200401292nd Request of NW Energy Coalition to Idaho Power.pdf

William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise ID 83701
[phone]
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Express Mail:
1320 W. Franklin St.
Boise ID 83702
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- E-03-
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION
Intervenor NW Energy Coalition, by and through counsel, requests that Idaho Power
Company ("Idaho Power" or "Company ) provide the following information.
This Production Request is considered to be continuing, and the Company is requested to
provide, by way of supplementary responses, additional documents or information that it or any
person acting on its behalf may later obtain that will augment the infonnation or documents
produced.
In answering each request, please provide the name of the person(s) preparing the
answers , along with the title and function such individual holds with the Company and the
witness who can sponsor the answer at the hearing.
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION --
REQUEST NO. 11: Are costs associated with the preparation of the Annual
Reports (years 1995 through 2001) on the status of the Idaho Springsnail, Bliss Rapids
Snail, Utah Valvata, Banbury Springs Lanx, Snake River physa included in the
Company s calculation of revenue requirement? If such costs are included, please state
the amount.
REQUEST NO. 12: Are costs associated with Dr. Gary Finni's independent
review of the Annual Reports identified in Request No. 11 (above) included in the
Company s calculation of revenue requirement? If such costs are included, please state
the amount.
REQUEST NO. 13: Are costs associated with the preparation, filing, and
withdrawal of petitions to the US. Fish and Wildlife Service to de-list the Bliss Rapid
Snail and the Idaho Springsnail from the lists of "threatened" and "endangered" species
respectively, under the Endangered Species Act, 16 US.c. 9 1531 et seq.included inihe
Company s calculation of revenue requirement? If such costs are included, please state
the amount.
REQUEST NO. 14: Please state the amount of hydropower relicensing costs
(including any expected future costs for relicensing) included in the Company
calculation of revenue requirement associated with the fol1owing categories of activities:
(a) collaborative processes, (b) field surveys , consultants, and preparation of technical
reports, (c) application and environmental impact statement preparation, and (d)
li tigation.
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION -- 2
DATED this 29th day 0 f J anuf'
William M. Eddie
On behalf ofNW Energy Coalition
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION -- 3
CERTIFICATE OF SERVICE
I hereby certify that on this 29th day of January 2004, true and correct copies of
the foregoing SECOl"ID PRODUCTION REQUESTS OF N\V ENERGY COALITION
were delivered to the following persons via hand delivery (for Commission and Idaho
Power recipients) and US. Mail (for all others):
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Randall Budge
Eric Olsen
Racine, Olson, et al.
O. Box 1391
Pocatello, ill 83204-1391
Lisa Nordstrom
Weldon Stutzman
Deputy Attomey Generals
Idaho Public Utilities Commission
472 W.Washington
Boise, ID 83702
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Bmion Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Lawrence Gollomp
Assistant General Counsel
US. Dept. of Energy
1000 Independence Ave., SW
Washington, DC 20585
John R. Gale
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Dennis Goins
Potomac Management Group
5801 Westchester St.
Alexandria, VA 22310-1149
Peter Richardson
Richardson & O'Leary
O. Box 1849
Eagle, ID 83703
Dean Miller
McDevitt & Miller
O. Box 2564
Boise, ID 83701
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
Jeremiah Healy
United Water Idaho
O. Box 190420
Boise, ID 83719-0420
Conley Ward
Givens Pursley
O. Box 2720
Boise, ID 83701-2720
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION -- 4
Dennis Peseau
Utility Resources
1500 Liberty St, S.
Suite 250
Salem, OR 97302
Thomas Power
Economics Dept.
Liberal Arts Bldg. 407
University of Montana
Brad Purdy
2019 N. 1 ih St.
Boise, ID 83702
32 Campus Drive
Missoula, MT 59812
Michael Karp
147 Appaloosa Lane
Bellingham, W A 98229
Michael Kurtz
Kurt J. Boelm1
Boehm, Kmiz & Lowry
36 E. Seventh St., Suite 2110
Cincinnati, OH 45202
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION -- 5