20070910ICIP to IPC 7-11.pdf

Peter J. Richardson ISB # 3195
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(fYrichardsonando leary. com
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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-
FOURTH 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 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
copy in electronic format, if available.
1 - FOURTH PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-O7-
For each item, please indicate the name of the 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.
Reference Keen page 9, line 1-7: the average amounts of power purchases and sales are
listed for the periods 1993-1996 and 1997-2006. Please provide the amount of power purchases
and sales for each year a1993 through 2006, broken down between CSPP and off system sales
and purchases.
REQUEST FOR PRODUCTION NO.
Reference Said: Exhibit 33 differs from Exhibit 32 due to the inclusion of expected and
actually PURP A projects an Horizon wind. Exhibit 33 does list Horizon wind as a generating
unit. How is Horizon wind included in Exhibit 33? Is it included under Purchase Power
(Excluding CSPP) Contract Energy?
REQUEST FOR PRODUCTION NO.
Reference Tatum: On page 51 of 115 , Exhibit 49, lines 386 through 395 , are the dollar
amounts for FERC accounts 555.1 and 555.2 along with the allocators PP-KW and PP-KWH.
Please identify the KWs and prices used to determine the dollar values and please identify the
KWhs and prices used to determine the dollar values.
REQUEST FOR PRODUCTION NO. 10.
Reference the same as No.9 above. Please provide in the same format as used in cases
IPC-03-13 and IPC-05-28 the (a) above dollar values (b) the KWs and prices used to
determine the dollar values and (c) the KWhs and prices used to determine the dollar values.
REQUEST FOR PRODUCTION NO.
2 - FOURTH PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-O7-
Please provide Idaho Power s answers to the following Staff Audit Requests: 21 , 33 , 45
, August 15 memo. Please also include the electronic versions ofC.
Schwendiman s Exhibit 20-
DATED this ih day of September 2007.
RICHARDSON & O'LEARY PLLC
By:
Peter 1. Richardson, ISB #3195
Attorneys for the Industrial Customers
of Idaho Power
3 - FOURTH PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-O7-
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of September, 2007, a true and correct copy of
the foregoing THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER was served by U.S. Mail, postage prepaid to:
Barton Kline
Lisa Nordstrom
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Weldon Stutzman
Donovan Walker
Idaho Public Utilities Commission
PO Box 83720
Boise, Idaho 83720-0074
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Eric Olsen
Racine, Olson, Nye, Budge
PO Box 1391
Pocatello, Idaho
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Conley Ward
Givens Pursley LLP
PO Box 2720
Boise, Idaho 83701-2720
Michael Kurtz
Boehm, Kurtz & Lowry
36 E. Seventh Street, Ste. 1510
Cincinnati, OH 45202
Lot H. Cooke
United States DOE
1000 Independence Ave. SW
Washington, DC 20585
Dennis Peseau
Utility Resources, Inc.
1500 Liberty Street, Ste. 250
Salem, OR 97302
41~
Dale Swan
Exeter Associates
5565 Sterrett Place, Ste. 310
Columbia, MD 21044
4 - FOURTH PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-O7-