20060829IPC to ICIP 1.pdf

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An IDACORP Company
IDAHO POWER COMPANY
O. BOX 70
BOISE, IDAHO 83707
BARTON L. KLINE
Senior Attorney
August 29 2006
HAND DELIVERED
Re:
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Case No. IPC-04-15
In the Matter of the Investigation of Financiallncentiv~-s to Go.)
Investment in Energy Efficiency by Idaho Power Company
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise , Idaho 83720-0074
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of Idaho Power
Company s Response to First Production Request of Industrial Customers of Idaho Power
regarding the above-referenced matter.
I would appreciate it if you would return a stamped copy of this transmittal letter
to me in the self-addressed , stamped envelope enclosed.
Barton L. Kline
BLK:sh
Enclosures
Telephone [phone] Fax [phone] E-mail BKline(g)idahopower.com
BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB # 5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Phone: [phone]
FAX: [phone]
bkline (QJ idahopower.com
mmoen (QJ idahopower.com
RECEIVED
2006 AUG
29 PM 3:
1D~~to PUB! UTiLlTlt~ COMMISSION
Attorneys for Idaho Power Company
Express Mail Address
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF FINANCIAL INCENTIVES TO
INVESTMENT IN ENERGY EFFICIENCY BY
IDAHO POWER COMPANY
) CASE NO. IPC-04-
IDAHO POWER COMPANY'
RESPONSE TO FIRST
PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company ) and, in
response to the First Production Request of the Industrial Customers of Idaho Power to
Idaho Power Company dated August 15 , 2006, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER -
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.
RESPONSE TO REQUEST NO.1: Idaho Power objects to this request on the
grounds that it is vague , ambiguous and imprecise. Idaho Power further objects on the
grounds that the request seeks information not reasonably calculated to lead to the
discovery of admissible evidence and/or information that is not relevant to the subject
matter of this case. Idaho Power further objects to the extent the request as written is
overly broad, unduly burdensome , expensive and oppressive. Idaho Power further objects
to the extent that the request is open-ended as to the time period at issue.
An example of the ambiguity and over-breadth of this request is that it would cover
discussions in scheduled public workshops or settlement conferences which ICIP either
attended or had the opportunity to attend. It would also cover responses to discovery
requests propounded by Staff to Idaho Power which ICIP already receives as a matter of
course.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
The response to this request was prepared by Barton L. Kline, Senior Attorney,
Idaho Power Company.
.Lk
Respectfully submitted this day of August, 2006.
BART
~~-
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this e'f th day of August, 2006 , I served a true and
correct copy of the within and foregoing upon the following named parties by the
method indicated below, and addressed to the following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise , Idaho 83720-0074
) U.S. Mail , Postage Prepaid
(X) Hand Delivered
) Overnight Mail
) Facsimile
(X) Email Scott.woodbury(QJpuc.idaho.Qov
Peter J. Richardson
Richardson & O'Leary PLLC
515 N. 2ih Street
Boise , Idaho 83702
(X) U.S. Mail , Postage Prepaid
) Hand Delivered
) Overnight Mail
) Facsimile [phone]
(X) Email peter(QJ richardsonandoleary.com
William M. Eddie
Advocates for the West
O. Box 1612
Boise, Idaho 83701
(X) U.S. Mail , Postage Prepaid
) Hand Delivered
) Overnight Mail
) Facsimile
(X) Email billeddie (QJ rmci. net
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise , Idaho 83702
(X) U.S. Mail, Postage Prepaid
) Hand Delivered
) Overnight Mail
) Facsimile
(X) Email dreadinq (QJ mindsprinq.com
W/~
Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4