated by this Exhibit or 8 years as indicated by Response to Request No. 11 of First
Commission Staff Request? Please explain fully why a change to 5 years for account 391.2 is
recommended in this filing.
DATED this
~O -t;June 2003,
RICHARDSON & O'LEARY PLLC
By OJ d-fJ~Peter J. Richardson, ISB #3195
Attorneys for the Industrial Customers
of Idaho Power
3 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have, this 30th day of June, 2003, served the foregoing SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO
IDAHO POWER COMPANY as indicated below:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83720
[phone]
( )u.S. Mail, Postage Prepaid
(X)Hand Delivered
( )Overnight Mail
( )Facsimile
Barton L. Kline
Monica B. Moen
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
( ) u.S. Mail, Postage Prepaid
Hand Delived
( )
Overnight Mail
( )
Facsimile
John R. Gale
VP - Regulatory Affairs
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
( ) U.S. Mail, Postage Prepaid
txrHand Delivered
( ) Overnight Mail
( ) Facsimile
Sign
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Nina M. Curtis
CERTIFICATE OF SERVICE
Second Production Request of the Industrial Customers of Idaho Power to Idaho Power
Company