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Home My WebLink About20080826ICIP to IPC 36-44.pdfPeter Richardson ~r.Ql~"itATTORNEYS AT LAW Tel: 208-938-7901 Fax: 208-938-7904 peter(¡r ichardson andoleary. co m P.O. Box 7218 Boise, in 83707 - 515 N. 27th St. Boise, ID 83702 25 August 2008 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702 RE: IPC-E-08-10 Dear Ms. Jewell: We are enclosing an three copies of the THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, in the above case. The original has been served on Idaho Power Company. Sincerely, N~ì~-f.\ Richardson & O'Leary PLLC Peter 1. Richardson ISB # 3195 RICHARDSON & O'LEARY PLLC 515 N. 27th Street Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~richardsonandoleary .com Attorneys for the Industral 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 ELECTRC SERVICE. ) CASE NO.IPC..E-ØS-IO ) ) THIR PRODUCTION REQUEST OF ) THE INDUSTIAL CUSTOMERS OF ) IDAHO POWER ) Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commssion (the "Commission"), The Industrial Customers of Idaho Power ("ICIP") by and though their attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Company") provide the following documents. Ths production request is to be considered as continuing, and the Company 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 physical copy and one electronic copy, if available, of your answer to Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if unvailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idaho 83703, Tel: (208) 342-1700; Fax: (208) 384-1511; dreading~mindspring.com i - THIRD PRODUCTION REQUEST OF INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E-08-1 0 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 hearng who can sponsor the answer. Some of the following requests may include disclosures deemed by Idaho Power to be confdential. Idaho Power, along with all other paries to this case, are reminded that the Industrial Customers of Idaho Power have entered into and filed with the Commssion on July 16 and 23, 2008 the Protective Agreement in connection with ths case IPC-E-08-1O. REQUEST FOR PRODUCTION NO. 36: On pages 31 and 32 of Company witness Tim Tatu's workpapers is a table 'System Coincident Demand at Generation Level (kW), 2008 (5-year Median Factors), Idaho. Please provide, in electronic form, the data for each individual year for the 5 years that were used to find the values found in the table. REQUEST FOR PRODUCTION NO. 37: Please provide all input and supporting data, analysis, calculations, and any other materials used to produce the "Idaho Power Company Virtl Peaker Levelized Cost Analysis" submitted in response to ICIP's Production Request Number 10. REQUEST FOR PRODUCTION NO. 38: The Company's "Virtl Peaker Program Update" filed April 4, 2008 on page 2 states that the Company "talked with a tota of forty-five customers about the potential for a virt peaker prograi". Please identify each of these forty-five customers and provide a detaled account of the scope and content of these talks. REQUEST FOR PRODUCTION NO. 39: 2 - THIRD PRODUCTION REQUEST OF INUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E-08-1 0 The "Virtal Peaker Program Update" fied April 4, 2008 on page 2 states that twelve of the forty-five customers whom the company initially discussed the potential for a virt peaker program "expressed an interest in having more in-depth taks". Please identify these twelve customers and provide a detailed account of the scope and content of these "in-depth taks". REQUEST FOR PRODUCTION NO. 40: The "Viral Peaker Program Update" filed April 4, 2008 on page 2 discloses that thir thee of the fort five customers initially approached by Idaho Power declined to have "more In- depth talks" about the potential for a virt peaker program. Please provide a detaled account of the reasons given by these thrty thee customers who were not interested in fuer discussing the potential for a virtl peaker program. REQUEST FOR PRODUCTION NO. 41: The "Virtl Peaker Program Update" filed April 4, 2008 on page 2 states "the Company began its investigation into air quality and permitting issues by holding discussions with the Deparent of Environmenta Quaity (DEQ)". Please provide a detailed account of these discussions including the DEQ personnel spoken with, the scope and content of the matters discussed, and the dates and length of time for each discussion. REQUEST FOR PRODUCTION NO. 42: Please provide the research and documentation that supports the Company's conclusion on page 2 of the "Virtal Peaker Program Update" filed April 4, 2008: "that paricipation in the virtl peaker program would require customers with existing generators to modify their curent permits because they would no longer be using the generators exclusively for emergency puroses. To modify their permits, the Company's 3 - THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-08-1 0 research indicated customers would be required to submit an application along with an air quality analysis based on the total emissions on the customers' premises". REQUEST FOR PRODUCTION NO. 43: The "Virtl Peaker Program Update" filed April 4, 2008 states on page 2 ''te Company solicited input form the environmental communty". Please identify the specific members of the "environmental community" the Company discussed the virtal peaker program with, as well as, a detaled account of the scope and contents of these discussions. REQUEST FOR PRODUCTION NO. 44: The "Virual Peaker Program Update" filed April 4, 2008 concludes on page 3 that: "Environmental ramfications may exist if the program is implemented. It is because of these impacts that Idao Power believes the next logical step is to hold a workshop soliciting customer input regarding the implementation of a vir peaker program." Please explain how soliciting customer input regarding a virt peaker program will address the environmental ramifications identified by the DEQ and environmental community. ~~~,DATED this _ day of August, 2008. RICHASON & O'LEARY PLLC By:-fJÆ Peter J. Richardson, ISB #3195 Attorneys THE INDUSTRIL CUSTOMERS OF IDAHO POWER 4 - THIRD PRODUCTION REQUEST OF INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E-08-1 0 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 25th day of August, 2008, a tre and correct copy of the withn and foregoing THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, was served in the maner shown to: Ms. Jean Jewell Commssion Secreta Idao Public Utilties Commssion POBox83720 Boise, il 83720-0074 _ Hand Delivery -- U.S. Mail, postage pre-paid Facsimile Electronic Mail John R. Gale Vice President, Regulatory Affairs Idaho Power Company PO Box 70 Boise, Idaho 83707-0070 _ Hand Delivery X U.S. Mail, postage pre"paid Facsimile Electronic Mail Baron L. Kline Lisa D. Nordstrom Donovan E. Walker Idaho Power Company POBox 70 Boise, Idaho 83707-0070 _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile Electronic Mail Randall C. Budge Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Chrd. PO Box 1391 Pocatello, Idaho 83204-1391 ~ Hand Delivery .-U.S. Mail, postage pre-paid Facsimile Electronic Mail Anthony Yanel 29814 Lake Road Bay Vilage, Ohio 44140 _ Hand Delivery .-U.S. Mail, postage pre-paid Facsimile Electronic Mail Michael Kur, Esq. Kur J. Boehm, Esq. Boehm, Kur & Lowr 36 E Seventh St, Suite 1510 Cincinati OH 45202 _ Hand Delivery .-U.S. Mail, postage pre-paid Facsimile Electronic Mail Kevin Higgins Energy Strtegies, LLC Parkside Towers 215 S State Street, Suite 200 Salt Lake City UT 84111 _ Hand Delivery .-U.S. Mail, postage pre-paid Facsimile Electronic Mail BradMPurdy 2019 N 17th Street Boise ID 83702 _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile Electronic Mail LotH Cooke Arhur Perr Bruder United States Deparent of Energy 1000 Independence Ave., SW Washington DC 20585 _ Hand Delivery .-U.S. Mail, postage pre-paid Facsimile Electronic Mail Dwight Etheridge Exeter Associates Inc 5565 Sterrett Place Ste 310 ColumbiaMD 21044 _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile Electronic Mail Conley E Ward Michael C Creamer Givens Purley LLP PO Box 2720 Boise ID 83701-2720 _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile Electronic Mail Dennis E. Peseau, Ph.D. Utilty Resources Inc 1500 Libert Street SE Ste 250 Salem OR 97302 _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile Electronic Mail ~ÛU~\ Nina Curis