20061002NEWC 11, 12 to IPC.pdf

Law Office of William M. Eddie
610 SW Alder St. Suite 910
Portland, OR 97205
Ph: 503-542-5245
Fax: [phone]
Cell: 208-484-7908
September 29 2006
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
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t:.)Please find enclosed for filing three (3) copies each of the SECOND PRODUCT~N 0
REQUESTS OF NW ENERGY COALITION and NWEC'S RESPONSE TO FIRST
PRODUCTION REQUEST OF IDAHO POWER COMPANY in the matter referenced
above. I have included a cover page of each document to be conformed and returned to
me.
Re: IPC-O6-
Dear Ms. Jewell:
William M. Eddie
iT!
William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
610 SW Alder St., Suite 910
Portland, OR 97205
Ph: [phone]
Fax: [phone]
bill (illeddi elawfirm. com
RECEIVED
200b OCT -2 AM 8: 31
IDAHO HJBUC
UTILITIES COMMISSIO!~
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR
MODIFICATION OF THE LOAD GROWTH
ADJUSTMENT FACTOR WITHIN THE POWER)
COST ADJUSTMENT (PCA) METHODOLOGY
CASE NO.IPC- E-06-
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION TO
IDAHO POWER COMPANY
Intervenor NW Energy Coalition, by and through counsel, requests that Idaho Power
Company ("Idaho Power" or "Company ) provide the following information as soon as possible
but no later than October 13, 2006.
These Production Requests are 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 information 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.
REQUEST NO. 11: Please provide actual--or in their absence, best
estimates--of the average fixed costs per customer that the Company incurs to serve new
customers for each of the three (3) most recent years that are available. Please break
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION --
down these costs by customer class for each class that would be affected by the PCA
mechanism at issue in this docket.
REQUEST NO. 12: Please provide the same information requested in the
previous question net of any line extension revenues. In calculating the line extension
revenues per customer per year, assume an appropriate amortization time period.
DA TED this 29th day of September, 2006.
W( -------
Willia ddie
On behalf ofNW Energy Coalition
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION -- 2
CERTIFICATE OF SERVICE
I hereby certify that on this 29TH day of September 2006, true and correct copies
of the foregoing SECOND PRODUCTION REQUESTS OF N~ ENERGY
COALITION were delivered to the following persons via U.S. Mail:
Jean Jewell (3 copies)
Idaho Public Utilities Commission
472 W. Washington St.
Boise , ID 83702
Barton Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise , ID 83702
Peter Richardson
Richardson & O'Leary
O. Box 1849
Eagle, ID 83703
Lawrence Gollomp
Assistant General Counsel
S. Dept. of Energy
1000 Independence Ave., SW
Washington, DC 20585
Dale Swan
Exeter Assoc., Inc.
5565 Sterret Place, Suite 310
Columbia, MD 21044
SECOND PRODUCTION REQUESTS OF NW ENERGY COALITION -- 3