200401284th Request of Staff to Idaho Power.pdf

RECEIVED
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ILED
ITJ
LISA NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 5733
20011 Jp,N 28 AN 9:
;- , U!J Li
UTILITIES cor.lt'IISSION
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
AUTHORITY TO INCREASE ITS INTERIM
AND BASE RATES AND CHARGES FOR
ELECTRIC SERVICE.
CASE NO. IPC-03-
FOURTH 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
Lisa Nordstrom, Deputy Attorney General, requests that Idaho Power Company (Idaho Power;
Company) provide the following documents and information on or before FRIDAY,
FEBRUARY 13, 2004.
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.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name and telephone number of the person
FOURTH PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 28, 2004
preparing the documents. Please identify 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 if need
be.
Request No. 87: In Case No. IPC-01-, Order No. 28773, the order authorizing
Idaho Power to proceed with the construction of the Danskin plant, the Commission stated that
the information provided by Idaho Power was insufficient to determine the reasonableness of the
costs for Danskin. Please provide any information that the Company believes can permit the
Commission to judge the reasonableness of Dans kin costs.
Request No. 88: In Order No. 28773, the Commission also stated that Idaho Power
provided no comparison of alternatives to Danskin and that there is no record as to whether other
alternatives were also considered and rejected. Please list the costs of each alternative
considered and provide copies of any analysis performed to compare the costs. Please
demonstrate that Danskin was the least cost alternative.
'f.f.
2./3 day of January 2004.Dated at Boise, Idaho , this
~~~
Lisa Nordst mn
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc/prodreq/ipceO3.131nrps4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 28, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF JANUARY 2004
SERVED THE FOREGOING FOURTH 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
MONICA MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
PETER J RICHARDSON ESQ
RICHARDSON & O'LEARY
PO BOX 1849
EAGLE ID 83616
RANDALL C BUDGE
ERIC L OLSEN
RACINE OLSON NYE BUDGE BAILEY
CHARTERED
PO BOX 1391
POCATELLO ID 83204-1391
LAWRENCE A GOLLOMP
ASSISTANT GENERAL COUNSEL
UNITED STATES DEPARTMENT OF
ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
WILLIAM M EDDIE
ADVOCATES OF THE WEST
PO BOX 1612
BOISE ID 83701
JOHN R GALE
VICE PRESIDENT - REGULATORY
AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
DON READING
BEN JOHNSON ASSOCIATES
6070 HILL ROAD
BOISE ID 83703
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
DENNIS GOINS
POTOMAC MANAGEMENT GROUP
5801 WESTCHESTER ST
ALEXANDRIA VA 22310-1149
JEREMIAH J HEAL Y
UNITED WATER IDAHO INC
PO BOX 190420
BOISE ID 83719-0420
NANCY HIRSH
NW ENERGY COALITION
219 FIRST AVE SOUTH SUITE 100
SEATTLE WA 98104
CERTIFICATE OF SERVICE
CONLEY E WARD
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
DENNIS E PESEAU PH.
UTILITY RESOURCES INe.
SUITE 250
1500 LIBERTY STREET SE
SALEM OR 97302
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
MICHAEL KARP
147 APPALOOSA LANE
BELLINGHAM W A 98229
MICHAEL L KURTZ, ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E. SEVENTH ST SUITE 2110
CINCINNATI OH 45202
THOMAS M POWER
ECONOMICS DEPARTMENT
LIBERAL ARTS BLDG. 407
UNIVERSITY OF MONTANA
32 CAMPUS DR
MISSOULA MT 59812
In ~~
SECRETAR
CERTIFICATE OF SERVICE