20060925IPC to ICIP 54.pdf

--~~--~~--_..
IDAHO POWER COMPANY
P.O. BOX 70
BOISE, IDAHO B3707
RECE\\ td
l~Uo St.? 22 p\'\ 4: 56
\ D f~~)~U;
~;j
\~S \ 0 \\
UI \L\T It.;:,
101"
Monica B. Moen
Attorney II
An IDACORP Company
September 22, 2006
Jean D. Jewell , Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. IPC-06-
Idaho Power Company s Response to the Fourth Production Request
of the Industrial Customers of Idaho Power
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of Idaho Power
Company s Response to the Fourth Production Request of the 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 enclosed self-addressed stamped envelope.
Very truly yours
(6- 4th&-
Monica B. Moen
MBM:sh
Enclosures
Telephone [phone] Fax [phone], E-mail MMoen(g)idahopower.com
BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
RECEIVED
200G SEP 22 PM 4: 56
IDAHO FUGUQ ~,
UTILITIES COjlid'vH::;SIU\~1
Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVENIENCE)
AND NECESSITY FOR THE RATE BASING
OF THE EV ANDER ANDREWS POWERPLANT.
CASE NO. IPC-06-
IDAHO POWER COMPANY'S
RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company") and, in
response to the Fourth Production Request of the Industrial Customers of Idaho Power to
Idaho Power Company dated September 5, 2006 , herewith submits the following
information.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
Page
REQUEST FOR PRODUCTION NO. 54: Please provide a copy of all directive and
instructions from Idaho Power management to Idaho Power employees and agents during
the last ten years regarding the Company s Conservation and Demand-Side Management
programs and spending.
RESPONSE TO REQUEST FOR PRODUCTION NO. 54: Idaho Power objects to
the ICIP's Request for Production No. 54 on the basis that it is vague, ambiguous
imprecise and not properly defined or explained for purposes of the request. Idaho Power
further objects on the grounds that the request seeks information that is not relevant to the
subject matter of this case and on the grounds that the request is overly broad and unduly
burdensome.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 54:
Notwithstanding its objection to this request and without waiving its objection , in
response to this request , Idaho Power has attached hereto as "Response to Request for
Production No. 54 " the annual report concerning the Company s Conservation and
Demand Side Management programs for each of the years 1996 through 2006.
The response to this request was prepared by Monica Moen, Attorney II , Idaho
Power Company
DATED at Boise , Idaho , this 2ih day of September 2006.
(6.
MONICA B. MOEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
Page 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of September 2006, I served a true andcorrect copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TOTHE FOURTH PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO
POWER upon the following named parties by the method indicated below , and addressed to thefollowing:
Commission Staff ----.2L Hand Delivered
Donovan Walker US. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
472 W. Washington (83702)Email Donovan.walkerc:iYpuc.idaho.govO. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power Hand Delivered
Peter J. Richardson, Esq.----.2L u.S. Mail
Richardson & O'Leary Overnight Mail
515 N. 27th Street FAX
O. Box 7218 Email peter(g)richardsonandolearv.comBoise, Idaho 83702
Don Reading Hand DeliveredBen Johnson Associates u.S. Mail6070 Hill Road Overnight Mail
Boise, Idaho 83702 FAX
Email dreading c:iy mindspring.com
~(j3-
Monica B. Moen
CERTIFICATE OF SERVICE , Page
IDAHO POWER COMpANY
CASE NO. IPC-O6-
FOURTH PRODUCTION REQUEST
OF INDUSTRIAL CUSTOMERS
RESPONSE TO
REQUEST NO. 54
. -' -- .. '
Case No. \PC-O6-
Evander Andrews
d).
Fourth Production Request
of the \C\P