20060816ICIP to IPC 1.pdf

RECEIVED
2006 AUG 16 AM 8: 07m'€:~1Nr &: (I)!ATTORNEYS AT LAW
Peter Richardson IDAHO F'UBLiC
UTILITIES COIvHIJjSSIONTel: 208-938-7901 Fax: [phone]
p eter~ rich ardso na n d oleary. co m
O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, 10 83702
15 August 2006
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise 10 83720-0074
RE: Case No.lPC-O4-
Dear Ms. Jewell:
Enclosed please find three (3) copies of the FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY in the above case. The original request has been sent to
Idaho Power Company.
An extra copy is also enclosed to be stamped & returned to our office.
Sincerely,
Nina Curtis
Administrative Assistant
encl.
Peter 1. Richardson
Richardson & O'Leary
515 N. 2ih Street
O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(fYrichardsonando leary. com
Attorneys for the Industrial Customers of Idaho Power
RECEIVED
2006 AUG 16 AN 8:
IDAI.IO PUBLiC
UTILITiES COi'"iMISSION
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF FINANCIAL DISINCENTIVES TO
INVESTMENT IN ENERGY EFFICIENCY BY )IDAHO POWER COMPANY
CASE NO. IPC-04-
FIRST PRODUCTION REQUEST
OF INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities
Commission (the "Commission ), the Industrial Customers of Idaho 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 s copy in electronic format, if available.
- 1 -FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER
For each item, please indicate the name ofthe 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.
Please provide a copy of all correspondence and communications between Idaho
Power (including its employees and agents) and the Commission staff concerning this
proceeding, or matters at issue in this proceeding, that have occurred since the last
noticed workshop. If correspondence and communications occurred that were not in
writing, please provide a detailed description of all such communications and
correspondence. Also, please identify the place and date of each communication or
correspondence. Please consider this request to be continuing, and provide
supplementary responses if relevant communications or correspondence occur after the
date of this request.
DATED this 15th day of August 2006.
RICHARDSON & O'LEARY PLLC
- 2-FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th day of August, 2006, I caused a
true and correct copy of the foregoing FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER to be served by the method
indicated below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street (83702)
Post Office Box 83720
Boise, Idaho 83720-0074
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Barton L. Kline
Monica L. Moen
Idaho Power Company
1221 W. Idaho St. (83702)
PO Box 70
Boise, Idaho 83707
bkline~idahopower. com
mmoen(~jdahopower.com
( ) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(X) Electronic Mail
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities
Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
Scott. W oodburv~puc.idaho. gov
( ) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(X) Electronic Mail
William M. Eddie
Advocates for the West
1320 W. Franklin St. (83702)
PO Box 1612
Boise, ID 83701
beddi e(fYad v oc ates west. org
( ) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(X) Electronic Mail
Signed:Wb- CuJ\ \1\ \
Nina . Curtis
- 3 -FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER