20071204ICIP to IPC 12.pdf

Peter J. Richadson ISB # 3195
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandoleary .com
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zmn DEC -4 AN 8= 04
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-E-07-08
FIFTH 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 Utilties Commission
(the "Commission"), the Industrial Customers of Idaho Power (ICIP), by and though their
attorney of record, Peter J. Richardson, hereby requests that Idao 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 supplementar 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 Hil Road, Boise, Idaho 83703. Please provide Dr. Reading's
copy in electronic format, if available.
1 - FIFTH PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-E-07-08
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. 12:
Please describe in detail the efforts Idaho Power has made with respect to connecting
customer owned emergency generators to its electric distrbution system. Such description
should include copies of all correspondence with customers regarding the program as well as a
list of companies paricipating in the program and a list of companies who were approached
about the program.
DATED this 3rd day of December 2007.
RICHARDSON & O'LEARY PLLC
By: t.;r ~ ~
Peter J. Richardson, ISB #3195
Attorneys for the Industral Customers
of Idaho Power
2 - FIFTH PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-E-07-08
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of September, 2007, a tre and correct copy of
the foregoing FIFTH PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER was served by U.S. Mail, postage prepaid to:
Baron Kline
Lisa Nordstrom
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
Weldon Stutzman
Donovan Walker
Idaho Public Utilities Commission
PO Box 83720
Boise, Idaho 83720-0074
JohnR. Gale
Vice President, Regulatory Affairs
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
Eric Olsen
Racine, Olson, Nye, Budge
PO Box 1391
Pocatello, Idaho
Jean Jewell
Commission Secreta
Idaho Public Utilties Commission
472 West Washington Street
Boise, Idaho 83702
Anthony Yanel
298 i 4 Lake Road
Bay Vilage, OH 44140
Conley Ward
Givens Pursley LLP
PO Box 2720
Boise, Idaho 83701-2720
Michael Kurz
Boehm, Kurz & Lowr
36 E. Seventh Street, Ste. 1510
Cincinnati, OH 45202
Lot H. Cooke
United States DOE
1000 Independence Ave. SW
Washington, DC 20585
Dennis Peseau
Utilty Resources, Inc.
1500 Libert Street, Ste. 250
Salem, OR 97302
j;J ,lwP Rib Peter carson
Dale Swan
Exeter Associates
5565 Sterrett Place, Ste. 310
Columbia, MD 21044
3 - FIFTH PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-E-07-08