20081014IPC to CAPAI 1-16.pdf

BARTON L. KLINE
Lead Counsel
1SIDA.~PO~
An IDACORP company
October 10, 2008
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-08-10
General Rate Case
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies each of Idaho Power
Company's Second Supplemental Response to the Sixth Production Request of the
Commission Staff, Idaho Power Company's Response to the Fourth Production ReqUest of
the Industrial Customers, Idaho Power Company's Response to Community Action
Partnership Association of Idaho's First Production Requests, and Idaho Power Company's
Response to the Seventh Production Request of the Commission Staff.
In addition, also enclosed are CDs containing the Company's responses to
production requests in which electronic/excel files were requested and also for ease of
production of the information. .
Upon receipt of this filing, i would appreciate it if you would return a stamped copy of
this letter for my file in the enclosed stamped, self-addressed envelope.ve~iO!
Barton L. Kline
Lead Counsel for Idaho Power Company
BLK:csb
Enclosures P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, 10 83702
BARTON L. KLINE, ISB #1526
LISA D. NORDSTROM, ISB #5733
DONOVAN E. WALKER, ISB #5921
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
bklineaRidahopower.com
InordstromaRidahopower.com
dwalkeraYidahopower.com
RECEIVED
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Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MAnER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND
CHARGES FOR ELECTRIC
SERVICE.
) CASE NO. IPC-E-08-10
)
) IDAHO POWER COMPANY'S
) RESPONSE TO COMMUNITY ACTION
) PARTNERSHIP ASSOCIATION OF
) IDAHO'S FIRST PRODUCTION
) REQUESTS TO IDAHO POWER
) COMPANY
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
response to Community Action Partnership Association of Idaho's First Production
Requests to Idaho Power Company dated September 26, 2008, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 1
In response to the First Production Requests of Community Action Partnership
Association of Idaho ("CAPAI"), Idaho Power assumes that CAPAI is referring to the
Weatherization Assistance for Qualified Customers ('WAQC") program by the
program's former name of Low-Income Weatherization ("LlWA") program.
REQUEST NO.1: Please provide the name and title of every Idaho Power agent
or employee who is involved with and/or works on the Company's Low-Income
Weatherization ("LlWA") program.
RESPONSE TO REQUEST NO.1: In response to Request No.1, below are the
following names and titles of the involved Idaho Power employees:
Cheryl Paoli, Special Needs Program Specialist
Celeste Becia, Energy Effciency Program Leader
Theresa Drake, Manager Customer Relations and Energy Effciency
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 2
REQUEST NO.2: For each employee or agent identified in response to the
preceding Request, please specific precisely what tasks and functions said agent or
employee performs with respect to LlWA and provide a hierarchy chart outlining levels
of authority and who reports to whom.
RESPONSE TO REQUEST NO.2: Cheryl Paoli, Special Needs Program
Specialist, provides oversight of program operations, contract development, invoice
payment, and auditing for contract compliance. Celeste Becia, Energy Effciency
Program Leader, provides general supervision of the Special Needs Program Specialist
and authorizes payment of invoices. Theresa Drake provides general supervision of
Celeste Becia, Energy Effciency Program Leader, and authorizes general operations
contracts.
Please see Idaho Power's response to Staffs Production Request No. 16 for the
Customer Relations and Energy Effciency departmental organizational chart specifying
the hierarchy of levels of authority and who reports to whom.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 3
REQUEST NO.3: For each agent or employee identified in response to the
preceding Requests, please specify how much of their daily work is exclusively related
to LlWA as opposed to any other function.
RESPONSE TO REQUEST NO.3: Cheryl Paoli is a full-time staff person at
Idaho Power. Cheryl's primary responsibility is to administer the Company's WAQC
program. Approximately 80 percent of her daily work is exclusively related to the
WAQC program as opposed to any other function. Since September 2006, Celeste
Becia has supervised Cheryl and she dedicates a de minims percent of time exclusively
related to the WAQC program. Theresa Drake supervises Celeste and she dedicates
an even smaller percent of her work time exclusively to the WAQC program.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 4
REQUEST NO.4: How many different positions are allocated within the LlWA
program?
RESPONSE TO REQUEST NO.4: See responses to Requests No.1, 2, and 3.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 5
REQUEST NO.5: Of all allocated positions within LlWA, how many are filled?
RESPONSE TO REQUEST NO.5: All positions within WAQC are currently
filled.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 6
REQUEST NO.6: Are there any weatherization measures eligible for LlWA
according to U.S. Department of Energy criteria but that Idaho Power refuses to fund?
If the answer is yes, please specify all such measures and explain why the utilty does
not fund them.
RESPONSE TO REQUEST NO.6: Under the WAQC program, Idaho Power
funds all weatherization measures that are eligible, according to U.S. Department of
Energy criteria.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 7
REQUEST NO.7: What is the source document that Idaho Power relies upon to
determine which weatherization measures are eligible for Company funding under the
low-income weatherization program?
RESPONSE TO REQUEST NO.7: Idaho Power relies on the Idaho State
Weathenzation Assistance Program Operations Manual (produced in response to
CAPAI Request No.8) to determine which weatherization measures are eligible for
Company funding under the low-income weatherization program.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 8
REQUEST NO.8: Please produce a copy of any source document identified in
response to the preceding Production Request.
RESPONSE TO REQUEST NO.8: An electronic copy of the Idaho State
Weathenzation Assistance Program Operations Manual is included on the enclosed CD.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 9
REQUEST NO.9: For each of the past ten years, please identify every year, if
any, that the Community Action Agencies ("CAP"s) who contract with Idaho Power for
LlWA fully exhausted the total annual amount of funding appropriated for their program?
RESPONSE TO REQUEST NO.9: Prior to 2004 and prior to the issuance of
Commission Order No. 29505, Idaho Power did not develop statistics identifying which
CAP agencies did or did not spend the funds they received annually from Idaho Power.
After 2004, the CAP agencies that contract with Idaho Power, as a group, have not fully
exhausted the total annual funding. Individually, some of the CAP agencies have
exhausted the total annual funding. In the years 2004-2007, the following Agencies
exhausted their funding:
2004 - EISSA (Eastern Idaho Special Services Agency, Inc.)
2005 - EICAP (Eastern Idaho Community Action Partnership)
2006 - EL-ADA (EI-Ada Community Action Agency, Inc)
2006 - SEICCA (Southeastern Idaho Community Action Agency)
2007 - SEICCA (Southeastern Idaho Community Action Agency)
As previously noted, prior to 2004 and the issuance of Commission Order No.
29505, Idaho Power stored its data and reported on it differently than after that date.
As a result, Idaho Power has not prepared the data requested for the period prior to
2004. If CAPAI desires to develop these statistics, Idaho Power can make the
underlying data in its possession available to CAPAI.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY -10
REQUEST NO. 10: In the case at hand, Idaho Power proposes increasing the
amount of usage subject to the first tier of residential rates for non-summer months. In
this regard, has the Company made any calculations of the average residential
customer's monthly usage.
RESPONSE TO REQUEST NO. 10: As stated on page 10 of Ms. Waites'
testimony, in Idaho, the average monthly residential customer energy use in 2007 was
1,065 kWh.
This response to this Request was prepared by Courtney Waites, Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 11
REQUEST NO. 11: Has Idaho Power made any calculations or conducted any
analyses of the amount and nature of low-income residential usage as opposed to non-
low-income residential usage? In answering this, please consider "nature" to include
any identifiable factor such as time of day use, time of year use, purpose of use (e.g.,
air conditioning versus hearing, etc.).
RESPONSE TO REQUEST NO. 11: Idaho Power has not made any calculation
or conducted any analyses of the amount and nature of low-income residential usage as
opposed to non-low-income residential usage, as the Company does not track the
income levels of our customers, nor does it have any data that supports the income
level of customers.
This response to this Request was prepared by Courtney Waites, Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 12
REQUEST NO. 12: If the Company has tracked low-income usage as
referenced in the immediately preceding Requests, please explain the criteria used to
define what constitutes a "low-income" customer.
RESPONSE TO REQUEST NO. 12: Please see response to Request No. 11.
This response to this Request was prepared by Courtney Waites, Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY -13
REQUEST NO. 13: In addition to low-income weatherization, please identify all
programs Idaho Power offers that it perceives to be of assistance to its low-income
customers in paying their electric bil and provide an explanation and itemization of the
nature and degree of assistance provided by any such program.
RESPONSE TO REQUEST NO. 13: Idaho Power does not directly offer
programs to its low-income customers to pay their electric bils. Please see Idaho
Power's responses to Requests Nos. 78 through 82 of the Staffs Fifth Production
Request for a complete description of Project Share and the Company's efforts in
assisting low-income customers. Idaho Power has started the Home Weatherization
Pilot program, which does not help low-income customers pay their bils, but may
reduce energy usage and thus reduce their bils. Please see Idaho Power's response to
Request No. 20 of Staffs Second Production Request for a complete description of this
pilot program.
Idaho Power also offers the Energy House Calls program, which does not require
any contribution from the participant and is available to customers who live in
manufactured homes heated by an electric furnace or heat pump. Once again, this
program does not specifically pay the participants' bils, but it does reduce their energy
usage.
The response to this Request was prepared under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 14
REQUEST NO. 14: Has the Company tracked its account arrearages over the
past five years and, if so, are there any discernible trends (e.g., arrearages are
increasing or decreasing). Specifically, please provide any and all calculations and/or
analyses the Company has performed with respect to month by month trends over the
past five years.
RESPONSE TO REQUEST NO. 14: Below are the percentages of service
locations that were more than 60 days past due each month and the percentages of
dollars that were more than 60 days past due each month from 2003 through August
2008. At the bottom of each chart is an average percentage for the year. The most
notable trend is the increase in delinquency seen year-to-date in 2008.
00 ervice oca ions +ays as ue
2003 2004 2005 2006 2007 2008
Jan 8.4%8.6%8.2%7.9%7.9%8.5%
Feb 7.7%7.5%7.6%7.7%7.0%8.1%
Mar 7.8%6.8%6.7%5.9%6.8%7.7%
Apr 6.0%7.0%6.3%5.8%6.6%6.8%
May 6.6%7.3%6.8%6.7%6.7%6.8%
Jun 7.4%7.2%6.3%6.5%6.6%7.6%
Jul 7.1%7.2%6.5%6.5%6.5%7.1%
Aug 6.5%6.1%6.6%6.3%6.1%6.8%
Sep 6.0%6.1%6.2%6.3%6.3%
Oct 6.5%6.7%6.8%6.4%6.4%
Nov 6.7%6.6%7.1%6.6%7.0%
Dec 7.9%8.0%7.8%7.6%7.9%
% fS L f 60 0 P tD
AVERAGE 7.0%7.1%6.9%6.7%6.8%7.4%
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY -15
00 o ars +ays ast ue
2003 2004 2005 2006 2007 2008
Jan 4.5%4.1%3.8%3.9%4.1%4.7%
Feb 5.4%4.1%4.7%5.1%4.4%5.8%
Mar 4.4%3.8%4.2%3.3%4.5%5.5%
Apr 3.0%3.9%3.5%3.1%4.6%5.0%
May 3.2%4.0%3.9%3.8%4.5%4.6%
Jun 3.9%3.1%3.1%3.0%2.6%4.9%
Jul 2.8%2.3%2.3%2.3%2.4%3.4%
Aug 2.3%2.0%2.3%2.2%1.4%2.8%
Sep 2.3%2.3%2.3%2.7%2.9%
Oct 2.5%2.8%3.3%3.0%3.6%
Nov 2.7%2.8%3.3%2.8%3.6%
Dec 3.2%3.1%3.0%3.1%3.6%
0/c fD II 60 D p D
AVERAGE 3.4%3.2%3.2%3.2%3.4%4.5%
This response to this Request was prepared by Maggie Brilz, Manager,
Customer Service, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 16
REQUEST NO. 15: Please provide the same information sought in Request No.
14 for disconnections due to non-payment and account write-offs including whether the
rate and frequency of these have increased and whether customers are trending toward
increasing untimeliness in paying their bils.
RESPONSE TO REQUEST NO. 15: Below is the percentage of service
locations disconnected due to non-payment, compared with the total number of active
service locations from January 2003 through August 2008. The percentage increase in
2008 reflects the trend in delinquency discussed above in response to Request No. 14.
°isconnec ions ue 0 on.aymen
2003 2004 2005 2006 2007 2008
Jan 0.46%0.22%0.24%0.26%0.23%0.25%
Feb 0.42%0.21%0.28%0.35%0.25%0.25%
Mar 0.64%0.55%0.72%0.47%0.57%0.50%
Apr 0.74%0.53%0.62%1.18%0.64%0.60%
May 0.58%0.45%0.50%1.31%0.58%0.48%
Jun 0.44%0.32%0.48%0.53%0.46%0.48%
Jul 0.35%0.23%0.22%0.34%0.33%0.44%
Aug 0.27%0.26%0.24%0.22%0.43%0.43%
Sep 0.32%0.25%0.19%0.22%0.39%
Oct 0.35%0.34%0.24%0.32%0.45%
Nov 0.31%0.27%0.26%0.14%0.35%
Dec 0.22%0.15%0.14%0.39%0.21%
Total 0.43%0.32%0.34%0.48%0.41%0.43%
0/c D.f d t N P t
Below is the monthly percentage of gross dollars written off, compared to gross
revenue. Again, the most significant trend is the increase year-to-date in 2008.
In 2003 and 2004, bad debt, resulting from irrigation service locations, was
written off in November. In 2005, these accounts were written off in July. In 2006,
2007, and 2008, these accounts were written off in May.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 17
% Gross Write-offs compared to Revenue
2003 2004 2005 2006 2007 2008
Jan 0.36%0.23%0.07%0.26%0.22%0.44%
Feb 0.26%0.35%0.14%0.35%0.03%0.39%
Mar 0.57%0.23%0.34%0.47%-0.39%0.54%
Apr 0.68%0.68%0.50%0.53%0.47%0.86%
May 1.02%0.79%0.18%1.23%0.71%1.01%
Jun 0.75%0.57%0.55%1.04%0.65%1.01%
Jul 0.65%1.00%0.56%0.47%0.20%0.58%
Aug 0.30%0.19%0.40%0.33%0.22%0.47%
Sep 0.28%0.20%0.22%0.26%0.18%
Oct 0.89%0.18%0.31%0.30%0.47%
Nov 2.29%1.72%0.33%0.32%0.43%
Dec 0.47%0.14%0.13%0.39%0.04%
Average 0.71%0.52%0.31%0.50%0.27%0.66%
This response to this Request was prepared by Maggie Brilz, Manager,
Customer Service, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY -18
REQUEST NO. 16: Has Idaho Power conducted in cost studies to determine
increases or changes in costs attributable to the non-recovery of bad debt,
disconnection and reconnection fees? Please provide the results of any such studies.
RESPONSE TO REQUEST NO. 16: Idaho Power routinely examines the net
bad-debt write-off, with perspective to each $1,000 of revenue biled. The chart below
shows monthly and annual averages of net bad-debt write-offs per $1,000 from January
2003 through August 2008. The net bad-debt write-off is comprised of gross write-off
amounts minus amounts collected on previously written-off bad debt.
January
February
March
April
May
June
July
August
September
October
November
December
Average
Net Loss per $1, 000 biled Revenue
2003 2004 2005 2006
$3.69 $2.12 $0.66 $2.57
$2.64 $3.45 $1.39 $1.84
$5.69 $2.29 $3.41 $3.46
$6.80 $6.84 $4.98 $5.28
$10.25 $7.86 $1.76 $14.21
$7.47 $5.68 $5.53 $10.39
$6.47 $10.05 $5.65 $4.69
$2.96 $1.91 $3.95 $3.26
$2.82 $1.93 $2.19 $2.63
$8.92 $1.81 $3.15 $3.04
$22.90 $17.19 $3.34 $3.23
$4.72 $1.38 $1.31 $1.20
$6.67 $5.07 $3.16 $4.59
2007
$2.21
$0.33
-$3.91
$4.74
$7.05
$6.46
$2.03
$2.24
$1.83
$4.75
$4.34
$0.36
$2.66
2008
$2.60
$1.80
$2.77
$3.65
$7.57
$8.33
$4.63
$2.10
$4.12
No recent studies have been performed to analyze disconnection and reconnet:tion
fees.
This response to this Request was prepared by Maggie Brilz, Manager,
Customer Service, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY -19
DATED at Boise, Idaho, this 10th day of October 2008.
L~lJ~A~
LISA D. NORDSTROM ~ (k/~
Attorney for Idaho Power Com~ny
BARTON L. KLINE
Attorney for Idaho Power Company
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 20
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of October 2008 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO
IDAHO POWER COMPANY upon the following named parties by the method indicated
below, and addressed to the following:
Commission Staff
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power
Peter J. Richardson, Esq.
RICHARDSON & O'LEARY PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates
6070 Hil Road
Boise, Idaho 83703
Idaho Irrigation Pumpers
Association, Inc.
Randall C. Budge
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391
201 East Center
Pocatello, Idaho 83204-1391
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IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 21
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Kroger Co. I Fred Meyer and Smiths
Michael L. Kurt
Kurt J. Boehm
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
The Kroger Co.
Attn: Corporate Energy Manager (G09)
1014 Vine Street
Cincinnati, Ohio 45202
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lake City, Utah 84111
Micron Technology
Conley Ward
Michael C. Creamer
GIVENS PURSLEY, LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Dennis E. Peseau, Ph.D.
Utilty Resources, Inc.
1500 Libert Street SE, Suite 250
Salem, Oregon 97302
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IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 22
Department of Energy
Lot R. Cooke
Arthur Perry Bruder
Offce of the General Counsel
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
Routing Symbol GC-76
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Dwight D. Etheridge
Exeter Associates, Inc.
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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Community Action Partnership
Association Of Idaho
Brad M. Purdy
Attorney at Law
2019 North 1th Street
Boise, Idaho 83702
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Snake River Allance
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
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cl~tJ.w~
Lisa D. Nordstrom~~(~
IDAHO POWER COMPANY'S RESPONSE TO COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 23