200306122nd 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]
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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
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AN
ACCOUNTING ORDER AUTHORIZING
INCLUSION OF POWER SUPPLY EXPENSES
ASSOCIATED WITH THE PURCHASE,
PROFIT CAPACITY AND ENERGY FROM PPL )
MONT ANA, LLC IN THE POWER COST ADJUSTMENT.
CASE NO. IPC-03-
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STATT TO
IDAHO POWER COMPANY
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 (Idaho
Power; Company) provide the following documents and information on or before THURSDAY
JUNE 19, 2003.
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 IDAP A 31.01.01.228.
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.
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF JUNE 12 2003
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.
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.5: It has been reported in newspapers and trade publications that
Northwestern Corp., parent of Northwestern Energy may be considering a Chapter
II/Bankruptcy filing. Please provide a written explanation and any analysis made related to
contract risks and reliability associated with the transmission contracts required for the proposed
PPL Montana purchase agreement.
Respectfully submitted this / ~ 1't day of June 2003.
Technical Staff: Terri Carlock
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SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF JUNE 12, 2003
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS
TH DAY OF JUNE 2003
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-03-
BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
SENIOR ATTORNEY
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
JOHNP. PRESCOTT
VICE PRESIDENT - POWER SUPPLY
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
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SECRETARY
CERTIFICATE OF SERVICE