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Home My WebLink About20080703ICIP to IPC 1-11.pdflI(c)li:B'~..iNr &:0~"l PW;ATTORNEYS AT LAW II: 21 Peter Richardson Tel: 208-938-7901 Fax: 208-938-7904 p eterli r ichardso n andoleary. co m P.O. Box n18 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702 3 July 2008 Ms. Jean Jewell Secretary Idaho Public Utilties Commission 472 W. Washington Boise, I D 83702 RE: IPC-E-08-13 Dear Ms. Jewell: We are enclosing an three copies of the FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, in the above case. The original has been served on Idaho Power Company. Sincerely, ~s(w~\ Richardson & O'Leary PLLC Peter J. Richardson ISB # 3195 RICHASON & O'LEARY PLLC 515 N. 27th Street Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~chardsonadoleary.com Attorneys for the Industrial Customers of Idaho Power 1\: 21 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FORAN ) ACCOUNTING ORDER AUTHORIZING ~ TH INCLUSION OF POWER SUPPLY) EXPENSES ASSOCIATED WITH THE ) PURCHASE OF CAPACITY AND ) ENERGY FROM PPL ENERGYPLUS, ) LLC IN THE POWER COST )ADJUSTMENT ~ ) CASE NO. IPC-E-08-13 FIRST PRODUCTION REQUEST OF THE INDUSTIAL CUSTOMERS OF IDAHO POWER Pursuat to Rule 225 of the Riles 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 Idaho Power Company ("Idaho Power") provide the followig documents. The Commission's Notice of Modified Procedure issued in ths case on June 25, 2008 set a deadline of Thursday, July 24,2008 for fillng comments or protests. In light of this deadline ICIP respectfly requests the Company to submit their responses to this request as soon as possible but in any event no later than Monday, July 14,2008. FIRST PRODUCTION REQUEST OF INTERVENORS - IPC-E-08-13 1 This 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 augent 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 unavailable, a physical copy to: Dr. Don Reading, 6070 Hil Road. Boise, Idaho 83703 Tel: (208) 342-1700 Fax: (208) 384-1511 dreading~mindspring.com For each item, please indicate the name and job title of the person(s) preparing the answers, along with the name, location and phone number of the reeord holder and, if different, the witness who can sponsor the answer at hearing if needed. Reference IDAPA 31.01.01.228. REQUEST FOR PRODUCTION NO.1: Please provide a copy of all materials, information, documents, or any other item, in both hardcopy and digital format, requested by the Commission Staff in the present case, No. !PC-E- 08-13. REQUEST FOR PRODUCTION NO.2: Please provide all workpapers, analysis, inputs, documents, and the natual gas forecasts used in developing the May 29, 2008 Operating Plan and the estimated operating costs of Idaho Power's gas fired combustion tubines as discussed on page 9, lines 7-12 of Mr. Bokencamp's direct testimony. FIRST PRODUCTION REQUEST OF INTERVENORS - IPC-E-08-13 2 REQUEST FOR PRODUCTION NO.3: Please provide all workpapers, analysis, inputs, and documents used to forecáSt the predicted peak-hour reductions attbutable to the A/C Cool Credit and Irgation Peak Rewards programs referred to on page 11, lines 8-16 of Mr. Bokenkamp's direct testimony. REQUEST FOR PRODUCTION NO.4: Please provide the kW and kWh savings andthe cost per kW and kWh attibutable to Idaho Power's A/C Cool Credit Program referred to on pages 10-11 of Mr. Bokenkamp's direct testimony. REQUEST FOR PRODUCTION NO.5: Please provide all workpapers, analysis, inputs, documents, and forcasts used in comparg the costs of the PP A with other available DSM options as discussed on page 10, line 7 though page 11, line 19 of Mr. Bokenkp's direct testimony. REQUEST FOR PRODUCTION NO.6: Please provide a copy of each anual DSM report to the Commission from 2003 through 2007 as referenced on page 10, lines 19-24 of Mr. Bokenkp's direct testimony. REQUEST FOR PRODUCTION NO.7: Please provide a detaled accounting of the effect to Idaho Power's Power Cost Adjustment by the addition of the costs incured by the PP A. REQUEST FOR PRODUCTION NO.8: Please provide all workpapers, analysis, inputs, and documents used to determine that the PPA costs are competitive and favorable to alternative resource options as discussed on page 7, lines 2-4 of Mr. Bokenkamp's direct testimony. FIRst PRODUCTION REQUEST OF INTERVENORS - IPC-E-08-13 3 REQUEST FOR PRODUCTION NO.9: Please provide an explanation that reconciles this PPA with Idaho Power's curent IRP. REQUEST FOR PRODUCTION NO.1 0: Please identify the location of this new resource represented by the PP A in Idaho Power's transmission queue. REQUEST FOR PRODUCTION NO. 11: Please describe the how this new resource will be delivered to Idaho Power's load center under the terms of the settlement agreement in Docket No. IPC-E-06-21. r!/ DATED this 6 tl day of July 2008. RICHARSON & O'LEARY PLLC BY:ptl~ Attorneys for the Industrial Customers of Idaho Power ". FIRST PRODUCTION REQUEST OF INTERVENORS ~ IPC-E-08-13 4 . .. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 3rd day of Ju1y, 2008, a tre and correct copy of the within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, was served in the maner shown to: Ms. Jean Jewell Commssion Secreta Idao Public Utilities Commssion POBox 83720 Boise il 83720-0074 2L Hand Delivery _ U.S. Mail, postage pre-paid Facsimile Electronic Mail John R. Gale Vice President, Regu1atory Affairs Idaho Power Company POBox 70 Boise, Idaho 83707-0070 .- Hand Delivery _ U.S. Mail, postage pre-paid Facsimile Electronic Mail Baron 1. Kline Senior Reguatory Attorney Idaho Power Company PO Box 70 Boise, Idao 83707-0070 .- Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail ~UA~~ Admnistrative Assistant Intervention ~ IPC-E-08- I3 1