20070614ICIP to IPC 1-3.pdf

Peter J. Richardson
RICHARDSON & O'LEARY PLLC
515 N. 27 Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(fYrichardsonando leary. com
.. ..
\ Ii \2:C\
.. '
i~, '
,-- "\ ,,' ,
I' '
' \ \ "') ,
, I
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE STATE
OF IDAHO.
CASE NO. IPC-07-
FIRST PRODUCTION
REQUEST OF THE
INDUSTRIAL CUSTOMERS
OF IDAHO POWER TO IDAHO
POWER COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission ), the Industrial Customers ofIdaho 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
copy in electronic format, if available.
I - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-O7-
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.
Because Idaho Power s system is becoming increasingly capacity constrained why does
the cost of service study show a shift of relative costs to high load factor customers?
REQUEST FOR PRODUCTION NO.
Because residential and small commercial have similar load shapes why does the cost of
Service method selected by the Company (3CP/12CP) indicate a much higher increase for small
commercial (15.29%) than residential (1.27%)?
REQUEST FOR PRODUCTION NO.
The "base case" and "non-weighted cost of service study (Tatum Exhibit No. 57) filed in
this case is said to be the same as those filed in the last case (IPC-05-28), however reference
Brilz Exhibit No. 48 in that case which shows the cost of service increases being less for small
commercial than residential. What is the explanation for such a large difference?
DATED this 14th day of June 2006.
RICHARDSON & O'LEARY PLLC
By:dQ tJPeter J. Richardson, ISB #3195
Attorneys for the Industrial Customers
of Idaho Power
2 - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER- IPC-O7-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of June, 2007, a true and correct copy of the
foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER was served by U.S. Mail, postage prepaid to:
Barton Kline
Monica Moen
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
CW\~'s
Nina Curtis
Administrative Assistant
3 - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-O7-